Circular economy strategy draft: consultation analysis

Environmental Impacts

The Environmental Assessment (Scotland) Act 2005 requires any plans, programmes and strategies that are likely to have a significant impact on the environment be assessed and measures identified to avoid, prevent or reduce adverse effects, where possible, prior to implementation. As such, the consultation sought views on the potential environmental impacts of the draft strategy.

In addition, the draft Strategic Environmental Assessment (SEA) Environmental Report was being consulted on alongside the draft Circular Economy Strategy. The responses received to both this and the SEA consultations will inform the final strategy and will be reflected upon in the Post Adoption Statement. The Scottish Government also intend to monitor the implementation and environmental effects resulting from implementing the strategy.

Again, a smaller number of respondents provided feedback at this section compared to earlier sections of the consultation, with 50 respondents providing comments.

Q17. Do you have any views on whether there are likely to be any positive or negative environmental impacts from the draft Environment Strategy that have not been identified in the Strategic Environmental Assessment?

Although not necessarily addressing the question directly, both individuals and organisations suggested that the SEA should explicitly consider plastics/microplastics and packaging waste. In addition, it was noted that shifting towards more sustainable packaging materials may have unintended consequences, which would require packaging innovations to be coupled with broader national and international supply chain shifts.

Other issues which individuals felt the SEA should explicitly consider included the climate impact of food waste, the health impacts of forever chemicals, and food production and farming.

Organisations also suggested that the SEA should consider the impact of the various specific proposals put forward in the strategy. This included: kerbside collection of textiles; reductions in embodied carbon through circular practices in construction and infrastructure; increased emissions resulting from transport used for movement and haulage (especially if circular activities are centralised rather than localised); and benefits that might arise from applying composts and digestates to soils.

It was also felt that there needed to be consideration of the international impacts of the strategy. This included impacts from Scotland's consumption and the potential displacement of environmental impacts internationally if circular economy measures did not sufficiently address global supply chains. It was felt that the impacts of exporting environmental harm through overseas processing of materials needed to be considered:

“We recognise that the Strategic Environmental Assessment is necessarily focused on domestic environmental effects and operates within a defined legal scope. However, this limitation means that some of the most significant environmental risks associated with Scotland’s production and consumption - particularly those related to water use and pollution embedded in global supply chains - are not captured. As a result, there is a risk that the Circular Economy Strategy is interpreted as environmentally robust based on an assessment that cannot account for impacts occurring beyond Scotland’s borders…Without explicit recognition of these limits - and complementary monitoring of international and water-related impacts - there is a risk that environmental harm is shifted rather than reduced.” (Organisation: Third Sector)

Other suggestions for environmental impacts that may be under-represented or not currently well reflected within the SEA (mentioned by just one or two organisations each) included:

• The role of small-scale, local and regenerative systems;
• Offshore specific considerations;
• The role of farming and crofting;
• Discussion of water reuse;
• Cumulative impacts of infrastructure development on the environment;
• Negative effects of continued reliance on incineration;
• Impacts of dust and noise pollution in the environment;
• Potential for increased pressure on land use or transport networks in a circular economy; and
• The positive role of education, cultural change and lifelong learning in reducing environmental harm.

Other organisations emphasised the positive environmental impacts that could result from the strategy and felt that these could be emphasised more in the SEA. This included reduced transport emissions; improved land and marine outcomes; reduced quarrying impacts; lower embodied carbon in the built environment; biodiversity gains from avoided extraction; and enhanced ecosystem resilience.

One organisation expressed disappointment with the approach to the assessment, as they felt it did not adequately consider the historic environment or the historic environment strategy for Scotland (Our Past, Our Future (OPOF)). In particular, they would have welcomed more consideration and discussion of the potential interactions between cultural heritage and the built environment.

A few organisations commented that the environmental assessment was too broad, imprecise or lacking in detail, and some linked this to the high-level nature of the strategy itself:

“Given the high-level nature of the priorities noted in the draft Circular Economy Strategy, it is difficult to see how the predicted environmental impacts contained within the environmental assessment can be anything better than loosely indicative, with the predicted impacts being more of an assessment on what could be achieved rather than an assessment on the particular actions, especially given some of the priority actions have been excluded from the SEA due to insufficient detail at present.” (Organisation: Public Body - Local Authority)

One organisation again urged consideration of other aligned policies when considering environmental impacts overall:

“Consideration should also be given to cumulative environmental impacts across strategies, particularly where circular economy infrastructure, renewable energy deployment and industrial decarbonisation coincide spatially. Coordinated planning and assessment across these agendas will be essential to ensure net environmental benefit and maintain public confidence.” (Organisation: Representative/Membership Body - Other)

Aside from comments related to the SEA, several respondents provided more general feedback about the strategy itself. Individuals suggested that:

• Measuring success and outcomes must be done in the right way with measurable, time-bound actions, but should not overemphasise targets at the expense of other outcomes;
• Focus should be on producers/suppliers and consumers proportionately across the strategy;
• The roll out of the strategy must be phased and practicable; and
• The strategy should consider the risk of rebound effects (also reiterated by one organisation):

“…where efficiency or circularity interventions reduce impacts per unit, but overall environmental pressures remain unchanged or increase because total consumption rises, costs fall, or activity expands.” (Individual)

Organisations also reiterated feedback, including:

• The need to fully consider the financial impacts of any changes on local authorities, business and others; and
• That ongoing engagement with practitioners, communities and early-stage innovators would be important to ensure environmental impacts were accurately understood.