Deposit return scheme: gateway review report - March 2023

7.0 Review Team Findings and Recommendations

7.1 Programme and Review Context

7.1.1 With experience of many Scottish and UK projects and programmes, the Review Team acknowledged that due recognition should be given to the ambition and innovation of this Programme. Whilst the Programme, seeks to make a major, and apparently wanted behavioural change to Scottish society, it also creates a new and significant business in the Scottish landscape with many subsequent economic activities including numerous new jobs and other business opportunities, whilst also bringing huge environmental improvement benefits. However, probably its greatest challenge is that the Programme pioneers a new way of working between the public and private sector as the first major step to achieve Extended Producer Responsibility (EPR). Here, government sets regulation and industry has largely independent responsibility to most effectively deliver society's needs. This working relationship is new territory in many respects and Government is having to find its way, particularly how to control and govern such an arrangement, giving industry the freedom to deliver an efficient service whilst also protecting public interest. This is an ambitious and courageous programme to deliver societal good and it would be imprudent to expect this new arrangement to work smoothly and at first attempt. The Programme, and wider stakeholders, should recognise, and champion, a progressive and evolutionary change. Indeed, given the many complexities, especially around cut over, it is hard to see how this Programme can be introduced without significant friction and it is important that expectations are set with the public, retailers, wholesalers, producers and government ministers, that there will be implementation challenges regardless of when the system is introduced.

7.1.2 The findings of this Review must be considered with recognition that the Review examines a Programme that is exceedingly sensitive and extremely complex with a great deal of detail, much of which is still being explored by the Programme. Whereas a Gateway Review in Scottish Government would normally speak with 12-15 people over two days, this Review has spoken with over 45 people in 2.5 days covering a very wide stakeholder group. Gateway Reviews are strategic in nature and this Review is confident in the high-level issues and concerns that it raises; however, the Review was not able to confirm detailed understanding of many points in some areas. It should also be understood that, at the time of the Review, significant political and media scrutiny was being applied to the Programme; some of the opinion we received would have been influenced by this attention and we were not always able to discern what could have been a 'lobbying position' and what were genuine operational concerns.

7.2 Governance of the Whole DRS Programme

7.2.1 The previous Gateway Review (Assurance of Action Plan October 2022) identified that what an agreed vision of what a 'go-live' looked like, was urgently required with transparency of a phased/evolutionary approach. At that time there was talk of a minimum viable product (MVP) and this language was also used by interviewees in this Review. However, the Review Team were not presented with a

document that gave an MVP description and scope, and no interviewees were able to articulate what this singular scope would be; there remained no evidence that a collective whole system MVP (or other whole system go-live scope) yet exists. By 'whole system' we mean not just the technology, logistics and finance systems, but a scope that covers the entire, end-end activity system that includes the full ranges of customer experiences, worker experience, commercial flow dynamics, business supply chain dynamics, regulation and other system activities. Without a shared agreement on delivery scope for the important, whole system, impacts of individual stakeholder decisions cannot be managed to successfully achieve a shared vision. There is also significant risk of gaps or overlaps in delivery with the potential to leave some stakeholders significantly disadvantaged.

7.2.2 We heard and saw detailed separate programme plans that described the scope and workstreams of the CSL delivery programme, ICT contractor and logistics programmes and these appeared to come together at the CSL programme level. We also heard and saw programmes from many other stakeholders including Scottish Government, SEPA and individual retailers. Some of the detail of individual plans was shared manually through forum such as the System Wide Assurance Group (SWAG), but there was no shared common programme that identified workstream and stakeholder activity interactions and, most importantly, a shared critical path with clear dependencies identified and managed. The Review Team also consider that a shared programme is not possible without an agreed, and authoritative, description and scope of the go-live and any subsequent phasing functionality. Examination of meeting minutes, and comment from interviewees, suggest that the SWAG and the Executive Oversight Group are very useful forum for sharing progress and issues (currently meeting infrequently for this stage in a Programme) but lack the ability to have full governance of the whole Programme.

7.2.3 There were many examples where decisions and actions taken to the satisfaction in one part of the system did not meet the assumptions and needs of another part of the whole system. [Redacted], the Review also heard an assured view from interviewees of almost certain consumer confusion and poor customer experience across the retail sector, credible descriptions of unworkable processing for small businesses, significant commercial risk in the closed loop systems (unreturnable cans), a limited understanding from scheme designers of the logistics of small producer products and no mention was made of the experience of vulnerable groups such as those with sight impairment. The Review Team, and many interviewees, recognised that the system dynamics of the very small number of very large producers and main retailers was generally understood, in most areas. However, it was evident that whole system dynamics, including the vast number of small producers, retailers and users, was not yet understood. The Review Team consider that Scottish Government objectives for their DRS Programme cannot be met without a whole system approach to decision making.

7.2.4 The previous Gateway Review also identified weaknesses in the governance of the DRS Programme, in particular the Scottish Government's needs to protect the public interest in the behaviour of the scheme administrator (SA). The Scottish Parliament passed the DRS regulations to place the burden of compliance on the private sector and enabled the private sector to appoint one or more scheme administrators (SA) to enable their compliance. One SA application was received from the private sector and CSL were confirmed as SA. CSL is a not-for-profit Company Limited by Guarantee with members drawn from the producer and wholesaler community, based on production volume, and the retailer community (based on collection volume and numbers of return points). Given that the burden of compliance resides with the private sector, and to avoid any SA(s) being re-classified as a public body, Government has relatively little direct control; it was not a policy intention to control of the corporate behaviour of the SA. The Deposit Return Regulations do establish SEPA as an environmental regulator of the SA, but this role does not extend to corporate oversight.

7.2.5 Once established the SA will be one of Scotland's larger companies (by turnover) and will find itself as an effective monopoly. Once a DRS is in operation, SG will have further reduced ability to influence behaviour. Currently control of the SA's performance and actions is dependent upon the ability of its industry membership to effect oversight and control, most interviewees felt that this control was very limited. This view was strongly held by many CSL members, and this apparent deficiency has led to some of CSL's members to seek government support to address the control that they have not been able to achieve internally. However, the Review was cognisant that CSL is tasked with establishing an entire market eco-system amongst competing interests in a very challenging timeframe, and this will undoubtedly restrict its capacity to refine its membership relationships. This issue of governance and influence, transferring responsibility and risk, whilst progressing public benefit, is at the heart of the ambition of this Programme and EPR. In the opinion of this Review, self regulation and self organisation in industry sectors has had mixed success, the Review Team could not think of an example where such self organisation had been achieved, across industry sectors, to establish a £500m turnover business and within a 2-3 year timescale. It seems very ambitious to expect this to be achieved without much evolution, resolution of many issues, and without significant nurturing and support.

7.2.6 In interview, most interviewees spoke positively of the professional capability of the current SA team and some recognised the "astonishing" achievement of the team, amidst significant pressure to achieve progress. Nonetheless, very many interviewees from across CSL's membership, and other central stakeholders expressed [Redacted] dissatisfaction with performance with CSL, communication, decision making and appropriate representation of interests. [Redacted].

7.2.7 [Redacted]. Whilst SG have hoped for industry to provide collective responsibility and governance, so far this appears not to be fully effective. Further, this does not allow for an effective governance of the whole DRS system across society. The Review Team consider that to maintain the full public interest, to influence a whole system approach to system development and operation, SG must take advantage of the small window it has to consider and introduce additional/alternative governance arrangements.

7.2.8 This need for reconsideration of the governance of DRS would be a significant change to DRS as constructed and needs deeper examination including policy, legal and further governance advice. This could include both soft and hard influence and control measures such as placing Non-exec Directors on the SA Board, and utilising governance codes commonly used in the finance and other sectors such as the UK Corporate Governance Code. Other measures to accommodate the wider stakeholder perspective could also usefully inform governance, such as for the consumer experience – independent published surveys and responses on matters such as coverage and ease. Operational performance could be benchmarked with other jurisdictions, if possible, to ensure the SA learns from evolving best practice.

Recommendation:

R1 The SRO should most urgently re-assess and implement alternative governance options to provide much more rigorous control of the whole DRS Programme in both the immediate and longer term.

7.3 Achievement of Programme Schedule

7.3.1 The Terms of Reference for this Review are given in Annex B, and in particular this Review has been tasked with assessing the likelihood of a whole system DRS successful implementation in Scotland in August 2023 and to discuss possible options for a descoped, partial or delayed DRS implementation.

7.3.2 The Review met with members of the CSL Board, most of the executive team and a number of the senior managers. Like many interviewees, we were impressed by the apparent high calibre of the CSL team and their drive and commitment to achieve a functioning DRS for Scotland; we were told that many had given up significant opportunities to join CSL. As mentioned in paragraph 7.2.5, standing-up a £500m turnover company from nothing is a an extremely ambitious undertaking, especially in a very in a short timescale.

7.3.3 Achieving the momentum, and funding to establish the Company had taken some time and a number of the permanent senior executives had only recently joined. As a consequence, and an already ambitious schedule, CSL are working at significant pace to deliver DRS. CSL's prime contractors were also brought on-board with ambitious schedules and are also working at significant pace. There are many issues and tasks still to be resolved and achieved. Nonetheless, we heard a very driven confidence that CSL will deliver a functioning DRS technology and logistics solution in August 2023; this was supported with somewhat more caution by their prime suppliers. However, given the pace and necessary singular focus to achieve this, not all business processes, with appropriate depth that one would expect to see for a business of this scale, are currently, and are unlikely to be, in place. [Redacted]. Further, while a functioning DRS may be achievable, this will be very much in the guise of a CSL vision of an MVP – see the discussion in Section 7.2.1. Only 600+ of the (anticipated) 4000+ suppliers have so far signed up, but it was understood that this smaller group represents c95% of the total producer volume; sufficient to meet CSL's view of viability. The Review was informed of some well-known producers who have not yet signed up and "may not" initially remain on the Scottish market. CSL are also confident that they will have sufficient retailers to provide a viable return service with adequate geographical coverage. Some major retailers have yet to commit, and we heard from some retailers that have committed that only some of their stores will be ready. General opinion received was that the readiness of medium and small retailers will be very limited.

7.3.4 The Review was content that an operating logistics system for scheme article collection would be available for August 2023, in that, even if not fully functioning or efficient, the logistics operation would have staff, vehicles and was sufficiently organised that it could rely on short term workarounds if absolutely necessary. We were given confidence that this would have a slim but majority geographic coverage of Scotland. From many interviews, the Review was given confidence that, at launch and shortly after, there will be a plentiful supply of incidents of poor customer experience for observers the media to denigrate the performance of DRS. The very significant majority of these incidents may be of very minor consequence to the overall performance of the system, but will matter to individual system actors such as small retailers, particular producer groups etc. We can be sure of this because we heard that whole system end-to-end testing has not taken place and because stakeholders (retailers and producers) are taking decisions now, some of which will be proven to be wrong and are also contrary decisions across the various actors.

7.3.5 [Redacted].

7.3.6 In DRS a big bang approach is not possible. In the absence of what stakeholders refer to as meaningful decisions (detail system operation), stakeholders are making decisions now based on assumptions that may prove incorrect and are varying across industry. Stakeholders have previously highlighted a critical path of meaningful decisions 12 months before launch. We heard that many of these critical decisions were made in February 2023, but that guidance on interpretation is still being developed. Such decisions include, amongst many others: invoicing, VAT-cash flow issues, fraud prevention, exemptions, cutover management, collection scheduling. Other important operating factors are still unknown, such as collection schedules and invoicing format. Without these details, industry partners can only develop solutions at risk – this is particularly challenging for smaller business with limited resource and financial risk capacity. We heard that, in the absence of this detail, some producers and retailers (including some well-known brands) are choosing to take limited or no action to comply. Most interviewees described an August launch as "very messy" or used similar idioms. [Redacted].

7.3.7 Further for a successful, low risk whole system launch (either big-bang, evolutionary or hybrid), a whole system governance and decision-making capability needs to exist (see Section 7.2).

7.3.8 Several interviewees expressed opinion that the greatest threat to Programme success was uncertainty, and they were eager for SG to urgently provide clarity on direction. The ongoing debate amongst potential First Minister candidates is bringing much uncertainty to Programme delivery – we heard opinion that many industry stakeholders are pausing further action until a new First Ministers position is made clear. Potential conflict with the Internal Market Act (IMA) is another well-known major issue, which is awaiting a ministerial decision in Westminster; there was no clarity amongst interviewees as to the gravity of this issue, some believed it to be a "show- stopper". Similarly, there is an ongoing debate across the UK as the requirements of Trading Standards on DRS article pricing, this is already having an effect as some producers and retailers are making their individual decisions on this issue now, and these decisions vary, other businesses are again pausing critical path activity until further clarity is given. This situation is creating confusion and inconsistency which will be apparent for an August launch. Collectively these issues, amongst many other system operation uncertainties, are creating indecision, inaction and a severe lack of confidence at the very time when actions and decisions are critical to delivering a working system with smooth operation. Statements were made such as "Industry just needs clarity and confidence, we accept that it won't be smooth".

7.3.9 When asked for their most favoured way forward, there was a spread of responses from industry interviewees ranging from "we should just press ahead with August, and accept there will be issues or we will just lose too much faith and confidence" through to "August will be a car crash, it just will not happen and must be delayed". Perhaps not surprisingly, given the way the system has been developed, these opinions broadly, but not consistently, ranged from large producers at one end to small retailers at the other end, respectively. When asked about a delay to align timescales with rUK schemes, some said "that would be nice" but none pushed that option with any conviction. Whilst some talked of a few months delay, most interviewees, and those that appeared to have given it serious thought, felt that a delay of "at least 12 months" would be necessary to give a worthwhile improvement to the balance of risks and allow opportunity to resolve issues in business processes and systems. However, many believed that a delay will bring, possibly significant, financial, confidence and reputational risks. The Review Team concur with these views , believing that to conduct a launch with minimal performance issues, many months will be required to understand, design and then implement a complete end- end testing capacity and, this would first require a whole system governance structure that does not exist. Integral to achieving a whole system approach is the cohesion of partners, yet currently the membership confidence and satisfaction with CSL remains very low.

7.3.10 Some interviews expressed that August was the worst possible month for a launch, being at the peak summertime market for single use drinks and at a time of many summer festivals. We heard that February or October were the optimal times for launch. Cut-over will present issues that are already 'built in' to the delivery approach. Guidance has not yet been issued and again many industry actors have different plans to deal with this. The only apparent way to have a minimally disruptive cut-over seems to be to have a long preparation period when deposit labelled articles are in logistics system, but the DRS has not gone live; some scheme articles have extremely long shelf lives and so a very small volume of articles will also need additional cut-over consideration.

7.3.11 [Redacted]

7.3.12 When asked what could be done to make both an August or delayed start more successful many believed that a phased approach would make a significant difference – "that changes the picture" was expressed. Phases to allow Opt in/out for smaller retailers and possibly smaller producers was a commonly favoured suggestion, allowing businesses to make a business decision on initial participation. Indications from CSL suggest that a 'sufficient' geographical spread will be achievable for August and this would allow many retailers to not initially participate. The Review Team consider that a staged/phased approach is worthy of very serious consideration.

7.3.13 Another significant schedule consideration is the amendment of the DRS Regulations. It is understood that an amendment to the Regulations has been drafted and should have just sufficient time to be put before the Scottish Parliament before August. This draft includes changes that will improve the situation with some of the issues raised by interviewees. However, this will be a single opportunity. If some of the recommendations on launch approach and governance recommended by this Report require further Regulation amendment, exceedingly prompt assessment, staffing and decisions will need to be taken.

7.3.14 The Review heard that DEFRA recently concluded a public consultation for the implementation of an English DRS system with a second round of consultation being considered. It is understood that DEFRA hopes to lay and have approved a Statutory Instrument in the next 12 months and appoint a DMO (SA) also by June 2024, with ministerial aspiration for an operating DRS system in October 2025. In the opinion of the Review Team, with limited examination of the English proposal, but confidently reflecting on the Scottish Government experience, an English DRS is not likely to be available until well beyond the 2025 ambition. Aligning a Scottish scheme with an English scheme would probably mean a delay well beyond October 2025.

7.3.15 This crude assessment of the rUK potential also recognises that Scotland is effectively trialling DRS for the other UK nations, exposing and resolving the many system issues inherent. This is recognised by DEFRA, but more formal recognition of this reality of Scotland's piloting role would be valuable to all parties, achieving efficiencies and more effective answers for all.

7.3.16 [Redacted].

Recommendations:

R2 The SRO should most urgently evaluate delivery options and whilst recognising that all options carry significant risk, gain ministerialsupport for a clear decision.

R3 In collaboration with all Programme stakeholders, the SRO should define an initial whole system MVP and subsequent delivery phases, confirming agreed vision, scope, a set of go live success criteria for all parties, and critical path with dependency mapping for all participants.

7.4 Management of Technology Systems

7.4.1 This Review was not a technology review but sought to gain confidence that technology systems would be ready for an August 2023 go-live and to understand the relative risks. There are multiple technology systems involved and the Review was afforded limited opportunity to examine any of these with much substance; particularly for the CSL and industry technology systems. Nonetheless, we were able to develop an opinion with some confidence that the CSL technology systems are being delivered by experienced technology professionals with a robust understanding of good technology delivery; however, it was evident that the CSL technologies are being developed at pace and so have potential vulnerabilities. [Redacted].

7.4.2 [Redacted]

7.4.3 [Redacted]

7.4.4 [Redacted]

7.4.5 [Redacted]

7.4.6 [Redacted]

7.4.7 [Redacted]

7.4.8 [Redacted]

7.4.9 [Redacted]

7.4.10 [Redacted]

7.4.11 [Redacted]

7.4.12 [Redacted]

7.4.13 [Redacted]

7.4.14 [Redacted]

7.4.15 [Redacted]

7.5 Management of Financial Systems

Financial Management - CSL

7.5.1 The Review Team heard that CSL has made progress in building the finance
function; there is currently a team of eleven and the recent appointment of a CFO. The General Ledger in use currently is SAGE and management accounts are produced using spreadsheets. Work is underway to migrate the General Ledger to an ERP package and the Review Team heard that testing is ongoing currently with a parallel run and switch in April. CSL has an Accounting Reference Date (ARD) of 31 December, so the production of the annual accounts and audit are also ongoing. There is a plan to change the ARD to 31 July and accounts for the seven months to July 2023 will be produced.

7.5.2 The Review Team was advised that the key financial model informing all major business decisions such as the decision to cut producer fees, is maintained by an external financial contractor using integrated spreadsheets. Reliance is placed on this arrangement for running scenarios and forecasting the cashflow impact of changes in assumptions such as volumes, timings, handling fees, producer fees. Management of the financial modelling work is carried out by the new CFO. The resilience of this approach will be important to ensure capital adequacy and liquidity is managed as events evolve.

7.5.3 [Redacted]

7.5.4 In the experience of the Review Team the introduction of a new ledger system and two annual accounts / audit processes in a compressed time is challenging with a relatively new team. Factoring in the new business processes planned to launch in August adds a further layer of risk for a small, fairly new team.

Recommendation:

R4 The SRO should request that an assessment should be made of the resilience of workplans, timetables, capacity and capability to deliver (without undue risk) a very challenging series of requirements. Particular attention should be paid to identifying single points of failure and ensuring these vulnerabilities are managed.

Financial Flows – whole system

7.5.5 The financial flows intrinsic to the DRS are complex in terms of the number of parties involved, the basis for calculation and the timing of transactions/payments. This is understood and captured at entity level in a helpful diagram. The Review Team understands that work is ongoing to design the detailed transaction processing arrangements and the supporting technical infrastructure.

7.7.6 The successful introduction of the DRS is dependent on multiple hand-offs of financial information and the smooth integration of the processes and systems. The plans for ensuring reliable timely end-to-end processing of financial flows are at an early stage. The flow of the deposit around the system are particularly critical, including the handling fees and self-invoicing arrangements for retailers.

7.5.7 The Review Team heard concern from multiple interviewees about the lackof clarity about processes, timings and detailed arrangements for the financial flows. This presents practical difficulties for several parties involved as they are unable to make robust plans for their parts of the whole system operation.

7.5.8 In the experience of the Review Team these arrangements would be expected to be more advanced for a launch date in 5 months' time. The risk of fractured processes, delays in transaction processing and loss of financial control would be reduced by comprehensive mapping of flows, testing (including user acceptance testing) of systems, training of all parties involved.

Recommendation:

R5 The SRO should request that a comprehensive design, documentation and testing plan of financial flows is prepared involving all affected parties with clear accountability and timescales.

7.6 Regulation

7.6.1 The Review Team note that the planned regulatory activities focus solely on environmental performance and exclude other regulatory oversight such as corporate performance, corporate conduct and senior officer "fit and proper" assessment. Other sectors with protected revenue streams and a public interest dimension typically have a wider regulatory regime than is evident and this is referred to in Section 6.1.

7.6.2 The Review Team received the SEPA Project Initiation Document, Workstream Plan Key Milestone Implementation Plan and Risk Register and understand that activities were progressing well, in line with plans until February, when key variables changed unexpectedly. [Redacted]

7.6.3 The Review Team heard from several interviewees that the level ofcompliance with regulation required from go-live could be/may be "flexed" down initially in response to go-live pressures. However, we heard that SEPA's approach to new regulation would normally be a constructive approach to use education initially and ramp up enforcement once systems start to settle. There is a variance in expectations, across numerous stakeholders and this could be counterproductive. Clear communications of the regulatory approach, and why, would be useful including confirming SG's expectations of SEPA's level of regulatory oversight.

Exemptions

7.6.4 The Exemptions Request process is referenced in the Technology Section of this Report. In addition, there is a regulatory dimension to be considered in terms alignment of Exemptions with the overall wider objectives of the DRS. There was strong feedback from several interviewees about the burden placed on small retailers to achieve an exemption if they fall within the proximity or environmental criteria. The Exemption Request Portal was considered by user interviewees as cumbersome, confusing and not user friendly, with exemption turnaround times making it hard for applicants to plan ahead.

7.6.5 The Review Team heard from several interviewees of a perception that a high level of rejection of exemption requests was due, at least in part, to overly rigorous interpretation of the rules. Also, there was a plea for clarity and certainty if changes are to be made as the investments in processes and technology are significant, with valuable retail space lost to accommodate infrastructure requirements. The observation was made that if changes are made too late, the most prepared are the most harmed. Some interviewees were concerned that approaching go-live there could be a sharp increase in application numbers and this could, in the Review Team's opinion, be challenging for the team to accommodate particularly over the summer period, despite the plans to redirect resource from elsewhere in the ZWS organisation on a reactive basis if required. A quick calculation of possible exemption numbers suggests that ZWS will struggle to adequately process an application surge.

Recommendation:

R6 The SRO should confirm the scale and scope of the regulatory task, (aligned with SG/SEPA's tolerance for noncompliance) and including an assessment of resource need and ensure it is appropriately funded if there is a shortfall in registration revenue.

R7 The SRO should urgently review the Exemption process and make improvements to its efficiency, practicality and resourcing.

7.7 Communications and Stakeholder Engagement

7.7.1 The communications landscape for this Programme is extremely complex and nuanced and, especially with recent adverse media coverage, now highly contentious. While the broad responsibilities of each partner seem clear at a high level, it was not clear whether each party had a detailed communication plan. [Redacted]

7.7.2 A number of interviewees expressed concern that the current level of consumer and industry communication, especially across social channels, was leading to vacuum of information which was being filled with significant negative narrative. Almost every stakeholder expressed the need for clarity and certainty in order to help them invest and plan with confidence. It was noted that lack of certainty was also inhibiting the industry and public engagement. The Review Team consider that strong and proactive communications are one of the most effective, if not the most effective, tool that the collective programme can deploy to manage expectations. It is imperative that a clear scope for go-live, at any date, and any subsequent delivery phases, is very clearly communicated with all stakeholders to allow them to make their own individual plans and, most importantly, to engender a collective ownership of the Programme and the significant benefits it can bring. This will require a much more robust and carefully coordinated communications approach, with pro-active action, than is currently apparent.

7.7.3 The Review Team saw and heard about extensive stakeholder engagement with trade associations, individual retailers and producers with various forums available to discuss progress, concerns and key risks. Each participant in the Programme is carrying out engagement to some extent. It is recognised that in such a complex programme, with potentially thousands of stakeholders, there will always be room for improvement; however, the teams in each of the organisations responsible for delivering DRS appear be relatively small relative to the scale of the communications task. While high level budget figures were noted in the document set, no detailed plans were provided to the Review Team.

7.7.4 CSL are actively trying to manage stakeholder relationships but, inevitably, with a relatively new and growing team, working under considerable pressure, there were a number of stakeholder groups who expressed concern about the lack of response from CSL on key issues.

7.7.5 The System Wide Assurance Group and Executive Oversight Groups were identified as key forums for all parties to collaborate and while this seems to have been an effective means of allowing communication, it doesn't seem to have been able to drive urgency and action around the critical issues which threaten the successful delivery of the scheme. [Redacted]

7.7.6 [Redacted]

Recommendation:

R8 In-line with a significant review of Programme governance, and flowing from this, the SRO should review and agree the full governance, leadership and scope of communications activities across parties.

R9 The SRO should vigorously pursue a significantly more proactive communications strategy and actions to drive the societal change, and gain cohesion across the whole society stakeholder groups.