WRAP unveils TEEP ‘Waste Regulations Route Map’

The Waste & Resources Action Programme (WRAP) has unveiled its 'Waste Regulations Route Map' to help local authorities understand what recycling services they are legally obligated to provide under waste law.

The Route Map was developed by a working group comprising WRAP, the London Waste and Recycling Board (LWARB) and the Waste Network Chairs assisted by environmental consultancy Eunomia.

The document has been commissioned in “order to reduce the extent to which individual authorities need to invest in advice, and to help bring consistency and clarity to the way that the Waste England and Wales Regulations 2011 (as amended) … are interpreted.”

The regulations state that from January 2015 separate collections of at least paper, metal, plastic and glass are required where they are technically, environmentally and economically practicable (TEEP) and appropriate to meet ‘the necessary quality standards for the relevant recycling sectors’.

Local authorities have been waiting for steps and guidance from the Government on the definition of ‘separately collected’ within the context of TEEP from the start of this year. However, Defra said it will not be publishing guidance on the matter.

Whether local authorities could be liable for prosecution for continuing commingled collections after 2015 has also been a cause for concern for many councils currently operating this system, despite a Judicial Review into the matter in 2013 finding that commingled collections will continue to be permissible.

As such, the working group has released its route map to provide local authorities with a “decision support tool” to assess compliance with the regulations. It is hoped that by using this document, local authorities will avoid “reinventing the wheel” and spending “time and effort developing their own approach”.

The document outlines a six-stage process for local authorities to follow to ensure that they are compliant with the regulations – as well as links to additional information about following the process. It also outlines the need for local authorities to provide a clear audit trail to support any decision taken over services.

It is addressed primarily to English waste collection authorities (WCAs) – but is also relevant to Welsh authorities – and to waste disposal authorities (WDAs) – and is primarily concerned with household waste collections.

The working group notes that its route map is not “guidance” (and therefore is not legal advice) and as such “will not tell a council which materials (if any) it must collect separately”.

However, it also warns local authorities that if they choose not to separately collect plastic, cans and glass they will need to collect evidence to demonstrate that “commingling them allows for high quality recycling” in their area.

WRAP head of resource management Linda Crichton said: “The Route Map provides useful information to help local authorities understand the requirements of the Waste Regulations. The Waste Networks Chairs and LWARB are to be commended for taking the initiative forward.We hope this will be a great source of information for local authorities.”

Eunomia director James Fulford added: “The implications for the UK waste and resources sector of the Waste Framework Directive and the related UK Regulations are significant and pressing yet remain poorly understood.

“With statutory guidance no longer expected, various local authority representative organisations stepped into the breach to commission Eunomia to prepare the Waste Regulations Route Map. We’re proud to have been involved and hope that the work will help Local Authorities better understand both existing and new obligations.”

Chartered Institution of Wastes Management chief executive Steve Lee added: “In the absence of official Defra guidance, this ‘routemap’ could be a useful support tool for local authorities when assessing whether their collection arrangements satisfy the legal requirements and to assist with future decision-making.

“It offers the opportunity for local authorities to carry out their assessments in a consistent way that will stand up to scrutiny, and a common framework for those who wish to work together and share approaches.

“Waste collection and recycling is going through a period of change and uncertainty and it is unusual for support of this kind not to come from Government, given the strategic importance of the issues involved and the potentially far reaching consequences.”

Liz Gyekye

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