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

2. Business Resource Efficiency

Business Resource Efficiency Support (Resource Efficient Scotland)

2.1 The Scottish Government proposed, by April 2013, to develop a new single business resource and energy efficiency service which will replace the business and public sector energy and resource efficiency advice currently delivered through Carbon Trust, Energy Saving Trust and ZWS.

2.2 The new service will offer comprehensive information, advice and support to business and public sector organisations including a specific focus on supporting SMEs to implement waste, energy and carbon efficiency measures that will translate into cost savings and increase competitiveness.

Question A: We have already decided to go ahead with the integrated Business Resource Efficiency service and are engaging directly with stakeholders over how it should be focused. We would however, welcome views on the priorities for the new integrated service.

2.3 Forty eight respondents (48% of standard responses) addressed this question.

Reasons given in support of the proposal

2.4 All of those who provided a view supported the proposal. Five substantive reasons were provided in support:

• Will result in a more streamlined and efficient 'one-stop' shop approach which is easier to access than the present arrangements (15 mentions). Typical comments were:
  'An integrated service should enable a more efficient delivery of advice to businesses, with a one stop shop making signposting of advice simpler and easier to access information, advice and funding' (Highland Council).

  '....hope that this will streamline the often confusing and cumbersome process through which small businesses, often with limited administrative resources, must go through to receive the necessary and correct support to reduce waste and achieve efficiency savings' (Scottish Grocers' Federation).

• Particularly helpful for SMEs (3 mentions).
• Will allow shared expertise, experience and strengths of the individual bodies to be pooled (2 mentions).
• Good for the many companies which do not have the technical skills to improve their resource efficiency and cannot buy in help (1 mention).
• Good to have both domestic and public bodies coming under the same support umbrella (1 mention).

Vision for the new service

2.5 It was proposed that a title for the new service should reflect its role in serving both the business and public sectors (LA). One respondent proposed the title of 'Resource Efficiency Scotland' (The Chartered Institution of Wastes Management). Two NGOs urged that the service is prominently advertised; another recommended a central location (WM).

2.6 Clarity was requested (2 respondents) on whether the service will be free, and if not, how access will be priced. One considered that:

'Uptake of the service will likely be inversely proportional to the cost of accessing the service' (Scottish Borders Council).

2.7 One respondent (Man) urged that the new service should be positioned as an advice service rather than a quasi-public policy regulatory body.

2.8 Three respondents envisaged the service as providing web-based information and tools. Two respondents considered that its functions should incorporate training and accreditation. It was recommended that the service should have a role in directing SMEs to local points of contact in addition to providing centralised support (2 mentions).

2.9 Three respondents recommended that the service be able to offer site visits. One commented:

'New approaches to reaching out to the small businesses are required. It is suggested that dedicated advisors are assigned to small businesses to 'walk through' and assist, hands on if necessary, with implementing change' (Clackmannanshire Council).

Suggestions for priorities for the new integrated service

2.10 A recurring comment (9 mentions) was that the service should focus initially on areas offering most savings for least input. For example:

'We believe that this service should focus on practical and easily implementable measures that will deliver both cost savings and resource efficiency outcomes for business' (Valpak Ltd).

2.11 Other recommendations were for:

• information on the legal requirements with regard to the Waste (Scotland) Regulations 2012 (5 mentions)
• management of recyclables (4 mentions)
• carbon efficiency plans (2 mentions)
• energy efficiency (2 mentions)
• water efficiency (1 mention)
• products which can help to achieve reduction of energy use (1 mention).

2.12 One respondent (WM) considered that it is difficult to set national priorities as different businesses have different priorities.

Outstanding concerns

2.13 Despite supporting the proposal, some respondents identified concerns or issues which they felt needed to be addressed in setting up the new service. One recurring comment (7 mentions) was that the Scottish Government should engage with stakeholders including trade association groups in establishing the role and nature of the new service. Others (5 mentions) urged that the there should be no deterioration of service as a result of the integration of different bodies into the one service.

2.14 Other concerns were:

• the need for consistent and impartial advice (2 mentions)
• how will the new body be managed/funded/evaluated? (2 mentions)
• how will the new body interact with support delivered by other bodies? (2 mentions)
• a need to ensure there is no duplication of effort as the different bodies merge (1 mention)
• the new service should also engage with larger organisations such as Scottish Water (1 mention).

Voluntary agreements with businesses

2.15 The Scottish Government proposes to ensure that voluntary agreements with business sectors work well in Scotland and include a focus on waste prevention - both through engaging positively with proposals for new UK or Scottish agreements and reviews of existing agreements. Although the consultation did not specifically seek views on this proposal, 14 respondents commented on this proposed action. Their comments are summarised below.

2.16 Seven respondents simply expressed support for the proposal with existing voluntary agreements perceived by them to be working well. One respondent remarked:

'....the Scottish Government is right to want to seek to develop voluntary agreements with businesses and sectors in relation to resource efficiency. Such an approach can be both constructive and effective' (CBI Scotland).

2.17 Other respondents qualified their support by stating that voluntary agreements can be effective so long as certain conditions are met:

• clear objectives and priorities are set (Retail, Pack)
• the agreements are evidence-based and accompanied by evaluation (Retail)
• the reporting requirements are clear and simple (PR-C)
• there is business buy-in (Retail)
• there is good communication between individual businesses/sectors and government officials (Business)
• agreements are bespoke to the sector (Man)
• agreements take account of waste producers as well as the waste management industry (LA)
• as a minimum, pledges should commit businesses to meeting their responsibilities and regulatory obligations as prescribed by the duty of care and Waste Scotland regulations (WM)
• most likely to help achieve targets set out in the consultation if broadened to include water, transport and energy (Pub-Oth)
• stakeholders from across the sector are involved in the establishment and running of the voluntary agreement, creating industry ownership and responsibility (Pub-Oth)
• targets promote real environmental improvements (Pub-Oth)
• results are transparent (Pub-Oth).

Concerns relating to voluntary agreements

2.18 A minority of respondents expressed concerns about the proposed action. One waste management respondent expressed doubts over whether voluntary agreements are capable of bringing about real change. Another waste management respondent considered it a drawback that companies are not made to sign up to such agreements, allowing some to avoid otherwise regulatory obligations. One respondent commented:

'....this must not be perceived by the business community as a 'soft option' to avoid new (and existing) regulatory obligations' (Scottish Environmental Services Association).

One retailer urged that voluntary agreements should not present companies with an unnecessary burden.

Zero Waste Pledges

2.19 The Scottish Government wishes to see proactive companies in Scotland gain recognition through pledging their commitment to zero waste. They propose that ZWS develops a high level Zero Waste Pledge system with a menu of actions open to companies of any size, such as waste prevention planning, staff training, adopting sustainable procurement guidelines and reporting on their achievements. ZWS will work to encourage Scottish companies to sign up and support signatories to take actions.

Question B: We would welcome views on the type of 'Zero Waste Pledge' companies might be interested in signing up to and the type of support needed.

2.20 Forty one respondents (41% of standard responses) addressed this question including 12 of the 14 local authorities, with much cross-sectoral support expressed in general for the proposal which was seen to have benefits for companies largely in terms of showcasing their good intentions, commitment and 'green' credentials.

2.21 A recurring theme (10 mentions) was for the scope of the pledge to be widened to encompass 'resource efficiency' rather than focus solely on waste. This was seen as more reflective of the holistic approach to efficient use of all resources adopted by businesses.

2.22 Many respondents expressed their broad support but only if certain conditions are met. These are listed below from most mentioned to least mentioned.

• Targets should be meaningful, realistic and measurable (9 mentions). Comments included:
  'The concept of zero waste is too theoretical and unrealistic for many sectors and we would consider 'significant reductions and 100% re-use or recycling to be more motivating' (Marks and Spencer).
  'Zero waste is the wrong message - indeed this is not even the 'target' and it will be impossible to get people on board with this vision' (SGL Carbon Fibers Limited).
• The pledge should not place an additional burden on businesses (7 mentions).
• Monitoring of performance should be ongoing and transparent to ensure the credibility of claims of achievement (6 mentions).
• Reporting should use simple and clear indicators and should be aligned with existing reporting arrangements (3 mentions).
• Should not duplicate existing arrangements which could lead to 'market clutter' (3 mentions).
• Needs to be able to accommodate organisations of different types (e.g. both public and commercial sectors) and of different sizes (2 mentions).
• There should be robust evidence of commitment and performance (2 mentions). One respondent remarked:
  'Making a pledge can be good for organisations in marketing their environmental credentials but it should be combined with more tangible evidence that they are working towards reducing their carbon footprint, rather than ticking a few boxes' (Highland Council).
• The pledge should remain voluntary and not mandatory (1 mention).
• Should not be overly prescriptive so as to restrict innovative action (1 mention).
• Should involve businesses (1 mention) and the community (1 mention) in developing the agreement.

2.23 Seven respondents suggested that incentives, particularly economic benefits, could be advantageous in underpinning the initiative. Two recommended that the pledge should become embedded into procurement policies so that companies are required to sign up to the pledge in order to tender for contracts. Other ideas for incentivising the scheme, each mentioned by one respondent were business rate reductions and tax breaks and rebates. Two local authorities considered that organisations may need help in identifying the particular benefits of the pledge for them and how incentives could play a part.

2.24 A few respondents outlined other types of support which companies may need. Two local authorities suggested an online website with measuring and monitoring tools, examples of good practice, local contacts for support, tips, advice and so on. Another local authority described their success in establishing a Zero Waste 'champion' dedicated to this topic, with resulting benefits for their organisation. A waste management company remarked that many companies do not know the cost of their waste and may need support in drawing up their waste prevention plan. They recommended companies sign up to other pledges too (e.g. Courtauld commitment) as this would help by generating company-specific information. One retailer considered that by being provided with examples of good practice, organisations will gain confidence in the achievability of the pledge.

2.25 Few remarks were made wholly in opposition to the proposal. However, three respondents expressed their concern that if the pledge remains voluntary, there will be no guarantee that any organisations bar the 'usual suspects' will take part.

Preventing construction wastes

2.26 Construction and demolition waste represents around 44% of total waste produced in Scotland^[7].

Question C: For companies and organisations involved in the construction sector, do you agree with the principle of a new voluntary agreement, following on from 'Halving Waste to Landfill', encompassing the impact of design on both construction waste and materials? We would also welcome views on the level of ambition for such an agreement.

2.27 Twenty nine respondents (29% of standard responses) addressed this question as follows:

	No.	%
Agree with principle of new voluntary agreement	14	48
Partially agree	7	24
Disagree	4	14
Commentary only	4	14

Responses were submitted from across a wide range of sectors with no obvious pattern emerging in where the support and disagreement lay.

2.28 Supporters of the proposed new voluntary agreement outlined what they perceived to be its key benefits. It was thought that committing to the agreement would bring indirect financial and competitive advantages to organisations. They were seen as better able to promote their business in the construction sector on the basis of this commitment. The new voluntary agreement was seen as helping steer strategy at organisational level. One respondent remarked:

' ....it would give clear indication to the construction industry of the direction the Scottish Government is moving towards, as well as influencing investment decisions' (AmeyCespa Ltd).

Several respondents agreed that the proposal will help to progress the designing out of construction waste.

2.29 Ten respondents (six of them local authorities) expressed concern that the proposal is for a voluntary rather than a mandatory agreement. It was felt that smaller SMEs in particular may not sign up without statutory requirement. Two respondents urged that any new scheme avoids duplication with existing programmes. A further two respondents suggested that the agreement may need to be adapted for small, domestic projects involving micro-construction companies. One individual respondent suggested that the scheme might be simpler if it incorporated economic incentives. One NGO considered the ambition to halve waste to landfill was 'commendable' but perhaps not realistic.

The value of data and tools

2.30 For any business to reduce its resource use, it needs first to understand how much it is using. The Scottish Government proposes that for those 500 or so businesses with the greatest potential environmental impact, the Scottish Environmental Protection Agency (SEPA) will develop the use of Resource Utilisation Assessments (RUAs) to drive resource efficiency. This will include guidance, training and focus on RUAs during audits, and will be in line with the principles of better regulation.

Question D: For companies with existing RUAs, we want to hear any lessons or good practice points to help us make sure future guidance on RUAs is as useful as possible in enabling relevant businesses realise resource savings.

2.31 Eleven respondents (11% of standard responses) representing seven different respondent sectors addressed this question. Five specifically outlined their support for actions to improve the quality of data available to businesses in order to help them to be more resource efficient. One respondent (Pub-Oth) urged that any changes to data collection should be done in consultation with industry.

2.32 Five respondents emphasised that good practice in RUAs along with all data collection should avoid placing additional administrative burdens on organisations. One respondent commented:

'While monitoring can allow business to identify efficiency savings, it is essential that it does not divert resources away from genuine improvement and innovation. Data collection will yield the most positive results if the data is already available, and where this is not possible business must be supported through the learning curve' (Scottish Council for Development and Industry).

2.33 One respondent expressed doubts over the added value of benchmarking resource efficiency (WM); another raised their concern that there may be general confusion over what RUAs are (NGO).

Waste Management Industry Role

2.34 The waste management industry is uniquely placed to help their clients move from waste disposal to advising on how to manage resources more efficiently to maintain the maximum value. The Scottish Government proposes that it along with ZWS will explore with the waste management industry the potential for a voluntary agreement to provide resource efficiency services to their customers and help them reduce waste.

Question E: For waste management companies, would you be interested in signing up to a voluntary agreement to provide resource efficiency advice to your customers?

2.35 Twenty three respondents (23% of standard responses) addressed this question including 11 of the 14 local authorities responding to the consultation and four of the six waste management companies. Overall, 21 were generally supportive of waste management companies signing up to such a voluntary agreement. Two respondents (Man, LA) provided arguments against the proposal. All four waste management companies were amongst the respondents supporting the proposal.

2.36 Ten local authorities requested that councils should also be able to sign up to the voluntary agreement, arguing that advising on resource efficiency is already part of their remit. One typical comment was:

'We believe this is also applicable to the council as waste authority as this would be beneficial to help maximise the local authority's waste services available to businesses. It would also help the local authority to progress towards the Zero Waste targets set out in the Waste (Scotland) Regulations 2012' (Dumfries and Galloway Council).

Concerns about the proposal

2.37 The reasons provided in opposition to the proposal were:

• The proposal appears to conflict with Action 1 by adding another party to the provision of advice to business (LA).
• Seems to present a conflict of interest for waste management companies who would be better off striving to be more efficient and effective in what they do (Man).

2.38 Despite providing support in principle, potential conflicts of commercial/procurement interests were highlighted by others, with two local authority respondents suggesting that individual waste management companies should be encouraged to provide consistent advice, and not be driven by their own commercial interests and sensitivities. One suggestion to make the option of signing up more attractive was to offer accreditation to engage the waste management industry (NGO).

2.39 Two respondents (both local authorities) considered that there may be staff resourcing and training issues should the proposal be extended to encompass local councils.

2.40 A waste management company argued that the approach should not be overly prescriptive or try to dictate the arrangements between businesses and their waste providers.

2.41 One view was that the voluntary requirements should be tailored to the size of the company:

'....for such a scheme to be effective it has to a) be widely used in the industry and b) recognise that standards expected from large, national waste companies may not be appropriate for small, community 'niche' waste organisations' (Federation of Small Businesses).

2.42 A few other relevant comments were made by respondents. One local authority argued that the voluntary agreement should have two sides to it, with waste producers also having clear responsibilities to fulfil their part of the agreement. Another local authority recommended that the voluntary agreement should be linked to national and local waste management awareness campaigns.

2.43 One waste management company suggested that the Scottish Government should refer to the Defra/ESA Responsibility Deal for an indication of the measures which the industry would be willing to sign up to.

2.44 A local authority respondent questioned whether support and training would be available for waste management companies who have signed up to the agreement.

Question F: For other companies, what more would you want to see in terms of advice on resource savings and recycling from your waste management contractor? (Action 6)

2.45 Eighteen respondents (18% of standard responses) addressed this question. Half of these respondents were either local authorities or manufacturers. The responses are summed up below in order from most mentions to fewest.

• Waste management infrastructure including good practice guidelines on reducing waste (4 mentions).
• Range of data services to help businesses understand better what can be thrown away (4 mentions).
• Identification of process improvements and efficiencies including the carbon footprint of the customer's operations (4 mentions). However, in contrast one respondent commented:
  'While advice on resource efficiency may be helpful and provide a firm with a competitive edge, this is probably not something a small business would expect from their waste collector. It would, perhaps, be better to expect waste collectors to signpost business customers to the Business Resource Efficiency Support service' (Federation of Small Businesses).
• Better transparency of billing to give customers more understanding of resource efficiency opportunities (3 mentions).
• Information on the destination of recycled materials (2 mentions).
• Guidance on/assistance with segregation of materials for recycling (2 mentions).
• Advice on options for baling/compacting (1 mention).
• Information on takeback schemes/reverse vending (1 mention).
• Advice on how to handle 'problem' materials (1 mention).
• Information on the National Industrial Symbiosis Partnership (1 mention).
• Sources of funding available to implement more costly resource efficiency measures (1 mention).

2.46 Three respondents raised their broad concern that waste management companies may not provide impartial advice, as they have a vested commercial interest in the outcome. One potential solution was provided by a local authority:

'advice should be driven centrally by either the Scottish Government or ZWS to ensure there is a continuity of advice and good practice being delivered by waste management companies but also allowing customers to 'shop around' for the best price. If this type of advice was delivered direct by individual waste management companies it would be tailored to their specific preferred methods rather than the best method for that individual customer' (Inverclyde Council).