Safeguarding Scotland's Resources - A Programme for the Efficient Use of Our Materials: Analysis of Consultation Responses

Annex 3: Summary Of Comments On The Environmental Report

On 1 February 2013 the Scottish Government published a Strategic Environmental Assessment (SEA) of the proposed programme, Safeguarding Scotland's Resources^[9] with comments invited by 1 March 2013. During this time the main consultation was also re-opened for responses. A summary of the views relating to the SEA is documented below. Where new comments were received on the original proposals, these are incorporated into the main analysis.

Six submissions were made in response to the invitation to comment on the Environmental Report; three from organisations and three from individuals. Five of these respondents had already submitted views on the main consultation document. The responses on the Environmental Report are published in full on the Scottish Government website at http://www.scotland.gov.uk/SSRresponses.

A brief summary of the topics they addressed and their key points follows.

General comments

One individual respondent provided their overarching view of the document. This respondent considered the report to be lacking in clear strategy and complicated. It appeared to them to be overly focused on the proposal to introduce a plastic carrier bag levy and on waste recycling rather than waste minimisation, which in their view could lead to greater sustainability.

This respondent advocated more policy focus on lifestyle-based changes, not simply targeting recycling, including greater incentives to householders to be more responsible for their waste.

The respondent highlighted what they perceived to be gaps: for example, no mention of the 'circular economy'; and no mention of addressing the instructions on packaging materials which state 'not presently recyclable'.

They encouraged the government to take the initiative in dealing with resistance from certain stakeholders such as manufacturers and retailers whom they viewed as largely resistant to working towards minimising packaging. They also recommended investigating what they perceived to be supermarkets' role in encouraging food waste through offers such as buy-one-get-one-free.

Specific comments

Producer Responsibility for Packaging Waste (Action 8)

One respondent (Pack) considered that in comparison with the coverage given to producer responsibility for packaging in the main report, the Environmental Report gave scant coverage to this topic.

Carrier Bags (Action 10)

Three respondents provided comments on the Environmental Report's coverage of Action 10.

One respondent (Ind) considered that the report did not provide an accurate picture of the many complex issues or unintended consequences surrounding the proposed imposition of a charge for 'thin gauge carrier bags,' such as the increase in energy requirements, fuel usage, transport requirements, harmful emissions and increase in landfill requirements which they envisaged will follow the introduction of the proposed charge.

Another respondent (NGO) recommended that all funds from charging for carrier bags should be channelled to good causes that deliver environmental benefits and address behaviour change in relation to waste and consumption. This respondent considered that the content of the report relating to impacts of carrier bags on biodiversity should be improved by including more available information on impacts of plastic waste on wildlife.

A packaging company recommended that the public be made aware of the view that 'the introduction of a 5p tax is an additional tax on an item that is already 'taxed' under The Producer Responsibility (Packaging Waste) Regulations'. This respondent considered it to be more beneficial if the financial penalty on carrier bags under the PRO regulations is spent on recycling the carrier bags. The respondent made further comments including advocating plain/unprinted and un-pigmented carrier bags which would be easier to recycle; questioning what they perceived to be the singling out of carrier bags over general street litter; questioning how much of the 5p will be taken up by retailers' running costs; citing Defra reuse data showing that 80% of people reuse single trip plastic carrier bags within their household; and highlighting the health hazard of multi-use carrier bags.

Comments relating to Appendix B

More specific comments related to Appendix B of the Environmental Report headed, "Longlist of potential actions".

Pilot deposit refund systems

Pilot deposit refund systems are listed in Appendix B as a potential action. One individual respondent welcomed this as a potential action but queried why pilot deposit refund systems are not included within the 13 actions proposed in section 2 (pages 10 - 11) of the report.

Reuse

One NGO recommended the following wording for the Background section:

'Revolve is Scotland's national re-use quality standard. The objective is to increase re-use by improving professionalism, customer experience and visibility of re-use organisations through harmonised standards, branding, data collection, training and awareness raising.

Re-use is also promoted through the Re-use Hotline which refers consumers to their nearest re-use centre. The Business Re-use and Recycling Directory has been developed to allow commercial organisations to access re-use and recycling provision.'

This NGO also recommended the following wording for the brief description of potential action:

'Continued expansion of the Revolve standard to the reuse sector and the promotion of the Reuse Hotline and the Business Reuse and Recycling Directory'.

Procurement

This section refers to The Climate Change (Scotland) Act which contains a provision allowing Scottish Ministers to make regulations requiring contracts to specify the use of recyclate.

One respondent (Pack) raised 2 queries:

• What is the definition of 'recyclate' i.e. process/commercial scrap? Or post consumer recycled (PCR) materials?
• Are there currently any Government contracts in place that specify the use of recyclate?