Local authorities and the waste and resource management sector have been calling for Government to clarify its amendments to the Waste (England and Wales) Regulations, which stipulate separate collections of paper, plastic, metals and glass should be made by 2015, where necessary to ensure that waste undergoes recovery operations and are technically, environmentally and economically practicable (TEEP).
A letter, in October 2013, from Lord de Mauley (the relevant Defra minister at the time), to all local authorities, caused a stir within the waste collection and handling industry and left an air of uncertainty whether further guidance will be published by Defra, in order to define what TEEP standards will be.
While guidance from government is not forthcoming, it is clear that the procurement of new waste contracts must take account of this issue. Service providers should be ready to give robust evidence showing how they have considered TEEP. Local authorities imminently procuring new services could find themselves at risk of a legal challenge, so they should engage with the market and satisfy themselves that the approach they are taking will meet the legal tests of the regulations.
Similarly, for service arrangements that will still be in operation in 2015, senior managers in local authorities need to be briefing elected members about TEEP and contractors should be ensuring that it is a board level discussion, getting the topic on their risk register and talking about it at committee meetings.
There should be no knee-jerk reactions: if following collection the subsequent separation of materials can achieve recycling of a quality similar to the standard that can be achieved through separate collections, then commingling can be in line with Article 11 of the revised Waste Framework Directive and the principles of the waste hierarchy.
It is fundamental to get the whole supply chain in the same room to talk and collaborate. That includes local authorities, collection contractors, reprocessors and manufacturers using reprocessed material. Only through such an approach can we arrive at an understanding about the quality of materials required at each stage of the process and how each can support one another. Some MRF operators and reprocessors have amazing technology to sort and separate ‘acceptable’ materials and keep it moving around the circular economy and these innovations will help overcome barriers and perceptions of what quality actually is.
Overall, those responsible for collecting dry recyclables, including commercial and industrial collections, need to ensure their decision-making is robust. There is no ‘one size fits all’ approach and there will be different solutions in different areas because of, for instance, demographics, housing type, street layout and waste stream material composition. And with recycling rates in England stagnating, ‘TEEP’ could be viewed positively as a catalyst to review long-term strategies and migrate to a paradigm, which will not only comply with ‘TEEP’, but simultaneously addresses the capture of more materials and more value from these materials, by improving quality.
The TEEP debate continues at another LRS event, on 28 January in Manchester: ‘Recycling services: Avoiding exposure and turning TEEP to your advantage’.
Dee Moloney, managing director, LRS Consultancy