Publication - Impact assessment
Wet wipes containing plastic - proposed ban: strategic environmental assessment
Consultation on strategic environmental assessment (SEA) for the proposed ban on the manufacture, supply and sale of wet wipes containing plastic.
8 Appendix A: Addressing responses from the statutory consultees following the screening and scoping reports produced for the SEA
| Reference | Response from statutory consultee | Commentary / action taken by Scottish Government |
|---|---|---|
| NatureScot comments | ||
| Table - Proposed Scoping In / Out of SEA Topics | We agree with the topics scoped into the assessment. | |
| Assessment Methodology | It would be useful to have more detail in relation to how the assessment will be carried out and how the environmental effects will be assessed. This is often done through the use of SEA questions and assessment matrices, for example. SEA Objectives can be supported by a list of more detailed criteria or questions which can be added to an additional column in Table 3: SEA Objectives to help focus the assessment and aid in considering the likely significant of environmental effects. For example, the water environment could ask: “To what extent will the proposed ban of wet wipes affect the ecological status of water courses/bodies?” In conjunction with this, assessment matrices are often used to present the findings of the assessment using a scoring system (e.g. +/++/-/--/?/0) as well as commentary to provide detail and explain the level of significance of any environmental effects. It would be useful to draft an example assessment matrix which includes the score, commentary, and enhancement measures. | SEA questions and assessment matrix used. Suggested question included, and other questions added in similar format. |
| We note under Section 4.4 Identifying mitigation and monitoring proposals that the proposals are expected to only provide positive effects and so mitigation measures have not been considered however it would perhaps be useful to consider any potential enhancement measures. | Short section added. | |
| Table - SEA Objectives | We welcome the SEA Objective to enhance marine and coastal ecosystems as well as safeguarding in line with NPF4’s objective to secure positive effects for biodiversity. | |
| Some of the objectives could be more ambitious and measurable. For example, the objectives which aim “to work towards achieving ‘Good Environmental Status’”. This will also be challenging to assess and monitor. We recommend amending this as follows: “To achieve ‘Good Environmental Status’…” | Banning wet wipes containing plastic will not result in all plastic items being banned, and marine plastic litter will still exist. Therefore this proposed ban will not result in GES being achieved, this will only be done through a wider set of policy and actions to tackle the wider problem of marine litter and marine plastics. | |
| Similarly, in relation to the Material Assets topic, we think the wording could be more ambitious and measurable. It would also be useful to be more specific in relation to the type of infrastructure damage. As such, we recommend amending as follows: “To work towards” with “Reduce further damage to infrastructure…” | Banning wet wipes containing plastic will not result in all sewage-related debris items being banned, and such items will still enter the sewage system. Therefore this proposed ban will not result in a definite and measurable reduction in damage to infrastructure. | |
| Identifying mitigation and monitoring proposals | We note that the proposals are only expected to provide positive effects and so mitigation proposals have not been considered. In terms of monitoring, the use of SEA questions (or another more detailed, robust assessment method), as noted above, will increase transparency and support the monitoring process. | See above. |
| Consideration of reasonable alternatives | We note the consideration of reasonable alternatives and Scottish Government’s conclusion that there are no reasonable alternatives to the proposed ban. | |
| Initial Environmental Baseline | It is interesting to note that the ban itself will not have a significant impact on the environmental baseline but the impact will be indirect through improving the ecosystem and reducing the source of marine litter. | Banning wet wipes containing plastic will not result in all plastic items being banned, and marine plastic litter will still exist. Therefore this proposed ban will not result in a significant change to the environmental baseline, this will only be done through a wider set of policy and actions to tackle the wider problem of marine litter and marine plastics. |
| It would be useful to have a fuller summary of the existing environmental problems under each of the scoped in topics as well as the likely future changes to the environment without the plan. | This has been done. | |
| We recommend including a list of relevant plans, programmes and strategies (PPS) such as Scotland’s National Marine Plan and the Scottish Biodiversity Strategy with some commentary outlining how these PPS impact the objectives and assessment on this plan. | Section added. | |
| Next steps | We are content with the proposed 12 week consultation. | |
| SEPA comments | ||
| Assessment Methodology | We support the use of SEA objectives as assessment tools as they allow a systematic, rigorous, and consistent framework with which to assess environmental effects. However, it would have been useful for the scoping report to have included more detail on how the assessment will be set out. The results of the assessment in the Environmental Report should provide enough information to clearly justify the reasons for each of the assessments presented. It is also helpful to set out assumptions that are made during the assessment and difficulties and limitations encountered. | Further SEA questions have been included. |
| Mitigation and monitoring proposals | It is noted that the proposals are only expected to provide positive effects therefore mitigation measures have not been considered. However, we encourage you to use the assessment to think about proposals for enhancement of positive effects. | Short section added. |
| Section 5.2.2 states; “We will monitor the environmental impacts of the proposed ban through the abundance of wet wipes found as marine litter on Scottish beaches.” Who will carry out the monitoring, and how will it be carried out and funded? Will the Scottish Government use the data collected by other existing bodies working in this area? | National and European level data collection programmes will supply the data, as outlined in the environmental baseline information. | |
| Consideration of alternatives | We agree with the statement in section 4.5.2 that there aren’t any reasonable alternatives we therefore support the proposed ban. | |
| Initial environmental baseline | Section 5.2.2 mentions that the environmental baseline is expected to include information and data from beach litter surveys and environmental research studies, including “The number of wet wipes per 100m of surveyed beach from litter surveys, including: ….” – there is some ambiguity as to whether the use of the terms “… expected to include …” and “… including …” suggest that data may be found from other sources. What is the proposed complete list of data sources to inform the environmental baseline and do these data sources relate to continuing data collection projects that allow them to be used in future monitoring of the impact of any proposed ban or will new data collection projects have to be established and funded? If new data collection projects are required who will fund them? | All data sources are outlined in the environmental baseline section. These are well established and ongoing data collection projects. |
| Consultation period | We are satisfied with a consultation period of 12 weeks for the Environmental Report. | |
| Historic Environment Scotland comments | ||
| Consultation period | We are content with the 12 week period you propose for consultation on the proposal and its accompanying environmental report. | |
Contact
Email: WWSEAandBRIA@gov.scot
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