Wardell Armstrong’s James Benn takes a look at the latest TEEP developments and asks: why are waste collectors facing this challenge – and what is this likely to mean for their services?
The Government is looking to force change upon waste operators, meaning the obligations on local authorities and other waste collectors to comply with TEEP (technically, environmentally or economically practical) are likely to become more challenging in the coming years.
So why are waste collectors facing this challenge and what is this likely to mean for their services?
The Waste Strategy consultation documents issued in February concentrated on the need to increase recycling material quality, by tackling contamination and low-quality outputs from MRFs.
The most common collection method remains fully commingled kerbside waste collections.
Some plastic outputs from MRFs currently exceed 10% contamination, significantly reducing potential end-markets.
It is cited that the existing TEEP regulations have not resulted in a noticeable improvement to material quality to date and have not brought about a separation of glass from other materials.
The initial application of the TEEP regulations by the end of 2015 did not result in large scale changes to the way recyclates are collected in England.
In the build up to their implementation the Environment Agency, as regulator, published a risk-based regime detailing their approach to assessing compliance and performance of individual authorities.
Common collection
An EA survey conducted at this time identified commingled collection as the predominant method of recycling collection, accounting for 65% of England’s kerbside dry recyclate collected. Of the completed assessments, only 4% (8 authorities) had identified the need to change their service delivery methods as a direct result of the process.
The most common collection method remains fully commingled kerbside waste collections.
Briefings indicate that the requirements of local authorities, and other waste collectors, to comply with TEEP are likely to become more stringent in the coming years, specifically through removing the economic practicability test from TEEP.
Thérèse Coffey, Parliamentary Under Secretary of State for resource and environmental management, suggested in January that the then imminent Waste Strategy consultation documents would see the economic practicability test removed from TEEP.
The implication of this intervention is a clear message to local authorities that the Government expects change and will adopt a stronger approach to compliance with the regulations. It was claimed that authorities had been using the economic practicability test as an ‘excuse’ not to offer a source segregated collection of recyclables at the kerbside.
Quick on the heels of this announcement, the Environment Agency’s Pandora Rene confirmed that they were ‘going to take the economic bit out of TEEP’. Waste collection authorities need to heed these warnings which will place separate collection as the default collection method without considered and robust justification.
They will be expected to plan accordingly.
“Not necessary”
Local authorities that provide either fully commingled or partially commingled services (primarily in the form of dual stream collections) will need to demonstrate that change to separate collection is either not necessary or not practicable.
Otherwise they will need to enact service changes which as a minimum means separately collecting both glass and paper/card material streams. Whilst it appears to focus on household kerbside collection services, it is going to apply to HWRCs, bring sites and local authority’s commercial waste collection services.
The Waste Strategy ‘consistency’ consultation provides a clearer picture of the future regulations, dependent on the outcomes and further consultation periods.
This may have significant cost implications to providers who have previously separated out paper at the kerbside due to its higher value.
This won’t just effect TEEP but other associated Council services like food waste collections, free garden waste collections, business recycling collections and frequency of kerbside collections, which will all have to be considered in any service redesign.
The consultation does not go as far as removing economic practicability from the regulations, as indicated in pre-release briefings, but does introduce the concept of ‘disproportionate cost’.
This will require all waste collectors to demonstrate that costs are not just higher but are significantly so, whilst also considering a host of associated costs including adverse environmental and health costs.
The difficulty quantifying some of these additional expenses could well rule out the economic practicability argument by undermining the legitimacy of the assessment, and therefore increasing the likelihood that commingled or dual-stream service providers will have to change collection methods.
Cost implications
There is also significance in the decision to favour the separation of glass, rather than paper, from all other materials. Up to this point, the available guidance, and industry practice as evidenced by the range of two-stream collections operated nationally, has not preferred the separation of glass over the separation of paper.
This may have significant cost implications to providers who have previously separated out paper at the kerbside due to its higher value.
Statutory guidance is proposed designed to help authorities establish the compliance of their services with the TEEP regulations, advising on best practice and defining the assessments scope more clearly.
Importantly, where changes are required, there is a commitment to allow suitable timespans for implementation.
This will be important in ensuring that existing contracts can be honoured, and future services planned comprehensively alongside consideration of any required infrastructure developments and commitments.
