Deposit return scheme - gateway review: action plan assurance

Annex A

Summary of recommendations and Update on Action Plan

The information below contains comment of action from the Project Team against each of the recommendations from the Gateway Review 0 carried out between the 10th-12th May 2022.

Ref. No.: 1.

Report section: 6.1

Recommendation: The SRO should ensure that sufficient mechanisms and resources are put in-place to capture the value of the Programme learning for the benefit of wider government.

Status: E.

Aligned with SG PPM Principle: Knowledge & Data

Aligned with profession: Policy

Action Plan*: Establish a new dedicated DRS unit to lead on DRS oversight, assurance, continuing policy development (e.g., alignment with UK scheme) and evaluation.

• DRS established, with four full time staff in place, and additional project- based support. Unit will be in place until at least December 2023 to ensure that learning from the development, implementation, launch and early running of the scheme is captured.
• Unit building strong relationships with other administrations to share learning from SG programme.
• Discussion with SG analytical services underway on steps to capture value of the Programme learning.

Ref. No.: 2.

Report section: 6.3

Recommendation: The SRO should urgently review the needs and structure for Programme governance and leadership, to ensure accountability lines and oversight roles are clearly defined and understood.

Status: C.

Aligned with SG PPM Principle: Leadership

Aligned with profession: Project Delivery

Action Plan*: Review governance structures to ensure that they reflect responsibilities for scheme delivery.

• CSL seen as responsible for implementing DRS, with board now fully appointed and functional as primary governance and assurance body within scheme administrator. CSL sharing internal governance information (from board) with SG
• Formalising structures to report readiness, information gaps and emerging risks within the 'system-wide assurance group.' Group providing good mechanism for sharing information and highlighting collective risks but could do more to provide assurance function. Working with CSL to align its Board's assurance needs (though their business readiness workstream) with assurance needs of Scottish Government.
• At executive and ministerial level, we are reinforcing formal reporting mechanisms to complement regular meetings between officials, Ministers, CSL and SEPA. New governance structures established (e.g., policy board) where new requirements emerging, and work planned to clarify role of Executive Oversight Group.

Ref. No.: 3.

Report section: 6.4

Recommendation: The SRO should urgently re-evaluate the 'go-live' schedule and the Scheme 'go-live scope' [redacted]

Status: C.

Aligned with SG PPM Principle: Planning

Aligned with profession: Project Delivery

Action Plan*: Review go-live schedule, scope, cut-over (launch) approach, online takeback obligation, operational information, compliance approach, and early launch opportunities

• Considered the potential risks and benefits of a further delay to the scheme. Ministers remain strongly committed to go live on the current schedule. [redacted]. Business models (including substantive bank funding and large commercial contracts) are now predicated on an August 2023 launch, and retailer and producer implementation is now underway.
• Expectations shared that Scotland cannot expect a fully mature scheme at launch. Continuing to assess ways to de-risk launch.
• [redacted] a 'cut-over' model [redacted] will allow the gradual flow-through of DRS articles from 16 August 2023. Resolved concerns relating to use of UK- wide barcodes. Measures should reduce operational challenges for producers and need for a sudden transition of stock at launch. Slower launch should also help manage logistical challenges due to lower volumes of DRS stock.
• Considering some limited change to [redacted] address concerns with online takeback obligation [redacted].
• Preparing to publish updated return point exemptions guidance that would make it clearer, quicker and easier for eligible retailers to apply for an exemption, should they wish to do so. Anticipated reduction in number of return points would also reduce costs for CSL and producers.
• CSL progressing detailed planning with the operations provider to help de- risk launch, including making use of existing LA infrastructure, establishing shared return points, and supporting the exemptions process.
• SEPA has committed to take a supportive approach to compliance.
• Orkney Return Initiative on track to launch on 04 November. The project will provide a practical test of scheme logistics (especially on island communities) and help to de-risk elements of the scheme, as well as providing public signal that delivery is on track.

Ref. No.: 4.

Report section: 6.5

Recommendation: The SRO should re- examine the roles and coordination of communications across the Programme and ensure a significant improvement in communications flows.

Status: C.

Aligned with SG PPM Principle: Stakeholders

Aligned with profession: Communications

Action Plan*: Review the remit and leadership of the communications group to ensure that (1) responsibilities of the different organisations are clear, with a view to CSL taking lead responsibility (2) more is done to identify and target 'hard to reach' groups, (3) there is greater clarity in 'essential information' on the scheme to support business decision making, and (4) the group is better integrated into wider delivery plans (e.g., infrastructure roll-out.

• CSL agreement to take lead on communications from 2023, with Director for Communications now recruited.
• Progress on business communications since the Gateway Review, including production and distribution of tailored communications tools for stakeholders, expansion and regular updates to SEPA's FAQs. SEPA comms campaign launched August 2022, CSL comms campaign launched Sep 2022.

Ref. No.: 5.

Report section: 6.6

Recommendation: [redacted]

Status: C.

Aligned with SG PPM Principle: Risk

Aligned with profession: Project Delivery

Action Plan*: [redacted]