Delivering Scotland's Circular Economy - route map to 2025 and beyond: consultation analysis

3. Impact Assessments

This chapter provides an analysis of the five impact assessment questions. While the publication of the Route Map will not result in any direct impacts, the Scottish Government wishes to assess how a specific intervention may have an impact if introduced. The impact assessment questions cover equality, socio-economic considerations, island communities, business and regulation, and the environment.

For further information, review the initial impact assessments that were published by the Scottish Government alongside this consultation.

3.1 Impact Assessments

Q16. Please provide any further information or evidence that should be considered in the accompanying Equalities Impact Assessment

Of the 19 respondents who provided an answer to Q16, the most common theme was that no other information of evidence should be considered in the accompanying Equalities Impact Assessment.

The second most common theme considered regulations and secondary legislation on recycling and waste management and the effects they may have on certain groups of disabled people or the elderly who suffer from dementia. These respondents noted that not all people may be able to separate waste or recycle without assistance and consideration of this should be acknowledge in any regulations. CIWM Scotland noted concerns about increased costs associated with the proposals, specifically the reuse proposal, and Dundee City Council suggested that specific proposals related to charging individuals should be assessed independently to determine their impact on equalities.

A few respondents highlighted the impact of some of the proposals on rural communities in general, although do not speak more specifically to the effects on those with protected characteristics in those communities.

Q17. Please provide any further information or evidence that should be considered in the accompanying Fairer Scotland Assessment

There were 22 responses to Q17. Of those, the most common theme was a concern about the socio-economic impacts on low-income households.

“All measures must be 'affordable' to those on the lowest incomes. Some solutions may only be affordable to the wealthier such as reuse. It is important to avoid a two-stream programme which means only the wealthier can participate in achieving objectives.” – Foodservice Packaging Association

Two respondents mentioned the economic impact some proposals would have in rural communities, while two others suggested the same about densely populated urban centres. For example, the City of Edinburgh Council suggested adapting or shifting costs so those who do not benefit from certain proposals are not faced with the burden of paying for them, such as garden waste collection paid for by residents without access to a garden. Two respondents noted that increasing infrastructure investment, such as transport and community resources, could help to mitigate any financial burden caused by the proposals.

A few respondents noted that no further information or evidence should be considered, and two others recommended further assessments be done at the implementation of some of the proposals or for any secondary legislation put forward.

One respondent each highlighted the following areas for further consideration:

• Recommendations for regulations on fair rent based on earned wages relating to the housing and construction proposals.
• Regarding food surplus redistribution, particularly effective ways to direct it in-person food preparation and consumption activities or care settings, such as after school clubs, shared meals, rather than just to individual households.
• Finally, one individual noted support for the proposals as they will provide a need for high-skilled labour and reduce demand on imported commodities that hurt natural resources.

Q18. Please provide any further information or evidence that should be considered in the accompanying Island Communities Impact Assessment.

There were 14 responses provided to Q18. Support for no further information or evidence was the theme with the most responses and two respondents noted that the proposals would affect island communities but did not provide further information on how.

Two respondents, FareShare Scotland and Shetland Islands Council, noted that transport links and infrastructure necessary to implement aspects of the proposal - especially around food waste management and deposit return schemes - needed to be considered carefully as the proposals did not seem to currently account for hard-to-reach areas. Two individuals highlighted the need for further assistance with consumption goals, with one also suggesting a ‘responsible emissions solution to island communities for recycling and reuse’ although they did not give details as to what that would look like.

Q19. Please provide any further information or evidence that should be considered in the accompanying Business and Regulatory Impact Assessment.

The most common theme to emerge from the 21 responses to Q19 was for further considerations about the financial impact of the proposals on businesses. Respondents mentioned increased administrative costs for local authorities, particularly regarding waste management and in relation to forthcoming DRS (Deposit Return Scheme) and EPR (extended producer responsibility) regulations. CIWM Scotland asked for further assessments into these reforms as well as a capacity assessment ‘within Scotland to allow for circularity of materials’. NSS mentioned that the proposals may increase the financial burden on NHS boards, and the Scottish Wholesale Association recommended engagement with the food and drink wholesalers on the proposals as costs and burdens were likely to increase with the proposals set out in the route map.

‘We are supportive of these extra measures as long as they are applied consistently across the industry to ensure that those driving forward circular solutions are not disadvantaged with additional cost or process burdens.’ – Balfour Beatty

A few respondents highlighted concerns about legislation. Rio ESG Ltd. recommended aligning Scottish legislation with EU and UK regulations wherever possible, although they did not specifically say why. Supply Chain Sustainability School noted that legislation should not inhibit economic growth, and similarly an individual respondent recommended more assistance for business that may suffer and struggle under the new regulations. Another individual thought that legislation should be stronger with businesses recognising ‘the need for business to take responsibility for its actions, including those that do not enhance profits or externalise costs’. As with the other impact assessments, a small number noted that no further information or evidence should be considered.

3.2 Strategic Environmental Assessment (SEA)

Q20. Please provide any further information or evidence that should be considered with regards to the environmental impact of proposals outlined in the Route Map.

Across the 25 responses which provided an answer to Q20, the most common theme was suggestions for further information or evidence regarding waste management. Many of these respondents provided positive assessments of the consultation, and provided specific caveats related to waste. Two respondents supported the steps to improve the volumes and quality of material for recycling, and one of these suggested further regulations on the greatest waste producers.

“Throughout the documents there are laudable references to ensuring the more deprived sectors of our society are considered and provided with extra help. In addition to this, it is important, given the urgency of the issues being addressed, to give extra consideration to targeting those sectors of society which generate the most waste and use the most resources and energy per capita as these areas offer the greatest potential to make rapid progress.” – Lochaber Environmental Group

Aberdeenshire Council raised a concern that the Waste Framework Directive did not dictate that these collections should be kerbside, and Dundee City Council noted that there should be special consideration for dense urban centres.

“It is anticipated that all of the proposals and packages would have a positive effect on the environment through improving recycling by householders & businesses, minimising the impacts of disposal, embedding circular practises and promoting responsible consumption. Consideration should be given to high density urban areas where deprivation, poor quality housing stock, multi occupancy households and a lack of infrastructure impact the ability to provide quality recycling facilities and where participation is historically low.” – Dundee City Council

A small number of respondents suggested further consideration be given to supply chain issues. Again, these respondents were largely supportive of the packages presented, and expressed interest in further examination of certain practices. These included recommendations to consider the emissions associated with bulk transportation.

“The Route Map should consider additional environmental factors, such as transport emissions. For example, our sector deals with heavy and bulky materials, with significant implications for transport and processing. Any measures to encourage reuse and recycling should avoid inadvertently increasing energy use or increased transport emissions.” – MPA Scotland

Concerns about supply chain resilience in the face of economic and climate shocks were expressed by two respondents.

A small number of respondents reaffirmed the need for strategic environmental assessments (SEA) as early as possible. Historic Environment Scotland suggested that they should be carried out considering the impact proposals in the Route Map may have on historic buildings, specifically around construction and demolition. NatureScot recommends that partners assist with the SEA process, arguing that the SEA will help discover any unintended consequences that may lead to adverse impacts.

Other less mentioned themes include:

• Concerns about the investment and resources set aside to fund the proposals in the consultation
• A request that the proposals rank and present interventions in order of priority
• An acknowledgement that impacts of Brexit, Covid and the cost-of-living crisis have already created instability and make the outcomes of the proposal harder to predict.