Strengthening approach to household recycling collection services: consultation analysis

4. Assessing the Impact of the Proposal

Chapter 4 presents the analysis of responses to questions which asked respondents to consider the impact of the proposals on different groups. This includes impacts on people with protected characteristics, businesses or the business sector, children’s rights, island communities, the Fairer Scotland Duty and the environment.

Q1. Equality: Are there any additional likely impacts the proposals contained in this consultation may have on particular groups of people, with reference to protected characteristics?

No impact

Just under half of respondents answered Q1. The most common theme, mentioned by several respondents, was that the proposal would not impact groups of people with protected characteristics.

“We do not foresee additional impacts any sectors of the community that are able to manage their own waste materials at present and resources are available to help those that are disabled or unable to utilise existing collection arrangements to participate.” - REA - Renewable Energy Association

Positive impact

A few respondents anticipated the proposals could have a positive impact on everyone, but they did not specify a specific group that would benefit. They did not provide any details as to why people would benefit or what the benefit would be.

People with accessibility concerns

A few respondents noted potential impacts for people with accessibility concerns, particularly older people or disabled people. Stirling Council suggested that people living in areas where kerbside collection may be impossible should have alternatives provided to ensure they have the same level of accessibility as those with kerbside collection.

English as a second language

Two individuals thought that people unfamiliar with the recycling procedures, particularly those who may be less confident with the English language, may find it challenging to understand the proposals due to their complexity.

Q2. Business and Regulation: Do you think that the proposals contained in this consultation are likely to increase or reduce the costs and burdens placed on any business or sector?

Impact on local authorities

Just over half of respondents answered Q2. The most common theme, mentioned by some respondents particularly local authorities, was an anticipated negative financial impact on local authorities. Most of these respondents did not provide further details at this question, but those who did mentioned operational costs, particularly if uptake of a new service is low. One individual thought some of the cost may be recouped with a landfill tax.

“The mandatory collection of an additional waste stream will place additional burden on local authorities, whether this is directly from households or the expansion of a public collection point network. This may require, dependent on the system adopted, and not limited to: additional or dedicated vehicles for textile collection; separate collection routes and staff; procurement of containers whether bags/boxes/other provided direct to householders or public collection units and procurement of re-processor; maintenance of public collection points (if used); any back-office system/processes to manage the collection of textiles, if direct from households e.g. booking a collection of textiles, monitoring of data, increase in number of enquiries to council call centre; [and] communications/engagement with residents.” - Glasgow City Council

Further detail about financial concerns for local authorities is mentioned under Q9 of Chapter 2 (household textile collection) and Q2 of Chapter 3 (food waste).

Impact on the third sector

Some respondents suggested the proposal for household textile collection could cause a loss of income for charity shops and reuse shops due to their dependence on donated textiles, as described in Chapter 2 (household textile collection).

“We have concerns about the impact on business models that are built on the donation of textiles for reuse, repair or remanufacturing.” - Lower Impact Living (Lil) CIC

Impact on the private sector

Some respondents mentioned a positive financial impact on private sector organisations and businesses. Respondents thought that rather than paying for textile recycling or food waste collection, as some businesses currently do, the council would collect it for free.

In contrast, a few respondents felt the proposals may increase costs for waste management businesses, due to the need to separate and process food waste separately from other waste. One individual was also concerned that it may increase fly tipping if the costs to recycle increase for some businesses.

Positive impacts

A few respondents felt that a new approach to recycling textiles may provide opportunities for innovation and growth within local communities, specifically for rural and island communities.

“There may be on-island solutions which deliver growth opportunities to Island businesses across food and textiles, as well as other waste potentially being diverted from landfill. The Council are keen to work with and support businesses within our Islands, although the net carbon impacts of these opportunities along with the potential costs would require to be modelled.” - North Ayrshire Council

Q3. Children's Rights and Wellbeing Impact Assessment: Do you think that the proposals contained in this consultation are likely to have an impact on children’s rights and wellbeing?

No impact

Just under half of respondents answered Q3. Most commonly, many respondents felt that there would be no impact on children’s rights and wellbeing.

Environmental improvements

Improvements to the environment were mentioned by a few respondents as a positive impact on children’s wellbeing. Stirling Council also mentioned the inclusion of initiatives on environmental stewardship in schools.

Access to reused toys and clothing

Two organisations highlighted a negative impact that fewer textile donations may have on families who depend on charity shop donations or reuse shops for clothing and toys.

“Many textile reuse initiatives support families on low incomes and are services upon which they rely.” - Lower Impact Living (Lil) CIC

Q4. Islands Communities Impact Assessment: Do you think that the proposals contained in this consultation are likely to influence an island community significantly differently from its effect on other communities in Scotland?

Infrastructure, transportation and haulage costs

Just under half of respondents answered Q4. Several respondents raised concerns about the proposals’ impact on island communities due to transportation and haulage costs. Respondents noted that without local recycling options, it would be necessary to transport recycling off the island, which could be even more expensive if there is low uptake.

“Yes. Due to the low volumes of material, increased logistical challenges and lack of viable local infrastructure, island communities are likely to face increased costs if required to introduce a collection scheme for new materials and for haulage and logistical costs, particular in proportion to the lower volumes and benefits.” - LARAC

General statements on impact

Some respondents acknowledged that they thought there would be impacts, but did not provide further details as to what those impacts would be. In contrast, a few respondents felt there would be no impact, but again, they did not provide more details.

Infrastructure investment

Two respondents noted the potential for increased investment in island communities' infrastructure. They felt that the proposal may spur the development of on-island recycling and waste management facilities.

Q5. Fairer Scotland Duty: Do you think that the proposals contained in this consultation are likely to have an impact in relation to the fairer Scotland duty?

No impact

Just over one third of respondents answered Q5. Most commonly, some respondents felt the proposals would have no impact in relation to the Fairer Scotland Duty.

Charity shop donations

As mentioned at Q9 in Chapter 2, some respondents reiterated the impact that kerbside textile recycling may have on donations to charity and reuse shops. In response to this question, respondents also reiterated the impact that this could have on community members who depend on charity and reuse shops for their clothing and household textiles.

Accessibility

Two organisations felt that kerbside collection could improve the accessibility of recycling facilities for people who struggle to get to recycling centres or those who do not own cars.

Q6. Environment: Do you think that the proposals contained in this consultation are likely to have an impact on the environment?

Increased carbon footprint

Seven in ten respondents answered Q6. Several mentioned a concern about an increase in carbon emissions. Respondents felt that the kerbside collection of food waste and textiles would increase Scotland’s net carbon footprint. Two main reasons were highlighted: increased haulage distances for communities without local recycling facilities and a lack of uptake undermining the benefits.

“Whilst, in principle, there could be an environmental benefit in the collection of higher volumes of textiles and the capture of food waste, this needs to be carefully considered in light of the challenges associated with implementing such a system, in particular the distance travelled by collection vehicles and then the onward transport to reprocessing centres. Ultimately, any collection system needs to be confident of a high volume of materials, otherwise there is a risk that the costs and environmental impact of the system is far higher than any potential beneficial impact.” – Orkney Island Council

General positive impact

Several respondents suggested the proposal would positively impact the environment, but did not provide further details as to why. Some others mentioned that the proposals would decrease waste, which they described as generally beneficial for the environment.

Other concerns

Other concerns were raised by smaller numbers of respondents. These included, from most to least prevalent, that the proposal could:

• Undermine the waste hierarchy by promoting recycling over reuse when reuse is better for the environment and community.
• Lead to an increase in fly-tipping, littering and waste-related crimes.
• Benefit from a complete Environmental Impact Assessment.
• Lead to dangerous persistent chemicals in textiles getting into the environment if recycling processes do not handle textiles correctly.

“There is a serious risk that the proposals for kerbside textile collections from households will harm the environment by diverting used clothing away from reuse and towards recycling or incineration.” - Charity Retail Association

Final comments: Do you have any other comments that you would like to make, relevant to the subjects of this consultation, that you have not covered in your answers to other questions? - Please provide your answer here.

One in ten respondents left a comment at the final question. However, these comments reiterated points noted in prior questions:

• Cost implications for local authorities, as described in Q9 of Chapter 2 and Q5 of Chapter 3.
• Negative impact on charity shop donations, described in more detail at Q9 in Chapter 2,
• The continued importance of clear communication and community education, as described in Chapter 2 at Q11.