The Manx Nationalist Party - Advocating Republican Independence since 1963

The following submission was made to the Isle of Man Department of Local Government and the Environment in response to consultation on the Wste management Strategy - October 2005.

The document should be read in conjenction with the DLGE's consultation

Waste Management - An overview

Mec Vannin, since its earliest days, has recognised the necessity of an "environmentally friendly" approach to waste management. The necessity is formed of three basic components:

1. It is ultimately far more expensive to import and throw away then to reduce, reuse or recycle.

2. It is not physically possible to endure such a policy of disposal.

3. The indirect negative results of such a policy far outweigh its benefits in terms of  expedience and low direct cost.

Opponents of what are referred to as "environmentally friendly" policies immediately cite cost and practicallity as an inhibitor. Such people either have a vested economic interest in pursuing such a policy or do not have a full appreciation of cause and effect.

The government in the Isle of Man recognised the harsh reality that simple land-fill was impossible to sustain some twenty years ago. Incineration was identified as a quick-fix alternative.

Mec Vannin opposes incineration as a bulk waste disposal option.

Since it was decided that incineration would form the primary method of waste disposal in the Island, government policy has been drawn up so as to give the appearance of a structured policy with incineration as a final option. In reality, little appears to have been done to back this up.

Reduction: In the 15+ years that incineration has been the objective of the DLGE, no policies have been instituted to reduce the volume of the waste stream to start with.

Re-use: In the same time span, there is no eveidence that any policies have been instuted to encourage or force the re-use of materials.

Re-cycle: The general public has demonstrated its willingness to cooperate with recycling initiatives such as bottle, paper and clothing banks. This goodwill has all too often been ignored and undermined by the DLGE which has, in the past, dumped segregated materials on the excuse that it was uneconmic to recycle them.

A meeting with the previous minister confirmed that newspapers, segregated so concientiously by the public, are being used to pack-out the bulk required for incineration.

All these combine to confirm our position that the DLGE has not been adhering to its own policies. Nor has the government operated cohesively, most especially between the DLGE, Treasury and DTI, to provide the structures necessary to make them work. Mec Vannin submitted to government in the mid-1990s stating the requirement to do this.

Such alternative waste disposal options that have been established are on an ad-hoc basis, usually by private enterprise when there is a market available.

This has been the complete reverse of how the process should have been tackled.

The Treasury and DLGE have had over 15 years to introduce fiscal measures to discourage  waste at source. This could include packaging tax, as suggested by Mec vannin in the mid 1990s. Taxes could be levied on new materials when reusable ones are available. Fiscal measure could be used to change both domestic and commercial purchasing and disposal habits. this opportunity has not been taken.

Early measures should have been taken to encourage segretation of re-usable and recyclable materials. contrary to the claims made in the consultation paper, both the public and business sector have shown great willingness to co-operate with such initiatives without the need for "incentives". Naturally, commercial activities in particular will be discouraged if they have to spend any time and expense in this but if the means are provided, most will comply. Only after this is in place, should negative incentives be considered.

The opportunity to create industry in the Island as part of the recycling initiative have been largely ignored. Again, the Treasury, DTI and DLGE have had 15 years in which to establish operations that take recyclable waste and create useable materials for our own consumption.

Card and paper can be readily recycled to produce packaging card and mashe. Much of the  wood ripped out and burnt / dumped could be readily remachined and used were that to be economically preferable to bying new timber. Thousands of tons of inert building material has gone into landfill when it could have been segregated and "banked" to provide a source of hardcore and infill material for construction projects.

Composting is finally being looked at but this should have been available from the start. Onchan Commissioners tried a pilot project in the 1990s that was not succeesful. It failed because, in such an isolated pilot scheme and without help from central government, it proved simply too expensive as an ad-hoc project.

As one of the major sources of domestic waste, composting would have had a huge impact on waste volume had it been introduced years ago. Experiments in composting show that it is successful with most organic materials when carried out correctly. This includes light plastic materials and card.

We support kerbside segregation and collection of re-usable and recyclable materials but the proposed costing structures are contentious to say the least. The lack of clear direction in the DLGE once more becomes clear. A central, all Island policy on how to manage waste is essential if it is to be successful but the DLGE wants to dump responsibility for implementation and costing on the Local Authorities.

Central governemnt must provide all facilities, available to all at a uniform rate. The   method of charging must be consistent or there will be chaos.

In this, the "user / polluter pays" principle has been, at least in part, misinterpreted. Government has allowed (even encouraged) a society to develop that cannot avoid producing waste. Much of this waste is imported. Who is the polluter? The person who consumes a food item supplied in non-re-susable / recyclable packaging or the vendor who supplies it in that form?

The document acknowledges our expressed concern that illegal dumping will ensue if costs are prohibitive, despite having this concern rejected by the previous minister.

If the domestic household is to be charged on a pro-rata basis for waste, then the methods of measurement must be in place beforehand, not later.

It is irrational to fix a price and then subsidise it as is happening at the moment. Domestic users should be afforded a waste allowance before charges are incurred. Commercial operations may require a different structure as the nature of waste will differ from case to case. In all instances, however, a prohibitively high cost of disposal will result in illegal dumping and economic hardship for some, at least.

An affordable disposal cost should be identified and any disparity between that cost and the actual cost of disposal be met through the department's budget.

There should be no disparity between the cost of like for like types of waste between domestic and commercial waste.

Only non-segregated, non re-usable / recyclable waste should incur the pro-rata disposal charge in the domestic environment at least.

The incinerator is supposed to be a "last resort" method of dealing with waste. The current practice of burning re-usable / recyclable material to maintain a certain bulk should be discontinued, especially as the operation is a net consumer of energy.

We are not entirely negative about the document, but have not had time to properly study its implications: Only a month while Treasury has also put out three consultative documents with a mere month and the DHSS also have an entire draught bill with the same time for input.

If government departments genuinely want quality input from consultation, it will have to learn to co-ordinate itself a little better.

In summary, we feel that the DLGE has failed to adhere to its own policies. It has failed to liase with other departments to produce an effective, practical policy to aid in the implementation of the stated policies and, while some of the proposals are moves in the right direction, the department has worked completely in reverse.

The priority must be put heavily on reduction of waste at source and shifting at least part of the cost of waste management onto those who produce what will become waste at source, not merely economically penalise those who are effectively forced to throw it away at the end of the process.


31st October 2005

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