TEEP and lessons learned from UK approach to EU compliance
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A presentation from Dr Nia Owen, Principal Consultant, Ricardo Energy & Environment
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TEEP and lessons learned from UK approach to EU compliance
- 1. TEEP AND LESSONS LEARNED FROM UK APPROACH TO EU COMPLIANCE Dr Nia Owen Principal Consultant
- 2. 2© Ricardo-AEA LtdRicardo 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
- 3. 3© Ricardo-AEA LtdRicardo Energy & Environment in Confidence • 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
- 4. 7© Ricardo-AEA LtdRicardo Energy & Environment in Confidence Legislative Context
- 5. 8© Ricardo-AEA LtdRicardo Energy & Environment in Confidence • 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
- 6. 9© Ricardo-AEA LtdRicardo Energy & Environment in Confidence • To improve the quality of recyclate collected across Europe by requiring key materials to be collected separately Aim of revised EU Waste Framework Directive
- 7. 12© Ricardo-AEA LtdRicardo Energy & Environment in Confidence 12 Recycling Systems
- 8. 13© Ricardo-AEA LtdRicardo Energy & Environment in Confidence • 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
- 9. 14© Ricardo-AEA LtdRicardo Energy & Environment in Confidence • Types of collections used across the UK: Recycling in the UK
- 10. 15© Ricardo-AEA LtdRicardo Energy & Environment in Confidence 15 Necessity & TEEP Tests
- 11. 16© Ricardo-AEA LtdRicardo Energy & Environment in Confidence • 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
- 12. 17© Ricardo-AEA LtdRicardo Energy & Environment in Confidence • 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 data 2. TEEP test – separate collection is only required if it is Technically, Environmentally or Economically Practicable. Necessity and TEEP assessment
- 13. 18© Ricardo-AEA LtdRicardo Energy & Environment in Confidence • 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
- 14. 19© Ricardo-AEA LtdRicardo Energy & Environment in Confidence Source: http://www.wrap.org.uk/sites/files/wrap/Route%20Map%20Revised%20Dec%2014.pdf Waste Regulation Route Map
- 15. 20© Ricardo-AEA LtdRicardo Energy & Environment in Confidence • 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 Approach to the undefined terms set out in rWFD
- 16. 21© Ricardo-AEA LtdRicardo Energy & Environment in Confidence Economic Practicability and efficiency savings £0.00 £1,000,000.00 £2,000,000.00 £3,000,000.00 £4,000,000.00 Optimised Co- mingled Collection Optimised Separate Collection Current Service Cost 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
- 17. 22© Ricardo-AEA LtdRicardo Energy & Environment in Confidence Separate collection may no longer be TEEP £0.00 £1,000,000.00 £2,000,000.00 £3,000,000.00 £4,000,000.00 Optimised Co- mingled Collection Optimised Separate Collection Current Service Cost A bigger saving can be achieved through a co-mingled collection ...... But, optimised co-mingled gives a bigger saving!
- 18. 24© Ricardo-AEA LtdRicardo Energy & Environment in Confidence Route Map and the Ricardo-AEA method Route Map stage 3 Route Map stage 4 Necessity test Route Map stage 4 TEEP test Route Map stage 5 Future 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 test Quantity 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
- 19. 25© Ricardo-AEA LtdRicardo Energy & Environment in Confidence • 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
- 20. 27© Ricardo-AEA LtdRicardo Energy & Environment in Confidence • 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
- 21. 28© Ricardo-AEA LtdRicardo Energy & Environment in Confidence • 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 .....
- 22. 29© Ricardo-AEA LtdRicardo Energy & Environment in Confidence Separate collection NOT economically practicable!
- 23. 30© Ricardo-AEA LtdRicardo Energy & Environment in Confidence • 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
- 24. 31© Ricardo-AEA LtdRicardo Energy & Environment in Confidence What Necessity & TEEP tests mean for Local Authorities?
- 25. 32© Ricardo-AEA LtdRicardo Energy & Environment in Confidence • 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 Legislativerisk
- 26. 33© Ricardo-AEA LtdRicardo Energy & Environment in Confidence • 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
- 27. 34© Ricardo-AEA LtdRicardo Energy & Environment in Confidence • 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?
- 28. 35© Ricardo-AEA LtdRicardo Energy & Environment in Confidence 35 Good Morning!
- 29. 36© Ricardo-AEA LtdRicardo Energy & Environment in Confidence Good Morning!
- 30. © Ricardo-AEA Ltd www.ricardo-aea.com T: E: W: Ricardo-AEA Ltd The Gemini Building Fermi Avenue Harwell, Didcot, OX11 0QR Nia Owen 01235 75 3688 Nia.Owen@ricardo.com www.ricardo.com
Hinweis der Redaktion
- European Union (EU) Thematic Strategy (EC, 2011) on the prevention and recycling of waste was adopted in 2005 and was part of the 6th Environmental Action Programme (2002 – 2012). It is now part of Europe 2020 Strategy for smart, sustainable and inclusive growth. The Thematic Strategy’s aim, in terms of recycling, revolved around “further elaboration of the EU’s recycling policy” building on the existing EU waste legislation and the Waste Framework Directive 2008 (the WFD) (Directive 2008/98/EC). It aims to: Improve recycling, and enable for an EU wide playing field for recycling activities throughout the EU (recycling itself needs to be environmentally sound and this requires the introduction of standards) Make recycling easier Overcome market drivers through appropriate use of the waste hierarchy However the WFD set no minimum quality standards for recyclate which in turn means that global market prices are the primary determinant of how recyclable wastes are managed. It is still the case that recycling and recovery targets are weight-based which lead to Member States being driven by quantity being diverted from landfill rather than the quality of recyclable materials.
- Across the EU, it is has become clear that Member States that are achieving high recycling rates are doing so by using separate collection, and restricting commingled collection to compatible dry waste. This has been a key fact in developing the Revised European Waste Framework Directive (rWFD) and implementing a strict requirement around separate collection of materials.
- Although the legislation for England and Wales is the same the approach taken at a national level is different. Wales – WAG have put in place the Blueprint and have decided for the LAs that separate collection is required and the method they should use. England – left to the LAs and so each LA has had to assess legal situation on their own. There are 326 LAs in England.
- In Scotland the legislation has been handled quite differently with responsibilities placed on the waste producer as well as the collector. If you want any further information about the situation in Scotland please drop me a line.
- Bring site based collections: Householders bring waste to a specific location where glass, paper and card, containers and organic waste are collected in separate (e.g. Spain and Portugal) Kerbside collections of separate waste streams: Householders required to separate waste in to different containers which are collected at the kerbside from outside their property (e.g. Germany and Denmark) Co-mingled collections Local authority collects a range of materials comingled from the kerbside and materials are then sorted at a materials recycling facility (e.g. UK and France) Bring sites and kerbside collections of separate waste streams already compliant with Article 11 requirements and so many countries within the EU are not required to make any changes to their existing systems
- http://laportal.wrap.org.uk/ORIS.aspx Across the UK, there are two common approaches to collecting dry recyclate. Both approaches involve collecting the material from the kerbside, i.e. from outside each household, where the materials are either sorted into different compartments on the collection vehicle – multi-stream or separate collections - or they are collected in a single compartment vehicle and the different dry recyclables are “co-mingled” on the vehicle and then sorted at a Materials Recovery Facility (MRF).
- There are some new terms in Article 11 with no definition.
- All cases we’re aware have reached TEEP – lack of evidence of necessity… extra protection as no definition of required standards
- In England, each local authority must undertake a “TEEP assessment” to determine whether separate collection is required in their context. Defra has not issued formal guidance on legislative compliance as it believes that such decisions should be made at a local level. In order to help, the Waste & Resources Action Programme (WRAP), a government funded charity, and other key stakeholders have issued a Waste Regulation Route Map explaining the key considerations but this is not official guidance. The Route Map was designed for use in England, Wales and NI. Not sure whether it has been used in Wales due to the blueprint? In NI it turns out it doesn’t work very well due to the different wording of the legislation a NI specific Route Map will be produced. THE ROUTE MAP CONSISTS OF A number of steps. The key step is STEP 4 This involves undertaking a Necessity Test and then a TEEP Test Key points: Helped achieve consistent approach to necessity and TEEP BUT doesn’t give all the answers so LA’s need to fill in the blanks Defra did not issue guidance – concerns about judicial revuew
- The legislation introduces a number of new terms which have no formal definition. In the UK, following the early legal challenge to the transposed legislation, the Government has taken a step back and has not provided any formal statutory guidance offering interpretation of these terms. Therefore, in the absence of case law, each local authority has been left to interpret the legislation within their local context. To facilitate or improve recovery There is no definition of “facilitate” or “improve” in the rWFD, regulations or guidance documents. The Waste Regulation Route Map, which is non-statutory advice on how the regulations might be addressed, does give some consideration to these terms. The Route Map suggests the following may be relevant: ““Facilitate” means to make possible or easier. If a measure “facilitates” recovery, it might be expected to result in the amount of material recovered rather than sent for disposal being increased. Recovery is “improved” if it achieves better results. Recovery may therefore be “improved” if: more waste is recycled rather than subject to other recovery; and/or more of the recycling is “high quality”.”. The Route Map definition has not been tested in Case Law and it is also possible that “facilitate” means that as well as referring to quality or quantity, it may simply require that separate collection should make it easier to recover value from the waste than if the material was co-mingled. This requirement would then be similar to the requirement that separate collection is technically practical but could mean that not only should separate collection be practical but that in order to be necessary it should in fact be easier than if the material was co-mingled. In addition, we note that the terms “facilitate” and “improve” suggest this is a relative assessment but it is not clear what the facilitation and improvement should be measured against. In this context it is perhaps reasonable to assume that this is relative to collecting the waste materials together either in a mixed waste stream or in a “co-mingled” recycling scheme. The European Commission (EC) guidance states that if subsequent separation of a co-mingled waste stream can achieve “high-quality recycling similar to that achieved with separate collection, then co-mingling would be in line with Article 11 WFD and the principles of the waste hierarchy”. 3.1.1 High quality recycling It would appear that achieving “high quality recycling” is the primary objective for the stipulation in Article 11 of the rWFD that waste be collected separately. It is therefore reasonable to assume that “facilitating” and “improving” recovery refers to enabling “high quality recycling” to take place. However, there is no definitive definition of this term. In Defra’s Quality Action Plan for England (Defra, 2013) “High Quality Recycling” appears to be defined as closed-loop recycling rather than open loop recycling (although no definitive definition is presented). Under the section entitled “What is high quality recycling and why does it matter?”, the plan states: “In general, there are more environmental benefits in turning recyclate back into a product of similar quality to what it was originally. This is often referred to as ‘closed loop’ recycling, and examples include: - The use of recovered glass in re-melt applications to create new glass products (rather than for aggregate in construction); - The separation of recovered plastic into individual polymers to produce, for example, new food and drinks containers (rather than the use of mixed polymers for low grade construction products); - The use of recovered paper for the production of new paper products (rather than other uses such as animal bedding, insulation etc.).”. 3.1.2 Necessary quality standards for the relevant recycling sectors “High quality recycling” is referred to in Article 11 of the rWFD in the context that this would enable recyclate to “meet the necessary quality standards for the relevant recycling sectors.” These standards are not stipulated in the rWFD, guidance or regulations.
- EU guidance on Economically Practicable ‘Economically practicable’ refers to a separate collection which does not cause excessive costs in comparison with the treatment of a non-separated waste stream, considering the added value of recovery and recycling and the principle of proportionality.”. Is this the same as affordable? Especially in a time when LAs in England are being asked to find 40% budget cuts the current service cost may no longer be affordable. Therefore, for an authority with an existing comingled collection. What is the benchmark? Is it the current cost of the service (which may no longer be affordable) or is it the cost of an optimised comingled collection? A separate collection scheme may be cheaper than current costs but more expensive than an optimised comingled scheme. So is it Economically Practicable? Can the LA decide this? Economics is typically key driver….
- What is the baseline? Current expenditure or the optimised service? Cost benefit analysis and public service delivery
- We use a stepped approach to investigate both the necessity and practicality of separate collection for each council, in order to achieve the aims of the regulations, taking into consideration the best environmental outcome. In order to facilitate this assessment we model the performance of a number of different scenarios for the collection of waste. The modelling provides information relating to the potential performance of each scenario with respect to tonnages collected, tonnages recycled, contamination levels, resource requirements (number of vehicles, containers and staff), costs and environmental burdens. The model under pins the assessment and provides information which is used at various stages in the process: What is the current situation? How might separate collection perform? Would separate collection lead to more recycling? (Necessity) Would separate collection be environmentally or economically practicable (TEEP)? Key things: Build a model, test scenarios and use data to ansewer questions i.e. necessity and TEEP Essentially an options appraisal of different systems Accuracy of assumptions is key – accuracty of national data, knowledge of data from many local authorities plus operational knowledge of team. Ealing – switching from source seg to commingled – twitchy.. Good example
- We use Ricardo-AEA’s mass flow and collections model to create the baseline against which the source separated systems (fully source separated or twin stream) can be assessed. In developing the baseline scenario a range of data is required on the current operations including tonnage information, participation and set out rates, scheme design, work hours and non-productive time elements. The model outputs include an estimated cost for delivery of the service based on the resources required and assumptions relating to vehicle, staff, container and other operational costs, as well as treatment facility gate fees. The total mileage travelled by each collection over the year and the greenhouse gas impact (measured as CO2(eq) emissions) of the system are also calculated. The model is rerun for each option being investigated. This might be Separate collection of all 4 materials, or just glass, just paper and card, an improved comingled collection.
- Technically practicable Low-deprivation authorities with a range of ruralities Differing refuse collections, different vehicle types, some DSOs and some contracted out services We found no technical barriers Environmentally practicable The revised Waste Framework Directive (rWFD) guidance suggests closed-loop recycling and climate impacts more important than local amenity 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 Based on model outputs
- Could flag difference in Scotland
- If you’re looking at changing your service – look to the UK to see the evidence base – range of options, which have been assessed..