LAWR

February 2014 Local Authority Waste & Recycling 9 TEEP ANALYSIS authorities find themselves having the most amount of money taken out of their budgets in recent memory. We are half way through a six-year programme of service reductions; after which, most authorities will have reduced their budgets by over 45%. Many authorities will find during their assessments that adding in separate glass collection, for example, will be very costly and highly disruptive to services and, therefore, clearly not economically practicable, particularly within an existing contract." Industry's role So what is industry's role and should the buck stop with local authorities? From a legal viewpoint, the regulations state that it will, but this is a wide and complex issue and in order to facilitate a circular economy there is a need for collaboration and engagement throughout the supply chain. In addition, others in the supply chain will need to work with local authorities if their own objectives are to be met around processing of recyclates. Is it fair to ask authorities to become custodians for commercial areas further down the chain, over which they have little or no control, or should more onus be placed on other sectors? Forward-thinking manufacturers, brands and retailers, responsible for placing packaging in the marketplace, are taking further steps to intervene, supporting the development of a circular economy and ensuring that they are in control of meeting their objectives. There is potential to generate supply chain resource security through these public-private sector relationships, and some local authorities and waste management contractors are already creating partnerships to improve the quality of materials collected in order to enhance their access to appropriate raw materials from the secondary commodity markets. What does high quality mean? Material reprocessors remind us that 'good' quality materials may not necessarily mean achieving the 'highest' quality standards in the market. Understanding the quality requirements of a chosen market and proving the ability to supply a material specification that consistently meets these (therefore providing a reliable, sustainable, 'good- quality' feedstock) is highly valuable to that market, and if evidenced robustly, is suggested by some to be enough to satisfy the regulations. Material markets have a vital role to play in communicating with suppliers on a more transparent and complex level regarding quality requirements. Local authorities should engage through the supply chain in order to better understand and be confident about where their materials are ending up, which the Resource Association has been pushing for some time now through its End Destinations of Recycling Charter. Future procurement processes Local authorities currently procuring new waste services, or due to initiate processes prior to 2015, find themselves under immediate pressure to ensure they can evidence that their decisions meet the 'TEEP' requirements. There is no certainty that any further formal guidance will be published and therefore consideration should be maintained for the key objectives of the new regulations; achieving high-quality recycling solutions. Specifications written to build robust and demonstrable evidence from contactors on their methodology for achieving 'high-quality' materials will be important in proving that services meet 'TEEP' requirements. If local authorities aren't in circumstances which require immediate contractual decisions, the new regulations offer the opportunity to review long-term strategies rather than make knee-jerk decisions. A robust evaluation of current recycling services and alternate options combined with thorough recording of decisions should help to prove that you have considered and made appropriate decisions regarding 'TEEP'. This exercise will work positively to encourage new collaborations and provide clarity in all sectors of this large and complex supply chain, while not only ensuring services comply with 'TEEP', but simultaneously addressing the capture of more materials and more value from these materials, by improving quality. Ultimately, it will facilitate strides toward creating a more sustainable, circular economy. Dee Moloney is managing director at LRS Consultancy

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