By the Act of December 14, 2012, on Waste Management, many issues related to waste management were regulated, but at the same time, many became unnecessarily complicated. The Act introduced the necessity to process mixed municipal waste, including in installations for the which in turn leads to the production mechanical-biological treatment of mixed municipal waste, of significant amounts of the combustible fraction of waste. In turn, this cannot be dumped in landfills because it does not meet the regulation requirements of the Minister for the Economy on the criteria and procedures for allowing waste to be placed at certain types of landfill. The only way to manage them is the production of alternative fuels. However, the fuel produced in our country can be burned practically only in cement plants because we do not have energy installations dedicated to alternative fuels.

On the other hand, cement plants significantly reduced the amount of waste accepted for processing, which in turn led to the accumulation of huge amounts of waste in the places where they are formed, often contrary to the administrative decisions held. This situation triggered a wave of fires, as we witnessed in 2018. The problem with the disposal of the flammable fraction continued to deepen. Waste was often transported over long distances (over 400 km), which generated high costs and influenced the increase in prices for collecting and managing municipal waste. Another problem was the lack of recycling installations of selectively collected waste, which in turn causes problems with the management of waste from the separate collection. It is also crucial that without creating appropriate waste recycling installations, it will not be possible to achieve the proper recycling levels.

Another significant change related to waste management appeared in 2019. One of them bearing severe consequences was the elimination of regions in municipal waste management. The existing regional installations became municipal ones that could accept waste generated in each Voivodeship and from other, even remote places in the country. The elimination of regionalization also applied to structures for thermal waste treatment. As a result, local governments are not shareholders conducted competition procedures to select waste suppliers who would submit the most attractive price offers.

Later the legislator repealed Art. 35b and Art. 35c of the Act on Waste Management, which resulted in the fact that the current planning of installations for thermal processing of municipal waste and waste from the processing of municipal waste at the national level, in particular, supporting the resignation from the minister's creation of a list of thermal waste processing installations, was transferred to the voivodeship level.

Favourable opinion of the minister

• creation of new compost plants (also in new locations), however in the following cases:
  • when cities of considerable size, so far without sufficient capacity of Mechanical-Biological Treatment (pl. mechaniczno-biologiczne przetwarzanie odpadów) installations enabling the adaptation of the biological part for organic recycling of bio-waste, where it would be unjustified to transport large streams of bio-waste (which should appear after the effective implementation of separate bio-collection) over long distances - this applies in particular to Rzeszów, or
  • when the use of existing biological parts for organic recycling of bio-waste proves to be ineffective (for this reason, it is purposeful to confront operators’ requests for adaptation of biological parts to the new BAT Conclusions, as well as, in the near future, a purposeful review of Biological Treatment installations in the light of the new EU Fertiliser Regulation, effective as of 2022);
• The creation of new bio-waste installations (including  new locations) in technologies where, as well as organic recycling, they will also carry out energy recovery (i.e., biogas plants) - bearing in mind that these will be installations allowing for the more efficient use of waste potential than composting;
• The results of analytical calculations also indicate that there may be an insufficient processing capacity of installations for sorting raw material waste collected separately - in the event of failure to implement national solutions allowing the increase of efficiency of the selective waste collection "at the source", and thus helping to relieve sorting plants (e.g. by developing mechanisms related to the Regional Operational Programmes (pl. Regionalne Programy Operacyjne, ROP)), the problem of scarcity in the capacity of sorting installations will worsen over time due to increasing targets for preparing waste for reuse and recycling;
• in the Subcarpathian Voivodeship, there is insufficient processing capacity to recycle the entire target stream of selectively collected paper, cardboard and plastics for recycling;
• there are no installations for recycling multi-material packaging in the Subcarpathian Voivodeship;
• in terms of Installation for the Thermal Processing of Waste (pl. Instalacja Termicznego Przekształcania Odpadów, ITPO) processing capacity with energy recovery, at least 86 thousand Mg/year, assuming that in the existing Waste-to-Energy Thermal Treatment Installations (pl. Instalacja Termicznego Przetwarzania z Odzyskiem Energii, ITPOE) in Rzeszów, a stream of non-segregated (mixed) municipal waste from the area of the Subcarpathian Voivodeship at the level of 70 thousand tonnes is subjected to the thermal transformation process. Mg/year and the remaining 30 thousand of Mg/year going to this installation is the overflow fraction.

Concerning the last-mentioned point, it should be noted that the investors reported to the WPGO their intention to implement in total nine installations for the  thermal processing of waste, planned processing capacity at the level of 530,000 Mg/year (waste management aspect) and the characteristics of the planned energy parameters along with the directional idea for the management of the produced electricity and heat (energy/heating aspect). While giving his opinion, the minister pointed out that "the development of thermal waste treatment installations with energy recovery is fully justified and complies with the waste management hierarchy, provided that this energy is collected in the form of electricity and heat. Energy from the thermal transformation of waste must be collected in the heating and power system; hence it is vital to design the installation in line with the planned waste stream for energy recovery, but also optimal in terms of the requirements of the heating network, its transformation and heat demand of consumers. A waste incineration plant with the recovery of energy in the form of heat and electricity must be included in the locally appropriate plans for the transformation of district heating systems to guarantee the collection of this heat and improve the given district heating system's efficiency. " Therefore, it should be noted that two of the notified installations using the heat generated for their own needs do not meet the minister's postulate, and therefore were not included in the Investment Plan.

More expensive than primary resources

From the verifications of the reports of commune heads, mayors and city presidents submitted via the database on products and packaging and waste management on the implementation of municipal waste management tasks for 2019, it results that as many as 51 municipalities (out of 160) did not achieve the required level of preparation for reuse and recycling of municipal waste: paper, plastics, glass, metal (there were 16 in 2018). However, the situation for 2020 will be worse, as the required level of preparation for reuse and recycling of waste is 50%, and during the pandemic, a lot of waste was perceived as mixed.

From year to year, there has been an increase in selectively collected and collected municipal waste in communes. In 2017, there were 131,524 Mg, in 2018 - 175,804 Mg, and in 2019 - 192,756 Mg. Even though more and more waste is collected and collected selectively, there is still a lack of decisive steps towards proper management. There are still insufficient installations on the market that use waste material as raw material because it is sometimes more expensive to produce products from waste than from virgin raw materials. There is also no need for recycled products. Besides, there is also too many products on the market, particularly packaging that cannot be recycled after use. As a result, 50% of plastics cannot be sold, and the collected and sorted waste remains in warehouses. For municipalities to improve, it is necessary to introduce regulations on extended producer responsibility as soon as possible. It is necessary to speed up introducing restrictions for manufacturers of packaging or non-recyclable products or introducing an additional product fee for this type of product.

Author: TOGETAIR Editors