National litter and flytipping consultation: strategic environmental assessment

10. Cumulative Effects

Schedule 3 (6) (e) of the Environmental Assessment (Scotland) Act 2005 requires that the “secondary, cumulative and synergistic effects” of the new National Litter and Flytipping Strategy are assessed. To provide an overall assessment of the aims and objectives for preventing litter and flytipping with the SEA topics, an assessment was carried out to determine the potential impacts of the aims and objectives in terms of effects on the environment (Section 10.1). Further to this, assessment of the cumulative effects of the four litter and flytipping strategy themes are included, both alone (Section 10.2) and in-combination with other plans and programmes (Section 10.3).

In terms of the overall assessment of the cumulative effects, it should be noted that accurately assessing the impact of measures proposed in the new National Litter and Flytipping strategy is challenging due to limitations on data available on levels of littering and flytipping in Scotland (in common with other countries^[180]) and recognition of the high level nature of the measures proposed in the strategy.

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 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.

10.1 Compatibility assessment of aims and objectives for the NLFS

This section presents the findings of the appraisal of effects of the aims and objectives that have directed the development of actions proposed in the new National Litter and Flytipping Strategy. These are assessed separately for Litter and for Flytipping.

10.1.1 Compatibility Assessment for the Litter Strategy Aims and Objectives

The aims and objectives proposed in the strategy specific to litter prevention are presented in Table 10-1, along with a summary appraisal of the expected effects of these aims and objectives with respect to the SEA topics.

The assessment concludes that the stated aims and objectives for litter prevention under each of the strategy themes are compatible with an approach that would deliver positive environmental effects in each of the SEA topics. This reflects the premise that litter is defined as waste in the wrong place, i.e. the wider environment, and therefore objectives targeting the prevention of litter would be positive for the environment. Prevention would result in reduced amounts of litter and risks of injury or harm to biodiversity and human health. More effective control of littered materials would break the link between litter and pollution in the water environment, increase the potential for carbon savings through greater recycling and extension of resource value, and reduce the pressure on landfill capacity. Prevention of littering would also reduce visual impacts, increasing the value of the amenity of public open space and enhancing human health through improved well-being. Given the high-level nature of the stated visions and aims, minor positive effects have been identified in each case, along with an uncertainty symbol to indicate the level of positive impact is unknown at this stage

Table 10-1 Compatibility assessment of the aims and objectives for the prevention of litter

Behaviour Change – Aim & Objectives

Litter Strategy Theme	Biodiversity	Human Health	Water	Climatic Factors	Material Assets	Landscape and Visual
Aim: Improve the consistency and nature of our communications so people have greater awareness and understanding of their responsibility in preventing litter and motivate people to behave responsibly.	+/?	+/?	+/?	+/?	+/?	+/?
Objective: Understand litter perceptions and behaviour to allow targeted approaches to be developed.	+/?	+/?	+/?	+/?	+/?	+/?
Objective: Develop and adopt a shared approach between Scottish Government, Local Authorities, public agencies and the third section, to litter prevention and behaviour change across Scotland.	+/?	+/?	+/?	+/?	+/?	+/?

Services and Infrastructure – Aim & Objectives

Litter Strategy Theme	Biodiversity	Human Health	Water	Climatic Factors	Material Assets	Landscape and Visual
Aim: Scotland’s services and infrastructure are fit for purpose and prioritise action and innovation that proactively prevents litter and supports a circular economy.	+/?	+/?	+/?	+/?	+/?	+/?
Objective: Encourage a shared approach to services that will effectively support litter prevention.	+/?	+/?	+/?	+/?	+/?	+/?
Objective: Empower community groups to take action.	+/?	+/?	+/?	+/?	+/?	+/?

Enforcement – Aim & Objectives

Litter Strategy Theme	Biodiversity	Human Health	Water	Climatic Factors	Material Assets	Landscape and Visual
Aim: There is a strong and consistent enforcement model across Scotland that is fit for purpose and acts as a proportional deterrent and effectively stops people from littering.	+/?	+/?	+/?	+/?	+/?	+/?
Objective: Develop an effective enforcement model.	+/?	+/?	+/?	+/?	+/?	+/?
Objective: Improve the consistency of enforcement practices.	+/?	+/?	+/?	+/?	+/?	+/?
Data and Research – Aim & Objective
Aim: We understand the behaviours, attitudes and drivers behind littering and develop an evidence base of litter data that can facilitate design, implementation and monitoring of effective policy interventions.	+/?	+/?	+/?	+/?	+/?	+/?
Objective: Improve our understanding of the sources, levels and composition of litter.	+/?	+/?	+/?	+/?	+/?	+/?

10.1.2 Compatibility Assessment for the Flytipping Strategy Aims and Objectives

The aims and objectives proposed in the strategy specific to the prevention of flytipping are presented in Table 10-2, which also includes a summary assessing the compatibility of the aims and objectives with the SEA topics.

The assessment concludes that the stated aims and objectives for the prevention of flytipping under each of the strategy themes are compatible with an approach that would deliver positive environmental effects in each of the SEA topics. Flytipping is the illegal dumping of waste, which the aims and objectives intend to control and prevent. Although flytipping may be driven by different causes and sources to littering, the impacts on the environment are similar. Therefore, the positive effects attributable to the aims and objectives for flytipping are broadly aligned with those identified for littering i.e. objectives to reduce flytipping incidents and the uncontrolled dumping of waste material will reduce the potential for harm to biodiversity, human health and the water environment; improve the visual appearance of public spaces and the wider landscape; and reduce impacts on the climate and pressure on material assets, through more effective management of material resources. Again, given the high-level nature of the stated aims and objectives for flytipping, minor positive effects have been identified in each case, along with an uncertainty symbol to indicate the level of positive impact is unknown at this stage.

Table 10-2 Compatibility assessment of the aims and objectives for the prevention of flytipping

Behaviour Change – Aim & Objective

Flytipping Strategy Theme	Biodiversity	Human Health	Water	Climatic Factors	Material Assets	Landscape and Visual
Aim: Improve flytipping messaging to ensure individuals are confident in their understanding of their role in disposing of waste appropriately and those who deliberately flytip are motivated and enabled to change their behaviour.	+/?	+/?	+/?	+/?	+/?	+/?
Objective: Understand the flytipping behaviours to allow targeted approaches to be developed.	+/?	+/?	+/?	+/?	+/?	+/?
Objective: Develop and adopt a shared approach between Scottish Government, Local Authorities, public agencies and the third sector to flytipping behaviour change across Scotland.	+/?	+/?	+/?	+/?	+/?	+/?

Services and Infrastructure – Aim & Objectives

Flytipping Strategy Theme	Biodiversity	Human Health	Water	Climatic Factors	Material Assets	Landscape and Visual
Aim: There is a resilient national framework which provides consistent and joined up services that are effective for both preventing flytipping where possible and tackling it effectively where it does occur.	+/?	+/?	+/?	+/?	+/?	+/?
Objective: Support development of consistent, innovative and effective waste services and infrastructure.	+/?	+/?	+/?	+/?	+/?	+/?
Objective: Provide support to private landowners and land managers that experience flytipping on their land.	+/?	+/?	+/?	+/?	+/?	+/?

Enforcement – Aim & Objectives

Flytipping Strategy Theme	Biodiversity	Human Health	Water	Climatic Factors	Material Assets	Landscape and Visual
Aim: A strong, consistent enforcement model that is fit for purpose and acts as an effective deterrent for flytipping behaviour.	+/?	+/?	+/?	+/?	+/?	+/?
Objective: Develop an effective enforcement model.	+/?	+/?	+/?	+/?	+/?	+/?
Objective: Improve consistency of enforcement practices across Scotland.	+/?	+/?	+/?	+/?	+/?	+/?

Data and Research – Aim & Objective

Flytipping Strategy Theme	Biodiversity	Human Health	Water	Climatic Factors	Material Assets	Landscape and Visual
Aim: Understand the behaviours and drivers behind flytipping and collect data and establish a monitoring program which provides guidance for policy and evaluates actions undertaken.	+/?	+/?	+/?	+/?	+/?	+/?
Objective: Improve our understanding of the sources, levels and composition of flytipping.	+/?	+/?	+/?	+/?	+/?	+/?

10.2 Cumulative effects associated with the NLFS proposals

This section presents the cumulative effects for proposed in scope actions for the National Litter and Flytipping strategy. The cumulative effects identified are based on an overall judgment of the effects of proposed measures on the six SEA topics included in the assessment, taking into account the range of effects on the assessment SEA criteria as presented in sections 4 to 9 (i.e. whether significant or minor, positive or negative).

10.2.1 Cumulative Effects for the Litter Strategy Actions

The cumulative effects of proposed measures against each of the four SEA strategy themes are summarised in Table 10-3 for Litter.

Table 10-3 Summary of cumulative effects from actions for the prevention of litter

Litter Strategy Theme	Biodiversity	Human Health	Water	Climatic Factors	Material Assets	Landscape and Visual
Behaviour Change	+/?	+/?	+/?	+/?	+/?	+/?
Services and Infrastructure	+	+	+	+	+	+
Enforcement	+/?	+/?	+/?	+/?	+/?	+/?
Data and Research	+/?	+/?	+/?	+/?	++/?	+/?

The analysis for the Litter strategy shows that the proposed measures will generate cumulative positive effects across each of the environmental topics.

No cumulative significant negative effects have been identified during the assessment.

Although positive effects are determined for each of the environmental topics, in general these are not considered to be significant, which in part is due to the high level nature of the proposed actions, along with some additional uncertainty regarding the quantitative effects of litter on the environment and unknowns regarding implementation by relevant stakeholders. A significant level of cumulative positive effects is determined for the proposals related to data and research for material assets, where there are considered to be benefits in recouping the resource value of materials in litter that would otherwise be lost, as well as avoiding disposal of litter and therefore reducing pressure on landfill capacity.

10.2.2 Cumulative Effects for the Flytipping Strategy Actions

The cumulative effects of proposed measures against each of the four SEA strategy themes are summarised in Table 10-4 for Flytipping.

Table 10-4 Summary of cumulative effects from actions for the prevention of flytipping

Flytipping Strategy Theme	Biodiversity	Human Health	Water	Climatic Factors	Material Assets	Landscape and Visual
Behaviour Change	+/?	+/?	+/?	+/?	+/?	+/?
Services and Infrastructure	+	+/?	+	+	+	+
Enforcement	+/?	+/?	+/?	+/?	+/?	+/?
Data and Research	+/?	+/?	+/?	+/?	+/?	+/?

The analysis for the Flytipping strategy shows that the proposed measures will also generate cumulative positive effects across each of the environmental topics.

Again, no cumulative significant negative effects have been identified during the assessment.

In the case of the measures developed for combating flytipping, none of the cumulative positive effects for the environmental topics are found to be significant, although there is considerable uncertainty identified. In principle, the proposals for enforcement should deliver positive effects for the environment but the uncertainty arises from insufficient evidence currently available to demonstrate causal links between enforcement measures and sustained reductions in flytipping. The uncertainty points to the need for further clarity, and monitoring, to assess the effectiveness of the proposed actions in changing existing levels of flytipping.

10.3 Cumulative effects of the NLFS with other plans and programmes

The proposals in the National Litter and Flytipping strategy would sit within and across a number of other pre-existing plans and programmes (Sections 4.1-9.1 above) that are relevant to the effective prevention of litter and flytipping and their wider effects. Although the combined effects of proposals in the strategy and other plans and programmes are difficult to fully assess, it is anticipated that this intervention will support and enhance the pre-existing aims, objectives and targets of the Plans and Programmes as follows:

• UN Strategic Plan for Biodiversity 2011-2020 (including Aichi Biodiversity Targets) – includes strategic goals to reduce pressures on biodiversity and safeguard ecosystems, which are supported by the proposal to prevent litter and flytipped materials entering the environment.
• UN Sustainable Development Goal 3 – seeks to ensure healthy lives and promote well-being for all at all ages, and UN Sustainable DevelopmentGoal 11 – seeks to make cities and human settlements inclusive, safe, resilient and sustainable. The prevention and improved management of litter and flytipping would support both of these goals in improving the environment for human habitation.
• UN Sustainable Development Goal 14 – the prevention and improved management of litter and flytipped materials is in line with efforts around UN Sustainable Development Goal 14 relating to conservation and sustainable use of oceanic and marine resources.
• UN Sustainable Development Goal 15 – relates to conservation, restoration and sustainable use of terrestrial ecosystems, and halting and reversing land degradation and biodiversity loss. The prevention of litter and flytipped materials entering the environment, particularly plastic degradation products, would support the conservation of terrestrial ecosystems.
• EU Water Framework Directive (2000); Water Environment and Water Services (Scotland) Act, 2003; The River Basin Management Plan for the Scotland River Basin District (2015 – 2027) – each seek to protect the water environment including groundwater, surface water and wetlands. Proposals in the strategy aimed at preventing litter and flytipping entering the environment and reducing associated levels of pollution support the aims to protect the water environment and improve water quality.
• The Environmental Protection Act (1990) – seeks to improve resource use and environmental conditions through the control of pollution from waste management across the UK to protect air, water and land. This aligns closely with the aims of the strategy to reduce levels of litter and flytipping and associated pollution.
• The Climate Change (Scotland) Act (2009) and The Marine Litter Strategy for Scotland (2014) – both emphasise the need for a decrease in terrestrial and marine pollution and litter, and for greater consideration and respect for the Scottish environment, which is a key objective of the National Litter and Flytipping strategy.
• The Climate Change (Emissions Reduction Targets) (Scotland) Act 2019 – sets targets for the reduction of greenhouse gases emissions towards a legally binding net-zero carbon target by 2045. There is potential for proposals in the strategy for the optimisation of services and infrastructure to unduly increase carbon emissions associated with transport or waste management options, however, the aims of the strategy to prevent litter and flytipping are in line with targets to reduce carbon emissions through extending the value of material resources.
• Toward a Litter free Scotland – The National Litter Strategy (Scotland) (2014) – introduced actions to reduce levels of litter and flytipping in Scotland and improve the management of these materials. The National Litter and Flytipping strategy is fully aligned with these objectives and following a review of the National Litter Strategy is seeking to develop further actions for more effective measures to prevent littering and develop a more targeted approach to reduce flytipping.
• The Scottish Biodiversity Strategy (2004/2013) – calls for the imperative need to continuously improve the health of ecosystems and natural habitats within Scotland, which would be supported by the aims of the strategy to prevent litter and flytipped materials entering the environment.
• The Scottish Government Circular Economy Strategy (2016) – the improved management of litter and flytipped materials supports this strategy in promoting the need for more responsible, sustainable resource use and greater respect for material assets,

It is predicted that the proposals in the new National Litter and Flytipping strategy would generally not result in conflict between the programmes highlighted above (and those identified in Sections 4.1-9.1) but would in most instances compliment the aims and aspirations of these programmes.

In addition, it is considered that the new National Litter and Flytipping strategy is closely aligned with the objectives of the European Union, Single Use Plastics Directive 2019 (SUP Directive), which draws attention to the significant negative environmental, health and economic impact of littered products, and The Deposit and Return Scheme for Scotland Regulations 2020 (DRS Regulations), which promotes an increase in recycling of materials and a change in people’s attitudes to recycling and littering. It is anticipated that proposals in the new National Litter and Flytipping strategy would work in tandem with both the SUP Directive and DRS Regulations, particularly in relation to commonly littered plastics and packaging materials. which should enhance the cumulative positive effects for the environment.