Marine litter strategy for Scotland: consultation analysis

9. Business and Regulatory Impact Assessment

Context

9.1 To help us determine the impact of the actions proposed in the Strategy, we are interested to find out if these proposals would lead to increased costs and/or impact on resources for you or your business (if applicable). Any comments received will be used to inform the final Business and Regulatory Impact Assessment (BRIA) which would be prepared as part of the Strategy development process.

Question 12: Do you think that any of the proposals/actions in this consultation have any financial, regulatory or resource implications for you and / or your business (if applicable)?

9.2 Almost one-quarter (23.0%) of respondents, primarily organisations, reported that the proposals/actions in the Consultation Document would have any financial, regulatory or resource implications for them and/or their business/organisation, Table B26 (Appendix B).

9.3 Organisations with a focus on the issues of coastal development and conservation, or environment and conservation, followed by industry were more likely to consider that the proposals/actions would have implications for their business/ organisation.

9.4 The BRIA is focussed on a business impact assessment, and as such not all comments from individuals may be relevant/evidenced.

If "Yes", please specify which of the proposals/actions you refer to and why you believe this would result in financial, regulatory or resource implications for your business.

9.5 The most common response was from individuals who considered that financial implications would likely be inevitable for businesses and/or consumers, and that this may be the only way to drive change and solve the problem of marine litter.

9.6 For organisation respondents (excluding industry) the main concern was that any expansion of their activities, such as litter picking/removal or monitoring would entail extra costs/resources and therefore require additional funding.

9.7 A few comments mentioned that the provision of core funding could be beneficial for community groups to help sustain/expand existing activities. A related point was that funding could be difficult to attract for existing activities with some funders keener to support new and/or innovative activities.

9.8 Representative quotes included:

"Operated by KIMO UK, the UK is host to the largest Fishing for Litter project in Europe (probably in the world) in terms of numbers of participating ports and vessels and the project continues to grow, such that it will be nearly doubled in terms of the number of ports participating compared to a baseline of 2019. The greatest cost to the project is of waste disposal….KIMO UK has not infrequently found itself in a position where it must take funds from its own reserve to cover the extra cost of waste processing. This is clearly not sustainable. There are solutions, based around a cost recovery system that can be sufficiently flexible and can offset the cost of waste management, however these may involve an extra administrative burden on both harbour staff and local authorities".

KIMO UK

"Community groups and charities who are already dealing with this mass pollution event need core funding to employ staff to do this incredibly repetitive, physically demanding job. That should be the starting point".

Islay Development Initiative

9.9 Industry respondents connected to the wet wipe industry noted that there could be a significant cost increase of 40% or more in the event of a ban on wet wipes containing plastic. Further, this could impact on both domestic and commercial users.

9.10 In the event that there was any requirement for the reformulation of wet wipes, an appropriate timeframe for implementation was considered preferable so that existing products do not need to be withdrawn from the market. This could limit costs for producers and the environmental impact of disposal.

9.11 Below are some quotes which illustrate these concerns:

"Gama Healthcare would urge that a recognition is made between "Consumer" wet wipes and "Professional" wet wipes. A transition to a "plastic free" version of a professional wipe for surface disinfection purposes would currently result in an estimated 40% on cost for the cost of the nonwoven material used to fabricate the wipe. It is further anticipated that during the next year (December 2021 to December 2022) the cost of cellulose based fibres will increase an additional 40%. So, we would not only have a less efficacious product, but we would also have a more expensive product."

GamaHealthcare Ltd

9.12 On the fishing industry side, the Scottish Fishermen's Federation reported that new technologies for tackling fishing based marine litter could likely impose costs on the Scottish fishing fleet. Salmon Scotland also reported that continuing to support action on tackling marine litter could have cost implications for the aquaculture industry, but also that it could bear these costs to benefit the environment.