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

6. Measuring Progress

Background

6.1 The proposed Programme for the Efficient use of our Materials is designed to meet the requirements of the 2008 Waste Framework Directive for a waste prevention programme. The Directive requires appropriate benchmarks for waste prevention measures, with indicators to monitor these. The Scottish Government proposes to set:

• An overall target of a 5% reduction in all waste by 2015 against a baseline year of 2011.
• A longer term vision of a 15% reduction in all waste by 2025.
• Headline indicators relating to:
  • amount of waste produced (in different categories)
  • carbon impact of waste
  • amount of waste produced per unit of GDP/GVA in Scotland

Question O: We would welcome comments on these proposed targets and indicators, in particular views on the merits of an absolute target or one relative to GDP, given the strong relationship between economic growth and waste generation in previous years.

6.2 Overall, 528 respondents addressed this question, of which 490 resulted from the WWF campaign and 38 were standard responses.

General comments on targets

6.3 Whilst general support was given by many respondents to the principle of overarching targets, some expressed reservations that those proposed appeared to lack the context of a broader strategy. Two respondents recommended that any Scottish strategy should be linked with the EU Resource Efficiency Roadmap. One respondent (Man) urged that the experiences of other countries regarding targets and indicators are taken on board.

6.4 Other general requirements of Scottish targets and indicators suggested were:

• should be associated with a consistent approach to reporting of performance (3 mentions)
• achievement must be weighed against the costs generated (1 mention)
• should not be commercially disadvantaging businesses operating in Scotland (1 mention)
• in the measurement of progress towards overall targets, it must still be possible to identify at micro level where reductions can be achieved (2 mentions).

Specific comments on the targets proposed

6.5 The 490 WWF campaign responses urged that the scale of ambition reflected by the targets should be increased, with an aim to cut waste volumes by half by 2025. Whilst one standard response (LA) considered the 15% waste reduction target ambitious in the context of economic growth returning to previous levels, other standard responses considered the headline targets not challenging enough. Recommendations included doubling the targets (Ind); making them more in line with the more ambitious Welsh Assembly targets (NGO); or more stretching like those for carbon emissions reduction (80% by 2050) (Pub-Oth). Three of the standard responses questioned what policy initiatives will be put in place to achieve a further 10% waste reduction after the initial 5% by 2015. One retailer suggested that the longer term target of 15% waste reduction should be reassessed in the light of progress towards the 5% target as lessons may emerge which could strengthen the 2025 target.

6.6 A perceived lack of accuracy of the baseline data in particular concerned four respondents, with COSLA welcoming more consideration of this matter.

6.7 Other comments included:

• The mantra of "Zero Waste" should be replaced with a more meaningful message such as a vision of efficient use of valuable materials (2 mentions).
• There is inconsistency in that the commercial and industry sectors are included here in waste arisings yet excluded from the Waste (Scotland) Regulations recycling targets (1 mention).
• Prefer to see the targets apply to all waste and not just municipal waste (1 mention).
• How will the weight-based targets and the carbon metric-based measurements work together? (1 mention)
• Need to take account of the predicted increase in population and household numbers in some areas and the increase in waste arisings this will generate (1 mention).
• There are already numerous targets associated with the Zero Waste Plan. No further targets should be set (1 mention).
• The headline targets are too simplistic. One respondent remarked:
  '....targets such as 5% overall are a crude method of monitoring progress and are exposed to economic influences that the sector has no control over' (Clackmannanshire Council).

Views on whether targets should be absolute or relative to GDP

6.8 Eighteen respondents provided a view on the merits of an absolute target or one relative to GDP, given the strong relationship between economic growth and waste generation in previous years. Of these, one (WM) recommended further debate and consideration of this topic before final decisions are made. Another (PR-C) did not consider GDP and waste generation to be inextricably linked. Not all of the others provided a clear view one way or the other, but overall the main balance of view was in favour of linking targets to GDP which was seen as providing context, being readily available and fitting with the agenda of economic growth.

6.9 Three of the 18 respondents were very clear that targets should be absolute. One (Retail) commented that absolute targets are more accurate. Another considered that absolute targets would reflect the need to drive down the use of resources in a sustainable manner (Pub-Oth). The third argued that unless absolute measures are used, overall growth in consumption will 'swamp those gains' (Changeworks).

Views on the carbon impact of waste indicator

6.10 Of the proposed indicators, the carbon impact of waste attracted most attention. Broad opinion was that the indicator will be very useful and important in measuring advances in both prevention and recycling. However, challenges were envisaged in terms of:

• requirement to analyse the contents of waste collected, which could be costly
• application to industrial waste is difficult.

Other proposals for indicators

6.11 A few respondents identified further indicators which they considered could provide useful information on progress towards the targets:

• capture rate into recycling/recovery or reuse - measuring how efficiently materials are recovered (LA)
• flows of WEEE collected and recycled by all actors (Man)
• ratio of raw materials to recycled materials (Retail)
• the proposed indicators, with data disaggregated by sector (Retail)
• supplementary indicators (such as levels of community engagement; indicators focused on environmental impact) in order to take more account of other contextual factors which have a significant bearing on the amount of resources used in Scotland (Pub-Oth).