Westminster City Council

TEEP Assessment Report

Assessment of compliance with requirements of the Waste (England & Wales) Regulations 2011 (as amended)

18th December 2014

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Contents

Executive summary…………………………………………………………………………………..3

1. Background ...................................................................................................................... 6

1.1. Demographics ............................................................................................................ 6

2. TEEP: the Legal & Technical Position .............................................................................. 9

2.1. The Waste (England and Wales) Regulations 2011 (as amended) ............................. 9

2.2. The Revised Waste Framework Directive ................................................................. 10

2.3. European Commission guidance .............................................................................. 10

2.4. Judicial review 2011 ................................................................................................. 11

2.5. Enforcement Body (EA)……. ………………………………………………………………12

2.6. WRAP - the Waste Regulations Route Map ............................................................. 12

2.7. When & How Frequently to Perform a TEEP Assessment ........................................ 13

2.8. Pending Legal Challenges or Changes ..................................................................... 13

3. ’TEEP Assessment’ ........................................................................................................ 15

3.1. Step 1 – Determine what is collected and how.......................................................... 15

3.2. Step 2 - Check how materials are treated and recycled ............................................ 16

3.3. Step 3 – Apply the Waste Hierarchy ......................................................................... 16

3.4. Step 4 - Decide whether separate collection of the 4 materials is required ............... 17

3.4.1. The necessity test .............................................................................................. 17

3.4.2. The practicability test ......................................................................................... 18

3.4.2.1. Segregated Collections - all streams-Kerbsider Mode 1..…..……………......18

3.4.2.2. SSMDRC with glass collected from bring banks Model 2….………………...21

3.4.2.3. Split back vehicles (30%-70% split) Model 3..…..……………………………..24

3.4.2.4. TEEP summary…………………………………………………………… …….27

3.5. Step 5 - Obtain Sign-Off ……………………………………………………………………27

3.6. Step 6 – Retain evidence .......................................................................................... 27

3.7. Step 7 – Re-evaluation process ................................................................................ 28

4. Conclusions .................................................................................................................... 28

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5. Recommendations .......................................................................................................... 28

6. Appendixes ..................................................................................................................... 29

6.1. Appendix One – Impact assessment of potential collection methodologies ............... 29

6.2. Appendix Two -- Potential cost of new collection methodologies: ............................. 30

6.3. Appendix Three – Waste composition analysis ......................................................... 31

6.4. Appendix Four – Castle Point Borough Council TEEP assessment .......................... 31

6.5. Appendix Five -- London borough of Camden reports……..……………………………31

6.6 Appendix Six -- Air Quality and economic impact reports ……………………………....31

6.7 Appendix Seven -Kerbside Analysis Tool KAT tables and charts.……………………..31

6.8 Appendix Eight--- Legal TEEP- The Waste Regulations 2011 .…………………….…31

6.9 Appendix Nine --- WRAP Kerbside recycling collection & costs reports……………….31

6.10 Appendix Ten --- WCC Doorknocking Reports …………….. .……………………….31

6.11 Appendix Eleven - Carbon Calculator ….........……………… .……………………….31

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Executive Summary

The revised Waste Framework Directive requires the UK to promote high quality recycling.

By 1st January 2015 the UK is required to set up separate collections of paper, plastic, metal

and glass. The requirement to separately collect applies when: (a) it is necessary to ensure

that waste undergoes recovery operations, and to facilitate or improve recovery; [the

necessity test] and (b) it is technically, environmentally and economically practicable ('TEEP')

[the TEEP test]

This report has been complied in line with the WRAP Route Map Guidance Document in the

absence of any guidance provided by DEFRA and agrees that separate collection is

necessary to facilitate recovery.

The City Council has analysed four collection models to test their practicability in accordance

with the Regulations (TEEP Test). The four models analysed were

1. Model 1 : Segregated collection of all four streams – Kerbsider model

2. Model 2: Single stream mixed dry recycling collections from doorstep with glass

collected from bring banks

3. Model 3: Split back vehicles ( 30% glass and 70% other mixed recycling)

4. Model 4: Single stream mixed dry recycling collections (SSMDRC) – Kerbside mixed

collections (including glass) the current collection method.

Our research, analysis, lesson learnt from similar neighbouring boroughs and WRAP

research/reports are summarized in Table 1.

Table 1 - Comparison of key findings of the four modelled options.

Model Technically

Practicable

Environmentally

Practicable

Economically Practicable

Capital Costs On-going costs

p.a.

1. All segregated No +213t of carbon +£3.5m +£1m

2. Separate Glass Yes +1000t of carbon + £3m +£430k

3. Split Vehicle No +161t of carbon +£4.5M +£1m

4. SSMDRC Yes No change No change No change

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Models 1 and 3 failed all three practicability tests. Model 2 was not environmentally or

economically practicable. Model 4 (SSMDRC) proved to be technically, environmentally and

economically practicable in Westminster’s operational environment.

It is recommended that City Council should:

Continue using the SSMDRC model which is technically, environmentally and

economically practicable.

Continue to document and retain all evidences associated with this report so that

future ’TEEP’ assessments can be readily investigated as required

Perform TEEP assessments where any significant changes to its waste management

practice are planned or have occurred until further guidance is issued.

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Authors

Edward Yendluri (Westminster City Council) and Caroline Dupont (Veolia Environmental

Services)

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1. Background

1.1. Demographics

The 2011 census results from the Office of National Statistics suggest that Westminster had

a resident population of 219,400. Up from 190,631 in 2002 (ONS, Mid-Year Estimates

2002). The daytime population however increases to more than one million, including

550,000 people employed in Westminster and more than 29 million tourists visiting each

year. There are more than 3,300 entertainment venues in Westminster, with music and

dance venues alone having capacity for 190,000 people each night. Total capacity in late-

night venues (after 11.00pm) is approximately 225,000.

The 2011 Census also confirmed that Westminster has the:

second smallest average

household size (2.0 persons);

second highest percentage of one-

person households (49%);

second highest percentage of

households living in flats (89%);

fourth lowest percentage of

households with a car or van (37%).

Located in the heart of London the City

of Westminster is home to the Monarchy, the Government and many Commonwealth High

Commissions and foreign embassies. One of 33 London Boroughs, the City includes within

its boundaries some of London’s most prestigious landmarks and districts, including

Westminster Abbey, Houses of Parliament, Buckingham Palace, Big Ben, Marble Arch,

Mayfair, Oxford Street, Piccadilly Circus, Soho and Trafalgar Square.

Within its 2,204 hectares (8.51 square miles) Westminster takes in Regent’s Park to the

north, Hyde Park to the west, and Covent Garden to the east. To the south it follows the

River Thames. The residential areas of the City extend from Queens Park to St John’s

Wood and from Bayswater to Pimlico.

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Westminster is also one of Europe’s most prestigious business locations and houses the

international headquarters of many multinational organisations. Small businesses play an

equally important part in the economy of Westminster. There are 48,000 businesses in

Westminster; more than 93% of firms employ fewer than 25 people.

Westminster has a unique set of challenges to face in delivering sustainable waste

management services which include:

89% of households are flats, waste storage space (internal and external) is as a

result limited The ability to identify who is and isn’t recycling in a multiple

occupancy/high turnover environment to allow targeted communications is a

considerable barrier to achieving elevated recycling rates.

20% of households have single waste chutes severely discouraging recycling

initiatives. To increase the challenge, doorstep recycling collections in many housing

estates and similar multi-occupancy properties are not considered ‘fire safe’ by the

London Fire Brigade and therefore near entry bring facilities are the only viable option

which have already been installed. (65,000 properties)

121,000 households in 6 square miles, 12,000 businesses served. Westminster has a

reported population density of 102 people per hectare compared to 52 and 4 the

London and UK average respectively. However, the WCC figure includes the Royal

Parks and in reality the density is over double that formally reported. The congestion

and complexity of operating in a densely populated environment makes the

consistent capture of high quality recyclables a challenge to access.

The 160 bring sites are subject to contamination/fly-tipping and collection staff

actively check whether materials are suitable for recycling or need to be disposed of

as general waste.

Waste is often (61,000 properties/50% of housing stock) managed by porters,

cleaners, housing management teams (‘gatekeepers’) rather the waste producers.

Door knocking exercises in Westminster are less effective than elsewhere because of

‘gatekeepers’ not allowing access to speak to or deliver leaflets to residents in multi-

occupancy due to privacy concerns.

Resident turnover of 30% per annum means a continual communications effort is

required.

Significant language and cultural diversity.

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A security zone covers 15% of the city preventing the installation of recycling on the

go facilities in some of the highest footfall areas.

Car ownership is low (37% of households have access) limiting the ability of

households to reuse and recycle larger items of waste,

Listed building and conservation areas limit the ability to alter streets and buildings to

incorporate sustainable waste management systems.

Visitor and commuter population is over 1 million each week day.

48,000 businesses generating 2.1% of UK’s GDP.

High number of special events including Royal Events, London Marathon, New Years

Eve, and Notting Hill Carnival where security and a requirement to reopen roads

quickly prevent significant separation of recyclables.

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2. TEEP: The Legal & Technical Position

The legal requirement for waste collection authorities to perform a TEEP assessment is a

complex one (http://ec.europa.eu/environment/waste/framework/pdf/guidance_doc.pdf). In

summary, the UK was required to transpose the requirements of Europe’s revised Waste

Framework Directive (rWFD), which it did. The wording in the resultant English Regulations

was ambiguous. This led to much debate and a series of challenges, by those supporting

complete separate collection of the four material streams of glass, plastic, metals and

papers. Although these challenges culminated in a European Ruling, at the time of writing,

DEFRA has not, and is currently not prepared, to issue any further guidance on the issue.

Therefore, we have included the following summary of the legal and technical position, as

this is the basis upon which we have performed the TEEP assessment.

What guidance is available? – The Waste (England & Wales) Regulations 2011. Note that Regulation 13 was amended in

2012.

– Part 5 of the Regulations. See Annex 1 of the regulations.

– Pages 53-57 of European Commission guidance on the Waste Framework Directive.

– Lord de Mauley’s letter of October 2013 reminded local authorities of their obligations from

2015.

– The Judicial Review Ruling which upheld the 2012 Regulations.

What does 'Separate Collection' mean? Separate collection is defined in Article 3(11) of the Waste Framework Directive as a

collection where a waste stream is kept separate from waste of a different type or nature, so

as to facilitate a specific treatment. Further information on the definition of separate collection

can be found in Chapter 1.5.1.

2.1. The Waste (England and Wales) Regulations 2011 (as amended)

The Waste (England and Wales) Regulations 2011, as amended by the 2012 Regulations,

(’the Waste Regs’) set out what WCAs will have to do.

From 1st January 2015, an establishment or undertaking which collects waste paper, metal,

plastic, or glass, must do so by way of separate collection. And every waste collection

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authority must, when making arrangements for the collection of waste paper, metal, plastic or

glass, ensure that those arrangements are by way of separate collection, where separate

collection is:

a) Necessary to ensure that waste undergoes recovery operation and to facilitate or

improve recovery;

And

b) Technically, environmentally and economically practicable.

2.2. The Revised waste framework directive

The Waste Regs transposes requirements in Articles 3, 10, 11, and 36 of the Revised Waste

Framework directive with references to articles 4 and 13.

Article 11 says – Member State 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.

Article 10(2) is a proviso that separate collection is necessary in order to comply with the

waste hierarchy or in order to protect human health and the environment.

Article 3 defines ’’separate collection” as the collection where a waste stream is kept

separately by type and nature so as to facilitate a specific treatment.

2.3. European Commission guidance

The European Commission has issued guidance on the rWFD, which is relevant. The

guidance states that:

‘Technically practicable’ means that the separate collection may be implemented

through a system which has been technically developed and proven to function in

practice

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‘Environmentally practicable’ should be understood such that the added value of

ecological benefits justify possible negative environmental effects of the separate

collection ( e.g. additional emissions from transport)

’Economically practicable’ refers to a separate collection which does not cause

excessive costs in comparison with the treatment of a non-separate waste stream,

considering the added value of recovery and recycling and the principle of

proportionality.

2.4. Judicial review 2011

In 2011 a Judicial Review was launched against Defra and the Welsh Government,

challenging the way in which the Waste Regs (before being amended in 2012) transposed

provisions of the rWFD relating to the separate collection of paper, metal, plastic and glass.

The application was dismissed on Wednesday 6 March 2013. Mr Justice Hickinbottom’s

points included:

The phrase ”technically, environmentally and economically practicable” is

used in the Directive as a term of art, importing the principle of proportionality

and demanding a sophisticated context-driven exercise of judgment, balancing

(amongst other things) the positive and negative environmental and economic

effects of separate collection.

It was and is open to United Kingdom to fulfil its obligations under the Directive

by the system created by the 2011 Regulations, which allows a local authority

to determine within its area whether separate collection is technically,

environmentally and economically practicable; enforced by the Environment

Agency.

It appears to be common ground that, whilst glass is a well-recognised

potential contaminant, metal and plastic can be separated at a stage later than

kerbside without any significant contamination or other relevant disadvantage.

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2.5 Enforcing Body – The Environment Agency

The Environment Agency is the organisation responsible for ensuring that the Waste Regs

are complied with within England & Wales. At the time of performing the TEEP assessment,

and writing the report, the Environment Agency has not issues guidance on the TEEP

assessment elements of the waste Regs.

It is, however, imperative that Westminster keeps all evidence to demonstrate to the

Environment Agency that it has duly undertaken a TEEP assessment, as required by the

Waste Regs.

2.6. WRAP - the waste regulations route map

WRAP is a not for profit company limited by guarantee, set up with an independent board to

promote resource efficiency. It is funded by an increasing number of governments and other

(not quasi) public sector organisations – it receives funding from DEFRA.

DEFRA has made it clear that they will not, and do not want, formal guidance to be issued.

Therefore, WRAP has facilitated the creation of a ”Route Map”, which has been tested by

several local authorities across the country.

The WRAP Route Map comprises the following 7 steps:

Step 1 - Determine what waste is collected and how

Step 2 - Check how materials are treated and recycled

Step 3 - Apply the waste hierarchy

Step 4 - Decide whether separate collection of the 4 materials is required

o The Necessity Test

o The Practicability Test

Step 5 - Obtain Sign-Off

Step 6 - Retain Evidence

Step 7 - Re-evaluation process

It should be noted that the Route Map is for regulations 12 and 13 of the Waste Regulations:

Regulation 12 concerns itself with assessment of waste management practises in

line with the waste hierarchy.

Regulation 13 is concerned with the separate collection of the four waste streams of

paper, metal, plastic and glass, where it is technically, economically and

environmentally practicable: the TEEP assessment.

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The City Council agrees the separate collection of dry recyclables would yield better quality

but not high capture rates of paper, glass, metals and plastics.

Therefore from this point on this report is only concerned with regulation 13, and hereon

does not make reference to the waste hierarchy. Consequently, some steps in the

assessment, contained within section 3, will be marked as such.

2.7. When & How Frequently to Perform a TEEP Assessment

Current thinking is that TEEP should be assessed within existing Direct Service

Organisations and waste collection contracts from the date of the Judicial Judgement

(6th March 2013) and completed ahead of the date that rWFD passes into law in England

and Wales ( 1st January 2015). DEFRA and industry thinking is that logical decision making

trigger points in relation to re-assessment of TEEP are likely to be:

When existing waste collection contracts are re-tendered or extended

When waste processing services / contracts are re-tendered or extended

When collection service delivery is modernised / amended

When a new vehicle fleet is being procured

When there is a change in local circumstances

2.8. Pending Legal Challenges or Changes

At the time of undertaking the TEEP assessment, and writing the report, there are no know

pending legal challenges, changes to the legislation of formal government guidance.

The outgoing Environment Minister, Lord de Mauley, issued a memo to Local Government

before he left the post in November of 2013. This memo set out the requirements of the act

and reiterated the need for Local Authorities to provide high quality recyclates through the

means of separated collections.

The industry bodies CIWM/ESA suggested that the memo was unhelpful, and along with

Local Authorities, have called for further guidance and support from DEFRA – in particular in

relation to the permissibility of mixed dry recyclable collections.

The Government has suggested that it thinks its position in relation to the Waste Regs is

clear and in particular with the findings of the Judicial Review. The new Environment

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Minister, Dan Rogerson, has already stated publically that he and his department are unlikely

to issue any further guidance in this area.

This view is supported in the recent January 2014 DCLG Guidance on weekly rubbish

collections, which states;

’’In March 2013, the government won a high Court Case, confirming that

councils can continue to provide commingled collections. Councils are not

required by any diktat to make householders separate rubbish into 5 separate

bins.’’

In terms of legal challenge, on the broad consensus of opinion is that there is ’unlikely’ to be

a further high profile national legal challenge from the Campaign for Real Recycling and its

supporters. But this cannot be ruled out.

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3. TEEP Assessment

The WRAP “Route Map” has been used as the framework for performing the TEEP

Assessment. Key factors such as such as mileage, number of vehicles, type of vehicles, fuel

type, number of rounds, CO2 equivalent savings from different material types, WRAP

research on bring sites, kerbsides, cost and income from different collection systems along

with waste composition data were analysed to assess TEEP requirements.

3.1. Step 1 – Determine what is collected and how

Westminster currently provides a single stream mixed dry recycling service (mixed

collections) and typically collects recyclables such as paper, glass, metals, and plastics from

households using four methods, kerbside collections using disposable blue bag , reusable

boxes, near entry bring banks on housing estates and on street communal banks (MRC‘s).

MRC’s can be mixed or segregated and are collected up to 7 days a week. We also collect

segregated paper, cardboard, food waste and glass along with commingled dry recyclables

from commercial properties where storage space and building management allows and we

propose to continue to do so.

The table below provides more service details

Table1. Waste collection methodology for household dry recycling

Scheme name Scheme type Frequency Waste Container

Households on

containers

Flats–

mansions

blocks

Mixed Weekly to

twice a

week

Aerosols, cans ,

cardboard, glass

bottles and jars ,

paper

A combination of

communal bins

and disposable

blue bags

40,000

Flats – Housing

estates

Mixed Twice a

week.

Aerosols, cans ,

cardboard, glass

bottles and jars ,

paper

Communal bins 16,234

Kerbside-

Properties- D2D

collections

Mixed Weekly Aerosols, cans ,

cardboard, glass

bottles and jars ,

paper

Box 11,000

Kerbside –

Properties- D2D

collections

Mixed Weekly Aerosols, cans ,

cardboard, glass

bottles and jars ,

paper

Disposable blue

bags

52,000

TOTAL 119,234.00

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Table 2. Commingled Waste Composition analysis of City of Westminster

(Source: http://laportal.wrap.org.uk/ORIS.aspx)

Waste Type No of HH Total Kgs/year

Collected per year

City of Westminster

Total kgs collected /

HH per annum

City of Westminster

Waste

Composition

Analysis CoW

(Total kgs

collected in the

commingled

collections /HH

per year)

Calculated

Capture Rate

Paper and

Card

119,234 8,191,376 68.7 51.34 74.7%

Glass Bottles

and Jars

119,234 3,755,871 31.5 24.64 78.2%

Cans 119,234 727,327 6.1 3.55 58.2%

Plastics Film 119,234 393,472 3.3 2.98 90.3%

Plastic bottles 119,234 989,642 8.3 6.53 78.7%

Total 14,057,689 117.9 89.04 75.5%

3.2. Step 2 - Check how materials are treated and recycled

After collection, the recyclables are taken to Materials Recovery Facilities (MRF) in

Southwark and Wandsworth, where the collected recyclables are visually inspected for

obvious contamination by the MRF and then loaded into the bag splicer to separate

disposable blue bags. The commingled recyclables are then separated using trammel, wind

sifters, magnet and infra-red sensors along with manual sorting. The separated materials are

then sent to recycling reprocessors in the UK, Western Europe and Asia.

3.3. Step 3 – Apply the waste hierarchy

See section 2.6.

The City Council agrees the separate collection of dry recyclables would yield better quality

but not high capture rates of paper, glass, metals and plastics.

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3.4. Step 4 - Decide whether separate collection of the 4 materials is required

3.4.1. The necessity test

The necessity test concerns itself with identifying whether separate collection is necessary to

facilitate or improve recovery. These terms are not defined in the Regulations. But the Route

Map suggests they refer to a system that facilitates the four affected waste types being:

Captured at a higher rate

And

of a higher quality i.e. meets the necessary quality standards for the relevant

recycling sectors.

The City Council agrees the separate collection of dry recyclables would yield better quality

of paper, glass, metals and plastics. However as regards capture rates the WRAP data1

would suggest otherwise, given that 19 of the top 20 recycling performing local authorities in

England have commingled collection systems and in 2011, WRAP released the report

’’Kerbside collection options’’,2 which advised that commingled recycling schemes increase the

yields of the mixed dry recyclable materials and stated that:

’’Kerbside dry recycling yields can be expected to, on average, be lower than Mixed

recycling yields (all other factors being equals) as follows :

- 10.5% lower if kerbside dry collections are carried out weekly;

- 18.3% lower if kerbside dry collections are carried out fortnightly.’’

The Regulations refer to ’high quality’, and it is well known in the waste industry that glass

within mixed collections do negatively affect the quality of paper3. However the same do not

apply to the quality of metals and plastics when collected with glass.

To capture a better quality of paper, industry recommends collecting glass separately,

however there is no guidance and tested evidence to suggest this process will yield better

capture rate.

To satisfy the TEEP regulations, four different scenarios have been modelled for their

technical, environmental and economical practicability.

1 (http://www.wrap.org.uk/sites/files/wrap/12.%20Commingled_0.pdf)

2

http://www.wrap.org.uk/sites/files/wrap/Choosing%20the%20right%20recycling%20collection%20system.pdf 3 (http://www.wrap.org.uk/sites/files/wrap/12.%20Commingled_0.pdf)

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3.4.2. The practicability test

The practicability test refers to the following three tests

Technically

Environmentally and

Economically.

In this section, the City Council has analysed four scenarios to test their practicability. The

four models analysed were

5. Model 1 : Segregated collections – all four streams– Kerbsider model

6. Model 2: Single stream mixed dry recycling collections from doorstep with

glass collected from bring banks

7. Model 3: Split back vehicles ( 30% glass and 70% other mixed recycling)

8. Model 4 : Single stream mixed dry recycling collections (SSMDRC) – kerbside

mixed collections ( including glass )

3.4.2.1. Segregated collections – all four streams - Kerbsider model (Model 1)

In this model, we look at the possibility of collecting all four streams of dry recyclables i.e.

paper, cardboard, cartons, tins, cans & plastic bottles including pots tubs and trays

separately. Residents would be encouraged to use different colour disposable recycling bags

/ reusable boxes to present their segregated recyclable waste for collections.

The technical, environmental and economical impacts on this model will be as follows

Technically practicable:

This model demands significant additional storage space than is currently provided. Given

89% of residents live in high rise flats with very limited or no storage space internally or

externally this model is considered as technically not practicable. In this model, residents

would have to store, segregate and present all four streams of recyclables separately using

different colour coded bags and boxes for collections and with no storage, it is considered

likely that residents will be discouraged from recycling.

Westminster doorknocking campaigns and recent residents’ surveys on encouraging

recycling service participation states residents prefer a “simple and convenient” service4. In

a City where over 120 languages are spoken (only 58% have English as their first language)

with significant cultural diversity and with 30% residents turnover per annum to ask residents

4 Refer to appendix 10 WCC Doorknocking report

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to segregate their waste and present in four different colour coded bags / boxes would

significantly increase complexity among service users and increase the contamination rate in

dry recycling stream.

In addition, the inability to identify who is and isn’t recycling in a multiple occupancy/high

turnover environment to allow targeted communications is a considerable barrier to achieving

elevated recycling rates and this model with its complexity has the potential to perplex the

service users and lead to increased recycling contamination and fall in yield.

A City with a density of 120k properties in 6 Square miles area, on street parking (parked

cars on road) and restricted access to properties would increase drag distances causing

significant health and safety risk to collection crew.

This option is also considered unsafe in the operating environment. The kerbsider model

necessitates operations to stand to the side of the vehicle. Given on street parking is

common, the vehicle would have to be over the road’s white line to allow access. This is

deemed unsafe and therefore technically impractical.

Considering the above concerns and risks associated with this model 1, City Council

classifies this option as technically not practicable.

Environmentally practicable:

Implementation of this model would have greater adverse impact on the environment than

existing collection system due to the increased number of additional vehicles that are

required to collect segregated waste from kerbside properties, housing estates, mansion

blocks and MRC sites. Experience from other local authorities operating this vehicle type

shows longer loading times and lower pass rates than other modelled options. To collect the

recyclables currently presented would require additional vehicles. As a direct consequence

CO2 equivalent emission will rise5.

This model would significantly increase the inefficiency of the collection fleet, demanding

more vehicles on residential and commercial streets to cope with existing collection

arrangements and generate a bigger carbon footprint. This model will also need additional

normal standard RCV’s to carryout segregate collections from housing estates, MRC’s and

mansion blocks.

It is considered likely that the environmental gain from segregated collections is dwarfed by

the loss of recycling tonnage and elevated environmental impact associated with increased

5 Please refer appendix 1 and 2 for additional vehicles and CO2 impact

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noise, congestion, air pollution and CO2 equivalent. It is acknowledged that this data isn’t

currently available.

The below table demonstrates the additional impact of CO2 by using split vehicles.

Table 3: The additional CO2 equivalent emissions generated from the Kerbsider model in

comparison with that currently delivered

Total fuel

used

(L/Year)

Total miles

driven per

year

Total CO2

emitted per

year (kgs)

Additional CO2

per year

Total CO2

gained from

segregated

collections.

Segregated

collections –

kerbside model

217,826 184,262 574,865 213,397 kgs

N/A

It’s calculated that an additional 213 tonnes of CO2 p.a. will be released into atmosphere

using this model.

Segregated collections using Kerbsider vehicles can yield CO2 emission savings as material

quality is improved. However, the additional emissions generated as a result of reduced

participation and capture of materials far exceeds the savings. The evidence6 suggests the

environmental burden associated with implementing Model 1 would be significant and

classified as environmentally not practicable.

Economically practicable:

The additional costs associated with implementing this model are significant. The City

Council would need to purchase 20 additional RCV’s costing around £2.5m along with 6 four

way split Kerbsider vehicles costing a further £1m7. The current vehicle fleet do not have the

capacity to collect the recyclables separately and with 5 years of depreciation left on the

existing fleet the economic burden of this model is significant (£3.5m+). Given the reduced

participation and capture rates associated with this model the additional disposal costs are

calculated at £1m p.a. (£70 per tonne differential)

It is acknowledged that some of the costs will potentially be offset by lower gate fees

associated with better and improved quality of dry recyclables going through MRF. This

model could not be implemented until 2020 at the earliest without incurring significant costs.

6 Please refer appendix 1 for costs and CO2 impact

7 Please refer appendix 2 for costs

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This model would decrease the pass rate and increase collection inefficiency, demanding

more vehicles on streets along with significant increase in supply demand for different colour

coded bags, boxes and bins.

It should be noted that the increased costs associated with increased congestion and lower

air quality were not included in this calculation, which could be well over £4.5 million per

annum8.

The table below shows the costs for current fleet and additional resources required to secure

new split and additional vehicles

Table 4: Cost comparison of current fleet and model 1 requirements

Collection

service

Cost of

vehicle per

annum

Labour cost

per annum

Cost of fuel

per annum

Total cost per

annum

Additional

cost

SSMDRC £377,369 £1,302,581 £157,254 £1,837,204 /

Split vehicles

and extra RCV’s £2,698,415 £1,590,757 £227,500 £4,516,672 £2,676,468

The additional financial burden of this option (£4m) makes it economically impractical for the

City Council to pursue.

The results of model 1 show it is not technically, environmentally and economically

practicable for City Council to pursue.

3.4.2.2. Mixed collection from doorstep with glass collected from bring banks (Model2)

Model 2 is to collect dry mixed recyclables i.e. paper, cardboard, cartons ,tins, cans & plastic

bottles including pots tubs and trays using disposable bags and reusable boxes and

encourage residents to use bring banks which are dotted across the city to recycle glass.

The technical, environmental and economical impacts of this model are assessed as follows

8 Please refer appendix 6, 6a, 6b, 6c, 6d and 6e for economic impact due to congestion.

22 | P a g e

Technically practicable:

In this option, dry recyclables other than glass are collected the same way as current method

(Single stream mixed dry recycling collections), it is predicated that the capture of the dry

recyclables with the exception of glass will not change and would be of higher quality.

We currently have 87 glass bring banks in the city but the lack of space restricted any

significant expansion of this provision. As only 36% of Westminster residents have access to

cars they would be discouraged from recycling glass and a significantly drop in collected

glass tonnage is predicted. WRAP research suggests bring site usage is only 10-15%

compared with 78% kerbside capture.9

15% of the city classified as a high security zone, preventing the installation of recycling

facilities in some of the highest footfall areas. Westminster has a high density of listed

building and conservation areas further limiting the ability to alter streets to include on-street

facilities.

This model would increase the quality of materials collected but significantly reduce the

quantity of glass collected for recycling and therefore contradicts the aims of Regulation 13.

This model is classified as technically practicable.

Environmentally practicable:

Model 2 results in a loss of recycled glass of 3100t p.a. (based on WRAP’s suggested

guidance of 15% recycled by bring banks and estimate 0.32t CO2 saved by recycling 1t of

glass stats) this equates to 992 tonnes of additional CO2 p.a.

An extra vehicle would be needed to collect segregated glass from bring banks, as a direct

consequence CO2 equivalent emission will rise. (Please refer to appendix 1) These additional

vehicles would generate further pollution including noise, PM10 particulates, NOx and S

emissions.

It is acknowledged that saving are generated by lower MRF emissions with improved quality

and lower MRF usage, however that data isn’t currently available and need further

investigation in the next stage of the report.

Table 5 shows the additional carbon footprint of this model when compared to the current

system (SSMDRC).

9 WRAP bring site evidence –please see appendix 9, 9a and 9b.

23 | P a g e

Table 5: The additional CO2 equivalent emissions generated from model 2 in comparison

with that currently delivered

Total fuel used

(L/Year)

Total miles

driven per year

Total CO2

emitted per year

(kgs)

Additional

CO2 per year

Mixed collection

from doorstep

with glass

collected from

bring banks

Emission due to

loss in recycled

glass

167,826 168,045

390,096kgs

992,000 kgs

29,218 kgs

992,000

It is calculated that an additional 1021 tonnes of CO2 will be emitted per year to collect glass

separately from bring banks, which contradicts council’s commitment to London Mayor’s

Municipal Waste Management Strategy that aims to achieve a 50% reduction in its waste

collection footprint by 2020.

The carbon benefits of having higher quality collected paper were considered insignificant

(estimate of 0.12t CO2 saved by recycling 1t of paper stats, this equates to 0.2t of additional

CO2 p.a. generated for every tonne of glass lost)10. When compared to carbon burden

associated with the loss in glass tonnage.

The additional environmental burden associated with the reduction in collected glass for

recycling makes this option environmentally impractical.

Economically practicable:

On the basis that 3100 tonnes of previously recycled glass would end up in the residual

waste stream and an additional glass collection vehicle would be required this model would

increase the service costs by £320K p.a.

WRAP research indicates glass capture will reduce by 3100 tonnes p.a as bring sites are

less convenient to use than doorstep collection services11.

10

Please refer appendix 11 for carbon calculator 11 Please refer appendix 9, 9a ,9b for kerbside WRAP reports

24 | P a g e

This model could not be implemented until 2020 at the earliest (end of current vehicle life)

without incurring significant costs.

It has been calculated that the gate fee for the remainder of the commingled waste will be

increased by £10 per tonne (£100,000). This is only considered as a short term measure as

MRF’s are reconfigured to take the residual waste streams. Overall this model would result in

significant additional cost (£330K p.a.)12

Table 6: Cost comparison of current fleet and model 2 requirements

Collection

service

Cost of

vehicle per

annum

Labour cost

per annum

Cost of fuel

per annum

Total cost per

annum

Additional

cost

SSMDRC £377,369 £1,302,581 £157,254 £1,837,204 /

Mixed collection

with glass from

bring banks

£440,264 £1,743,953 £193,000 £2,377,217 £540,013

The results of model 2 show it is technically practicable however environmentally and

economically not practicable for City Council to pursue.

3.4.2.3. Split back vehicles - (30% glass and 70% other mixed recycling) (Model 3)

Model 3 is to collect dry mixed recyclables i.e. paper, cardboard, cartons ,tins, glass cans &

plastic bottles including pots tubs and trays from kerbside by using 70% - 30% compartment

split vehicles. All streams of dry recyclables other than glass will be collected using

disposable bags and reusable boxes in the 70% compartment of the vehicle and glass in

reminder 30% compartment. In this model residents will be encouraged to present glass in

separate bags / boxes and separate bins for housing estates and mansion blocks.

The technical, environmental and economical impacts on this model will be as follows

12

Please refer appendix 9a for wrap suggested costs report

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Technically practicable:

In this option, dry recyclables other than glass are collected the same way as current method

(Single stream mixed dry recycling collections), it is predicted that the capture of the dry

recyclables with the exception of glass will not change and would be of higher quality.

As stated in section 3.4.2.1, this model has similar issues associated with storage space,

convenience to residents and H&S to crew and increase contamination rate. Hence City

Council classifies this option as technically not practicable13.

Environmentally practicable:

Implementation of this model would have adverse impacts on the environment due to the

increased number of split vehicles and standard vehicles that are required to collect

segregated waste from kerbside properties, mansion blocks, housing estates and MRC sites.

Experience from other authorities operating this vehicle type shows longer loading times and

lower pass rates than other modelled options. To collect the recyclables currently presented

would require additional vehicles. As a direct consequence CO2 equivalent emission will

rise.

This model would increase the inefficiency of the collection fleet, demanding more vehicles

on residential and commercial streets to cope with existing collection arrangements and

generate a bigger carbon footprint along with increased PM10 particulates, NOx and S

emissions.

The below table 7 demonstrates the additional impact of CO2 by using split vehicles for

glass.

Table 7: The additional CO2 equivalent emissions generated from model 3 in comparison

with that currently delivered

Total fuel used

(L/Year)

Total miles

driven per year

Total CO2

emitted per year

(kgs)

Additional

CO2 per year

Split back collection –

glass in small side,

remainder in the other

side

197,826 196,629 522,083 kgs 161,205 kgs

It is calculated that additional 161 tonnes of CO2 will be released into atmosphere every year

13

Please refer appendix 10 for WCC Doorknocking report.

26 | P a g e

using this model. The carbon savings of having higher quality collected paper were

considered insignificant14, when compared to carbon burden associated with increased

vehicles and loss in glass tonnage and its CO2 impact.

The additional environmental burden associated with the reduction in collected glass for

recycling makes this option environmentally impractical.

Economically practicable:

The additional costs associated with implementing this model are significant. The City

Council would need to purchase 15 split RCV’s costing £1.8m15. The current vehicle fleet do

not have the capacity to collect the recyclables separately and with 5 years of depreciation

left on the existing fleet the economic burden of this model is significant (£3m+). Given the

reduced participation and capture rates associated with this model the additional disposal

costs are calculated at £1m. (£70 per tonne differential)

This model would decrease the pass rate and increase collection inefficiency, demanding

more vehicles on streets along with significant increase in supply demand for different colour

coded bags, boxes and bins. This model could not be implemented until 2020 at the earliest

without incurring significant costs.

The table below shows the increased costs of this model. It should be noted that the

increased costs associated with increased congestion and lower air quality were not included

in this calculation, which could be well over £4.5 million per annum16.

The table 8 below shows the costs for current fleet and resources required to secure new

split vehicles

Table 8: Cost comparison of current fleet and model 3 requirements

Collection

service

Cost of

vehicle per

annum

Labour cost

per annum

Cost of fuel

per annum

Total cost per

annum

Additional

cost

SSMDRC £377,369 £1,302,581 £157,254 £1,837,204 /

Split back collection

glass in small side,

remainder in other

side

£1,875,000 £1,590,757 £227,500 £3,693,257 £1,856,053

14

Please refer section 3.4.2.2 environmental practicable section for CO2 calculations. 15

Please refer appendix 1 for costs 16

Please refer appendix 6, 6a, 6b, 6c, 6d, and 6e

27 | P a g e

The additional financial burden associated with this option (£3m) makes it economically

impractical for the City Council to pursue.

The results of model 3 show it is not technically, environmentally and economically

practicable for City Council to pursue.

3.4.2.4. TEEP Summary

After careful analysis of the possible four collection models, it is clear from the evidence that

segregated four stream collections are technically, environmentally and economically not

practicable in Westminster environment.

Our research, analysis, lesson learnt from similar neighbouring borough and WRAP

suggested case studies17 ,research & reports suggest SSMDRC system is most suitable for

the City Council to pursue.

The table 9 below shows a comparison of key findings from four modelled options.

Table 9: Comparison of all 4 modelled options

Scenarios Technically Environmentally Economically

Capital Costs On-going costs p.a.

All segregated No +213t of carbon +£3.5m +£1m

Separate Glass Yes +1000t of carbon + £3m +£430k

Split Vehicle No +161t of carbon +£4.5M +£1m

SSMDRC No change No change No change No change

3.5. Step 5 - Obtain Sign-Off

The outcomes of this report should be considered alongside with City Council budget

constraints and obtain the appropriate ’sign-off’ from SMT and Head of services.

3.6. Step 6 – Retain evidence

WRAP route map advises to maintain all records pertaining to the TEEP assessment;

including this report and the information related to the waste management service i.e.

number of vehicles and type, mileage, fuel used number of rounds, waste treatment

contracts, costs associated with all aspects of its service.

17

Please refer appendix 9, 9a, 9b

28 | P a g e

The retention of these records and evidence is important to demonstrate compliance with the

requirements of Regulation 13 of the Waste Regulations to the enforcing body, the

Environment Agency.

3.7. Step 7 – Re-evaluation process

There is currently no stated requirement, or guidance, detailing how often City Council must

perform a TEEP assessment in line with Regulation 13 of the Waste Regulations. However,

it is suggested that City Council performs a TEEP assessment where any significant

changes to its waste management practises are planned such as

Procuring a new waste collection contract (2024)

Purchasing new collection vehicle fleet (2020)

Purchasing new waste containers

Negotiating/procuring new waste treatments contracts

4. Conclusions

Segregated four stream collections are technically, environmentally and economically not

practicable in Westminster operational environment.

Two out of the three other collections systems that were modelled are glass from bring banks

and glass collected using split vehicles both proved to be technically, environmentally and

economically not practicable in Westminster operational environment.

The final SSMDRC model has proved to be the technically, environmentally and

economically practicable in Westminster operational environment.

5. Recommendations

It is recommended that City Council should

Continue using the SSMDRC model which is technically, environmentally and

economically practicable.

Continue to document and retain all evidences associated with this report so that

future ’TEEP’ assessments can be readily investigated as required

Perform TEEP assessments where any significant changes to its waste management

practice are planned or have occurred until further guidance is issued.

29 | P a g e

6. Appendices

6.1. Appendix 1 – Impact assessment of potential collection methodologies

Using single compartment compaction to collect glass and paper separate waste streams.

These materials streams will be separated by residents.

Collection

service

Required

number of

collection

teams per

week

Additional

collection

teams

required per

day

Collections per

round/day

Required

number of

staff per

week

Increased

staff per

day

Fuel Effects if

service changes

from current (L)

C02 emitted

per tonne

collected

(KGS)

Carbon

effects if

service

changes

from

current/ C02

per tonne

collected

(Additional

KGS)

SSMDRC 37 / 2876 88 / / 26 /

Mixed

collection

from

doorstep

with glass

collected

from bring

banks

55 18 4107 124 36 31,084 44 21.61

Split back

collection-

glass in

small side,

remainder

in other

side

48 11 1136 144 56 61,083 37 11.47

Segregated

collections-

kerbside

model

60 23 852 160 72 81,083 41 15.22

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6.2 Appendix 2 - Potential cost of new collection methodologies:

Collection

service

Cost of

vehicles per

annum

Labour cost per

annum

Cost of fuel

per annum

Total cost per

annum

Additionnal cost

from current

service

SSMDRC £377,369 £1,302,581 £157,254 £1,837,205 /

Mixed

collection

from

doorstep

with glass

collected

from bring

banks

£440,264 £1,743,953 £193,001 £2,377,218 £540,013

Split back

collection-

glass in

small side,

remainder

in other

side

£1,875,000 £1,590,757 £227,500 £3,693,257 £1,856,052

Segregated

collecions-

kerbside

model

£2,500,000 £1,766,172 £250,500 £4,516,672 £2,679,467

Note:

1. SSMDRC -commingled collection.

2. In this option glass will be removed from the commingled collection and collected

from bring banks. Metals, cans, paper, card and plastics will still be collected in a

commingled way (blue bags).

3. In this option, glass will be removed from the commingled collection. We will use a

split collection vehicle, glass will remain in the small side and metals, cans and

plastics will remain in the other side.

4. In this option, all materials will be collected separately with split body vehicles.

31 | P a g e

6.3. Appendix 3 – Waste composition analysis

Local Authority waste and recycling performance benchmarks 2012/13

Source: (http://laportal.wrap.org.uk/)

The table below displays the kerbside dry recycling yield for each of the main materials

collected (paper, card, cans, glass, plastic bottles, mixed plastic packaging and textiles).

Detail Paper Card Cans GlassPlastic

bottles

Mixed plastic

packaging

All 5 widely

recycled materials

Yield(kg/hh/yr) 50.1 18.6 6.1 31.5 8.3 3.3 114.6

Percentage 43.72 15.78 5.17 26.72 7.04 2.8 101.23

6.4. Appendix 4 – Castle Point Borough Council TEEP assessment

6.5. Appendix 5, 5a, 5b – London borough of Camden – Comingled collections switch

reports

6.6. Appendix 6, 6a, 6b, 6c, 6d, 6e - Air Quality, Traffic and Economic impacts reports

6.7. Appendix 7, 7a, 7b – Kerbside Analysis Tool (KAT)

6.8. Appendix 8 – Legal TEEP – The Waste (England and Wales) Regulations 2011

6.9. Appendix 9, 9a, 9b – WRAP Kerbside Recycling Reports 2011

6.10. Appendix 10 – WCC Doorknocking report

6.11. Appendix 11 – Carbon calculator