The current consultation document "Towards a new National Waste Policy Discussion Document" ignores more than three years of work, according to the environmental lobby group FIE.

The "International Review of Waste Management Policy", published in 2009 with 65 Annexes, the largest waste policy study ever undertaken in Ireland, at significant cost to the taxpayer, by an international consultancy is effectively ignored in the consultation document.

Also disregarded as is the work done by the Department of the Environment on implementing the 24 Recommendations of the International Review leading to consultation by the Department on a 2010 Draft Statement of Waste Policy only a year ago.


A spokesperson for FIE said "The significant Recommendations made by the Review deserve to be the subject of explicit decisions. If the Department/Minister/Government is now rejecting them, it should tell us why."

The new document also substantially downgrade references to sustainability. A spokesperson for FIE said: "It appears that sustainability is not considered to be the fundamental conceptual foundation of waste policy. In the context of Ireland's international commitments to sustainable development and the government's stated intention to integrate sustainability into all policy areas this is inexplicable."

Truly astonishing, however, is the absence of any reference in the Discussion Document to human health. The protection and promotion of human health was a key objective of both the International Review and the 2010 Draft Statement of Waste Policy. There is no reference in the new document to human health.

A spokesperson for FIE said: "The impact of waste facilities on public health has been a major public concern in Ireland over recent years. The public concern has been fed and substantiated by instances such as the evacuation of houses due to landfill gas infiltration. The concern was recognised by the Department of the Environment which commissioned a literature review, published in 2003, on the "Health and Environmental Effects of the Landfilling and Incineration of Waste". It is shocking that Minister Hogan apparently thinks that waste policy can ignore the impact of waste facilities on human health."

Consultations on A New National Waste Policy Discussion Document 2011 closed Friday 30th September 2011.

 


Background

In 2008 an international consultancy was contracted by the Department of the Environment, Heritage and Local Government (as it then was) by open competition to carry out a review of Irish waste policy. It was a major study at significant cost to the taxpayer and is by far the most detailed piece of waste policy research carried out in Ireland. It involved detailed analysis and consultation with stakeholders and interested parties. The results were published in September 2009 as a voluminous"International Review of Waste Management Policy", made up of a Summary Report and 65 Annexes. It made 24 key Recommendations.

In Autumn 2010 a Draft Statement of Waste Policy was published for consultation, based on that Review and setting out how most of the Recommendations found in the Review would be implemented. It appears from the departmental website that 72 submissions were received, many of which were quite detailed.


The Policy-making Process

The current consultation document "Towards a new National Waste Policy Discussion Document" deals with the above process as follows:

Existing waste policy was the subject of review over the past number of years, including the preparation of a report by international consultants. Many in the waste and resource management sector have indicated that the review process has led to a level of uncertainty which in turn has hampered investment in the sector.
A previous public consultation on a draft statement of waste policy received over 70 contributions from a wide range of stakeholders on an equally wide range of waste management issues; those views have been considered in the development of this paper.
Surprisingly while 9 other documents are referenced in footnotes to the Discussion Document, no reference is given for either the International Review or the Draft Statement of Waste Policy.
Rational and successsful policy-making requires that all relevant matters are taken into account. The significant Recommendations made by the Review deserve to be the subject of explicit decisions. If the Department/Minister/Government is now rejecting them, it should tell us why. Respondents to this consultation are likely to recommend, for example, the setting of residual waste targets or a residual waste levy. However, these recommendations have already been made to the Department by its' consultants and we have no idea why they are not mentioned in the current document. Proper consultation in this context requires a dialogue wherein the results of previous policy development work and previous consultations are made clear to all concerned.


The versions are strikingly different.

The first fundamental change which is evident is a reduction in clarity. We urge tha tguiding principles should be set out as clearly and discretely as possible. To state that "[t]he policy will be consistent with the cornerstones of National and European policy, including the waste hierarchy, the principle that the polluter pays, sustainable materials management and the urgent imperative to reduce greenhouse gas emissions" is to run a number of distinct considerations together and, worse, to effectively state that there are further guiding principles which are unenunciated; if the policy is indeed to be consistent with the cornerstones of policy, it has to be possible to state what those cornerstones are.

Aside from the reduction in clarity there are two changes which jump out.

Human health

The first is the absence of any reference in the Discussion Document to human health. This is truly astonishing. The impact of waste facilities on public health has been a major public concern in Ireland over recent years. The public concern has been fed and substantiated by instances such as the evacuation of houses due to landfill gas infiltration. The concern was recognised by the Department of the Environment which commissoned a literature review, published in 2003, on the "Health and Environmental Effects of the Landfilling and Incineration of Waste". In addition, the recent EPA Review recognises the inadequacy of the EPA's handling of human health issues, including in relation to waste licensing, and the EPA is now seeking to remedy this acknowledged defect. In that context it is astonishing that a Discussion Document on waste policy should now seek to disregard human health issues.

Sustainability


We believe both of these to be grave mistakes. We strongly urge that the Government puts sustainability at the heart of waste policy and that it fully integrates the protection and promotion of human health as fundamental objective of environmental policy including waste policy.

We also urge that the guiding principles be set out as clearly and discretely as possible. To state that "[t]he policy will be consistent with the cornerstones of National and European policy, including the waste hierarchy, the principle that the polluter pays, sustainable materials management and the urgent imperative to reduce greenhouse gas emissions" is to run a number of distinct considerations together and, worse, to effectively state that there are further guiding principles which are unenunciated; if the policy is indeed to be consistent with the cornerstones of policy, it has to be possible to state what those cornerstones are.


Policy initiatives/ recommendations

We cannot improve on the 24 recommendations from the International Review. The Department has already considered the practial aspects of the implementation of these recommendations in preparing the Draft Statement of Policy issued last year.


Democracy and Accountability

Some additional issues are raised in the Discussion Document, in relation to accountability and democratic control. We strongly urge that the administration of waste management be subject to full democratic accountability and full transparency. This has been far from the case in the recent past. Local authorities have hidden behind claims of commercial secrecy and have not acted in accordance with the wishes of local people and their elected representatives.


Lock-in and "no regrets" policy-making

Excessively high waste generation predictions, based on assumptions that waste generation increases infinitely and that prevention and minimisation is impossible, risk leading to over-investment in waste infrastructure. In the worst scenarios, as with over-sized incinerators such as that proposed for Dublin, they risk leading to a lock-in to inferior waste management options, low on the hierarchy, contrary to the requirements of the waste hierarchy. National waste policy must recognise this and set out to prevent it. The residual waste targets and levy recommended in the International Review are good policy responses. If they aren't being adopted, it would be important to know why and to set out alternative policies

Producer responsibility

We welcome the statements in the discussion document about increased producer responsibility. However this needs to extend to fundamental changes to the sustainability of production and consumption patterns.


References

DoEHLG, 2010, Draft Statement of Waste Policy http://www.environ.ie/en/Publications/Environment/Waste/WasteManagement/FileDownLoad,23397,en.pdf

Hogg, D, et al., 2009, International Review of Waste Management Policy: Summary Report and Annexes
http://www.environ.ie/en/Environment/Waste/ReviewofWasteManagementPolicy/

 

 

 

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