Tag Archives: Consultation

ZWNW response to the NW Region Waste Management Group survey

Don’t ‘Waste’ Your Voice is the title of NW Region Waste Management Group online questionnaire asking for opinions on their current waste management plan.

There is a link on that page or you can go directly to the questionnaire.

Zero Waste NW welcome the NWRWMG questionnaire as an opportunity for everyone to express our views on the management of waste, or resources.
We are asking supporters to respond to the NW Region Waste Management Group survey using the following text as a guideline. The priority is to send a resounding ‘NO‘in answer to question 10 ‘ Do you support the principle to further reduce landfill by using waste as a resource to recover energy? The survey closes on 27th November.

Please pass this information on to anyone you know living in the seven council areas covered by the NWRWMG –

  • Ballymoney Borough Council
  • Coleraine Borough Council
  • Derry City Council
  • Limavady Borough Council
  • Magherafelt District Council
  • Moyle District Council
  • Strabane District Council.

Below are suggested answers to each of the questions on the NWRWMG Survey.

Question 1:  Which Council area?

Question 2:  In what capacity are you responding?

Question 3:  Do You support the overall aim of the plan? Answer: No
NWRWMG should make a commitment to ‘continuously reduce the residual waste to zero ie. phase out disposal options of landfilling and incineration whilst continuing to improve sustainability, economic resilience and social cohesion.Zero Waste Europe

Question 4:  Do you support the Waste Hierarchy as a priority area for action? Answer: Yes
In proposing a gasification plant, the NWRWMG itself is not supporting the Waste Hierarchy as a priority area for action. Investing £500 million in a process near the bottom of the hierarchy will undermine the development of recycling, re-use and prevention systems for the next 25 years.

Question 5:  Are there any specific actions which could be undertaken by councils? Answer: Yes
People in the Derry City Council area have shown that we are willing to play an active part in reducing waste. Council recycling depots in Derry and Eglinton were even occupied when threatened with closure!
WRAP (Waste and Resource Action Plan) is working with the UK government, Welsh, Scottish and NI Assemblies on waste management. They have produced the tools for analysing different collection systems.  We suggest that the NWRWMG councils work with WRAP, carry out the research, publish the results and implement the changes indicated.

Question 6:  Do You support the Proximity Principle? Answer:   Yes
(The Proximity Principle (art 16 Waste Framework Directive 2008/98/EC)
Signing a 25 year contract for a gasification plant with the capacity to burn waste greater than that produced by the Derry City Council area (and indeed greater than that of the NWRWMG area) clearly contravenes the Proximity Principle of ‘treating or disposing of waste as close as possible to the point of generation to minimize the environmental impact’. Bringing lorry loads (or possibly boat loads) of waste to the NW could only have a negative impact on air and noise pollution.
(A report produced by GAIA (Global Alliance for Incinerator Alternatives) Jan 2013 revealed that the incinerators operating in some EU states already have the capacity to burn more than the recyclable waste generated (22% capacity 20% non-recyclable waste).)

Question 7:  Do you believe that the NW can meet the recycling target set out in the NWRWMG plan (50% by 2020) Answer: Yes +
The people of the NWRWMG area working in conjunction with the community, statutory and local business sector can surpass the 50% recycling target by 2020. With simple kerbside collection and resource recovery systems, it is possible to increase the diversion from landfill rate much more quickly. An analysis by WRAP in Wales 2007 showed that sorting recyclables at the kerbside is better than co-mingled collections. (The net cost of kerbside sorted collections was about £11 per household per year compared with more than £25 per household for co-mingled collections. Carbon emissions were also about 20kg per household lower each year.)

Question 8:  Do you believe actions outlined in the NWRWMG plan can assist in reaching the 60% statutory recycling target which the Minister of the Environment is ‘minded’ to set? Answer: No
The proposed operation of a gasification plant will block the development of innovation in recycling for the next 25 years and beyond.

Question 9: Do you support using MBT (mechanical biological treatment) to divert waste from landfill? Answer:  No
The proposed MBT plant is linked to the proposed gasification plant and will only serve to process resources for burning. There are simpler, more effective systems for separating resources for recovery and in particular for separating foodstuff and other organic materials for composting.
If an MBT plant were to be used, FOE, in their response to ‘Towards Zero Waste – One Wales: One Planet’ suggest making use of the material after treatment by MBT (rather than burning it):
Depending upon the quality of the input material the MBT residues could be used for land spreading; remediation of contaminated sites; landfill cover (where they are effective at oxidising methane emissions and thus reducing climate impacts). Whilst not favoured there is also the back-stop option of using these residues in cement kilns as they are likely to be cleaner than the petcokes currently used and they displace fossil fuels more efficiently than in incineration.’
Background information from   Friends of the Earth

Question 10:  Do you support using waste to recover energy? Answer: No
It makes no sense to sign a £500 million contract, binding the NWRWMG councils to burning waste for 25 years when there are rapid developments in the recovery of resources. One local company, River Ridge Recycling which this September won two Sustainable Ireland 2013 awards, is currently working towards the goal of 100% diversion from landfill.

Already the NWRWMG has recognised that there isn’t enough non-recyclable waste from their council areas to justify the proposed ‘energy from waste’ facility and that they would need to bring in waste from other areas! This clearly contravenes the Proximity Principle.

I am also seriously concerned about the environmental and human health impacts of the proposed gasification plant. Gasification is classified as incineration in the EU Waste Incineration Directive and its emissions are regulated by the same mandate. A 2009 FOE (Friends of the Earth) report states that there are considerable uncertainties about these plants and that much of the data comes from the individual companies – ‘it is often unclear what emissions will be involved, and what sort of ash or other residue will be produced’.

A report by consultancy company Juniper explains that:  While gasification is not the same as incineration, the actual practical differences between some commercial gasification systems (that incorporate combustion to produce electricity) with incineration are relatively modest.’  Juniper (2008), Briefing document on the pyrolysis and gasification of MSW (municipal solid waste)

The 2008 Report of the British Society for Ecological Medicine highlights ‘the very high release of dioxins that arise during start-up and shut-down of incinerators….Of equal concern is the likelihood that these dangerously high emissions will not be detected by present monitoring systems for dioxins’.

The World Health Organisation fact sheet: Dioxins and their effects on human health’ states –
Dioxins are highly toxic and can cause reproductive and developmental problems, damage the immune system, interfere with hormones and also cause cancer.
Prevention or reduction of human exposure is best done via source-directed measures ie. strict control of industrial processes to reduce formation of dioxins as much as possible

The Stockholm Convention for the elimination of dioxins (where possible) is incorporated into European Law. Its regulations require that ‘priority consideration’ should be given to processes which do not generate persistent organic pollutants including dioxins.
HMSO, The Persistent Organic Pollutants Regulations 2007 Statutory Instrument 2007 No 3106

I do NOT support the proposed ‘energy from waste’ proposal. It is not needed; it contravenes the spirit of the EU Waste Framework Hierarchy; it contravenes the Proximity Principle; it poses a significant danger to human health.

Question 11:  Do you believe the mix of facilities MBT (mechanical biological treatment) and Energy Recovery will be sufficient to deliver sustainable waste management and meet statutory requirements? Answer: No

Energy Recovery should be excluded as an option. A £500 million, 25 year contract is inflexible, creating a market for waste and seriously undermining developments in resource recovery. Burning resources may meet statutory requirements for reducing waste to landfill but cannot be described as sustainable.

Mechanical Biological Treatment is a more flexible approach but there are more

Question 12:  additional comments
NWRWMG should adopt the principles and practices of Zero Waste, including:

  1. Waste prevention
  2. Repair and Reuse
  3. Recyling
  4. Composting
  5. Analysis of residual waste

A Zero Waste strategy will –

  • Provide thousands of extra jobs
  • Help close the loop (so we aren’t producing waste)
  • Reduce dependency on imports
  • Bring nutrients back to the soil
  • Reduce the environmental impact associated with waste disposal
  • Drive innovation in product design
  • Involve citizens in designing sustainable communities

If you are not for Zero Waste, how much waste are you for?’

From:  Zero Waste Europe 

ZWNW Response to the DoE Consultaiton on the NI Waste Prevention Programme

Zero Waste NW are asking supporters to submit a response (based on the text below) to the DoE (Department for the Environment NI) consultation on the NI Waste Prevention Plan.  (The draft plan can be read in full DoE website, via that link.)  The consultation closes December 11th.

ZWNW Response to the NI Waste Prevention Programme

The Draft NI Waste Prevention Programme must be seen in the context of the overall NI Waste Management Strategy –Delivering Resource Efficiency. In an open letter presented by hand to Minister for the Environment Mark H Durkan on the 7th Nov 2013, Zero Waste NW requested that he postpone publication of the Waste Management Strategy to allow for community participation in developing zero waste strategies. (see our Open Letter to the Minister)

Zero Waste NW supports the aim of the Waste Prevention Programme ‘to maintain the downward trend in waste arisings in NI, and in particular to decouple economic growth from the environmental impacts associated with waste generation’. However, while ZWNW recognise the excellent work of WRAP in supporting local authorities, businesses and the construction sector to ‘rethink waste’, we are concerned that the proposals in the draft plan will remain token, and possibly meaningless, unless the following actions are taken:

  1.  Target figures are set for reducing, reusing and recycling across all areas – Household Activity; Commercial and Industrial Activity; Construction and Demolition Activity and Re-use Activity. At the very least there needs to be a commitment to matching the target figures for waste prevention which will be set by the European Commission at the end of 2014.
  2. Legislation is set in place requiring the business sector to take waste prevention measures in line with zero waste principles rather than relying on voluntary agreements.
  3. A clear strategy is outlined for ‘decoupling economic growth from the environmental impacts associated with waste generation’. This is essential. Without strong safeguards, the workings of the market economy will ensure that perceived ‘economic benefit’ overrides real concerns for the environment, for human health and indeed, human rights.  Zero Waste NW are concerned that the conditions are already in place for a European market in waste going to ‘energy for waste’ plants. [This was documented earlier this year by the Global Alliance for Incinerator Alternatives]
  4. The DoE  ensures that there is no place for ‘energy from waste’ in a meaningful waste prevention plan. ‘Energy from waste’ is at the bottom of the Waste Framework Directive hierarchy (EU 2008).   A £500million,  25 year contract for a plant treating 120,000 tonnes of waste a year (as proposed by NW Region Waste Management Group) would create a market for waste and undermine all the aims of the Waste Prevention Plan. [Again documented by GAIA]

Zero Waste NW are a group of individuals giving our time voluntarily to research successful worldwide models in zero waste practice. We are very willing to meet with the Minister for the Environment and with other officials from the Department of the Environment to discuss the low-scale, flexible ways in which communities are taking charge of our own resource recovery, creating jobs and ensuring a healthy environment for our children.

Zero Waste NW
November 2013