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The Waste Framework Directive and TEEP

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What is TEEP?
  
TEEP is the buzz-word (or acronym) of 2014 for the UK’s waste management industry, particularly given that it’s implementation has to be carried out by 2015. TEEP stands for “Technically, Environmentally and Economically practicable”. It’s implementation appears of concern to many local Authorities, who have in turn been seeking additional guidance from DEFRA (Technical Guidance). The issue extends to the potential need for local authorities to set up separate collections for Paper, Glass, Metal and plastic. However, as published in January 2014, further guidance will not be forthcoming form DEFRA.
  
The Regulations:
  
TEEP, in essence places an onus upon local authorities and follows on from a requirement to meet specific targets for “separately collected fractions”. In setting this out, the EU commission laid down Article 11 of the revised WFD, which states that: “By 2020 the preparing for reuse and the recycling of waste materials such as at least paper, metal, plastic and glass from household and possibly from other origins as far as these waste streams are similar to waste from households, shall be increased to a minimum of overall 50% by weight.
  
The Implementation:
  
In following on from these targets, a key requisite of TEEP is the need for better segregation of wastes into glass, metals, plastics and paper. This in turn provides better “feedstock” for materials re-processors, all in a push towards the ultimate goal of a “circular economy”. Of concern to local authorities is whether existing recycling services meet the new technical requirements of the waste framework directive (WFD). However, as highlighted by DEFRA, there’s still a place for the co-mingled collection of wastes, which makes up a significant proportion of the UK’s waste collection process. The reason for this is that it’s not economically viable to provide separate collections for recyclables in suburban areas. This is best highlighted where a single vehicle is used for the collection of all recyclable materials (hence the term co-mingled), thus reducing the environmental burden, financial burden and need to put more vehicles on already congested streets. This, in effect is the crux of the current issue- whether existing infrastructure will meet the new requirements of the rWFD.
  
Key issues:
  
In targeting TEEP as the “bottle neck” to this legislation, a greater issue has been overlooked, that being the need for re-processors to meet the requirements of “end of waste” where a material ceases being a waste and starts being a resource again. TEEP and end of waste go hand in hand. One cannot be achieved without first considering the other. Without the environmentally practicable recovery of separate fractions (glass, metal, plastic and paper), it won’t be possible to implement “end of waste” without extensive secondary treatment of wastes. This in turn places the emphasis in the provision of suitably graded feedstock, which is the responsibility of the Local Authority.
  
A case for continued Co-Mingling:
  
Whilst co-mingled collection can be supported more than adequately by materials recycling facilities (MRFs), not every suburban local authority has one on their doorstep. Furthermore, there is the issue of the UK having invested significantly in existing infrastructure in the form of MRFs. To this end, the Government will “encourage the separate collection of wastes where this is technically, environmentally and economically practicable, while allowing the co-mingled collection of paper, metal, plastic, glass and other recyclable materials for subsequent separation in material recycling facilities to continue after 2015 where this is the most effective means of increasing recycling rates in the local circumstances.” However, this in turn opens up a debate with regard to costs, both environmentally and fiscally, placing a burden on local authorities to determine the most economically viable means by which the new legislation can be met- to send out more trucks, operatives and recycling bins or to build an MRF?
  
What About:

  
Isn’t TEEP just another acronym to describe the existing targets that have been known about for quite some time? The answer in short is yes, but there’s a caveat in that answer. TEEP goes one step further and this could explain why DEFRA has not been forthcoming with further guidance. In essence, TEEP is in itself guidance- or maybe that should be a “get out clause”. In building upon the existing requirement for targets- hence pushing towards a circular economy- TEEP is providing guidance as to how the targets should be met. It is in effect a recognition of the need to adapt the legislation so as to meet the vastly different communities that make up the European Union.
  
Date Published: 05th March 2014