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Wednesday, March 25, 2015

An Overview of Solid Waste Management in the Ja-Ela Area

1. Introduction

1.1 About this survey

The aim of this survey is to describe the various aspects of solid waste and its management in the Ja-Ela Divisional Secretary (DS) division, and to investigate the possibility of a participative community project in waste-management under the Integrated Resources Management Programme in Wetlands (IRMP).

1.2 IRMP

IRMP is a five-year project of the Central Environmental Authority (CEA), which currently operates in the wetland area of Muthurajawela Marsh and Negombo Lagoon. It aims to develop a workable model for participative and integrated management of wetlands in Sri Lanka. Activities are first run as pilot projects, to see whether they work and how they can best be implemented.

1.3 The area

The Ja-Ela DS Division lies in the Gampaha District of the Western Province, and is located just north of Colombo. It covers some 65 km2, has about 190,000 inhabitants, and is subdivided into the Pradeshiya Sabha (PS) areas of Kandana, Ragama, Batuwatta and Dandugama, and the Ja-Ela Urban Council (UC) area. Both its population density and population growth are relatively high. A small strip on the western side of the division is part of the Muthurajawela Marsh.

1.4 The waste problem

Infrastructure and resources for waste collection are lacking in most parts of the country, so uncontrolled scattering and dumping of garbage is widespread. There are no proper facilities for final disposal of most of the solid waste produced by households and industries. Waste that is improperly dumped can impede water-flow in drainage channels, and provides breeding places for disease vectors such as rats and mosquitoes. Open dumping sites in natural areas cause pollution of ground- and surface-water, and will facilitate encroachment. Open burning of waste at low temperatures is also widespread. It contributes to atmospheric pollution and may cause serious health problems.

1.5 Government organisation

The government levels in Sri Lanka include the National Government (the President, Parliament, and the Ministries and their departments, agencies, boards, etc.), Provinces (headed by Provincial Councils), Districts (headed by a Government Agent), Divisions (headed by a Divisional Secretary), Pradeshiya Sabhas (PS) and Municipal and Urban Councils (MC and UC), and Grama Seva Nildaris (GN). The PS, MC and UC are assigned a Public Health Inspector (PHI) by the Ministry of Health, who usually also takes care of solid waste management. At the national level, the Ministry of Forestry and Environment (MFE) and the Central Environmental Authority (CEA) are responsible for policies regarding solid waste.

1.6 Legal Aspects

Important laws and regulations with regard to solid waste are the National Environmental Act, the Pradeshiya Sabha Act, and the Urban Council and Municipal Council Ordinances. The Environmental Act restricts the emission of waste materials into the environment, and states the responsibilities and powers of the CEA. The local Government Acts and Ordinances state that the local authorities are responsible for proper removal of non-industrial solid waste, and for providing suitable dumpsites.

1.7 Life cycles

Organic waste consists of materials that will naturally degrade within a reasonable time period. It can be composted or converted into methane (biogas), and some of it can be fed to animals.
Paper and cardboard waste are essentially also a form of organic waste. When to too dirty, they can be recycled or re-used (e.g. for wrapping, as bags or envelopes, and for writing on the unused side). When dirty, they could be composed, but caution may be needed because of the printing ink.
Glass can be recycled, and glass bottles can be re-used. Other silicate (stony) materials can be used in things like road construction, but might first need to be grinded.
Most metals can be recycled. Care should be taken with dumping, as heavy metals can cause serious pollution.
Plastics will degrade naturally, but only very slowly. Addition of certain materials during production can speed up this process. Some types of plastic waste (mostly PET, PE and PP) can be recycled mechanically, but will have to be sorted and cleaned. Tertiary (chemical) recycling of plastics is also possible, and can often handle more contaminated waste, but these techniques are not yet widely available.

2. Methodology

2.1 Interviews

To get more insight into the workings and organisation of solid waste management, interviews were conducted with national and local government agencies, "town-cleaning" firms, waste resellers and local residents. The reliability and completeness of the information obtained through these interviews might in some cases be questionable, so care should be taken in its interpretation.

2.2 Collection survey

We accompanied a group of town cleaners on their morning shift, to gain familiarity with their methods, to get an idea of the composition and amounts of collected waste and to see which materials are kept apart by the cleaners for reselling.

2.3 Dumpsite survey

The main dumpsites in Ja-Ela DS were visited and detailed observations were made (see appendix IV). Quantitative measurements of any kind proved difficult, so were not really performed. The size of the sites was estimated.

2.4 Measurement of waste production

Waste production and composition were measured for 15 households, half of which were located in a more "rural" area (Delature), and half in a more "urbanised" area (Ekala). The households were further divided into two or three income groups. Waste was collected four times over three weeks, sorted into several material types and weighed. Waste from some retail-shops and eating-houses was also collected and analysed. The results obtained are mostly indicative, as precision and representation of the measurements leave something to be desired.

3. Survey Results

3.1 Waste production

The reliability of the figures is somewhat questionable, due to small sample-size and large variation. Collection by the households might also have been selective, leading to a slightly biased result.
Waste production of the households measured seems to be in the range of 100-300 g per day, not including waste materials that were recycled or re-used. Households in more rural areas often seem to use their organic waste as animal feed (not necessarily for their own animals) or for composting.
The average composition of the household waste we measured (by weight), seems to be roughly as follows: 15%-30% plastics, 30%-40% paper, 0-30% organic fraction and 10%-30% rest-fraction. The plastic and paper fractions make up most of the volume of household waste, but can be significantly compressed. The organic fraction makes a relatively large contribution to the total weight, due to its high density and water-content.
Packaging materials make up more than half of the plastic and paper fractions, both by weight and by volume. A significant part of the paper-fraction is already made of recycled materials. Only a small part (less than half) of the plastic fraction would be easy to recycle mechanically. Most packaging materials produced in Sri Lanka do not state the material type.
Restaurants and eating-houses produce a lot of food and kitchen remains, which are usually collected by local pig farmers, who use it as animal feed. Retail shops produce mostly packaging waste.

3.2 Waste collection

Some relevant information on the waste collection resources of the various local authorities is listed in table 3.3. Cleaning of (main) roads and markets has been recently privatised in Kandana PS and Ja-Ela UC, and seems to function better than the former public cleaning systems.
Waste collection and cleaning is mostly paid out of assessment tax and trade licences.
Frequent cleaning and collection of roadside waste is mostly restricted to main roads and town areas. Cleaning of the roadside drains is included in the duties of the local authority cleaners, but is currently insufficient.
The cleaners proceed along their daily route, sweeping and shovelling up roadside litter and garbage (including a lot of sand and stones), and throwing it in a tractor-trailer or handcart.
There seems to be an increasing tendency, especially among shop owners and higher-income households on the town-edges, to use bags or bins, instead of just dumping the garbage along the roadside. Centrally placed garbage barrels, which are provided by the private cleaning companies in Ja-Ela and Kandana, are also effective, although many barrels get stolen.
Plant material makes up a very large part of the collected municipal waste. Estimates give around 60%-90% for the organic fraction (by weight).

3.3 Waste disposal

Households generally dump or burn their waste materials. Dumping is usually done in a shallow pit in the ground, along the roadside, on a nearby dumpsite, in low-lying marshland or in waterways or waterbodies. Dumped material is often periodically burned.
Local authorities usually dump their collected waste on privately owned land. Finding suitable sites is difficult, and current sites are therefore often over-used. Officially, waste is not burned by the authorities after dumping, but it does happen.
No regulations or guidelines have been made to govern dumping of solid waste by private companies or industries. Uncontrolled dumping of (hazardous) industrial waste and of slaughterhouse waste is problematic, and poses a potential health risk. Other problems with disposal include smell, prolonged exposure to noxious gases from the burning of waste, scattering of waste materials, presence of potential container habitats and ingestion of plastic bags by cows, pigs and other animals. Serious water pollution (mostly eutrophication) was observed in a few places, but does not (yet) seem widespread. Measurements are needed, however.
There do seem to be any usable laws or regulations that deal with unauthorised dumping of non-hazardous solid waste. Sometimes the Nuisance Ordinance is used by local authorities to stop undesired dumping.

3.4 Re-use and recycling

Especially households in more rural areas re-use organic waste as animal-feed and/or for composting. Pieces of cloth are also sometimes re-used. In more urbanised areas, re-use of waste materials seems virtually non-existent.
Town cleaners seem to keep several materials separate from the rest of the collected waste. Especially corrugated cardboard, metal cans, scrap metal, glass bottles, firewood and some food remains are re-used or sold to waste buyers for recycling.
Waste buyers (re-sellers) often have small shops, where they buy, sort and store things like (news)paper, corrugated cardboard, scrap metal, glass, barrels, plastic containers, sacks and sometimes black-coloured plastics. These materials are obtained from companies, town cleaners, house-to-house collectors, scavengers and other individuals, and are either sold locally for re-use or are sold to recycling-companies, usually through a middleman.
House-to-house collectors buy mostly (news)paper, glass and metal from households, and sell these to the re-sellers at a small profit.

3.5 Public awareness and attitude

The results below might not be representative, because of the small sample group and superficiality of the answers.
Many people do not seem aware of the (potential) environmental problems caused by disposal of solid waste. Garbage is often only seen as a problem because of practical reasons.
Most people seem to know about health problems (especially mosquitoes) relating to garbage, from school education or media. The extent and depth of this knowledge was not determined.
Waste materials that can still be sold or re-used are not seen as waste, but as something which still has value. However, it is usually thrown away when not collected.
Proper collection (and dumping) is seen by many residents as a solution to garbage problems.

3.6 The role of the Government

Lack of resources makes it difficult for local authorities to do anything about the waste problem other than clean the main roads. According to them, the National Government should provide the necessary legislation and resources.
According to the CEA, waste management is a task for the local authorities. The CEA have neither a license-system, nor any regulations, standards or guidelines for solid waste disposal (except for some hazardous materials). The relevant sections of the National Environmental Act have not been implemented. Measures of National Government agencies to help solve the waste-problem seem currently limited to some awareness-material, mostly for schools.

3.7 Future policy

The Ministry of Forestry and Environment is working on a National Strategy for Solid Waste Management (NSSWM), aimed at municipal solid waste. A three-year implementation plan has already been made. Responsibilities are to be shared between national Government bodies (Ministries, the CEA, etc.), local authorities, the private sector, and the general public. Implementation is co-ordinated through committees at national, provincial and local levels. Details and the matter of funding are still unclear.
Waste reduction is mostly envisaged through public awareness and regulation. Re-use and recycling are to be promoted, partly through tax-measures. Properly engineered landfills are to be set up on a regional level and are to be shared between various local authorities.

4. Conclusions and Recommendations

Shown here is the full text of the chapter from the report, not a summary.

4.1 Main conclusions

  • The relation between weight and volume of household waste can vary greatly with water content and the amount of compression, and is thus partly dependant on methods of storage, transport and disposal. This means that some care should be taken in interpreting figures that state weight or volume of household waste, without giving additional information about water content and/or density.
  • The main solid-waste streams in the Ja-Ela District can be depicted as follows:

Figure 4.1 The main product- and solid-waste streams in the Ja-Ela DS Division.
  • Responsibilities of Government agencies with regard to solid waste management (and the maintenance and cleaning or drainage channels) often overlap. This leads most of the agencies involved to pass responsibility for solving the problems to each other, without taking any action themselves.
  • Several parts of the National Environmental Act seem currently unimplemented and/or not used, including the provisions for solid waste disposal.
  • There are currently no regulations, standards or guidelines for the disposal of solid waste. There are only some guidelines for certain hazardous materials.
Waste production
  • Relatively little can be said about the waste production of a given household based on its income and location.
  • The plastic and paper fractions of household waste make up most of its volume, but the organic fraction often contributes the most to its weight. This is mainly because of the high water-content of the organic fraction, when compared to the other fractions.
  • Packaging waste makes up more than half of the paper and plastic fractions of household waste, both by weight and by volume. In the case of the households we measured, some 60%-80% of the plastic and paper waste consisted of discarded packaging material.
  • The "municipal solid waste" as collected by town cleaners contains a lot more organic material and sand/gravel/stones than the household waste that was measured outside the towns. This is partly because the methods used to collect the waste, which make that a lot of sandy material and leaves from the roadside are included. It is also likely that not all of the organic waste produced by households was measured. Gardening waste seemed largely absent (and is possibly re-used in the garden), and selective collection might also have played a role, making that the size of the organic fraction was possibly underestimated.
Waste collection
  • Waste collection (or "town cleaning") involves sweeping and the removal of waste from the roadsides. It covers mostly town areas and main roads. Byroads are sometimes also cleaned, but less frequently.
  • Household waste is only collected when deposited along the side of the road. Some households just dump it there, but especially shops and (higher-income) households at the edges of towns are also starting to use garbage bins or plastic bags.
  • The manner in which the roadsides are swept and garbage is picked up, makes that relatively large amounts of leaves, soil, gravel and small stones are included in the waste which is collected and subsequently dumped.
  • Privatisation of the collection / cleaning system seems to significantly increase its effectiveness.
  • Cleaning and maintenance of roadside drainage channels is currently insufficient.
  • Possibilities to improve the efficiency of roadside waste collection include promoting the use of garbage bags and bins, and placement of central barrels or depots for disposal of household waste. The main problems are that barrels are often stolen, and that bags inhibit the extraction of recyclable or re-usable waste materials by town cleaners.
Waste disposal
  • Finding suitable dumping sites for collected waste poses a problem for most local authorities.
  • Most dumpsites in the Ja-Ela District are located in marshy areas, especially along the edges of Muthurajawela Marsh.
  • Although plastics make up a relatively small fraction of the dumped waste (especially by weight), they do dominate the dumpsites because they do not easily decompose (like paper and organic waste) and are not recycled (like metal and glass waste).
  • Access to many dumpsites can be a problem, especially in rainy periods.
  • The majority of dumping sites may constitute a hazard to the public health and to the environment. The dumped waste is not covered frequently, waste materials (especially plastics) are spread by wind and water, and leachate and runoff are free to reach ground- and surface water.
  • Solid waste disposal is also a problem for most industries, both large scale and small scale. There are no facilities, no regulations, and in most cases no guidelines or standards.
  • Uncontrolled dumping of slaughterhouse waste takes place at a fairly large scale and constitutes a nuisance as well as a risk to the public health.
Re-use and recycling
  • Most households do not seem to re-use much. Bottles and containers are often re-used, as are some plastic bags. Organic material is mostly used as animal feed or compost in the more rural areas. But especially in urbanised areas, re-use of organic materials is currently insufficient to non-existent, and can easily be much higher.
  • Most paper and organic waste could theoretically be easily recycled, but sorting and quality of the materials would be a problem.
  • Plastics are difficult to recycle and sort. Plastic waste contains a lot of laminate materials and other composite products, and is sometimes very dirty.
  • Contaminants, including heavy metals and other toxic substances, might become a problem when organic material is re-used (by composting, or in a biogas-digestor) on a larger scale.
  • It seems that in the current situation, a number of recyclable and/or reusable materials are almost completely removed from the waste stream by the "informal" circuit of waste collectors and resellers. The materials involved are mostly:
  • newspaper, books and plain paper (before re-use);
  • corrugated cardboard, when dry and relatively clean;
  • glass bottles and jars;
  • larger sized metal objects, sometimes also including cans;
  • food remains, in some (rural) areas and households;
  • gardening waste, in some (rural) areas and households; and
  • empty barrels and good-quality (plastic) containers of larger size;
  • The waste materials which are currently not collected for recycling, include:
  • paper and cardboard packaging;
  • newspaper and paper, after re-use;
  • plastic packaging and other plastic articles;
  • most composite materials;
  • organic waste (depending on the area and the household); and
  • hazardous waste, such as chemicals, oil remains, batteries, etc.
  • The "informal" circuit creates a significant amount of jobs, for collection, buying and selling, processing and sorting, transport, and recycling.
    Collection and/or re-selling of recyclable and re-usable waste materials has a low profit margin, but can nevertheless provide a full income in many cases.

4.2 Recommendations

  • Measures for waste reduction at the source, should probably focus on reducing the number of plastic bags provided at shops (or used by consumers), and on reducing the amount of (plastic) packaging waste. Better alternatives should be provided.
  • Plastic packaging materials should be marked for material type, to ease sorting for mechanical recycling. Many imported products are already marked.
  • Plastic products which might be suitable for recycling (and are relatively easy to sort and clean) include cups (of yoghurt, ice, etc.), bottles (PE/PET), pots and other containers (usually PE), and PE/PP packaging foil and bags, although distinguishing between material types might be difficult.
  • The possibilities for tertiary recycling of plastics should be investigated (see § 1.7).
  • Properly engineered dumpsites are needed. At the very least, suitable locations should be selected for new sites (which means that a suitability check has to be performed).
  • The biogas-digestors which are being developed and tested at the National Engineering and Research Department (NERD) in Ekala, could provide a cheap and effective method for disposal (or at least reduction) of municipal solid waste with energy recovery, as the organic content of the waste is very high.
  • More research is needed into the effects of the current open dumpsites. Some samples of groundwater and surface water in the vicinity of some dumpsites should at least be taken and analysed.
Awareness and instruction
Proper awareness and instruction campaigns are needed on the effects of the current solid-waste disposal practices, and on solutions for (some of) the problems.
Awareness material and usage instructions for things like compost barrels should be suitable for theentire target group intended. This is currently not always the case, as most material produced is only suitable for better-educated people who already have an interest in the subject. If needed, various versions of the same material can be produced for different target groups.
The channels used to distribute the message should also be able to reach the entire target group. Newspapers are often only read by a small portion of the population, and each newspaper has a slightly different target group. Television is effective, but does not reach the lowest income groups. Radio is somewhat less effective, but can also reach some people with lower incomes, and especially people at work. Posters are usually the least effective, but may gain something in effectiveness when put up at places where they will be frequently and easily seen. Brochures can be very effective, but are also expensive and difficult to distribute.
Usage instructions should give clear and short instructions, preferably using additional illustrations. They should be written in simple and unambiguous language, and should also include information on what not to do.

4.3 Suggestions for local action

As waste is seen more as a practical than as an environmental problem, it will be difficult to mobilise community support for a participative waste-collection and recycling programme. Most people feel that waste management is a task for the Government, and would only be willing to take action themselves if it yields sufficient benefit. Experiences with the Arthacharaya community waste collection programme have already shown that financial benefits from selling sorted garbage are fairly low on a household level (IRMP, 2000). Therefore such a programme would only be effective in very low-income areas, where even small benefits count.
The low benefits for selling waste materials are mostly caused by the fact that one household does not produce much waste, and does therefore not get much income from selling it. This problem is avoided if the benefit is spread over fewer people. A house-to-house buyer for instance, can make a living out of buying and selling waste materials from a number of neighbourhoods (see § 3.4). His profit margin is low, but this is because the major part of the financial benefit actually goes to the households!
To start a successful and self-sustainable community/neighbourhood waste-management project, it would be most efficient to incorporate the informal collection and recycling routes that already exist. This existing system of "informal waste collection" can then be extended to include the waste materials that are currently not (sufficiently) collected and/or recycled. When implemented correctly, this could result in benefits for everyone involved (households, collectors, resellers, recyclers).
In such a system it is absolutely essential to have the support of the community. The households are the ones that have to initially sort and store the waste materials that are to be collected for recycling. Therefore to ensure co-operation, the local population must be involved in setting up the system. It is very important that they are correctly informed on proper sorting of waste materials, on composting and on management of household waste in general. For most people, the incentive for co-operation will probably be the fee for selling the waste (IRMP, 2000), and the fact that waste is now properly collected (see § 3.5), so that it is no longer their worry.
It would probably not be difficult to get support from waste buyers and recyclers, as such a project would mean an expansion of their market, by which they have something to gain. One potential problem might be that they might get more competition, which (especially considering the nature of the Sri Lankan society in this regard) might not always be appreciated.
The project would have to focus mostly on collection of paper and plastic packaging materials, and on collection and/or local re-use (composting, feeding animals) of organic waste (in areas where this is not already happening). In a proper collection system, provisions also need to be made for the rest-fraction and for hazardous waste (chemicals, etc.). This might pose a problem, as no profit can be obtained from collection and disposal of these fractions, and these activities will have to be funded somehow.
The local residents should be briefed in a workshop on how to sort waste and make compost, and also on what not to do. This last point is very important, and can help to avoid many problems. This is often forgotten: instruction briefings for many projects only seem to focus on what to do, but not on what to avoid.
Expected problems include the following:
  • Lack of space for storage, especially among low-income households, and in more urbanised areas. Collections will have to be more frequent (which will result in decrease of benefits for the collector), or other provisions need to be made. Central storage could be considered, but is impractical and involves extra cost.
  • Lack of space for composting, or no use for compost. In this case organic waste will have to be collected for composting by someone else, for biogas production or for animal-feed. This might be a problem, as storage of organic waste is near to impossible, due to smell and animals.
  • Animals. Especially dogs, cats and crows will often go through waste, looking for something to eat. This may cause the (sorted) material to be scattered again, and will make (storage for) collection very difficult. The animals are usually able to open plastic bags, so these offer no protection. A (heavy) bin would help, but will involve extra costs.
  • Improper sorting. For many people it is difficult to distinguish between waste-types, even with proper instruction. Also, quality of the waste is of importance. Dirty paper should for instance be deposited with the organic fraction or the rest-fraction. Very dirty plastics are difficult to clean and recycle, so should also go with the rest-fraction. The organic fraction often contains small bits of plastic, which are difficult to sort out. If the waste materials are improperly sorted at the household level, the quality (and with it the value) will go down.
  • Plastics. For (mechanical) recycling, plastics will have to be cleaned and sorted to material type. This will involve extra costs, which might outweigh the benefits, except when done by volunteers. Sorting plastic types is also very difficult, as most locally produced packaging materials are currently not marked.

  • An alternative would be to only recycle product types that are easy to sort, to clean and to recycle. Things like plastic bottles, yoghurt cups, etc. The rest would have to be dumped, or burned at elevated temperatures (for which no installation seems to be currently available in Sri Lanka). Tertiary recycling (see § 1.7) is also an option, but the technology for this might not yet be available in Sri Lanka or around.
  • Residual waste. As was already mentioned, collection of these (usually non-recyclable) waste fractions will involve extra cost (except when done by volunteers - perhaps schoolchildren). The rest-fraction would have to be dumped or burned. It is likely that there are currently no proper facilities on the island to dispose of hazardous materials (chemical residues, batteries, etc.) in residual household waste.

  • Meat remains are best not composted, so these will go into the rest-fraction. However, this will make it more difficult to store, because of smell and animals.
Besides the sort of larger-scale community project suggested above, initiatives for waste collection and recycling are also possible on a smaller scale, and for a more limited target group. An example of this could be the following:
Hotels and restaurants, especially in tourist areas, produce a significant amount of plastic (PET) drink bottles. These are relatively easy to collect, store and clean, and also easy to recycle mechanically. Therefore, it might be useful to set up a kind of bottle-collection system for hotels, restaurants and guesthouses in the Negombo area. Hotels and guesthouses could have a separate bin in which tourists can deposit PET bottles. This would be good for the "environmental" image of the participating hotels, restaurants and guesthouses, and might also provide some positive publicity for IRMP.

4.4 Comments on the NSSWM

The proposed National Strategy for Solid Waste Management is fairly complete, in that it covers the entire waste-cycle from production (avoidance) through re-use, collection, recycling to disposal. This is done in a fairly integrated manner, and according to the established hierarchy of waste management. In the light of this report however, a few notes need to be made on the strategy:
  • Some practical aspects of the proposal are still very vague. For example, the motto of "reduce, re-use and recycle" is one of the pillars of the plan. But nowhere is it mentionedwhich kinds of products might be re-used (for instance containers, bottles and plastic bags might be possible candidates). The measures for waste reduction on the consumer side are also somewhat unclear. But more importantly, it is still not fully known where the initial money for implementation of the plan has to come from.
  • The proposal does not consider the fact that many materials are already being sorted out of the waste stream for re-use and recycling, by the "informal" circuit (see § 3.4). Integration of the existing informal systems into the proposed collection system might somewhat simplify implementation of segregated waste collection.
  • Practical problems with collection and with sorting of waste at the household level are not considered. See paragraph 4.3 for examples. Especially storage of waste will be a problem for many households.
  • The plan only targets municipal solid waste. And more importantly, through the proposed methods of sorting, composting and awareness building, it implicitly targets mainly better-educated and higher-income households located in more urban areas. This is not really a problem, as this group is the easiest to start with, but nowhere is this explicitly mentioned. It is however an important realisation, as it implicitly limits the initial scope of the plans for segregated waste-collection. It means that low-income and poorly educated families, and households in more rural areas will or can not easily be included in the waste-collection and recycling schemes. At least, not at first. In other words, the majority of households in the country would initially not be covered by the measures proposed in the strategy.
And finally of course, as is the case with all proposals: The plan looks good, but it is always the question if it can and will be implemented properly. The proposed three-year timeframe sounds good, but may be a bit optimistic considering previous experiences.


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