Councils urged to exercise caution in TEEP tests

Peter Jones, senior consultant at Eunomia Research and Consulting was among the authors of the Waste Regulations Route Map, a tool for local authorities to help assess whether they are compliant with legal obligations from January 2015, when new collection rules come into place.

Speaking at the Local Authority Recycling Advisory Committee (LARAC) annual conference in Nottingham yesterday (October 15), Mr Jones outlined how the Route Map could be used to help authorities meet their obligations.

After January 1, councils will be required to carry out separate collections of at least paper, glass, metal and plastic unless it is not technically, environmentally or economically practicable (TEEP) for them to do so or necessary to encourage ‘high quality recycling’.

Councils are also required to have robust evidence to demonstrate that their collection method meets the requirements of the regulations, but Mr Jones warned that councils must ensure that their assessments are ‘sophisticated and context based’.

He said: “What the regulations tell us to do as a default is that every collection authority must separate materials. The question every collection authority has to apply is ‘is that applicable in our case?’

“At the moment we have got a situation where commingled collections are the majority and the incidence of kerbside sort collections has reduced over the last three years.”

Practicable

Mr Jones noted that he had seen some analyses where councils had focused on justifying a commingled service, even though the burden of proof lies in demonstrating whether separate collection is practicable.

He also warned against using evidence that could be applied nationally, instead recommending that local authorities focus on circumstances relating to their own locality.

He added: “It is important to think about what the aim of your analysis might be. Some organisations have looked to focus on demonstrating that their current collection method is practicable. That may well be established but the law is asking you to establish that separate collection is practicable.

“It is really important to be specific and look at your particular circumstances. It is easy for consultants to fall back on generic comments about the whole country.”

Cost

He also advised local authorities that they should examine every aspect of the costs involved with employing a separate collection system, including the operational and capital costs of such a switch, and any other associated costs.

“Changing collection system could be an expensive option to consider, however what we would suggest doing is looking at the operational costs separately from the capital transition costs. It is important to look at how those costs would factor in over the lifetime of a service otherwise there would not be change to collection systems ever.

“You need to look at the costs and benefits of the whole collection method and I would encourage you to look at separate collection costs earlier. If the circumstances change you may want to revise those tests.”