GB No. 1(20)/96
Waste Prevention Association was founded in March 1993. This independent and not umbrella association was created as a result of the demand of members of many NGOs, such as the Green Federation, Polish Ecological Club, Greenpeace International and local activists to establish a professional organisation to service the information needs of these groups.
The statutory objectives of the Waste Prevention Association are:
The Association fulfills the above objectives primarily through the use of information banks about Clean Production and environmentally sound waste management methodologies. It collects information about waste management practices which are being introduced in Poland and worldwide; it provides environmental organisations and local authorities with information: materials, databases and contacts; it organises awareness rising campaigns.
The Association's activities todate
Waste Prevention Association has been sponsored, among others, by:
Zagospodarowania Odpadów "3R"
Waste Prevention Association "3R"
P.O. Box 102, 31-829 Kraków 31, Poland
Office: ul. Sławkowska 12, 31-014 Kraków
tel. +48 12 22 22 64, 22 21 47 w. 25
fax: +48 12 22 22 64, 21 21 07
E-mail: (Internet) email@example.com,
At the end of the 1980s, the number of waste incinerators being built in the US and Western Europe dropped drastically. One of the reasons was the incinerating capacity of hundreds of incinerators built in the 1970s and 80s.
However, another reason was scientific evidence indicating incinerators to be major sources of heavy metal emissions (mercury, lead, cadmium, chrome) and organochlorine pollution (dioxins and furans). Public opposition to incinerators grew as people became aware of their dangers. They opposed the building of new incinerators and demanded the closure of existing ones.
One of the first international successes of environmental and social groups campaigning against waste incineration was the ban on ocean incineration, which was to come into force in 1995, but in fact, was achieved by 1991.
In the late 1980s, stricter standards led to more stringent requirements for pollution control equipment on incinerators. This increased the high costs of incineration - already the most expensive waste disposal option. Pollution control technology absorbs some 2/3 of the costs of any incinerator.
Incineration costs have contributed to increased interest in reducing waste at source, recycling and other hazardous waste management options. Ultimately, the only way of reducing waste generation is to move to low- or non-waste technologies, to change the production process to eliminate the use of hazardous materials and replace them with renewable materials or to change consumer behaviour.
The drop in profits for Western incineration companies from the reduced sales of incinerators there, motivated their search for new markets beyond the newly opened borders of Central and Eastern Europe (CEE).
In CEE, awareness of the dangers and problems caused by incineration remains low. Apart from the Czech Republic, none of the countries of CEE have any incinerator regulations. There is no experience or information regarding waste prevention options or organising waste segregation. In addition, there is no market for alternative waste management technologies. The incinerating capacity of existing incinerators is very small. Often, the only obstacle to Western companies wanting to build incinerators in CEE is the lack of money there. To some extent, the companies resolve this financial problem by offering older and therefore cheaper incinerators with poorer pollution control equipment. In addition, proposals to build incinerators are often supported by Western bi-lateral and multilateral funding programmes.
Environmental organisations have an important role to play in informing communities about the dangers of waste incineration, about the alternative options and in putting pressure on the authorities to introduce and enforce regulations promoting waste prevention.
In 1992, environmental groups in Poland first started hearing about many proposals to build incinerators. Greenpeace forwarded us information about some proposals - to build incinerators in CEE to burn waste imported from abroad. They also organised a visit to Poland by Prof. Paul Connett who provided us with useful information and encouraged us to start campaign against incineration.
We started the campaign by collecting information about incinerator proposals from the press and from the regional environmental authorities. From our research, we realised that Poland was being flooded with incinerator proposals to burn all types of waste. By the end of 1992, the building of some 30 incinerators was being considered. Over the last few years, there have literally been hundreds of offers to build incinerators. Those being seriously considered numbered 50 municipal waste burners, 15 hazardous waste incinerators and some 10 for hospital waste.
We registered a new organisation, Waste Prevention Association, to enable us to use the legislative process in fighting incinerator proposals. Polish laws on the siting of investments, undertaking EIAs etc. require the participation of social organisations.
The high number of incinerator proposals meant that we could not fight this battle alone. We started cooperating with other Polish and foreign environmental groups - in particular, Greenpeace. From the beginning, we also worked closely with environmental specialists, economists and waste management experts. In local communities fighting incinerator proposals we also found unusual allies in the church, other polluters...
We also ensured good media relations. We regularly informed the press about our activities by sending them our press releases and publications. Thanks to good media contacts, in many cases, it was the journalists that fought our incinerator battles in the pages of national and local newspapers and on national/regional TV and radio.
The ultimate objective of the campaign is to promote a front-end approach to waste problems by promoting waste reduction and Clean Production. In the short term, our approach is make the public and authorities aware of the dangers of incineration. We also promote more environmentally sound waste management systems, such as waste segregation, composting and recycling.
Because of many incinerator proposals, we have focused our campaign work on municipal waste and hazardous waste incinerators.
Our most important campaign tool is information. For this reason, we have prepared several reports presenting the Polish waste situation, incinerator proposals, alternative technologies and Polish case studies of more appropriate waste management activities. Besides Polish information, we have also collected case studies from other countries. In particular, alternative management systems for hazardous waste, case studies of cleaner technologies and model legislation.
Recently, we completed a database of companies and institutions who provide waste management (including recycling) services and equipment (not incineration). This is the first database of this type in Poland. We hope that it will stimulate better planning and functioning of existing management systems for municipal and some industrial waste streams.
We have also published a guidebook, jointly with the Environmental Law Association , targeting NGOs to show them how they can use the legislative process in their campaigns and explaining the way to register and organise social organisations.
Another important element of the campaign is the use of legal tools. This entails researching legal loopholes and exposing violations of existing laws. Every incinerator proposal investigated by WPA violated some regulation.
One example, is the Environmental Protection Law, which requires the participation of NGOs in decision-making and has been violated in almost every incinerator proposal. Another example concerns the requirement to undertake EIAs before making any decisions on siting the investment. There have been numerous cases, including the Warsaw incinerator, where the location of the incinerator has been agreed prior to doing the EIA. Other violations include the granting of permits to build incinerators by institutions with no authority to do so and the incorrect classification of incinerator investments. However, these violations are not confined to Poland and CEE alone.
Another essential tool of this campaign has been exposing the inadequacies of the project proposal. Our experience in Poland is that the project documentation is generally very poor, in terms of technical, economic and environmental information. Many studies are based on waste generation growth projections which bear no relation to reality - unless one is to assume waste imports from abroad.
The main flaws of project documentation include:
Finally, business plans detailing the raising and repayment of loans for the building of incinerators are often miscalculated.
In the last 4 years, environmental groups in Poland have defeated 27 incinerator
proposals, that would have burnt all types of waste: municipal, hazardous and hospital
waste. This figure includes small incinerators with a annual capacity of several thousand
tonnes, but also large incinerators with capacities of 150-220 thousand tonnes per year.
Of the 75 incinerator proposals mentioned earlier, a significant proportion were withdrawn
for financial reasons. A further 30-40 proposals were rejected by the authorities in their
Case Study: Zychlin (1992-93)
Zychlin is a small municipality in central Poland with a population of 14,000 people. The main activity in the area is agriculture, specifically sugar beet production. The only industrial activities are a sugar beet processing factory and a plant making transformers. In 1992, the Danish company BS Miljoteknik made a proposal to the local government to build an incinerator with a 18,000 ton/year capacity. The incinerator was to burn mainly municipal, but also, industrial waste. The proposal was supported financially by the Danish government who offered Zychlin a soft loan to buy the incinerator. The argument used to support the building of an incinerator was the need to close the local waste dump due to its being full up and its environmental contamination. The proposal was also supported by the Polish environment Ministry. According to one official, the Zychlin incinerator would enable "the operation of an incinerator in Polish conditions to beevaluated".
An assessment of the project documentation prepared by WPA revealed serious mistakes and omissions. The most important shortcoming of the documents was the economic evaluation. To pay back the interest on the loans, the local government in Zychlin would need to ensure that the incinerator was in operation for almost 100 years!
In addition, the quantities of waste to be burn were exaggerated. Zychlin generates about 3,000 tonnes of waste a year - six times less than the amount proposed to be burned. There were attempts to find more waste from around the region, namely 3,000 tonnes of waste plastic. This type of misleading information was used to show that the waste would have a sufficiently high calorific value. The local authority was convinced that the incinerator would make the waste 'disappear'. The documentation made no mention of the need to dispose of incinerator ash - which would, on a weight basis, be the same amount of waste currently generated by Zychlin.
A campaign lasting a year and bringing together all the opponents: the transformer production plant, the sugar beet factory, a dairy and almost all the local community, finally made the local government see sense and reject the proposal.
A few months after defeating the incinerator, the main campaigner against the incinerator was nominated the head of Zychlin's local government. Under his management, the waste dump has been made more secure, waste segregation has been introduced and some 30% of municipal waste generated is now reclaimed. By the end of 1996, a new waste segregation plant is to come on line and a composting plant should be complete.
Case Study: Pustkow ERG (1995)
Pustkow ERG is a factory producing plastics and chemicals. At the beginning of the 1990s, this company starting cooperating with industrial plants from south-east Poland with the objective of creating a consortium. Its purpose was to burn hazardous and municipal waste. The proposed incinerator was to operate for 10 years and burn 10,000 tonnes of waste per year.
The proposal was opposed both by the local environmental group, the Mielec chapter of Green Federation and WPA. Together, the groups reviewed the financial analysis and calculated that the pay back period for the incinerator was 9 years. They revealed that the consortium would not achieve the projected profits. In addition, they found that the projected amounts of wastes to be incinerated were over-estimated. Due to the economic recession and waste minimisation programmes carried out in the factories this amount of waste would not be generated.
These comments were submitted to the management of ERG and resulted in their dropping the proposal.
Apart from stopping the tide of incinerator proposals, our campaign has also achieved several other objectives:
Case Study: Gdynia (1995-96)
Gdynia lies on the Baltic coast next to Gdansk and has a population of 350,000 people. Proposals to build an incinerator in this city date back to the mid-1980s when there was a proposal to build an incinerator next to a National Park!!! Negotiations on the building of an incinerator were still taking place even in 1996. The incinerator was to use German technology from the company KAB, and was to burn 150,000 tonnes a year. KAB was to supply not only the technology but also arrange the finance.
As with other proposals, WPA found many serious flaws in this project documentation:
The presentation of these arguments at a conference attended by the Gdynia authorities and councillors, scientists and inhabitants, created a strong lobby against the proposal. In addition, the World Bank which has a project to monitor and recycle waste in the Gdynia and Gdansk region supported the environmentalists, claiming that "the building of an incinerator in Polish conditions, cannot be economically justified and is not a state-of-the-art solution to waste problems".
For the time being, the incinerator proposal has been defeated, but for how long....
Of the numerous incinerator proposals, only five have been built - four medical waste incinerators (which were not our priority) and one hazardous waste incinerator (which we knew nothing about!)
At present, five municipal and hazardous waste incinerator proposals are under consideration. However, the number of new incinerator proposals has drastically dropped. We are confident that environmental activists will defeat these five new proposals - two are already going our way.
Unfortunately, the number of hospital incinerator proposals continues to increase. This is, in part, due to the support given to the incineration option by the Ministry of Health, the National Fund for Environmental Protection and foreign funding sources eg. PHARE. The afore-mentioned Polish institutions hope to have some 30 regional hospital incinerators, each burning 1000-4000 tonnes of waste a year.
Ironically, a report commissioned by these Polish institutions and prepared by WHO and
UNEP demonstrates that autoclaves and microwave ovens would be more economically viable
than incinerators, and would cause less pollution. However, according to the president of
the National Fund for Environmental Protection: "there are no other alternatives for
hospital waste - only incineration". This shows that he did not read the report which
his organisation commissioned. But this was public money...
At present, the most important objective of the campaign is the introduction of the Pollution Prevention Act and to try and get as many changes as possible into the Waste Management Act. We believe that we can use this legislation to defeat the incineration lobby, and more importantly, force waste generators to reduce the amounts and toxicity of the waste they produce. We also campaign to ensure right to know and to get subsidies, soft loans and grants to those industries who want to change their processes and products to reduce waste.
The proposed legislation will also affect local governments. We want local authorities to have legal incentives to reduce waste and encourage the sustainable use of resources. As with industry, local authorities should also be required to prepare and introduce local waste reduction programmes. We are also pushing for local governments to be able to introduce local regulations eg. to introduce local taxes on disposable and plastic packaging, environmental levies etc. This is an ambitious objective, because it will require many other laws to be amended.
At present, the most that local governments can do is to introduce waste segregation and recycling. However, there are several examples of local governments, who without much money and no appropriate laws have achieved major reductions in pollution, use of energy, water and other resources.
Next year, jointly with these exemplary local authorities, cleaner production experts and other NGOs, we intend to organise a series of training sessions for other local governments and NGOs on pollution prevention, energy conservation, waste segregation and recycling and environmental education.
Although we will continue to fight incinerator proposals, we are convinced that waste prevention activities and promoting positive case studies on waste/pollution prevention can achieve more than just endless incinerator battles. We hope to co-operate in this work with Clean Production Action whose main objective is to be a resource to NGOs on cleaner production case studies and pollution/waste prevention initiatives.
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Zagospodarowania Odpadów "3R"
Waste Prevention Association "3R"