Circular economy and waste route map to 2030: strategic environmental assessment - post adoption statement

4. How opinions expressed on the consultation have been taken into account

4.1 Public consultation

In 2022, the Scottish Government set out a range of proposals across the resources and waste system through an initial Route Map consultation. The consultation sought views on the feasibility and ambition of these proposals. The analysis of the responses to this first consultation was published in April 2023^[10].

A second public consultation was held from 18 January to 15 March 2024 to obtain the opinion of public individuals and organisations on the proposed measures within the Route Map and their possible impacts. Views were obtained through the completion of a questionnaire hosted on the Scottish Government's Consultation Hub. The consultation documentation included the SEA Environmental Report along with online links to the Business and Regulatory Impact Assessment, the Islands Communities Screening Assessment, a Fairer Scotland Duty Summary, and an Equality Impact Assessment.

A total of 160 responses were received from individuals (48) and organisations (112). An analysis of the second public consultation was published by the Scottish Government in August 2024^[11].

4.2 Consultation on the Environmental Report

Statutory consultees responses

The combined SEA Screening and Scoping report was shared with statutory consultees (SEPA, NatureScot, and Historic Environment Scotland) for a 5-week consultation period starting on 16 November 2022.

During the initial Screening and Scoping consultation, feedback from the statutory consultees on the Scoping Report indicated all were content with the proposed scope and approach to the assessment. Some changes were proposed around the related Plans, Programmes and Strategies (PPS), the approach to monitoring, and the suggestion of an additional objective relating to the historic environment. These suggestions were summarised and addressed in the Environmental Report (see the report's Appendix B).

No changes were suggested to the proposed assessment methodology set out in the Scoping Report.

Some further feedback on the Environmental Report was received from Statutory Consultees during the public consultation period described below.

Public consultees responses

The public consultation results were largely positive regarding the proposed Route Map content. Each set of actions was met with between 71% and 81% of respondents expressing 'Agree' or 'Strongly agree.'

The public consultation included the following four questions directly relating to the Environmental Report:

• What are your views on the accuracy and scope of the environmental baseline set out in the SEA Environmental Report?
• 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. What are your views on the findings of the Environmental Report and the proposals for mitigation and monitoring of the environmental effects?
• What are your views regarding potential reasonable alternatives, in reference to the approach set out in the SEA Environmental Report?
• What are your views on the approach to mitigation, enhancement and monitoring of the environmental effects set out in the SEA Environmental Report?

Highlights from the responses received against each of the consultation questions are set out in the following paragraphs. All insights in the section below have been taken from the independent analysis of consultation responses, published on the Scottish Government website.^[12]

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

Approximately one third of the thirty-five responses submitted to this question expressed positive views on the accuracy and scope of the environmental baseline set out in the Environmental Report. The report was described in the comments as "comprehensive", "accurate", and "robust".

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 one respondent stated that the SEA, while accurate based on current data, fails to account for population growth.

Suggestions for improvements included greater 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.

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 thirty-eight responses to this question. 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.

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 given the Scottish Government's ambitions for housebuilding and infrastructure.

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 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.

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

Twenty-five responses were submitted to this question, but few comments engaged directly with the subject matter of the question. Approximately half were wider comments on the Route Map as a whole.

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.

What are your views on the findings of the Environmental Report and the proposals for mitigation and monitoring of the environmental effects?

Twenty-four comments were submitted against this question. Most 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 respondents emphasised the need for clear metrics and indicators of success, with Glasgow City Council suggesting that 'Cornerstone Indicators' 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.

The responses to the consultation were welcomed by the Scottish Government.

A number of common themes emerged across the consultation responses. These included:

• The need for additional detail on specific measures. A number of respondents noted that the Environmental Report was a high-level document containing a significant level on uncertainty.
• The need to future-proof measures and associated effects, for example, considering future population growth.
• The resource requirements of the measures within the Route Map and the importance of properly resourcing both their implementation and monitoring.

The Scottish Government recognises that some measures will require additional, more detailed impact assessments in future prior to implementation. These will be produced in due course, where appropriate. The Scottish Government reiterates its commitment to work in partnership with stakeholders to assess the full impacts of specific measures as they are further defined to ensure they remain feasible, impactful and avoid any unintended consequences. We recognise that, where appropriate, individual measures set out in the Route Map may be subject to further public consultation, for example where secondary legislation is needed.

The Scottish Government is working within the current fiscal constraints to deliver on 11 priority actions to drive progress, setting out delivery timescales that have been arrived at through collaboration and listening to local government and business community partners to ensure they remain affordable and deliverable. The Scottish Government is committed to progressing a circular economy at pace and will continually look to increase the speed of delivery where possible, taking account of partner feedback and the fiscal situation. This approach will help ensure appropriate resourcing for delivery of the measures outlined in the Route Map, and appropriate resourcing for the monitoring and evaluation.

In light of the predominantly positive feedback on the content of the Route Map itself, the measures will be taken forward largely as outlined in the Environmental Report. The measures will be introduced with minor amendments, as discussed in section 2.2.