6 – Enforcement

This is Part 6 of the input into the Department of Communications, Climate Action and Environment’s Waste Advisory Group consultation process on the circular economy by Feasta member Féidhlim Harty.

Following are my responses to the questions raised by the department for consideration as part of the third meeting:

Are there alternative forms of waste regulation/enforcement which could be more flexible and effective?

Introduction of Waste Cost at Purchase

The primary reason for illegal dumping is to avoid the cost of proper disposal. The main reason for the rise in illegal waste operations is to profit from the space between collection and proper disposal by avoiding the cost of proper disposal. Both of these problems can be readily addressed by charging up front for waste collection as part of the purchase of any item. Thus everything from sweet wrappers to mattresses would have an associated waste collection charge included in the purchase price. This is completely in line with the polluter pays principle, charging the purchaser, while also steering, in a very modest way, towards zero waste options at the point of sale.

Another benefit of this process would be a shift in waste collection practices. Given that the service is already paid for, home owners would not have to pick and choose based on operator price plans, but would have the service provided free of any additional charge. Instead of multiple operators collecting in a single housing estate at different times of the week, the local authority would contract out the service to a single operator in a given area. The same contractors would still function within their own county areas, but divide the work by geographical boundaries rather than house by house.

At present contractors are squeezed by different financial pressures and competition, to the point where good education engagement for each household is financially uneconomic. A modest charge at purchase would also provided much needed funds to allow operators to engage in home owner education, which has already been identified as a very effective method for encouraging proper bin usage habits. At the time of bidding for a contract for a given area, education would become part of the overall contract sum.

Another aspect of illegal dumping is littering. Most casual littering is the result of carelessness rather than cost avoidance per se, and would thus not necessarily be addressed by the “waste cost at purchase” measure. Most casual littering includes a high proportion of cans, bottles and disposable cups. The former of these could be readily reduced by the introduction of a deposit and return system; while cups can be made from 100% biodegradable paper which would at least rot into the soil if dumped at roadsides. The cost of a deposit scheme should come from the “waste cost at purchase” fee process.

Most litter collection is carried out by Tidy Towns groups and concerned citizens and it is important that this work is either assisted to a great extent by local authorities (funded under the cost at purchase scheme) or is rewarded by provision of greater financial assistance for local projects within the community.

Is the culture of compliance in Ireland sufficiently developed to enable us transition to an alternative model?

The “waste cost at purchase” model would encourage compliance by virtue of the service being essentially free to the end user, and thus remove financial incentives to dodge proper rubbish collection.

What measures are required to respond to the links between waste crime and other forms of serious criminal offences, such as organised crime?

The “waste cost at purchase” model would eliminate waste crime since all contracts would be issued by local authorities to waste collection companies and the gate fees would be free of charge thereafter, so there would be no benefit to illegal dumping.

Note that other measures will be needed to encourage greater rates of recycling, given that the costs of disposal will be free to the waste contractors and homeowners. Most people are used to recycling now, and with greater education and a consistent media message about the benefits of proper social practices, Corona has shown that compliance can be very high.

How can performance be best measured from both a qualitative and quantitative perspective?

The plastic bag levy was immediately measurable by observing that the hedgerows were suddenly free of their usual adornment of flapping plastic. The “waste cost at purchase” scheme would be readily quantifiable by the revenue generated and then spent on education and remediation of historic problems. There is an urgent need for adequate funding to address the following legacy issues:

• to clean up old dump sites;
• to initiate large scale litter clean-ups of beaches and out-of-the-way places;
• to fund global ocean plastic clean-ups;
• to add filters to all sewage outfalls to contain microplastics until such time as plastic fabrics are phased out;
• to add filters to road runoff locations to filter tyre plastic fines until such time as fully biodegradable tyres are developed and introduced. Tyres contribute c.50% of all microplastic pollution;
• to reintroduce a glass bottle/jar collection/washing infrastructure in Ireland so that all containers can be fully zero waste in nature, an essential cornerstone of any circular economy;
• to support the development of zero waste alternatives to common household items that currently use plastic, from dental floss to coffee cups to clothing. Signifiant public investment is needed to assist with the move from a single-use plastic economy to a natural-fibre circular economy.

Continue to section 7 – Construction and Demolition Waste
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