Appendix 2. Domestic Waste Recovery Infrastructure. A2.0 Overview. A2.1 Non-hazardous waste infrastructure Landfill facilities

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1 Appendix 2 Domestic Waste Recovery Infrastructure A2.0 Overview This section discusses the available non-hazardous waste infrastructure facilities, and notes any deficiencies. The EPA (2014) provides a survey of domestic waste management infrastructure in Ireland as of The survey covers both non-hazardous and hazardous waste management facilities. As is clear from Ireland s need to export, waste treatment facilities are reasonably limited in Ireland, although the deficit is not evenly spread across all waste categories. In this section the available non-hazardous waste management infrastructure is discussed first, providing some high-level considerations on the potential development of additional domestic capacity. This is then followed by a similar discussion of available hazardous waste infrastructure. A2.1 Non-hazardous waste infrastructure A2.1.1 Landfill facilities Landfill infrastructure in 2012 was such that 18 landfills (four private sector and 14 local authority managed) disposed of 1,027,577 tonnes of municipal waste. As noted earlier in this paper, this volume has dropped in The strides made by Ireland in recent years in pushing activities higher up the waste hierarchy, particularly recycling, means that the economic viability of landfill operations has diminished significantly. Consented landfill capacity was estimated to be approximately 17.3 Mt nationally. Only 1.6 Mt of this is reported to have been operational at the end of 2012; that is, less than two years capacity based on the fill rate in Figures 14 and 15 summarise the constructed and unconstructed capacity at nonoperational and operational landfill sites respectively. Amongst the remaining constructed capacity, almost all sites have a life expectancy of less than 5 years, with only one site identified as have a life expectancy between 5 and 10 years.

2 Figure 14: Consented capacity remaining at operational landfills. Source: Environmental Protection Agency (2014). Figure 15: Consented capacity remaining at non-operational landfills. Source: Environmental Protection Agency (2014). A2.1.2 Incineration facilities In terms of incineration and energy-from-waste, the same 2014 analysis by the EPA of waste infrastructure notes that Indaver Ireland Ltd managed the only commercial operation in The facility has been consented to treat up to 200,000 tonnes of waste per year and is designated with R1 energy efficiency status. It is reported that consented energy-from-waste capacity in Ireland in 2012 amounted to 542,875 tonnes per annum, although 127,875 tonnes of this capacity had not been utilised in These figures include incineration of municipal waste and co-incineration of wastes in cement kilns. The excess of incineration over the capacity of Indaver Meath, points to the growing importance of SRF in cement production. Co-incineration of waste in cement kilns offers cement producers an opportunity to have a steady cost input as part of their fuel needs rather than being dependent on global fuel price fluctuations, and also allows cement to be marketed as green.

3 However, despite these developments there is a current under-capacity in operational incineration in Ireland, meaning there is an inevitable dependence on export markets and energy-from-waste facilities abroad. In light of this under-capacity, O Donovan and Collins (2011) 1 conduct a formal cost benefit analysis of incineration as an alternative option to landfill for residual waste generation in Ireland. The technical details of the cost benefit analysis - underlying assumptions and modelling - may be accessed within the study, but some main conclusions are drawn and reproduced here. Based on the median valuation, incineration is shown to provide a net social benefit relative to landfilling. Of the landfilling that is unavoidable, the net present value of existing landfill capacity is shown to increase with improved pre-treatment of municipal solid waste and the capture and use of landfill gas emissions. Given the sensitivity of the net present value calculations to key model inputs, the study endeavours to validate the cost benefit analysis with a sensitivity analysis. This shows that the NPV of incineration in relation to: its scale, its operational costs and the environmental benefits accrued in the form of climate change mitigation and resource recovery. The authors conclude that incineration does not provide a net benefit against landfill if its scale and energy recovery capacity are insufficient. In terms of new capacity; Indaver Ireland Ltd. has also been granted a licence for a facility in Ringaskiddy, Co. Cork, while DwTE has been granted a licence for a facility at Poolbeg, Co. Dublin. Only Poolbeg however, being operated by DwTE, is proceeding for now. This plant will have 600,000 capacity, with the plant likely to be operational from Poolbeg will represent a seismic shift in treatment capacity when it comes on stream. A2.1.3 A note on the pre-treatment of waste Municipal waste accepted to landfill and incinerators is obliged to be pre-treated. This is particularly aimed at separating out BMW waste for higher-in-hierarchy treatments in order to comply with landfilling obligations set out in Article 5.2 of the Landfill Directive requiring a reduction in the amount of BMW waste going to landfill. Pre-treatment also frees up feedstock for recycling and potentially re-use. The first and most desired approach to pre-treatment (assuming the waste has been generated rather than prevented) is source separation and separate collection. In this approach, households and other waste producers separate out waste into more refined categories to allow easier recovery and national legislation/ permit conditions do not allow for subsequent mixing of source segregated waste with either unsegregated waste or other types of source segregated waste. The provision of recycling bins to households for presentation to the separate collection system is an example of this form of pretreatment, as well as the current roll out of three-bin systems with the brown bin being provided to households for bio-waste. Bring-banks, for the segregated reception of higher value recyclables, also offer this pre-treatment opportunity. This is an aspect of pre-treatment that the three new waste regions are particularly at the fore of, both in terms of educating households, and in terms of ensuring the provision of 1 O'Donovan, E., & Collins, M. L. (2011). An Economic Evaluation of Incineration as a Residual Municipal Solid Waste Management Option in Ireland (No. tep1811). Trinity College Dublin, Department of Economics.

4 separate bins in order to enable this form of pre-treatment. As a nation Ireland is still quite behind in this area, with only 37% of households having three collection bins by Germany, by contrast, provides five bins to households for: non-recyclables, organics, paper, light packaging, and glass. Waste that is not separated at source, needs to be pre-treated through either thermal treatment or Mechanical Biological Treatment (MBT). EPA technical guidance document Municipal Solid Waste: Pre-treatment and Residuals Management defines MBT as the treatment of residual municipal waste through a combination of mechanical processing and biological stabilisation, in order to stabilise and reduce the volume of waste which requires disposal. Currently thermal treatment or MBT is a requirement for municipal waste collected through a 2-bin or 3-bin system offered to households only to the extent that the EPA Technical Guidance Document and consequent conditions imposed on the waste licenses of landfill sites effectively set a quota for the maximum amount of BMW that may be consigned to landfill. In this regard, 98% of households at least have a 2-bin service if they have a bin service in the first place. However, the Regional Waste Management Plans require that by January 2016 MBT will be a requirement for the black bin element of all residual municipal waste collected that is being consigned to landfill. This represents a major challenge for the regional waste authorities, but also offers an opportunity to prevent waste going to landfill that could be more effectively used as a resource higher up the waste hierarchy. The planned introduction of pay by weight for all household waste collection in 2015 and 2016 has the potential to transform Ireland s performance in terms of the most desired form of pretreatment, segregation at source by households followed by separate collection of the dry recyclables and bio-waste streams. A Composting facilities Drawing on the Market Report on Irish Compost Production and Use (rx3, 2012), the EPA notes that at a national level, consented capacity for biological treatment totalled 412,700 tonnes per annum as of 2012, with 45 composting and five anaerobic digestion facilities in operation (respective capacities: ~377,700 tonnes, ~35,000 tonnes). The rx3 report also notes that at the same time 16 composting facilities were not operational. Based on 2010 survey data from composting operators, the domestic composting market is broken down by market share as follows: landscaping, 24%; agriculture, 29%; amateur gardening, 18%; horticulture, 21%; landfill capping 7%; and grounds maintenance, 1%. As of May 2011, the rx3 report states that 600,000 tonnes of treatment capacity was at the planning and development stage for brown bin and organic waste. A number of anaerobic digestion facilities are identified as being at development stage, ranging from concept stage through to commissioning. Twelve composting facilities and three anaerobic digestion facilities were also approved to process animal by-products 2 to an estimated 2 Food waste, also an integral part of bio-waste consisting of a mixture of food and landscaping wastes, is the key animal by-product from the perspective of municipal solid waste and, accordingly, composting and anaerobic digestion of bio-waste is invariably subject to the onerous requirements of animal by-product legislation.

5 capacity of 181,000 tonnes. Indeed, it is reported that as of May 2012, 23 composting and 19 biogas technology based facilities were seeking approval to process animal by-products. Given the low rates of composting and biodegradable waste recycling identified earlier in the report, especially compared to our European neighbours, optimisation of all available composting capacity should be made a priority. The rx3 report provides a comprehensive assessment of the potential for expansion of the domestic composting markets across the agriculture and organic sector, horticulture sector, retail sector, landscaping and forestry sector, and brownfield and contaminated land sector. The analysis concludes that with most revenue earned through gate fees, few companies have developed sound compost sales in local markets. To exploit higher price markets and generate proper revenue from sales, a greater focus on marketing and product development is required. The rx3 report suggests that potential for sales of compost products exists: Horticultural clusters show that local markets potentially exist for composting facilities. Irish certified organic compost which could displace German/UK imports. rx3 crop trials show that compost can displace artificial fertiliser for lower costs. Improved arable and grass crop yields were also shown. Quality focussed markets that require quality assurance can be addressed using the national compost quality assurance scheme. Lack of high quality compost product for specialist users, e.g. in sports turf sector. Specialist compost brokers/sales companies that can undertake logistics of compost sales from specialised compost producers not wishing to diversify into this area. Higher value peat dilution and retail sales outlets. A Bring Banks and Civic Amenity Facilities At a household level a range of civic amenity and bring bank facilities are offered countrywide in Ireland. In 2012, it is reported that 15% of household municipal waste was managed through bring bank and civic amenity facilities. Table 4 breaks down these waste management figures for 2012, with comparison against 2009, 2010 and It can be seen that the number of bring banks had been on a gradual decline since 2009, with the volume of waste collected down year-on-year as well. The number of civic amenity sites had increased over the same period but in contrast the volume collected at these sites declined. It is possible that the volume declines are partially related to the general decline in waste generation over the period of the financial crisis. Alternatively the increased provision of multi-bin separated kerbside waste collection services might have made these facilities redundant for some households.

6 Table 4: Number of and tonnages collected at bring banks and civic amenity sites, Source: Environmental Protection Agency (2014). A Recycling infrastructural deficits Lacking from Ireland s waste infrastructure landscape are a number of key recycling facilities. Ireland has no glass manufacturing facility, paper mill or metal smelter. These materials are generally exported for recycling. A common reason for the absence of these facilities is the lack of economies of scale in order to make such infrastructure viable due to Ireland s small population. Indeed, the metal reprocessing plant at Irish Ispat closed in 2001, Irish Glass Bottle Company closed in 2002 and Smurfit Paper Mills closed in 2005 There are some positive features of the recycling market. The National Waste Report 2012 shows that 58% of wood recovered in the waste collection process is recycled, with the remainder used as fuel in Irish facilities. Almost half of plastics recovered are processed in Ireland. The key issue with plastics is the lack of segregation by households and thus the poor quality of the material available for reprocessing figures collated by the rx3 group report 319,800 tonnes of capacity for plastic reprocessing on the island of Ireland, but that this capacity is not fully utilised due to poor quality recyclates. Both glass and metals recycling are victims of economies of scale. Just 40,000 tonnes of metals are available for recycling in Ireland each year. While the tonnage of glass is about three times this amount, it too is an insufficient volume to ensure a viable glass manufacturing facility in the absence of government support. For example, one single plant in the UK, the Recresco recycling facility in Kent, is capable of processing 200,000 tonnes of glass each year. Any Irish plant would be required to compete with the economies of scale of facilities like this in the sale of end product. Some potential exists in paper recycling. A feasibility study on establishing a paper mill on the Island of Ireland (including the Republic of Ireland and Northern Ireland) was commissioned by WRAP (The Waste and Resources Action Programme, 2006) in the UK. Although somewhat dated at this point, the analysis is insightful in its consideration of potential paper mill infrastructure for processing of recovered paper based products: packaging containers; packaging cartons; tissue; printing and writing; newsprint; or magazines. The technical details of the feasibility study (underlying assumptions and modelling) may be accessed within the study itself, but some main conclusions are drawn and reproduced here. The report highlights that a world-class facility is needed which can effectively compete with any international competitors and determines that tissue offers the best opportunity for paper recycling on the Island of Ireland. Packaging cartons also offer

7 potential. Recycling of other recovered paper based products would face both investment and operational challenges. WRAP (2006) present a ranking of the recovered paper based products in order of most potential: Tissue - only the tissue mill option is well matched with local demand. Exports are potentially minimal. The other options are required to be export competitive with much of the product sold outside the island of Ireland. Packaging Cartons - a potential good link to local converters and Island of Ireland packaging needs. Printing and Writing Papers - requires high grade recovered paper collection. Exposed to existing and potential mills in the UK and Continental Europe. Packaging Containers - already large capacity in Europe. Newsprint - excluded as insufficient fibre. Magazines - excluded as insufficient fibre. As tissue is a low volume user of recovered paper, the WRAP study suggests the possibilily of a small tissue mill. Another possibility is a medium sized packaging carton mill but this would require a very supportive business platform to succeed. An updated assessment of the potential for developing domestic paper mill infrastructure would be particularly timely as Ireland continues its efforts to improve its overall recycling rate. It is however worth pointing out a counter argument to the potential for tissue mill infrastructure Ireland. The difficulty with the development of a tissue mill is that we are not dealing with perfect competition in the Irish market due to the existence of speciallyconstructed supply chains, where a merchant facility would find it difficult to break into markets in Ireland and displace imported tissue without the active collaboration of the existing market players. A2.2. Hazardous waste infrastructure The EPA in its assessment of domestic hazardous waste infrastructure identifies that Ireland has a number of licensed and permitted facilities authorised to treat hazardous waste, but no dedicated hazardous waste landfill disposal facility. Treatment occurs either on-site at the location where the hazardous waste is generated or off-site at authorised commercial hazardous waste treatment facilities. Of the onsite hazardous waste treatment in Ireland in 2012, the EPA reports that 48% underwent a disposal operation and 52% a recovery operation. The chemicals sector conducted the majority of onsite treatment of hazardous waste. Twenty facilities with environmental licences (IED/IPC/IPPC) reported treating hazardous waste on-site in the most recent figures for 2012 totalling 68,100 tonnes. The treatment methods on-site are detailed in Table 5. Solvents are the most commonly recovered, while salt cakes and oil sludges are the most commonly disposed of (in the ground). Off-site domestic recovery methods are detailed in Table 9 and show that this waste is more commonly recovered rather than disposed. Approximately half of waste is treated domestically either on-site or off-site and half is exported. As noted in the section on exporting, the most frequently exported category of hazardous waste is solvents, which is

8 also the most frequently domestically recovered category of such waste. This raises a question as to why more waste is not recovered domestically. Table 5: Methods of treatment of hazardous waste on-site at IPPC licensed facilities, Source: Environmental Protection Agency (2014). On the policy front, a recent development has been the issuance of the latest, revised National Hazardous Waste Management Plan for Ireland, to cover the period This revised plan identifies a number of priorities to improve the management of hazardous waste, with objectives set out as follows: To prevent and reduce the generation of hazardous waste by industry and society generally; To maximise the collection of hazardous waste with a view to reducing the environmental and health impacts of any unregulated waste; To strive for increased self-sufficiency in the management of hazardous waste and to minimise hazardous waste export; To minimise the environmental, health, social and economic impacts of hazardous waste generation and management.

9 Table 9: Methods of treatment of hazardous waste off-site, Source: Environmental Protection Agency (2014). The EPA identifies three overarching strategic needs in order to reduce dependency on the export of hazardous waste and increase the amount of domestic treatment: Expansion of recovery and treatment capacity in Ireland for waste that does not need thermal treatment or landfill (i.e. physico-chemical treatment); Addressing the deficit in thermal treatment capacity in Ireland (i.e. use as fuel, coincineration or incineration) for Irish hazardous waste currently being exported; Securing of long-term disposal arrangements for hazardous waste streams not suitable for thermal treatment or recovery. In order to achieve these goals two primary plans are set. The first is to continue to support research grants directed towards the development of hazardous waste and waste treatment technologies from concept through to pilot scale roll-out in order to support the commercial development of treatment capacity. The second revolves around the management of solvents and other wastes currently exported. It is identified that there is scope to expand on specific on-site and off-site infrastructure such as (in order of preference on the waste hierarchy) solvent recycling, fossil fuel substitution at existing appropriate sites (energy recovery and co-incineration) and purpose-built incinerators. It should also be noted that Regional Waste Management Plans support the development of up to 50kt of thermal capacity to treat hazardous waste within the country.

10 A.2.3 Barriers to waste recovery infrastructure development in Ireland There is a general perception of policy uncertainty in the waste sector and this has acted as a brake on investment in previous years. Respective governments, as is their right, have adopted differing views on the desirability of certain waste infrastructure facilities; particularly around incineration. Community perceptions of the desirability of waste projects play into this policy uncertainty as they influence political actions. For example, there have been consistent objections by communities in recent times to the development of composting facilities. This can affect future policy development and local political actions, creating uncertainty over the viability of development. Associated with this is the potential for future regulations to increase policy uncertainty further. One example being the ongoing issue as to whether waste collection should involve competition in the market or for the market. This could impact on negotiation for the supply of feedstock by waste collectors. The eventual firming up and implementation of the EU legislative proposal to increase resource efficiency in waste management practices as envisaged in the Commission Communication Towards a Circular Economy A Zero Waste Programme for Europe adds to long-run uncertainty as its eventual goal is to eliminate much of the feedstock that supports recovery processes (such as waste-toenergy facilities). Even recycling plants should experience an impact as the EU focus moves to prevention and re-use. On a practical basis, a major barrier for some infrastructure development is economies of scale. This was discussed in the preceding sections with regards to why certain domestic waste infrastructure is not currently feasible. The growth in waste projected by 2030 might ease this barrier, but that is very much a long-term solution to an immediate issue. The availability of imports could also be used to substitute for the lack of available domestic feed in some circumstances.