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REVIEW OF THE WELSH GOVERNMENT COLLECTIONS BLUEPRINT Joe Papineschi Emma Tilbrook Luke Emery 8 th March 2016

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Page 1: REVIEW OF THE WELSH GOVERNMENT COLLECTIONS BLUEPRINT · REVIEW OF COLLECTIONS BLUEPRINT 1 Executive Summary The Welsh Government published the ZCollections Blueprint - For affordable

REVIEW OF THE WELSH GOVERNMENT COLLECTIONS BLUEPRINT

Joe Papineschi

Emma Tilbrook

Luke Emery

8th March 2016

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Report for Waste and Resource Efficiency Division, Welsh Government

Prepared by Joe Papineschi, Emma Tilbrook and Luke Emery

Approved by

Joe Papineschi

Director

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

United Kingdom

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

Web: www.eunomia.co.uk

Acknowledgements

Our thanks to the Welsh Government, WLGA, WRAP Cymru and the members of the Technical Advisory Group for their support in gathering the evidence required to carry out this project and also developing the project outputs. Also, our thanks to Nigel Naisbitt of Naisbitt Resource Management for carrying out an independent peer review as part of this project.

Disclaimer

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

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Executive Summary

The Welsh Government published the ‘Collections Blueprint - For affordable and sustainable local authority collection services for recyclable, compostable and residual waste’ in March 2011. The Collections Blueprint describes the Welsh Government’s recommended service profile for the collection of waste from households, including the following central policies:

weekly separate collection of dry recyclables via ‘kerbside sort’, with material being collected separately in boxes and/or in re-usable sacks, with two or more boxes provided per household, and recyclables being sorted into separate compartments on the collection vehicle by the collection staff;

weekly separate collection of food waste;

the use of modern lightweight, multi-compartment vehicles for a single pass collection of dry recyclables and food waste; and

fortnightly collection of residual waste, from collections with reduced residual waste capacity, where ‘no side waste’ policies are enforced.

The Environment and Sustainability Committee held an Inquiry into recycling in Wales in December 2014. The purpose of this Inquiry was to explore current local authority household waste recycling practice and arrangements across Wales. It was recommended in this report that the Welsh Government commissions an independent review of the Collections Blueprint and the evidence it is based upon. This recommendation was accepted by the Welsh Government. In September 2015, Eunomia Research & Consulting (Eunomia) was commissioned by the Welsh Government to review the Collections Blueprint in light of new evidence arising since its publication in 2011. The aim of the project was to review emerging evidence to establish if the Collections Blueprint is still the best option for a waste management service across Wales that best delivers:

the well-being goals set for the Welsh Government and local authorities in the Well-being of Future Generations (Wales) Act 2015;

the best overall value for money;

compliance with the EU Waste Framework Directive. This includes compliance with:

o Article 11 – separate collection requirements: o Article 28 & 30 - to produce and update waste management plans: o high quality recycling and the best overall environmental outcome, as

a requirement of Articles 10 and 4 respectively of the Waste Framework Directive;

local authority landfill diversion and statutory recycling targets;

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support for the drive for a circular economy in Wales;

resilience in terms of recyclate markets;

the least reputational risk to local authorities and the Welsh Government (e.g. risks associated with contamination/rejects, illegal exports of contaminated recyclate etc.); and

high levels of public satisfaction with the service.

The project methodology was developed with a focus on delivering clear, transparent and auditable outputs from which the Welsh Government could have confidence in developing policy. To deliver this, the project methodology was divided into four parts:

initial evidence gathering;

detailed evidence assessment;

synthesis and presentation of findings; and

external peer review to consider the assessment methodology and how effectively it had been applied.

Within the initial evidence gathering stage, over 140 pieces of evidence were analysed to ascertain if they could support the review of the Collections Blueprint. Evidence which could help to address the research questions was passed through for detailed assessment. The detailed evidence assessment process was developed in order to provide a consistent, auditable and transparent analysis of the literature. Over 30 hypothesis statements were developed to allow for a methodical, standardised assessment of these 120 documents. The evidence for each hypothesis statement was assessed using a standard rating system with a scale from 0-5. The scoring was accompanied by detailed notes to justify scores and provide accountability and transparency to the process. These results were then collated and synthesised to draw conclusions on the extent to which the Collections Blueprint still provides the best option for waste management services across Wales. The evidence reviewed also demonstrates that the Collections Blueprint provides the best opportunity for local authorities and the Welsh Government to comply with Article 11 and Articles 28 and 30 of the Waste Framework Directive (2008) (WFD). In recognition of the importance of this review to the future development of Welsh Government policy, an external peer reviewer was also appointed to consider the assessment methodology and also how effectively it had been applied. Within the limitations inherent in a review restricted to considering secondary literature sources (very few of which were produced to study the relative performance of the Collections Blueprint) the following points could be drawn from the assessment:

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There is strong evidence to support policies focussing on the restriction of residual waste capacity in line with the Collections Blueprint, both in terms of impact on improving recycling performance and on reducing cost.

The evidence regarding collection system cost (both from actual cost data from Welsh authorities and from comparative cost modelling projects) indicates that the Collections Blueprint represents a lower overall cost option than alternative collection systems. The investment cost for implementing the Collections Blueprint may mean the savings may not be immediate.

The evidence on recycling performance suggests that the Collections Blueprint would be expected to perform similarly in terms of recycling rate to other dry recycling collection systems that also employ restricted residual waste capacity in line with the Collections Blueprint.

The evidence supports the view that separate collection results in higher quality, less contaminated material. This in turn results in a higher likelihood of material being appropriate for higher value-added closed-loop uses in the UK and Europe. This could result in greater climate change mitigation benefits and better overall greenhouse gas emissions performance for the Collections Blueprint versus alternative systems – thus helping Welsh Government and Welsh authorities comply with the Well-being of Future Generations (Wales) Act 2015.

Higher quality material is also likely to support the retention of material within the Welsh and UK economies, resulting in economic and social benefits. This supports the objectives of the Well-Being of Future Generations (Wales) Act 2015, improves resilience to materials market downturns and reduces the reputational risk associated with the fate of materials collected for recycling.

The evidence is strongest in relation to recycling performance, cost and material quality (issues that have been studied directly in many of the evidence sources considered) and weaker in areas more related to social and economic benefits, which have been considered in fewer studies and are in any event more challenging to research.

In relation to performance against the aims of the Well-Being of Future Generations (Wales) Act 2015, it is clearly too early for a direct evidence base to have developed, but it is likely that as local authorities increasingly consider their decisions taking account of these aims, the evidence base will improve.

Material quality is clearly a key area of differentiation between the Collections Blueprint and many other dry recycling collection systems. The environmental benefits of closed-loop recycling are clear, but the evidence in support of the wider economic and social benefits associated with this is weaker, despite the logic of the arguments in favour of maximising material quality.

Within this review a number of areas have been identified which the Welsh Government could consider further in the development of future policy or additional work within this area. These are as follows:

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The emerging evidence from operational schemes and collections options appraisals regarding further restriction of residual waste capacity (e.g. through a move to three-weekly or four-weekly collections) strongly indicates that this could result in further improvement in terms of recycling performance (in particular for food waste) and in cost reduction. It would therefore be sensible to independently investigate and analyse the impact of these changes further, with a view that the Collections Blueprint could be updated to reflect proven best practice.

An area where evidence has been relatively weak regarding the specific issues relating to the different collection systems is health and safety. Additional primary research could be carried out to thoroughly investigate the comparable health and safety implications of the Collections Blueprint and other collection services. Although some research has been undertaken in areas such as manual handling and noise, the scope of this was limited and much of it was carried out before the introduction of design improvements in Resource Recovery Vehicles (RRVs) and rear compaction vehicles (RCVs) that were intended to address these issues. It would therefore be beneficial to look at all aspects of the health and safety associated with collections in a holistic manner.

Although clear, logical conclusions that support the Collections Blueprint providing the best opportunity to support the achievement of the well-being goals set for the Welsh Government and local authorities in the Well-being of Future Generations (Wales) Act 2015 can be made, further research would be required to confirm and establish the magnitude of these benefits compared to other collection systems including in relation to employment.

The overarching objective of this study has been to consider whether the Collections Blueprint still provides the best blueprint for Welsh local authorities to follow, rather than to consider the merits or otherwise of having a single blueprint in the first place. Given that starting point, the Collections Blueprint does still appear to offer clear benefits in terms of cost and material quality, whilst offering no relative overall disadvantages in terms of recycling performance and health and safety (and clear advantages regarding residual waste volume restriction and food waste collection). The evidence surrounding the wider social and economic performance of different collection systems is not available, but it is reasonable to conclude that the improved material quality associated with separate collection is beneficial, even if quantifying this in any satisfactory way is not currently possible. As such it can be concluded that the Collections Blueprint does still provide a good basis for a waste collection standard for Wales.

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Contents

Executive Summary ........................................................................................................ 1

1.0 Introduction ....................................................................................................... 6

2.0 Project Methodology ......................................................................................... 7

2.1 Initial Evidence Gathering ................................................................................... 7

2.2 Detailed Evidence Assessment ............................................................................ 8

2.3 Synthesis and Presentation of Findings ............................................................... 9

2.4 Peer Review ...................................................................................................... 10

3.0 Findings from the Evidence Review ................................................................. 10

3.1 The Best Overall Value for Money..................................................................... 10

3.1.1 Residual Waste Collections ......................................................................... 10

3.1.2 Recycling Collection Methodology .............................................................. 13

3.2 Compliance with the EU Waste Framework Directive ....................................... 15

3.3 High Quality Recycling and the Best Overall Environmental Outcome ............... 16

3.4 Landfill Diversion and Statutory Recycling Targets ............................................ 19

3.4.1 Impact of Residual Waste Restriction ......................................................... 20

3.4.2 Separate Food Waste Collections................................................................ 22

3.4.3 Dry Recycling Collection Methodology ........................................................ 23

3.5 Supporting a Circular Economy in Wales ........................................................... 25

3.6 Resilience in Terms of Recyclate Markets ......................................................... 26

3.7 The Least Reputational Risk to Local Authorities and the Welsh Government ... 26

3.8 High Levels of Public Satisfaction with the Service ............................................ 28

3.9 The Goals of the Well-being of Future Generations (Wales) Act 2015 ............... 29

4.0 Conclusions ...................................................................................................... 31

Appendix ....................................................................................................................... 33

A.1.0 Hypothesis Questions .................................................................................... 33

A.2.0 Evidence ........................................................................................................ 35

A.3.0 Summary of Hypothesis Scores ...................................................................... 40

A.4.0 Peer Review – Summary of Findings .............................................................. 44

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1.0 Introduction

The Welsh Government published the ‘Collections Blueprint - For affordable and sustainable local authority collection services for recyclable, compostable and residual waste’ 1 in March 2011. The Collections Blueprint describes the Welsh Government’s recommended service profile for the collection of waste from households, including the following central policies:

weekly separate collection of dry recyclables via ‘kerbside sort’, with material being collected separately in boxes and/or in re-usable sacks, with two or more boxes provided per household, and recyclables being sorted into separate compartments on the collection vehicle by the collection staff;

weekly separate collection of food waste;

the use of modern lightweight, multi-compartment vehicles for a single pass collection of dry recyclables and food waste; and

fortnightly collection of residual waste, from collections with reduced residual waste capacity, where ‘no side waste’ policies are enforced.

The Collections Blueprint forms part of the overarching Wales waste strategy document, ‘Towards Zero Waste’, and the Municipal Sector Plan, and supports the implementation of a number of Welsh Government strategic commitments, as laid down in its Programme for Government2, Sustainable Development Scheme3, Environment Strategy4 and Climate Change Strategy5. In September 2015, Eunomia Research & Consulting (Eunomia) was commissioned by the Welsh Government to review the Collections Blueprint in light of new evidence arising since its publication 2011. Within this project over 140 pieces of evidence have been reviewed to answer the following research questions (as agreed with the project Technical Advisory Group).

Is the Collections Blueprint still the best option for a waste management service across Wales that best delivers:

1 Welsh Assembly Government (2011) Municipal Sector Plan Part 1- Towards Zero Waste One Wales: One Planet. Collections Blueprint, 2011, http://gov.wales/docs/desh/publications/110310municipalwasteblueprinten.pdf 2 Welsh Government (2014) Welsh Government Programme for Government, 2014, http://gov.wales/about/programmeforgov/?lang=en 3 Welsh Government (2009) One Wales:One Planet - The Sustainable Development Scheme of the Welsh

Assembly Government, May 2009, http://gov.wales/docs/desh/publications/090521susdev1wales1planeten.pdf 4 Welsh Government (2008) Environment Strategy Action Plan, 2008,

http://gov.wales/desh/publications/enviroprotect/environmentstrategy/environmentactionplan/esap0811e.pdf?lang=en 5 Welsh Government (2010) Climate Change Strategy for Wales, October 2010, http://gov.wales/docs/desh/publications/101006ccstratfinalen.pdf

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the well-being goals set for the Welsh Government and local authorities in the Well-being of Future Generations (Wales) Act 2015;

the best overall value for money;

compliance with the EU Waste Framework Directive. This includes compliance with:

o Article 11 – separate collections requirements: o Article 28 & 30 - to produce and update waste management plans: o high quality recycling and the best overall environmental outcome, as

a requirement of Articles 10 and 4 respectively of the Waste Framework Directive;

local authority landfill diversion and statutory recycling targets;

support for the drive for a circular economy in Wales;

resilience in terms of recyclate markets;

the least reputational risk to local authorities and the Welsh Government (e.g. risks associated with contamination/rejects, illegal exports of contaminated recyclate etc.); and

high levels of public satisfaction with the service.

The following report details the methodology undertaken by Eunomia to address these questions ensuring all analysis was carried out in a transparent and suitable way.

2.0 Project Methodology

The project methodology was developed with a focus on delivering clear, transparent and auditable outputs from which the Welsh Government could have confidence in developing policy. To deliver this, the project methodology was divided into four parts:

initial evidence gathering;

detailed evidence assessment;

synthesis and presentation of findings; and

external peer review to consider the assessment methodology and how effectively it had been applied.

The following sections provide further detail about each of these parts of the process.

2.1 Initial Evidence Gathering

A process of initial evidence gathering was used to identify literature sources which could help to address the research questions presented in Section 1.0. The aim was to gain evidence from a broad range of sources to ensure that the findings were representative. To achieve this, a desk-based literature search was carried out in conjunction with a request for evidence from local authorities.

The Welsh Government provided a range of reports relating to the Collections Blueprint or the research questions in general. This was supplemented with additional desktop

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research undertaken by Eunomia. Research methods included focussed internet searches, open requests for evidence from WRAP and Zero Waste Scotland who hold a significant amount of evidence which could impact the analysis carried out as part of this work, and also a review of outcomes of other relevant Eunomia projects. This work was complemented by a two week call for evidence which was presented to all Welsh local authorities through the Technical Advisory Group (TAG), allowing local authorities to send relevant evidence and to contribute their views and experience to the process.

During the initial evidence assessment, over 140 pieces of evidence were obtained by Eunomia including authority reports, collections options appraisals and trial results. The evidence was logged and assigned a unique ID number to organise the evidence ready for assessment. The content of each document was categorised in a spreadsheet, with a rating used to determine the extent to which each document met the research themes.

The system used to rate the documents is shown in Table 2.1. This was used to compare the extent to which the individual literature sources fit with different aspects of the research. This was useful to identify areas of the literature which required more evidence and to rank the documents in terms of their contribution towards the review of the Collections Blueprint. In total, over 120 documents were progressed to the next stage for a detailed evidence assessment.

Table 2.1: Rating system for the initial evidence categorisation

Rating Extent to which content meets each research theme

A Major Focus

B Covered but not Major Focus

C Minor Focus

2.2 Detailed Evidence Assessment

The detailed evidence assessment was developed in order to provide a consistent, auditable and transparent analysis of the literature. Over 30 hypothesis statements were developed to allow for a methodological, standardised assessment of each document (see Table A.1.1). The hypotheses were designed to test the research questions within the review, with specific reference to the key policies of the Collections Blueprint. An example of such a hypothesis statement is as follows:

“The reduction of refuse frequency to fortnightly and containment volumes to 140 litres increases dry recycling captures from the baseline position”.

All of the hypotheses were written in such a way as to test the current structure of the Collections Blueprint i.e. the hypothesis tested whether the current Collections Blueprint method is better or worse than alternatives. It is important to note that a lack of evidence did not mean that the conclusion defaulted in favour of the current structure of the Collections Blueprint. Where no evidence was found, it was concluded that the hypothesis could not be either accepted or rejected. Similarly, failure to prove the hypothesis did not necessarily mean that it was assumed to be false or vice versa.

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The evidence for each hypothesis statement was assessed using a standard rating system with a scale from 0-5 as shown in Table 2.2. This scale accounted for varying degrees of evidence for (4 and 5) or against (1 and 2) the hypothesis along with a provision for situations where there was either inconclusive evidence (3) or no relevant evidence at all (0).

Table 2.2: Evidence Scoring

Score Score Meaning

0 Does not provide relevant evidence

1 Provides strong evidence to reject the hypothesis

2 Provides evidence to reject the hypothesis

3 Provides no clear evidence to either accept or refute the hypothesis

4 Provides evidence that supports the hypothesis

5 Provides strong evidence supporting the hypothesis

This standardised approach allowed consistent evaluation of each document. The scoring was accompanied by detailed notes to justify scores and provide accountability and transparency to the process. The resulting scoring enabled an objective evaluation of the extent to which each document provided evidence to support the ability of the Collections Blueprint to meet the objectives listed in Section 1.0. The process was also designed to highlight any evidence that indicated that other collections options might better meet the objectives.

A key part of the detailed evaluation process was a consideration of the relevance and quality of the evidence. Information in the literature was not just taken at face value but was interrogated to ensure that the evidence was robust enough to draw the associated conclusions. The technical experience of evaluators was drawn upon for this process and an objective, fair approach was employed and this process was observed through formal peer review process (see Section 2.4 for further details). An example to highlight the importance of this process is where a document was found to claim that a change in collection system would lead to an increase in recycling. In cases where the assumptions of the report were not stated in a transparent manner and supported by robust evidence then this was assessed as being weaker evidence than reports which clearly documented and justified their evidence-based assumptions.

2.3 Synthesis and Presentation of Findings

The individual responses to each hypothesis (found in Table A.1.1) were collated to provide a single overall response for each research question based on all of the relevant pieces of evidence. A record of the scoring allocation for each hypothesis question can be found in Table A.3.1. Where the evidence appeared to strongly support or contradict the statement it was subjected to additional scrutiny. The Eunomia research lead was responsible for the overall technical quality of the review and technical direction. This research lead carried out checks to ensure the quality of the assessment. This was complemented by an independent peer reviewer who checked the quality of a 10%

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sample of the assessments including some of the most significant pieces of evidence to ensure that they had all been carried out to an equal standard.

The findings of the assessment are presented within Section 3.0.

2.4 Peer Review

In recognition of the importance of this review to the future development of Welsh Government policy, an external peer reviewer was also appointed to oversee the appropriate application of the agreed project methodology by Eunomia. Nigel Naisbitt of Naisbitt Resource Management Ltd was appointed into this role, with Nigel’s appointment being agreed and authorised by the project TAG. As part of this role Nigel undertook the following activities:

a detailed review of the appropriateness and applicability of the project methodology;

review of the quality of the evidence review undertaken by Eunomia, ensuring that the review is carried out in detail and the analysis is reflective of the content of each piece of evidence;

provide feedback to Eunomia on the evidence review methodology and its execution, providing suggestions on how any weaknesses could be addressed;

attendance at a Eunomia internal project challenge session and meeting with Welsh Government and the TAG;

provide feedback and support to the Welsh Government and the TAG regarding the ongoing findings of the peer review; and

provide a written summary of the findings of the peer review.

A copy of the summary report from Naisbitt Resource Management can be found in Appendix A.4.0

3.0 Findings from the Evidence Review

The following sections detail the findings of the detailed evidence review.

3.1 The Best Overall Value for Money

The evidence reviewed indicates that the Collections Blueprint provides a lower cost solution than other comparative collection systems, even when the efficiency of all services is optimised.

3.1.1 Residual Waste Collections

Within the documents analysed, there is consistent evidence to suggest that the reduction of residual waste frequency to fortnightly and the restriction of containment volumes to, for example, 140 litres will reduce the cost of collecting and disposing of residual waste.

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The evidence to support this conclusion is taken from individual local authority collections options appraisals as actual budgetary information, specifically relating to the introduction of restriction of residual waste capacity and frequency was not available as part of this review.

Future collections options appraisals for the Welsh authorities of Wrexham6, Torfaen7, Blaenau Gwent8 (carried out under the Collaborative Change Programme) and English authorities of Calderdale9 and Walsall10 supported this statement. In all cases, when compared to residual waste collections with higher frequencies and/ or a greater residual waste capacity, collection costs were lower. It should be noted however, that when examining the collections options appraisal from Gwynedd11, the collection costs associated with the introduction of 140 litre wheeled bins for fortnightly residual waste collections increased against the baseline of using 240 litre wheeled bins. This higher cost was due to the capital costs of purchasing and distributing new smaller receptacles being included in the cost of delivering the service. This indicates that although as a policy the restriction of residual waste capacity drives a reduction in collection and disposal costs, issues such as local infrastructure and requirements will need to be taken into account as part of the decision making process.

In addition, where greater reductions in residual waste collection frequency are considered (e.g. three weekly and four weekly), the emerging evidence suggests that the costs of collection and disposal of residual waste could be further reduced due to a reduction in collection resources and in the amount of residual waste collected and disposed of. It is therefore reasonable to conclude that a weekly container volume equivalent of less than the 70 litres or a further decrease in collection frequency as currently suggested within the Collections Blueprint would be likely to result in a further reduction in collection costs versus the current Collections Blueprint. The evidence base for this conclusion is comprised of collections options modelling reports, as no evidence was obtained regarding the relative costs savings associated with these services when compared to the baseline costs. More restricted residual waste collection services were modelled in appraisals conducted under the Collaborative Change Programme for

6 WRAP Collaborative Change Programme Unit (2015) Collection Options Modelling for Wrexham County Borough Council, 2015 7 SKM Enviros (2013) Support to Torfaen County Borough Council (Collections Modelling), Report for WRAP, 2013 8 Eunomia Research & Consulting (2012) Blaenau Gwent CBC Business Plan: Supporting Technical Report,

Report for WRAP Cymru, March 2012 9 Eunomia Research & Consulting Ltd (2013) Calderdale MBC Collection Options Appraisal, Report for

WRAP, 2013 10

Eunomia Research & Consulting (2011) Identifying Potential Efficiency and Savings Options for Waste Services at Walsall Council, Report for Walsall Council, September 2011 11 SKM Enviros (2013) Recycling performance and Options Review for Gwynedd Council, Report for WRAP, 2013

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Anglesey12, Cardiff13, Gwynedd14, Torfaen15 and Wrexham16 and in all cases when collections were restricted beyond the minimum requirements of the Collections Blueprint, service costs decreased.

Three weekly residual waste collection services are still relatively new within the UK and it could be expected that detailed actual budgetary and financial information for these services would be available over the coming years. Table 3.1 details authorities in the UK that are currently operating more restricted residual waste collection services.

Table 3.1: UK Authorities Operating More Restricted Residual Collections

Authority Receptacle Size Collection Frequency

Introduction of Further Residual Waste Restrictions

Falkirk Council 240litre

Three Weekly

2014

Bury Council 240litre 2014

Gwynedd Council 240litre 2014

Rochdale MBC 240litre 2015

Powys CC 180litre 2015

Blaenau Gwent BC 240litre 2015

Salford MBC 240litre Pilots Approved

I of Anglesey CC 240litre Under Consultation

Within Table 3.1, all of the authorities are operating three weekly collections, with no examples of four weekly collections currently in place. Also, although all of the authorities have introduced three weekly collections, Powys has a smaller equivalent weekly residual waste capacity (60 litres as opposed to 80 litres in all other options – which is actually more than 140 litres per fortnight as per the Collections Blueprint). This indicates that when assessing the opportunity for further policy development, the financial impact of reducing the frequency (to for example a three weekly service) versus

12

Eunomia Research & Consulting (2013) Isle of Anglesey County Council Collection Options Appraisal, Report for WRAP, May 2013 13

Chris Mills, and Debbie Palfrey (2014) Cardiff Council KAT Modelling Summary Report, Report for WRAP Cymru, October 2014 14

As footnote 11 15 As footnote 7 16

As footnote 6

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increasing the restriction of residual waste capacity on a fortnightly basis should be re-examined. Within the emerging evidence analysed as part of this project, a reduction in the frequency of residual waste collections appears to potentially have a greater financial and performance impact than more frequent collections with a lower equivalent weekly capacity. In all cases residual waste volumes should be constrained by wheeled bins or capping the number of sacks presented and strict no side waste policies enforced.

3.1.2 Recycling Collection Methodology

A key piece of evidence used in reaching conclusions regarding the cost of the Collections Blueprint recycling collection methodology is the Welsh Local Government Association (WLGA) summary of the median costs of the provision of dry recycling services, which has been derived from the WLGA Waste Improvement Programme (WIP) benchmarking work.17 This analysis collates the total actual reported costs for all authorities in Wales of delivering dry recycling collection and groups these by collection system. This evidence shows the median annual cost per household for collections broadly similar to the Collections Blueprint being £28.60, Non-Collections Blueprint kerbside sort operations being £53.40 per household, twin stream operations being £55.08 per household, multi-stream operations being £37.25 per household and single stream co-mingled collections being £36.58 per household. Although this evidence uses actual cost data reported by local authorities, it does not take into account other factors which affect costs such as the service efficiency, local geographic and demographic characteristics and local disposal and material sales arrangements. As such, although important evidence, it does not on its own prove that the Collections Blueprint represents the lowest overall cost option.

However, these additional factors (underlying service efficiency, local geographic and demographic characteristics, disposal costs and material sales values) are taken into account within the collections options modelling reports analysed as part of this project.18 Although modelling is no substitute for actual cost data such as the WLGA’s WIP benchmarking work, these reports do directly compare the costs of delivering different types of recycling schemes within the same authority. This therefore provides a direct, ‘like for like’ comparison of the relative cost of different schemes, taking account of the geographic and demographic situation and other local cost drivers. In all of these reports (including for Anglesey19, Blaenau Gwent20, Merthyr Tydfil21 and Gwynedd22), although the cost of collecting dry recycling was higher in options which reflected the

17

Welsh Local Government Association (2015) Waste Finance Data Report 2013-14, 2015 18

These were produced under the Collaborative Change Programme (CCP) 19

See footnote 12 20

See footnote 8 21

Eunomia Research & Consulting Ltd (2012) Merthyr Tydfil CBC Business Plan: Supporting Technical Report, Report for WRAP Cymru, 2012 22

See footnote 11

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Collections Blueprint, the overall service costs were consistently lower. These lower costs appear to be largely driven by the income received by authorities from the sale of the separately collected dry recyclables and the avoidance of Materials Recovery Facilities (MRFs) processing costs. The actual cost data from the WLGA’s WIP is therefore consistently corroborated by modelling of collections options for authorities across Wales.

With regards to the use of modern Resource Recovery Vehicles (RRVs), all of the reports reviewed considered the use of these as standard and other vehicles were not considered as part of this analysis, indicating that these vehicles are widely recognised as currently the most appropriate vehicles for carrying out these collections.

3.1.2.1 Food Waste

Food waste collections were considered as part of all of the collections options appraisals reviewed; however, in all cases they were modelled as being collected separately on a weekly basis. Therefore from the evidence reviewed it was not possible to ascertain if separate weekly food waste collections presented a lower cost than food waste collected in other non-caddy based systems. However, the fact only separate collections of food waste collected on a weekly basis were explored as part of these future options appraisals, indicates that these are widely accepted as the most appropriate method for collecting food waste from the kerbside and a key part of the Collections Blueprint.

3.1.2.2 Bring Sites and On the Go Recycling

Bring sites and on the go recycling were not widely considered within the evidence reviewed. Bring sites were, however, discussed within the ‘Powys County Council Waste Strategy 2014/2015’23 and also the Wales Audit Office Report ‘Public Participation in Recycling’24. Within these reports, bring sites were described locally by Powys as a cost –effective addition to the collection of dry recyclables, on a national level the Wales Audit Office stated that these services have high public use and waste throughput, and, in their view they remain a cost-effective means of re-use and recycling. Although it should be noted that Eunomia’s experience from working with other authorities across England, is that in many cases bring bank provision is being reduced or removed where a comprehensive recycling service is in place as a cost reduction measure.

23

Powys County Council (2014) Powys County Council Waste Strategy 2014/2015, Report for Powys County Council, 2014, http://pstatic.powys.gov.uk/fileadmin/Docs/Planning/LDP/Powys_Waste_Strategy_2014-15.pdf 24 Wales Audit Office (2012) Public Participation in Waste Recycling, February 2012, http://wao.gov.uk/system/files/publications/Public_participation_in_Waste_Recycling_English_2012.pdf

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3.2 Compliance with the EU Waste Framework Directive

The evidence reviewed demonstrates that the Collections Blueprint provides the best opportunity for local authorities and the Welsh Government to comply with Article 11 and Articles 28 and 30 of the Waste Framework Directive (2008) (WFD).

Article 11 of the WFD, which has been transposed into the Waste (England and Wales) Regulations 2011 (as amended), requires the separate collection of paper, plastic, metal and glass. The Collections Blueprint stipulates that recyclables should be separated at the kerbside and is therefore compliant with the requirement of regulations for separate collection. As such, it poses no risk of legal challenge to authorities and can reasonably be considered, alongside other methods of separate collection, to offer the best means of compliance.

The way that the WFD is transposed in the Regulations has been the subject of judicial review, and the original wording of Regulation 13 was amended by Defra and the Welsh Ministers in 2012, in effect clarifying that co-mingled collection is not a form of separate collection. Whilst the Regulations express a clear presumption in favour of material being collected in separate streams, collecting materials co-mingled may be permissible where separate collection is not necessary to achieve high quality recycling or where separate collection can be demonstrated to be technically, environmentally or economically impracticable. The legal position is clear that any decision to deem separate collection either unnecessary or impracticable has to be taken at the local level.

The Collections Blueprint is part of the Municipal Sector Plan,25 which is part of the Welsh waste strategy Towards Zero Waste.26 It sets out the background of the existing situation and provides analysis of the quantities of waste produced, recycling levels and end destinations of waste relating to the sector. It also provides a discussion around compliance with targets and the requirements of the WFD.

The Collections Blueprint reflects the requirements of Article 28 of the WFD. Also, paragraph 8 of Schedule 1 of the Waste (England and Wales) Regulations 2011 (reflecting the requirements of Article 11(1)) requires the Welsh Government to include in its waste plan ‘Measures to promote high quality recycling including the setting up of separate collections where TEEP and appropriate to meet the necessary quality standards for the relevant recycling sectors’. The Collections Blueprint reflects this requirement through its promotion of high quality recycling.

Article 30 of the WFD concerns the evaluation and review of plans and programmes. There is a requirement that the waste management plans and programmes are evaluated at least every six years to review progress. The Welsh Government published a progress report27 in 2015 which provided a detailed review of the progress towards the

25

As footnote 1 26

As footnote 3 27 Welsh Government (2015) Towards Zero Waste 2010–2050 Progress Report, 2015, http://gov.wales/docs/desh/publications/150724-towards-zero-waste-progress-report-en.pdf

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targets set in the Towards Zero Waste Strategy which again suggests compliance with the directive. This project which has been commissioned to review the Collections Blueprint, also ensures compliance with the directive.

The Welsh Government has published guidance28 to inform Local Authorities making decisions related to the separate collection of recyclables. The guidance helps Authorities to interpret and comply with the legislation.

3.3 High Quality Recycling and the Best Overall Environmental Outcome

The evidence reviewed supports the Collections Blueprint as continuing to be the best option for the collection of high quality recycling with the best overall environmental outcomes. All of the evidence reviewed which refers to the issue of quality suggests that the quality of the material collected with Collections Blueprint-aligned collection services is higher than for other kerbside collection services analysed.

To enable the assessment of evidence in relation to the quality of material produced through the Collections Blueprint and other collections options, it is necessary to establish a definition of ‘high quality recycling’. There is considerable debate within the waste industry regarding the appropriate definition of ‘high quality recycling’. An argument made at one end of the spectrum is that any material that finds a willing buyer (and therefore meets a market-based quality standard) is by definition of high enough quality. In the context of the Welsh Government’s focus on sustainable development, the development of a circular economy and the retention of as much of the economic benefit of resource management within Wales, a definition which says that ‘all recycling is high quality recycling’ seems inappropriate. For the purpose of this project, we have assumed that high quality recycling requires quantities of non-targeted or contaminated material to be minimised and the potential for material to be sent for closed-loop recycling, which has been shown in the case of several key materials to lead to increased environmental benefits, is maximised.29

In all examples where Collections Blueprint recycling services were compared with other collection services such as co-mingled or twin stream, higher kerbside contamination rates were recorded for co-mingled or twin stream services and this conclusion is supported by WasteDataFlow information. In many cases, the evidence discussed in the literature review only accounted for contamination collected at the kerbside and not

28

Welsh Government (2014) Statutory Guidance on the Separate Collection of Waste Paper, Metal, Plastic and Glass, 2014, http://gov.wales/docs/desh/publications/141217-statutory-welsh-guidance-on-separate-collection-of-waste-v2-en.pdf 29

For example WRAP (2006) Environmental Benefits of Recycling: An International Review of Life cycle Comparisons for Key Materials in the UK Recycling Sector, Final Report to WRAP, May 2006 and WRAP (2011) Kerbside collections options: Wales - technical annex, January 2011, both of which draw upon a number of other referenced studies

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process losses. Losses can occur due to collection rejection, sorting rejection and removal of contamination by reprocessors.

Data from work commissioned by WRAP is summarised in Table 3.2.30 It suggests that average contamination rates from source separated collections are lower for all materials, with a greater percentage of each material collected being recycled.

Table 3.2: Source Separated and Co-mingled Materials Contamination Rates

Material

Material Contribution as % of whole

Recorded Contamination

Actually Recycled

Source Separated

Co-mingled Source Separated31

Co-mingled32

Source Separated

Co-mingled

Paper 31.9% 28.5% 1.1% 15.8% 31.6% 24.0%

Card 21.1% 18.8% 4.1% 12.0% 20.2% 16.6%

Glass 30.5% 27.2% 0.4% 10.4% 30.3% 24.4%

Plastic 11.3% 10.1% 2.9% 18.2% 11.0% 8.3%

Aluminium 1.3% 1.1% 1.0% 2.5% 1.3% 1.1%

Steel 3.9% 3.4% 3.0% 6.2% 3.7% 3.2%

MRF Reject 10.90% 0%

Total 100% 100% 98.2% 77.5%

Source: Eunomia Research and Consulting (2015) 33 drawing upon data from Enviros Consulting (2009) 34 and Zero Waste Scotland (2014)35

This is an example of a study which took into account evidence regarding contamination levels and process losses, and provides a measure of the amount of material actually being recycled. It should be noted that the data from the 2009 Enviros study is now relatively old in technology terms and the composition and recorded contamination levels may have varied over this period. However, this report does still represent the most extensive work carried out in this area. The data reported as part of The Environmental Permitting (England and Wales) (Amendment) Regulations 2014 (the MRF Regulations) is still emerging and a full year of data is not yet available to enable a more up to date comparison to be made.

WRAP states in its 2009 report ‘Choosing the Right Collection System’36 that kerbside sort systems provide a more reliable stream of quality materials than other methods.

30

Eunomia Research & Consulting Ltd (2015) Implementing the Welsh Government Collections Blueprint, Report for WRAP, 2015 33

As footnote 30 34

Enviros Consulting (2009) MRF Quality Assessment Study, Report for WRAP, November 2009 35 Zero Waste Scotland (2014) Contamination in source-separated municipal and business recyclate in the UK 2013, 2014

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The sources of contamination identified by WRAP include householders putting incorrect materials into containers, the issue of broken glass binding different materials together and the capacity of MRFs to separate the waste they receive. This leads them to the conclusion that lower quality recycling is typically more often suitable for lower value open-loop applications while the greatest benefits are associated with closed-loop recycling.37

This conclusion is supported by a confidential assessment carried out by WRAP which tracked the materials from four Welsh authorities.38 The report concludes that across all materials, source segregated materials are more likely to serve UK markets whilst materials leaving MRFs are more commonly destined for export markets where the tolerance for contamination can often be higher.

The report also concluded that MRFs appear in some cases to be presenting local authorities with contamination rates which are based on their incoming material contamination and not necessarily including the rejects from the MRF process. The report also highlights that many primary MRFs are using secondary sorting facilities to further sort their MRF residues which can complicate the assessment of recycling rates from a specific facility. Additionally, process losses do not appear to be reported correctly by local authorities in all circumstances within WasteDataFlow and so MRF rejects are actually likely to be higher than currently presented – with the potential that authority recycling rates may be being overstated.

The evidence provides further support for the Collections Blueprint as providing the best option for the collection of high quality recycling with the best overall environmental outcomes.

Within the evidence reviewed, the actual end destinations of materials collected from schemes operating the Collections Blueprint or other collections methodologies were not reported. As such, the evidence reviewed doesn’t confirm the hypothesis that a higher proportion of material collected from authorities operating the Collections Blueprint is reprocessed within the UK in closed-loop processes. However, evidence from the Resource Association, which represents reprocessors in the UK, indicates that materials which contain lower levels of contamination are more likely to achieve higher values and be accepted by UK reprocessors. In the case of paper contaminated with glass, contamination rates as low as 0.5% are considered likely to significantly reduce the acceptability of the material to UK reprocessors.39 No evidence has been obtained that assists in confirming whether levels of contamination as low as this could be achieved through MRF operations. However, the evidence suggests that it is more likely that these

36

WRAP (2009) Choosing the Right Recycling Collection System, 2009, www.wrap.org.uk/downloads/Choosing_the_right_recycling_collection_system.f5add909.7179.pdf 37

As footnote 36 38

WRAP (2015) CONFIDENTIAL Materials Tracking Report, Report for WRAP Cymru, October 2015 39 Resource Association (2014) ReQIP contamination value chart, accessed 12 January 2015, http://www.resourceassociation.com/reqip-contamination-value-chart

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will be achieved through separate collection, although the report from Zero Waste Scotland (ZWS) indicates that quality improvements need to be made even in separate collections.40 The contamination rates found in this study (summarised in Table 3.2) vary between 0.4% (mixed glass) and 4.1% (card), although it should be noted that this study included contamination by similar materials within its data (e.g. incorrectly separated coloured glass within a glass collection).41

Emerging evidence following the introduction of the MRF Regulations in October 2014 indicates possible under-reporting of MRF rejects within current WasteDataFlow returns.42 This data relates to sampling and measurement of input contamination from MRFs, with many declaring higher rates of input contamination than the reject rates reported by their local authority users. This situation will not be fully understood until further reporting has been undertaken under the regulations, but it is clearly a counter-intuitive result that merits further examination. Quarter 2 reporting from the Materials Facility (MF) Reporting Portal43 indicates that within England 5.5% of input material received was non-target recyclable materials and a further 8.0% was non-recyclable material. In Wales these figures were slightly lower at 5.8% and 4.3% respectively. The Quarter 2 reporting from the MF Reporting Portal under the requirements of the Regulations shows that the average percentage of target material in the outputs of responding MRFs is 89.10 % (10.9% being non-target). Although these levels have increased from Quarter 1, the level of contamination within these output materials are still considerably higher than observed within kerbside sorted materials as part of the Zero Waste Scotland (ZWS) analysis.

3.4 Landfill Diversion and Statutory Recycling Targets

The evidence reviewed suggests three key findings regarding the ability of the Collections Blueprint to represent the best approach for local authorities to meet landfill diversion and statutory recycling targets:

1) Key elements of the current Collections Blueprint (reducing residual waste capacity to 140 litres once a fortnight and collecting no side waste) increases the amount of dry recycling and food waste captured from the kerbside. In addition, emerging evidence indicates that if further restrictions on residual waste were introduced, dry recycling and food waste yields could increase further, alongside the possibility of an overall reduction in kerbside waste arisings.

2) The evidence confirms that where analysed, weekly separate collections of food waste obtain higher material yields than when compared to other lower frequency or non-caddy based options.

40

See footnote 36 41

See footnote 36. 42

England and Wales (2014) The Environmental Permitting (England and Wales) (Amendment) (England) Regulations 2014, 2852 43

WRAP (2015) WRAP MF Portal Quarter 2 Information Sheet

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3) The evidence regarding dry recycling collection system performance is generally

weaker in drawing conclusions, apart from the recent multi-factorial analysis carried out by WRAP as part of their report Analysis of Recycling Performance and Waste Arisings in the UK 2012/1344 which is discussed in more detail in Section 3.4.3. However, in general the evidence supports the view that the separate collection element of the Collections Blueprint can achieve performance levels similar to those of other high-performing options that include comparable restricted residual waste policies.

3.4.1 Impact of Residual Waste Restriction

The evidence reviewed suggests that the current Collections Blueprint policy (reducing residual waste capacity for example to 140 litres in sacks or wheeled bins, reducing residual waste collection frequency to once a fortnight and collecting no side waste) increases the amount of dry recycling and food waste captured from the kerbside.

A significant amount of the evidence reviewed addressing this issue were collections options modelling reports, although these were supplemented with the results of residual refuse sack number reduction policies in Swansea and Monmouthshire.

The WRAP report ‘Support to Monmouthshire Council’45, concluded that when Monmouthshire restricted its residual waste capacity to two kerbside sacks per fortnight, residents decreased the number of residual sacks put out for collection by 47%. This equated to a reduction of 2.95kg per household per week (kg/hh/wk) or 6,093 tonnes annually across all Monmouthshire households. Two kerbside sacks represents approximately 140 litres per fortnight (70 litres per sack); however, unlike with wheeled bins, the full capacity of the sack cannot be reached as it needs to be tied and lifted, therefore the actual available volume is lower than this. In addition to the reduction in residual waste participation and yields, food waste participation increased by 32%, with a 4% - 5% increase in participation in the dry recycling service. This performance was supported by evidence from Swansea46, which restricted its residual waste collections to three sacks per fortnight and recorded a reduction of over 7,500 tonnes of kerbside residual waste and a 3.87% increase in recycling rate. In both cases it is not possible to state that all of the reduction in residual waste arisings were wholly attributable to the restriction policy, as there would have also have been additional communication regarding service changes around this time.

44

WRAP (2015) Analysis of Recycling Performance and Waste Arisings in the UK 2012/2013, WRAP, July 2015 45

M.E.L Research, and WYG (2013) Support to Monmouthshire County Council (Compositional analysis), Report for WRAP, 2013 46

City and County of Swansea Collection Performance Review City and County of Swansea (Briefing note)

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Wheeled bin solutions were more extensively tested within the collections options modelling reports from a number of Welsh Authorities including Cardiff47, Torfaen48, Anglesey49, Gwynedd50 and Ceredigion51. In all of these reports where residual waste collections were restricted in line with the policies of the Collections Blueprint, residual waste yields were modelled to decrease and dry recycling and food waste yields were modelled to increase. Within a number of these reports the assumptions regarding changes in yields were supported by detailed benchmarking information, which referenced the impacts seen within other authorities that have implemented the scheme being modelled.

As discussed in Section 3.1.1, many of the pieces of evidence submitted for this project (largely modelling reports) explored greater reductions in residual waste collection frequency than fortnightly (e.g. three weekly and four weekly). This provides some evidence to suggest that this change further increases capture of dry recycling and food waste at the kerbside. In many cases the impact of these further reductions are based on modelling assumptions, as changes to three weekly collections are still quite new and no authority in the UK currently operates a four weekly residual waste collection service. However, within work carried out by Somerset Waste Partnership52, the impact of three weekly collections is analysed in detail using actual tonnage data from authorities that have already made this change (Gwynedd, Bury and Falkirk) and also the results of trials across Somerset (this data is presented in Figure 1).

47

See footnote 13 48

See footnote 7 49

See footnote 12 50

See footnote 11 51

AMEC Environment & Infrastructure UK Limited (2014) Assumptions Report (Ceredigion), Report for WRAP, August 2014 52 Eunomia Research & Consulting (2015) Collection Options Appraisal – Part 1, Report for Somerset Waste Partnership, November 2015

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Figure 1 - Compilation of Three Weekly Collection Impact Data

Source: Eunomia Research and Consulting (2015)53 drawing upon data from WasteDataFlow.

In all of these examples (as shown in Figure 1) when residual waste collections were moved to three weekly, dry recycling and food waste yields increased, residual waste yields decreased and there was some overall reduction in waste arisings. The impact of three weekly recycling collections cannot be directly compared, as in each case the baseline service and therefore the scale of change was different. However, the impact is notable in all cases.

3.4.2 Separate Food Waste Collections

In many cases the performance of weekly separate food waste collections were not directly compared to less frequent or mixed food and garden waste systems, as weekly separate food waste was considered to be the ‘default’ system. However, the relative performance of these schemes was examined within collections options appraisal reports for Wrexham54 and Gwynedd.55 Within the Wrexham report, lower yields were predicted for food collected fortnightly with garden waste relative to weekly separate collections. Within the Gwynedd report, the impact of the change from mixed garden and food waste to weekly separate food waste was analysed. The WasteDataFlow

53

As per footnote 51 54 See footnote 6 55

See foot note 11

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information shows an increase of circa 800 tonnes in organics yields following this change. As the service moved from a mixed garden and food waste service, it is not possible to accurately ascertain how much of this increase can be attributed to the introduction of separate food waste collections. However, WasteDataFlow information also shows a decrease in residual waste tonnage of approximately 1,000 tonnes in the same period. With such a significant increase in food waste yields and reduction in residual waste tonnage, it seems reasonable to conclude that a notable amount of this tonnage was food waste. Two earlier studies published by WRAP in 200756, 57 which were reinforced by a 2008 update58 found evidence that separate food waste collections outperform both separate garden waste collections and mixed food and garden waste collection systems.

3.4.3 Dry Recycling Collection Methodology

With regards to the dry recycling system performance, many studies acquired for consideration within the project failed to provide real insight. This was because, for example, optimised examples of different collection systems were not considered or the analysis had not adequately isolated the issue of the collection system from other factors which may affect performance such as demographics or the nature of residual waste service.

When trying to evaluate the impact of the dry recycling collection system on overall recycling rate, it is essential to isolate the dry recycling scheme as a factor in this analysis. Although several of the pieces of evidence sought to compare the recycling performance of different collection systems, very few attempted to isolate the cause of variation in recycling performance relative to other factors.

The best, most comprehensive independent source of evidence in this area is WRAP’s recently published “Analysis of Recycling Performance and Waste Arisings in the UK 2012/13”.59 The sophisticated multi-factorial regression analysis undertaken as part of this work concludes that in unitary authorities such as those in Wales, factors such as the presence of food waste collections, level of social deprivation, rurality and available residual containment volume are significant factors impacting recycling rates, while the choice of dry recycling collection system was found to be a non-significant factor driving recycling rate.

56 Eunomia Research & Consulting (2007) Dealing with Food Waste in the UK, Report for WRAP, 2007, http://www.leics.gov.uk/dealing_with_food_waste_wrap_eunomia.pdf 57

Eunomia Research & Consulting (2007) Managing Biowastes from Households in the UK: Applying Life-cycle Thinking in the Framework of Cost-benefit Analysis, Report for WRAP, 2007, http://www.wrap.org.uk/sites/files/wrap/Biowaste_CBA_Final_Report_May_2007.pdf 58

Eunomia Research & Consulting (2008) Food Waste Collection: Update to WRAP Biowaste Cost Benefit Study, Report for WRAP, 2008, http://www.wrap.org.uk/sites/files/wrap/Update_to_Biowaste_CBA_Report.pdf 59 WRAP (2015) Analysis of Recycling Performance and Waste Arisings in the UK 2012/2013, WRAP, July 2015

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The White Young Green (WYG) Report “Review of Kerbside Recycling Collection Schemes in the UK in 2011/12”60 takes a different approach and comes to a different conclusion to the WRAP work. This report examines the relative performance of the 30 highest performing UK authorities in terms of recycling rate and seems to examine from this performance data which collection systems are highest performing. The report concludes that, of the top 30 dry recycling performers in 2011/2012, 20 operated fully co-mingled services and a further six were co-mingled with one stream separated (normally glass). The WYG and WRAP reports both draw on the same source data from WasteDataFlow (although use data reported from different years) to undertake their analysis; however, the WYG work is not multi-factorial in nature and does not take into account other factors which have been shown to affect recycling performance such as residual waste frequency or volume restriction, the types of materials collected, the impact of food waste collection schemes, demographics and housing type. As such, it is not possible to attribute the trend observed in the top 30 performers in terms of collection system to the collection system choice itself. The focus on the top 30 performers also excludes a significant amount of potentially valuable data that the WRAP study has included within its scope. This is not to discount the information within the report, as it does draw a useful correlation between deprivation and recycling performance, which is echoed within the WRAP work. The WYG report indicates that the amount of material collected for recycling decreases as deprivation increases and that those who collect material co-mingled with glass have significantly higher dry recycling yields than those co-mingling without glass. The report also observes that authorities that collect fully co-mingled materials including glass tend to outperform those collecting materials separately across the range of deprivation; however, once again this analysis does not take into account other important factors which contribute to dry recycling yields. The impact of the reporting of contamination and rejected material plays a significant role in comparative scheme performance in terms of recycling rate. This is a complex area which should take into account input and output contamination alongside secondary process losses, to ensure that all authorities account for their recycling performance in the same way. As discussed in Section 3.3, emerging evidence from reporting under the MRF Regulations61 suggests possible under-reporting of MRF rejects within current WasteDataFlow returns. This data relates to sampling and measurement of input contamination from MRFs, with many declaring higher rates of input contamination than the reject rates reported by their local authority users. Whilst it is technically possible for a MRF to have higher input contamination than its reject rate,

60

White Young Green (2013) Review of Kerbside Recycling Collection Schemes in the UK in 2011/12, Report for Biffa; Kier; Plastics Europe; Serco, 2013, http://www.wyg.com/recyclingreview/Kerbside_Recycling_Report_2011-12.pdf 61 England and Wales (2014) The Environmental Permitting (England and Wales) (Amendment) (England) Regulations 2014, 2852

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given that rejected material generally includes some miss-sorted target material one would expect input contamination to be lower than the reject rate. The impact of this will not be clear until further reporting has been undertaken under the regulations, but there does seem to be a risk that improved accounting for input contamination in MRF material will result in reduced recycling rates for some Welsh authorities against the stringent Welsh Government definitions of recycling.

In support of the overall conclusion that dry recycling collection system choice is non-significant in driving recycling performance, the evidence base in this area also includes a significant number of options modelling reports. All of those examined assume similar recycling performance between Collections Blueprint options and other high performing options. In all cases, the assumptions made within these reports were reviewed to ensure that predicted waste flows were clear and where possible based on performance benchmarking of other statistically similar authorities.

3.5 Supporting a Circular Economy in Wales

Although a universally accepted definition of the circular economy concept is yet to be established, for the purposes of this project we have defined it as the objective of ‘keeping products, components and materials at their highest utility and value’.62 Achieving a circular economy in Wales includes utilising as much as possible of the recyclate collected in Wales within reprocessing and manufacturing operations in Wales63. Research gathered by WRAP in providing its support to the development of the Welsh Government’s Collections, Infrastructure and Markets Sector Plan64 identified that ‘some of the reprocessors working at the high quality end have reported their difficulties in obtaining high quality recyclate feedstock from Wales’. Thus securing a greater quantity of high quality recyclate will see Wales move towards a more circular economy.

As discussed in Section 3.2and 3.3, the evidence concludes that the Collections Blueprint is still the best option in terms of ability to deliver high quality materials to reprocessors for high value, closed-loop recycling. In the context of collection system choice, material quality is likely to be the key factor in maximising utility and value of materials. When specifically considering the drive for a circular economy in Wales, again the role of the collection system is in providing the highest quality of material possible and the Collections Blueprint seems the most likely approach to achieve this. Clearly, a circular economy in Wales will also depend crucially on the development of viable reprocessing infrastructure, and this seems likely to be best supported by maximising material quality.

62

Ellen MacArthur Foundation Circular Economy - Ellen MacArthur Foundation, accessed 14 December 2015, http://www.ellenmacarthurfoundation.org/circular-economy 63

Speech and presentation by Dr Andy Rees, Welsh Government at the WRAP Cymru 2015 conference - http://www.wrapcymru.org.uk/sites/files/wrap/WRAP%20CYMRU%20CONFERENCE%20-%20Oct%202015%20-%20Andy%20Rees.docx and http://www.wrapcymru.org.uk/sites/files/wrap/Dr%20Andy%20Rees%20presentation.pdf 64

http://gov.wales/docs/desh/publications/120713wastecimsectorplanen.pdf

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3.6 Resilience in Terms of Recyclate Markets

None of the evidence sources considered within the project include a post hoc analysis of whether the recyclable materials from particular collection systems are more or less resilient to market downturn. Indeed, this is a subject which suffers from a relative lack of research. However, during the periods of market downturn, many anecdotal examples of the challenges of marketing lower quality material can be found in the trade press, with some making the direct comparison of higher quality recyclates associated with kerbside sort systems.65 From the evidence presented in Sections 3.2 and 3.3, we can conclude that the Collections Blueprint represents the best opportunity for local authorities to produce high quality recycling outputs.

High quality materials are generally more versatile, in that they can be used for a wider range of applications and be acceptable in a wider range of markets (e.g. closed and open-loop, export and domestic). The market size for high quality materials is therefore larger and likely to be more resilient during times of market over-supply. Conversely, lower grade or more contaminated materials, whilst often relatively easy to sell in times of high market demand relative to supply, become more difficult to sell during a downturn. This occurs as a result of the market shifting from an under-supplied one where reprocessors are competing with one another for material to an over-supplied one where those with material to sell are competing to attract deals from reprocessors.

3.7 The Least Reputational Risk to Local Authorities and the Welsh Government

The issue of reputational risk was not directly addressed in any of the evidence sources available to this project and this is clearly a difficult area for objective measurement. However, as with several of the other Collections Blueprint objectives, quality of material is relevant in considering relative performance of different collection systems. In particular, collecting high quality material is clearly a good approach to minimising reputational risks relating to the fate of materials collected for recycling.

A particularly important risk is in respect of compliance with the separate collection requirements of Article 11 of the EU Waste Framework Directive (WFD), as already discussed in Section 3.2. Article 11 of the WFD, which has been transposed into the Waste (England and Wales) Regulations 2011 (as amended), requires the separate collection of paper, plastic, metal and glass. The Collections Blueprint stipulates that recyclables should be separated at the kerbside and is therefore compliant with the requirement of regulations for separate collection. As such, it poses no risk of legal challenge to authorities and can reasonably be considered to be the best means of compliance and the least reputational risk to both local authorities and the Welsh Government.

65

Resource (2009) Spoilt for Choice

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Another key risk is that of material that was collected for recycling being landfilled or incinerated due to the lack of availability of a recycling market. There is considerable media interest in this issue, as well as in the issue of material being exported for recycling in emerging or developing economies, and being rejected by the recipient country authorities because of high levels of contamination. Both of these risks are minimised when higher-quality material is collected, as such material is more likely to be acceptable for reprocessing within in the UK in closed-loop, higher value-added end uses.

Perhaps the area of greatest concern in terms of reputational risk for authorities not currently following the Collections Blueprint collection method for dry recyclables relates to the process of service change. Authorities are likely to be concerned about the impact of change in containment method (e.g. a move from sacks to boxes) or in pre-sorting requirements that need to be communicated to residents. While no evidence on this issue was available to this project, recent experience of Welsh authorities in adopting the Collections Blueprint has ranged from examples where roll-out and adoption of the new service by residents has been relatively straightforward (e.g. Merthyr Tydfil) to those where the service change has triggered considerable opposition from some residents (e.g. Blaenau Gwent). These near-neighbouring authorities share many similarities in terms of housing types and socio-demographics and so research into the reasons for the apparently different reaction of the public may well help to inform approaches to future service changes.

Finally, another known area of concern expressed by authorities not currently operating the kerbside sort element of the Collections Blueprint relates to workforce health and safety. It is clearly the case that different collection systems expose collection operatives to different risks and varying numbers of exposures to similar risks. For example, the use of kerbside collection boxes exposes operatives to a different type and number of manual handling-related muscular-skeletal injury risk exposures than a sack or wheeled bin based collection.66 The same goes for risks associated with exposure to noise associated with loading material (especially glass),67 working around the collection vehicle (in particular at the rear of the vehicle) and in sorting, bulking and baling materials either at a depot or MRF. The comparative literature (most of which is from 2011 or before) on these issues has been studied extensively and has been reviewed in the course of this project and reveals little in terms of overall comparative performance of collection systems. The key reasons for this are that the data available is actually surprisingly poor and difficult to associate with different collection or sorting systems and that some key elements of some of the options (e.g. MRF accident rates) have as yet

66

Eunomia Research & Consulting, Resource Futures, and HCW Consultants (2011) Kerbside Collections Options: Wales, Report for WRAP, January 2011, ⬚http://www.wrapcymru.org.uk/kerbside_collection.html⬚ 67 Health and Safety Executive (2013) Reducing noise risks from ‘kerbside’ glass collection, June 2013, www.hse.gov.uk/pubns/waste16.pdf

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not been studied. What can be concluded from the evidence is that health and safety performance varies considerable within systems and that a very high degree of risk elimination and mitigation can be achieved through detailed service design, risk assessment and implementation and management of safe working systems, whatever the collection system adopted. Within the evidence reviewed there was no evidence from the Health and Safety Executive (HSE) or other professional bodies which specifically addressed the issue of one kerbside collection option being more or less safe than another.

3.8 High Levels of Public Satisfaction with the Service

The evidence reviewed is inconclusive in determining whether the Collections Blueprint achieves higher or lower levels of public satisfaction with the service, particularly regarding the dry recycling element of the service design.

There were a number of pieces of evidence submitted that examined the satisfaction of residents with their waste and recycling collection services including individual authority information from Caerphilly and Powys and also the results of the National Survey for Wales 2014-2015.68 From the National Survey for Wales we can see an overall satisfaction level with the waste collection service provided, which ranges from 69% satisfaction in Torfaen to 88% in Caerphilly. The survey analyses overall satisfaction with services and as such they do not specifically address the issue of collection scheme design. Satisfaction with a service is driven by a number of factors of which service design is one, alongside issues such as perceived service reliability and quality of delivery amongst others. However, it should be noted that eight of the top ten authorities for resident satisfaction operate a co-mingled recycling collection service.

In addition to the National Survey for Wales, additional evidence was supplied by Powys as part of their consultation on three weekly residual waste collection service. Through this consultation process, Powys specifically asked residents about the recycling collection service and 87% of households found it very or fairly easy to recycle using the Blueprint-compliant boxes provided for paper, plastics, glass and food waste.69

It is clearly difficult to draw conclusions from general customer satisfaction surveys regarding specific questions on collection system design. There is a perception within parts of the waste collection industry that simpler collection systems requiring less effort to separate materials on the part of householders are inherently more popular, but this contention has never been properly studied. Although it is also widely accepted that, whatever the current collection system, residents on the whole don’t like change, there have been examples of very successful service changes from kerbside sort to co-mingled

68

Wales National Statistics Office (2015), National Survey for Wales: Headline results, April 2014 – March 2015 (Revised), Report for Welsh Government, September 2015 69

Powys CC (2015) Powys Three Wekly Refuse Collections Key Findings From the Consultation Exercise, accessed 23 December 2015, http://pstatic.powys.gov.uk/fileadmin/Docs/Consultations/3Weekly-waste-Key_findings_for_website_en.pdf

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and vice versa, as well as examples of both that have met with considerable resistance. Without well prepared ‘before and after’ research into actual service changes, it is impossible to draw any meaningful conclusion on relative satisfaction with recycling service designs.

3.9 The Goals of the Well-being of Future Generations (Wales) Act 2015

When seeking to ascertain whether the evidence considered supports or refutes the contention that the Collections Blueprint provides the best opportunity to meet the goals set in the Well-Being of Future Generations (Wales) Act 2015 (‘the Act’), it is important to note that none of the evidence reviewed addresses the Act or associated well-being goals or proposed indicators directly. The lack of direct evidence can be attributed to two main causes. Firstly, much of the evidence submitted is operational in nature and therefore does not consider the wider impact of the service provided. Secondly, many of the pieces of evidence submitted pre-date the enactment of the legislation, or even its publication as a Bill.

Taking consideration of the above, it is possible to draw on the wider evidence base and apply the findings from this to the achievement of the well-being goals. In doing this, we can conclude that the Collections Blueprint has the potential to provide the best means of meeting the goals of the Act relative to other potential service configurations.

The evidence supports the view that the Collections Blueprint should best encourage the achievement of a Prosperous Wales through the development of ‘a low carbon society which recognises the limits of the global environment and therefore uses resources efficiently and productively’, and also a Globally Responsible Wales by ensuring that any changes made ‘improve the environmental well-being of Wales and make a positive contribution to global well-being’. Evidence analysed as part of the project, which includes ‘A Sustainability appraisal of service change options for Cardiff Council’70 indicates that when compared with other collections options, the Collections Blueprint had the lowest overall environmental impact and provides the greatest climate change benefits. Within this evidence, the recycling of materials made the greatest contribution to the reduced environmental impact of the service, followed by secondary transport, organic treatment and primary transport. This evidence also demonstrates the importance of the recycling of materials collected through more resource efficient closed-loop systems. In support of this position, independent work carried out by ADAS for the London Borough of Camden concludes that for the Borough, the overall effect of using a MRF to sort dry recyclables in a co-mingled solution, increases the carbon footprint from 68% within kerbside sort service with local transfer station to 177% after the MRF operations and delivery as far as the M25.71 Additional work is being carried out

70

Ricardo-AEA (2015) Sustainability appraisal of service change options for Cardiff Council, Report for WRAP, January 2015 71

ADAS (2008) Energy Audit of the Kerbside Recycling Services: The London Borough of Camden, 2008

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by Eunomia to provide evidence relating to the carbon impacts of different collection services across the UK to address the lack of evidence in this area.

In general, the evidence base regarding employment and job creation is weak and it is not covered in detail within much of the evidence base. As a result, the evidence is largely inconclusive in this area with regards to the Collections Blueprint or any other collections systems supporting the development of additional employment within Wales. Although there is little evidence in this area, it could be argued that when considering the wider employment opportunities associated with waste and recycling services (and not just those linked to the direct operation of frontlines collections), if more high quality material were to be generated from Welsh authorities, more of this could be collected, transported and reprocessed within the UK and Wales. This could therefore increase the wider employment opportunities associated with the Collections Blueprint. However, although this is a logical contention, there is a lack of evidence regarding the size of any benefit that might actually be attributable to relative material quality and additional research would have to be carried out in this area to understand the potential comparative impact of this.

A recent report from Green Alliance and WRAP stated that a move towards a circular economy could have benefits for the labour market in Wales. The study suggested that a more extensive expansion of circular economy activities in Wales as described in a “transformational scenario” could create around 30,000 jobs (gross), with lasting reductions in unemployment of around 5,500.72 The report references a WRAP Cymru project Accelerating Reprocessing Infrastructure Development (ARID) which had helped businesses to create 178 new jobs by October 2014 through the development of reprocessing and collections infrastructure in Wales’ Convergence Area. 73

72

WRAP (2015) Employment and the circular economy summary. Job creation in a more resource efficient Britain. 73

WRAP Cymru (2015) ARID (Accelerating Reprocessing Infrastructure Development) External Programme Evaluation: Summary Report, 2015, http://www.wrapcymru.org.uk/sites/files/wrap/WRAP%20Cymru%20ARID%20Event%20Summary%20Report_e4.pdf

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4.0 Conclusions

Within the limitations inherent in a review restricted to considering secondary literature sources, very few of which were produced directly to study the relative performance of the Collections Blueprint, it is possible to draw a number of conclusions in support of the Collections Blueprint:

There is strong evidence to support policies focussing on the restriction of residual waste capacity in line with the Collections Blueprint, both in terms of impact on improving recycling performance and on reducing cost.

In addition, there is emerging evidence that strongly indicates that further restriction of residual waste capacity (e.g. through a move to three-weekly or four-weekly collection) would result in further improvement in terms of recycling performance (in particular for food waste) and in cost reduction.

The evidence on collection system cost (both from actual cost data from Welsh authorities and from comparative cost modelling projects) indicates that the Collections Blueprint represents a lower cost option overall than alternative collection systems.

The evidence on recycling performance suggests that choice of dry recycling collection regime (e.g. kerbside sort, co-mingled), when combined with the Collections Blueprint’s recommended restricted residual waste capacity, is not a material consideration in predicting recycling performance. In other words, the Collections Blueprint would be expected to perform similarly in terms of recycling rate to other dry recycling collection systems that also employ restricted residual waste capacity in line with the Collections Blueprint.

On material quality, the evidence supports the view that the separate collection system in the Collections Blueprint results in higher quality, less contaminated material. This in turn results in a higher likelihood of material being appropriate for higher value-added closed-loop uses in the UK and Europe, resulting in greater climate change mitigation benefits and better overall greenhouse gas emissions performance for the Collections Blueprint versus alternative systems.

Higher quality material that is more likely to be produced by the Collections Blueprint collection system is also likely to support the retention of material within the Welsh and UK economies resulting in; economic and social benefits and supporting the objectives of the Well-Being of Future Generations (Wales) Act 2015; improved resilience to materials market downturns; and a reduction in reputational risk associated with the fate of materials collected for recycling. However, there is a lack of direct evidence to support the relationship between material quality and these benefits and although these are logical conclusions, further research would be required to establish the magnitude of these benefits.

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The evidence is stronger in relation to recycling performance, cost and material quality (issues that have been studied directly in many of the evidence sources considered) and weaker in areas more related to social and wider economic benefits, which have been considered in fewer studies and are in any event more challenging to research. In several areas that are of considerable interest to local authorities (such as recycling performance and health and safety), it is more a case of there being no evidence that one system performs better than another, rather than there being strong evidence in favour of or against the Collections Blueprint.

In relation to performance against the aims of the Well-Being of Future Generations (Wales) Act 2015, it is clearly too early for a direct evidence base to have developed, but it is likely that as local authorities increasingly consider their decisions taking account of these aims, the evidence base will improve.

Material quality is clearly a key area of differentiation between the Collections Blueprint and many other dry recycling collection systems. The environmental benefits of closed-loop recycling are clear, but the evidence in support of the wider economic and social benefits associated with this is weak, despite the logic of the arguments in favour of maximising material quality.

The context of this project is the starting point that the Welsh Government wants to provide clear guidance to Welsh local authorities on collection services. The overarching objective of this study has therefore been to consider whether the Collections Blueprint still provides the best blueprint for Welsh local authorities to follow, rather than to consider the merits or otherwise of having a single blueprint in the first place. Given that starting point, the Collections Blueprint does still appear to offer clear benefits in terms of cost and material quality, whilst offering no relative overall disadvantages in terms of recycling performance and health and safety (and clear advantages regarding residual waste volume restriction and food waste collection). The evidence surrounding the wider social and economic performance of different collection systems is weak, but it is reasonable to conclude that the improved material quality associated with separate collection is beneficial, even if quantifying this in any satisfactory way is not currently possible. As such, although more primary research would clearly improve the evidence base, it is reasonable to conclude that the Collections Blueprint does provide a good basis for a waste collection standard for Wales. The evidence considered suggests some improvements that could be made to the current Collections Blueprint, most importantly regarding the evidence on ‘less than fortnightly’ collection of residual waste.

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Appendix

A.1.0 Hypothesis Questions

The hypothesis questions used to assess the evidence are listed in Table A.1.1, separated into the relevant sections and policy areas.

Table A.1.1: Table of Hypothesis questions.

Policy area Number Hypothesis

Waste Performance (including commercial waste)

Fortnightly refuse in 140l wheeled bins

1 The reduction of refuse frequency to fortnightly and containment volumes to 140 litres increases dry recycling captures from the baseline position.

2 The reduction of refuse frequency to fortnightly and containment volumes to 140 litres increases food waste captures from the baseline position.

3 The reduction of refuse frequency to fortnightly and containment volumes to 140 litres reduces overall waste arisings from the baseline position.

Less than fortnightly refuse/ reduced containment

4

The reduction of refuse frequency to less than fortnightly and containment volumes to less than 70 litres containment per household per week has a greater increase in dry recycling capture than a fortnightly 140 litre refuse collection.

5

The reduction of refuse frequency to less than fortnightly and containment volumes to less than 70 litres containment per household per week has a greater increase in food waste capture than a fortnightly 140 litre refuse collection.

6

The reduction of refuse frequency to less than fortnightly and containment volumes to less than 70 litres containment per household per week has greater reduction in overall waste arisings than a fortnightly 140 litre refuse collection.

Garden Waste

7 Chargeable garden waste reduces the amount of waste to landfill when compared to no garden waste.

8 Chargeable garden waste captures a lower amount of garden waste when compared to a free year-round service.

9 Chargeable garden waste captures a lower amount of garden waste when compared to a free service suspended in winter months.

Food Waste 10 Weekly separate food waste collections result in higher food waste yields than lower frequency or non-caddy collection systems.

Weekly Dry Recycling

11 Weekly recycling collections for dry recycling capture more target materials than fortnightly collections.

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Policy area Number Hypothesis

Recycling Collection Methodology

12

Weekly collections of dry recycling from two or more boxes is likely to capture at least similar amounts of target materials as other dry recycling collection methods when paired with fortnightly residual collections of 140 litres or less.

13

Weekly collection of dry recycling from two or more boxes is likely to capture at least the same contribution to recycling rate (as measured in Wales) when paired with fortnightly residual collections of 140 litres or less.

14 The collection of dry recycling from two or more boxes demonstrated a better contamination rate than other collection methodologies.

Other Services

15 The inclusion of other services such as bring site collections or on-the-go recycling increased recycling performance.

Cost of Service (including commercial waste)

Fortnightly Refuse in 140l wheeled bins

16 The reduction of refuse frequency to fortnightly and containment volumes to 140 litres offers the lowest collection cost option for residual waste collections.

17 The reduction of refuse frequency to fortnightly and containment volumes to 140 litres offers the lowest disposal cost option for residual waste collections.

18 The reduction of refuse frequency to fortnightly and containment volumes to 140 litres offers the lowest overall cost option for residual waste collections.

Less than fortnightly refuse/ reduced containment

19

The reduction of refuse frequency to less than fortnightly and containment volumes to less than 70 litres containment per household per week offers the lowest collection cost option for residual waste collections.

20 The reduction of refuse frequency to less than fortnightly and containment volumes to less than 70 litres offers the lowest disposal cost option for residual waste collections.

21

The reduction of refuse frequency to less than fortnightly and containment volumes to less than 70 litres containment per household per week offers the lowest overall cost option for residual waste collections.

Garden Waste

22 Chargeable garden waste has a lower cost (netting off income) when compared to no garden waste.

23 Chargeable garden waste has a lower cost (netting off income) when compared to a free year-round service.

24 Chargeable garden waste has a lower cost (netting off income) when compared to a free service suspended in winter months.

Food Waste 25 Weekly food waste collections present a lower cost than other lower or non-caddy collection systems.

Recycling Collection Methodology

26 Weekly collection of dry recycling from two or more boxes with fortnightly residual collections of 140 litres or less, presents a lower collection cost than other collections options explored.

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Policy area Number Hypothesis

27 Weekly collection of dry recycling from two or more boxes with fortnightly residual collections of 140 litres or less, presents a lower overall cost than other collections options explored.

28 Weekly collection of dry recycling using RRV vehicles presents a lower overall cost than when exploring the same option using a different vehicle.

Other Services

29 The development of other services such as bring site collections or on-the-go recycling where not described as cost prohibitive.

Social Issues

Resident Satisfaction

30 Residents express that they would be equally or more satisfied with a collection service which reflects the Collections Blueprint.

Health and Safety

31

The post-mitigation health and safety risks of operating the collections methodology described with the Collections Blueprint are materially similar or lower than other collections methodologies.

Job Creation 32

The number of people employed in the operation of collection services which reflect those described within the Collections Blueprint is higher than for other kerbside collection services analysed.

Skills and Training

33 The services which reflect those similar to the Collections Blueprint clearly demonstrate opportunities for Welsh people to gain skills and receive training.

Quality of Material

34 The quality of material collected with collection services which reflect those described within the Collections Blueprint is higher than for other kerbside collection services analysed.

Carbon Impact

35 The overall carbon impact of services which reflect those described within the Collections Blueprint is greater than for other kerbside collection services analysed.

A.2.0 Evidence

The sources of evidence which were reviewed are included in Table A.2.1.

Table A.2.1: Table of Evidence.

Author Title

4R Environmental Ltd Procurement outcomes for waste collection systems in the UK market

ADAS Energy Audit of Kerbside Services LB Camden

Caerphilly CBC Collections from a Local Authority perspective (Caerphilly)

Caerphilly CBC Local Environmental Quality- Public Services Survey 2007

Caerphilly CBC Public consultation of waste, cleansing and parks services 2013

Caerphilly CBC Public services consultation survey 2011

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Author Title

Caerphilly CBC Positive result for Caerphilly

Cardiff Council Recycling Waste Management Strategy 2015 - The City of Cardiff Council

CHERE A Health and Safety Study of kerbside recycling schemes using boxes and bags

Conwy CBC Environmental & Technical Services

Recycling Collection Service Design Risk Assessment

Denbighshire Blueprint Review Document

Enviros Consulting Measure to Report the Final Destination of Recyclate Sent Outside the European Community and European Free trade Area

Eunomia Recycling Carbon Index- England, Wales & Northern Ireland Local Authorities 2011/12

Eunomia Recycling Carbon Index- England, Wales & Northern Ireland Local Authorities 2013/14

Eunomia Gravesham Collection Options Appraisal

Eunomia Phase1_Bulking Station Analysis

Eunomia Calderdale Collection Options

Eunomia LB Havering Options Appraisal

Eunomia Mid-Devon Efficiency Project

Eunomia The Cost to Welsh Businesses of a Requirement to Sort Commercial, Industrial, Construction and Demolition Waste

Eunomia An Operational Review of Lampeter HWRC

Eunomia Identifying Potential Efficiency and Saving Options for Waste Services at Walsall Council

Eunomia Recycling Carbon Index Tool

Eunomia Somerset Waste Partnership – Options Part 1

Green Alliance Resource resilient UK A report from the Circular Economy Task Force

Green Alliance Wasted opportunities: Smarter systems for resource recovery A report from the Circular Economy Task Force

Haringey Council Recycling review comparison of source separated and co-mingled collection methods in Haringey

(HSE) Reducing noise risks from ‘kerbside’ glass collection

HSE Safe transport in the waste and recycling industry

HSE Safe waste and recycling collection services

HSE The safe use of refuse collection vehicle hoists and bins

HSE Waste and recycling vehicles in street collection

HSE HSE Inspection Intervention - Waste Management and Recycling

Health and Safety Laboratory

Manual handling in refuse collection

Hyder Consulting Caerphilly CBC Doorstepping Event for 75,000 Properties

Hyder Consulting Monmouthshire County Council Participation and Capture Monitoring Study (Consultation with Residents)

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Author Title

Hyder Consulting Monmouthshire County Council Participation and Capture Monitoring Study

Hyder Consulting Monmouthshire County Council Participation and Capture Monitoring Study (Waste Composition Analysis)

M·E·L Research Neath & Port Talbot Kerbside Residual Waste Composition Analysis

M·E·L Research Support to Monmouthshire County Council (Effects of the service change)

M·E·L Research Pembrokeshire County Council - Waste and Recycling Education Campaign

Monmouthshire CC Monmouthshire County Council Consultation Response

Monmouthshire CC Green Waste Charging- MTFP Proposal

Monmouthshire CC Recycling Review (Monmouthshire CC)

Monmouthshire CC Recycling and Waste Changes- Policy Approval

Monmouthshire CC Recycling and Waste Service Resident and Business Survey

National Statistics National Survey for Wales: Headline Results, April 2014-March 2015 (Revised)

Natural Resources Wales

Report on the Landfill Allowances Scheme (LAS) Wales 2014/15

Natural Resources Wales

Survey of Industrial & Commercial Waste generated in Wales 2012

Navigant Consulting Waste Collection Services Review

Neath Port Talbot Blueprint Review Document

Pembrokeshire CC Pembrokeshire Citizens’ Panel – survey 29

Philip Wells Evaluation of Conwy CBC Pilot Kerbside Collection Containment system

The Pioneer Trollibocses are ready for rolling out

Powys County Council Waste Strategy

Powys County Council Waste Strategy 2014/2015

Resource Futures Analysis of kerbside dry recycling performance in the UK 2008/09

Resource Futures Waste Compositional Analysis (Pembrokeshire County Council)

Resource Recycling Single Stream Uncovered

Romaquip Romaquip Vehicles Technical specification

RPS Planning and Development

Survey of Funding of Municipal Waste Management Kerbside Collection in Wales Summary Report

SKM Enviros Evaluation of Newtownabbey Borough Council 'Wheelie Box" pilot

SKM Enviros Dry Recycling End Destinations a Report for Local Authorities in Wales

South Wales Arugus Council scores top marks in national survey

Swansea Council Collection Performance Review City and County of Swansea (Briefing note)

Unknown Results Summary (Ceredigion)

Unknown Recycling in Wales

The Washington Post American recycling is stalling, and the big blue bin is one reason why

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Author Title

Torfaen CBC Reducing residual waste capacity

Wales Audit Office Public Participation in Waste Recycling

Caerphilly CBC Kerbside collection of recyclables - update on recycling market issues (Caerphilly)

WastesWork Ltd, AEA Composition analysis of the separate food and garden waste kerbside collections in Caerphilly

WastesWork Ltd, AEA Composition analysis of the separate food and garden waste kerbside collections in Caerphilly – Summer period

Welsh Government Statutory Guidance on the Separate Collection of Waste Paper, Metal, Plastic and Glass

Welsh Government Environment and sustainability committee: inquiry on recycling in wales: the Welsh Government’s evidence. Annex 1: evidence used to develop, update and test the collections blueprint

Welsh Government Environment and sustainability committee: inquiry on recycling in wales: the Welsh Government’s evidence.

Welsh Government (National Statistics)

Local authority municipal waste management report for Wales, 2014-15

Welsh Government National Survey for Wales April 2014 - March 2015 Recycling Satisfaction stats

WLGA Waste Finance Data Report 2008-09

WLGA Waste Finance Data Report 2009-10

WLGA Waste Finance Data Report 2010-11

WLGA Waste Finance Data Report 2011-12

WLGA Waste Finance Data Report 2012-13

WLGA Waste Finance Data Report 2013-14

WLGA Waste management benchmarking – Working paper. Analysis of kerbside dry recycling service costs

WLGA Waste management benchmarking – Working paper. Analysis of Food Waste service costs

WRAP Cardiff Council KAT Modelling Summary Report

WRAP Assessing the suitability of post-consumer glass in container applications

WRAP (MEL) Evaluation of Conwy CBC Pilot Kerbside Collection Containment System

WRAP Assessment and recommendations on Conwy CBC’s kerbside recycling operations.

WRAP Recycling on The Go: Bargoed, Newbridge and Risca Train Stations, Caerphilly

WRAP Bron Afon Recycle on the Go Case Study

WRAP Conwy Feast Recycle on the Go Case study

WRAP Commercial Recycling Collections Guide

WRAP Commercial Food Waste Collections Guide

WRAP Household Waste and Recycling Centre (HWRC) Guide

WRAP HWRC Assessment of Performance

WRAP Subscription Based Garden Waste Collection Services

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Author Title

WRAP The Composition of Solid Waste in Wales

WRAP Analysis of recycling performance and waste arisings in the UK 2012/13

WRAP Collection Options Modelling for Wrexham CBC

WRAP Resource Recovery Vehicle (RRV Scoping Study)

WRAP CONFIDENTIAL Materials Tracking Report

WRAP Evaluation of Castlereagh Borough Council ‘Wheelie Box’ Pilot Kerbside Collection System

WRAP (AMEC) Assumptions Report (Ceredigion)

WRAP (Environmental Resources Management Ltd)

Kerbside Recycling in Wales: Environmental Costs

WRAP (Eunomia) Isle of Anglesey County Council Collection Options Appraisal

WRAP (Eunomia) Strategic Self-assessment Report (Blaenau Gwent)

WRAP (Eunomia) Blaenau Gwent CBC Business Plan: Supporting Technical Report

WRAP (Eunomia) Blaenau Gwent CBC Business Plan: Technical Appendix – Modelling Assumptions

WRAP (Eunomia) Implementing the Welsh Government Collections Blueprint

WRAP (Eunomia) Strategic Self-Assessment Report (Merthyr Tydfil)

WRAP (Eunomia) Merthyr Tydfil CBC Business Plan: Supporting Technical Report

WRAP (Eunomia) Kerbside recycling in Wales – Indicative Financial Costs

WRAP (Eunomia) Kerbside recycling in Wales – Summary report

WRAP (Eunomia, Resource Futures and HCW consultants)

Kerbside Collections Options: Wales

WRAP (LRS Consultancy Ltd)

Support to Monmouthshire County Council (Transfer station review)

WRAP (M·E·L Research and WYG)

Support to Monmouthshire County Council (Compositional analysis)

WRAP (Resource Futures)

MRF Output Material Quality Thresholds

WRAP (Ricardo-AEA) Sustainability appraisal of service change options for Cardiff Council

WRAP (SKM Enviros) Recycling performance and options review for Gwynedd Council

WRAP (SKM Enviros) Support to Torfaen CBC (Collections Modelling)

WRAP (WastesWork and AEA)

The composition of municipal solid waste in Caerphilly

WYG Group Review of Kerbside Recycling Collection Schemes in the UK in 2011/12

WYG Group Review of Kerbside Recycling Collection Schemes Operated by Local Authorities

WYG Group Review of Kerbside Recycling Collection Schemes in the UK in 2010/11

Zero Waste Scotland Contamination in source-separated municipal and business recyclate in the UK 2013

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Author Title

Zero Waste Scotland Commentary report: The potential health impacts of extending the frequency of non-recyclable waste collections

A.3.0 Summary of Hypothesis Scores

A summary of the scores given to each hypothesis question is included in Table A.3.1. It shows how many times a hypothesis was given a particular score.

Table A.3.1: Table Summarising the Number of Instances of Each Score for the Hypothesis Questions.

Counts

Question 0 1 2 3 4 5

Fortnightly refuse in 140l wheeled bins

1) The reduction of refuse frequency to fortnightly and containment volumes to 140 litres increases dry recycling captures from the baseline position.

101 0 0 6 14 2

2) The reduction of refuse frequency to fortnightly and containment volumes to 140 litres increases food waste captures from the baseline position.

109 0 0 5 8 1

3) The reduction of refuse frequency to fortnightly and containment volumes to 140 litres reduces overall waste arisings from the baseline position.

108 0 1 6 7 1

Less than fortnightly refuse

4) The reduction of refuse frequency to less than fortnightly and containment volumes to less than 70 litres containment per household per week has a greater increase in dry recycling capture than a fortnightly 140 litre refuse collection.

115 0 0 3 5 0

5) The reduction of refuse frequency to less than fortnightly and containment volumes to less than 70 litres containment per household per week has a greater increase in food waste capture than a fortnightly 140 litre refuse collection.

117 0 1 1 4 0

6) The reduction of refuse frequency to less than fortnightly and containment volumes to less than 70 litres containment per household per week has greater reduction in overall waste arisings than a fortnightly 140 litre refuse collection.

116 0 2 2 3 0

Garden Waste

7) Chargeable garden waste reduces the amount of waste to landfill when compared to no garden waste.

118 1 2 1 1 0

8) Chargeable garden waste captures a lower amount of garden waste when compared to a free year-round service.

113 0 0 3 6 1

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Counts

Question 0 1 2 3 4 5 9) Chargeable garden waste captures a lower amount of garden waste when compared to a free service suspended in winter months.

122 0 0 1 0 0

Food Waste

10) Weekly separate food waste collections result in higher food waste yields than lower frequency or non-caddy collection systems.

112 0 0 5 5 1

Weekly Dry Recycling

11) Weekly recycling collections for dry recycling capture more target materials than fortnightly collections.

112 0 1 6 3 1

Recycling Collection Methodology

12) Weekly collections of dry recycling from two or more boxes is likely to capture at least similar amounts of target materials as other dry recycling collection methods when paired with fortnightly residual collections of 140 litres or less.

104 0 1 11 7 0

13) Weekly collection of dry recycling from two or more boxes is likely to capture at least the same contribution to recycling rate (as measured in Wales) when paired with fortnightly residual collections of 140 litres or less.

105 0 1 8 9 0

14) The collection of dry recycling from two or more boxes demonstrated a better contamination rate than other collection methodologies.

110 0 0 2 10 1

Other Services

15) The inclusion of other services such as bring site collections or on-the-go recycling increased recycling performance.

104 0 1 7 8 3

Fortnightly refuse in 140l wheeled bins

16) The reduction of refuse frequency to fortnightly and containment volumes to 140 litres offers the lowest collection cost option for residual waste collections.

109 0 2 8 4 0

17) The reduction of refuse frequency to fortnightly and containment volumes to 140 litres offers the lowest disposal cost option for residual waste collections.

109 0 1 6 7 0

18) The reduction of refuse frequency to fortnightly and containment volumes to 140 litres offers the lowest overall cost option for residual waste collections.

104 0 3 8 8 0

Less than fortnightly refuse

19) The reduction of refuse frequency to less than fortnightly and containment volumes to less than 70 litres containment per household per week offers the lowest collection cost option for residual waste collections.

113 0 0 5 5 0

20) The reduction of refuse frequency to less than fortnightly and containment volumes to less than 70

113 0 0 4 6 0

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Counts

Question 0 1 2 3 4 5

litres offers the lowest disposal cost option for residual waste collections.

21) The reduction of refuse frequency to less than fortnightly and containment volumes to less than 70 litres containment per household per week offers the lowest overall cost option for residual waste collections.

112 0 0 4 7 0

Garden Waste

22) Chargeable garden waste has a lower cost (netting off income) when compared to no garden waste.

120 0 2 1 0 0

23) Chargeable garden waste has a lower cost (netting off income) when compared to a free year-round service.

117 0 0 2 4 0

24) Chargeable garden waste has a lower cost (netting off income) when compared to a free service suspended in winter months.

123 0 0 0 0 0

Food Waste

25) Weekly food waste collections present a lower cost than other lower or non-caddy collection systems.

112 0 0 10 0 1

Recycling Collection Methodology

26) Weekly collection of dry recycling from two or more boxes with fortnightly residual collections of 140 litres or less, presents a lower collection cost than other collections options explored.

106 0 4 11 2 0

27) Weekly collection of dry recycling from two or more boxes with fortnightly residual collections of 140 litres or less, presents a lower overall cost than other collections options explored.

102 0 0 8 13 0

28) Weekly collection of dry recycling using RRV vehicles presents a lower overall cost than when exploring the same option using a different vehicle.

111 0 0 10 2 0

Other Services

29) The development of other services such as bring site collections or on-the-go recycling where not described as cost prohibitive.

117 0 0 3 2 1

Resident Satisfaction

30) Residents express that they would be equally or more satisfied with a collection service which reflects the Collections Blueprint.

108 0 1 11 3 0

Health and Safety

31) The post-mitigation health and safety risks of operating the collections methodology described with the Collections Blueprint are materially similar or lower than other collections methodologies.

109 0 0 9 4 1

Job Creation

32) The number of people employed in the operation of collection services which reflect those described within

113 0 1 7 2 0

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Counts

Question 0 1 2 3 4 5 the Collections Blueprint is higher than for other kerbside collection services analysed.

Skills and Training

33) The services which reflect those similar to the Collections Blueprint clearly demonstrate opportunities for Welsh people to gain skills and receive training.

123 0 0 0 0 0

Quality of Material

34) The quality of material collected with collection services which reflect those described within the Collections Blueprint is higher than for other kerbside collection services analysed.

113 0 0 5 5 0

Carbon Impact

35) The overall carbon impact of services which reflect those described within the Collections Blueprint is greater than for other kerbside collection services analysed.

116 0 0 3 4 0

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A.4.0 Peer Review – Summary of Findings

The Welsh Government commissioned Eunomia Research and Consulting (Eunomia) to review the Collections Blueprint document and its evidence base in light of any new evidence arising since 2011, with the aim of providing advice on the applicability of the current Collections Blueprint and any changes that could be made in light of new evidence.

Eunomia’s methodology included an option for a third party peer review of their methodology and evidence synthesis as part of the quality review process. Following discussions with the Welsh Government and the local authority representatives on the Technical Advisory Group, Naisbitt Resource Management was commissioned to carry out the third party peer review.

The peer review contained three main elements:

an assessment of the methodology and initial evidence gathering phase;

a quality check of a sample of detailed assessments and attendance at an internal challenge session; and

a review of the Summary Report.

A.4.1 Methodology and Initial Evidence Gathering

There has been no specific research to assess the Collections Blueprint as a whole since its publication. Therefore, the Eunomia methodology provides a logical and structured approach to the evidence gathering and review process by using an initial screening process to identify relevant evidence followed by a detailed evaluation. The methodology includes a number of review points to check the evidence being reviewed and to test the assumptions and conclusion being drawn in relation to the Collections Blueprint. The review points observed included internal quality checks carried out by the research lead, an internal director challenge session and also a meeting with the project Technical Advisory Group.

The initial evidence gathering phase identified a wide range of documents and reports to be assessed through the process. The review of the initial evidence identified highlighted a small number of additional documents that could be added to the process, which were subsequently included in the assessment. In addition, it was highlighted that consideration needed to be given to how older evidence (i.e. pre-2011) would be used in the process.

A.4.2 Quality Check of Detailed Assessments

A sample of twenty detailed evidence assessments were reviewed to check the quality of the assessments undertaken. The review highlighted a number of points for further consideration by Eunomia. These are detailed below:

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In some of the assessments, it was not clearly set out how the scores against the hypothesis statements were determined and the relevant sections of the evidence were not clearly cited to support the score awarded. This was reviewed and addressed by Eunomia, with more detailed justifications of allocated scores being developed and provided for review. These justifications were subsequently reviewed and found to validate the scores.

Some of the key documents reviewed were collections options appraisal studies, and whilst a number of the options appraisals reviewed provided logical rationales in the development of the assumptions, the evidence supporting the assumptions were not always clearly documented or available. This issue was raised with Eunomia and where assumptions were not clear this was documented and reflected within the assessment of the document. As part of the detailed review process, this issue of how collections options appraisal studies should be used to draw conclusions about the Collections Blueprint was discussed and it was agreed that they could be used as evidence within the review, however their use would need to be justified and issues surrounding the validity of assumptions discussed fully within the final report.

Some of the evidence collated was dated back to pre- 2011 and the publication of the original Collections Blueprint and would have formed part of the original evidence base. This would therefore need to be considered when drawing conclusions on the current evidence base. This was raised with Eunomia and Eunomia agreed to assess the evidence in line with the detailed evidence assessment criteria and take this factor into account when drawing conclusions.

A.4.3 Review of the Draft Summary Report

The draft summary report produced by Eunomia was reviewed and detailed comments were provided. As the summary report was designed to provide a strategic overview of the project outcomes, it did not provide a detailed account of the supporting evidence used to draw conclusions. Therefore the following recommendations were made for inclusion within the final report (and the summary report if deemed necessary):

The reader should be able to understand how the conclusions have been drawn and be able to consider the key pieces of evidence, for example why dry recycling costs alone have been used to evaluate overall value for money; therefore the key pieces of evidence use to support statements/conclusions should be justified and cited throughout the report.

Where counter-evidence is present this should be cited and if discounted then a clear justification should be given, again to allow the reader to understand how the conclusions have been drawn.

Where pre- 2011 evidence has been used to draw/support conclusions, this should be highlighted, again to help the readers understanding.

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Where collections options appraisal studies have been used to generate conclusions, these should be clearly noted and the reliance on these accounted for with the assessment of the evidence.

A.4.4 Conclusions

The key conclusions from the peer review are:

The project methodology developed and undertaken by Eunomia provided a logical and structured approach to the review of evidence and development of conclusions. The methodology takes into account the broad scope of the Collections Blueprint and the fact that there has been no specific research to assess the Collections Blueprint as a whole.

The detailed review of evidence as part of this project was assessed and the review of evidence has been carried out to the required standard.

The summary report developed by Eunomia provides a strategic overview of the project, with the detailed evidence supporting the conclusions being provided as part of the detailed technical report.