Dublin Waste Plan Evaluation Report TABLE OF CONTENTS 1 INTRODUCTION ___ 1
9.1 WEEE ___ 35
LIST OF FIGURES - - LIST OF TABLES - - APPENDICES APPENDIX A Existing Plan Policy Objectives 12 Pages APPENDIX B Waste Legislative Requirements 3 Pages APPENDIX C Capacity Review 11 Pages MDR0927RP0001 i Rev F01


Dublin Waste Plan Evaluation Report MDR0927RP0001 1 Rev F01 1 INTRODUCTION Under the transposing regulations (S.I. 126 of 2011) of the Waste Framework Directive (2008/98/EC) there is a requirement on all local authorities to evaluate existing waste management plans by 31 December 2012 and, consequent to such an evaluation, to revise plans as appropriate. In compliance with this statutory requirement the Dublin Local Authorities1 have completed an evaluation of the Dublin Waste Plan2 (hereafter the Plan) which was published in November 2005. When issued the period of the Plan extended to five years.

The evaluation process commenced with the publication of a public notice by the Department of the Environment, Heritage and Local Government (DEHLG) in January 2012. The notice was taken out in a national newspaper on behalf of the waste regions.

The evaluation of the Plan provides an opportunity for Dublin Local Authorities to review the previous period assessing the rate of implementation of key policy objectives3 and progress towards the Plan targets. It is not only a backward looking exercise. The requirements of important European and National waste legislation and policy, which have come into effect since the publication of the previous Plan, need to be considered to ensure these are being taken account of. Lastly the evaluation needs to examine the implication for the environment if objectives and legislative requirements are not met.

The outcome of the evaluation is a decision by the local authorities to revise or replace the Plan, refer to Section 11 for the decision taken. The completed evaluation will inform the next stage of the Plan process. The Minister has signalled the intention to revise the arrangement of the existing waste regions and it is expected that Dublin will be part of a wider eastern region. A workshop was held in August 2012 which was attended by representatives of each of the local authorities and RPS. The aim of the workshop was to facilitate a round table discussion on the delivery of key objectives from the current Dublin Waste Plan.

The outcome of the workshop fed into the preparation of this evaluation document.

1 Dublin City Council (DCC) as Lead authority, Dun Laoghaire Rathdown County Council (DLRCC), Fingal County Council (FCC) and South Dublin County Council (SDCC). 2 Waste Management Plan for the Dublin Region 2005 to 2010 3 All of the policy objectives from the existing Waste Plan are saved in Appendix A. Over 120 objectives were contained in the original Plan. For the purpose of the evaluation key objectives under each heading have been identified and are included in a text boxes at the start of each Section of the report. It is recommended that the number of objectives is substantially reduced in the next generation of the Plan.


Dublin Waste Plan Evaluation Report 2 LEGISLATIVE DEVELOPMENTS As part of the evaluation it was necessary to examine the legislative requirements which have come into force since the publication of the Plan. The purpose is to assess if the existing objectives of the Plan meet the requirements of recent regulations. This will help inform the decision to revise or replace the existing objectives. 2.1 RECENT REGULATIONS A review of recent regulation has been completed and a non-exhaustive list of key statutory instruments is included in Appendix B. The waste regulations identified are deemed to be the most relevant in terms of the evaluation and the subsequent waste plan review process.

The key requirements of these regulations have been considered as part of the evaluation exercise and are documented where relevant in Sections 3 to 10 of this report.

2.2 NATIONAL WASTE POLICY Since the evaluation process commenced the Minister for the Environment, Heritage and Local Government published a new national waste policy statement. The document entitled, A Resource Opportunity, sets out a number of policy actions which are important in the context of the evaluation process including:
  • Hierarchy – the revised 5 step waste hierarchy is part of the policy with a commitment to increased prevention, reuse and recycling activities.
  • A move away from landfill – the virtual elimination of landfill is set as a long-term goal with the introduction of landfill bans a possibility to ensure landfill diversion targets are met. The landfill levy is due to increase to €75 by mid-2013.
  • Brown Bin Roll-Out – new regulations will be introduced to mandate the collection of source segregated organics from households. A phased rollout over 4 years is planned.
  • Significant reduction of Planning Regions – the number of waste regions will be reduced from from ten to three, allowing for greater efficiency in the delivery of waste plan objectives. The principles of proximity and self-sufficiency are to be implemented to ensure that the state develops the necessary waste recovery infrastructure.
  • Household Waste Collection – side by side collection in the household market will remain in the short term with the collection permit system strengthened to ensure the implementation of the waste hierarchy, better service levels and incentivised pricing structures. The Competition Authority will maintain an ongoing oversight of the household waste collection markets to ensure that it works well, with their next formal review scheduled in 2016.
  • New Collection Service Standards – this will be introduced for the collection of household waste to ensure a minimum standard for the separate collection of residual waste, recyclables and organics. Charging structures will also be more transparent and consumers will be able to compare costs and switch operators at ease.
  • Placing responsibility on Householders to prove they use an authorised waste collection service or manage their waste in an environmentally acceptable manner. This will help combat illegal fly-tipping, littering and backyard burning of waste by a minority of households.
  • Compliance and Enforcement – a greater level of enforcement is required in the coming years at the household, commercial and industrial level with better use of resources across the different authorities. A team of Waste Enforcement Officers will be established for cases relating to serious criminal activity.

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Dublin Waste Plan Evaluation Report 3 OVERARCHING WASTE POLICY The Dublin Region’s overarching waste policy in the Plan sets out the framework to deliver integrated solutions and a sustainable waste management system. The policy statement is ambitious and aims to adhere to the principles of the EU Waste hierarchy and to deliver the Plan targets. The policy statement supports an environment where all citizens are entitled to equal and cost effective services as part of the best environmental performing system.

Selected overarching objectives are reproduced below and have been identified as being significant in terms of delivering the overall policy aim in the Dublin Plan: Policy Statement 1.

The integrated waste management approach will be applied to waste generated, implementing reuse, maximum recycling, recovery of energy from residual waste, and minimising landfill disposal where possible 2. It is a goal to create equity of access to waste management facilities and services across the Region 3. It is a goal to deliver a cost-effective and affordable system meeting the ‘polluter pays principle’ that meets high standards of environmental performance and all legislative obligations 4. The Dublin Region will aim to develop an integrated suite of waste management infrastructure, to enable waste generated in the Region to be treated in the Region as far as possible, in the interests of sustainability.

5. The private sector waste industry will be encouraged to provide waste management infrastructure and services. Policy on Self Reliance 6. The Dublin Region will aim to become self-reliant in terms of waste management infrastructure: waste generated in Dublin should be managed in Dublin as far as possible. Policy on Inter-Regional Waste Movement 7. The Dublin Local Authorities will be receptive to treating waste from other counties where it is in accordance with their Waste Management Plans, where the other counties express a requirement e.g. for biological or thermal treatment or landfill disposal, and where capacity can be made available or developed.

8. It is expected that there will continue to be a need to treat waste arising in Dublin in the counties of the GDA, in particular for materials such as C&D waste, Green Waste – which require access to greater land availability and remote sites - and in the short term municipal waste for disposal. 9. Where infrastructure deficits arise in the Dublin Region, facilities in other Regions with spare capacity should be employed until this deficit is corrected and if required in accordance with this Plan.

Policy on Cost Recovery 10. Increasing cost recovery for functions such as regulation and enforcement 11.

It is an objective that the full cost of collection, sorting and recycling of packaging waste - less the revenue from recyclables - will be recovered from producers of packaging materials as defined in the Waste Management (Packaging) Regulations 1997, as amended. 12. Benefiting from grant assistance from the Government’s Environment Fund for appropriate schemes or other grant assistance that may become available from national or EU sources. 13. Any company collecting household waste will be required to provide the full range of services outlined in this Plan – bring banks, dry-recyclables collection, organic waste collection (when introduced by Local Authorities), Recycling Centres and Bulky Waste collection – or alternatively to pay the costs for providing these services to the local authorities.

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Dublin Waste Plan Evaluation Report MDR0927RP0001 4 Rev F01 Directing Waste to Meet Plan Objectives 14. The Dublin Local Authorities will if necessary and/or appropriate for environmental reasons, direct that certain waste streams must be delivered to a certain tier in the waste hierarchy (e.g. reuse, recycling, biological treatment, energy recovery). This will be achieved by means of the Waste Collection Permit system or other appropriate regulatory or enforcement measures. Assessing Implementation: Overall Policy Statement The over-arching policy statement is a mission statement for the better management of waste for the citizens and businesses in Dublin.

The Dublin Local Authorities are the foremost stakeholder in waste management in Dublin. Throughout the Plan period the decisions and actions taken have been to deliver an integrated approach to waste management in line with the EU Waste hierarchy. The attempt has been made to be resource efficient, to deliver the best environmental service to society and minimise the risk from waste (and associated treatments) to human health and the environment. Integrated Waste Management Solutions Delivering integrated solutions which maximise prevention, recycling and recovery opportunities ahead of landfill has been a key objective for the authorities.

Prevention and reuse have been key action areas. National campaigns such as the Green Schools have grown substantial since 2005 with 401 flags awarded in Dublin by the end of 2010. Awareness, education and information are the pillars to growing waste prevention and the local authority EAOs, GBOs and GSOs have been active throughout the period guiding household, communities and business in this area. Reuse has been another prevention area which has been given attention. The local authorities have provided support during the Plan to community based reuse schemes. Separately the authorities have taken a lead role in developing community reuse and repair programmes under the Rediscovery Centre umbrella based in the Ballymun area (see Section 4 for more details).

Through the development of the online FreeTrade service, the Dublin Local Authorities made reuse convenient, accessible and valuable. The service has since become part of national policy and is now available to all citizens in the State though the www.FreeTradeIreland.ie website.

Maximum recycling has been a key ambition throughout the period. The local authorities have implemented the largest kerbside collection scheme in the State. All householders can avail of a 2-bin collection service with over 200,000 of these householders also having a separate collection for organic waste4 (refer to Section 5 for more details). This collection system was delivered by the authorities to householders prior to their exiting from the market between 2010 and 2012. In addition the network of recycling centres and bring banks maintained during the plan period have provided a means to recycle other waste materials.

Commercial waste has been managed in a similar manner by private collectors, refer to Section 6 and 7 for details, with conditions set down by local authorities in collection permits following the aim of the Plan.

The local authorities have attempted to deliver recycling treatment capacity for the region during the Plan. A Materials Recovery Facility for household waste was successfully delivered and is currently operational treating household waste primarily. The authorities attempted to deliver biowaste capacity under a PPP arrangement but the projects were cancelled for financial reasons. Private sector operators have built significant mechanical, transfer and processing capacity in the region for the treatment of municipal and construction and demolition wastes. The local authorities have generally supported the development of infrastructure in line with the Plan policy objectives.

A capacity review provided in Appendix C provides a summary of capacity expansion in the region over the period. 4 DCC, FCC and SDCC rolled out a separate collection system for organic waste prior to exiting the market. DLRCC did not rollout such a service prior to exiting the market.

Dublin Waste Plan Evaluation Report MDR0927RP0001 5 Rev F01 The local authorities recognise the value in delivering more efficient treatment of residual wastes with the aim to recover this stream instead of sending it to landfill. During the Plan the authorities have been actively trying to a key piece of waste treatment infrastructure, the Dublin Waste to Energy Facility, to move residual waste management up the hierarchy. The intention is to capture heat and generate electricity from Dublin’s residual waste and management residual waste in a more resource efficient manner. The development of this facility has not followed the original timeline and the delays have set the region back with over 610,000 tonnes of municipal waste sent for disposal to landfills in Dublin and outside of the region.

Section 10 on infrastructure provides a summary of the Region’s progress in delivering key piece of waste infrastructure.

Equity of Services It was an objective of the Waste Plan to deliver equitable waste management services to the citizens in the region. The local authorities considered themselves as having the primary role in delivering services to household and ensuring the necessary infrastructure was in place to deliver plan targets. The local authorities in Ireland do not own waste unless contracted to collect waste by a householder. This legal definition of waste ownership has led to an open and competitive market where public and private competitor competing next to each other.

In Dublin competition for the single dwelling household market changed in late 2006 when a private collector began offering services to households.

This led to the arrival of other operators. The Dublin Local Authorities decided to vary the waste management plan to safeguard the integrity of the plan and its policy objective. The Dublin Local Authorities identified potential environmental and social concerns which could arise from the long-term fracturing of the household collection market. This were documented and published 5 as part of the final variation. The variation inserted objectives into the Waste Plan stating that only the local authorities or representatives appointed on their behalf shall collect source separate household waste from single dwelling households.

The variation to the Plan was challenged by private sector collectors in the high court with the court issuing a decision to overturn the variation in December 2009. The local authorities have appealed the decision to the Supreme Court.

Cost Effective Waste Management During the Plan period the local authorities have supported the polluter pays principle with waste charges applicable to waste collected from householders and businesses. Private operators have operated similarly in the commercial market. The local authorities have applied an incentivised charging system affording the opportunity to householders to reduce their waste charges by recycling more and reducing residual waste. This approach has been effective and rewarding and needs to continue. The offering of ineffective flat charging systems needs to be tightly policed and removed.

Some operators are offering services which do not incentivise segregation and needs to be addressed through the collection permit system. Over the course of the Plan household waste charges in Dublin have compared favourably to costs elsewhere in other regions. Cost recovery by authorities was at 66% in 2004 but improved over the course of the Plan. Local authorities funded costly services such as street sweepings, waivers and waste clean ups as well as collection and treatment of wastes. The on-going costs of providing the collection and treatment service in an increasingly competitive market was one of the reasons why the local authorities in Dublin took the decision to exist the market.

Regulations and enforcement was financed during the period through central funding and grants, local authority rates and funding, authorisation fees and producer responsibility contributions. Funding in this area will become increasingly important as the local authorities take on an enhanced regulatory role. 5 Variation to the Waste Management Plan for the Dublin Region, Made on 3 rd March 2008

Dublin Waste Plan Evaluation Report Self-Reliance & InterRegional Movement of Waste The existing Plan aimed for Dublin to become a self-compliance region in terms of waste management infrastructure particularly for the management of household waste.

Self-reliance in the region has not been achieved due to a lack of particular infrastructure (e.g. soil and stone recovery sites), a failure to deliver identified capacities (e.g. biowaste and WTE capacity) and the open nature of the Irish waste market. The objectives in the Plan addressed these scenarios to a degree. However during the course of the Plan period the movement of waste across the Dublin Region boundary has become the norm. Final destination capacities such as landfills are located outside of the region and waste is moving to these end destinations daily. Similarly for recyclables the end destinations are located outside of the State and waste is exported abroad on a daily basis.

The municipal waste collection market in Dublin (and Ireland) has multiple waste operators competing against each other for waste (although competition is limited in certain parts of the county). For the duration of the period household waste was primarily managed by the local authorities and residual wastes were typically landfilled in the region. This has changed following the closure of the regional landfills and the exiting from the market by the authorities.

In the open market waste collected by a private operator is generally brought to facilities owned by the collector for treatment. There is substantial intermediate treatment capacity in Dublin for municipal and C&D wastes but final destinations, such as biowaste facilities, soil recovery sites, cement kilns and landfills are beyond the boundary of the region. Inter-regional movement is a daily occurrence in the Irish market and this is set to continue. The region is currently a net exporter of waste and relies on facilities outside of the region. This may change if the Dublin WtE facility becomes operational and offer a higher form of treatment to residual waste from outside of the region.

Enforcement The policy statement does not contain a specific enforcement objective which needs to be reviewed as increased regulation is earmarked for the sector with local authorities ensuring it is implemented. Enforcement has been a key part of the last Plan period. It a critical function carried out by the local authorities and Table 3-1 shows the level of enforcement activities carried out during the period. Local authority enforcement activities such as audits and inspections go across all waste streams and facilities and are an underlying theme in the plan. The enforcement resources have grown over the plan period and there is co-operation between the authorities on different issues.

Table 3.1 Local Authority Enforcement 2006 - 2010 Local Authority 2006 2007 2008 2009 2010 Waste Permit Facility Audits 85 68 91 150 117 No of Inspections carried out: TOTAL 2,049 3,345 2,772 3,444 2,515 No of Complaints 616 624 426 422 1,517 Recent Legislative Requirements: European Communities (Waste Directive) Regulations 2011 These regulations transposed the requirements of the EU Waste Framework Directive which is the foremost piece of waste legislation governing activities in all Member States. The Framework has brought into effect radical changes in the way wastes are to be managed.

Key changes which have come into force through the transposing regulations are as follows: MDR0927RP0001 6 Rev F01

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  • Waste Hierarchy – the EU waste management hierarchy which has been bedrock of Irish national and regional waste policy. The Framework Directive has revised the hierarchy and set out a priority order for the management of wastes – prevention, preparing for reuse, recycling, other recovery and disposal. The interpretation of recycling6 has changed as has the definition of recovery7 . The application of the hierarchy is to deliver the best environmental outcome. Departures from the hierarchy are permitted for waste streams and can only be justified through life cycle thinking.
  • Wider Considerations – the transposing regulations have adopted the requirements which require local authorities when carrying out their waste policy functions to take into account general environmental protection principles of precaution and sustainability, technical feasibility and economic viability, protection of resources as well as the overall environmental, human health, economic and social impacts.
  • Self Sufficiency and Proximity – the regulations require that an adequate network of disposal and mixed municipal waste recovery installations are developed in the State. The aim is to become self-sufficient in waste disposal and recovery of mixed municipal waste. The proximity principle is to be applied for the disposal recovery of mixed municipal wastes specifically.
  • Waste Recovery – the regulations have made it a duty on competent authorities, waste holders and producers to recover waste in keeping with the waste hierarchy. Under the regulations it is an offence not to recover wastes.
  • Collection and Recycling – separate collections are required where they are technically, environmentally and economically practical. The aim is to move towards a recycling society with 50% of household and commercial paper, metal, glass, plastics and cardboard to be recycled by 2020.

Environmental Considerations: The failure to deliver on the ambitious overarching policy will have implications for the environment which are documented in each of the waste stream sections (Sections 3- 9) and in the infrastructure section (Section 10) of this report.

Recommendation: The assessment shows that the local authorities have acted in line with over-arching policy statement of the Plan. The core policy statement remains true. Certain objectives need to be revised to reflect the legislative changes which have come into effect following the transposition of the Waste Framework Directive. This will take account of the revisions to the hierarchy, treatment definitions, and the principles of self-sufficiency and proximity.

The overarching targets which accompany the policy statement need to be reviewed and replaced with more measurable indicators to reflect the way household, commercial and construction and demolition waste is managed. Targets for municipal waste also need to be included. 6 Recycling is recycling means any recovery operation by which waste materials are reprocessed into products, materials or substances, whether for the original or other purposes, including the reprocessing of organic material and does not include— (i) energy recovery, and (ii) the reprocessing into materials that are to be used as fuels or for backfilling operations; 7 Recovery means any operation the principal result of which is waste serving a useful purpose by replacing other materials which would otherwise have been used to fulfil a particular function, or waste being prepared to fulfil that function, in the plant or in the wider economy.

Dublin Waste Plan Evaluation Report MDR0927RP0001 8 Rev F01 4 WASTE PREVENTION Waste prevention was a central objective of the Dublin Plan with the aim to promote and implement initiatives to prevent waste. The provision of adequate resources was prioritised and staff designated at the household, community and business levels. . Three areas were identified as key for waste prevention and needing additional resources and staff; environmental awareness, green business and green schools. The following prevention objectives were key to obtaining the overall policy aim in the Dublin Waste Management Plan: Waste Prevention and Minimisation 15.

The Dublin Region will continue to apply use-related charges for waste services in support of prevention, minimisation and recycling.

Local Authority Prevention and Awareness Staff 16. In addition to the current EAO each Local Authority employs (if it has not already done so) a Green Business Officer, and a Green Schools Officer. 17. The Regional Waste Steering Group will establish a mechanism for coordination of the activities of the Awareness Staff (EAO GBO and GSO) in each of the four Local Authorities to deliver a coherent strategy for the Region. Community and Voluntary Sector Involvement 18. The Dublin Region will work closely with National/EPA initiatives for waste prevention/minimisation 19. The Local Authorities will encourage community/voluntary groups to establish sustainable additional waste services or facilities (e.g.

small scale facilities for recycling, reuse/repair) they would like in their area and assist them to develop a strategy to provide it, for and with the members of their community.

Reuse and Repair 20. To develop a ‘resource recovery centre’ in the Region enabling reuse/ repair of household items. 21. To provide an online ‘virtual’ reuse centre through the Dublin Regional Website www.DublinWaste.ie to enable the public to reuse household goods. Assessing Implementation: Waste Prevention and Minimisation A key objective of the Plan was to implement a user based charging system to encourage waste minimisation and recycling. Household waste arisings have declined since 2006, with a decrease of 9% during the plan period as shown in Table 4.1.

Table 4-1 Waste Arisings in the Dublin Region 2006 – 2010 Local Authority 2006 (Tonnes) 2007 (Tonnes) 2008 (Tonnes) 2009 (Tonnes) 20108 (Tonnes) TOTAL 464,332 470,221 474,767 470,806 421,506 Waste per Household 1.1 1.12 1.12 1.01 0.80 Waste per Capita 0.41 0.41 0.40 0.39 0.33 Source: WMP for the Dublin Region - Annual Progress Report 2010 & 2011 8 .2011 CSO Population of Dublin Region = 1,270, 603 persons; Number of households = 529,312 households

Dublin Waste Plan Evaluation Report Waste charges existed in Dublin during the plan period. The charging systems across the region were not consistent as the local authorities implemented different pay-by-use schemes and pricing arrangements in their administrative areas. The systems in place during the Plan period: Table 4-22 Waste Arisings in the Dublin Region 2006 – 2010 Local Authority Charging System Details DCC Pay By Lift DCC charged householders according to the frequency of the waste presented for collection. The system also incorporated an annual standing charge.

DLRCC Pay By Weight DLRCC operated a system that charges householders depending on the weight of waste presented for collection.

The system also incorporates an annual standing charge and a charge per bin lift. FCC Bin Tags FCC and SDCC employed the tag-a-bag/tag-a-bin system. Under this system householders prepay for tags for either bags or bins and then also for the relevant type of waste. FCC expanded this system during the period to include a standing charge. SDCC The pay-by-use systems and charging mechanisms implemented by the Local Authorities financially and environmentally incentivised recycling and the diversion of material from the residual ‘black’ bin collection. These systems contributed to the increase in recycling experienced over the period and were a factor in reducing the quantity of residual waste produced.

The plan set a generation target of 1.25 tonnes per annum per household from 2006 onwards and this was achieved throughout the period.

Local Authority Prevention and Awareness Staff A central prevention objective of the plan was the provision of additional designated staff to work towards waste minimisation and the promotion of best waste management practices. A target was set to employ one Green Business Officer and a Green Schools Officer in addition to the EAO (Environmental Awareness Officer) already in place. Table 4-2 shows the dedicated local authority prevention and awareness staff for the period 2006 to 2010. In 2010 these targets had not been met across the region. An EAO has been appointed in each Local Authority since 2001.

The role of the EAO is increasingly important in the achievement of the plan objectives for the promotion of better waste management practices in the community. The Local Authorities had varying numbers of EAOs employed over the 5 year period, but this always fell within the range of 1 – 2 staff.

Table 4-3 Local Authority Prevention and Awareness Staff DCC DLRCC FCC SDCC Regional Total Regional Target Environmental Awareness Officer (EAO) 2006 2007 2008 2009 2010 MDR0927RP0001 9 Rev F01

Dublin Waste Plan Evaluation Report Green Business Officers (GBO) 2006 2007 2008 2009 2010 Green Schools Officers (GSO) 2006 2007 2008 2009 2010 Source: WMP for the Dublin Region - Annual Progress Report 2008, 2009, 2010 & 2011 The reduction in waste prevention staff numbers reflects the change in economic circumstances in recent years in Ireland. The moratorium on recruitment of public sector staff has limited the refilling of positions which have become vacant.

In addition the remit of the local authority from a waste perspective is primarily focused at the household and community level. Working at the business level has not been as high a priority which has also explains the lack of GBOs in the region during the period. In the circumstances where awareness roles were not filled, the tasks associated with a GBO or GSO would fall to the EAO employed during the Plan period.

The Green Schools campaign is a noteworthy national environmental programme. EAOs and GSOs have been growing the programme during the period. In 2010 the local authorities had successfully registered 79% or 551 schools out of a possible 694 in Dublin in 2010. Of the 551 schools registered, 401 had been awarded green flag status at the end of 2010 which is a marked increase from 137 Green Flag Schools in 2006. Community and Voluntary Sector Involvement The Plan objectives include focused prevention initiatives and the establishment of sustainable waste services at a community and voluntary level.

Activities with households and the communities have taken many forms over the Plan period. Examples include the participation of local authority staff in one off and annual events such as the DLRCC’s involvement in the Cool Earth Exhibition at the annual Festival of World Cultures, the SDCC annual Eco Week, the annual Dublin City Neighbourhoods Competition –organised by DCC and provision of workshops and tours of the Estuary Recycling Centre, Swords by FCC for individuals and groups alike.

The Local Authorities supported community/voluntary groups establishing sustainable waste activities within their communities. This has included supporting community composting and reuse projects. There are many reuse initiatives and organisations operating in the Dublin region. The Dublin Local Authorities provide assistance to community and voluntary groups working in this area where possible. Some such examples include: Rehab Recycling, Sunflower Recycling/ Busy Bees, Liberties Recycling Training and Development, Rothar, the Rediscovery Centre, Clondalkin Community Recycling Initiative and Camara.

Reuse and Repair It was an objective of the Waste Management Plan to develop a ‘resource recovery centre’ in the Region enabling reuse/ repair of household items. The Rediscovery Centre was planned for Ballymun as part of the regeneration work on-going in the area. This facility has not been constructed as originally envisioned at a site in the area. However many of the reuse initiative which were planned under the Rediscovery umbrella name have gone ahead including Rediscover Fashion, Rediscover Paint, Rediscover Furniture, and Recycabike. 24 staff are employed full time and part time through MDR0927RP0001 10 Rev F01

Dublin Waste Plan Evaluation Report MDR0927RP0001 11 Rev F01 these initiatives. A recent addition is the Rediscover Business programme which aims to encourage environmental responsibility and promote environmental, economic and social benefits from effective environmental management. It is evident that the community elements of the Rediscovery Centre have already proved successful. The development of the centre as planned to house the initiatives may prove to be too ambitious and a lack of finances will most likely prevent the centre from being constructed. A further reuse objective was the creation of an online ‘virtual’ reuse centre through the Dublin Regional Website to enable the public to reuse household goods.

The Dublin Local Authorities decided to create a unique service in Ireland to implement this objective. The free online reuse service, FreeTrade, was created in 2006 and allowed users to pass on unwanted goods to other users. Alternatively users could browse the site and pick up items for free. The service was hosted on the DublinWaste.ie website, from 2006 to June 2010 and proved to be hugely popular with the public. Its success led to this regional initiative being rolled out nationally. In July 2010 a national online reuse service based on original Dublin based initiative was implemented on a national level and transferred to the FreeTradeIreland.ie website.

The new site has continued to prove as popular in Dublin with membership increasing further.

Between 2006 and 2011 42,867 items were reused through the FreeTrade service as shown in Table 4-3 below. This level of reuse equates to over €4 million 9 in savings for users of the service. The initiative has become a cornerstone of reuse policy in Ireland making it accessible to all and delivering a real environmental solution. Table 4-4 Items Reused on FreeTrade in Dublin since 2006 Free Trade On DublinWaste.ie FreeTrade Ireland Year No. items Reused No. items Reused 2006 (Aug - Dec) 1,551 - 2007 6,174 - 2008 8,736 - 2009 9,365 - 2010 4,968 3,62310 2011 - 8,450 Total items reused Per site 30,794 12,073 Total Items reused 42,867 Source: WMP for the Dublin Region - Annual Progress Report 2011 9 This figure is made up of financial savings from the avoidance of waste disposal and new purchase costs.

The recipient of a new item from the website is achieving considerable financial savings and the cost of purchasing an equivalent new item is saved. The estimated cost of new items has been set at an average of €100. The saving from disposal costs is based on the tonnage diverted which is estimated to be over 1,000 tonnes of material. The disposal of 1 tonne of bulky waste material by skip would typically cost €200.

10 The decrease in figures arises from improvements in the websites data recording system

Dublin Waste Plan Evaluation Report Recent Legislative Requirements: EU Waste Framework Directive The EU Waste Framework Directive which has been transposed into Irish law has important prevention and reuse requirements. Prevention is defined clearly in the Directive and includes re-use. The waste hierarchy has been revised to 5 steps with prevention sitting at the summit. The activity of re-use is present in other Articles of the Directive, including Article 5 on By-Products which sets out the conditions for determining if a material is a by-product, and not a waste, and if so can be reused again without authorisation.

The Directive also sets requirements on member states to design waste prevention and decoupling objectives for 2020 by the end of 2014, based on best available. The existing Plan is based on the previous incarnation of the waste hierarchy which separated out prevention and reuse as two different activities. Accordingly the Plan has separate prevention and reuse objectives. During the course of the Plan it has become clear from activities on the ground that reuse is an important element of waste prevention. A future plan needs to recognise this and incorporate the decoupling objectives as required under the Directive.

Environmental Considerations: The prevention and reuse of waste has the potential to deliver improved resource efficiency and the highest environmental outcome. The failure to prevent and reuse waste means waste needs to be managed. The management of waste is a complicated process and has consequences for the environment all along the treatment chain in terms of the emissions generated. Preventing waste reduces the need for primary resources and avoids emission generation from the production of new materials to replace those which have become wastes. The lower treatment solutions such as landfills pose the highest potential emissions generation and risk to the environment.

Prevention and reuse need to remain at the core of the Plan to minimise waste generation in Dublin and reduce the impact on the environment.

Recommendation: The existing Plan contained many prevention and reuse objectives. Some of these remain relevant, such as those supporting national prevention initiatives and assisting active community and voluntary groups. The recommendations relating to use related charges are also needed but require strengthening to ensure incentivised charging for waste is implemented. Reuse will be a key component of a future plan and continued support of the national reuse service, FreeTrade Ireland, is foreseen. It is recommended that the core prevention and reuse objectives are replaced to reflect the future role of local authorities in the waste sector and specifically prevention and reuse activities.

Resourcing this area is key but needs to be considered in light of the changed financial position which each Council is now operating in. The revising of the prevention definition in the Waste Framework Directive and the requirement to introduce decoupling activities is not addressed in the current Plan. New objectives are required to address these issues in support of the national prevention plan. MDR0927RP0001 12 Rev F01

Dublin Waste Plan Evaluation Report 5 HOUSEHOLD WASTE MANAGEMENT The management of household waste was a key priority for the Dublin local authorities in the Plan, which set out ambitious objectives and targets to be achieved over the period. The Dublin Local Authorities aimed to offer an integrated and cost-effective collection service to households in the Region. The emphasis was placed on the separate collection of clean, high value resources. The authorities aimed to harmonise the current system by rectifying some inconsistencies in the service levels across the Region. The vision to develop a recycling based waste management system in the plan is epitomised by the household recycling rate targets in the plan (as shown).

Source Recycling Waste-to-Energy Landfill Household Waste 60% 39% 1% To deliver these ambitious targets specific policy objectives were put in place and those which are identified as being key are as follows: Pay-By-Use Regulation 22. To implement use-related charging systems in support of waste minimisation and recycling in accordance with the Polluter Pays Principle (as outlined in Section 7.5) 23. To continue to extend and improve the green bin recycling service, increasing the quantity of material collected for recycling. This will be achieved through on-going public information and motivation, increasing the capacity of the system, and continuing to extend collection to multi-unit dwellings.

It is proposed to include new materials such as plastic bottles in the door-to-door collection.

Kerbside Collection 24. The Local Authorities will specify through consistent Bye-Laws across the Region how householders must separate and present waste. Bye-laws will set out how various household materials will be presented (broadly following the representation in Figure 18.3), and will be updated by the Local Authorities as required. The Bye-Laws will include a suitable fine for non compliance. 25. Continual improvement of the Green Bin service is an objective. This can be achieved through regular reporting of tonnages, regular composition surveys on the materials collected, and subsequent targeted actions by the local authorities to address areas where performance can be improved by better public awareness and service provision.

The proposed model for household waste collection and recycling in the Region is presented in Figure 18.3. 26. The Dublin Local Authorities propose to introduce an additional household waste collection (‘brown bin’) for organic waste generated by households. This will be introduced on a phased basis once biological treatment capacity is established. The household waste collection system (including the grey/black bin) may switch to an alternating fortnightly collection for household waste at this time.

27. The Brown Bin Service will be piloted in different locations throughout the Region to establish the most appropriate service for all householders, taking into account bin size and type, and collection frequency in order that the public are satisfied and willing to use the service. The most suitable charging mechanism for the Brown Bin service will be investigated during the pilots Bring Banks & Recycling Centres 28. To continue to expand the network of bring banks, employing innovative methods of siting and collection e.g. underground banks. 111 new bring banks are proposed (see Table 18.1).

Existing sites may be expanded or upgraded to accept additional materials.

29. To provide additional Recycling Centres with facilities to accept a variety of materials not catered for in the door-to-door collection service, including WEEE, household hazardous waste, green waste and household C&D (DIY) waste. Several additional facilities are proposed as outlined in Map 11, Table 18.2 and Appendix H. It is intended to have at least 12 full-scale Recycling Centres in operation by 2010, complimented by additional Centres at community level. MDR0927RP0001 13 Rev F01

Dublin Waste Plan Evaluation Report Waste in Apartments – Additional Policies 30.

All private apartments will be required to introduce a separate collection system for household dry recyclables, meeting the same standard as Local Authority services (see box below). 31. Space for Recycling – recycling requires separation of recyclable materials both within the apartment, and in the communal waste storage/ collection area. Adequate space needs to be made for 3-bin recycling systems (green, brown, and black bins) in both respects. Assessing Implementation: Progress towards the Target The plan set an ambitious target for the recycling of household waste at 60% for the region for 2013.

The regional rate of recycling has grown each year and has increased by 17 percentage points (from 27% to 44%) over the five year period from 2006 to 2010. Dublin City Council and Fingal County Council have experienced good growth in the recycling rate in their areas with an increase of 20% and 25% respectively over the 5 year period. The regional increase in the recycling rate was achieved through implementation of the 3 bin collection system and more materials being collected in the green Bin. The tonnage collected by the brown bin has grown but future participation and capture of material will be key to moving the recycling rate on.

Although progress is expected to continue in the regional recycling rate over the next couple of year, the significant gains experienced over the plan period are expected to slow down. A steadier rate of growth is anticipated with participation in the brown bin system key to this growth. It is thought that the delivery of the 60% target by 2013 will not be achieved within this timeframe. The ambition remains to achieve this rate but 2016 to 2018 is a more likely delivery date. Table 5-1 Recycling Rate (%) 2006 - 2010 Local Authority 2006 (%) 2007 (%) 2008 (%) 2009 (%) 2010 (%) 2013 Target DCC 21% 23% 31% 40% 41% DLRCC 43% 42% 44% 41% 41% FCC 25% 28% 41% 48% 50% SDCC 30% 29% 32% 34% 39% Regional Recycling Rate 27% 28% 35% 41% 44% 60% Total Household Waste Arising in the Dublin Region 464,332 470,221 474,767 470,806 421,506 Source: WMP for the Dublin Region - Annual Progress Report 2010 & 2011 During the period of the Plan the local authorities were the primary collectors of household waste from single dwelling households and to a lesser degree from apartments.

Unlike most other European Member States the ownership of household waste is with the holder of the waste and is not vested in the local authorities. This allowed private waste collectors to begin offering services to householders in Dublin. In late 2006 a private waste collector began advertising collection services in the Dun Laoghaire area. This began the change in collection services in the functional area with the private operator gradually obtaining a significant market share. Other collectors followed and private operators began to collect household waste in FCC and SDCC.

The local authorities responded by varying the Waste Plan (March 2008) inserting objectives in the Waste Plan stating that only local authorities or representatives appointed on their behalf shall collect source separate household waste from single dwelling households. The reasons for the variation are MDR0927RP0001 14 Rev F01

Dublin Waste Plan Evaluation Report MDR0927RP0001 15 Rev F01 explained in Section 3. The variation to the Plan was challenged in the high court with the court issuing a decision to overturn the variation in December 2009. Following the court decision pressures in the household collection market increased on the local authorities.

Private operators undercut the price of collection services offered by the authorities and their market share reduced. The scale of the reduction varied with the largest loss of customers occurring initially in the Dun Laoghaire Rathdown functional area. The change in the market dynamics was accompanied by the national economic recession. Public services came under increased financial pressure with budgets cut back substantially. Between mid-2010 to January 2012 the Dublin Local Authorities gradually exited the household collection market.

Pay-by-use & Regulation The Dublin Local Authorities implemented effective pay-by-use systems which was a factor in reducing household waste residual arisings and increasing recycling rates as shown in Table 5.1. Section 4 on provides further detail on the pay-by-use systems in place during the plan period. A further objective of the waste management plan was to implement consistent Bye-Laws across the region describing how householders must separate and present waste. These Bye-Laws have been put in place for all four local authorities and are consistent in so much as possible. Different charging mechanisms and local waste policy have given rise to minor differences in the waste Bye-Laws of the region.

Kerbside Collection Kerbside collection was the primary method for the collection and management of household waste in Dublin during the plan period. In 2010 kerbside collection accounted for 83% of the management of household waste. During the period kerbside collection in Dublin was undertaken by both public and private parties11 and consisted of 1, 2 and 3-bin collection systems. In 2010 the proportions of biowaste and dry recyclables collected in Dublin were 11% and 25% respectively. The black bin system remains the largest waste kerbside collection system collecting 64% of the total kerbside waste in 2010.

The quantity of waste collected in the black bin has changed. Over the period from 2006 to 2010 a significant decrease was recorded in the total tonnage of black bin residual waste collected. Since 2006 this is a 28.5% drop representing almost 90,000 tonnes. This fall is due to different factors such as the pay-by-use system but the expansion of the 3-bin collection system is recognised a being the key delivery. The importance of the changed economic circumstances in Ireland since 2008 cannot be underestimated either, the recession has impacted on householders discretionary income and consumer spending has decreased.

This has impacted on household waste tonnages also.

Table 5-2 Black Bin Collection Service 2006 - 2010 2006 (tonnes) 2007 (tonnes) 2008 (tonnes) 2009 (tonnes) 2010 (tonnes) Total Regional 310,386 313,811 283,367 258,286 221,968 Source: WMP for the Dublin Region - Annual Progress Report 2007, 2008 & 2011 Important policy objectives in the plan related to the improvement of the Green Bin Recycling network. An objective was set to accept greater types of waste to increase the overall quantity of waste in the Green Bin collection. Table 5.3 shows the Green Bin Recyclables collected between 2006 and 2010 for the Dublin region.

11 In 2010 24% of kerbside household waste was collected by private operators with 76% collected by the public authorities.

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