The National Waste Management Plan for a Circular Economy - my submission

The National Waste Management Plan for a Circular Economy recently went to public consultation. Of any area in the country, the North Inner City faces unique challenges in terms of waste, litter and dumping. These need to be addressed as a basic step towards a circular economy. Below is the submission I sent in with Neasa Hourigan, T.D. and Feljin Jose, Carba-Glasnevin area rep.

To Whom It May Concern,

Please find the below comments regarding the draft National Waste Management Plan for a Circular Economy. The issues outlined below primarily relate to how waste, litter and dumping are managed for communities in Dublin North Inner City and the considerable road ahead to reach the ideal of a low-waste and circular economy. We also touch on issues of reduction in production of waste at source.

Our area suffers from very significant littering and dumping and is completely under-served and under-resourced in terms of waste management. This leaves an unhygienic, unpleasant and undignified living environment on many streets. In the month of May 2023, over 50 tonnes of dumped waste was collected from the Central Area of DCC alone. Addressing this takes changes in waste management policy at the national level and significant increase in resourcing of Dublin City Council’s role.

There are multiple reasons why inner-city communities suffer so disproportionately with litter, waste and dumping. As well as a lack of personal responsibility among those offending, there are also issues with the types of tenancies and behaviours that proliferate in this part of the city. Dublin North Inner City has a high concentration of short-term rented accommodation where tenants struggle to negotiate the costs and responsibilities of a bin contract between often large numbers of shared housemates. We are also aware of landlords who do not make tenant aware of the need to have a waste contract and actively encourage their tenants to dump rubbish for Dublin City Council to collect. There are also issues with people coming from outside the area dumping waste in inner-city residential areas which they would never do in their own home areas and showing contempt for people living here. Finally the high number of households that rely on bags as their main form of disposal leads to confusion and often bags being left out on the wrong day. When seagulls and other creatures rip these apart this adds to the unhygienic nature of the streets.

We call on the Minister to declare Dublin North Inner City as a uniquely challenging litter and dumping hotspot for which the current waste system doesn’t work and that requires unique solutions. Some of these potential solutions we have outlined below but significant further investment and exploration of possible solutions is needed.

Cllr. Janet Horner, North Inner City

Neasa Hourigan, T.D., Dublin Central

Feljin Jose, Local Area Rep for Cabra-Glasnevin

Provision of brown bins/organic waste facility

Many inner-city homes don’t have access to a brown bin at home which is adding to landfill and causing issues with composting. We need solutions so every home in the country can compost food waste. In inner city areas, we need community composting and smaller brown bins that allow people a hygienic way to manage brown waste in their households. This needs to be given urgent priority to save as much waste as possible from landfill.

Provision of Green Bins

Many Dublin City Council flats still don’t have green general recycling bins. This is appalling when the state should be leading in this area and recycling has been mainstreamed in privately owned homes for well over a decade. We need a rapid and immediate roll out of green bins to all households in the country - most especially those in state-provided housing. An ambition should be set for every home in the country to have access to a green recycling bin by the end of the year. 

Shared Bins

Ultimately in inner-city areas, we need to invest in shared bins for residential areas to allow for waste separation and also the elimination of bags which are not only unsightly and obstructive on footpaths, but also often ripped apart by seagulls, foxes and other urban creatures who share our streets. Shared bins will require significant investment but have demonstrated to be very successful in other city environments, such as Portimao in Portugal and Utrecht in the Netherlands. While a trial is about to start in Dublin City Council, we need the resources to scale this up rapidly once the trial is complete.

Changes in legislation needed

Where residents are dumping because they do not have a waste contract in place, the Council needs greater resources and powers to pursue them in the courts and ensure compliance with both litter and dumping instances. 

Where offenders are renters, we need a change in legislation so that landlords are responsible for ensuring that their tenants have bin contracts. This is particularly important in cases of overcrowded accommodation where it can be difficult for a large number of sometimes short-stay tenants to assign responsibility for holding and paying for the bin contract. 

We also need our LAs to be resourced to experiment and find solutions through shared bins, underground bins etc. 

Finally we need to aim towards re-municipalisation of waste collection - at least for city centre areas. Privatisation of bins has simply failed and the result has been a massive amount of litter, dumping and unhygienic conditions for people living and using the inner city. 

Data gathering from bin companies

Companies are currently not obliged to disclose information to local authorities about how and where waste is disposed of and the extent to which it is recycled or sent to landfill. This is important information to measure the effectiveness of domestic recycling and also for building public trust and buy-in to waste separation. There are regular stories of residents seeing bin company staff throwing all separated waste into the same bin which seriously erodes public trust in the ambition of recycling and their own personal responsibility. 

Bring Centres in the Context of the 15 minute city

In spite of the stated ambition of achieving both a circular economy and a 15-minute city, we are seeing a significant retrenchment of recycling services in the north inner city which goes against both these ambitions. Both the Shamrock Terrace and the Grangegorman bring centres are due to be reduced in capacity in the coming months. Both these centres are the only centres within walking distance for many of the residents in the north inner city. This is the only LEA in the country where the majority of households don’t own cars so are disproportionately reliant on services within walking and cycling distance. This is totally unacceptable and needs to be addressed in a collaborative way between government departments and local authorities to ensure the widest possible range of recycling facilities bringing the circular economy into reality. Part of this means resourcing local authorities to revise their bye-laws to remove the barrier of the bring centres being 50 metres away from residential areas and open additional services. Currently, there are no sites in the north inner city which meet this criteria which would allow for additional services to be opened. 

Cities should also invest in collection services, such as DCC’s bulky waste service, for other items such as paints, white goods, clothes etc either on a regular or an arranged basis so that recycling and safe disposal is made possible for those for whom carrying a large number of items to a nearby bring centre is not an option.

Finally, bring centres should accept recycled waste for free and brown, organic waste in inner city bring centres particularly where people do not have the option to dispose of it at home.

Deposit-Return Scheme

The deposit-return scheme was launched in 2022 and offers a significant incentive to people to recycle their drinks bottles and cans. It will also encourage people to collect litter in this form too. However, the scheme has been slow to be rolled out and currently there are no deposit-return venues in Dublin North Inner City where littering is most acute! The scheme should be scaled up so it can play a part in turning the tide on litter and dumping locally.

Reduction in the amount of goods produced

Ultimately, we need to less goods and packaging to be produced at source. The onus needs to be on companies to reduce the amount of packaging they use and stop externalising the costs associated with disposing of this packaging. Additional incentives and penalties need to be implemented to move shops towards low/no packaging options.

State services should take the lead

All state services and state-funded services should be obliged to choose sustainable materials. Some of the privately run, but publicly funded IPAS (International Protection Accommodation Services) centres in our constituency use single use small plastic bottled water for all their drinking water. This is a shockingly unsustainable practice for a state-funded service and a condition should be placed on all publicly funded services to establish more sustainable means of working. 

Managing Construction Waste in a Busy City 

It is a positive development that the requirements around construction waste are now more tightly controlled than they have been in the past and that some contractors provide further sorting and management above regulatory requirements. Urban areas such as Dublin can be significantly affected by waste and dust from construction sites in the city. 

Despite positive changes the C&D sector in Ireland generated an estimated 8.2 million tonnes of waste in 2020 (based on data reported by authorised waste collectors and local authorities). The vast majority (95 per cent) of C&D waste underwent final treatment in Ireland in 2020 and only five per cent was exported abroad for final treatment.

Most of the C&D waste undergoing final treatment in Ireland was recovered by backfilling (82%), while 10% went for disposal and only 8% was recycled. 

There are a number of ways that the state should legislate for more robust waste strategies in the construction sector through building regulation and the planning requirements of local authorities. These include:

• The requirement for an active bill of quantities that refers to waste and the volume of materials onsite. 
• A requirement for supply change management and liaising with suppliers to reduce plastic and packaging waste, reduce wastage through improper storage of products and by products and the use of recycled or recyclable packaging as a default
• Onsite sorting and protective storage of waste material for reuse, recycling and storage. 
• Active management of waste generated and stored onsite during construction to monitor waste streams and excess
• Cradle to cradle supply chain management between suppliers and contractors
• Publication of waste statistics by contractors to communicate performance to the public and the construction sector

Concerns regarding framing of the draft plan:

Regarding the draft plan, there are a few concerning issues which we wish to raise:

• The plan lists the waste collection running at a deficit as a problem that should be corrected. This is a very concerning framing of the issue. Waste collection is a public good and the benefits of a comprehensive waste collection and management service should be through externalised gains and cost-savings and should not be profit making. Providing a clean and efficiently run city will help people to feel pride in it, help social inclusion, add to feeling of safety and support tourism and participation in the city. 
• The plan also attributes the growth of waste to population growth which we disagree with as a framing. There are countries that have many multiples of the population of Ireland and produce significantly less waste. The issue is not the number of people living in the country but the resource intensive and disposable nature of the systems that we live in. 
• Finally, it is proposing an additional €6.6 million a year to resource the plan. We would suggest that we need an awful lot more than that. €6.6 million would barely cover the range of interventions needed in the North Inner City alone to address the issues of waste management.

Immediate Actions

Immediate actions which should be undertaken to address the litter, dumping and dog fouling issues locally include: 

• Better collaboration between litter wardens and An Garda Síochána to allow litter wardens to be accompanied by plain clothes Gardaí. 
• Waste Management representatives should be on the Joint Policing Committees.
• Regular meetings between waste management and local residents/businesses.
• Education campaigns by DCC, particularly in areas with a high proportion of transience, as new residents may not be aware of an area’s waste collection system.
• More frequent and proactive collection of illegal waste by DCC
• Enforcement of section 2.9 of Storage, Presentation and Segregation of Household and Commercial Waste 2018.
• Enforcement action on overcrowding of rental properties.
• Increase the number of public street bins in the area, even if these are used for domestic waste. We’ve seen a decrease in the number of bins in recent years. This is particularly important for disposing of dog foul. The streets are often littered with full dog foul bags.
• Expanding the BagBins across the city if successful.