Dr David Greenfield FCIWM CEnv, Chair of the Waste Network Chairs and Director of Social, Environmental & Economic Solutions (SOENECS) Ltd discusses the Waste Regulations and understanding TEEP.
The debate between co-mingled and kerbside sort collections is one that has been going on ever since the first comprehensive recycling schemes were introduced in the 1990’s. The creation of a diverse range of collection methods was prompted by the governments challenge to increase dry recycling through weight-based target.
At present 274 councils covering 19 million households across England and Wales provide co-mingled collections, whilst the other 102 councils provide a form kerbside sort. Many residents would suggest that each of the 376 collection authorities have a different collection methodology, this may not be true, but I believe there are probably around 100 unique collection methodologies (through variances in size, colour and number of bins, frequency and number of materials collected). The process for getting to this diverse position has been through staged local development, and in the last few years there been move, particularly in partnerships, to have similar schemes across authorities.
So, where does the 2008 European Commission’s Waste Framework Directive – which introduced the requirement that separate collections of paper, glass, cans & plastic must be implemented by 1 January 2015 – sit with councils?
Firstly, we have to look at the process that led to the UK Government transposing the Waste Framework Directive into UK law. This occurred through the Waste Regulations (England and Wales) 2011, which came into force on 1st October 2012 with Defra announcing amendment 13 (revised Waste Regulation (England & Wales) 2012.
The amendment meant that councils need to collect four materials separately, and that there are two tests, a necessity and a Technical, Environmental, Economic and Practicable (TEEP) test. In practical terms this means that local authorities will need to consider their collection arrangements against these requirements. The regulations do not prohibit the co-mingled collection of these materials, rather they establish separate collection as the ‘default’ and it is for a local authority to demonstrate that separate collection is not necessary or practicable in their area.
Following extensive discussion between LGA and Defra, the department announced in January 2014 that they would not to publish guidance on how to meet the directive. The decision by Defra had been anticipated by the local authority Waste Networks Chairs (WNC)[1], WRAP and LWARB, and a commitment to establish a single methodology for individual authorities to assess their ability to meet the amended regulations was made.
To this end, a working group (the‘Working Group’) was established to develop a ‘Route Map’ to understanding the Waste Regulations 2011 (and 2012 amendments), specifically the requirements relating to the separate collection of paper, glass, cans and plastics.
The Waste Regulations Route Map was launched on 22nd April and is a support tool to help local authorities to assess their compliance with the regulations. It aims to help local authorities navigate their obligations from January 2015 and has been developed as a resource for local government. An important distinction is that the document is not guidance but it addresses the key questions that local authorities will need to consider when considering whether or not their service meets these requirements and, where necessary, in assessing TEEP. The routemap should allow local authorities to understand through a structured process, how they stand in relation to meeting their legal obligation. It will then be up to the local authorities to decide the next course of action.
The creation of this route map, by the sector, for the sector, demonstrates what can be achieved by partnership working. The route map is a great achievement and an accurate and un-opinionated solution to an imminent problem. I believe that given the budget cuts and resource pressures put upon local government, this sort of strategic demonstrable partnership working will continue to play a significant role in the future and should encompass the wider sector. Our next sectorial challenge may well be coming out of Europe in the very near future.
Dr David Greenfield FCIWM CEnv is Chair of the Waste Network Chair and Director of Social, Environmental & Economic Solutions (SOENECS) Ltd
[1]The Waste Network Chairs Members: ADEPT – Association of Directors of Environment Planning and Transportation; ALCO – Association of Cleansing officers; CTS – County Treasurers Society; DTS – District Treasurers Society; LARAC – Local Authority Recycling Advisory Committee; LEDNet – London Environment Directors Network; NAWDO – National Association of Waste Disposal Officers; NWRPF – National Waste Resources Partnership Forum; POS - Planning Officers Society; TAG – Technical Advisory Group
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How will the government and DMOs address the challenges of including glass in DRS while ensuring a level playing field across the UK?
There's no easy solution to include glass in the DRS while maintaining a level playing field. Potential approaches include a phased introduction of glass, potentially with higher deposits to reflect its logistical challenges. The government and DMOs could incentivise innovation in glass packaging design and subsidise dedicated return points for glass-handling. Exemptions for smaller businesses unable to handle glass might also be necessary. Any successful solution will likely blend several approaches. It must address the differing priorities of devolved administrations, balance environmental benefits with logistical and cost implications, and be supported by robust consumer education campaigns emphasizing the importance of glass recycling.