The Regulation of Household Waste Collection
Consultation Document
Department of the Environment, Community and Local
Government
November 2013
1
1.
Introduction
The Minister for the Environment, Community and Local Government published A
Resource Opportunity - Waste Management Policy in Ireland in July 2012. The
Policy Statement provides a roadmap on the way Ireland will move away from an
over dependence on landfill, by putting in place the most appropriate technologies
and approaches to reduce waste, while at the same time maximising the resources
that can be recovered from waste. It recognised that the performance of the
household waste collection market in particular will be crucial in achieving overall
policy objectives and meeting national targets on landfill diversion.
A Resource Opportunity identified a number of problematic issues with the current
arrangements for household waste collection and acknowledged that revised
organisational procedures were needed to address these deficiencies . A Regulatory
Impact Analysis (RIA) published by the Department in July 2012 considered the
introduction of franchise bidding for household waste collection, whereby private
sector collection firms would bid to provide waste collection for a given period of time
and to a guaranteed level of service. This approach has been adopted in other EU
Member States, whereby a local authority or group of authorities invite tenders from
private operators to bid for the exclusive right to collect waste or certain streams of
waste within their functional area. The RIA identified a number of risks associated
with such an approach and ultimately made the recommendations to preserve the
current market structure of side by side competition and to strengthen
significantly the regulation of household waste collection.
The policy document sets out a range of proposals to significantly revise the existing
regulatory regime to ensure, inter alia, that waste collected is managed in
accordance with the waste hierarchy; that mandated service levels are delivered,
that pricing structures are put in place to incentivise waste reduction and source
segregation by households and that Customer Charters are put in place by all waste
collection providers.
2
The Department has had some preliminary discussions with a range of stakeholders
to map out new regulatory structures for the purposes of consultation.
It is the intention that the new and enhanced regulatory approach would deliver both
improved environmental performance and a quality service for consumers.
This discussion paper is designed to facilitate a public consultation process
on the environmental regulation of household waste collection to further
inform the detailed development of the new regulatory regime to strengthen
the regulation of household waste collection.
This consultation document sets out a series of questions on different themes and
areas associated with household waste management, as follows:
Questions 1 to 10:
Waste hierarchy and segregation of waste (pages 18 -
20)
Questions 11 to 13:
Mandated service levels (pages 20 - 21)
Questions 14 to 22:
Pricing structures (pages 25 - 26)
Questions 23 to 29:
Fit and proper person (pages 28 - 29)
Questions 30 to 35:
Waste Management Collection Permit Fees (pages 31 -
32)
Questions 36 to 40
Customer Charters (pages 33 - 34)
Questions 41 to 44
Managing nuisance and health & safety (page 35)
Questions 45 to 47
Householder obligations and awareness and education
measures to support householders (page 37)
Questions 48 to 49
Reducing Administrative Burden (pages 38 - 40)
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2.
Household Waste Collection Legislation
The regulation and enforcement of waste collection are the responsibility of the
relevant local authority under sections 33, 34 and 35 of the Waste Management Act
1996. Under Section 34 of the Waste Management Act a waste collector, other than
a local authority, must have a permit to collect waste for the purpose of reward, with
a view to profit or otherwise in the course of business, and must comply with the
conditions of that permit. Waste collection permits (WCP) are issued by the relevant
local authority, or a nominated authority acting on a local authority’s behalf. Since 1
February 2012, Offaly County Council (OCC) has been designated as the single
Nominated Authority (NA) for the administration of Waste Collection Permits (WCP)
on behalf of all Local Authorities. As Nominated Authority OCC use the title National
Waste Collection Permit Office (NWCPO).
The Waste Management (Collection Permit) Regulations 20071 set out the
procedures for the making of waste collection permit applications as well as the
conditions which can be attached to a Waste Collection Permit. A guidance manual
on the waste collection permit regulations2 may be consulted for more detailed
information.
A local authority may review or amend the conditions attached to a waste collection
permit, or may revoke a waste collection permit3. In this regard, waste collection
permitting may be used by local authorities in a flexible and responsive manner to
control waste collection and thereby achieve the objectives required by national,
regional and local waste policy.
Currently, waste collectors are required to hold a waste collection permit for each
Waste Management Planning Region or to hold a multi-region permit. The conditions
1
http://www.nwcpo.ie/forms/Collection_Permit_Regs_2007.pdf
2
http://www.nwcpo.ie/forms/WCP%20Guidance%20Manual.pdf
3
Section 34(6) of the Waste Management Act, 1996
4
attached to each permit are subject to the Waste Management (Collection Permit)
Regulations 2007 (which provide powers to local authorities to attach conditions to a
permit) and are informed by the relevant regional Waste Management Plan.
Among the measures contained in A Resource Opportunity – Waste Management
Policy In Ireland which will play an important role in the provision of effective and
efficient delivery of waste management services is the reduction in the number of
waste management planning regions from 10 to 3. The County and City Managers
Association has confirmed the composition of the three new Waste Management
Planning Regions - which correspond with the regional structures set out in the
Government’s Action Programme for Effective Local Government - and ratified the
Lead Authorities tasked with developing new plans for the three Waste Management
Planning Regions. In accordance with Section 22 of the Waste Management Act,
1996 and the Waste Management (Planning) Regulations, 1997, the Lead
Authorities for the three regions gave notice of the intention to commence the
preparation of New Regional Waste Management Plans4 on 10 October, 2013 and
written submissions to the Lead Authorities in relation to the new plans are invited by
19 December, 2013.
The rationalisation of the regions has been undertaken to ensure enhanced and
homogenous regional waste management planning by allowing the regions to pool
and concentrate their specialist resources, while at the same time freeing up
additional resources for other priority areas such as implementation and
enforcement.
4
http://www.environ.ie/en/Publications/Environment/Waste/WasteManagement/FileDownLoad,34313,en.pdf
5
3.
Waste Hierarchy
A Resource Opportunity - Waste Management Policy in Ireland is predicated on the
waste hierarchy as set out in the Waste Framework Directive 2008/98/EC and
requires that waste be managed in accordance with the following priority order:
Diagram 1: Waste Hierarchy, as per Article 4 of the Waste Framework Directive 2008/98/EC
Prevention is first in the priority order of the waste hierarchy. Preventing the
generation of waste is at the forefront of the national waste policy. Obviously it is far
preferable to avoid creating waste in the first place and prevention encompasses
many measures such as eliminating superfluous packaging, reuse of products and
smart purchasing, i.e. buying the right amount of goods such as food, so that none
goes to waste.
When waste generation is unavoidable, the maximum value must be extracted from
it by ensuring that it is prepared for reuse, recycled or otherwise recovered, including
6
through the appropriate treatment of mixed municipal waste or residual waste
collected in our black bins.
Preparing for Reuse is the next preferable approach to waste management,
products for which an owner has no further use, but which could be prepared for
reuse by a new owner. This includes for example, the repair of discarded items, such
as computers and furniture, to facilitate their reuse by others.
Recycling is third in the priority order, which involves reprocessing of waste
materials into products in order to displace the use of virgin materials. A simple
example is the recycling of aluminium cans so that they can be used to produce
aluminium products, including new cans.
Other recovery is fourth in the priority order, which relates to the use of other
materials in order to replace materials that would otherwise have been used to serve
a particular function including recovery of energy, such as through the generation of
electricity by waste to energy or anaerobic digestion plants.
Disposal lies at the bottom of the hierarchy, which in Ireland generally involves
waste being sent to landfill. Landfilling results in resources being buried and wasted
without a possibility of recovery, with risks such as emissions from methane
generated from decomposing biodegradable waste, leachate and groundwater
contamination, having to be closely monitored and managed. This is an
unsustainable way of managing our waste. A key theme of the waste policy is to
move away from an over-reliance on landfill as a waste management option and
move towards more sustainable waste management approaches in the higher tiers
of the hierarchy.
Disposal of municipal waste to landfill must be a last resort. Notwithstanding the
State’s obligations to divert biodegradable municipal waste from landfill under the
Landfill Directive 1999/31/EC, the national policy also aims to virtually eliminate
disposal of waste to landfill by the year 2020.
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4.
Polluter Pays Principle
Under EU and national legislation the waste producer and the waste holder are
required to manage the waste in a way that guarantees a high level of protection of
the environment and human health. The polluter pays principle is a fundamental
principle of environmental protection at international, EU and national levels. It is
based on the premise that waste generators or the current or previous waste holders
should pay the full costs of waste management services including collection,
treatment and disposal. Responsibility for the costs of waste management focuses
attention on the implications of waste generation and provides a direct economic
incentive for waste prevention. Application of the principle also ensures that the
waste management costs arising during the life of a product are included in the price
charged to consumers. Such costs can be minimised where materials and products
are managed in an environmentally effective manner throughout their life cycle.
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5.
EU Waste Legislation and Targets
Ireland’s waste policy is also influenced significantly by a range of EU waste
management Directives. In addition to the obligation on the State to ensure that the
public and the environment are not threatened or damaged by the activities of rogue
operators, there is also an obligation on the State to ensure that our EU obligations
concerning technical requirements and performance targets are met and that the
state, and therefore the taxpayer, is not exposed to the legal and financial
consequences of failures in our regulatory regime.
Appendix 1 contains a ‘snapshot in time’ overview of how the State is fairing in
relation to waste management targets set under a number of EU Directives as set
out in the EPA National Waste Report 2011. However, such targets are ‘moving’ and
subject to change, a situation underlined by the review of key targets in EU waste
legislation consultation process being undertaken on behalf of the European
Commission during 2013.
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6.
Issues identified with Household Waste Collection
Areas for Improvement
The analysis of the regulation of household waste collection underpinning the
national waste policy identified a number of areas of poor or problematic
performance in the current regulatory model, including:

low rates of householder participation in some areas;

insufficient levels of prevention and reuse of waste;

insufficient levels of segregation of household waste;

pricing issues, including pricing structures which do not incentivise
sustainable behaviours;

concerns in relation to meeting the state’s legal obligations under EU law,
where the state is currently not achieving some obligations and is at risk of not
meeting others in the future;

potential competition and corporate governance issues;

other social and environmental failures such as illegal waste activities; and

insufficient or ineffective implementation of the polluter pays principle in cases
where industry does not take appropriate responsibility for the end of life
treatment of their products.
Household Waste Collection Policy Goals
Government’s goals are to maximise the collective wellbeing by establishing and
maintaining a system of regulation of household waste collection which provides the
optimal mix of economic, environmental and social outcomes. Specifically, those
which:

support the attainment of our environmental objectives, adhere to the waste
hierarchy and the principle that the polluter pays, minimise the disposal of
waste in landfill, and maximise recoverable resources;

are consistent with the legal cornerstones of National and European policy,
including the Landfill Directive, the Waste Framework Directive and the
Producer Responsibility Directives on a number of priority waste streams;
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
provide for the segregation of household waste, as required by EU and
national law;

maximise the number of households with access to a waste collection service
and maximise householder participation;

minimise
the
price
paid
by householders,
commensurate
with
the
achievement of environmental objectives;

ensure a high quality service to the householder;

sustain a competitive and progressive waste management industry which
works in partnership with the State to meet its responsibilities;

provide the market stability and regulatory certainty necessary to underpin
investment in the suite of infrastructure we require and supports the
development of associated markets; and,

meet other social preferences, such as minimising community disamenity and
maximising health and safety.
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7.
A Resource Opportunity - Waste Management Policy in Ireland
The policy recognises the critical nature of household waste collection services to
the economy and the wellbeing of society and that the performance of the household
waste collection industry is central to contributing to the achievement of the policy
statement’s objectives. The policy proposes a number of measures to improve the
performance of household waste collection which are discussed in the following
pages. The questions posed in the paper are intended to facilitate discussion on the
various policy measures and actions that have been proposed to strengthen the
regulatory regime for household waste collection. Furthermore, submissions on any
issues relating to household waste collection (whether discussed specifically in this
paper or not) are now also being invited.
It should, however, be noted that two issues in particular are not discussed as part of
this consultation process, as they are being addressed in separate processes.
An inter-departmental working group was established under A Resource Opportunity
- Waste Management Policy in Ireland to report to Government with options to
minimise the impact of waste charges on low income households. The Working
Group, which comprises representatives of this Department and the Departments of
Social Protection; Public Expenditure and Reform; Finance; and the Tánaiste's
Office, submitted its second report to Government on 23 July, 2013. Government
considered the report and, given the complexity of the issues involved, the
deployment of further expert resources in the process is being considered with a
view to the Working Group submitting a third report to Government by the end of
2013. In this context, the issue of supporting low income households will not be
discussed expressly in this consultation paper. However, other household waste
collection issues in the paper are discussed which are clearly connected to this topic,
including household waste collection pricing structures, application of the polluter
pays principle, segregation of household waste, education and awareness measures
for householders, etc.
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In addition, Producer Responsibility Initiative (PRI) waste is the subject of a separate
root and branch review and is not discussed in detail in this paper. However,
Producer Responsibility Initiative (PRI) waste is also a significant consideration in
terms of household waste collection. It is essential that householders ensure that
PRI items are disposed of appropriately (e.g. WEEE / batteries are not disposed of in
household waste). For example, the application of a per kilogramme pay per weight
charging system, as discussed in questions 14 to 22 below would encourage
householders to dispose of PRI items (especially WEEE which can be heavy)
through the proper channels without charge rather than paying to have them
disposed of inappropriately in their residual bin. This should ensure that leakage of
waste streams such as scrap metal / WEEE through the household waste collection
system should be minimised as there is a financial incentive for the householder to
dispose of such waste for free at a designated facility. Requiring a waste collector to
demonstrate how they are monitoring the potential contamination within the
segregated waste streams being collected, including ensuring that other waste
priority streams (such as PRI waste with other dedicated collection systems) are not
being disposed of through the household waste collection service is discussed at
question 7 below and would further assist in ensuring PRI waste is managed
appropriately.
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8.
A Resource Opportunity - Household Waste Collection Policy Measures
and Actions
A number of respondents to the summer 2011 public consultation process in relation
to the regulation of household waste collection suggested that amendments to and
improved enforcement of the current waste collection permitting system can rectify
many of the difficulties associated with the system by strengthening regulatory
control over private sector waste collectors.
It should be noted that enforcement activities against operators who are noncompliant with their permits or persons who collect waste without the proper
authorisation also increase the ‘value’ of a permit by the removal of such operators.
A strengthened regime for non-compliant firms, involving the revocation of waste
collection permits will help ensure that the permit system plays its proper role to
deliver desired outcomes.
“A Resource Opportunity” established the following policies for household waste
collection permits:
 Through collection permits issued under a strengthened permitting system,
waste collectors will be required to:
a. manage the waste collected in accordance with the waste hierarchy and
in a manner supportive of the development of a resource efficient and
sustainable approach to the management of waste;
b. deliver mandated service levels; and
c. operate pricing structures designed to incentivise environmentally
sustainable behaviours by households in terms of waste reduction and
segregation.
a. Waste hierarchy
Measures such as the recent increases in the landfill levy and the introduction and
roll out of the organic bin are assisting in having waste managed in the higher tiers of
the waste hierarchy. Nonetheless, the percentage of (managed) household waste
disposed to landfill5 was reported to be 53% in 2011, which, although a reduction of
5
http://www.epa.ie/pubs/reports/waste/stats/National%20Waste%202011_web.pdf
14
some 11% on the previous year, is still unacceptably high. The aim of virtually
eliminating landfill will not be achieved unless further action is taken.
A Resource Opportunity seeks to prevent and reduce waste generation to the
greatest extent possible. Where waste is generated, it should be managed in
accordance with the waste hierarchy, reducing the amount of this waste which is
disposed to landfill. In this regard, increasing the level of segregation of waste will
further promote recycling and recovery of waste. In addition, the national policy
requires that the maximum value should be extracted from residual waste that is
presented for collection. It is imperative therefore that a waste collection system is
provided that can enable householders to maximise the opportunities for the
diversion of waste from landfill.
Segregation of household waste / resource efficient and sustainable approach
to the management of waste
A system of segregated collection of waste is a cornerstone in achieving compliance
with the waste hierarchy and exploiting the maximum resource value from waste.
The latest EPA National Waste Report (2011) notes the following levels of service
being made available to households in Ireland which were reported as being
provided with a household kerbside collection service:

26,631 households (2%) on a single bin (black bin/ residuals bin) service only;

723,374 households (61%) on a 2-bin service only (residuals bin and dry
recyclables bin); and

447,923 households (37%) on a 3-bin service (residuals bin, dry recyclables
bin, and organics bin).
Although the above figures are a small improvement on 2010 figures with an
increase in the number of households being offered a segregated household waste
collection service, greater source segregation of waste by households is necessary
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to secure investment in the suite of recovery and recycling infrastructure which is
required to meet the Government’s waste management objectives.
Besides the obvious environmental benefits, an additional advantage of increased
segregation is that the industrial processes which recover and recycle segregated
waste are more labour intensive than waste disposal and thus have the potential for
greater job creation.
The current legislation6 enables the nominated authority to attach conditions to a
waste collection permit requiring that all waste, or a specified portion of waste, is
source segregated, treated or recovered in such a manner as may be specified and
where practicable and having regard to the waste hierarchy, delivered to facilities
which reuse, recycle or recover waste. Requiring that collectors on a national basis
offer a service which allows the householder segregate waste into at least three
streams (residuals bin, dry recyclables bin, and organics bin in all agglomerations
with populations greater than 500 persons) in accordance with the European Union
(Household Food Waste and Bio-waste) Regulations 2013) is a fundamental step in
the drive to achieving compliance with the waste hierarchy.
Consideration can be given now, or at a later date (possibly during the 2016 midterm review of the policy) to introducing additional national mandated levels of waste
segregation, keeping in mind the requirements of the 2020 targets or any future
revised targets under the Waste Framework Directive 2008/98/EC; the national
waste policy goal of virtually eliminating landfill; and contributing to a resource
efficient economy through a national waste management system based on recycling
and reuse.
In terms of the development of a resource efficient and sustainable approach to the
management of waste, it has been suggested that the size of the Irish market
provides a significant challenge for the development of commercially viable
indigenous recovery and recycling/reprocessing opportunities for certain waste
6
Regulation 20(2)(g) of the Waste Management (Collection Permit) Regulations 2007
16
streams, particularly when competing with emerging economies. In addition, the
relatively high prices offered on international markets and the absence of economies
of scale for reprocessing of waste available within Ireland mean that the bulk of
municipal waste (including household waste) recovered is exported for recovery.
However, it is worth noting that Article 16 of the Waste Framework Directive
2008/98/EC7 states that “Member States shall take appropriate measures, in
cooperation with other Member States where this is necessary or advisable, to
establish an integrated and adequate network of waste disposal installations and of
installations for the recovery of mixed municipal waste collected from private
households, including where such collection also covers such waste from other
producers, taking into account best available techniques.” The possible introduction
of measures to encourage the development of such installations has been raised
with the Department and submissions on this issue are invited in Question 9 below.
A Resource Opportunity highlights the importance of promoting awareness of the
benefits of waste prevention and recycling. It identifies the key parties who should
share the responsibility for providing an effective and efficient programme of
awareness-raising activities, including producer responsibility schemes, local
authorities, waste collection companies, the wider public sector and the business
community.
Another issue which has been highlighted by both household waste collectors and
local authorities is the increasing appearance of pay-to-use receptacles/compactors
(PTUs) around the country. Although PTUs are not directly governed by the Waste
Management (Collection Permit) Regulations 2007, concern has been expressed at
their potential to undermine the segregation of household waste as many do not offer
the option of the segregated reception of dry recyclates and/or organic waste
material. Currently PTUs must comply generally with the regulatory requirements for
Certificates of Registration as set out in the Waste Management (Facility Permit &
Registration) Regulations 2007, though some local authorities have also introduced
further requirements, such as separate reception points and separate storage
elements for the recovery/disposal of dry recyclable waste and residual waste. Given
7
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:312:0003:0030:en:PDF
17
the obligations on household waste collectors to provide residual, dry recyclate and
as appropriate, organic waste collections, it has been articulated that PTUs have a
commercial advantage over kerbside collectors and have the potential to undermine
the segregation of household waste collection. While it is acknowledged that PTUs
can have a contribution to make in certain circumstances and locations in ensuring
that waste management is carried out without endangering human health or causing
harm to the environment (for example, in certain rural areas that are without kerbside
collection services or areas characterized by a high proportion of holiday homes),
policy articulates that waste is managed in accordance with the waste hierarchy and
in a manner supportive of the development of a resource efficient and sustainable
approach to the management of waste.
Questions
(1)
What are your views on the level of awareness, information and education that
needs to be provided to householders to assist them in waste prevention and
source segregation techniques? How best can the representatives of the
producer responsibility sector, local authorities, waste collection companies,
the public sector and the business community work in partnership to promote
awareness?
(2)
What are your views on the operation of the current commingled collection
service for dry recyclables? Are there ways that the performance of
commingled collections could be improved to increase the quality of
household material being collected for recycling / recovery? (e.g. by lowering
contamination rates, or by prohibiting the collection of glass containers in
commingled dry recyclable collections).
(3)
Should local authorities, at a local or regional level, be given the flexibility to
introduce more stringent requirements regarding the segregation of household
waste?
(4)
What are your views on the requirement that all household waste collection
firms without exception provide, at a minimum, a residual waste collection, a
recyclates collection, and, in the specific circumstances [as set out in the
18
European Union (Household Food Waste and Bio-waste) Regulations 2013,]
an organic bin collection. Non-compliance with the above minimum
requirement would result in action being taken against a household waste
collector seeking to have their permit revoked. Would it be preferable for the
above requirements to be included as ‘binding obligations’ in national
legislation as opposed to being attached as conditions in particular functional
areas?
(5)
Do you think legislation should also provide the possibility that action can be
taken against a non-compliant operator to seek to have their permit
suspended (in addition to the possibility of seeking to have a permit revoked)
for non-compliance with the legislation?
(6)
In what limited circumstances are pay-to-use compactors (PTUs) appropriate
for waste collection purposes?
(7)
Should a condition be included in waste collection permits to require a waste
collector to demonstrate how they are monitoring the potential contamination
of waste streams being collected, including ensuring that other waste streams
(such as PRI waste with other dedicated collection systems) are not being
disposed of through the household waste collection service?
(8)
Given that 53% of (managed) household waste was disposed to landfill in
2011 and that the policy aims to virtually eliminate landfill by 2020, what are
your thoughts on the potential following measures:
a) the application of landfill bans on particular waste materials at this time or
in the future?
b) further increases in the rate of the landfill levy?
c) removing the exemption from the landfill levy for further waste materials?
19
d) providing appropriate legislative support for enforcement activities of the
EPA in relation to landfill gate fees and financial guarantees for licensed
facilities?
(9)
Are there economic or other instruments you think could be explored or
introduced to further encourage the development of recycling and recovery
infrastructure within the State for managing household waste in accordance
with Article 16 of the Waste Framework Directive? For instance, should
measures to confine the export of household waste to encourage the
development of indigenous recovery infrastructure be considered?
(10)
In addition to measures already introduced or proposed, including the landfill
levy, the roll out of the brown bin and the potential introduction of pricing
structures which incentivise householders to manage their waste in
accordance with the hierarchy, are there further measures (e.g. the provision
of information on the various waste types that can be deposited in the dry
recyclables bin) you deem necessary to give effect to the waste hierarchy in
the context of household waste collection?
b. Deliver mandated service levels
In order to secure flows of quality recyclates and organics to provide a platform for
investment in recycling and recovery infrastructure and to maximise the resources
that can be recovered from waste, the mandating of minimum standards in terms of
the segregated collection services to be provided and the collection frequencies is a
useful instrument to further increase the level of recycling in households.
Questions
(11)
Do you think it necessary for the introduction of further mandatory segregation
at source of household waste (e.g. paper, metal, glass, plastic and glass) at
this time?
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(12)
What are your views on the following collection frequencies being mandated in
national legislation (i.e. non-compliance with the below minimum requirements
will result in action being taken against a household waste collector seeking to
have their permit revoked) :
a. household waste collectors provide a mixed dry recyclates collection at
least every fortnight;
b. an organic bin collection is provided at least every fortnight, in accordance
with the European Union (Household Food Waste and Bio-waste)
Regulations 2013; and,
c. a residual waste collection is provided no more frequently than the
collection of the organic bin, however, a collector may have a more
frequent residual waste collection service in circumstances where there is
an acceptable pricing structure to ensure that a financial disincentive
exists for using the residual bin.
(13)
Are there any other issues you wish to raise in relation to mandated service
levels?
c. Pricing Structures
Prevention is at the pinnacle of the waste hierarchy and it is essential that the
appropriate price signals are sent to the waste producer, i.e. the householder to
prevent and reduce the generation of waste. Pay-by-use, whether weight based or
tag/lift based implements to a greater or lesser extent the ‘polluter pays principle’,
ensuring that those who generate waste bear the costs of managing it.
The introduction of a mandatory and well-designed pricing structure for waste
collection would provide a clear financial incentive to the householder to prevent and
recycle waste and would further ensure that waste is managed in accordance with
the hierarchy.
21
The composition of the pricing structure offered to households can vastly influence
their behaviour in terms of:
(i)
Reducing the generation of waste (prevention being the top tier of the waste
hierarchy); and
(ii)
Increasing the segregation of waste (which ultimately influences how that
waste can be treated, the greater the degree of segregation the greater the
chance the waste will be prepared for re-use, recycled or otherwise
recovered).
The Regulatory Impact Analysis8 (RIA) which accompanied the publication of the
national waste policy considered the option of price regulation (the setting of prices,
price floors, price ceilings etc.) as inappropriate. However, the RIA did recommend
regulating the pricing structures which apply to household waste collection services
to ensure that pricing structures incentivise householders to reduce waste and
segregate recyclates in defined categories.
A Study of Pay-by-use Systems for Maximising Waste Reduction Behaviour in
Ireland9 published in 2011 estimated that:

46% of households used differential bin-based charges (flat fee),

34% used tag-based charges (either pay-by-lift / tags)

and 20% used weight based charges
The study concludes that weight-based charges are the single most effective Payby-use (PBU) system in terms of waste prevention, waste recycling and diversion of
waste from landfill. These charges prompted the highest per household recycling
levels (between 27% and 32%), highest diversion rates from landfill (between 28%
and 35%) and the lowest total kerbside waste figures (between 800kg and 947kg per
annum). The study projected that if the estimated 80% of those households across
8
http://www.environ.ie/en/Environment/RHLegislation/FileDownLoad,30784,en.pdf
9
http://www.epa.ie/pubs/reports/research/waste/STRIVE_84_web.pdf
Page 47
22
Ireland currently on pay per lift / tags and differential bin systems switched to ‘per kg’
based PBU systems, it could lead to an annual diversion from landfill of
approximately 446,000 tonnes of domestic waste per annum.
The Study examined three separate forms of Pay-by-Weight system:
1. A charge per kg of waste presented, in addition to an annual flat service charge;
2. A “banded” weight-based system using several weight ranges within which the
annual weight of waste presented will fall within, with a different price applicable
to each weight band; and
3. An “average” weight-based system with 800 kg per annum being an atypical
weight – if less than 800 kg is presented during the year, a credit is given for the
following year’s bill; if more than 800 kg is presented during the year, the
customer is billed for the additional weight.
The data from the Study clearly indicates that a ‘pay per weight (per kg)’ form of
weight based-charging is the most effective pricing system in terms of influencing
household behaviour under all indicators, as illustrated in Table 4.1.4 of the study,
reproduced below.
System
Percentage
Percentage
Total waste per
residual waste
recycling
household (kg)
Per kilogramme
weight based
65
32
800
All weight based
72
27
947
Tag based (i.e. Tag or
per Lift)
79
20
928
Differential (i.e. bin
size)
79
21
1,294
The Study highlights the desirability of “providing a continuous pricing signal to
householders” through the charging system. (e.g. when using of a smaller bin (even
at a lesser charge), the householder will not reduce waste costs if they do not fill
23
their bin and thus have no on-going incentive to change their waste management
behaviour to divert waste from landfill any further than is necessary to avoid
exceeding the capacity of the bin size).
The practice of charging a simple flat rate fee (annual or otherwise periodic) for
waste collection services does not appear from the Study to incentivise the
management of waste in line with the national waste policy, the waste hierarchy, the
polluter pays principle and incentivising waste reduction and segregation by
householders. The argument which has been made that by offering the choice of a
large and a small residual bin and applying a smaller annual charge for smaller sized
bin, that due regard is being had for waste prevention. However, the Study identified
that the practice of waste compaction undermined the rationale for the use of the
smaller size bin. Indeed, the STRIVE Study overall finding on Differential Bin-sized
Pay-by-use Charges was that “This PBU system was found to be the least effective
system in terms of impact upon the environment, resulting in a high waste to landfill
rate (79%) and highest total waste of the three PBU systems (i.e. Pay-by-weight,
Tag-a-bag and Differential-Bin-Sizes) studied (1,294kg per household per annum).”
The pay per lift approach results imply that it is more effective than a flat fee
charging system in terms of encouraging waste reduction and recycling. However, in
the case of organic bins the pay per lift approach encourages consumers to wait until
their bin is full and the waste within it is well compacted before having the material
removed, which can mean that unnecessary odour nuisance has been created and
much of the resource value of the material has diminished by the time it is collected.
Applying a per kilogramme pay by weight charging system for organic bins
encourages a more frequent collection of such material and thus ensures a reduction
in potential odour nuisance and a better quality product to the end processor.
The RIA recognised the cost to industry in moving over to a pay by weight system,
but, on the basis of the findings of the STRIVE research Study, asserted that “A
transition to weight based charging on a national basis could be achieved relatively
cheaply, in view of the potential benefits.”
24
Questions
(14)
Should the practice of household waste collection companies charging a
single flat rate fee (annual or other periodic fee) be expressly prohibited in
legislation given that the practice appears to run contrary to the ideals of the
polluter pays principle and the waste hierarchy?
(15)
Given the overwhelming arguments in favour of the per kilogram weight form
of Pay-by-use, on what basis should it be introduced and what are the
appropriate transitional arrangements?
(16)
In order to incentivise source segregation of organic waste by householders in
the brown bin, how can the charging system be designed and structured so as
to avoid wilful consignment of non-organic material to the brown bin? What is
the appropriate balance between the rate per kg for organic waste deposited
in the brown bin and the rate per kg for residual waste deposited in the black
bin?
(17)
Should a ‘pay per weight (per kg)’ charging system be mandatory for
household waste collection, how can the balance between the variable cost
‘pay per weight (per kg)’) element of the charge and the fixed cost (standing
charge) element of the charge be best achieved?
(18)
Traditionally in many instances the dry recyclate bin has been provided ‘free
of charge’ by waste collection operators. Do you consider it appropriate that
the green bin for dry recyclables should continue to be collected free of
specific charge?
(19)
What do you think of the proposal that where a standing charge is being
applied, that it should be uniform, i.e. an operator would be obliged to impose
the same standing charge for the provision of 3 bins or 2 bins (where the
householder is disposing brown bin waste in accordance with the European
Union (Household Food Waste and Bio-waste) Regulations 2013?
25
(20)
What are your views on a regulatory approach whereby non-compliance with
any new pricing structure requirements would result in action being taken
against a household waste collector seeking to have their permit revoked?
(21)
Do you consider it appropriate that any new pricing structure requirements
which may be introduced should apply universally and be included as binding
obligations in legislation as opposed to being attached to individual permits as
conditions in particular functional areas?
(22)
Are there any other issues you wish to highlight in terms of pricing structures?
“A Resource Opportunity” established the following policies for the household waste
collection permitting structure:
 The collection permitting system will be strengthened further so that:
o robust controls are in place to ensure that only “fit and proper”
individuals and companies are allowed to hold such permits and
appropriate corporate governance arrangements are implemented;
o Permit fee structures reflect the value of the permission to collect waste
conferred by a permit, the need to contribute to the costs of essential
enforcement of the permitting system and the potential liabilities for the
state which may arise from poor collection and management practices.
“A Resource Opportunity” also established the following policies for the inspection
and enforcement of household waste collection permits:
o Inspection and enforcement resourcing for collection permits will be
increased, funded in part by the revised permitting fee structure.
“Fit and proper” person
Notwithstanding the discretion of a local authority to decide that a person may still be
regarded as “fit and proper” despite been convicted of a scheduled offence 10, under
current legislation a ‘fit and proper person’ applies to a person if—
(a) neither that person nor any other relevant person has been convicted of an
offence under the Act, the Environmental Protection Agency Acts 1992 and
10
Article 17(3) of the Waste Management (Collection Permit) Regulations 2007.
26
2003, the Local Government (Water Pollution) Acts 1977 and 1990 or the
Air Pollution Act 1987,
(b) in the reasonable opinion of the nominated authority, that person or, as
appropriate, any person or persons employed by him or her to direct or
control the carrying on of the activity to which the waste collection permit
relates or, as the case may be, will relate has or have the requisite technical
knowledge or qualifications to carry on that activity in accordance with the
waste collection permit and the other requirements of the Act,
(c) in the reasonable opinion of the nominated authority, that person is likely to
be in a position to meet any financial commitments or liabilities that will be
entered into or incurred by him or her in carrying on the activity to which the
waste collection permit relates in accordance with the terms thereof or in
consequence of ceasing to carry on that activity;
Given the strategic importance of the waste industry to society’s welfare, the
economy and the welfare of the environment, it is imperative that individuals and
companies who have been found to be in serious breach or repeated breach of
waste legislation not be allowed to continue to hold a waste collection permit. In
addition, those in the industry must have the technical competence and financial
capacity to operate this vital service. In certain circumstances, it may be appropriate
for the permitting authority to require a waste collector to undertake formal training
so that the collector will gain the competence to engage with the State authorities
‘on-line’ in terms of applications/reviews of permits and completing annual returns.
This should reduce the administrative burden for all parties involved and facilitate
smoother data flows.
Another element of the ‘fit and proper’ test relates to the ability of a collector to make
adequate financial provisions in order to discharge their obligations as imposed by
the permit. Current practice in this regard requires waste collectors to include a
financial commitment declaration with their application for a permit / review. It is
understood, however, that some financial governing bodies have advised their
27
members not to sign such declarations. Whether such an approach is fit for purpose
has been questioned.
The waste policy requires that “appropriate corporate governance arrangements are
implemented”. This could be dealt with through the assessment of an applicant as a
fit and proper person. Undertaking formal training courses on corporate governance
could be a condition, if appropriate, to granting of a waste collection permit.
Questions
(23) Current legislation permits a local authority to regard a person as ‘fit and
proper’, if it considers it proper to do so, even if the person has been convicted
of a specified offence. Should a local authority still retain this flexibility or how
should the circumstances whereby a person is considered as ‘fit and proper’
(notwithstanding the fact they have been convicted of a specified offence) be
defined?
(24) Would you consider it reasonable that a household waste collection
company/operator would have their waste collection permit revoked if they
amassed a designated number of specified offences or administrative fines in a
specified rolling period (e.g. mixing source segregated waste such as organic
and residual waste in a collection vehicle)?
(25) Should authorities be given additional powers to require collectors to furnish
evidence that a person is ‘fit and proper’ in terms of qualifications, experience,
financial provisions in relation to the company’s ability to meet the financial
commitments or liabilities that the EPA reasonably considers will be incurred in
carrying on the activity?
(26) Is it necessary to have a specified level of both motor and public liability
insurance to be considered a ‘fit and proper’ person?
(27) Do you agree that the technical competence of an applicant should include
skills such as computer literacy for submission of annual returns? Do you think
28
it appropriate that authorities could require a waste collector to undertake an
accredited training course(s) to ensure they possess the required level of
technical competence, particularly in the IT, corporate governance and record
keeping fields?
(28) Should there be an onus on operators to demonstrate that they are ‘fit and
proper’ on an annual basis, such as a declaration that the operator has not
been convicted of any specified offences? Operators could be required to
obtain a Certificate of Compliance from the National Waste Collection Permit
Office on an annual basis based on such a declaration, which could also
include, for instance, that the waste collector has submitted their annual data
return under Regulation 20(2) (f) of the Waste Management Collection Permit
Regulations. Are there other provisions which ought to be included in such a
proposal (e.g. confirmation that a Customer Charter is in place, an appropriate
pricing mechanism is in place etc.)?
(29) Are there any other issues you wish to raise in terms of only ‘fit and proper’
individuals/companies are allowed to hold waste collection permits?
Waste Management Collection Permit Fees
Under Article 20(3)(d) of the Waste Collection Permit Regulations 2007, a local
authority can impose a Condition on a Waste Collection Permit that allows it to
recoup the reasonable costs incurred in inspecting, monitoring, auditing and
enforcement of the waste collection activity.
The policy clearly requires that the permitting fee structure be reformed so that
permit fees for household waste collection reflect the economic value of collecting
the waste; the risk associated with undertaking the activity; and the cost of enforcing
the permit.
29
Notwithstanding the fact that waste can become a commodity and in certain
circumstances assume a positive financial value, there is an intrinsic economic value
associated with being conferred with a permit to collect household waste.
In terms of addressing the risk element associated with waste collection activities,
this can be to a greater or lesser extent offset by raising the permit fees to act as a
form of insurance against undischarged liabilities due to the collapse of any
individual waste collection firm.
A ‘one size fits all’ approach may not be an appropriate approach to setting permit
fees, given the differing scale and extent of waste collector operations. The
economic value of collecting waste, the potential liabilities associated with the activity
and the costs of enforcing a permit are very much dependent on the scale and extent
of the operation concerned.
However, permit fees could be structured on a fixed and variable basis, the fixed
charge reflecting the cost of processing and the on-going administration of the
permit, while the variable element could be based on the extent and scale of the
waste managed or the number of refuse collection vehicles used to carry household
waste in a company’s fleet.
Currently, the fees payable for a waste collection permit are €1,000 for a single
region permit and €5,000 for an all-region permit. The permits cover different classes
of waste collection, including household waste collection. Amending the permit fee
structure for household waste collection may require an overhaul of the fee structure
for other classes of waste collection. Such matters can be discussed at a later date
post this consultation process, though views are sought on the proposal set out in
Question 30 below.
In addition, there are now three waste management planning regions as opposed to
ten and this may be an opportune time to update the waste collection permitting
system in terms of single / multi-region permits. Given the reconfiguration of local
authorities into three regions, now may be an appropriate time to give consideration
30
to basing the waste collection permit fee on the type of waste and the scale and
extent of the activity being undertaken rather than simply on where the waste is
being collected.
Questions
(30) The waste collection permitting regime in general could be reformed in terms of
introducing different classes of waste collection permit (based on EWC codes)
and associated suitable permit fees. Permits could be granted on a national
basis rather than on a regional basis. Each class of permit would have its own
standard conditions. In terms of reforming the permit fee structures generally
for waste collection, including household waste collection,
(a)
(b)
(c)
What are your views on the following classes of waste collection permit
being established?
Are there other ways of restructuring permits which you would see as
more beneficial / practical?
Do you think it reasonable that a cap would be set for the fees for
waste collection firms who would require more than one permit?
Class
Description
Fee
Class 1
Collection of waste for preparation for re-use
(registration only)
A
Class 2
Haulage of bulked waste from authorised waste
facilities (non-hazardous)
B
Class 3
Haulage of bulked waste from authorised waste
facilities (including hazardous)
C
Class 4
Single code /waste type, (non-hazardous)
collection e.g. scrap metal, septic tank sludge,
C&D
D
Class 5
Single code / waste type, (including hazardous)
collection e.g. oil interceptor, ELV’s
E
Class 6
Multiple waste type collector (non-hazardous
waste)
F
Class 7
Multiple waste type collector (including hazardous
waste)
G
Class 8
Household kerbside waste collector
H
31
(31) Taking into account the need for the cost of a household waste collection
permit to reflect the economic value of collecting the waste; the risk associated
with undertaking the activity; and the cost of enforcing the permit, at what level
do you think the household waste collection permit fee should be set? Should
the fees be different for the various classes of Collection Permit as proposed in
previous question?
(32) Is there merit in structuring the fee in such a way that there is a fixed element
and a variable element to the fee, so as to reflect the risk associated with larger
volumes of waste being collected? For instance, what are your views on the fee
comprising a fixed charge price plus a variable charge (based for example on
the number of waste collection vehicles used by an operator)?
(33) Is there merit in structuring the permit fee do that the enforcement cost element
is clearly distinguishable?
(34) Should waste collection permits be issued only at a national level or is there still
a need for regional permits?
(35) Are there any other issues you wish to raise in terms of waste management
collection permit fees?
“A Resource Opportunity” established the following policies for the household waste
collection customer charters:
All household waste collection service providers will be required to put in place
Customer Charters, clearly setting out information for customers in relation to issues
such as charging structures, procedures for dealing with customers who may fall into
arrears, and arrangements for switching from one waste collector to another. These
will be audited annually as part of the permitting process.
Following the publication of A Resource Opportunity a number of waste collectors
have already put customer charters in place ahead of the regulatory requirement to
do so.
32
The policy requires that all waste collectors have customer charters in place and it is
proposed that such a requirement be a condition of the grant of a waste collectors
permit. The Regulatory Impact Analysis set out requirements which should be
included in such a charter.

Clear information on charges and pricing structures;

Clear information on other terms and conditions;

The provision of payment options by firms to households;

How households can access their account statements and balances;

The provision of clear information to households on the ownership of bins and the
policy and procedure should a customer wish to return a bin;

Procedures for the handling of billing disputes and other complaints about service
levels made by households;

Procedures for the refund of standing charges in the event that a household
switches from one firm to another mid-term;

The treatment of households which have fallen into payment arrears, including
protocols concerning debt collection; and,

The provision of information about how a household may cancel a service
provided by a firm.
Questions
(36) See question 28 in relation to an operator being requested to confirm annually
that they have a customer charter which meets specified requirements.
(37) Are there further conditions, additional to those listed above, which should be
included in a customer charter, such as the provision of better or more
information to customers on preventing and segregating waste?
(38) Do you think it reasonable that an operator would be required to make a copy
of their waste collection permit available on their website?
(39) What measures could be introduced to ensure that the commitments contained
in customer charters are delivered? For example, should household waste
33
collectors be obliged to publish statistics on the commitments made in their
customer charters (e.g. publication of performance indicators such as the
number / percentage of collections are made on-time etc.)?
(40) Are there any other issues you wish to raise in terms of customer charters?
“A Resource Opportunity” established the following policies for the reduction of
nuisances and the health & safety of household waste collection:
Measures will be introduced through the strengthened collection permit system to
manage better the nuisance, emissions and health and safety risks of overlapping
household waste collection networks.
There is an opportunity to introduce ‘binding obligations’ which would apply to all
waste collectors in terms of managing the noise/nuisance/health & safety issues
associated with competing household waste collectors operating in the same area.
Disamenity may be caused when waste is being collected on four or five different
days in a given area. Health and safety issues may also arise when multiple
competing operators collect waste on the same day.
Whatever the solution to these issues, a balance needs to be struck between having
a national approach and the need to address local issues arising, such as a
requirement for local traffic management plans, etc.
The Regulatory Impact Analysis identified a number of options in this regard. One
option would be to regulate the hours during which household waste collections
could occur, to minimise the risk of a serious or fatal road traffic accident and to
reduce the nuisance value of multiple refuse collection vehicles and crews collecting
from housing estates.
The RIA also proposed an alternative solution whereby refuse collection vehicles
could be required to operate under a certain decibel threshold, for example by using
electric vehicles, in residential areas. A requirement to progressively introduce
compartmentalised refuse collection vehicles could also be put in place, to reduce
34
the number of waste collection journeys made by a waste collection firm on any
given street.
It has been suggested that the issue of managing nuisance can be best resolved
through each local authority issuing waste collection bye-laws by requesting, for
example, that all household waste collection within a functional area be undertaken
on a particular day. The advantage of such an approach is that any nuisance caused
by waste collection (e.g. noise) is confined to one day of the week within a particular
area, though this may raise health and safety issues. In addition, bye-laws issued at
a local level can take account of local traffic management issues.
Questions
(41) Do you think it appropriate that measures be introduced at a national, regional
or local level in terms of better managing the nuisance, emissions and health
and safety risks of overlapping household waste collection networks?
(42) Should times be specified when waste collection is prohibited? Should this be
established at a local, regional or national level?
(43) Bearing in mind the potential costs associated with upgrading waste collection
fleets and the potential knock-on costs for consumers, what are your views on
requiring waste collection fleets to:
a.
operate under a certain decibel level?;
b. introduce compartmentalised refuse collection vehicles so that different
streams of waste can be collected by the same vehicle, reducing the
number of waste collection journeys?
(44) Are there any other issues you wish to raise in terms of managing the nuisance,
emissions and health and safety risks of overlapping household waste
collection networks?
35
“A Resource Opportunity” established the following policies for the households:
All householders will be obliged to demonstrate that they are availing of an
authorised waste collection service or are otherwise managing their waste in an
environmentally acceptable manner, in accordance with legislation and the
provisions of waste management plans, in order to combat illegal fly-tipping, littering
and backyard burning of waste by a minority of households, and to avoid the
compliant majority having to bear the costs of dealing with the consequences of such
activities.
To support households, awareness and education measures will be strengthened;
the waste collection industry will be encouraged to play a role in such measures.
“householders will be obliged to demonstrate that they are availing of an
authorised waste collection service or are otherwise managing their waste in
an environmentally acceptable manner,”
The EPA’s most recent National Waste Report (2011) estimates that approximately
70% of occupied Irish households availed of kerbside collection in 2011. In some
areas, participation rates (in a collection scheme) were as low as 37%; while in some
of the larger urban centres, coverage was reported to be close to 100%. The report
notes that part of the low participation issue may have been due to no kerbside
collection service being offered, particularly in rural areas, while the STRIVE Study
on Pay-by-use noted that a nationwide survey of 130 households without a waste
collection service found that 31% live in an area where a waste collection does not
operate. However, the National Waste Report (2011) notes that the EPA is working
with the CSO and other stakeholders to include some household waste management
questions in an environment module in the Central Statistics Office’s Quarterly
National Household survey (QNHS) in late 2013. This will provide a more statistically
robust and valid survey of household waste management behaviours to assist in the
implementation and evaluation of national waste policy. Notwithstanding the above,
a figure in the order of 30% of households not participating in an authorised waste
collection service begs the question as to how such waste is being managed.
36
A number of local authorities have already introduced waste collection bye-laws to
require householders to avail of a permitted waste collection service or to prove to
the satisfaction of an authorised officer that they are managing their waste in an
environmentally sustainable and acceptable manner, or face fixed payment notice
fines.
“awareness and education measures”
Local authorities, the EPA and the waste collection industry all have a role to play in
terms of implementing this measure. Many initiatives are currently in place, including
measures under the National Waste Prevention Programme, such as the Local
Authority Prevention Network11, which aims to develop capacity in prevention in all
local authorities to assist commercial and community initiatives or the Stop Food
Waste12 initiative.
Questions
(45) Do you consider the introduction of fixed payment notices (otherwise known as
on the spot fines) as a suitable penalty for householders who are not availing of
an authorised household waste collector and who cannot demonstrate they are
managing their waste in an environmentally sustainable and acceptable
manner? If not, what other sanctions would you deem appropriate?
(46) What are your views on waste collection companies being required to maintain
a register of household waste customers as a permit condition whereby a local
authority can request the collector to verify whether a specific householder is
availing of a service being provided by that operator?
(47) Are there any other issues you wish to raise in this section?
11
http://localprevention.ie/
12
http://www.stopfoodwaste.ie/
37
“A Resource Opportunity” established the following policies for the compliance with
and enforcement of household waste collection requirements:
The environmental regulatory regime governing the waste management sector will
be kept under on-going review, in order to ensure that any unnecessary
administrative burden is identified and reduced, while maintaining an appropriate
balance with the need for effective oversight and reporting.
The Department is committed to exploring ways to reduce duplication or inefficiency
of information flow, and to modernising and streamlining such processes wherever
feasible, in such a way as to reduce unnecessary administrative costs that may arise
both for business and for the public sector. However, this must be achieved in a
manner which does not diminish in any way the protections afforded to the
environment, citizens and society at large.
The Department’s Statement of Strategy 2011-2014 states that “while delivering on
our environmental obligations, we will work with stakeholders to reduce the burden
on business by simplifying administrative procedures, and by reducing the quantity
and improving the quality of regulation.” In addition, Regulation 5(5) of the Waste
Management (Collection Permit) Regulations 2007 provides that:
“Insofar as possible, local authorities shall co-operate to ensure an efficient
administration of the waste collection permit system to reduce the administrative
burden for applicants”.
Questions
(48) Do you have specific proposals in terms of reducing the administrative burden
for those complying with Waste Management (Collection Permit) Regulations
2007? For example, what are your opinions on:
a) introducing ‘binding obligations’ that apply nationally in the legislation to the
greatest extent possible to simplify the permitting process across local
authority and regional boundaries;
38
b) allowing operators to submit data on an on-going basis rather than making
an annual return;
c) publishing notices required under Regulation 6 of the Waste Management
(Collection Permit) Regulations 2007 on the National Waste Collection
Permit Office website rather than in national or local newspapers;
d) introducing greater scope for interactions with the regulatory authorities to
be carried out ‘on-line’;
e) making an application available ‘on-line’ on the National Waste Collection
Permit Office rather than available for inspection at local authority offices;
f)
introducing general binding rules for applying standard conditions to a
particular class of waste collector permits, any additional requirements
could be region specific rather set than at a local authority level;
g) allowing permit conditions to be carried on each vehicle without the
appendices, as these are readily available on the National Waste Collection
Permit Office website;
h) allowing a permit holder name or permit number to be displayed on the
vehicle – this would reduce the need to reprint new permit numbers on all
vehicles in the case where a new permit number is issued;
i)
making the process of application and renewal (prior to expiry) for a waste
collection permit the same procedure, introduce a separate process for
reviewing a permit (e.g. whether instigated by an enforcement authority on
suspicion of non-compliance or the waste collector in order to surrender or
transfer, or amend significantly a waste collection permit) and allow minor
technical amendments to be made without the requirement of a full review;
39
j)
streamlining/better clarifying
the timelines set out in the Waste
Management (Collection Permit) Regulations 2007 in terms of applying for
a permit, review, submitting annual return data, submissions from third
parties in relation to an application for a waste collection permit, etc.
(49) Are there any other provisions in the Waste Management (Collection Permit)
Regulations 2007 which could be improved / streamlined to reduce the
administrative burden of complying with waste collection legislation?
40
9.
Providing Your Views
The consultation period will close on Friday, 31 January 2014.
As previously stated, the questions posed in the paper are intended to facilitate
discussion, however, submissions on any issues relating to household waste
collection (whether discussed specifically in this paper or not) are now being invited.
Please provide responses to this consultation document using the following options:
By email to: household.waste@environ.ie
By post to:
Household Waste Consultation
Waste Policy and Resource Efficiency
Department of the Environment, Community and Local Government
Newtown Road
Wexford
Should you have any queries about the consultation process, please feel free to
enquire using the above contact details.
The Department of the Environment, Community and Local Government is subject to
the provisions of the Freedom of Information (FOI) Acts 1997 – 2003 and all
submissions received in relation to this public consultation will be subject to these
Acts. The Department is also subject to the provisions of the European Communities
(Access to Information on the Environment) Regulations 2007-2011 and all
submission will also be subject to these Regulations. The submissions will also be
published on the Department’s website (www.environ.ie)
Next Steps
Submissions received will inform the drafting of legislation to reform the regulation of
household waste collection.
41
Appendix 1
42
Appendix 1 (continued)
43