APPENDIX 1 TEEP REPORT

Westminster City Council
TEEP Assessment Report
Assessment of compliance with requirements of the Waste (England &
Wales) Regulations 2011 (as amended)
18th
December 2014

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Contents
Executive summary…………………………………………………………………………………..3
1. Background...................................................................................................................... 6
1.1. Demographics ............................................................................................................ 6
2. TEEP: the Legal & Technical Position .............................................................................. 9
2.1. The Waste (England and Wales) Regulations 2011 (as amended)............................. 9
2.2. The Revised Waste Framework Directive................................................................. 10
2.3. European Commission guidance .............................................................................. 10
2.4. Judicial review 2011 ................................................................................................. 11
2.5. Enforcement Body (EA)……. ………………………………………………………………12
2.6. WRAP - the Waste Regulations Route Map............................................................. 12
2.7. When & How Frequently to Perform a TEEP Assessment ........................................ 13
2.8. Pending Legal Challenges or Changes..................................................................... 13
3. ’TEEP Assessment’ ........................................................................................................ 15
3.1. Step 1 – Determine what is collected and how.......................................................... 15
3.2. Step 2 - Check how materials are treated and recycled............................................ 16
3.3. Step 3 – Apply the Waste Hierarchy ......................................................................... 16
3.4. Step 4 - Decide whether separate collection of the 4 materials is required ............... 17
3.4.1. The necessity test .............................................................................................. 17
3.4.2. The practicability test ......................................................................................... 18
3.4.2.1. Segregated Collections - all streams-Kerbsider Mode 1..…..……………......18
3.4.2.2. SSMDRC with glass collected from bring banks Model 2….………………...21
3.4.2.3. Split back vehicles (30%-70% split) Model 3..…..……………………………..24
3.4.2.4. TEEP summary…………………………………………………………… …….27
3.5. Step 5 - Obtain Sign-Off ……………………………………………………………………27
3.6. Step 6 – Retain evidence.......................................................................................... 27
3.7. Step 7 – Re-evaluation process................................................................................ 28
4. Conclusions .................................................................................................................... 28

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5. Recommendations.......................................................................................................... 28
6. Appendixes..................................................................................................................... 29
6.1. Appendix One – Impact assessment of potential collection methodologies............... 29
6.2. Appendix Two -- Potential cost of new collection methodologies: ............................. 30
6.3. Appendix Three – Waste composition analysis......................................................... 31
6.4. Appendix Four – Castle Point Borough Council TEEP assessment .......................... 31
6.5. Appendix Five -- London borough of Camden reports……..……………………………31
6.6 Appendix Six -- Air Quality and economic impact reports ……………………………....31
6.7 Appendix Seven -Kerbside Analysis Tool KAT tables and charts.……………………..31
6.8 Appendix Eight--- Legal TEEP- The Waste Regulations 2011 .…………………….…31
6.9 Appendix Nine --- WRAP Kerbside recycling collection & costs reports……………….31
6.10 Appendix Ten --- WCC Doorknocking Reports …………….. .……………………….31
6.11 Appendix Eleven - Carbon Calculator ….........……………… .……………………….31

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Executive Summary
The revised Waste Framework Directive requires the UK to promote high quality recycling.
By 1st
January 2015 the UK is required to set up separate collections of paper, plastic, metal
and glass. The requirement to separately collect applies when: (a) it is necessary to ensure
that waste undergoes recovery operations, and to facilitate or improve recovery; [the
necessity test] and (b) it is technically, environmentally and economically practicable ('TEEP')
[the TEEP test]
This report has been complied in line with the WRAP Route Map Guidance Document in the
absence of any guidance provided by DEFRA and agrees that separate collection is
necessary to facilitate recovery.
The City Council has analysed four collection models to test their practicability in accordance
with the Regulations (TEEP Test). The four models analysed were
1. Model 1 : Segregated collection of all four streams – Kerbsider model
2. Model 2: Single stream mixed dry recycling collections from doorstep with glass
collected from bring banks
3. Model 3: Split back vehicles ( 30% glass and 70% other mixed recycling)
4. Model 4: Single stream mixed dry recycling collections (SSMDRC) – Kerbside mixed
collections (including glass) the current collection method.
Our research, analysis, lesson learnt from similar neighbouring boroughs and WRAP
research/reports are summarized in Table 1.
Table 1 - Comparison of key findings of the four modelled options.
Model Technically
Practicable
Environmentally
Practicable
Economically Practicable
Capital Costs
On-going costs
p.a.
1. All segregated No +213t of carbon +£3.5m +£1m
2. Separate Glass Yes +1000t of carbon + £3m +£430k
3. Split Vehicle No +161t of carbon +£4.5M +£1m
4. SSMDRC Yes No change No change No change

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Models 1 and 3 failed all three practicability tests. Model 2 was not environmentally or
economically practicable. Model 4 (SSMDRC) proved to be technically, environmentally and
economically practicable in Westminster’s operational environment.
It is recommended that City Council should:
 Continue using the SSMDRC model which is technically, environmentally and
economically practicable.
 Continue to document and retain all evidences associated with this report so that
future ’TEEP’ assessments can be readily investigated as required
 Perform TEEP assessments where any significant changes to its waste management
practice are planned or have occurred until further guidance is issued.

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

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1. Background
1.1. Demographics
The 2011 census results from the Office of National Statistics suggest that Westminster had
a resident population of 219,400. Up from 190,631 in 2002 (ONS, Mid-Year Estimates
2002). The daytime population however increases to more than one million, including
550,000 people employed in Westminster and more than 29 million tourists visiting each
year. There are more than 3,300 entertainment venues in Westminster, with music and
dance venues alone having capacity for 190,000 people each night. Total capacity in late-
night venues (after 11.00pm) is approximately 225,000.
The 2011 Census also confirmed that Westminster has the:
 second smallest average
household size (2.0 persons);
 second highest percentage of one-
person households (49%);
 second highest percentage of
households living in flats (89%);
 fourth lowest percentage of
households with a car or van (37%).
Located in the heart of London the City
of Westminster is home to the Monarchy, the Government and many Commonwealth High
Commissions and foreign embassies. One of 33 London Boroughs, the City includes within
its boundaries some of London’s most prestigious landmarks and districts, including
Westminster Abbey, Houses of Parliament, Buckingham Palace, Big Ben, Marble Arch,
Mayfair, Oxford Street, Piccadilly Circus, Soho and Trafalgar Square.
Within its 2,204 hectares (8.51 square miles) Westminster takes in Regent’s Park to the
north, Hyde Park to the west, and Covent Garden to the east. To the south it follows the
River Thames. The residential areas of the City extend from Queens Park to St John’s
Wood and from Bayswater to Pimlico.

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Westminster is also one of Europe’s most prestigious business locations and houses the
international headquarters of many multinational organisations. Small businesses play an
equally important part in the economy of Westminster. There are 48,000 businesses in
Westminster; more than 93% of firms employ fewer than 25 people.
Westminster has a unique set of challenges to face in delivering sustainable waste
management services which include:
 89% of households are flats, waste storage space (internal and external) is as a
result limited The ability to identify who is and isn’t recycling in a multiple
occupancy/high turnover environment to allow targeted communications is a
considerable barrier to achieving elevated recycling rates.
 20% of households have single waste chutes severely discouraging recycling
initiatives. To increase the challenge, doorstep recycling collections in many housing
estates and similar multi-occupancy properties are not considered ‘fire safe’ by the
London Fire Brigade and therefore near entry bring facilities are the only viable option
which have already been installed. (65,000 properties)
 121,000 households in 6 square miles, 12,000 businesses served. Westminster has a
reported population density of 102 people per hectare compared to 52 and 4 the
London and UK average respectively. However, the WCC figure includes the Royal
Parks and in reality the density is over double that formally reported. The congestion
and complexity of operating in a densely populated environment makes the
consistent capture of high quality recyclables a challenge to access.
 The 160 bring sites are subject to contamination/fly-tipping and collection staff
actively check whether materials are suitable for recycling or need to be disposed of
as general waste.
 Waste is often (61,000 properties/50% of housing stock) managed by porters,
cleaners, housing management teams (‘gatekeepers’) rather the waste producers.
Door knocking exercises in Westminster are less effective than elsewhere because of
‘gatekeepers’ not allowing access to speak to or deliver leaflets to residents in multi-
occupancy due to privacy concerns.
 Resident turnover of 30% per annum means a continual communications effort is
required.
 Significant language and cultural diversity.

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 A security zone covers 15% of the city preventing the installation of recycling on the
go facilities in some of the highest footfall areas.
 Car ownership is low (37% of households have access) limiting the ability of
households to reuse and recycle larger items of waste,
 Listed building and conservation areas limit the ability to alter streets and buildings to
incorporate sustainable waste management systems.
 Visitor and commuter population is over 1 million each week day.
 48,000 businesses generating 2.1% of UK’s GDP.
 High number of special events including Royal Events, London Marathon, New Years
Eve, and Notting Hill Carnival where security and a requirement to reopen roads
quickly prevent significant separation of recyclables.

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2. TEEP: The Legal & Technical Position
The legal requirement for waste collection authorities to perform a TEEP assessment is a
complex one (http://ec.europa.eu/environment/waste/framework/pdf/guidance_doc.pdf). In
summary, the UK was required to transpose the requirements of Europe’s revised Waste
Framework Directive (rWFD), which it did. The wording in the resultant English Regulations
was ambiguous. This led to much debate and a series of challenges, by those supporting
complete separate collection of the four material streams of glass, plastic, metals and
papers. Although these challenges culminated in a European Ruling, at the time of writing,
DEFRA has not, and is currently not prepared, to issue any further guidance on the issue.
Therefore, we have included the following summary of the legal and technical position, as
this is the basis upon which we have performed the TEEP assessment.
What guidance is available?
– The Waste (England & Wales) Regulations 2011. Note that Regulation 13 was amended in
2012.
– Part 5 of the Regulations. See Annex 1 of the regulations.
– Pages 53-57 of European Commission guidance on the Waste Framework Directive.
– Lord de Mauley’s letter of October 2013 reminded local authorities of their obligations from
2015.
– The Judicial Review Ruling which upheld the 2012 Regulations.
What does 'Separate Collection' mean?
Separate collection is defined in Article 3(11) of the Waste Framework Directive as a
collection where a waste stream is kept separate from waste of a different type or nature, so
as to facilitate a specific treatment. Further information on the definition of separate collection
can be found in Chapter 1.5.1.
2.1. The Waste (England and Wales) Regulations 2011 (as amended)
The Waste (England and Wales) Regulations 2011, as amended by the 2012 Regulations,
(’the Waste Regs’) set out what WCAs will have to do.
From 1st
January 2015, an establishment or undertaking which collects waste paper, metal,
plastic, or glass, must do so by way of separate collection. And every waste collection

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authority must, when making arrangements for the collection of waste paper, metal, plastic or
glass, ensure that those arrangements are by way of separate collection, where separate
collection is:
a) Necessary to ensure that waste undergoes recovery operation and to facilitate or
improve recovery;
And
b) Technically, environmentally and economically practicable.
2.2. The Revised waste framework directive
The Waste Regs transposes requirements in Articles 3, 10, 11, and 36 of the Revised Waste
Framework directive with references to articles 4 and 13.
Article 11 says – Member State shall take measures to promote high quality recycling
and, to this end, shall set up separate collections of waste where technically,
environmentally and economically practicable and appropriate to meet the necessary
quality standards for the relevant recycling sectors.
Subject to Article 10(2), by 2015 separate collection shall be set up for at least the
following: paper, metal, plastic and glass.
Article 10(2) is a proviso that separate collection is necessary in order to comply with the
waste hierarchy or in order to protect human health and the environment.
Article 3 defines ’’separate collection” as the collection where a waste stream is kept
separately by type and nature so as to facilitate a specific treatment.
2.3. European Commission guidance
The European Commission has issued guidance on the rWFD, which is relevant. The
guidance states that:
 ‘Technically practicable’ means that the separate collection may be implemented
through a system which has been technically developed and proven to function in
practice

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 ‘Environmentally practicable’ should be understood such that the added value of
ecological benefits justify possible negative environmental effects of the separate
collection ( e.g. additional emissions from transport)
 ’Economically practicable’ refers to a separate collection which does not cause
excessive costs in comparison with the treatment of a non-separate waste stream,
considering the added value of recovery and recycling and the principle of
proportionality.
2.4. Judicial review 2011
In 2011 a Judicial Review was launched against Defra and the Welsh Government,
challenging the way in which the Waste Regs (before being amended in 2012) transposed
provisions of the rWFD relating to the separate collection of paper, metal, plastic and glass.
The application was dismissed on Wednesday 6 March 2013. Mr Justice Hickinbottom’s
points included:
 The phrase ”technically, environmentally and economically practicable” is
used in the Directive as a term of art, importing the principle of proportionality
and demanding a sophisticated context-driven exercise of judgment, balancing
(amongst other things) the positive and negative environmental and economic
effects of separate collection.
 It was and is open to United Kingdom to fulfil its obligations under the Directive
by the system created by the 2011 Regulations, which allows a local authority
to determine within its area whether separate collection is technically,
environmentally and economically practicable; enforced by the Environment
Agency.
 It appears to be common ground that, whilst glass is a well-recognised
potential contaminant, metal and plastic can be separated at a stage later than
kerbside without any significant contamination or other relevant disadvantage.

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2.5 Enforcing Body – The Environment Agency
The Environment Agency is the organisation responsible for ensuring that the Waste Regs
are complied with within England & Wales. At the time of performing the TEEP assessment,
and writing the report, the Environment Agency has not issues guidance on the TEEP
assessment elements of the waste Regs.
It is, however, imperative that Westminster keeps all evidence to demonstrate to the
Environment Agency that it has duly undertaken a TEEP assessment, as required by the
Waste Regs.
2.6. WRAP - the waste regulations route map
WRAP is a not for profit company limited by guarantee, set up with an independent board to
promote resource efficiency. It is funded by an increasing number of governments and other
(not quasi) public sector organisations – it receives funding from DEFRA.
DEFRA has made it clear that they will not, and do not want, formal guidance to be issued.
Therefore, WRAP has facilitated the creation of a ”Route Map”, which has been tested by
several local authorities across the country.
The WRAP Route Map comprises the following 7 steps:
 Step 1 - Determine what waste is collected and how
 Step 2 - Check how materials are treated and recycled
 Step 3 - Apply the waste hierarchy
 Step 4 - Decide whether separate collection of the 4 materials is required
o The Necessity Test
o The Practicability Test
 Step 5 - Obtain Sign-Off
 Step 6 - Retain Evidence
 Step 7 - Re-evaluation process
It should be noted that the Route Map is for regulations 12 and 13 of the Waste Regulations:
 Regulation 12 concerns itself with assessment of waste management practises in
line with the waste hierarchy.
 Regulation 13 is concerned with the separate collection of the four waste streams of
paper, metal, plastic and glass, where it is technically, economically and
environmentally practicable: the TEEP assessment.

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The City Council agrees the separate collection of dry recyclables would yield better quality
but not high capture rates of paper, glass, metals and plastics.
Therefore from this point on this report is only concerned with regulation 13, and hereon
does not make reference to the waste hierarchy. Consequently, some steps in the
assessment, contained within section 3, will be marked as such.
2.7. When & How Frequently to Perform a TEEP Assessment
Current thinking is that TEEP should be assessed within existing Direct Service
Organisations and waste collection contracts from the date of the Judicial Judgement
(6th
March 2013) and completed ahead of the date that rWFD passes into law in England
and Wales ( 1st
January 2015). DEFRA and industry thinking is that logical decision making
trigger points in relation to re-assessment of TEEP are likely to be:
 When existing waste collection contracts are re-tendered or extended
 When waste processing services / contracts are re-tendered or extended
 When collection service delivery is modernised / amended
 When a new vehicle fleet is being procured
 When there is a change in local circumstances
2.8. Pending Legal Challenges or Changes
At the time of undertaking the TEEP assessment, and writing the report, there are no know
pending legal challenges, changes to the legislation of formal government guidance.
The outgoing Environment Minister, Lord de Mauley, issued a memo to Local Government
before he left the post in November of 2013. This memo set out the requirements of the act
and reiterated the need for Local Authorities to provide high quality recyclates through the
means of separated collections.
The industry bodies CIWM/ESA suggested that the memo was unhelpful, and along with
Local Authorities, have called for further guidance and support from DEFRA – in particular in
relation to the permissibility of mixed dry recyclable collections.
The Government has suggested that it thinks its position in relation to the Waste Regs is
clear and in particular with the findings of the Judicial Review. The new Environment

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Minister, Dan Rogerson, has already stated publically that he and his department are unlikely
to issue any further guidance in this area.
This view is supported in the recent January 2014 DCLG Guidance on weekly rubbish
collections, which states;
’’In March 2013, the government won a high Court Case, confirming that
councils can continue to provide commingled collections. Councils are not
required by any diktat to make householders separate rubbish into 5 separate
bins.’’
In terms of legal challenge, on the broad consensus of opinion is that there is ’unlikely’ to be
a further high profile national legal challenge from the Campaign for Real Recycling and its
supporters. But this cannot be ruled out.

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3. TEEP Assessment
The WRAP “Route Map” has been used as the framework for performing the TEEP
Assessment. Key factors such as such as mileage, number of vehicles, type of vehicles, fuel
type, number of rounds, CO2 equivalent savings from different material types, WRAP
research on bring sites, kerbsides, cost and income from different collection systems along
with waste composition data were analysed to assess TEEP requirements.
3.1. Step 1 – Determine what is collected and how
Westminster currently provides a single stream mixed dry recycling service (mixed
collections) and typically collects recyclables such as paper, glass, metals, and plastics from
households using four methods, kerbside collections using disposable blue bag , reusable
boxes, near entry bring banks on housing estates and on street communal banks (MRC‘s).
MRC’s can be mixed or segregated and are collected up to 7 days a week. We also collect
segregated paper, cardboard, food waste and glass along with commingled dry recyclables
from commercial properties where storage space and building management allows and we
propose to continue to do so.
The table below provides more service details
Table1. Waste collection methodology for household dry recycling
Scheme name Scheme type Frequency Waste Container Households on
containers
Flats–
mansions
blocks
Mixed Weekly to
twice a
week
Aerosols, cans ,
cardboard, glass
bottles and jars ,
paper
A combination of
communal bins
and disposable
blue bags
40,000
Flats – Housing
estates
Mixed Twice a
week.
Aerosols, cans ,
cardboard, glass
bottles and jars ,
paper
Communal bins 16,234
Kerbside-
Properties- D2D
collections
Mixed Weekly Aerosols, cans ,
cardboard, glass
bottles and jars ,
paper
Box 11,000
Kerbside –
Properties- D2D
collections
Mixed Weekly Aerosols, cans ,
cardboard, glass
bottles and jars ,
paper
Disposable blue
bags
52,000
TOTAL 119,234.00

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Table 2. Commingled Waste Composition analysis of City of Westminster
(Source: http://laportal.wrap.org.uk/ORIS.aspx)
Waste Type No of HH Total Kgs/year
Collected per year
City of Westminster
Total kgs collected /
HH per annum
City of Westminster
Waste
Composition
Analysis CoW
(Total kgs
collected in the
commingled
collections /HH
per year)
Calculated
Capture Rate
Paper and
Card
119,234 8,191,376 68.7 51.34 74.7%
Glass Bottles
and Jars
119,234 3,755,871 31.5 24.64 78.2%
Cans 119,234 727,327 6.1 3.55 58.2%
Plastics Film 119,234 393,472 3.3 2.98 90.3%
Plastic bottles 119,234 989,642 8.3 6.53 78.7%
Total 14,057,689 117.9 89.04 75.5%
3.2. Step 2 - Check how materials are treated and recycled
After collection, the recyclables are taken to Materials Recovery Facilities (MRF) in
Southwark and Wandsworth, where the collected recyclables are visually inspected for
obvious contamination by the MRF and then loaded into the bag splicer to separate
disposable blue bags. The commingled recyclables are then separated using trammel, wind
sifters, magnet and infra-red sensors along with manual sorting. The separated materials are
then sent to recycling reprocessors in the UK, Western Europe and Asia.
3.3. Step 3 – Apply the waste hierarchy
See section 2.6.
but not high capture rates of paper, glass, metals and plastics.

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3.4. Step 4 - Decide whether separate collection of the 4 materials is required
3.4.1. The necessity test
The necessity test concerns itself with identifying whether separate collection is necessary to
facilitate or improve recovery. These terms are not defined in the Regulations. But the Route
Map suggests they refer to a system that facilitates the four affected waste types being:
 Captured at a higher rate
And
 of a higher quality i.e. meets the necessary quality standards for the relevant
recycling sectors.
of paper, glass, metals and plastics. However as regards capture rates the WRAP data1
would suggest otherwise, given that 19 of the top 20 recycling performing local authorities in
England have commingled collection systems and in 2011, WRAP released the report
’’Kerbside collection options’’,2
which advised that commingled recycling schemes increase the
yields of the mixed dry recyclable materials and stated that:
’’Kerbside dry recycling yields can be expected to, on average, be lower than Mixed
recycling yields (all other factors being equals) as follows :
- 10.5% lower if kerbside dry collections are carried out weekly;
- 18.3% lower if kerbside dry collections are carried out fortnightly.’’
The Regulations refer to ’high quality’, and it is well known in the waste industry that glass
within mixed collections do negatively affect the quality of paper3
. However the same do not
apply to the quality of metals and plastics when collected with glass.
To capture a better quality of paper, industry recommends collecting glass separately,
however there is no guidance and tested evidence to suggest this process will yield better
capture rate.
To satisfy the TEEP regulations, four different scenarios have been modelled for their
technical, environmental and economical practicability.
1
(http://www.wrap.org.uk/sites/files/wrap/12.%20Commingled_0.pdf)
2
http://www.wrap.org.uk/sites/files/wrap/Choosing%20the%20right%20recycling%20collection%20syste
m.pdf
3
(http://www.wrap.org.uk/sites/files/wrap/12.%20Commingled_0.pdf)

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3.4.2. The practicability test
The practicability test refers to the following three tests
 Technically
 Environmentally and
 Economically.
In this section, the City Council has analysed four scenarios to test their practicability. The
four models analysed were
5. Model 1 : Segregated collections – all four streams– Kerbsider model
6. Model 2: Single stream mixed dry recycling collections from doorstep with
glass collected from bring banks
7. Model 3: Split back vehicles ( 30% glass and 70% other mixed recycling)
8. Model 4 : Single stream mixed dry recycling collections (SSMDRC) – kerbside
mixed collections ( including glass )
3.4.2.1. Segregated collections – all four streams - Kerbsider model (Model 1)
In this model, we look at the possibility of collecting all four streams of dry recyclables i.e.
paper, cardboard, cartons, tins, cans & plastic bottles including pots tubs and trays
separately. Residents would be encouraged to use different colour disposable recycling bags
/ reusable boxes to present their segregated recyclable waste for collections.
The technical, environmental and economical impacts on this model will be as follows
 Technically practicable:
This model demands significant additional storage space than is currently provided. Given
89% of residents live in high rise flats with very limited or no storage space internally or
externally this model is considered as technically not practicable. In this model, residents
would have to store, segregate and present all four streams of recyclables separately using
different colour coded bags and boxes for collections and with no storage, it is considered
likely that residents will be discouraged from recycling.
Westminster doorknocking campaigns and recent residents’ surveys on encouraging
recycling service participation states residents prefer a “simple and convenient” service4
. In
a City where over 120 languages are spoken (only 58% have English as their first language)
with significant cultural diversity and with 30% residents turnover per annum to ask residents
4
Refer to appendix 10 WCC Doorknocking report

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to segregate their waste and present in four different colour coded bags / boxes would
significantly increase complexity among service users and increase the contamination rate in
dry recycling stream.
In addition, the inability to identify who is and isn’t recycling in a multiple occupancy/high
turnover environment to allow targeted communications is a considerable barrier to achieving
elevated recycling rates and this model with its complexity has the potential to perplex the
service users and lead to increased recycling contamination and fall in yield.
A City with a density of 120k properties in 6 Square miles area, on street parking (parked
cars on road) and restricted access to properties would increase drag distances causing
significant health and safety risk to collection crew.
This option is also considered unsafe in the operating environment. The kerbsider model
necessitates operations to stand to the side of the vehicle. Given on street parking is
common, the vehicle would have to be over the road’s white line to allow access. This is
deemed unsafe and therefore technically impractical.
Considering the above concerns and risks associated with this model 1, City Council
classifies this option as technically not practicable.
 Environmentally practicable:
Implementation of this model would have greater adverse impact on the environment than
existing collection system due to the increased number of additional vehicles that are
required to collect segregated waste from kerbside properties, housing estates, mansion
blocks and MRC sites. Experience from other local authorities operating this vehicle type
shows longer loading times and lower pass rates than other modelled options. To collect the
recyclables currently presented would require additional vehicles. As a direct consequence
CO2 equivalent emission will rise5
.
This model would significantly increase the inefficiency of the collection fleet, demanding
more vehicles on residential and commercial streets to cope with existing collection
arrangements and generate a bigger carbon footprint. This model will also need additional
normal standard RCV’s to carryout segregate collections from housing estates, MRC’s and
mansion blocks.
It is considered likely that the environmental gain from segregated collections is dwarfed by
the loss of recycling tonnage and elevated environmental impact associated with increased
5
Please refer appendix 1 and 2 for additional vehicles and CO2 impact

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noise, congestion, air pollution and CO2 equivalent. It is acknowledged that this data isn’t
currently available.
The below table demonstrates the additional impact of CO2 by using split vehicles.
Table 3: The additional CO2 equivalent emissions generated from the Kerbsider model in
comparison with that currently delivered
Total fuel
used
(L/Year)
Total miles
driven per
year
Total CO2
emitted per
year (kgs)
Additional CO2
per year
Total CO2
gained from
segregated
collections.
Segregated
collections –
kerbside model
217,826 184,262 574,865 213,397 kgs
N/A
It’s calculated that an additional 213 tonnes of CO2 p.a. will be released into atmosphere
using this model.
Segregated collections using Kerbsider vehicles can yield CO2 emission savings as material
quality is improved. However, the additional emissions generated as a result of reduced
participation and capture of materials far exceeds the savings. The evidence6
suggests the
environmental burden associated with implementing Model 1 would be significant and
classified as environmentally not practicable.
 Economically practicable:
The additional costs associated with implementing this model are significant. The City
Council would need to purchase 20 additional RCV’s costing around £2.5m along with 6 four
way split Kerbsider vehicles costing a further £1m7
. The current vehicle fleet do not have the
capacity to collect the recyclables separately and with 5 years of depreciation left on the
existing fleet the economic burden of this model is significant (£3.5m+). Given the reduced
participation and capture rates associated with this model the additional disposal costs are
calculated at £1m p.a. (£70 per tonne differential)
It is acknowledged that some of the costs will potentially be offset by lower gate fees
associated with better and improved quality of dry recyclables going through MRF. This
model could not be implemented until 2020 at the earliest without incurring significant costs.
6
Please refer appendix 1 for costs and CO2 impact
7
Please refer appendix 2 for costs

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This model would decrease the pass rate and increase collection inefficiency, demanding
more vehicles on streets along with significant increase in supply demand for different colour
coded bags, boxes and bins.
It should be noted that the increased costs associated with increased congestion and lower
air quality were not included in this calculation, which could be well over £4.5 million per
annum8
.
The table below shows the costs for current fleet and additional resources required to secure
new split and additional vehicles
Table 4: Cost comparison of current fleet and model 1 requirements
Collection
service
Cost of
vehicle per
annum
Labour cost
per annum
Cost of fuel
per annum
Total cost per
annum
Additional
cost
SSMDRC £377,369 £1,302,581 £157,254 £1,837,204 /
Split vehicles
and extra RCV’s
£2,698,415 £1,590,757 £227,500 £4,516,672 £2,676,468
The additional financial burden of this option (£4m) makes it economically impractical for the
City Council to pursue.
The results of model 1 show it is not technically, environmentally and economically
practicable for City Council to pursue.
3.4.2.2. Mixed collection from doorstep with glass collected from bring banks (Model2)
Model 2 is to collect dry mixed recyclables i.e. paper, cardboard, cartons ,tins, cans & plastic
bottles including pots tubs and trays using disposable bags and reusable boxes and
encourage residents to use bring banks which are dotted across the city to recycle glass.
The technical, environmental and economical impacts of this model are assessed as follows
8
Please refer appendix 6, 6a, 6b, 6c, 6d and 6e for economic impact due to congestion.

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In this option, dry recyclables other than glass are collected the same way as current method
(Single stream mixed dry recycling collections), it is predicated that the capture of the dry
recyclables with the exception of glass will not change and would be of higher quality.
We currently have 87 glass bring banks in the city but the lack of space restricted any
significant expansion of this provision. As only 36% of Westminster residents have access to
cars they would be discouraged from recycling glass and a significantly drop in collected
glass tonnage is predicted. WRAP research suggests bring site usage is only 10-15%
compared with 78% kerbside capture.9
15% of the city classified as a high security zone, preventing the installation of recycling
facilities in some of the highest footfall areas. Westminster has a high density of listed
building and conservation areas further limiting the ability to alter streets to include on-street
facilities.
This model would increase the quality of materials collected but significantly reduce the
quantity of glass collected for recycling and therefore contradicts the aims of Regulation 13.
This model is classified as technically practicable.
Model 2 results in a loss of recycled glass of 3100t p.a. (based on WRAP’s suggested
guidance of 15% recycled by bring banks and estimate 0.32t CO2 saved by recycling 1t of
glass stats) this equates to 992 tonnes of additional CO2 p.a.
An extra vehicle would be needed to collect segregated glass from bring banks, as a direct
consequence CO2 equivalent emission will rise. (Please refer to appendix 1) These additional
vehicles would generate further pollution including noise, PM10 particulates, NOx and S
emissions.
It is acknowledged that saving are generated by lower MRF emissions with improved quality
and lower MRF usage, however that data isn’t currently available and need further
investigation in the next stage of the report.
Table 5 shows the additional carbon footprint of this model when compared to the current
system (SSMDRC).
9
WRAP bring site evidence –please see appendix 9, 9a and 9b.

23 | P a g e
Table 5: The additional CO2 equivalent emissions generated from model 2 in comparison
with that currently delivered
Total fuel used
(L/Year)
Total miles
driven per year
Total CO2
emitted per year
(kgs)
Additional
CO2 per year
Mixed collection
from doorstep
with glass
collected from
bring banks
Emission due to
loss in recycled
glass
167,826 168,045
390,096kgs
992,000 kgs
29,218 kgs
992,000
It is calculated that an additional 1021 tonnes of CO2 will be emitted per year to collect glass
separately from bring banks, which contradicts council’s commitment to London Mayor’s
Municipal Waste Management Strategy that aims to achieve a 50% reduction in its waste
collection footprint by 2020.
The carbon benefits of having higher quality collected paper were considered insignificant
(estimate of 0.12t CO2 saved by recycling 1t of paper stats, this equates to 0.2t of additional
CO2 p.a. generated for every tonne of glass lost)10
. When compared to carbon burden
associated with the loss in glass tonnage.
The additional environmental burden associated with the reduction in collected glass for
recycling makes this option environmentally impractical.
On the basis that 3100 tonnes of previously recycled glass would end up in the residual
waste stream and an additional glass collection vehicle would be required this model would
increase the service costs by £320K p.a.
WRAP research indicates glass capture will reduce by 3100 tonnes p.a as bring sites are
less convenient to use than doorstep collection services11
.
10
Please refer appendix 11 for carbon calculator
11
Please refer appendix 9, 9a ,9b for kerbside WRAP reports

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This model could not be implemented until 2020 at the earliest (end of current vehicle life)
without incurring significant costs.
It has been calculated that the gate fee for the remainder of the commingled waste will be
increased by £10 per tonne (£100,000). This is only considered as a short term measure as
MRF’s are reconfigured to take the residual waste streams. Overall this model would result in
significant additional cost (£330K p.a.)12
Collection
service
Cost of
vehicle per
annum
Labour cost
per annum
Cost of fuel
per annum
Total cost per
annum
Additional
cost
SSMDRC £377,369 £1,302,581 £157,254 £1,837,204 /
Mixed collection
with glass from
bring banks
£440,264 £1,743,953 £193,000 £2,377,217 £540,013
The results of model 2 show it is technically practicable however environmentally and
economically not practicable for City Council to pursue.
3.4.2.3. Split back vehicles - (30% glass and 70% other mixed recycling) (Model 3)
Model 3 is to collect dry mixed recyclables i.e. paper, cardboard, cartons ,tins, glass cans &
plastic bottles including pots tubs and trays from kerbside by using 70% - 30% compartment
split vehicles. All streams of dry recyclables other than glass will be collected using
disposable bags and reusable boxes in the 70% compartment of the vehicle and glass in
reminder 30% compartment. In this model residents will be encouraged to present glass in
separate bags / boxes and separate bins for housing estates and mansion blocks.
The technical, environmental and economical impacts on this model will be as follows
12
Please refer appendix 9a for wrap suggested costs report

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In this option, dry recyclables other than glass are collected the same way as current method
(Single stream mixed dry recycling collections), it is predicted that the capture of the dry
recyclables with the exception of glass will not change and would be of higher quality.
As stated in section 3.4.2.1, this model has similar issues associated with storage space,
convenience to residents and H&S to crew and increase contamination rate. Hence City
Council classifies this option as technically not practicable13
.
Implementation of this model would have adverse impacts on the environment due to the
increased number of split vehicles and standard vehicles that are required to collect
segregated waste from kerbside properties, mansion blocks, housing estates and MRC sites.
Experience from other authorities operating this vehicle type shows longer loading times and
lower pass rates than other modelled options. To collect the recyclables currently presented
would require additional vehicles. As a direct consequence CO2 equivalent emission will
rise.
This model would increase the inefficiency of the collection fleet, demanding more vehicles
on residential and commercial streets to cope with existing collection arrangements and
generate a bigger carbon footprint along with increased PM10 particulates, NOx and S
emissions.
The below table 7 demonstrates the additional impact of CO2 by using split vehicles for
glass.
Table 7: The additional CO2 equivalent emissions generated from model 3 in comparison
with that currently delivered
Total fuel used
(L/Year)
Total miles
driven per year
Total CO2
emitted per year
(kgs)
Additional
CO2 per year
Split back collection –
glass in small side,
remainder in the other
side
197,826 196,629 522,083 kgs 161,205 kgs
It is calculated that additional 161 tonnes of CO2 will be released into atmosphere every year
13
Please refer appendix 10 for WCC Doorknocking report.

26 | P a g e
using this model. The carbon savings of having higher quality collected paper were
considered insignificant14
, when compared to carbon burden associated with increased
vehicles and loss in glass tonnage and its CO2 impact.
The additional environmental burden associated with the reduction in collected glass for
recycling makes this option environmentally impractical.
The additional costs associated with implementing this model are significant. The City
Council would need to purchase 15 split RCV’s costing £1.8m15
. The current vehicle fleet do
not have the capacity to collect the recyclables separately and with 5 years of depreciation
left on the existing fleet the economic burden of this model is significant (£3m+). Given the
reduced participation and capture rates associated with this model the additional disposal
costs are calculated at £1m. (£70 per tonne differential)
This model would decrease the pass rate and increase collection inefficiency, demanding
more vehicles on streets along with significant increase in supply demand for different colour
coded bags, boxes and bins. This model could not be implemented until 2020 at the earliest
without incurring significant costs.
The table below shows the increased costs of this model. It should be noted that the
increased costs associated with increased congestion and lower air quality were not included
in this calculation, which could be well over £4.5 million per annum16
.
The table 8 below shows the costs for current fleet and resources required to secure new
split vehicles
Collection
service
Cost of
vehicle per
annum
Labour cost
per annum
Cost of fuel
per annum
Total cost per
annum
Additional
cost
SSMDRC £377,369 £1,302,581 £157,254 £1,837,204 /
Split back collection
glass in small side,
remainder in other
side
£1,875,000 £1,590,757 £227,500 £3,693,257 £1,856,053
14
Please refer section 3.4.2.2 environmental practicable section for CO2 calculations.
15
Please refer appendix 1 for costs
16
Please refer appendix 6, 6a, 6b, 6c, 6d, and 6e

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The additional financial burden associated with this option (£3m) makes it economically
impractical for the City Council to pursue.
The results of model 3 show it is not technically, environmentally and economically
practicable for City Council to pursue.
3.4.2.4. TEEP Summary
After careful analysis of the possible four collection models, it is clear from the evidence that
segregated four stream collections are technically, environmentally and economically not
practicable in Westminster environment.
Our research, analysis, lesson learnt from similar neighbouring borough and WRAP
suggested case studies17
,research & reports suggest SSMDRC system is most suitable for
the City Council to pursue.
The table 9 below shows a comparison of key findings from four modelled options.
Table 9: Comparison of all 4 modelled options
Scenarios Technically Environmentally Economically
Capital Costs On-going costs p.a.
All segregated No +213t of carbon +£3.5m +£1m
Separate Glass Yes +1000t of carbon + £3m +£430k
Split Vehicle No +161t of carbon +£4.5M +£1m
SSMDRC No change No change No change No change
3.5. Step 5 - Obtain Sign-Off
The outcomes of this report should be considered alongside with City Council budget
constraints and obtain the appropriate ’sign-off’ from SMT and Head of services.
3.6. Step 6 – Retain evidence
WRAP route map advises to maintain all records pertaining to the TEEP assessment;
including this report and the information related to the waste management service i.e.
number of vehicles and type, mileage, fuel used number of rounds, waste treatment
contracts, costs associated with all aspects of its service.
17
Please refer appendix 9, 9a, 9b

28 | P a g e
The retention of these records and evidence is important to demonstrate compliance with the
requirements of Regulation 13 of the Waste Regulations to the enforcing body, the
Environment Agency.
3.7. Step 7 – Re-evaluation process
There is currently no stated requirement, or guidance, detailing how often City Council must
perform a TEEP assessment in line with Regulation 13 of the Waste Regulations. However,
it is suggested that City Council performs a TEEP assessment where any significant
changes to its waste management practises are planned such as
 Procuring a new waste collection contract (2024)
 Purchasing new collection vehicle fleet (2020)
 Purchasing new waste containers
 Negotiating/procuring new waste treatments contracts
4. Conclusions
Segregated four stream collections are technically, environmentally and economically not
practicable in Westminster operational environment.
Two out of the three other collections systems that were modelled are glass from bring banks
and glass collected using split vehicles both proved to be technically, environmentally and
economically not practicable in Westminster operational environment.
The final SSMDRC model has proved to be the technically, environmentally and
economically practicable in Westminster operational environment.
5. Recommendations
It is recommended that City Council should
 Continue using the SSMDRC model which is technically, environmentally and
economically practicable.
 Continue to document and retain all evidences associated with this report so that
future ’TEEP’ assessments can be readily investigated as required
 Perform TEEP assessments where any significant changes to its waste management
practice are planned or have occurred until further guidance is issued.

29 | P a g e
6. Appendices
6.1. Appendix 1 – Impact assessment of potential collection methodologies
Using single compartment compaction to collect glass and paper separate waste streams.
These materials streams will be separated by residents.
Collection
service
Required
number of
collection
teams per
week
Additional
collection
teams
required per
day
Collections per
round/day
Required
number of
staffper
week
Increased
staffper
day
Fuel Effects if
service changes
from current (L)
C02 emitted
per tonne
collected
(KGS)
Carbon
effects if
service
changes
from
current/ C02
per tonne
collected
(Additional
KGS)
SSMDRC 37 / 2876 88 / / 26 /
Mixed
collection
from
doorstep
with glass
collected
from bring
banks
55 18 4107 124 36 31,084 44 21.61
Split back
collection-
glass in
small side,
remainder
in other
side
48 11 1136 144 56 61,083 37 11.47
Segregated
collections-
kerbside
model
60 23 852 160 72 81,083 41 15.22

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6.2 Appendix 2 - Potential cost of new collection methodologies:
Collection
service
Cost of
vehicles per
annum
Labour cost per
annum
Cost of fuel
per annum
Total cost per
annum
Additionnal cost
from current
service
SSMDRC £377,369 £1,302,581 £157,254 £1,837,205 /
Mixed
collection
from
doorstep
with glass
collected
from bring
banks
£440,264 £1,743,953 £193,001 £2,377,218 £540,013
Split back
collection-
glass in
small side,
remainder
in other
side
£1,875,000 £1,590,757 £227,500 £3,693,257 £1,856,052
Segregated
collecions-
kerbside
model
£2,500,000 £1,766,172 £250,500 £4,516,672 £2,679,467
Note:
1. SSMDRC -commingled collection.
2. In this option glass will be removed from the commingled collection and collected
from bring banks. Metals, cans, paper, card and plastics will still be collected in a
commingled way (blue bags).
3. In this option, glass will be removed from the commingled collection. We will use a
split collection vehicle, glass will remain in the small side and metals, cans and
plastics will remain in the other side.
4. In this option, all materials will be collected separately with split body vehicles.

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6.3. Appendix 3 – Waste composition analysis
Local Authority waste and recycling performance benchmarks 2012/13
Source: (http://laportal.wrap.org.uk/)
The table below displays the kerbside dry recycling yield for each of the main materials
collected (paper, card, cans, glass, plastic bottles, mixed plastic packaging and textiles).
Detail Paper Card Cans Glass
Plastic
bottles
Mixed plastic
packaging
All 5 widely
recycled materials
Yield(kg/hh/yr) 50.1 18.6 6.1 31.5 8.3 3.3 114.6
Percentage 43.72 15.78 5.17 26.72 7.04 2.8 101.23
6.4. Appendix 4 – Castle Point Borough Council TEEP assessment
6.5. Appendix 5, 5a, 5b – London borough of Camden – Comingled collections switch
reports
6.6. Appendix 6, 6a, 6b, 6c, 6d, 6e - Air Quality, Traffic and Economic impacts reports
6.7. Appendix 7, 7a, 7b – Kerbside Analysis Tool (KAT)
6.8. Appendix 8 – Legal TEEP – The Waste (England and Wales) Regulations 2011
6.9. Appendix 9, 9a, 9b – WRAP Kerbside Recycling Reports 2011
6.10. Appendix 10 – WCC Doorknocking report
6.11. Appendix 11 – Carbon calculator

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