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The Caledonian Environment Centre is part of Glasgow Caledonian University’s School of the
Built and Natural Environment. The Centre offers a dedicated team of professionals with
expertise in a varied range of environmental disciplines including waste and resource
management, sustainability, carbon management and education/training.
The Centre has been providing such services for over 10 years and has become recognised
as a leading academic, research and consultancy organisation in the environment sector.
Much of our work is used to support or help implement public and private sector policies
and initiatives.
The Centre combines sound academic knowledge with responsive, practical experience,
enabling it to carry out valuable consultancy and research in order to provide accurate and
up to date information to clients and the sector.
We are pleased to submit this response to the consultation and trust that it is self-
explanatory, however should you require any clarification or further information please
contact us.
Our response to the consultation and questions posed are:
List of Consultation Questions
Scotland’s Zero Waste Plan Consultation
Question 1.
What further steps, if any, need to be taken to promote the waste hierarchy?
There are targets suggested for waste minimisation but no apparent penalty if these are not
made. Mandatory tonnage / weight targets and penalties, if any, all focus on recycling or
lower on the hierarchy. We therefore need to consider targets, penalties, incentives etc on
activities above recycling.
Development of practical ‘end of waste’ protocols would encourage process and product
development and provide some certainty for the reprocessor and markets.
Make costs of waste disposal more visible to public – the amount spent by councils and why –
how this could be improved by reduction in waste produced and greater emphasis on the
waste issue being an individual problem – need to move away from attitude that waste is
someone else’s problem.
The Sustainable Procurement Action Plan is mentioned in the Plan but only in relation to
recyclate. Sustainable Procurement policy also needs to focus on minimisation and re-use.
Please also see reply to Questions under as most are relevant.
Scotland’s Zero Waste Plan Consultation
Question 2.
a) Waste tonnage will continue to be the main measure of progress. However, should Government
also use other ways of measuring progress?
Yes
b) If yes, what measures, how and why?
It would be good to have a range of indicators that show progress and can be reported in the
proposed Annual report. Such indicators might be those that track aspects of the definition
of ZW together with economic and environmental factors. This could pick-up on issues raised
in the SEA and take the form of a ‘State of the Nation’ waste/resource/environment report.
Kg/household within recycling schemes/week (kg/hh/wk) would give a more accurate
measure of local performance and allow for improved comparison with other schemes and
countries.
Scotland’s Zero Waste Plan Consultation
Question 3.
a) Do you agree with these proposals on improving data?
No.
b) If no, what should be done and how and by whom?
The proposals don’t go far enough. If we are to achieve ZW we must be able to measure and
manage our waste. We therefore need better data particularly on C&I waste. Mandatory
returns by waste producers and the flows of waste are required and provisions for this has
been included in the Climate Change (Scotland) Act. Waste producers could easily
incorporate this as a requirement on their contractor in their contracts. See also answer to
Q13 re Waste Transfer Notes.
SEPA surveys have relied on too small samples and has largely led to the survey results
being discredited.
There is more scope for requiring further information about waste source in licences and
permits and undertaking detailed analysis of these. To our knowledge little is done at
present in analysing waste data contained within licence returns.
Consideration should also be given to requiring proper and detailed returns from ‘exempt’
sites.
Scotland’s Zero Waste Plan Consultation
Question 4.
What should be the future role of Area Waste Groups and Area Waste Plans?
Options include:
i) Abolition (if so, how do you feel local needs could best be supported and developed?).
They are out of date and, with Councils having a Concordat with the SG and specific SOAs
with agreed targets and responsibility, somewhat redundant. Regional development has
moved on in the past ten years and to have one AWG serving say Fife and one serving the
Glasgow and Clyde Valley demonstrates how much the AWGs don’t fit the regional needs.
Local needs and delivery should be addressed through the planning Delivery Plan process
rather than having a further set of AWG plans. However Scottish Government has to ensure
that LAs include adequate waste planning in their process.
SEPA has played a key role in managing the AWP process with allocated resources. These
resources might be better deployed in supporting other areas such as better data
management and analysis.
Yet the 25% cap on EfW talks about local as well as national, without defining what local
means, suggests some degree of co-ordination is needed. This could be done within the
context of SOAs where Councils would be asked – through guidance provided by the
Improvement Service to offer how their plans./targets fit within a regional context.
Scotland’s Zero Waste Plan Consultation
Question 5.
a) Is there a need for a simplified delivery body programme?
Yes
b) If yes, what form should this take?
CEC as the delivery organisation for Remade Scotland have been involved in the review
process and have made their views known to Scottish Government. In summary, our view is
that each delivery body is delivering specific parts of the National Waste Strategy (e.g.
capital funding, advice, research, support etc) but there is an opportunity for better
planning, co-ordination, governance and direction. This could take the form of a Programme
or Executive Board. Overall the current delivery bodies have helped Scotland achieve current
recycling levels and now have a considerable level of embedded knowledge and skills in
these bodies. This should be built on and not lost or diluted.
CEC currently receives its funding via a Grant Award (as do other Delivery Bodies) and hence
VAT is not added. If the method of funding is changed this is likely to attract VAT and add 15
– 17.5% to the cost or reduce the services purchased to the same extent. Therefore any
change to the current system would have to show benefits in excess of the VAT amount to
stand still in terms of value for money.
A ZW Programme Board to give policy, direction and governance, to include COSLA, SEPA
and Scottish Enterprise, could manage the bodies and make best use of the existing specific
skills and knowledge of each body or programme. There should also be a single ‘brand, ‘Zero
Waste Scotland’. The brand provides a outward facing image from which to promote ZW to
the public and industry. This brand has already been successfully used at the Futuresource
conference.
c) Are there areas where additional work is required from delivery bodies to support
progress towards a Zero Waste Scotland?
Yes
Annexe D explains the roles of the current delivery bodies while Annex T identifies the
continuing need for delivery bodies. These seem to identify and cover most of the likely
needs and skills with other work being identified and addressed as we move along the path
to ZW.
d) Are there current areas of work which delivery bodies could stop doing?
Scotland’s Zero Waste Plan Consultation
Yes
We have several capital programmes embedded into the WRAP programme. We believe that
Capital Grant Programmes is one measure that can be used where there is a market failure.
A review of these programmes is needed to see whether or not they are needed. Any potential
beneficiary from the private sector will be supportive, but businesses in other non-waste
sectors are having to make investment without such funds. Our view is that Government
should send clear signals to the market that (a) no such funding is available and (b) that the
targets need to be met. This will remove uncertainty and allow the private sector to raise the
necessary capital elsewhere.
On a wider point, as the ZWP progresses and time passes some areas will have been
completed or be less relevant, hence some work will stop and new work will start. However
the general areas of work will still require support, as identified in Annex T.
Scotland’s Zero Waste Plan Consultation
Question 6.
To date, development plans have not always identified sites and/or locational criteria for waste
management plants. What can be done to ensure that development plans do so in future?
The land use planning process is well defined and as noted in Annex E there are obligations
that the planning system MUST include the need and provide for waste management
infrastructure. Also, the necessary PANs and SPPs are in place and clearly lay out what is
required (and/or can be readily updated if required). The process is in place, Scottish
Government must ensure that it is applied.
WAS were very successful with their campaigns on recycling, perhaps a campaign to inform
the public about infrastructure needs and allay fears should be initiated. This would have
twin benefits of demonstrating the requirement for infrastructure and the realities of new
modern facilities as well as emphasising that waste disposal is not someone else’s problem.
One aspect of the AW Plans that was helpful at the time was an indication of the types of
facilities that were needed to deliver on the targets. Any reporting of this at a national or
regional basis has been lost recently. If we wish to avoid planning applications for facilities
in excess of 200kt/yr of EfW capacity, perhaps Scottish Government should offer a
commentary on the scale of infrastructure needed.
Scotland’s Zero Waste Plan Consultation
Question 7.
a) Should Government set a target of reducing municipal waste by 1% per annum?
No
Although the rational and basis of calculation must be clear and integrated with other
aspects of the Plan (e.g. communications, targets) and over a practical time frame (1%
accumulative per annum for a long period would be unachievable). Also how such a target
would be enforced needs to be thought through particularly when the current definition
includes C& I wastes collected by LAs. It is possible to separate out the C&I element and
consider a household waste reduction target (similar to England) and recognise the target is
linked to several policy areas (retailers waste reduction/consumer behaviour/local authority
services encouraging waste prevention.
However, needs to be recognised that waste reduction requires National action and is largely
out of the control of LA waste services. Targets, if put in place, should be used to support the
Waste Prevention Programme which will need co-ordinated input from a number of
stakeholders.
b) Should Government set any specific targets on reducing household waste?
Yes but on the basis given in Answer to 7(a) although it would need to be based on proper
criteria (e.g. population growth/decline, recycling infrastructure etc) and adequate
communication programmes and resources. We consider recycling performance for kerbside
schemes on basis of Kg/hh/wk. This could be applied to household waste arisings or per
capita also.
Scotland’s Zero Waste Plan Consultation
Question 8.
a) Should Government set a target in relation to "preparing for re-use"?
Yes
Although voluntary targets may be a first step.
b) If yes, what sort of target should be introduced and how will it be achieved and measured?
Further work needs to be done to develop the Framework in Annex G together with
development of data on reusable “wastes”. Thereafter targets, support and actions can be
developed.
Scotland’s Zero Waste Plan Consultation
Question 9.
What targets, if any, should Government set in relation to the prevention of commercial and
industrial waste and construction and demolition waste?
Better data is needed before targets can be set and this will probably require regulatory
measures. Although implementation of Site WMPs as in England and development of the
Demolition Protocol could drive better C&D waste data as well as increase waste prevention
in that sector.
In addition, Government and the public sector are by far the largest procurers of projects in
the country and should include SWMPs and appropriate waste plans/data as a requirement
on all contracts.
A further incentive could be an increase on the Aggregates Levy. Although this is a reserved
matter it might be appropriate for both the Scottish and UK Governments to assess the
impact on recycling if the Levy was increased.
Scotland’s Zero Waste Plan Consultation
Question 10.
a) Have any potential waste prevention actions been missed?
Support and encourage (related in some way to funding?) an Eco-Campus programme across
colleges and Universities. Currently the Eco-Schools programme stops and there is no follow-
on between further/higher education and into work and homeownership. See Action 56 of
Annex T.
b) Are there any actions listed which are not worth pursuing, and why?
Home composting has probably gone as far as possible bearing in mind that not all
householders can participate, those that wish to probably have and measuring the added
benefit is almost impossible. Perhaps divert resources to encouraging more community
composting.
Scotland’s Zero Waste Plan Consultation
Question 11.
On improving municipal recycling rates:
a) Do you agree with the key actions needed to improve municipal recycling rates?
Yes
b) Should most ( e.g. 80%) of the recycling targets be met through collections of recyclate at
kerbside and through recycling centres and points?
No.
Councils should be allowed, particularly those with a high level of flatted/high density
housing, to utilise treatment and other processes which can increase their recycling levels
(e.g. MBT and MHT, AD for organics/food waste).
c) Do you consider that local authorities need more in-depth support to help improve
municipal recycling performance.
No.
However LAs do need the continuing type of support and advice on best practice and
markets etc that is currently provided by the delivery bodies, all as generally recognised in
Annexes D & T.
Removing the LAS penalties has not been helpful in encouraging Councils to meet their BMW
LAS targets and Councils may choose to address other SOA targets in education and social
services during times of tight fiscal control. A review of the LAS scheme should be
undertaken with a view to reinstating the penalties.
d) Do you consider that there could be a greater role for incentives to improve recycling
performance.
Yes
The position is currently unclear as not enough research has been carried out into their effect
and particularly in the longer term and their cost/benefit. Therefore more research is
required before any decisions can be made. An observation is that waste management only
costs about £1-3per hh/week, it is difficult to see what level of incentive could be given that
would make a difference.
However ‘direct’ or ‘variable’ charging should not be ruled out of the Plan as it is a most
effective measure used by many countries outside of Scotland and the UK. Why should it be
Scotland’s Zero Waste Plan Consultation
beyond the Scottish Government (and UK Governments) to introduce an acceptable scheme
if other countries are able to?
e) Should any changes be made to the categories of household waste where local authorities can
charge for collection?
No.
Scotland’s Zero Waste Plan Consultation
Question 12.
What more should be done to encourage recycling in public places?
Support better design in new developments (commercial, public and residential) so
infrastructure for recycling is appropriately planned for. Guidance on best practice in
relation to putting recycling facilities in public places should be produced and consider
implementation of powers in Climate Change Act to require recycling at events and provision
of facilities.
Scotland’s Zero Waste Plan Consultation
Question 13.
Should a campaign be run reminding companies of their responsibility under Duty of Care?
Probably Yes. Although it is likely to remind companies of their responsibilities it is unlikely,
on its own, to drive increased recycling or recovery. As noted previously targets and/or
encouragement needs to be applied as does the collection of better C&I data if improved
recycling is to be achieved. Consideration should also be given to amending the current
regulations on DoC to give SEPA and LAs the power to enforce the Duty.
However making better use and/or further developing the Transfer Note system should be
utilised to obtain C&I data. It should not be discounted as per paras 29 – 32 of Annex C as it
is a system already in place which with some relatively small developments(e.g. SIC codes)
could provide the answer to collection of C&I data. In particular a move to an e-form could
solve the problems of administering a large mass of data. There would be little or no
additional burden on waste producers or waste contractors as they are already dealing with
TNs in paper form. A proper review and assessment of the role of TNs should be undertaken.
Currently the Notes are being completed for no real purpose or contribution to better waste
management.
Consideration should also be given to implementing the range of measures included in the
Climate Change (Scotland) Act
Scotland’s Zero Waste Plan Consultation
Question 14.
a) Do you agree that these are the priority materials and sectors for which tailored
programmes of work should be developed?
Yes
As the WFD identifies specific material streams it is important that these should be the
priority for any programmes, many of which are identified in Annex T. However other
potential criteria, as noted on page 36 of the Consultation, should also be used to determine
priorities particularly hazard or environmental impact.
Similarly the Scottish Government’s business strategy priority sectors should be considered
when setting specific priorities and developing programmes.
b) If no, what should be included?
Scotland’s Zero Waste Plan Consultation
Question 15.
a) Should Government set a target on reducing the amount of commercial and industrial
waste sent to landfill by 150,000 tonnes a year?
No.
As noted above targets on C&I should be considered but the rational for proposing an annual
landfill reduction target of 150,000 tonnes (over how many years?) is unclear and not
validated. As noted before better data on C&I waste is needed before any validation can be
given to targets.
b) Should Government set targets by specific sectors, companies or materials?
Yes - See response to Q 14 above.
Scotland’s Zero Waste Plan Consultation
Question 16.
a) Should Government explore further the merits of different forms of producer
responsibility, which might more directly support household recycling collections?
No
We recognise Scotland is constrained by what happens at the UK level particularly in relation
to packaging waste. As noted in the Consultation there are a number of existing producer
responsibility initiatives which, together with possible development of a Waste Prevention
Programme and Re-use Framework, should provide sufficient structure and cover most of
the household materials where “producer responsibility” would be practicable. Also the
Controlled Waste Regulations 1992 and current review allows for LAs to charge for collection
of specific household wastes (which may be increased as part of the review) and which could
be included or aligned with current producer responsibility materials.
However, with all other proposed measures, further different or additional forms of
responsibility are unnecessary.
b) Should Government explore further whether extended producer responsibility as outlined
in Article 8 of the revised Waste Framework Directive should be introduced?
No. See 16 a) above
Although more voluntary agreements with producers, that do not impact on LA or
householder costs, should be encouraged.
c) Should Government or other bodies do more to extend the concept of voluntary producer
responsibility? Yes/No. If yes, what?
Yes – the Scottish Government needs to work at the Uk level to ensure producer
responsibility programmes are ambitious enough, particularly around packaging waste
recovery targets.
Scotland’s Zero Waste Plan Consultation
Question 17.
Do you agree that the cap should not extend to mixed waste treatment, such as Mechanical
Biological Treatment ( MBT), Mechanical Heat Treatment ( MHT) and Anaerobic Digestion taking
mixed waste?
Yes
However there appears to be a contradiction between the Consultation (pages 12 para 1.11)
and Annex J’s guidance. Para 1.11 states that “By 2025, Scotland should be treating no more
than 25% of its municipal waste………in energy from waste facilities” which, in effect, is a
target to be achieved by 2025. However Annex J para 6 states that the 25% is a cap which,
with exceptions, applies from 24th January 2008.
We would go further and question the whole rationale for 25% particularly for large cities
with high density housing and other problems. It is worth noting that many of the major
waste projects in the rest of the UK are proposing more than 25% and that in Europe EfW
has become an integral part of a Country’s waste strategy – but not at the expense of
recycling. EfW needs to remain an option particularly if Scotland is to deliver on challenging
greenhouse gas reduction targets. We believe further research and validation is required to
determine if 25% is practical and achievable.
Perhaps the 25% should be a target rather than a cap.
Scotland’s Zero Waste Plan Consultation
Question 18.
Should the cap extend to single-stream municipal wastes going to energy from waste plants?
No.
Scotland’s Zero Waste Plan Consultation
Question 19.
a) Should Government support local authorities when they seek to procure or build infrastructure
to treat residual waste?
Yes
b) If yes, what should Government do?
Noting that the Government does not intend any further specific funding support there is
however a need for technical, procurement and funding support as the integration of
arisings, collection, sorting, treatment, disposal and recovery/recycling is complex. It is not
expected that LAs could carry sufficient expertise. Therefore, the Scottish Futures Trust (SFT)
should work closely with the other current delivery bodies who have, among others, the
understanding of the sector, its arisings, technical, contractual and market aspects of the
necessary infrastructure to deliver a package of bespoke support as each authorities needs
will be different.
Procurement needs to allow for non-conventional models which may have, for example, a
capital and management fee to cover the infrastructure development plus a tonnage gate
fee which might vary dependant on output factors such as tonnage reduction/recycling
increase, changes in waste composition, recyclate value.
Government also needs to support LAs with the difficult planning and other local issues in
delivering infrastructure as well as in partnership working between Councils.
Scotland’s Zero Waste Plan Consultation
Question 20.
Do you have any initial views on materials or streams or products which could be banned from
landfill?
As noted a number of countries outside Scotland and the UK operate landfill bans on a range
of materials as part of delivering their targets. Therefore bans should be seriously considered
and the current work assessing landfill bans should be consulted on as soon as possible.
However any decision should be made in conjunction with the rest of the UK different
‘regional’ bans will lead to cross border export of wastes to take advantage of differences.
Scotland’s Zero Waste Plan Consultation
Question 21.
a) What opportunities would arise in this area if Scotland had fiscal autonomy, with the
power to set the rate of landfill tax in Scotland?
Currently Scotland doesn’t have the fiscal authority to deliver this and is a question which is
framed in a political context.
On the downside it could lead to different tiers of tax and disposal regimes and encourage
cross border waste movements to avoid tax. It might also limit economic development in
Scotland if the tax is higher than elsewhere in the UK.
However it could be hypothecated back into developing our Zero Waste Society or the tax
changed from just landfill to give differentials for encouraging recycling and different types
of treatment (e.g. differential taxes for landfill, EfW, AD, MRF residual outputs).
b) What might the effects of a different constitutional arrangement for Scotland be in this
area?
See 21 a) above.
Scotland’s Zero Waste Plan Consultation
Question 22.
Are there any other points you wish to make?
General
The Plan is helpful in identifying issues and reviewing how we might deliver the targets and
sustainable waste management. However it lacks any assessment of the affordability or cost
to LAs or businesses in achieving Zero Waste. It is appreciated that a report, as mentioned in
Annex P para 5.3 is due for release on the costs to LAs but that is only a part of delivering
Zero Waste.
Also the Plan while addressing most of the issues does not actually ask what are the key
factors for the Government in delivering their strategy and/or what they need to do.
In our view key factors and requirements include:
• Planning – The processes are in place but the Government needs to ensure that they
are applied fairly and timeously. Guidance on some of the principles surrounding
waste and planning however needs clarification or better advice. For example, the
proximity principle where referred to in the plan seems to mean proximity to the
point of waste generation although Action 13 of Annex T seems to suggest it is
proximity to the recycler or reprocessor. However the WFD Article 16.3 refers more
practically to disposal locations being nearest and most appropriate methods and
technologies. Such confusion leads to disputed and extended planning processes as
well as uncertainty.
• Support - Targets are set and the Plan notes that there will be no specific
infrastructure funding. Nonetheless it is acknowledged that LAs and business will
need support. Exactly what support will be available and what other initiatives (e.g.
landfill bans) needs to be agreed and clearly laid out. This will allow the sector and
market a level of certainty in which they can plan and operate.
• Leadership and direction – The ZWP sets out the vision and overall strategy however
in order to deliver it there needs to be leadership by the Government to ensure all
aspects are co-ordinated, decisions made, regulations introduced and the Plan
delivered. Dealing with planning and support needs as above will go along way
towards showing leadership but in addition cross-party Parliament support which
would demonstrate a politically stable plan is also needed and confidence that the
Plan won’t change with a change of Government.
Scotland’s Zero Waste Plan Consultation
• Commercial and Industrial Waste - Review, consult on and implement early
measures and targets to be applied to C&I waste as this is the real challenge of
delivering ZW.
• Clarity of Strategy – Perhaps most significant, Government needs to send clear
signals to the market that key policy areas will remain firm. Recent changes in
administration at the time of Strategic Outline Cases led to confusion and a
considerable waste of time and effort on the part of many. Similarly the removal of
penalties associated with LAS sent uncertainty to those who might invest in waste
infrastructure.
Scotland’s Zero Waste Plan Consultation
Specifics
Annex C: Para 14 refers to waste compositional analysis which is becoming increasingly
important as we move towards process technology solutions rather than disposal. It is
necessary to know what is included in the waste stream if it is to be recovered and treated
adequately or their recycling systems optimised.
However it is not necessarily the case that this needs to be done by the LAs as it could be
included as part of any contractual arrangement for treatment or reprocessing. It is equally
important that the LAs’ contractors know what is in the waste. Even under current contracts
for collection or recycling LAs should be demanding adequate information on the materials
and recycling/recovery processes and tonnages.
Annex H: Do the examples give in para 5 also apply to wastes treated by MBT and MHT and
would the “recyclate” recovered from these processes count as recycling?
Re paras 7, 8 and 9 would food waste collected together with green waste, like co-mingled
collection of other materials, being sent for treatment, qualify as separately collected?
Para 27 refers to achieving the highest quality and highest price but does not refer to
security of outlet or market. Highest quality and price might not give the best security and
therefore a balance needs to be struck between price and security.
Annex T: The actions although covering many of those needed to deliver the Plan do not
address areas such as the low carbon agenda, bio-energy and the relationship with SFT.
.
Scotland’s Zero Waste Plan Consultation
