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

7. Strategic Environmental Assessment (SEA)

This chapter provides an analysis of the four questions about the Strategic Environmental Assessment. For further information, review the full document that was published by the Scottish Government alongside this consultation.

Q13: What are your views on the accuracy and scope of the environmental baseline set out in the SEA Environmental Report?

There were 35 responses to Q13. Approximately a third of these responses expressed positive views about the accuracy and scope of the environmental baseline set out in the SEA Environmental Report; the report was described in comments as “comprehensive”, “accurate” and “robust”.

“The scope and environmental baseline of the SEA appears proportionate across the themes and priority actions to further understand the impacts across the various environmental topics from the Route Map.” – 'One Bin to Rule Them All' Team, University of Manchester

Others described the SEA as high level and lacking in detail, with calls for more timescales and specific examples. One respondent described the content as “aspirational” and Stirling Council stated that the SEA, while accurate based on current data, fails to account for population growth.

A few organisations, including RMAS and Dundee City Council welcomed the baselining exercise but advised it must be applied consistently to allow direct comparisons between regions and other nations.

Dovesdale Action Group felt that the SEA could be enhanced by including more commentary on the impact of failing to progress the Route Map’s actions on public health, food production and the national economy. Historic Environment Scotland noted that the ‘Our Place in Time’ strategy referenced in the SEA has now been superseded by Scotland’s new strategy for the historic environment, ‘Our Past, Our Future’ (OPOF) which was published in April 2023.

Q14: What are your views on the predicted environmental effects of the draft Circular Economy and Waste Route Map as set out in the SEA Environmental Report? Please give details of any additional relevant sources.

There was little consensus among the 38 responses to Q14. A few respondents described the predicted effects as ‘accurate’, agreeing that on the whole, the measures are likely to have a positive environmental impact. However, a few highlighted that the predicted effects are based on successful implementation of the measures in the Route Map, which can only be achieved through adequate resourcing and significant positive behaviour change.

“If all of the objectives of the draft Circular Economy and Waste Route Map are achieved, the predicted outcomes are all positive. However, the costs of implementation have yet to be established and a full package of funding made available. Local Authorities are not currently in a position to take on increased financial obligation, so this must be funded by producer responsibility or direct Scottish Government revenue support. There is also a substantial need to achieve behavioural change.” – Comhairle nan Eilean Siar

A few reflected on the increased resource required to transition to a circular economy and questioned whether the environmental impact of this had been adequately considered in the SEA. Mineral Products Association Scotland disagreed with the conclusion that the measures proposed in the draft Route Map will lead to reduced demand for primary aggregates, arguing there is little scope for this in light of the Scottish Government’s ambitions for housebuilding and infrastructure.

As with other questions, a few respondents felt that this aspect of the SEA lacked sufficient detail and evidence. Aberdeenshire Council described the predicted environmental effects as “loosely indicative” given the high-level nature of the Route Map. Stirling Council repeated concerns that the predicted environmental affects do not account for population growth.

Scottish Islands Federation Marine Litter Working Group Looking commented specifically on the SEA’s table of likely results, highlighting the “significant number of question marks” and suggested that further scoping is required before significant changes in legislation are initiated.

British Glass raised concerns that the reduction in the production of new components as a way of reducing Scotland’s impact on the environment will move production to other countries that may have less environmentally friendly production processes.

Very few respondents provided details of additional relevant sources to consider; a few recommended further consultation with communities, SMEs and industry bodies.

Q15: What are your views regarding potential reasonable alternatives, in reference to the approach set out in the SEA Environmental Report?

While Question 15 received 25 responses, few comments engaged directly with the subject matter of the question. Approximately half were wider comments on the Route Map as a whole, for example discussing concerns about overconsumption and overdevelopment of land, the role of big business in tackling climate change and concerns about the burden of the measures on local authorities.

Of the comments that did consider the approach to assessing reasonable alternatives as set out in the SEA, most were in agreement with the Scottish Government’s decision to not identify any additional alternatives at this stage given the broad and high level nature of the Route Map.

However, United Kingdom Without Incineration Network (UKWIN) and Dovesdale Action Group called for consideration of alternative options, including: all-in plastic collection, a ban on new incineration capacity, middle band of Landfill Tax for bio-stabilised material, and the introduction of an incineration tax to minimise leakages from the circular economy.

Comhairle nan Eilean Siar advised that any reasonable alternatives must be assessed individually and in context with local circumstances.

Q16: What are your views on the approach to mitigation, enhancement and monitoring of the environmental effects set out in the SEA Environmental Report?

Question 16 received 24 comments. Most of these comments were supportive in nature, welcoming the approach to mitigation, enhancement and monitoring as set out in the SEA Environmental Report and recognising the need for a robust monitoring framework to support evaluation of the environmental effects of the Route Map.

A few emphasised the need for clear metrics and indicators of success, with Glasgow City Council suggesting that ‘Cornerstone Indicators^[7]’ could be considered as a way to assess the impacts of the Route Map.

Two respondents, while supportive of the approach, highlighted the additional resourcing such measures will require. Aberdeenshire Council advised that the approaches to mitigation, enhancement and monitoring will need to be flexible as actions and measures are developed and implemented.