The Institution of Engineers submission to the Minister for the Environment stopped short of naming the 19 local authorities it claims are facing capacity shortages in their landfills.
However The Irish Times has been told they included: counties Waterford, Wicklow, Meath, Donegal, Sligo, Roscommon, Leitrim, Clare, Louth, Tipperary (South) and Dublin (comprising South Dublin, Dún Laoghaire, and Fingal).
They also included city authorities in Waterford, Limerick, Galway, Cork and Dublin.
The institution said the fact that many of the authorities had applied for a licence from the Environmental Protection Agency to extend the lifespan of the landfills was evidence of a crisis. It claimed counties not listed could not be considered to have indefinite capacity in their existing landfills.