National litter and flytipping consultation: business and regulatory impact assessment

4.0 Options

27. Following the consultation process, full details of the litter and flytipping strategy will be set out in the final BRIA, and options reviewed against the strategic objectives defined.

28. Understanding the most common types of litter found in terrestrial and marine environments is important in the design of options, to best target resources at the highest priority areas. In achieving this understanding, there are several studies which aim to quantify the prevalence of litter in Scotland and the UK.

29. Looking first at terrestrial litter, the most recent data comes from a Keep Scotland Beautiful study in 2016^[24]. This data, shown below in table 1, shows that gum and gum wrappers, and cigarette stubs and packaging make up 84.5% of litter by item count in Scotland, with all other types of items making up a small percentage combined. This data is based on total item count and is a useful way of demonstrating best the visual disamenity of litter as, for example, cigarette stubs will have a very low individual weight but can be very visually prevalent in the local environment.

Table 1: Most common terrestrial litter items in Scotland by item count (2016)

Item	Prevalence (%)
Gum and gum wrappers	45.1
Cigarette stubs and packaging	39.4
Drinks containers	6.4
Food and food packaging	4.6
Other	4.5

30. Another method of measuring the prevalence of terrestrial litter in Scotland is to measure by total weight. This approach will be more accurate in gaining a picture on the costs of managing terrestrial litter in Scotland, as public bodies and businesses will have to consider the total weight of litter when deciding what to clean up. This data comes from Zero waste Scotland in 2013^[25]. Table 2 below shows the top ten terrestrial item types by weight.

Table 2: Most common terrestrial litter items in Scotland by weight (2013)

Item	Proportion of total weight (%)
Food/kitchen waste	15
Other combustible items	11
Cardboard	9
Newspaper and magazine	9
Packaging glass	9
Plastic bottles	9
Other materials	8
Other paper	8
Plastic film	7
Metal cans	4

31. Quantifying the prevalence of litter in Scotland in the marine environment is challenging. Beach litter provides a measure of litter types and can be used to identify sources (from both marine and terrestrial environments).The most recent data from the Marine Conservation Society's 2020 Great British Beach Clean^[7] identified the top five most littered items. As Table 3 shows, plastic and polystyrene pieces (0-50cm) are the most common item found littered in beaches by a large margin. This emphasises the wider issue of plastic pollution in the marine environment.

Table 3: Most common beach litter items in Scotland by average item count (2020)

Item	Average number (per 100m of beach)
Plastic and polystyrene pieces (0-50cm)	78.2
Wet wipes	48.5
Packets (crisp, sweet, lolly, sandwich)	26.5
Cotton bud sticks	19.9
Plastic/polystyrene string	15.6
Plastic and polystyrene caps and lids	10.5
Cigarette stubs	7.5
Glass	7.5
Plastic/polystyrene rope	4.9
Plastic/polystyrene drinks bottles	4.7

No policy change – business as usual

32. Business as usual is the baseline against which the costs and benefits of the implementation of the litter and flytipping strategy will be assessed.

33. Under this scenario, it is assumed that the annual costs of litter and flytipping to public bodies would remain unchanged, and it is anticipated, based on current trends, that it would rise annually in relation to future labour and landfill tax costs to maintain the status quo. The expected introduction of a UK-wide Extended Producer Responsibility (EPR) scheme after 2024 will mean that business will contribute its share to litter and flytipping removal.

34. The recent COVID-19 pandemic has led to an increase in the use of at least some disposable items, which will likely lead to a rise in littering and flytipping. Further information will be collected and presented in the final BRIA. A programme of engagement by Zero Waste Scotland with manufacturers, wholesalers, retailers and end-users began in August 2020 and will be supplemented with the findings from the consultation process.

35. Disposable items are still imported, made, bought and used in Scotland. Significant numbers of these items occur as litter (thereby creating societal disamenity costs) and enter Scottish waters (threatening the health of the marine environment). Under this scenario, consumer and businesses would not be incentivised further to prevent litter and flytipping and manage them effectively, other than through their own motivations to protect the environment and existing measures to prevent littering and flytipping.

Costs and Benefits

36. It is unlikely that additional financial costs or burdens will be placed on local authorities and enforcement bodies in Scotland specifically from the lack of implementation of any new national litter and flytipping strategy. The cost of littering and flytipping will continue to be borne by public bodies, businesses, and communities. It can however be expected that this will change with other similar future policy developments such as extended producer responsibility (EPR) being developed for areas such as packaging, batteries, waste electricals and electronics equipment (WEEE), as well as the forthcoming deposit return scheme (DRS) for Scotland. Without further action to encourage behaviour change and prevent littering and flytipping, the costs of the problem will continue to rise and burden society.

37. Further analysis of costs and benefits will be detailed in the final BRIA.

Option 1: Implementation of the litter and flytipping strategy

38. Under this option, the provisions of the litter and flytipping strategy.

39. Through our Equalities Impact Assessment we will work with different groups across society to consider impacts on medical, health and wellbeing, as well as independent living.

Sectors and Groups affected

40. The following sectors and groups may be directly or indirectly impacted by the litter and flytipping strategy:

• Local Authorities
• Railway bodies
• Scottish Canals
• National Park Authorities
• Police Scotland
• British Transport Police
• Private land owners and managers and their representative bodies
• Third Sector
• Waste Management Sector
• Scottish Environmental Protection Agency

41. At this stage it is not apparent to what extent different sectors and groups would be impacted. The results from the public consultation process will be used to inform our understanding in this area.

42. The strategy will however directly impact on anyone or any organisation that engages in activities that contribute to littering or flytipping.

Costs and Benefits

43. Society will benefit from a reduction in the volume of littering and flytipping. This will improve local environments and neighbourhoods and reduce the negative environmental impacts of litter entering the terrestrial and marine environments. A reduction in litter is also correlated with a range of socioeconomic benefits which include greater business investment, higher property values, and reduced car travel.

44. Communities benefit from higher quality local environments and from the contribution that this makes to wellbeing. Businesses could benefit from reduced costs for litter and flytipping removal and the reduction in the impact that litter has on their economic performance.

45. It has been estimated that the direct cost to public bodies from littering and flytipping are £53 million, with indirect costs likely to exceed £25 million.

46. Local Authorities and public bodies with a duty in relation to litter and flytipping may see a rise in costs due to measures such as extra enforcement, behaviour change and communications activities, and infrastructure. We will seek to quantify these in the Final BRIA. Effective litter and flytipping prevention activities should result in lower litter and flytipping incidents and therefore less spending on clean up activities.

47. New costs for businesses may also arise from preventative measures included in the strategy, including any greater responsibility to better manage the disposal of commercial waste.

48. Further analysis of costs and benefits will be detailed in the final BRIA.