Publication - Impact assessment

Deposit return scheme for Scotland: business and regulatory impact assessment

Final Business and Regulatory Impact Assessment (BRIA), which is a development of the partial BRIA published in June 2018 and the full BRIA published in July 2019.

16.0 Annex B:

Rationale

Scotland’s National Litter Strategy[78], Towards A Litter-Free Scotland, outlines 12 interventions across three strategic areas – information, infrastructure and enforcement. These provide a basis for potential prevention initiatives, coupled with overseas examples, that aim to achieve comparable reductions in litter alongside a household packaging EPR scheme for Scotland. In keeping with the aims of the National Litter Strategy, activities outlined below have a firm focus on prevention. This differs from some European litter funding which commonly includes a significant contribution towards clean-up rather than prevention.

The initiatives outlined in the low, medium and high scenarios:

  • Cover the range of interventions discussed in the National Litter Strategy e.g. to address needs and gaps in Information/Education, Infrastructure and Enforcement
  • Are aimed at litter prevention, not clean-up
  • Are primarily aimed at local authority participation due to the application of the household packaging EPR scheme’s full cost recovery payments, but include involvement from other recognised key stakeholders such as other duty bodies and statutory undertakers, businesses, private landowners, communities and the third sector
  • Are considered in the current Scottish context. The Zero Waste Scotland litter and flytipping team has engaged the target audience of litter prevention measures extensively, therefore the categorisation of initiatives is based on known barriers, likely engagement requirements and willingness of stakeholders to get involved
  • Take account of ‘standard’ initiatives included in litter prevention funding for other European EPR schemes. These align well with the measures most commonly requested by key stakeholders in Scotland, and therefore may be prioritised in the low or medium scenarios despite relatively high costs, difficulty to implement or low likely impact on litter volumes
  • Exclude the introduction of other legislative or policy instruments, in part due to the cost of planning and implementation and based on the remit and scope of litter prevention funding from other European EPR schemes for packaging.

Accepting the above considerations, initiatives have been considered for the low, medium and high scenarios on the characteristics outlined in Annex B Table 1.

Annex B Table 1. Litter Prevention Scenarios
Low Contribution Medium Contribution High Contribution
Small investment, few barriers to implementation, small additional effort to prevent litter generation. Includes all low contribution activities e.g. the contribution is cumulative. Includes all low and medium contribution activities.
Includes initiatives commonly requested by key stakeholders and members of the public e.g. aims to satisfy National Litter Strategy interventions and the minimum expectations of stakeholders. Managed, ambitious effort to prevent litter with initiatives that are medium cost, may not currently take place and require significant engagement to implement. Strategic, multi-disciplinary approach to litter prevention including place-making, health, wellbeing and social amenity impacts that have direct or indirect links to litter on the ground e.g. local environmental quality.
May include initiatives that are conducted rarely/piecemeal across Scotland which would provide benefit from wider coordinated uptake. May include higher investment initiatives already outlined low and medium contribution.
May include higher investment initiatives already outlined low contribution.

Proposed Scenarios

Annex B Table 2. Activity List for Low, Medium, High Contribution Scenarios
YEAR 1 (£million) ONGOING ANNUAL (£million/year)
Low Med High Low Med High
Local Authority Shared Service - formal, six regional agreements - - 1 - - 2
Local Authority Shared Service - non-formal, multiple agreements - 1.2 - - 1 -
Strategic Partnership 0.01 0.01 0.01 0.01 0.01 0.01
Litter Prevention Action Plans (community x 32; regional x6) - 1 1 - 0.2 0.2
National Consumer Campaign 1.1 1.35 1.6 1 1.25 1.5
Community Empowerment 0.6 1.1 1.6 0.5 1 1.5
Education and Skills 0.39 0.39 0.39 0.33 0.33 0.33
Citizen Science 0.2 0.2 0.2 0.1 0.1 0.1
Monitoring and Data Improvements 0.25 0.5 0.75 0.25 0.5 0.75
Next Generation Monitoring System - - 0.5 - - 0.1
Recycle on the Go Improvements 0.25 0.35 0.45 0.25 0.35 0.45
Escaping Waste from Containers and Vehicles 0.25 0.5 1 0.25 0.5 1
National 'Binfrastructure' Improvements 0.5 1 1.5 0.5 1 1.5
Optimisation of Enforcement System 0.5 0.5 0.5 0.05 0.05 0.05
Additional Enforcement Funding 0.5 1 2 0.5 1 2
CCTV Infrastructure - - 0.5 - - 0.1
Total Cost (£million) 4.55 9.1 13 3.74 7.29 11.59

Low Contribution Scenario

Annex B Table 3. Low Contribution Scenario Activities
Activity Year 1 Cost (£millions) Ongoing Cost (£millions/year)
Local Authority Shared Service – formal, 6 regional agreements - -
Local Authority Shared Service – informal, multiple agreements - -
Strategic Partnership 0.01 0.01
Litter Prevention Action Plans (community x32; regional x6) - -
National Consumer Campaign 1.10 1.00
Community Empowerment 0.60 0.50
Education and Skills 0.39 0.33
Citizen Science 0.20 0.10
Monitoring and Data Improvements 0.25 0.25
Next Generation Monitoring System - -
Recycle on the Go Improvements 0.25 0.25
Escaping Waste from Containers and Vehicles 0.25 0.25
National ‘Binfrastructure’ Improvements 0.50 0.50
Optimisation of the Enforcement System 0.50 0.05
Additional Enforcement Funding 0.50 0.50
CCTV Infrastructure - -
Total Cost 4.55 3.74

The Low Contribution Scenario includes a number of positive initiatives which would have a low-moderate impact on litter volumes. Activities include common requests from key stakeholders and members of the public, particularly the consumer campaign and investment in education, and is therefore likely to be viewed favourably by both. It contains a number of modest contributions to infrastructure and data capture that would improve on current practices.

Medium Contribution Scenario

Annex B Table 4. Medium Contribution Scenario Activities
Activity Year 1 Cost (£millions) Ongoing Cost (£millions/year)
Local Authority Shared Service – formal, 6 regional agreements - -
Local Authority Shared Service – informal, multiple agreements 1.20 1.00
Strategic Partnership 0.01 0.01
Litter Prevention Action Plans (community x32; regional x6) 1.00 0.20
National Consumer Campaign 1.35 1.25
Community Empowerment 1.10 1.00
Education and Skills 0.39 0.33
Citizen Science 0.20 0.10
Monitoring and Data Improvements 0.50 0.50
Next Generation Monitoring System - -
Recycle on the Go Improvements 0.35 0.35
Escaping Waste from Containers and Vehicles 0.50 0.50
National ‘Binfrastructure’ Improvements 1.00 1.00
Optimisation of the Enforcement System 0.50 0.05
Additional Enforcement Funding 1.00 1.00
CCTV Infrastructure - -
Total Cost 9.10 7.29

The Medium Contribution Scenario builds on the prevention measures implemented in the Low Contribution Scenario, with increased funding for activities where added value could be achieved, such as the National Consumer Campaign and investment in Community Empowerment, Recycle on the Go infrastructure, and ‘Binfrastructure’.

A number of new initiatives are included based on the larger contribution that present notable shifts in behaviour and approach towards litter, including the informal shared service which would overhaul the local authority approach to litter prevention, and litter prevention action plans which would create shared responsibility within and between council departments and their key stakeholders. These practices would address institutional barriers to litter prevention and provide suitable funding levels to effectively tackle known litter routes, in particular escaping waste and higher funding to ensure enforcement is seen as a credible deterrent.

High Contribution Scenario

Annex B Table 5. High Contribution Scenario Activities
Activity Year 1 Cost (£millions) Ongoing Cost (£millions/year)
Local Authority Shared Service – formal, 6 regional agreements 1.00 2.00
Local Authority Shared Service – informal, multiple agreements - -
Strategic Partnership 0.01 0.01
Litter Prevention Action Plans (community x32; regional x6) 1.00 0.20
National Consumer Campaign 1.60 1.50
Community Empowerment 1.60 1.50
Education and Skills 0.39 0.33
Citizen Science 0.20 0.10
Monitoring and Data Improvements 0.75 0.75
Next Generation Monitoring System 0.50 0.10
Recycle on the Go Improvements 0.45 0.45
Escaping Waste from Containers and Vehicles 1.00 1.00
National ‘Binfrastructure’ Improvements 1.50 1.50
Optimisation of the Enforcement System 0.50 0.05
Additional Enforcement Funding 2.00 2.00
CCTV Infrastructure 0.50 0.10
Total Cost 13.00 11.59

The High Contribution Scenario largely builds upon the Low and Medium Contribution Scenarios, providing substantive funding for information, infrastructure and enforcement initiatives that would ensure a comprehensive, multi-faceted, well-funded approach to litter prevention. The key changes at this level include the formalisation of a local authority shared service, the formality of which is more likely to radically shift working practices and ensure senior level buy-in to prevention. This contribution level would also ensure forward planning and best use of technology was adopted for monitoring data collection, evaluation and application that would underpin all other activities and ensure optimal, targeted investment in each area.


Contact

Email: DRSinScotland@gov.scot