Carbon Calculator and TEEP Assessment for Kerbside

Carbon Calculator and TEEP Assessment for Kerbside Collection Options

For London Borough of Hounslow

Maxine von Eye

Peter Jones

Simon Hann

18th May 2015

Report for Andrew Baker, Natasha Epstein, Nicola Taylor and Aled Richards, London Borough of Hounslow

Approved by

………………………………………………….

Joe Papineschi

(Project Director)

Eunomia Research & Consulting Ltd 37 Queen Square Bristol BS1 4QS

United Kingdom

Tel: +44 (0)117 9172250 Fax: +44 (0)8717 142942

Web: www.eunomia.co.uk

Disclaimer

Eunomia Research & Consulting has taken due care in the preparation of this report to ensure that all facts and analysis presented are as accurate as possible within the scope of the project. However no guarantee is provided in respect of the information presented, and Eunomia Research & Consulting is not responsible for decisions or actions taken on the basis of the content of this report.

http://www.eunomia.co.uk/

HOUNSLOW CARBON AND TEEP i

Executive Summary

Eunomia Research and Consulting is please to present this report to the London Borough of Hounslow (LBH) with additional analysis in relation to the upcoming re-procurement of its waste and recycling collection service. This report contains:

additional Hermes collection cost and performance modelling to investigate fortnightly co-mingled recycling collections;

an assessment of the collection options in terms of the GLA’s greenhouse gas (GHG) emissions performance standard; and

a waste regulations compliance check (commonly referred to as TEEP) to investigate whether separate collection is necessary and practicable.

The collection modelling results show that, although fortnightly co-mingled recycling collections offer savings compared to the current service, weekly kerbside sort recycling collections still offer LBH the lowest net cost option. This is partially as a result of the additional collection costs when collecting food waste weekly; the split-back or separate food waste vehicles required when collecting co-mingled recycling make this option more expensive than collecting food waste on the kerbside sort vehicle. In addition, the loss in material income from co-mingled collections has a big impact on the overall cost.

The results from the carbon calculator show that, while all the modelled options perform better than the baseline, kerbside sort performs best overall. The two-stream options (Option 2 and 3) also outperform the fully co-mingled options (Options 4 and 5). The differences are due primarily to the higher contamination collected in the two-stream and co-mingled systems, and the resulting MRF rejects and higher reprocessor rejects.

The work conducted in the course of this project indicates that separate collection may not be necessary to facilitate recovery, but may be necessary to improve recovery of high quality materials. This depends on the MRF that would be used; we have used assumptions based on the average of MRFs in London.

The TEEP analysis clearly indicates that separate collection of the four materials in LBH:

is technically practicable, since it is the system currently being operated;

is economically practicable, since it leads to cost savings compared with the baseline, and would be cheaper than the alternative options modelled; and

is environmentally practicable, since it would result in a net carbon saving, which would be greater than that achievable through the co-mingled or two-stream collections that have been modelled.

Therefore, separate collections are TEEP in Hounslow, so moving away from it would expose LBH to regulatory risk in relation to Waste (England and Wales) Regulations 2011 compliance. However, until prices are obtained from the market through a tendering process, there is considerable uncertainty regarding key variables such as the actual MRF gate fee or material income that would apply. Bidders could be required to bid both a kerbside sort and a co-mingled option, but presents complications for tender evaluation and can be off-putting to bidders. Ideally, LBH would be in a position to make this decision on collection system before the procurement process, or to go to the market with a genuinely open specification, leaving the collection system to be determined by the tender evaluation process. If LBH were to award the contract to a bid based on co-mingled collection, the TEEP test would be re-run at that point.

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HOUNSLOW CARBON AND TEEP iii

Contents

Executive Summary ..................................................................................................... i

1.0 Introduction ................................................................................................... 1

2.0 Collection Modelling Results ........................................................................... 2

2.1 High-Level Results ................................................................................................... 2

2.2 Fortnightly Co-Mingled Options ............................................................................. 3

2.3 Detailed Cost Results .............................................................................................. 4

3.0 Carbon Calculator ........................................................................................... 5

4.0 Waste Regulations Compliance ....................................................................... 8

4.1 Regulatory Background ........................................................................................... 8

4.2 The Necessity Test .................................................................................................. 9

4.2.1 Facilitating Recovery ........................................................................................ 9

4.2.2 Quality of Material ......................................................................................... 10

4.2.3 Necessity Test Conclusions ............................................................................. 11

4.3 The Practicability Test ........................................................................................... 12

4.3.1 Technical Practicability ................................................................................... 12

4.3.2 Economic Practicability .................................................................................. 12

4.3.3 Environmental Practicability .......................................................................... 13

4.3.4 Practicability Test Conclusions ....................................................................... 14

5.0 Summary and Recommendations .................................................................. 14

APPENDICES .............................................................................................................. 15

A.1.0 Collection Modelling .......................................................................................... 16

A.2.0 Environmental Modelling .................................................................................. 24

HOUNSLOW CARBON AND TEEP 1

1.0 Introduction

Eunomia Research & Consulting (Eunomia) has been commissioned by the London Borough of Hounslow (LBH) to present this analysis in relation to the upcoming re-procurement of its waste and recycling collection service. This report presents an update of the previously undertaken modelling, with the addition of a fifth collection option to investigate fortnightly co-mingled recycling collections. All five options, shown in Figure 1, are then compared based on their carbon performance, and a TEEP assessment is undertaken. The modelling undertaken is based on a recent options appraisal for LBH (funded by LWARB) that compared different kerbside collection options for household residual waste, recycling, food waste, and green waste.

Figure 1: Pictogram of Options Modelled

Baseline 1 - KS 2 - TS C+F 3 - TS Co 4 - SS Co 5 - F Co

Dry

Rec

yclin

g

Weekly Two-

Stream (Containers

and Fibres)

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mingled plus

Separate Glass)

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Stream Co-mingled

Food

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teG

arde

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aste Fortnightly Garden

Waste

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idua

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Weekly 140 L

Baseline 1 - KS 2 - TS C+F 3 - TS Co 4 - SS Co 5 - F Co

Weekly Kerbside Sort

Weekly Separate

Fortnightly Charged Garden Waste

Fortnightly 140 L

2x 1x

The structure of this report is as follows:

Collection modelling results are presented in Section 2.0. This section focusses on the additional option (Option 5 – Fortnightly Co-mingled), because the detailed results of the first four options were presented in the LWARB report.

Carbon indicator results are presented in Section 3.0. The modelling undertaken is based on the GLA’s carbon metric, and includes a comparison of all five options to the current baseline service.

Section 4.0 considers the implications for LBH concerning their obligations under the Waste Regulations to separately collect the four dry recycling materials (paper, plastics, metals, and glass), commonly referred to as a TEEP

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assessment, in order to provide evidence relating to compliance with Waste (England and Wales) Regulations 2011 (‘the Regulations’).1, 2

The report concludes with a summary and recommendations in Section 5.0.

2.0 Collection Modelling Results

This section presents the results of the collection options modelling, in particular, the costs associated with delivering each option. The options being investigated are shown in Figure 1, and detailed in the appendix in Table 1.

2.1 High-Level Results

Figure 2 shows the total cost difference from the baseline for each of the five collection options. The key messages are:

All options include the savings from changing to fortnightly residual waste collections and charging for garden waste collections;

Option 1 (weekly kerbside sort) offers the biggest saving, at over £1.3M in annualised revenue equivalent savings;3

Option 2 (weekly two-stream, containers and fibres) and Option 5 (fortnightly single-stream co-mingled) offer similar savings, which are around £175k less than the savings offered by Option 1; and

Option 3 (weekly two-stream co-mingled with separate glass) and Option 4 (weekly single-stream co-mingled) are still cheaper than the baseline, but offer less than £1M in annual savings.

Note that two versions of Option 5 have been modelled (see Section 2.2), and only the cheaper of the two has been carried forward and included in the headline results.

1 HM Government (2011) The Waste (England and Wales) Regulations 2011, S.I. 2011/988

2 HM Government (2012) The Waste (England and Wales) (Amendment) Regulations 2012, S.I. 2012/1889

3 All costs and savings are annualised, with the cost of financing capital investment included as though this

was funded through the revenue budget (for example through finance leasing, prudential borrowing or through the contractor financing assets). This provides a good like-for-like basis for comparison of options.


Figure 2: Cost of each Option Compared to the Baseline

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Diff from BL -£1,357k -£1,161k -£202k -£587k -£1,181k

1 - KS 2 - TS C+F 3 - TS Co 4 - SS Co 5a - F Co

2.2 Fortnightly Co-Mingled Options

As detailed in Table 1 in the appendix, two versions of Option 5 were modelled:

1) Option 5a involves a separate pass for the collection of food waste, while 2) Option 5b involves split-back vehicles on the recycling and residual waste passes

that collect food waste in the smaller compartment of the vehicle.

The detailed cost modelling results of these two options, in comparison to the weekly single-stream co-mingled option (Option 4), are shown in Figure 3. This figure shows:

Overall, Option 5a is the cheapest of the single-stream co-mingled options. The key difference to Option 4 is that the recycling collection (blue bar) is significantly less expensive on a fortnightly basis compared to on a weekly basis. Note that this includes the additional cost of separately collecting food waste on dedicated vehicles.

Option 5b is slightly more expensive than Option 5a. This is because split-back vehicles are being used on the residual waste pass, which reduces the capacity of the main compartment and results in more vehicle being required to provide the service. This additional cost makes the residual collections (grey bar) more expensive than the current costs. Relative to 5a, the residual costs are more than the additional savings in the dry recycling collection costs (blue bar) (i.e. recycling in 5b is £242k cheaper than 5a, but residual is £406k more expensive).

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Figure 3: Details of the Cost of the Two New Fortnightly Co-mingled Options compared to the Weekly Single-Stream Co-mingled Option

5a - F Co 5b - F Co

Collection Costs £2,706k £2,870k

Material Income/MRF Cost £594k £594k

Food Waste Treatment £89k £106k

Garden Waste Treatment £78k £78k

Residual Disposal £5,182k £5,182k

Total £8,648k £8,830k

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2.3 Detailed Cost Results

Figure 4 shows the details of the cost results of all five options (again only including option 5a, since it was cheaper than option 5b). These results show that:

All options benefit from the income from charging for garden waste collections and from the reduction in residual collection frequency. This is modelled as an income of £532k, and is included in the collection cost bar in Figure 4.

Although Option 1 has higher recycling collection costs than most other options, the additional material income from selling the materials offsets this. On the other hand, the co-mingled gate fee for single-stream co-mingled materials is much more expensive than the income received for dry recycling, so the co-mingled options (3, 4, and 5) are all less favourable than Option 1.

The residual treatment cost is higher for Option 1 because it includes material that is collected as contamination in the co-mingled options. In the co-mingled options, this tonnage has a MRF gate fee applied to it, which includes the disposal of rejected materials.

Collecting dry recycling fortnightly in 240 litre wheeled bins (Option 5) does not results in a reduction in the recycling rate compared to the weekly co-mingled option modelled, but does provides collection cost savings compared to weekly co-mingled collections (Option 4).


The material incomes and gate fees are detailed, along with other key modelling assumptions, in Appendix A.1.2.

We note that all options assume the same depot configuration that is co-located with a dry recycling tip. If different arrangements are made, then the kerbside sort options may be marginally more expensive due to the additional land needed to park the larger number of vehicles. Alternatively, the co-mingled options may be marginally more expensive if the depot and tip are not co-located (as a result of more vehicles and/or fuel being used). The details of the depot configurations and total costs are beyond the scope of this project, so the figure of £200k per year is used to represent the marginal cost for kerbside sort only of the additional equipment required to manage separate materials.

Figure 4: Details of the Costs of each Option Compared to the Baseline

BL 1 - KS2 - TSC+F

3 - TSCo

4 - SSCo

5a - FCo

Collection Costs £4,432k £3,888k £3,333k £3,850k £3,264k £2,706k

Material Income/MRF Cost -£810k -£1,030 -£87k £369k £594k £594k

Food Waste Treatment £75k £124k £89k £89k £124k £89k

Garden Waste Treatment £163k £78k £78k £78k £78k £78k

Residual Disposal £5,970k £5,412k £5,256k £5,242k £5,182k £5,182k

Total £9,829k £8,472k £8,668k £9,628k £9,242k £8,648k

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3.0 Carbon Calculator

The environmental assessment of LBH’s municipal waste was conducted using the Greenhouse Gas (GHG) Emissions Performance Standard (EPS) for London which was developed by Eunomia for the GLA in 2010. This has been updated on an annual basis to help the GLA to understand how London is performing against emissions targets. The EPS uses tonnage inputs derived from Waste Data Flow (WDF) which are converted into tonnes of CO2 equivalent (eq.) per tonne of waste managed as the metric for comparison; this is spit into the component parts of the system (transport, recycling, residual, etc.) to allow identification of where in the waste system the largest GHG emissions can occur.

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The same framework has been applied to LBH as an individual authority, but with a few modifications to make comparisons between options more accurate:

Rejects and contamination of dry recycling are an important part of the consideration of whether a co-mingled collection can outperform a kerbside sort collection. Because of this, the EPS has been modified to take this into account. Analysis of WDF reveals that the average MRF reject rate for London is 10.8%, which is also the rate that is suggested as the default in the WDF guidance documentation.

Reprocessor rejects (or process losses) from WRAP reports have been used to calculate how much of the MRF outputs will then actually be recycled. 4 Similarly, reprocessor reject rates for the kerbside sort options have also been used based on a recent study by Zero Waste Scotland.5

All recyclables for kerbside sort and co-mingled are assumed to go to the same end destination, as per the GLA EPS. In particular, the glass is assumed to go 50% to re-melt and 50% to aggregate.6 The results may vary slightly if glass from the MRF goes to aggregate while the glass from kerbside sort goes to re-melt, for example. However, this is not significant enough to change the order of results. See also the discussion of quality of materials in Section 4.2.2.

The transport system calculations use overall London assumptions for the EPS; however, the collection vehicle fuel use has been calculated for the kerbside collection within the Hermes model created for this assessment using MPG figures provided by LBH. It is therefore possible to use these more accurate values to estimate the emissions from the transportation of the waste.7

The EPS takes into account HWRC and bring site recycling and residual waste, as well as kerbside collection. To compare the various options, which reflect changes to the kerbside collection system only, the tonnages from HWRC and bring sites have been used from the 2013/14 WDF. These remain unchanged in all of the options except for the garden waste collected at HWRC, with the exception that it is estimated that introducing a charge-for collection of garden waste will result in 1,341 tonnes of this moving to the HWRC in Options 1-5.

For residual waste, the results are presented in two ways:

4 Enviros Consulting (2009) MRF Quality Assessment Study, Report for WRAP, November 2009

5 Zero Waste Scotland (2014) Contamination in Source-separated Municipal and Business Recyclate in the

UK 2013, March 2014, www.zerowastescotland.org.uk/sites/files/zws/Contamination%20in%20source-separated%20municipal%20and%20business%20recyclate%20in%20the%20UK%202013%20240314.pdf 6 Eunomia. (2011), Development of a Greenhouse Gas Emissions Performance Standard for London’s

Municipal Waste - Revised Report, Report for The Greater London Authority 7 The fact that Hounslow will be using B20 has not been included, since standard London assumptions are

used for the EPS. The transport emissions are only a small part of the total, so this would not change the order of results.

http://www.zerowastescotland.org.uk/sites/files/zws/Contamination%20in%20source-separated%20municipal%20and%20business%20recyclate%20in%20the%20UK%202013%20240314.pdf

http://www.zerowastescotland.org.uk/sites/files/zws/Contamination%20in%20source-separated%20municipal%20and%20business%20recyclate%20in%20the%20UK%202013%20240314.pdf


o The central assumption is that all collected residual goes to incineration, which will be the case from 2016/17 onward. This is the central assumption assumed in the report.

o The split between landfill and incineration has been maintained for all options at the levels reported in WDF for 2013/14 which is approximately 25% incineration and 75% landfill. This split is based upon figures reported by the West London Waste Authority (WLWA) as the disposal authority for LBH. These results are presented in the appendix.

As seen from the total CO2 eq. emissions in Figure 5, the baseline option is the worst performing of the options, principally due to the lower capture rate for dry recyclables. Option 1 performs the best overall with a reduction of 18,277 tonnes of CO2 saved by LBH.

Options 2 to 5, all of which involve commingled collections of some sort, perform at a similar level to one another saving between 16,000 and 17,000 tonnes of CO2; the slight differences are as a result of the different levels of contamination introduced by the variation in the collection systems. Options 2 and 3 are the best performing co-mingled options. Option 2 incorporates a collection using two streams (containers and fibres), which reduces the levels of contamination partly due collecting in boxes as opposed to wheeled bins; this tends to encourage the householder to introduce fewer non-targeted materials and makes it easier for collectors to spot contrary materials. In Option 3, collection of glass, which can be a large source of contamination when broken up with other materials, is collected separately. Options 4 and 5 have the most contamination due to being a fully commingled systems in wheeled bins. Option 5 outperforms option 4 due to the lower fuel usage for fortnightly recycling collections.

Note however that the difference between Options 2 to 5 is not huge, and the performance of the specific MRF can affect these figures, although it is unlikely that even a high performing MRF (~5% rejects) could produce equal or better performance from an environmental point of view relative to Option 1.

A full break down of the results using the GLA EPS is shown in Appendix A.2.2. This includes the results assuming the current residual waste treatment arrangements (25% incineration and 75% landfill), and more details of the results assuming the future arrangements (100% incineration). The comparison between the 75% landfill/25% incineration and 100% incineration scenarios illustrates the importance to the overall results of the switch from landfilling to incineration. Even the baseline, when compared with the current position where 75% of residual waste is sent to landfill, delivers an additional reduction in CO2 eq. of 9,710 tonnes when the switch to 100% incineration of residual waste is made.

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Figure 5: Hounslow Options GHG Comparison assuming 100% Incineration

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Transport Dry Recyclables Organics Incineration Landfill Rejects Total

4.0 Waste Regulations Compliance

This section draws on the findings of the options appraisal (Section 2.0) and environmental modelling (Section 3.0) to provide a view on which options would enable LBH to demonstrate compliance with the Waste England and Wales Regulations 2011 (as amended) (‘the Regulations’). In particular whether separate collection of one or more recyclable materials is necessary or practicable in the terms set out in the law.8,9

4.1 Regulatory Background

Regulation 13 states that from 1st January 2015, all waste collectors in England and Wales are required to collect glass, metal, paper, and plastic (‘the four materials’) in separate streams where doing so is both necessary and technically, economically and environmentally practicable (TEEP).

Effectively, “necessity” and “practicability” constitute two tests that, if met, mean separate collection is required. There is no statutory guidance on how to determine

8 UK Government (2011) The Waste (England and Wales) Regulations 2011, 28

th March 2011

9 UK Government (2014) The Waste (England and Wales) (Amendment) Regulations 2012, 1

st October 2012


whether separate collection is “necessary” or “practicable”. However, WRAP, the London Waste and Recycling Board, and Waste Network Chairs commissioned Eunomia to prepare a “Route-map” to assist authorities in interpreting the law.10 The Environment Agency has signalled that it will take account of the Route-map as part of its regulatory approach.11 The advice provided is therefore closely based on the approach set out in the Route-map.

4.2 The Necessity Test

This section addresses the ‘necessity test’, and seeks to establish whether separate collection of waste streams is, in the words of the Waste Regulations, “necessary to ensure that waste undergoes recovery operations in accordance with Articles 4 and 13 of the Waste Framework Directive and to facilitate or improve recovery”. If separate collection is not necessary, the law does not require it.

There is no definition of “facilitate” or “improve” given in the Waste Framework Directive, the Regulations or any guidance document. However, the Waste Regulations Route Map advises that:

“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:

o more waste is recycled rather than subject to other recovery; and/or o more of the recycling is of “high quality”.

The baseline system in Hounslow features source separated collections of the four materials (glass, metal, paper and plastic) and is therefore clearly compliant with the Waste Regulations’ default requirement that the council collects the four materials separately from all other materials from January 2015.

4.2.1 Facilitating Recovery

The Regulations state that separate collection is required if it is necessary in order to facilitate recovery. The Route Map explains that this can be understood to mean that separate collection is required if it could be expected to yield an increase in the volume of material collected.

There is little evidence based on the experience of other authorities to believe that separate collection delivers a significantly different quantity of the four materials compared with co-mingled collection. The modelling work carried out assumes that all

10

WRAP, and LWARB (2014) Waste Regulations Route-map, April 2014 11

Environment Agency (2014) Separate Collection of Recyclables: Briefing Note, June 2014

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recycling collection options that accompany fortnightly residual waste collections will deliver approximately the same quantity of recyclable material, net of contamination.

Our findings indicate that separate collection is not necessary to facilitate recovery.

4.2.2 Quality of Material

The aim of this section is to review whether separate collection is necessary to improve recovery in Hounslow. If a separate collection system improves recovery, the quality of material expected to be recycled should increase when it is implemented.

The Waste Framework Directive makes it clear that the aim of separate collection is to deliver high quality recycling; however, it is less clear regarding what constitutes ‘high quality’. There are several possible definitions of ‘high quality recycling’ that the council might consider:

1) Article 11 of the Directive appears to define ‘high quality’ in terms of “the necessary quality standards for the relevant recycling sectors”. This can be understood in three main ways:

a. Some have argued that any recyclable material for which an off-taker can be found must of necessity meet the standards of some part or other of the recycling sector. Therefore, all recycling is high quality – only if recyclate is so poor that it cannot be recycled at all would it fail to qualify. The council’s recycling clearly meets this definition of ‘high quality’ – but to rely on it could prove risky in the event of a challenge.

b. If the council’s material attracts premium prices, this might be indicative of it being high quality.

c. Alternatively, the council could compare the purity of its MRF outputs with the input specifications of UK reprocessors.12 Materials that meet the reprocessors’ standards could be deemed to be high quality. This is a lower-risk approach, but sets a standard that many MRFs seem likely to find it difficult to meet.

2) Section 4.3.4 of the Commission’s guidance on the Waste Framework Directive relates “high quality” to the standards achieved through separate collection. It gives two somewhat different statements, advising that separate collection is not necessary if:

a. “the aim of high-quality recycling can be achieved just as well with a form of co-mingled collection”. This suggests that co-mingled collection can be used only if the resulting material can be recycled in just the same way as separately collected material, i.e. there is no use to which it cannot be put that separately collected material could be; and

12

Resource Association Recycling Quality Specifications, accessed 5 August 2014, http://www.resourceassociation.com/recycling-quality-specifications/


b. “subsequent separation can achieve high-quality recycling similar to that achieved with separate collection”. This suggests that some minor differences in the recycling achieved may be permissible.

Whilst it does not have direct application to England, it is perhaps relevant to note that Welsh guidance on the same Regulations characterises “high quality” in terms that are more suggestive of definition 1) c or 2) than of 1) a or b.13

The council does not currently use a MRF, and it is not possible to know with confidence how pure the outputs of any MRF the council might select to sort co-mingled materials may be. However, MRF outputs typically contain higher levels of contamination than separately collected materials (see Appendix A.2.1).

MRF outputs can readily meet the less challenging definitions of “high quality”. However, the council would need to ensure that the outputs from any new MRF with which it might contract in future were considerably purer than is typical to enable it to be able to meet definitions 1) b or c of “high quality” above for all materials. Equally, were the MRF operator able to demonstrate that a large proportion of the material produced from its MRF goes into closed loop recycling, it might be possible to rely on definition 2) a or b.

Unless the council chooses to rely on a relatively weak definition of “high quality” such as 1)a or 1)b above in respect of this material, or is able in the future to evidence that it can meet one of the more testing definitions, it is likely that separate collection would improve recovery, compared with co-mingled collection.

4.2.3 Necessity Test Conclusions

On the basis of the modelling undertaken and the information provided by Hounslow:

separate collection does not increase the quantity of material collected and is therefore not “necessary” (in the technical language of the Regulations) to facilitate recovery of the four materials; and

on certain definitions of “high quality”, separate collection is not necessary in order to improve recovery of materials. However, MRF outputs may not meet more testing definitions of this term. Depending on the definition the council relies on, separate collection may not be necessary in order to improve recovery of the four materials.

It is therefore possible for the council to conclude that separate collections are not necessary to facilitate or improve recovery, provided that it is satisfied that any MRF outputs involved in co-mingled collections are high quality. If that is the case, the Regulations do not require separate collections in the council’s case. However, since

13

Welsh Government (2014) Statutory Guidance on the Separate Collection of Waste Paper, Metal, Plastic and Glass, December 2014, http://wales.gov.uk/docs/desh/publications/141217-statutory-welsh-guidance-on-separate-collection-of-waste-v2-en.pdf

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Hounslow does not currently send its material to a MRF, there is risk involved in relying on this conclusion. Therefore, in order to give the council a complete view of its compliance position, we will also assess whether a separate collection system is ‘practicable’.

4.3 The Practicability Test

Even where the separate collection of material is necessary in order to facilitate or improve recovery, it is only required under the law where it is deemed to be practicable. The Practicability (TEEP) Test examines whether separate collection would be technically, environmentally and economically practicable. It must be practicable in all three respects in order for it to be required. However, for something not to be practicable is a ‘high hurdle’.14 It is not the same as it being difficult or inconvenient.15

4.3.1 Technical Practicability

The European Commission guidance on the Waste Framework Directive says 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.” (Section 4.3.4)

LBH is one of many local authorities in both urban and rural settings that have implemented separate collections using the kerbside sort system that is modelled as part of this study. Kerbside sort therefore appears to be “a system which has been technically developed and proven to function in practice”.

In conclusion, the council’s track record of separate collections means that it would be difficult to argue that separate collections would not be technically practicable in future.

4.3.2 Economic Practicability

The European Commission guidance on the WFD says that:

“‘Economically practicable’ refers to a separate collection which does not cause excessive costs in comparison with the treatment [including recycling] of a non-separated [co-mingled or residual] waste stream, considering the added value of recovery and recycling and the principle of proportionality.” (Section 4.3.4)

‘Economically practicable’ does not therefore mean ‘the cheapest option’. Separate collection will be economically practicable so long as the cost is not excessive, or

14

Defra, Letter to Local Authority Bodies on the Separate Collection of Waste Paper, Metal, Glass and Plastic, October 2013, p2. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/250013/waste-seperate-collection-201310.pdf 15

Compare UK Recyclate Ltd and Others v Secretary of State for Environment, Food and Rural Affairs and Welsh Ministers, Royal Court of Justice, Case No. CO/6117/2011, paragraph 18

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/250013/waste-seperate-collection-201310.pdf

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/250013/waste-seperate-collection-201310.pdf


disproportionate to the benefits. Except where any extra costs of separate collection are very small or very large, assessing ‘proportionality’ is not straightforward. It may not be sufficient to show, for example, that the extra costs would marginally exceed the current waste budget. It may even be proportionate to consider cuts to other discretionary expenditure in order to meet the legal obligations regarding separate waste collection.

Eunomia has used its collection options appraisal tool Hermes in order to assess the likely cost of different collection systems (see Section 2.1). These modelling results are the basis of our analysis of whether separate collections are economically practicable.

The key conclusions from the economic modelling in terms of the economic practicability of separate collection are that:

all the options that involve some separate collection of materials (kerbside sort and two-stream options) offer savings compared to the baseline;

kerbside sort (Option 1) offers the most savings, £1,357,000, which equates to £176,000 more net savings than the next lowest cost option, fortnightly co-mingled (option 5); and

The modelling suggests that separate collection alongside fortnightly residual waste collections would be the best performing recycling option from an economic perspective. In conclusion, based on the modelling results it appears that separate collection in LBH is economically practicable.

4.3.3 Environmental Practicability

The European Commission guidance on the WFD says that:

“‘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).” (Section 4.3.4)

A system will therefore be environmentally practicable if the benefits from increased or improved recycling outweigh any negative impacts. However, this test is likely to be met by almost any recycling collection system, since the benefits achieved through recycling should almost always outweigh the environmental impacts of its collection and processing. We therefore also look at which collection systems deliver the best overall environmental results.

The results from the carbon calculator (see Section 3.0) show that, while all the modelled options perform better than the baseline, kerbside sort performs best overall, showing a reduction in carbon emission that is 2,097 tonnes greater than that shown in Option 5. The two-stream options (Option 2 and 3) also outperform the fully co-mingled options (Options 4 and 5). It should also be noted though that the greatest driver of improvement versus today’s performance for all options is the change from 75% landfill to 100% incineration, which is being introduced by WLWA.

In conclusion, the results of the modelling show that separate collection is environmentally practicable. It outperforms co-mingled collection due to greater benefit being derived from the material collected and lower infrastructure and processing costs.

14 18/05/2015

4.3.4 Practicability Test Conclusions

The work conducted in the course of this project clearly indicates that separate collection of the four materials in LBH is:

technically practicable, since it is the system currently operated by the LBH;

economically practicable, since it leads to cost savings compared with the baseline, and would be cheaper than the alternative options modelled; and

environmentally practicable, since it would result in net carbon saving, which would be greater than that achievable through the co-mingled or two-stream collections that have been modelled.

5.0 Summary and Recommendations

This report concludes:

Hermes collection modelling to investigate fortnightly co-mingled recycling collections: The collection modelling results show that, although fortnightly co-mingled recycling collections are significantly cheaper than weekly co-mingled recycling collections, weekly kerbside sort recycling collections still offer LBH the lowest cost option once material revenues and MRF gate fees have been taken into account.

An assessment of the collection options in terms of the GLA’s greenhouse gas (GHG) emissions performance standard: The results from the carbon calculator show that, while all the modelled options perform better than the baseline, kerbside sort performs best overall. The two-stream options also outperform the fully co-mingled options.

A waste regulations compliance check (commonly referred to as TEEP) to investigate whether separate collection is necessary and practicable: The work conducted in the course of this project indicates that separate collection may be necessary to facilitate the recovery of high quality recycling, and are practicable (TEEP). So, moving away from separate collection would expose LBH to regulatory risk in relation to Waste Regulations compliance.

In terms of the impact of this on procurement strategy, LBH has three broad options:

1) Bidders could be required to bid both a kerbside sort and a co-mingled option. This presents significant complications for tender evaluation, as a political decision on collection system at that point could open the procurement to challenge. The additional work involved for bidders can also be off-putting.

2) LBH could go to the market with a genuinely open specification, leaving the collection system to be determined entirely by the tender evaluation process.

3) Ideally though, LBH would be in a position to make this key collection system choice before the procurement, simplifying the process and giving market clarity.

If LBH were to award the contract to a bid based on co-mingled collection, the TEEP test would be re-run at that point, to test whether the actual bids changed the position.


APPENDICES

16 18/05/2015

A.1.0 Collection Modelling

A.1.1 Details of Options Modelled

Table 1: Details of Modelling Options

Dry Recycling Food

Waste Garden Waste

Residual Waste

Baseline

Frequency Weekly Weekly Fortnightly Weekly

Container and

Materials

Box for card, cans, glass, and textiles

Reusable sack for paper

Kerbside Caddy

Reusable bag for garden waste

Reusable bag for plastic

packaging

Sacks/140 L Wheeled

Bin

Vehicle Stillage Split-back RCV RCV

Option 1 (KS)

Frequency Weekly Weekly Fortnightly

charged Fortnightly

Container and

Materials

Box for paper and textiles

Box for card and glass

Reusable bag for plastic packaging

Kerbside Caddy

Reusable bag or

wheeled bin

140 L Wheeled

Bin

Vehicle Terberg-type RRV RCV RCV


Dry Recycling Food

Waste Garden Waste

Residual Waste

Option 2 (TS C+F)


charged Fortnightly

Container and

Materials

2x box for plastic packaging, cans, glass

1x reusable bag (or a third box) for paper and

card

Textiles set out in carrier bags

Kerbside Caddy

Reusable bag or

wheeled bin

140 L Wheeled

Bin

Vehicle Split-back RCV Separate-pass food

vehicle RCV RCV

Option 3 (TS Co)


charged Fortnightly

Container and

Materials

140 L wheeled bin for paper, card, plastic

packaging, cans

Box for separate glass


Kerbside Caddy

Reusable bag or

wheeled bin

140 L Wheeled

Bin

Vehicle Split-back RCV Separate-pass food

vehicle RCV RCV

Option 4 (SS Co)


charged Fortnightly

Container and

Materials


packaging, cans, glass


Kerbside Caddy

Reusable bag or

wheeled bin

140 L Wheeled

Bin

Vehicle Split-back RCV RCV RCV

18 18/05/2015

Dry Recycling Food

Waste Garden Waste

Residual Waste

Option 5a (F Co)

Frequency Fortnightly Weekly Fortnightly

charged Fortnightly

Container and

Materials




Kerbside Caddy

Reusable bag or

wheeled bin

140 L Wheeled

Bin

Vehicle RCV Separate-pass food

vehicle RCV RCV

Option 5b (F Co)

Frequency Fortnightly Weekly Fortnightly

charged Fortnightly

Container and

Materials




Kerbside Caddy

Reusable bag or

wheeled bin

140 L Wheeled

Bin

Vehicle Split-back RCV

Alternates with

recycling and

residual

RCV Split-back

RCV

A.1.2 Key Modelling Assumptions

A.1.2.1 Material Incomes and Gate Fees

The values listed here have been updated since the LWARB report in December 2014, following recent changes in the material markets. In particular, note that the co-mingled gate fees have increased as a result of recent market developments and the separately collected material incomes have also decreased by a similar amount. These recent changes in material markets have put secondary materials prices under considerable pressure with the result that, in parts of the reprocessing sector, several well-established companies have collapsed or are struggling to remain solvent. Current market conditions


for service providers are tricky and it is difficult to predict these values with much certainty.

Table 2: Material Incomes (-ve values) and Gate Fees (+ve values)

Material Stream Income/Gate Fee Haulage Total

Paper -£50 * -£50

Card -£60 * -£60

Dense Plastic Packaging -£45 * -£45

Mixed Cans -£215 * -£215

Glass -£10 * -£10

Textiles -£314 * -£314

Mixed Containers £15 £12.50 £27.50

Mixed Fibres -£37.50 * -£20.00

Co-mingled Excl. Glass £16.00 £12.50 £28.50

Co-mingled Incl. Glass £17.50 £12.50 £30.00

Food Waste £25 £10** £25/35

Garden Waste £32 - £32

Residual Waste £116 - £116

Notes:

* ex works

** Where food waste is collected on a recycling pass that does not tip at Transport Avenue, then it is assumed to be tipped with the recycling tip and hauled to Transport Avenue.

- direct delivered

20 18/05/2015

A.1.3 Detailed Modelling Results

A.1.3.1 Recycling Performance of Each Option

Figure 6: Total Recycling Performance Modelled in Hounslow for each Option (the Tonnages and Overall Kerbside Recycling Rate Includes both Low-Rise and Communal Bin Properties)

BL 1 2 3 4 5

KS TS C+F TS Co SS Co F Co

Residual Waste 51,463 46,652 45,310 45,193 44,671 44,671

Garden Waste 5,108 2,426 2,426 2,426 2,426 2,426

Food Waste 2,981 3,549 3,549 3,549 3,549 3,549

Dry Recycling 13,587 17,830 19,172 19,289 19,811 19,811

NI192 36% 40% 40% 40% 40% 40%

Overall Kerbside Recycling Rate 30% 34% 34% 34% 34% 34%

20%

25%

30%

35%

40%

45%

50%

0k

10k

20k

30k

40k

50k

60k

70k

80k

Rec

yclin

g R

ate

Ker

bsi

de

Was

te C

olle

cted

(to

nn

es/y

ear)


A.1.3.2 Resources Required

Table 3: Number of Dry Recycling and Food Waste Vehicles and Crew Modelled by Option

Option Vehicle Type Number of

Vehicles Total Number

of Vehicles Total Number

of Crew

BL

Stillage 13.8

20.4 56 Split-back in food/plastics week 4.0

CB Recycling 1.6

CB plastics + card 0.5+0.5

1 RRV 16.3

18.9 51.5 CB recycling/plastics/card Same as BL

2

Split-back for low-rise recycling 9.0

14.6 41.3 Standard RCV for CB recycling 1.3

Separate food waste 4.4

3

Split-back for recycling 12.4

15.9 51.7 Separate glass vehicle for CB 1.4

Separate food waste 4.4

4 Split-back for food and recycling 12.1 12.1 36.4

5a Standard RCV 5.2

9.6 28.9 Separate food waste 4.4

5b Split-back in food/recycling week

6.5 6.5 19.6

22 18/05/2015

Table 4: Number of Garden Waste Vehicles and Crew Modelled by Option


Vehicles Total Number of

Crew

BL Split-back in food/garden week 3.6 10.8

1-5 Standard RCV 2.2 4.3

Table 5: Number of Residual Waste Vehicles and Crew Modelled by Option


Vehicles Total Number of

Crew

BL RCV without bin lifts for low-rise 9

35 RCV with bin lifts for CB 4

1-5a RCV with bin lifts 10 30

5b Split-back in food/residual week 12.1 36.1

A.1.3.3 Capital Investment Required

Table 6: Capital Investment Required for Each Option

Option Recycling Containers Vehicles Total

1 £214k

£4,062k £4,275k

2 £3,822k £4,036k

3 £659k

£4,497k £5,156k

4 £4,039k £4,698k

5 £882k £3,644k £4,526k


Figure 7: Total System Costs from Figure 2 plus the Annualised Cost of New Containers from Table 6, showing the Net Savings of Each Option

1 - KS 2 - TS C+F 3 - TS Co 4 - SS Co 5a - F Co

Annualised Container Cost £21k £21k £66k £66k £88k

Total System Cost -£1,357k -£1,161k -£202k -£587k -£1,181k

Net Savings -£1,336k -£1,140k -£136k -£522k -£1,093k

-£1,400k

-£1,200k

-£1,000k

-£800k

-£600k

-£400k

-£200k

£k

£200k

£400k

Co

st D

iffe

ren

ce f

rom

Bas

elin

e

24 18/05/2015

A.2.0 Environmental Modelling

A.2.1 Key Assumptions

Table 7 and The kerbside sort contamination rates used are in the first column of Table 8. The quality criteria are not used in the modelling, but are drawn upon in the Necessity Test. Note that the fact that some of the contamination rates are lower than the quality criteria specified by repressors suggests that (a) some separate collectors will have some of their card rejected/downgraded by reprocessors, and (b) many reprocessors do some front-end sorting in order to ensure their machinery is not damaged by contraries in the material. LBH (or SITA) may be aware if they are having any card quality problems, and if not then their material could well be better than this reported average.

Table 8 show the contamination rates assumed for each material stream for co-mingled and kerbside sort respectively. The modelling assumes typical MRF contamination rates in Table 7 for the outputs sent to reprocessors, since this is published data representing a number of typical facilities, rather than a snapshot of one potential facility. The example London MRF shows how these values could vary depending on which MRF the material gets sent to, but is not used in the modelling.

Table 7: MRF Output Contamination Rates

Material Typical MRF16 Example London MRF

Paper 15.8% 4.5%

Card 12.0% 2.7%

Glass 10.4% 9.6%

Mixed Plastic 15.8% 14.7%

Aluminium 2.5% 7.3%

Steel 6.2% 7.5%

16

Enviros Consulting (2009) MRF Quality Assessment Study, Report for WRAP, November 2009


The kerbside sort contamination rates used are in the first column of Table 8. The quality criteria are not used in the modelling, but are drawn upon in the Necessity Test. Note that the fact that some of the contamination rates are lower than the quality criteria specified by repressors suggests that (a) some separate collectors will have some of their card rejected/downgraded by reprocessors, and (b) many reprocessors do some front-end sorting in order to ensure their machinery is not damaged by contraries in the material. LBH (or SITA) may be aware if they are having any card quality problems, and if not then their material could well be better than this reported average.

Table 8: Comparison of Typical Kerbside Sort Contamination and Reprocessor Specifications

Material Typical Kerbside Sort

Contamination Rates17 Quality Criterion: Reprocessor

Specification18

News and PAMs 1.1% 1.0%

Paper 0.9% 3.0%

Card 4.1% 3.0%

Glass 0.4% 1.0%

Mixed Plastic 2.9% 6.0%

HDPE Natural 2.9% 6.0%

PET Coloured 2.9% 6.0%

Aluminium 1.0% 3.0%

Steel 3.0% N/a

17

Zero Waste Scotland (2014) Contamination in Source-separated Municipal and Business Recyclate in the UK 2013, March 2014, http://www.zerowastescotland.org.uk/sites/files/zws/Contamination%20in%20source-separated%20municipal%20and%20business%20recyclate%20in%20the%20UK%202013%20240314.pdf 18

Resource Association Recycling Quality Specifications, accessed 5 August 2014, http://www.resourceassociation.com/recycling-quality-specifications/

26 18/05/2015

A.2.2 Detailed Results

A.2.2.1 Current Disposal Scenario

Figure 8: Hounslow Options GHG Comparison Assuming 25% Incineration and 75% Landfill

-5,718

-9,282-7,799 -7,870 -7,387 -7,480

-25,000

-20,000

-15,000

-10,000

-5,000

0

5,000

10,000

15,000


Option 2(TS C+F)

Option 3(TS Co)

Option 4(SS Co)

Option 5(F Co)

ton

nes

of

CO

2 e

q.


Table 9: GLA Environmental Performance (tonnes of CO2 eq. per tonne of waste managed) assuming 25% Incineration and 75% Landfill

Baseline Option 1

(KS) Option 2 (TS C+F)

Option 3 (TS Co)

Option 4 (SS Co)

Option 5 (F Co)

Transport 0.008 0.007 0.007 0.007 0.008 0.007

Dry Recyclables -0.196 -0.224 -0.213 -0.214 -0.220 -0.210

Organics -0.006 -0.006 -0.006 -0.006 -0.006 -0.006

Incineration 0.010 0.009 0.009 0.009 0.009 0.009

Landfill 0.126 0.118 0.116 0.116 0.114 0.114

Rejects 0.000 0.001 0.008 0.008 0.009 0.009

Total -0.058 -0.089 -0.080 -0.081 -0.076 -0.069


Figure 9: Hounslow Options GLA EPS Comparison Assuming 25% Incineration and 75% Landfill

-0.058

-0.095-0.080 -0.081 -0.076 -0.077

-0.25

-0.20

-0.15

-0.10

-0.05

0.00

0.05

0.10

0.15


Option 2(TS C+F)

Option 3(TS Co)

Option 4(SS Co)

Option 5(F Co)

ton

nes

of

CO

2 e

q. p

er t

on

ne

of

Was

te M

anag

ed


A.2.2.2 Future Disposal Scenario

The GHG comparison assuming 100% incineration is shown in the main report, in Figure 5.

Table 10: Environmental Performance (tonnes of CO2 eq. per tonne of waste managed) assuming 100% Incineration

Baseline Option 1

(KS) Option 2 (TS C+F)

Option 3 (TS Co)

Option 4 (SS Co)

Option 5 (F Co)

Transport 0.008 0.007 0.007 0.007 0.008 0.007

Dry Recyclables -0.196 -0.224 -0.213 -0.214 -0.210 -0.210

Organics -0.006 -0.006 -0.006 -0.006 -0.006 -0.006

Incineration 0.037 0.035 0.034 0.034 0.034 0.034

Landfill 0.000 0.000 0.000 0.000 0.000 0.000

Rejects 0.000 0.000 0.000 0.000 0.000 0.000

Total -0.157 -0.188 -0.178 -0.179 -0.174 -0.175

28 18/05/2015

Figure 10: Hounslow Options GLA EPS Comparison Assuming 100% Incineration

-0.157

-0.188-0.178 -0.179 -0.174 -0.175

-0.25

-0.20

-0.15

-0.10

-0.05

0.00

0.05


Option 2(TS C+F)

Option 3(TS Co)

Option 4(SS Co)

Option 5(F Co)

ton

nes

of

CO

2 e

q. p

er t

on

ne

of

Was

te M

anag

ed


Documents

Carbon Calculator and TEEP Assessment for Kerbside