EU single use plastics directive consultation: impact assessment - environmental report

6. Landscape and visual impacts

This section outlines the assessment of the proposed market restrictions against the scoped in topic of landscape and visual impacts. Whilst the SEA legislation does not provide any definition of the term "landscape" or "visual impacts", NatureScot^[57] quote the definition of the European Landscape Convention in defining landscape as "an area, as perceived by people, whose character is the result of the action and interaction of natural and/or human factors".

This section provides the contextual information to inform the assessment (in terms of the review of Plans, Programmes and Strategies (PPS) and the baseline information) as well as an assessment of the effects of the SUP Directive on landscape impacts.

6.1 Relationship with other Plans, Programmes and Strategies and Environmental Objectives

The PPS that are relevant to the landscape and visual impact topic that have been reviewed to inform the assessment exercise are shown in

Figure 6‑1 and summarised thereafter.

For the purposes of the review of the international plans and programmes for this SEA, it is assumed that the broad objectives of extant European Union (EU) legislation will be maintained once the UK has withdrawn from the EU and that similar or equivalent environmental protections will remain in place.

The relationship between the identified PPS and the restriction of single-use plastic items placed on the Scottish market are outlined below.

The European Landscape Convention (2006) seeks to promote the protection and management of urban and rural spaces. The ELC promotes the principles of developing and protecting landscapes through implementation of Landscape Quality Objectives requiring authorities to support public aspirations for their surroundings as opposed to solely expert opinion. The principles of the ELC are consistent with the aims of restricting single-use plastic items placed on the Scottish market in the preservation of the Scottish landscape which suffers significant and continued detriment through the prevalence of plastic litter. The ELC was adopted by the UK in 2006.

European Union (2019): Directive on the reduction of the impact of certain plastic products on the environment highlights significant negative environmental, health and economic impacts stemming from the continued use of certain plastic products. The aims and provisions of this Directive are outlined in Section 4.1 (above). In the context of Visual Impacts, embedding a more circular approach to resources will precipitate a reduction in waste and litter, which in turn will improve the aesthetic of the Scottish landscape. A reduction in plastic waste will also shorten the degradation period of littered materials.

UK Government (1990): The Environmental Protection Act seeks to improve resource use and environmental conditions through the control of waste collections and management across the UK. The main provisions of the Act are outlined in Section 5.1 (above). Restriction of single-use plastic materials in Scotland supports the ambitions of the act in ensuring that detrimental impacts of plastic on the Scottish environment, owing to its brief use phase and long degradation period, are significantly limited. By prescribing that littering is an offence, the Act seeks to deter occurrences of littering, thus diminishing its impact on the beauty of Scotland.

The NatureScot Statement (2005): The Landscape Policy Framework (Policy Statement No. 05/01) sets out Scottish Natural Heritage (now NatureScot) approach on conserving and managing Scottish landscapes. The document emphasises the importance of landscapes across Scotland to both individual well-being and the economic success of an area. The document reiterates the remit of NatureScot to preserve the aesthetics and natural qualities whilst protecting wildlife and natural schemes. Key actions of NatureScot include developing a sense of responsibility for landscapes across Scotland whilst acting as a statutory consultee to ensure landscape interests are considered in decision making. Restricting single-use plastic items within the Scottish market will support these ambitions by reducing litter across landscapes and nurturing a new behavioural paradigm of improved resource management.

Scottish Government (2014): A Marine Litter Strategy for Scotland identified five proposed strategic directions to reach a Zero Waste Scotland, supported by responsible behaviours. The main aims of the Strategy are outlined in Section 5.1 (above). The strategy seeks to reduce the litter entering the marine environment, with plastic being identified as a major contributor, and one which has particularly detrimental characteristics in terms of visual impacts on the landscape and marine habitats in Scotland. Restriction of single-use plastic products would support the drive to reduce littering in a marine environment, by necessitating their replacement by less harmful alternatives.

Scottish Government (2014): Toward a Litter free Scotland - The National Litter Strategy sets clear actions which have an impact upon material assets, when seeking to improve the environment through targeted approaches to litter and fly-tipping. The main aims of the Strategy are outlined in Section 5.1 (above). The restrictions of single-use plastic products will promote the outcomes of the Strategy by limiting the amount of plastic waste in circulation within Scotland, and the resultant harm to visual impacts caused by the leakage of this waste into the Scottish terrestrial and marine habitats.

Scottish Government (2014): The Scottish National Planning Framework and Scottish Planning Policy are two documents which promote waste as a resource. The main objectives of the documents are outlined in Section 5.1 (above). The Framework promotes the protection of Scottish lands from productive soils, to water resources and the natural landscapes, and this includes protection from littering and the leaching of microplastics into the Scottish terrestrial and marine habitat.

6.2 Baseline Characteristics

This section of the Environmental Report identifies and characterises current environmental baseline conditions for landscape and visual impacts. This baseline highlights the diverse nature of Scotland's landscapes. It also identifies the terrestrial and marine litter levels for the single-use plastic items in scope, and the impact litter has on communities and local environments.

6.2.1 Landscape (including townscapes and built heritage)

Scottish Natural Heritage (now NatureScot) identified a series of Natural Heritage Zones as part of their Natural Heritage Futures initiative and used these areas to describe a vision for sustainable use of local natural heritage. A total of 21 zones were identified,^[58] each having their own identity resulting from the interaction of geology, landforms, wildlife and land use.

Scotland has 40 National Scenic Areas (NSAs) covering more than one million hectares (12.7% of Scotland). The Planning etc. (Scotland) Act 2006 gives a statutory basis to NSAs. The purpose of the NSA designation is both to identify Scotland's finest scenery and to ensure it is protected from inappropriate development. This is achieved through the local authority planning scheme.^[59] Other areas designated for their landscape include two National Parks and three Regional Parks together with a number of Special (local) Landscape Areas.^[60]

6.2.2 Litter

6.2.2.1 Terrestrial Litter

The majority of litter in Scotland is discarded by members of the public, with business and commercial waste each accounting for less than 5% of total litter presence.^[61]

A 2016 survey^[62] by Keep Scotland Beautiful sought to identify the composition and distribution of litter in Scotland by recording the type and number of littered items in a representative selection of sites and to compare the results to an equivalent survey undertaken in 2014. A total of 120 sites were surveyed, with 30 in Edinburgh, Falkirk, Renfrewshire and Inverness respectively. Whilst all types of litter were recorded, of particular relevance to these proposals are the types of plastic litter items recovered.

The breakdown of these items is as follow:

• Drinking straws: 23 items, 0.4% of all litter
• Drinking cups (not all EPS): 27 items, 0.5% of all litter. An analysis by Resource Futures estimates that expanded polystyrene cups made up 0.14% of dropped litter waste by item count in Wales.^[63]
• Other drinks related (including stirrers): 5 items, 0.1% of all litter.
• Fast food packaging (not all EPS): 33 items, 0.6% of all litter
• Other food related (might include cutlery/plates): 6 items, 0.1%

Keep Britain Tidy's latest Local Environmental Quality Survey of England (LEQSE)^[64] (2017/2018), covering terrestrial litter found that 52% of sites were affected by non-alcoholic drinks-related litter (which includes drinks carton straws), and 12% of sites were affected by fast food-related litter (which includes large drinking straws and stirrers from fast food outlets and coffee shops).

The Keep Britain Tidy 2013/14 litter composition survey^[65] of England found the composition of terrestrial litter, by item count, was:

• 2.0% straws;
• 1.2% cartons (some containing straws) and
• 6.4% fast food packaging (fast food straws and stirrers are not individually reported).

This suggests that plastic straws are likely to account for between 2% and 10% of litter items, (most likely in the lower part of this range at around 2-4%). The prevalence of plastic stirrers is harder to gauge but this is likely to be much lower than straws.

Although the results of both studies vary largely due to differences in methodologies and sample size, both sources highlight the littering of single-use plastic products.

Public Attitudes Towards Litter Survey work carried out by Zero Waste Scotland^[66] found that:

• 10% of respondents had intentionally dropped litter in the 12 months prior to the survey being carried out;
• 26% of respondents had accidentally dropped litter and left it there in the 12 months prior to the survey being carried out;
• 86% of respondents had seen someone else drop litter (i.e. either intentionally or accidentally).

6.2.2.2 Marine Litter

Alongside terrestrial litter, marine litter also has a negative impact on the economy, environment and society. This includes damage to marine wildlife as well as wider ecosystem deterioration, public health issues and impacts on the aesthetics of Scotland's landscape. There are also a wider range of economic impacts across industries that rely on Scotland's coastal and marine environment.

The Marine Conservation Society Great British Beach Clean 2017^[67] identified that in Scotland beach litter rose by 6% in 2017 compared with 2016 in terms of the number of litter items identified. A total of 57,961 litter items were collected from 111 beaches, averaging 490 pieces of litter from every 100 metres cleaned, compared to 194 pieces of litter in 2013, an increase of approximately 250% in four years.

The Marine Conservation Society's latest data reveals that the littering of disposable items remains prevalent.

• Containers: Food (including fast food) = On average 2.3 per 100m of beach surveyed
• Cups = On average 1.7 per 100m of beach surveyed
• Cutlery/trays/straws = On average 5.8 per 100m of beach surveyed
• Plastic/polystyrene pieces (0-2.5cm) = On average 65 per 100m of beach surveyed
• Plastic/polystyrene pieces (2.5-50cm) = On average 34.9 per 100m of beach surveyed

The effects of marine litter on biodiversity are discussed in Section 7.

6.2.3 Likely Evolution of the Baseline without the SUP Directive

The Scottish Government has shown a continued commitment to eliminate single-use plastics from our communities due to negative impacts on our wildlife. Although the number of companies who have switched to non-plastic alternatives has increased in recent years, single-use plastic is still seen as one of the key threats to marine and wildlife. Introducing market restrictions for the specified single-use plastic items will help to accelerate the transition to non-plastic alternatives.

There is some evidence that rates of littering may reduce in the long term, thanks to nationwide awareness campaigns and media shows such as Blue Planet and War on Plastic with Hugh and Anita.^[68] Nevertheless, data is not sufficient to establish this for certain. It should be noted too that this trend data does not directly equate to an effect on the landscape as the data does not identify the sensitivity of the receiving environment.

6.3 Consideration of Reasonable Alternatives

This section outlines the assessment of each single-use plastic item in scope against the scoped-in topic of landscape and visual impacts. Whilst the SEA legislation does not provide any definition of the term "landscape" or "visual impacts", Scottish Natural Heritage (now NatureScot)^[69] quote the definition of the European Landscape Convention in defining landscape as "an area, as perceived by people, whose character is the result of the action and interaction of natural and/or human factors".

6.3.1 Methodology

Although all alternative options to the targeted single-use plastic products are also single-use and hence are expected to be discarded after use, market restrictions are expected to reduce the prevalence of marine litter as they will help inform consumers of the damage that could be caused by littering behaviour. Current estimates of single-use plastic litter are discussed in Section 6.2.2.

6.3.2 Results

The table below lists the contribution of each targeted single-use plastic item to the issue of littering in Scotland. The impact of littering non-plastic alternative options into terrestrial and marine environments is discussed below.

Table 6‑1 breakdown of single-use plastic litter by type.

Measure No	Single-use plastic items in scope	Alternative option	Litter share (% by item)
1	Cutlery	Wooden Cutlery	1
2	Plates	Wax-coated Paper Plates	1
3	Beverage Stirrer	Wooden Stirrer	0.1
4	Straws	Wax-line paper straws	1.9
5	Balloon sticks	Cardboard balloon sticks	N/A
6	Food containers made of expanded polystyrene	Wax-coated cardboard boxes	0.3 -0.5
7	Cups and beverage containers made of expanded polystyrene	Plastic-coated paper cups	0.14
8	Oxo-biodegradable HDPE	Conventional plastic	N/A

The key to each assessment score is shown below:

Score Key:

++ : Significant positive effect
+ : Minor positive effect
0 : No overall effect
- : Minor negative effect
-- : Significant negative effect
? : Score uncertain

NB: where more than one symbol is presented in a box it indicates that the SEA has found more than one score for the category. Where the scores are both positive and negative, the boxes are deliberately not coloured (i.e. 'no overall effect'). Where a box is coloured but also contains a "?" this indicates uncertainty over whether the effect could be a minor or significant effect although a professional judgement is expressed in the colour used. A conclusion of uncertainty arises where there is insufficient evidence for expert judgement to conclude an effect.

Measure No 1

Material/item in scope: Plastic cutlery

The alternative option: Wooden cutlery

Notes:

SEA criteria: Will the alternative option reduce the visual effects from littering of materials into terrestrial and marine environments and improve their scenic qualities?

Score: Minor positive effect / Score uncertain

Commentary:

According to an analysis undertaken by DEFRA,^[70] It is estimated that 1.5 - 4.5% of all global plastics production ends up in the oceans every year. These items are ingested by marine life (with potential knock-on effects further up the food chain), captured as marine debris in fishing equipment and washed up on beaches. The Marine Conservation Society has been monitoring the levels of cutlery/trays and straws found on beaches in the UK since 2004. Cutlery remains on the top 10 list of items that were found during the Great British Beach Clean 2017 with an average of 15.1 for every 100m of beach surveyed in 2017.^[71]

Assuming that plastic cutlery makes up half of the estimate made for cutlery/trays and straws ,^[72] we can attribute 1% of marine litter to plastic cutlery.

The introduction of a market restriction on plastic cutlery is expected to reduce the prevalence of terrestrial and marine litter by helping to inform consumers of damage that could be caused by littering behaviour. This will consequently reduce the visual effects and improve their scenic qualities.

Measure No 2

Material/item in scope: Plastics plates

The alternative option: Wax-coated paper plates

Notes:

SEA criteria: Will the alternative option reduce the visual effects from littering of materials into terrestrial and marine environments and improve their scenic qualities?

Score: Minor positive effect / Score uncertain

Commentary:

According to an analysis undertaken by DEFRA,^[57] it is estimated that 1.5 - 4.5% of all global plastics production ends up in the oceans every year. These items are ingested by marine life (with potential knock-on effects further up the food chain), captured as marine debris in fishing equipment and washed up on beaches. The Marine Conservation Society has been monitoring the levels of cutlery/trays (including plates) and straws found on beaches in the UK since 2004. This category remains on the top 10 list of items that were found during the Great British Beach Clean 2019 with an average of 5.8 for every 100m of beach surveyed in 2019.^[73]

Assuming that plastic plates make half of the estimate made for cutlery/trays (including plates), ^[74] we can attribute 1% of marine letter to plastic plates.

The introduction of a market restriction on plastic cutlery is expected to reduce the prevalence of terrestrial and marine litter by helping to inform consumers of damage that could be caused by littering behaviour. This will consequently reduce the visual effects and improve their scenic qualities.

Measure No 3

Material/item in scope: Plastic beverage stirrer

The alternative option: Wooden stirrer

Notes:

SEA criteria: Will the alternative option reduce the visual effects from littering of materials into terrestrial and marine environments and improve their scenic qualities?

Score: Minor positive effect / Score uncertain

Commentary:

According to an analysis undertaken by DEFRA,^[75] It is estimated that 1.5 - 4.5% of all global plastics production ends up in the oceans every year. These items are ingested by marine life (with potential knock-on effects further up the food chain), captured as marine debris in fishing equipment and washed up on beaches. The Marine Conservation Society has been monitoring the levels of plastic and polystyrene pieces (0 - 50cm) (including stirrers) found on beaches in the UK since 2004. Polystyrene pieces continue to feature in the top ten, ranking first in most common marine litter items in beach clean surveys with an average of 225.3 for every 100m of beach surveyed in 2017.^[76] Plastic stirrers contribute to these pieces as they are made of polystyrene.

Research suggests that stirrers and straws together make up 2% of marine litter. Assuming stirrers make up 5% of the group of straws and stirrers,^[77] we can attribute 0.1% of marine letter to plastic stirrers.

The introduction of a market restriction on plastic cutlery is expected to reduce the prevalence of terrestrial and marine litter by helping to inform consumers of damage that could be caused by littering behaviour. This will consequently reduce the visual effects and improve their scenic qualities.

Measure No 4

Material/item in scope: Plastic straws

The alternative option: Wax-lined paper straws

Notes:

SEA criteria: Will the alternative option reduce the visual effects from littering of materials into terrestrial and marine environments and improve their scenic qualities?

Score: Minor positive effect / Score uncertain

Commentary:

According to an analysis undertaken by DEFRA,^[78] It is estimated that 1.5 - 4.5% of all global plastics production ends up in the oceans every year. These items are ingested by marine life (with potential knock-on effects further up the food chain), captured as marine debris in fishing equipment and washed up on beaches. The Marine Conservation Society has been monitoring the levels of cutlery/trays and straws found on beaches in the UK since 2004. Cutlery, trays and straws remain on the top 10 list of items that were found during the Great British Beach Clean 2019 with an average of 5.8 for every 100m of beach surveyed in 2019.^[79]

DEFRA research indicates that stirrers and straws together make up 2% of marine litter. Assuming straws make up 95% of the group of straws and stirrers,^[80] we can attribute 1.9% of marine letter to plastic straws.

The introduction of a market restriction on plastic cutlery is expected to reduce the prevalence of terrestrial and marine litter by helping to inform consumers of damage that could be caused by littering behaviour. This will consequently reduce the visual effects and improve their scenic qualities.

Measure No 5

Material/item in scope: Plastic balloon sticks

The alternative option: Cardboard balloon sticks

Notes:

SEA criteria: Will the alternative option reduce the visual effects from littering of materials into terrestrial and marine environments and improve their scenic qualities?

Score: Minor positive effect / Score uncertain

Commentary:

According to an analysis undertaken by DEFRA,^[81] It is estimated that 1.5 - 4.5% of all global plastics production ends up in the oceans every year. These items are ingested by marine life (with potential knock-on effects further up the food chain), captured as marine debris in fishing equipment and washed up on beaches.

There are no estimates on the amount of plastic balloon sticks littered across Scotland. However, we do expect the litter rate to be substantially lower than other single-use plastic items such as plastic straws and stirrers.

The introduction of a market restriction on plastic cutlery is expected to reduce the prevalence of terrestrial and marine litter by helping to inform consumers of damage that could be caused by littering behaviour. This will consequently reduce the visual effects and improve their scenic qualities.

Measure No 6

Material/item in scope: Food containers made of expanded polystyrene

The alternative option: Wax-coated cardboard boxes

Notes:

SEA criteria: Will the alternative option reduce the visual effects from littering of materials into terrestrial and marine environments and improve their scenic qualities?

Score: Minor positive effect / Score uncertain

Commentary:

According to an analysis undertaken by DEFRA,^[68] it is estimated that 1.5 - 4.5% of all global plastics production ends up in the oceans every year. These items are ingested by marine life (with potential knock-on effects further up the food chain), captured as marine debris in fishing equipment and washed up on beaches.

The Marine Conservation Society has been monitoring the levels of plastic and polystyrene pieces (0 - 50cm) (including expanded polystyrene) found on beaches in the UK since 2004. Polystyrene pieces continue to feature in the top ten, ranking first in most common marine litter items in beach clean surveys with an average of 225.3 for every 100m of beach surveyed in 2017.^[82]

The Marine Conservation Society estimates that fast food packaging constituted around 0.6% of all marine litter in 2019. The MCS estimate includes all types of packaging materials (not only EPS) so we expect the amount of food containers made of EPS littered to range between 0.3%-0.5%.

The introduction of a market restriction on plastic cutlery is expected to reduce the prevalence of terrestrial and marine litter by helping to inform consumers of damage that could be caused by littering behaviour. This will consequently reduce the visual effects and improve their scenic qualities.

Measure No 7

Material/item in scope: Cups and beverage containers made of expanded polystyrene^[83]

The alternative option: Plastic-coated paper cups

Notes:

SEA criteria: Will the alternative option reduce the visual effects from littering of materials into terrestrial and marine environments and improve their scenic qualities?

Score: Minor positive effect / Score uncertain

Commentary:

According to an analysis undertaken by DEFRA,^[84] It is estimated that 1.5 - 4.5% of all global plastics production ends up in the oceans every year. These items are ingested by marine life (with potential knock-on effects further up the food chain), captured as marine debris in fishing equipment and washed up on beaches. The Marine Conservation Society has been monitoring the levels of cutlery (including cups) found on beaches in the UK since 2004. This category which includes cups remains on the top 10 list of items that were found during the Great British Beach Clean 2017 with an average of 15.1 for every 100m of beach surveyed in 2017.^[85]

Our analysis suggests that EPS cups littered in Scotland accounts for 0.14% of dropped litter waste by item count (Section 6.2.2.1). While EPS cups are highly likely to be replaced by plastic-coated paper cups following the introduction of proposed measures.

The introduction of a market restriction on EPS cups is expected to reduce the prevalence of terrestrial and marine litter by helping to inform consumers of damage that could be caused by littering behaviour. This will consequently reduce the visual effects and improve their scenic qualities.

Measure No 8

Material/item in scope: Oxo-degradable HDPE

The alternative option: Conventional HDPE

Notes:

SEA criteria: Will the alternative option reduce the visual effects from littering of materials into terrestrial and marine environments and improve their scenic qualities?

Score: No overall effect

Commentary:

We do not expect significant change when switching from Oxo-degradable to conventional HDPE carrier bags as both items are single-use and not widely recycled in Scotland.

6.4 Mitigation and Enhancement

No mitigation measures have been identified under this category.