Developing Scotland's circular economy - proposals for legislation: analysis of responses

Independent analysis of responses to the “Developing Scotland’s circular economy: consultation on proposals for legislation” paper which included proposals for a circular economy bill and two secondary regulations relating to single-use carrier bags and procurement.

2 Description of the responses and respondents

Number of responses received

2.1 The consultation received 1,660 submissions. Three-quarters of the responses (75%) were submitted through a campaign organised by Friends of the Earth Scotland (FoES); just over a fifth (21%) were submitted by respondents directly through the Scottish Government's online response form; and the remaining 4% were submitted by email. (See Table 2.1.)

Table 2.1: Number of responses received, by response type
Response type n %
FoES campaign responses 1,244 75%
Online responses 353 21%
Offline email responses 63 4%
Total responses 1,660 100%

2.2 It should be noted that around half of those submitting responses by email were organisational respondents. These respondents often amended the consultation questionnaire to make comments after closed questions where the standard questionnaire had not provided space to do so. In many cases, respondents who did this wanted to give an explanation of why they had answered 'no', 'neither agree nor disagree' or 'don't know' to specific closed questions.

Number of responses included in the analysis

2.3 An examination of the data found that, within the 1,660 responses received, two organisations had submitted two responses. Specifically, these organisations submitted an online response and sent an identical (or nearly identical) response by email to the Scottish Government. In both these cases, the responses sent by email were retained, and the online responses were removed.

2.4 The analysis was thus based on 1,658 responses, comprising responses from 144 organisations or groups, 270 individuals and 1,244 campaign supporters (Table 2.2).

Table 2.2: Responses included in the analysis, by respondent type
Respondent type n %
Organisations 144 9%
Individuals 270 16%
Campaign respondents 1,244 75%
Total 1,658 100%

Organisational respondents

2.5 The 144 organisations or groups who responded to the consultation included a wide range of public, private and third sector organisations - based in Scotland and elsewhere in the UK. Table 2.3 shows that the four largest categories of organisational respondent were:

  • Environmental charities, third sector and community sector organisations (29): This group included local economic development organisations.
  • Public sector organisations (28): This group included local authorities, local authority representative bodies, and national regulatory bodies.
  • Food, drink, hospitality, tourism and retail organisations (25): This group included food and drink producers, restaurant (including fast food) trade organisations, supermarkets, large and small tourism organisations, and a range of other retailers.
  • Environmental consultancies and resource management organisations (19): This group included recycling and waste management organisations.

2.6 The final three categories comprised academic and professional bodies and business representative bodies (17), packaging manufacturers and other types of manufacturing organisations (14), and beverage and vending companies (12). A list of all (144) organisational / group respondents is provided in Annex 1.

Table 2.3: Organisational respondents, by type
Organisation type n %
Environmental charities, third sector and community sector 29 20%
Public sector organisations 28 19%
Food, drink, hospitality, tourism and retail organisations 25 17%
Environmental consultancies & resource management organisations 19 13%
Academic and professional bodies and business representative bodies 17 12%
Packaging and other manufacturing organisations 14 10%
Beverage and vending companies 12 8%
Total 144 100%

Percentages may not total 100% due to rounding.

Campaign responses

2.7 The consultation received 1,244 standard campaign responses.[4] Friends of the Earth Scotland (FoES) encouraged their members and supporters to take part in the consultation by providing a standard response template on their website which individuals could add their signature to, and then send to the Scottish Government by email.

2.8 The campaign text addressed eight of the consultation questions as shown in Table 2.4. Campaign responses are included in the analysis in Chapters 3 to 9 and are reported in relation to each of the questions addressed by the campaign. However, they are not included in the tables in each chapter, which are based on the substantive (i.e. non-campaign) responses only. A complete copy of the FoES standard campaign response is provided in Annex 2 of this report.

Table 2.4: Assignment of campaign text to consultation questions
Campaign statement Consultation question
I fully support the Scottish Government's proposals outlined in this consultation to:
  • set charges for environmentally harmful items,
Question 1
  • require mandatory public reporting of business waste and surplus,
Questions 4(i) and 4(ii)
  • place additional requirements on local authorities and individuals to increase rates and quality of recycling of household items,
Questions 8 and 11
  • set powers to introduce a new fixed-penalty regime for littering from vehicles, and
Question 14
  • increase the minimum single-use carrier bag charge from 5p to 10p.
Question 20
However, I seek assurance that the Scottish Government's forthcoming Circular Economy Bill will also:
  • Include robust targets to tackle our overconsumption of resources including: reducing our carbon footprint to net zero by 2050, reducing our material footprint by 50% from 2020 to 2030 for minerals, metals and fossil fuel feedstocks, and an obligation to create a biomass strategy.
  • Set a duty on ministers to report annually on progress towards these targets.
  • Introduce a Resources Reduction Plan to be updated every 5 years with policies and other instruments to steer our economy towards meeting the targets.
I also support the full proposals outlined in Scottish Environment LINK's 'Call for a Strong Circular Economy Bill for Scotland' and note a move to a true circular economy could save Scotland 11 million tonnes of carbon emissions by 2050. Scotland's material consumption accounts for 68-74% of its entire carbon footprint and therefore I urge you to go further than the proposals and set ambitious targets which will help Scotland tackle climate change and our wasteful use of resources.
Question 22

2.9 Note that there was also some evidence of other organised campaign-type responses. For example, some lengthy responses included identical or similar wording or phrases. However, in most cases, these responses also included additional (personalised) comments. In addition, some respondents (including the standard campaign response from FoES, cited above) referred to, quoted and endorsed the response submitted by Scottish Environment LINK.

Response rate to individual questions

2.10 There was a relatively high response rate to the individual questions in this consultation. Across the consultation questionnaire, the closed questions attracted a particularly high level of response, with response rates for individual questions ranging from 81% to 90% for organisations and from 94% to 100% for individuals.

2.11 The response rates for open questions were lower and, for organisations, ranged from 52% for Question 16, which asked about the equalities impacts of the proposals, to 72% for Question 18, which asked about the environmental impacts of the proposals. Response rates for individuals for open questions ranged from 57% for Question 16 (on equalities impacts), to 79% for Question 7, which asked for suggestions for encouraging the reuse and redistribution of unwanted surplus stock, such as clothing and textiles. (See Annex 3 for full details.)



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