1

Report of: Neil Townrow, Waste Management Officer ________________________________________________________________ Report to: Simon Green, Executive Director of Place ________________________________________________________________ Date: 22 March 2016 ________________________________________________________________ Subject: Assessment of Compliance against the Waste Regulations 2011 (TEEP test) ________________________________________________________________ Author of Report: Neil Townrow, tel: 0114 2037622 ________________________________________________________________ Summary:

1.1. The EU’s Waste Framework Directive requires that Member States have in place separate collections of paper, glass, metal and plastic by 1st January 2015.

1.2. Every waste collector must, when making arrangements for the collection

of waste paper, metal, plastic or glass, ensure that those arrangements are by way of separate collection. The requirement to separately collect applies when it is 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; [the necessity test] and it is technically, environmentally and economically practicable ('TEEP') [the TEEP test].

1.3. The Waste Framework Directive is implemented in England and Wales through the Waste (England and Wales) Regulations 2011 (The Regulations) which were later amended in 2012.

1.4. The Regulations have a clear presumption in favour of the material being

collected separately, but there are circumstances where it is possible to collect the materials commingled.

1.5. Collectors who do not have separate collection arrangements in place are

required to review their collection practices and consider carefully if, and

FORM 2a

SHEFFIELD CITY COUNCIL

Officer Non-Key Decision Report

2

how they comply. This should include rigorous application of the Necessity and TEEP tests.

1.6. DEFRA and WRAP have developed a route map to assist local authorities

in carrying out their TEEP Test (Appendix 1). This sets out a 7 staged process (table 1).

1.7. This report uses the route map and details the high-level assessment of compliance to the separate collection requirement in The Regulations for waste and recycling collection services provided by Sheffield City Council.

1.8. Sheffield provides a separate collection service for paper (with card) and

therefore the Council can be seen as compliant with the requirements,

and no further testing for this material stream is required.

1.9. Currently Sheffield provides a commingled collection of glass, cans and

plastics. Separate collection of these materials is required by Regulation

13 if doing so passes both the necessity andTEEP test.

1.10. The Necessity test has found that in Sheffield, the introduction of

separate collections for glass, cans and plastics would not, in all

likelihood lead to an increase in the quantity of material collected or the

quality of output material sent for reprocessing. In addition, the high

proportion of material sent for closed loop recycling means that a move

to separate collections would not lead to an increase in the proportion of

waste sent for closed loop recycling.

1.11. The completion of the TEEP test found:

o From a technical perspective, separate collections are practicable

o Given that the necessity test found no increase in the quantity of material collected, the quality of material sent for reprocessing, nor the proportion of waste sent for closed loop recycling, a move to separate collections of glass, cans and plastics is not environmentally practicable.

o Over the next two years, the Council needs to achieve a 3.4 million

saving from its waste management budget. Given that additional costs associated with introducing separate collections have been estimated at £2,980,418, together with the projected reduction in recycling tonnages collected and no increase in the quality of recycling achieved, the Council deems that the costs associated with extra collections does not provide value for money, and indeed would realise a backward step in terms of environmental benefit. Therefore separate collections are not economically practicable.

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1.12. Having carried out a full assessment of Sheffield’s recycling service, it is

clear that the separate collections are not technically, environmentally or

economically practicable.

________________________________________________________________ Reasons for Recommendations: A review of waste and recycling collection services in Sheffield has been carried out to assess compliance with the requirement to provide separate collections of paper, glass, metal and plastic. The review concluded that separate collections of paper, glass, cans and plastics are NOT technically, economically or environmentally practicable. Therefore, there is no change proposed to the current waste collection arrangements.

The report recommends that approval be given at the appropriate level in order to ‘sign off’ the decision. Such sign off needs to be explicit and provided by a senior officer. The decision / report needs to be reviewed at the appropriate level (whoever has the lead for waste). There should be a full record retained setting out the assessment and the ‘sign off’ process that the Council has gone through.

Under the Leaders Scheme such approval can be provided, as an officer non-key decision, by the relevant Executive Director who can ‘sign off’ that Sheffield City Council’s waste assessment is both comprehensive and robust (utilising the Route map) as required under Waste Regulations 2011. ________________________________________________________________ Recommendations: Approve the review of collection services undertaken by Waste Management to ensure compliance with the requirements of The Waste Framework Directive as implemented in England and Wales through the Waste (England and Wales) Regulations 2011. ________________________________________________________________ Background Papers: Appendix A: Waste Regulations Route Map, April 2014

Category of Report: OPEN

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Statutory and Council Policy Checklist

Financial Implications

NO Cleared by: Chris Nicholson

Legal Implications

YES Cleared by: Henry Watmough-Cownie

Equality of Opportunity Implications

NO Cleared by:

Tackling Health Inequalities Implications

NO Cleared by:

Human Rights Implications

NO Cleared by:

Environmental and Sustainability implications

NO Cleared by:

Economic Impact

NO Cleared by:

Community Safety Implications

NO Cleared by:

Human Resources Implications

NO Cleared by:

Property Implications

NO Cleared by:

Area(s) Affected

None

Relevant Cabinet Portfolio Lead

Councillor Terry Fox, Cabinet Member for Environment, Recycling and Streetscene

Relevant Scrutiny Committee

Economic and Environmental Wellbeing

Is the item a matter which is reserved for approval by the City Council?

YES

Press Release

NO

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REPORT TO THE EXECUTIVE DIRECTOR OF PLACE ASSESSMENT OF COMPLIANCE AGAINST THE WASTE REGULATIONS 2011 (TEEP TEST) 2. SUMMARY

2.1. The EU’s Waste Framework Directive requires that Member States have

in place separate collections of paper, glass, metal and plastic by 1st January 2015.

2.2. Every waste collector must, when making arrangements for the collection

of waste paper, metal, plastic or glass, ensure that those arrangements are by way of separate collection. The requirement to separately collect applies when it is 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; [the necessity test] and it is Technically, Environmentally and Economically Practicable ('TEEP') [the TEEP test].

2.3. The Waste Framework Directive is implemented in England and Wales through the Waste (England and Wales) Regulations 2011 (The Regulations).

2.4. The Regulations have a clear presumption in favour of the materials each

being collected separately, but there are circumstances where it is possible to collect the materials commingled.

2.5. Collectors who do not have separate collection arrangements in place are

required to review their collection practices and consider carefully if and how they comply. This should include rigorous application of the Necessity and TEEP tests.

2.6. DEFRA and WRAP have developed a route map to assist local authorities

in carrying out their TEEP Test (Appendix 1). This sets out a 7 staged process (table 1).

2.7. This report uses the route map and details the high-level assessment of compliance to the separate collection requirement in The Regulations for waste and recycling collection services provided by Sheffield City Council.

2.8. Sheffield provides a separate collection service for paper (with card) and

therefore the Council can be seen as compliant with the requirements,

and no further testing for this material stream is required.

2.9. Currently Sheffield provides a commingled collection of glass, cans and

plastics. Separate collection of these materials is required by Regulation

13 if doing so passes both the necessity and TEEP test.

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2.10. The Necessity test has found that in Sheffield, the introduction of

separate collections for glass, cans and plastics would not, in all

likelihood lead to an increase in the quantity of material collected or the

quality of output material sent for reprocessing. In addition, the high

proportion of material sent for closed loop recycling means that a move

to separate collections would not lead to an increase in the proportion of

waste sent for closed loop recycling.

2.11. The completion of the TEEP test found:

o From a technical perspective, separate collections are practicable

o Given that the Necessity test found no increase in the quantity of material collected, the quality of material sent for reprocessing, nor the proportion of waste sent for closed loop recycling, a move to separate collections of glass, cans and plastics is not environmentally practicable.

o Over the next two years, the Council needs to achieve a 3.4 million

saving from its waste management budget. Given that additional costs associated with introducing separate collections have been estimated at £2,980,418, together with the projected reduction in recycling tonnages collected and no increase in the quality of recycling achieved, the Council deems that the costs associated with extra collections does not provide value for money, and indeed would realise a backward step in terms of environmental benefit. Therefore separate collections are not economically practicable.

2.12. Having carried out a full assessment of Sheffield’s recycling service, it is

clear that the separate collections are not technically, environmentally or

economically practicable.

3. WHAT DOES THIS MEAN FOR SHEFFIELD PEOPLE

3.1. Having carried out a full assessment of Sheffield’s recycling service in

accordance with the Regulations, it is clear that the separate collections

are not technically, environmentally or economically practicable.

Therefore, The TEEP assessment does not require any changes to the

current collection services operating in Sheffield, and Sheffield people

will not be affected in any way.

4. OUTCOME AND SUSTAINABILITY

4.1. The TEEP assessment does not require any changes to the current

collection services operating in Sheffield.

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4.2. Whilst no service changes have been recommended as part of the

assessment, a number of actions were identified to ensure ongoing

compliance:

o Quarterly review of input sampling data, with particular attention

needed for the paper and card content of the container stream

o Ongoing review of output sampling data, published as part of the

MRF protocol.

o The Authority acknowledges there is a lack of data to inform the

proportion of materials sent for closed loop recycling, particularly

plastics. Therefore, as part of future duty of care checks to be

carried out for all new outlets used for Sheffield’s waste streams

(annual checks are carried out for ongoing outlets), work will be

carried out to try and provide greater clarity in this information.

o Minimum annual review of this assessment to ensure ongoing

compliance, and mandatory review prior to any change of collection

type operated by the kerbside collection system.

5. ASSESSMENT OF COMPLIANCE AGAINST THE WASTE REGULATIONS 2011 (TEEP TEST)

5.1. Background:

5.1.1. The EU’s Waste Framework Directive requires that Member States have

in place separate collections of paper, glass, metal and plastic by 1st January 2015.

5.1.2. Every waste collector must, when making arrangements for the collection

of waste paper, metal, plastic or glass, ensure that those arrangements are by way of separate collection. The requirement to separately collect applies when it is 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; [the necessity test] and it is Technically, Environmentally and Economically Practicable ('TEEP') [the TEEP test].

5.1.3. The Waste Framework Directive is implemented in England and Wales through the Waste (England and Wales) Regulations 2011 (The Regulations) which were later amended in 2012.

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5.1.4. The Regulations have a clear presumption in favour of the material being collected separately, but there are circumstances where it is possible to collect the materials commingled.

5.1.5. Collectors who do not have separate collection arrangements in place are

required to review their collection practices and consider carefully if, and how they comply. This should include rigorous application of the Necessity and TEEP tests.

5.1.6. DEFRA and WRAP have developed a route map to assist local authorities

in carrying out their TEEP Test (Appendix 1). This sets out a 7 staged process (table 1).

Table 1: 7 staged TEEP process

5.1.7. This report uses this route map and details the high-level assessment of

compliance to the separate collection requirement in The Regulations for

waste and recycling collection services provided by Sheffield City Council.

5.2. Step 1: What is collected and how

5.2.1. All waste and recycling collection services in Sheffield are carried out by

Veolia, as part of a 35 year integrated waste management contract

running from 2001 until 2036.

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5.2.2. The contract includes all treatment and disposal of waste collected as part

of the services set out in Table 2.

Table 2: Services provided in Sheffield

Service Collection frequency Container Materials collected

Residual

waste Fortnightly (AWC) 240L black bin Residual waste

Dry recycling Fortnightly (AWC)

140L blue bin, 55L blue

box

Paper and card in one container, glass

bottles and jars, cans and plastic

bottles in the other container

Garden Waste

Fortnightly (April -

Oct) 240L green bin Garden waste

Clinical waste Weekly Yellow Sacks Clinical waste

Bulky waste On request N/A Bulky items

Bring sites As required Various

Paper, card, mixed plastics, glass, cans,

textiles

HWRCs As required Various

Paper, card, mixed plastics, glass,

metals, textiles, WEEE, oil,

plasterboard, wood, batteries, bric a

brac, residual waste

5.2.3. The composition of Sheffield’s household waste stream and method of

targeting is shown in table 3. No local waste composition audit has been

carried out across all waste services and so waste composition is based

around the most recent DEFRA waste analysis results, (DEFRA EV0801

National Composition Estimates for Local Authority Collected Waste and

Recycling in England, 2010/11 - prepared by Resource Futures).

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Table 3: 2014/15 estimated tonnage by waste type based on DEFRA composition estimates, 2010/11

Primary Level

Waste type

% of

waste

(primary)

Secondary Level Waste Type % of waste

(secondary)

14/15

Sheffield

waste

(tonnes)

Targeted

for

recycling?

Collected separately from

other recyclables?

Collection service/s

Food waste 16.51% Food waste 16.51% 32246 No No Residual waste - kerbside/HWRCs

Garden waste 17.53% Garden waste 17.53% 34237 Yes Yes Kerbside, HWRCs

Other organic 2.59% Organic pet bedding/litter 2.01% 3924

No No Residual waste - kerbside/HWRCs

Other organics 0.58% 1128

Paper 14.01% Newspapers 4.96% 9678

Yes Yes Kerbside, HWRCs, Bring sites

Magazines 2.92% 5699

Recyclable paper (excl News

and Mags) 3.62% 7075

Other paper 2.52% 4920

Card 4.77% Card packaging 4.25% 8305

Yes Yes Kerbside, HWRCs, Bring sites

Other card 0.52% 1018

Glass 6.88% Packaging glass

6.35% 12403 Yes

No (kerbside with plastic

bottles and cans) Kerbside, HWRCs, Bring sites

Non-packaging glass 0.53% 1033 Yes Yes HWRCs

Metals 3.75% Ferrous food and drink cans

1.15% 2256 Yes

No (kerbside with glass

bottles and plastic bottles,

HWRCs/Bring sites with cans) Kerbside, HWRCs, Bring sites

Other ferrous metal 1.18% 2311 Yes Yes HWRCs

Non-ferrous drinks cans (excl

non-ferrous food tins)

0.28% 537 Yes

No (kerbside with glass

bottles and plastic bottles,

HWRCs/Bring sites with cans) Kerbside, HWRCs, Bring sites

Foil 0.33% 638 Yes Yes HWRCs, Bring Sites

Other non-ferrous metal 0.81% 1574 Yes Yes HWRCs

Plastic 10.18% Plastic film 3.76% 7348 Yes No, collected with cans HWRCs, Bring Sites

Dense plastic

6.42% 12541 Yes

No (kerbside with glass

bottles and cans,

HWRCs/Bring sites with cans) Kerbside, HWRCs, Bring sites

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Textiles 2.96% Artificial textiles, excluding

shoes 1.07% 2084 Yes Yes HWRCs, Bring Sites

Natural textiles, excluding

shoes 1.46% 2852 Yes Yes HWRCs, Bring Sites

Shoes 0.43% 849 Yes Yes HWRCs, Bring Sites

Wood 3.76% Treated and composite wood 2.86% 5592 Yes Yes HWRCs

Untreated wood 0.89% 1743 Yes Yes HWRCs

WEEE 2.44% White goods 0.76% 1483 Yes Yes HWRCs

Large electronic goods

(excluding CRT TVs and

monitors) 0.22% 434 Yes Yes HWRCs

CRT TVs and monitors 0.57% 1112 Yes Yes HWRCs

Other WEEE 0.89% 1745 Yes Yes HWRCs

Hazardous 0.66% Batteries 0.10% 205 Yes Yes HWRCs

Clinical waste 0.12% 242 No No Clinical waste service

Paint/varnish 0.32% 631 No No Residual waste - kerbside/HWRCs

Oil 0.04% 71 Yes Yes HWRCs

Garden herbicides &

pesticides 0.07% 139 No No HWRCs

Sanitary 3.20% Disposable nappies 2.96% 5780 No No Residual waste - kerbside/HWRCs

Other (sanpro and dressings) 0.24% 474 No No Residual waste - kerbside/HWRCs

Furniture 2.04% Furniture

2.04% 3991 Yes Yes HWRCs, Bulky waste

Mattresses 0.65% Mattresses

0.65% 1275 Yes Yes HWRCs, Bulky waste

Misc Combustable 2.50% Carpet/underlay 1.28% 2502 No No Residual waste - kerbside/HWRCs

Other combustibles 1.22% 2379 No No Residual waste - kerbside/HWRCs

Misc. non-

combustable

2.33% Bricks, blocks, plaster 1.16% 2265 Yes Yes HWRCs

Other non-combustibles 1.17% 2286 No No Residual waste - kerbside/HWRCs

Soil 0.58% Soil

0.58% 1125 Yes Yes HWRCs

Other wastes 1.28% Other wastes

1.28% 2493 No No Residual waste - kerbside/HWRCs

Fines 1.37%

Unspecified Fine material

<10mm 1.37% 2677 No No Residual waste - kerbside/HWRCs

100.00%

100.00% 195297

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5.2.4. Table 3 shows that all materials sent for recycling are collected separately

with the exception of plastic bottles, cans and glass bottles at the

kerbside, and cans and plastic bottles at bring sites.

5.2.5. The annual service cost for the kerbside recycling service in Sheffield is

£5,934,139 (2014/15). This includes all collection, treatment and disposal.

5.3. Step 2: How the materials collected are treated and recycled

5.3.1. Sheffield produced 186,661 tonnes of household waste in 2014/15. An

additional 8636 tonnes of soil and rubble was also collected, bringing total

waste arising’s up to 195,297 tonnes.

5.3.2. The amount of material sent for recycling, recovery or landfill is shown in

Table 4. Where possible, the tonnages have been separated by material

stream.

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- Table 4: Collection and disposal routes for collected waste types 14/15

Recycling Energy Recovery Disposal

Primary Level Waste

type

Secondary Level Waste

Type

Tonnes in

Sheffield

waste

stream

14/15 est.

Kerbside HWRCs Bring

Sites

Bulky

Waste

Total

Recycled

Energy Recovery

Facility

Non-

hazardous

landfill

Hazardous

Landfill

Food waste Food waste 32246 0

122050 9354

Garden waste Garden waste 34237 2355 6458 8813

Other organic Organic pet bedding/litter 5052 0

Other organics

Paper Newspapers 36694 13958 1034 1188 16180

Magazines

Recyclable paper (excl

News and Mags)

Other paper

Card Card packaging

Other card

Glass Packaging glass 40639 22732 1260 1033 25026

Non-packaging glass

Metals Ferrous food and drink

cans

Other ferrous metal

Non-ferrous drinks cans

(excl non-ferrous food

tins)

Foil

Other non-ferrous metal

Plastic Plastic film

Dense plastic

Textiles Artificial textiles, excluding

shoes

5785 141 225 366

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Natural textiles, excluding

shoes

Shoes

Wood Treated and composite

wood

7335 4814 4814

Untreated wood

WEEE White goods 4774 1821 1821

Large electronic goods

(excluding CRT TVs and

monitors)

CRT TVs and monitors

Other WEEE

Hazardous Batteries 1288 76 76

Clinical waste

Paint/varnish

Oil

Garden herbicides &

pesticides

Sanitary Disposable nappies 6254 0

Other (sanpro and

dressings)

Furniture Furniture 3991 2145 2145

Matresses Mattresses 1275 0

Misc Combustable Carpet/underlay 4881 0

Other combustibles

Misc. non-combustable Bricks, blocks, plaster 4551 419 419 69

Other non-combustibles

Soil Soil 1125 0

Other wastes Other wastes 2493 99 99

Fines

Unspecified Fine material

<10mm 2677 0 0 0 0 0

59758 122524 13015

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5.3.3. Focussing on the collection of kerbside dry recycling, recyclables are

collected using 70:30 split bodied refuse collection vehicles. The use of

this vehicle type ensures that paper and card is kept separate from the

glass, cans and plastics.

5.3.4. Method statements are in place and include clear guidance to crews to

ensure that collections of containers which include non-target materials

are kept to a minimum.

5.3.5. Paper and card is tipped at Veolia’s paper and card Materials Recycling

Facility (MRF) in Beighton. The glass, cans and plastics are tipped at a

waste transfer station in Tinsley and bulk transferred to Glass Recycling

UK in Barnsley.

5.3.6. Mixed cans and plastic bottles collected from bring sites and the

Household Waste Recycling Centres (HWRCs) are taken to the waste

transfer station in Tinsley and bulk transferred with the kerbside material

to Glass Recycling UK in Barnsley (GRUK).

5.3.7. Once transported to the relevant MRF, the materials are subjected to

sampling as required under The Environmental Permitting (England and

Wales) (Amendment) Regulations 2014, and in accordance with WRAP’s

MRF Code of Practice requirements.

5.3.8. The results of the sampling carried out by Veolia (Jan –Dec 15) at their

paper MRF for the input material are shown in table 5a.

- Table 5a: Quality of materials collected: Veolia, Beighton sampling data

VES Beighton MRF

(Sep14 –Mar 15)

% composition

material input

Target

Material

News and Pams 60.4% Y

Mixed Paper 18.9% Y

OCC 13.0% Y

Other 7.7% N

5.3.9. Whilst the size of the MRF means that no output sampling is required, the

sorting process removes a high proportion of any non-target materials

present and non-target output levels are below the Resource Association

target levels (1.5% for news and pamphlets, 4.5% for mixed paper and

OCC). No loads have been rejected by the processors in the past three

years.

5.3.10. The results of the sampling carried out by GRUK (Jan-Dec 15) for the

glass, cans and plastic input material are shown in table 5b

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- Table 5b: Quality of materials collected: GRUK sampling data

GRUK

(Jan-Dec 15)

% composition

material input

Target

Material

Glass 37.4% Y

Metal 12.8% Y

Plastics 26.0% Y

Paper and card 20.5% N

Other 3.3% N

5.3.11. The sampling data for the input material shows that there is a high

proportion of paper and card within Sheffield’s glass, cans and plastics

waste stream.

5.3.12. Table 5C shows the results of the post sort sampling carried out by GRUK

in April 2015. The output contamination levels are compared to Resource

Association target contamination levels, and show that the contamination

levels for all materials fall within the Resource Association targets, with

the exception of plastics.

- Table 5c: GRUK output sampling

Output

material % Contamination

Resource Recovery

Contamination

Target

Steel 97% 3% N/A

Aluminium 98% 2% 3%

Plastics 84% 16% 5%

Glass 96% 4% < 5%

5.3.13. The sorted materials are then sold on from the MRFs to the processors

shown in Table 6.

- Table 6: Material outlets

Kerbside MRF Material Stream Outlet

Where

Processed

Paper and

Card

Beighton MRF,

Sheffield

Mixed Paper DS Smith, Kent UK

Dong Guan Nine Dragons

Paper Industries Asia

News and Pams UPM Kymmene (UK) Ltd UK

OCC Dong Guan Nine Dragons

Paper Industries Asia

Guandong Lee and Man paper

Ltd Asia

17

Plastic bottles,

glass bottles

cans

GRUK, Barnsley Glass cullet Ardagh Glass UK

Mixed plastics Roydon Polythene UK

Steel cans Northern Trading UK

Morris and Co UK

Aluminium cans Novelis UK

Glass aggregate Newlay Concrete UK

5.3.14. All paper and card is sent for closed loop recycling, as are the metals.

5.3.15. Plastics are sold to Roydon polythene which uses state of the art,

automated technology to sort the materials in to the various plastic types.

Whilst the proportion of plastics sent for closed loop recycling is not

available at this time, plastics are reprocessed domestically, maximising

closed loop recycling.

5.3.16. GRUK have confirmed that 97% of glass material is sent for closed loop

recycling (remelt), the remaining 3% is sent for aggregate.

5.4. Step 3: Waste hierarchy

5.4.1. Regulation 12 of the Waste (England and Wales) Regulations 2011

requires Local authorities to comply with the waste hierarchy. Departure

from it is allowed when the measures that would be required would not be

‘reasonable in the circumstances ‘or when departure will ‘achieve the best

overall environmental outcome where this is justified by life-cycle thinking

on the overall impacts of the generation and management of the waste’

5.4.2. The application of the waste hierarchy in Sheffield was subjected to an

appraisal (table 7 below) to assess compliance with Regulation 12.

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Table 7: Waste stream management compared to waste hierarchy

Material

Waste prevention and

reuse Recycling Recovery * Can material be moved up the waste hierarchy?

Food waste

Love food hate waste

campaign Kerbside black bin Separate collection costs for recycling prohibitive

Garden waste Home composting Kerbside green bin, HWRCs Kerbside black bin

Potential to improve waste reduction

communications

Other organic Kerbside black bin Separate collection costs for recycling prohibitive

Paper

General waste

reduction campaigns Kerbside blue bin/box, bring Sites, HWRCs Kerbside black bin

Potential to improve waste reduction

communications

Card

General waste

reduction campaigns Kerbside blue bin/box, bring Sites, HWRCs Kerbside black bin

Potential to improve waste reduction

communications

Glass

General waste

reduction campaigns Kerbside blue bin/box, bring Sites, HWRCs Kerbside black bin

Potential to improve waste reduction

communications

Metals

General waste

reduction campaigns Kerbside blue bin/box, bring Sites, HWRCs Kerbside black bin

Potential to improve waste reduction

communications

Plastic

General waste

reduction campaigns Kerbside blue bin/box, bring Sites, HWRCs Kerbside black bin

Separate collection costs for mixed plastic

recycling at kerbside is cost prohibitive.

Textiles

General waste

reduction campaigns Bring sites and HWRCs Kerbside black bin

Separate collection costs for kerbside recycling

prohibitive

Wood HWRCs, bulky waste collection Kerbside black bin Limited options to move up waste hierarchy

WEEE HWRCs, bulky waste collection Limited options to move up waste hierarchy

Hazardous HWRCs (batteries and oil)

Limited options for other materials to move up

waste hierarchy

Sanitary Offensive waste only No options available to move up waste hierarchy

Furniture

Some reuse from

HWRCs HWRCs, bulky waste collection Limited options to move up waste hierarchy

Mattresses HWRCs, bulky waste collection Limited options to move up waste hierarchy

Misc Limited options to move up waste hierarchy

19

Combustible

Misc. non-

combustible HWRCs (plaster board, rubble)

Limited options for other materials to move up

waste hierarchy

Soil HWRCs Limited options to move up waste hierarchy

Other wastes Kerbside black bin Limited options to move up waste hierarchy

Fines Kerbside black bin Limited options to move up waste hierarchy

*All black bin waste is taken to Sheffield’s Energy Recovery Facility where it is burned to produce electricity for the national grid and heat for over 140

buildings.

5.4.3. Whilst a review of waste communications will be carried out in 2016 to improve waste reduction messages, any resulting

impact is likely to be limited in terms of achieving tonnage reductions.

5.4.4. In summary, Sheffield can evidence that it has applied the waste hierarchy when considering each waste stream. The

services in place have been designed to target the recycling of key materials, balancing carbon benefit and cost, as well

as allowing for energy recovery from any waste not separated for recycling.

5.5. Step 4: Is separate collection required?

5.5.1. The purpose of step 4 is to determine whether Sheffield needs to operate a separate collection of glass, metals, paper

and plastic.

5.5.2. Sheffield already operates a separate collection of paper (with card) and therefore the Council can be seen as compliant

with the requirements, and no further testing for this material stream is required.

5.5.3. Currently Sheffield operates a commingled collection of glass, cans and plastics. Separate collection of these materials

is required by Regulation 13 if doing so passes both the necessity and TEEP test.

20

5.6. Necessity test

5.6.1. The separate collection of glass, cans and plastic has been subjected to the necessity test. This looks at whether a

separate collection service would facilitate or improve recovery, and consideration is needed to determine whether

separate collections would lead to an increase in the quantity or quality of material collected.

5.6.2. In terms of quantity, there is good amount of evidence to suggest that comingled collection arrangements achieve higher

recycling tonnages than could be achieved with separate collections.

5.6.3. Nationally, when comparing the top 20 dry recycling performers for 2014/15 it can be seen that all apart from North

Somerset, operate some form of comingled collection service.

Table 8: Dry recycling performance of top 20 Local Authorities 14/15

Rank Region Local Authority Authority type

Total household waste (tonnes)

Household dry recycling/ reuse (tonnes)

Dry recycling rate Service Provision (Glass, cans, plastics)

1 Yorkshire and Humber Calderdale MBC Unitary 78,847 35,357 44.8% Multi stream (comingled glass and cans)

2 Yorkshire and Humber

Bradford City MDC (MBC) Unitary 197,455 83,243 42.2% Comingled glass, cans and plastics

3 South East Surrey Heath Borough Council Collection 29,429 11,907 40.5% Comingled glass, cans, plastics and paper

4 South East Vale of White Horse District Council Collection 41,608 14,808 35.6% Comingled glass, cans, plastics and paper

5 South East South Oxfordshire District Council Collection 50,054 17,781 35.5% Comingled glass, cans, plastics and paper

6 South West West Somerset District Council Collection 12,263 4,176 34.1% Multi stream (comingled cans and plastics)

7 South West North Somerset Council Unitary 104,045 34,891 33.5% Multi stream glass, cans, plastics and paper

21

8 South East Waverley Borough Council Collection 42,287 14,117 33.4% Comingled glass, cans, plastics and paper

9 North West Halton Borough Council Unitary 56,692 18,621 32.8% Comingled glass, cans, plastics and paper

10 Eastern Harlow District Council Collection 25,688 8,369 32.6% Comingled glass, cans, plastics and paper

11 W Midlands Worcester City Council Collection 30,977 10,035 32.4% Comingled glass, cans, plastics and paper

12 Eastern Uttlesford District Council Collection 29,308 9,389 32.0% Comingled glass, cans, plastics and paper

13 South East Chiltern District Council Collection 34,676 11,105 32.0% Comingled glass, cans and plastics

14 South East Ashford Borough Council Collection 40,296 12,816 31.8% Comingled glass, cans, plastics and paper

15 South East Tandridge District Council Collection 29,010 9,226 31.8% Comingled glass, cans, plastics and paper

16 London City of London Unitary 3,771 1,192 31.6% Comingled glass, cans, plastics and paper

17 North West Cheshire East Unitary 181,268 56,857 31.4% Comingled glass, cans, plastics and paper

18 Yorkshire and Humber Barnsley MBC Unitary 99,829 31,146 31.2% Comingled glass, cans and plastics

19 Eastern Southend-on-Sea Borough Council Unitary 72,854 22,609 31.0% Comingled glass, cans, plastics and paper

20 E Midlands Rutland County Council Unitary 19,734 6,118 31.0% Comingled glass, cans, plastics and paper

22

5.6.4. The evidence set out in Table 8 suggests it is unlikely that a separate

collection would increase the quantity of recycling collected. This

conclusion is further supported by analysis undertaken by WYG (2013),

Figure 1 that shows that commingled collections tend to collect higher

yields than separate collections.

Figure 1: Range of kerbside dry recycling performance (kg/hhld/yr) by collection type 2011/12

Source: WYG ‘Review of Kerbside Recycling Collection Schemes in the UK in 2011/12’, June 2013 page 7)

5.6.5. The WYG report found that 20 of the top 30 local authority recycling

performers were fully commingled, whilst only 2 of the bottom 30 were

commingled.

Service type

Number

LAs in top

30

Number

LAs in

bottom 30

Fully comingled excluding glass 20 2

Fully comingled including glass 0 3

Two stream, separate paper/card 1 0

Two stream, separate glass 5 0

Other 3 9

Separate including glass 1 13

Separate excluding glass 0 3

23

5.6.6. An analysis of the performance achieved by Sheffield’s nearest

neighbours in 2013/14 is shown in table 9:

24

Table 9: Nearest Neighbour kerbside scheme and performance 13/14

Local Authority

Scheme

Type Materials Collected

Freq of Collection-

Recycling

Freq of

collection -

Residual

Paper

(Kg)

Card

(Kg)

Cans

(Kg)

Glass

(Kg)

Plastics

(Kg)

Coventry Comingled Glass, Cans, Paper, Card & Plastics Fortnightly Weekly 66.1 24.5 8 41.6 10.9

Leeds Comingled Cans, Paper, Card & Plastics Monthly Weekly 51.6 18 5.5 n/a 7.9

Wakefield Twin Steam Glass, Cans, Paper, Card & Plastics Fortnightly Fortnightly 61.8 29.1 11.7 53.6 12.5

Dudley

Multi

Stream Glass, Cans & Paper Fortnightly Weekly 48 n/a 5.1 32.5 n/a

Derby

Single

Material Card & Paper Fortnightly Weekly 36.5 22.9 10 56.6 13.5

Salford Twin Steam Glass, Cans, Paper, Card & Plastics Fortnightly Fortnightly 50.9 23.9 8.6 39.2 9.1

Gateshead Twin Steam Glass, Cans, Paper, Card & Plastics Fortnightly Fortnightly 47.8 32.7 10.6 55.5 14.6

Bristol

Multi

Stream Glass, Cans, Paper, Card & Plastics Weekly Fortnightly 53.1 30.7 9.4 50.7 12.5

Kirklees Comingled Cans, Paper, Card & Plastics Fortnightly Fortnightly 79 29.2 7.6 28.1 11.1

Stoke-on-Trent Twin Steam Glass, Cans, Paper, Card & Plastics Fortnightly Fortnightly 31.1 30.9 10.1 52.5 13.8

Bolton Twin Steam Glass, Cans, Paper, Card & Plastics Fortnightly/Monthly Fortnightly 49.2 23.2 10.4 47.7 11.1

Plymouth Comingled Cans, Paper, Card & Plastics Fortnightly Weekly 68.9 24 7.4 n/a 10.6

Rotherham

Multi

Stream Glass, Cans, Paper & Card Fortnightly Fortnightly 39.7 18.7 9.4 46 n/a

Wolverhampton Comingled Glass, Cans, Paper, Card & Plastics Fortnightly Weekly 87.8 32.5 10.6 55.2 14.5

Sheffield Twin Steam Glass, Cans, Paper, Card & Plastics Fortnightly Fortnightly 47.8 22.5 9.9 45.2 10.5

Table 10 shows that the highest performance amongst Sheffield’s

Nearest Neighbours is achieved by comingled collections, followed by

twin stream. Comparing Sheffield’s twin stream performance by material

against the multi stream averages, shows that Sheffield collects greater

quantities for all materials with the exception of plastics. This is likely to

be because Bristol, as the only authority collecting plastics through a

multi stream service, collects mixed plastics and not just bottles.

Table 10: Average performance of nearest neighbours by scheme type

5.6.7. The combined evidence presented by tables, 8 and 10, supported by

Figure 1 all demonstrate that comingled and twin stream collection

services provide the highest recycling yields. The best performance is

achieved by those authorities operating fully commingled collections

including glass. On average, the type of collection service provided in

Sheffield, namely a two stream system with separate paper, performs

better than separate collection (multi stream) service types.

5.6.8. Using the figures provided in Figure 1 which is sourced using data

compiled from across the UK, projections can be made on Sheffield’s

performance if it moved to a separate collection services.

5.6.9. In 2014/15 Sheffield collected 153kg/hhld/yr of dry recyclables which

means it performs slightly below the median for two stream systems,

but still above the median achieved by the separate collection service

types. Assuming that Sheffield, if it moved to a separate collection

service would perform comparably across the service types, the

kg/hh/yr would decrease to 139 kg/hh/yr if it moved to separate

collections. This equates to an overall decrease of 3,375 tonnes

(based on 14/15 figures).

Average

of Paper

(Kg)

Average

of Card

(Kg)

Average

of Cans

(Kg)

Average

of Glass

(Kg)

Average

of

Plastics

(Kg)

Total

(Kg)

Comingled 70.7 25.6 7.8 41.6 11.0 156.8

Multi Stream 46.9 24.7 8.0 43.1 12.5 135.2

Single

Material 36.5 22.9 10.0 56.6 13.5 139.5

Twin Steam 48.1 27.1 10.2 49.0 11.9 146.3

Grand Total 54.6 25.9 9.0 46.5 11.7

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5.6.10. Quality may be defined in different ways, however for the purpose of

this assessment, the measure of quality centres around ‘the quantity of

material available for closed loop recycling.’

5.6.11. The MRF sampling data carried out by GRUK for the period January to

December 2015 clearly indicates that there is significant proportion of

paper and card within the input material delivered by Sheffield to

GRUK. However, the output material, post sorting, is shown to be

within the limits identified by the Resource Association for all materials

apart from plastics.

5.6.12. The highest quality of recycling is achieved through closed loop

recycling. Given that all metals and 97% of glass is sent for closed loop

recycling, and that the level of plastics sent for closed loop recycling is

maximised, it is unlikely that a separate collection system would

increase the proportion of materials sent for closed loop recycling.

5.6.13. The evidence from the Necessity Test clearly indicates that the

introduction of separate collections for glass, cans and plastics would

not, in all likelihood lead to an increase in the quantity of material

collected or the quality of output material sent for reprocessing. In

addition, the high proportion of material sent for closed loop recycling

means that a move to separate collections would not lead to an

increase in the proportion of waste sent for closed loop recycling.

5.6.14. The high proportion of paper and card within the input container

material highlighted a concern to the Authority, which needed to be

addressed. A series of actions have been implemented by Veolia to

reduce the amount of non-target material being collected in the

container stream. Actions, including crew training realised a reduction

from 20.5% of content being paper and card for Jan-Dec to 10.1%

between Oct-Dec. This is within the 15% limit set by the MRF operator.

Monthly sampling data is to be sent to the Authority to enable continued

monitoring, and trends will be discussed with Veolia on a quarterly

basis.

5.6.15. The Authority acknowledges there is a lack of data to inform the

proportion of plastics sent for closed loop recycling. Therefore, as part

of future duty of care checks to be carried out for all new outlets used

for Sheffield’s waste streams (annual checks are carried out for

ongoing outlets), work will be carried out to try and provide greater

clarity in this area.

5.7. TEEP test

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5.7.1. The TEEP test determines whether separate collections are technically,

environmentally and economically practicable.

5.7.2. Whilst the necessity test found that separate collections do not meet

the necessity test, the TEEP test has been applied to provide greater

assurances and ensure the conclusions are sufficiently robust.

5.7.3. Assessment of technical practicability

5.7.4. With regards to technical practicability, whilst there has been no history

of previous separate collections of glass, cans and plastics in Sheffield,

it is clear that other Local Authorities do operate separate collections.

5.7.5. Whilst the nature of Sheffield’s housing stock, which includes high

density terraced housing, would make it difficult for some households to

accommodate additional recycling containers, leaving aside any cost

limitations, such issues could be overcome using standard refuse

collection vehicles with sacks or a bin caddy, or by using stillage

vehicles and operating a kerbside sort collection system.

5.7.6. From a technical perspective, it is clear that separate collections are

practicable, however, should the results of the TEEP assessment

identify that a change to separate collections is needed, further, more

detailed analysis of housing type and appropriate service delivery

methods would be needed to understand the barriers and limitations

associated with such a change.

5.7.7. Assessment of environmental practicability

5.7.8. The evidence set out in section 5.4 (Necessity) demonstrates that

separate collections would not lead to an increase in the quantity of

material collected, the quality of material sent for reprocessing, nor the

proportion of waste sent for closed loop recycling.

5.7.9. Therefore the move to separate collections of glass, cans and plastics

is not environmentally practicable, and therefore does not meet the

Necessity test.

5.7.10. Assessment of economic practicability

5.7.11. The current cost of Sheffield kerbside recycling service is £5,934,139.

This includes all collection, treatment and accounts for material income

received.

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5.7.12. Following discussions with our contractor, Veolia, we have been able to

project that the estimated service cost for providing separate, mutli

stream collections would amount to additional annual costs amounting

to £2,980,418 bringing the total service cost to £8,914,557. This is

based on a fortnightly collection service of paper and card in a 140 litre

wheeled bin collected by standard refuse collection vehicles, and a 55

litre blue box service for glass, cans and plastics, collected using

stillage vehicles. The increased cost incurred reflect the need for

additional vehicles and staff, together with an increase in the amount of

material presented in the black bin (therefore additional disposal costs),

as projected by a reduction in recycling yields set out in 5.6.9.

5.7.13. Over the next two years, the Council needs to achieve a £3.4 million

saving from its waste management budget. Given that additional costs

associated with introducing separate collections, together with the

projected reduction in recycling tonnages collected and no increase in

the quality of recycling achieved, the Council deems that the costs

associated with extra collections does not provide value for money, and

indeed would realise a backward step in terms of environmental benefit.

5.7.14. Having carried out a full assessment of Sheffield’s recycling service, it

is clear that the separate collections are not technically,

environmentally or economically practicable.

5.8. Step 5: Sign off

5.8.1. Step 5 of the Route Map (appendix A) requires sign off at ‘the right

level’.

5.8.2. As no service changes are recommended following the review, the

Council’s Governance Legal Team has confirmed that sign off should

be carried out as an Officer non-key decision.

5.9. Step 6: Retain Evidence

5.9.1. All evidence considered, including service method statements will be

retained and are available for review.

5.10. Step 7: Ongoing Review

5.10.1. The assessment has identified a number of actions which are needed

in order to ensure ongoing compliance to the separate collection

requirement of the Waste (England and Wales) Regulations 2011:

5.10.2. Quarterly review of input sampling review data, with particular attention

needed for the paper and card content of the container stream.

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5.10.3. Ongoing review of output sampling data, published as part of the MRF

protocol.

5.10.4. Minimum annual review of this assessment to ensure ongoing

compliance, and mandatory review prior to any change of collection

type operated by the kerbside collection system.

5.11. Legal Implications

5.11.1. As a responsible public authority, Sheffield City Council has to ensure

that its waste collection service is compliant with legal obligations and

to achieve high standards of compliance in order to minimise risk of

judicial review or regulatory enforcement.

5.11.2. Under the Waste Regulations 2011 (with amendments - 2012) waste

collection is the responsibility of a Local Authority, who act as the

Waste Collection Authority (WCA). A WCA must arrange for the

collection of household waste (and, if requested of commercial waste)

in its area. Regulation 13(2) originally specified that co-mingled

collection of recyclables (that is, collecting recyclable waste paper,

metal, plastic and glass (four recyclable waste materials) together, with

a view to their subsequent separation for recycling at a materials

recovery facility was a valid form of separate collection.

5.11.3. Following a judicial review, regulation 13 was amended to remove the

provision that co-mingling was a valid form of separate collection. The

amended regulation 13 came into force in October 2012; it provides

that from 1 January 2015 there is an obligation to collect the four

recyclable waste materials separately, where separate collection is

both:

a. Necessary to ensure that waste undergoes recovery operations in accordance with Articles 4 and 13 of the Waste Framework Directive 2008 and to facilitate or improve recovery, AND

b. Technically, environmentally and economically practicable. (‘TEEP’)

5.11.4. In April 2014, Waste & Resources Action Programme (WRAP) published its Waste Regulations route map. This provides guidance on the duty to collect the four recyclable waste materials separately (from 1 January 2015), where it is technically, environmentally and economically practicable (TEEP). The route map advises that WCAs should have:

Page 30 of 31

a. Carried out a robust assessment of their collection systems before 1 January 2015.

b. Justified any decision they take regarding the future of their activities, which may include retaining their current collection model.

c. Been careful if they were considering a change in their collection method, particularly where this could lead to paper, metals, plastics or glass being co-mingled with one or more other materials, when it had previously been collected as a separate stream.

d. Established a process for future reviews of compliance, which may need to take place at periodic intervals or when relevant circumstances change.

e. Given careful consideration when a collection, treatment or recycling contract ends, if vehicles are to be replaced, or if access to a new recycling facility or technology becomes available.

5.11.5. Sheffield Waste Management team report that they have carried out a full assessment of Sheffield’s collection services and have set out the decision they wish to take regarding future waste collection activities. They have concluded, utilising the Route Map, that such separate collections are NOT technically, economically or environmentally practical. Therefore, there is no change proposed to the current waste collection arrangements. The report recommends that approval be given at the appropriate level in order to ‘sign off’ the decision. Such sign off needs to be explicit and provided by a senior officer. The decision / report needs to be reviewed at the appropriate level (whoever has the lead for waste). There should be a full record retained setting out the assessment and the ‘sign off’ process that the Council has gone through.

5.11.6. Under the Leaders Scheme such approval can be provided, as an

officer non-key decision, by the relevant Executive Director who can ‘sign off’ that Sheffield City Council’s waste assessment is both comprehensive and robust (utilising the Route map) as required under Waste Regulations 2011.

5.12. Financial Implications

5.12.1. There are no specific financial implications (additional costs/savings) from adopting the recommendations within this report."

6. ALTERNATIVE OPTIONS CONSIDERED 6.1. As a collection authority which does not provide separate collections of

glass, metal and plastic, we are required to undertake a review of

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collection practices to ensure compliance with the Regulations, including rigorous application of the Necessity and TEEP tests.

6.2. As the alternative would have been not to undertake a review, this would

have meant the Council would not know whether it is compliant with the Regulations. Therefore, the alternative option to not carry out a review was not considered.

7. REASONS FOR RECOMMENDATIONS

7.1. A review of waste and recycling collection services in Sheffield has been

carried out to assess compliance with the requirement to provide separate collections of paper, glass, metal and plastic.

7.2. The review concluded that separate collections of paper, glass, cans and

plastics are NOT technically, economically or environmentally practicable. Therefore, there is no change proposed to the current waste collection arrangements.

7.3. The report recommends that approval be given at the appropriate level in

order to ‘sign off’ the decision. Such sign off needs to be explicit and provided by a senior officer. The decision / report needs to be reviewed at the appropriate level (whoever has the lead for waste). There should be a full record retained setting out the assessment and the ‘sign off’ process that the Council has gone through.

7.4. Under the Leaders Scheme such approval can be provided, as an officer

non-key decision, by the relevant Executive Director who can ‘sign off’ that Sheffield City Council’s waste assessment is both comprehensive and robust (utilising the Route map) as required under Waste Regulations 2011.

8. REASONS FOR EXEMPTION N/A 9. RECOMMENDATIONS

9.1. Approve the review of collection services undertaken by Waste

Management to ensure compliance with the requirements of The Waste Framework Directive as implemented in England and Wales through the Waste (England and Wales) Regulations 2011.

Neil Townrow Waste Management Officer March 2016