teep and lessons learned from uk approach to eu compliance

  TEEP AND LESSONS LEARNED FROM UK APPROACH TO EU COMPLIANCE

  Dr Nia Owen  Principal Consultant

2© Ricardo-AEA Ltd Ricardo Energy & Environment in Confidence

• A personal welcome• Legislative context• Recycling Systems• Necessity & TEEP tests• What it means for local authorities in the UK• Conclusion

Overview


• Principal Consultant • 11 years experience in the waste sector• Member of the Chartered Institution of Wastes Management• Knowledge Leader for Waste Auditing• PhD in material recovery facility design and performance• Expertise in recycling scheme monitoring, data analysis and options

appraisal• Acknowledgements– Lorna Pannett, Adam Read & Stephanie Boulos

A personal welcome


Legislative Context


• EU Thematic Strategy aiming to achieve a recycling society (adopted in 2005)

• Aims to: – Improve recycling & make it easier– Reduce the burden on the recycling sector– Overcome market drivers through appropriate use of the waste

hierarchy

• The Thematic Strategy is underpinned by the EU Waste Framework Directive (WFD)– Waste Hierarchy– Recycling targets

• A number of limitations to original WFD– No quality standards, so global market prices are the primary determinant– Weight-based targets have driven quantity over quality

Legislative context


• To improve the quality of recyclate collected across Europe by requiring key materials to be collected separately

Aim of revised EU Waste Framework Directive


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Recycling Systems


• There are a range of approaches to recycling collections currently in place.– Bring site based collections – Kerbside collections of separate waste streams– Co-mingled collections

• Bring sites and kerbside collections of separate waste streams already compliant with Article 11 requirements, so many countries within the EU are not required to make any changes to their existing systems

Recycling Across Europe


• Types of collections used across the UK:

Recycling in the UK


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Necessity & TEEP Tests


• Article 10 - Recovery:1. Member States shall take the necessary measures to ensure that waste

undergoes recovery operations, in accordance with Articles 4 [waste hierarchy] and 13 [protect human health and the environment].

2. Where necessary to comply with paragraph 1 (above) and to facilitate or improve recovery, waste shall be collected separately if technically, environmentally and economically practicable and shall not be mixed with other waste or other material with different properties.

• Article 11 - Re-use and recycling:1. Member States shall take measures to promote high quality recycling and,

to this end, shall set up separate collections of waste where technically, environmentally and economically practicable and appropriate to meet the necessary quality standards for the relevant recycling sectors. Subject to Article 10(2), by 2015 separate collection shall be set up for at least the following: paper, metal, plastic and glass

rWFD requirements


• Assessment is split into two parts.1. Necessity test – is a separate collection system necessary to permit

high quality recycling?– TEEP test needs to be undertaken if the Necessity Tests

concludes that:• Separate collection is necessary to improve or facilitate

recovery; or• It is not possible to reach a conclusion about the relative

quality of the different collection routes due to insufficient data2. TEEP test – separate collection is only required if it is Technically,

Environmentally or Economically Practicable.

Necessity and TEEP assessment


• Technical: Need to demonstrate that there is no reasonable way to carry out a separate collection– Kerbside sort systems operating across a range of geographies– Limited potential to make technical arguments e.g. Significant practical

barriers, such as: dispersed communities with low waste arisings, non-standard properties, e.g. narrow access issues etc.

• Economic: Need to demonstrate that a separate collection would incur excessive and disproportionate costs - even when the value of materials are considered

• Environment: Need to demonstrate that the negative environmental effects outweigh the benefits– Recycling rates, landfill diversion, carbon impacts, life cycle

considerations, and local environmental impacts such as air quality

TEEP


Source: http://www.wrap.org.uk/sites/files/wrap/Route%20Map%20Revised%20Dec%2014.pdf

Waste Regulation Route Map

http://www.wrap.org.uk/sites/files/wrap/Route%20Map%20Revised%20Dec%2014.pdf




• No formal definition of ‘facilitate’ or 'improve' in the WFD or regulations– Route Map = quality and quantity

• What is meant by 'recovery' in this context?– High-quality recycling

• What is high-quality recycling?– Current consensus

• High-quality recycling = Closed-loop recycling

• To 'meet the necessary quality standards for the relevant recycling sectors.' – Current consensus

• Reprocessors set the standards

Therefore, it has been assumed that the legislation requires that separate collection should increase the quantity of closed-loop recycling

This is tested through the Necessity Test

Approach to the undefined terms set out in rWFD


Economic Practicability and efficiency savings

Optimised Co-mingled Collection

Optimised Separate Collection

Current Service Cost

£0.00 £1,000,000.00 £2,000,000.00 £3,000,000.00 £4,000,000.00

TEEP relates to economically practicable.Separate collection is affordable in this example. It even achieves a saving.

• In England, Local Authorities are being asked to make budget cuts!!– This has an impact on the assessment of economic practicability – As the current budget may not be the baseline for assessing practicability


Separate collection may no longer be TEEP

Optimised Co-mingled Collection

Optimised Separate Collection

Current Service Cost

£0.00 £1,000,000.00 £2,000,000.00 £3,000,000.00 £4,000,000.00

A bigger saving can be achieved through a co-mingled collection ......But, optimised co-mingled gives a bigger saving!


Route Map and the Ricardo-AEA method

Route Map stage 3

Route Map stage 4Necessity test

Route Map stage 4TEEP test

Route Map stage 5Future approach

Route Map stages 1 and 2 Step 1: Baseline

Step 2: Waste hierarchy review

Step 3: Develop options

Step 4: Model options

Baseline model

Step 5: Necessity testQuantity or quality of high-quality recycling

Step 6: Practicality test

Performance Matrix

Step 7: Is separate collection required?

Options model

Model outputs:• Tonnes

• Cost• CO2 Emissions

Regulation 13 Assessment

Review MRF outputs and end destinations


• Aim of modelling is to:– Inform the necessity and practicality tests– Compare options and assess relative

performance– Provide decision makers with robust

information• In-house collection model calculates– Tonnages– Resources– vehicle numbers, staff, containers etc.

– High level CO2 emissions– Costs

Modelling underpins the assessment


• TEEP assessments for seven waste collection authorities in West Sussex– All share the same MRF - tied in to long-term contract

• Waste hierarchy – Analysed current waste destinations using our Waste Hierarchy Matrix– Most materials being dealt with at the appropriate level– Identified some materials that might be worth investigating further– Four key materials all collected at kerbside for recycling

• Necessity Test– Modelled recycling performance to assess quantity and quality– Little difference in performance for paper, cans and plastic– Glass might have higher closed-loop yields if separately collected– So, TEEP assessment needed!

Ricardo-AEA Case Study: West Sussex


• Technically practicable– We found no technical barriers

• Environmentally practicable– Our modelling showed

• Recycling rates likely to be similar• Increased closed-loop recycling of glass is a big factor in improved

performance of separate collection with respect to carbon emissions

• Economically impractical– Over 15% increase in costs for separate collection relative to current

service for all authorities and scenarios

.... continued .....


Separate collection NOT economically practicable!


• Trade waste is included in the legislation– Must provide separate collections to businesses unless it can be shown not

to be necessary or TEEP– Waste collectors (including private sector) must undertake TEEP

assessments of all collections operations– Operational and economic models will be different to a household waste

collection– Approach will need to take the form of a business case– Quality of separate collections may be an issue

for trade collections - especially from SMEs

• At sites where householders directly deliver waste – Household waste recycling centres and bring sites

• Consider is further separation is necessary?• Would it increase quantity or quality?

All collections are covered by the legal requirements


What Necessity & TEEP tests mean for Local Authorities?


• Options for addressing TEEP within the procurement include:– Council specifies co-mingled collections and asks bidders to

provide TEEP assessment – Council undertakes TEEP assessment and then specifies co-

mingled collections based on findings of the TEEP assessment– Council asks bidders to propose a solution and if the solution

is not a multi-stream collection, the bidder must provide evidence of TEEP compliance– Risk could be mitigated by asking contractors to provide

specific evidence regarding necessity and practicability (including cost saving relative to separate collection)

– Council asks bidders to provide costed variants to the bid requiring, as a minimum, a multi-stream system

What does it mean for Local Authorities tendering contracts?

Highest

Lowest

Legi

slat

ive

risk


• Necessity and TEEP tests are here to stay– lead to a paradigm shift in waste decision-making in the UK

• The legislation requires separately collection of the four key materials

• Only if separate collection fails the Necessity or TEEP tests is it not required

• Every time a trigger point is hit the assessment must be revisited

• Triggers might be:– Consideration of service change– Contract ending– New vehicles/ infrastructure required– Materials recycling facility changes (outputs/technology)– Recycling rates change significantly– Quality changes significantly– Significant change in recyclate value

Conclusions


• The UK’s engagement appears more comprehensive than many European countries due to the extent of comingled collections

• Responsibility for assessment of affordability and impacts of TEEP sits with local decision makers, until European definitions and case law are in place

• The UK has not yet established best practice regarding TEEP but has developed useful tools and is approaching consensus

• Experience is that, it is not economically practicable to change away from existing practices

• Evidence-based multi-criteria assessment is key to the UK’s approach to TEEP

• UK approach may help in the debate “separate collections vs comingled” • A useful methodology and evidence base for other countries when

planning for, adopting, and reviewing recycling collections

What’s in it for you?


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Good Morning!


Good Morning!

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Nia Owen

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