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Revision of Waste Framework Directive - 28-11-06

On Nov 28, 2006, the Environment and Public Health Committe of the European Parliament voted on a revision to the Waste Framework Directive. The most important issue was a proposal to redefine waste incinerators as 'energy recovery' instead of 'waste disposal' and so position them more favourably in the Waste Management Hierarchy.

The Committee overwhelmingly voted to retain the definition of incineration as 'waste disposal'. CHASE actively lobbied MEPs to achieve this outcome - the following is a copy of the letter from CHASE chairperson, Mary O'Leary, to Irish MEPs.


To: Eoin Ryan; Gay Mitchell; Simon Coveney; Sen Jim Higgins; Sean O Neachtain; Marian Harkin; Mairead McGuinness; Liam Aylward; Kathy Sinnott; Brian Crowley; Avril Doyle; Proinsias De Rossa; Mary Lou McDonald

28 November, 2006

Dear MEP,

Waste Framework Directive

I would like to make representation to you on behalf of all the communities in Cork Harbour Alliance for a Safe Environment (CHASE) on the proposed amendment to the Waste Framework Directive.

It is imperative that incineration remains classified as disposal rather than recovery. Incineration is a ’waste-of-energy’ not a ‘waste-to-energy’ process as the incineration lobby group would like us to believe. There are vast amounts of carbon tied up in waste than can be recovered by far more favourable technologies. Burning it and releasing it into the atmosphere is not alone a waste of resources but reckless in terms of the amounts of excess carbon dioxide being released back into the atmosphere. Waste incineration releases more harmful gases into the environment than the burning of fossil fuels

It is not true that incineration with energy recovery is a greener option than landfill. The two materials that supply a significant calorific value in municipal waste are plastics and cardboard. Plastics consist mostly of oil. In terms of the impact on climate change and our responsibility under the Kyoto Agreement, burning plastics is equivalent to burning fossil fuels. In terms of resource and energy recovery, it is far more efficient to recycle paper than burn it.

For each tonne of waste that is burnt there is approximately the equivalent amount of Co2 released to the atmosphere. This has huge implications in terms of Global warming and the Stern Report has clearly warned Governments of the danger of ignoring the importance of reducing our CO2 emissions. The penalties that Ireland would incur in Carbon taxes will be enormous and it is we the tax payers that will be footing the bill

It must therefore be stressed that waste incineration should continue to be classed as disposal rather than recovery, even if it is used to produce a limited amount of energy.

We would therefore ask you to support the following amendments:

  • Amendments 578-585 and 244, which reintroduce European Court of Justice criteria for energy recovery from waste incineration;
  • Amendment 242, in which incineration is only defined as recovery when it is preferable to substitution;
  • Amendment 480 or 481, which encourage more energy efficiency in MSW incineration.

Overall long-term objectives

A clear 5-step waste hierarchy will ensure that the objectives of the Directive remain beneficial to the environment in the long term. This will stress the importance of prevention, re-use and recycling of waste over incineration and landfill, while encouraging the phase-out of landfill and incineration of materials which can be recycled.

Please also support the following amendments:

  • Compromise amendment 1, which ensures a flexible 5-step waste hierarchy;
  • Compromise amendments 3, 4 and 5 which clearly define each of the steps in the waste hierarchy.

Incineration should have no place to play in Irelands’ Waste Management Strategy. It is possible to meet the Landfill Directive without it and utilise source separation, prevention and a flexible pick and mix option which will contribute to the economic, social and environmental goals of sustainable development.

I would urge you to do all in your power to ensure that incineration remains classified as disposal.

Thanking you

Mary O’Leary
Chairperson - Cork Harbour Alliance for a Safe Environment - CHASE


Cork Harbour Alliance for a Safe Environment
Bishop's Road, Cobh, Co. Cork
Tel - 021 481 5564      Email -
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