Scotland's Circular Economy and Waste Route Map to 2030 : Analysis of consultation responses

6. Impact Assessments

This chapter provides an analysis of the four impact assessment questions. While the publication of the Route Map itself will not result in any direct impacts, the Scottish Government wishes to assess how a specific intervention may have an impact if introduced. The impact assessment questions cover equality, socio-economic considerations, island communities and business and regulation.

For further information, review the impact assessments that were published by the Scottish Government alongside this consultation.

Q9: Please provide any further information or evidence that should be considered in the accompanying Equalities Impact Assessment.

Of the 30 responses received under Q9, the most common theme was a desire for further and ongoing consideration of the potential impact of the proposals on protected groups, such as people with disabilities and mental health conditions, the elderly and those who face language barriers. A few emphasised that any enforcement activity must take into account the personal circumstances and individual needs of those with protected characteristics. Common Weal highlighted that those within the protected characteristics of disability, age, race, and sex are more likely to be food insecure, and would therefore more likely to be affected by any measures intended to reduce food waste.

The British Soft Drinks Association described the Equalities Impact Assessment as effective in addressing ‘pertinent considerations’ and did not feel any further information or evidence was required for consideration. Comhairle nan Eilean Siar agreed that they had “no areas of concern” with the Equalities Impact Assessment.

Glasgow City Council called for more detail on which parties will be involved in the co-design processes mentioned in various proposed actions.

A few individuals questioned the need for an equalities impact assessment on the Route Map, with one arguing the impact of the measures will be felt equally by “everyone”.

Q10: Please provide any further information or evidence that should be considered in the accompanying Fairer Scotland Assessment.

There were 25 responses to Q10. Among those, the most common theme was concern about the socio-economic impacts of the proposals on low-income households, with some respondents emphasising the need to ensure that the proposals do not inadvertently adversely affect these groups. The British Holiday and Home Parks Association highlighted specific concerns around vulnerable and low-income households living on residential parks, noting that they may not be in a financial position to make significant changes to accommodate additional environmental changes and waste management. Dundee City Council cautioned that the proposals may inadvertently result in an unfair impact on those relying on surplus food, and advised that this should be considered moving forward.

Two respondents raised concerns about the socio-economic impact some proposals may have on rural communities given the additional costs and challenges with circularity and waste disposal in remote, rural and island towns.

A few respondents considered the Fairer Scotland Assessment to be adequate and felt that no further information or evidence needs to be considered.

Q11: Please provide any further information or evidence that should be considered in the accompanying Island Communities Impact Assessment.

Nineteen comments were submitted under Q19. The most common theme among these was a call for greater consideration of the increased costs and additional challenges with circularity and waste disposal in remote, rural and island areas.

“Any changes to waste management and associated circular economy regulation that creates specific burdens on Island local authorities need to be identified and fully costed. If there is an additional financial burden on island authorities, additional financial support must be provided. If there are technical reasons why any element of any of the proposed plans cannot be implemented due to Island-specific restrictions (e.g. limited ferry capacity, Energy from Waste facilities not available on-island) an alternative solution or derogation must be permitted.” – Comhairle nan Eilean Siar

The Scottish Islands Federation Marine Litter Working Group felt that the challenges in relation to Marine Litter and the lack of facilities or support from Local Authorities to pick-up and recycle waste had not been adequately considered in the Impact Assessment.

Orkney Islands Council welcomed the inclusion of the Island Communities Impact Assessment, and the British Soft Drinks Association considered the document adequate and did not feel any further information or evidence was required for consideration.

Q12: Please provide any further information or evidence that should be considered in the accompanying Business and Regulatory Impact.

The most common theme among the 32 responses to Q12 was for a desire for further consideration of the financial impact of the proposals on businesses. A few respondents highlighted the lack of data, cost impact assessments and targets within the BRIA and called for more detailed evidence to be included. Others requested more specific consideration of the impact of the proposals on different types of businesses in terms of size, sector and rurality, stressing that a ‘one size fits all’ approach is not sufficient.

“We would ask that the Business and Regulatory Impact Assessment takes care to consider all different sizes and sectors of business, as the potential impact of these policies and actions could vary hugely depending on these factors.” – Edinburgh Chamber of Commerce

While the British Standards Institution welcomed the Scottish Government’s commitment to working collaboratively with the business community on the draft Route Map, the British Holiday and Home Parks Association felt there was a lack of transparency regarding which businesses and business groups have been consulted throughout the process. Some respondents called for greater collaboration with SMEs and industry bodies in order to fully explore and understand the potential impact of the proposed measures on businesses. A number of respondents, including British Holiday and Home Parks Association and Scottish Wholesale Association volunteered to engage with the Scottish Government on further development of the BRIA. SUEZ Recycling and Recovery UK Limited suggested that a cross sector approach to the ongoing development of the BRIA should be adopted.

As with the other impact assessments, a small number felt that no further information or evidence should be considered within the BRIA.