- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Thursday, 24 March 2022
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Current Status:
Answered by Lorna Slater on 22 April 2022
To ask the Scottish Government, regarding the Final Business and Regulatory Impact Assessment for its Deposit Return Scheme, published in 2021, and the statements regarding local authority benefits as a result of half a billion containers being removed from local authorities, what its position is on whether such a removal of containers would represent a reduction in benefits for local authorities.
Answer
In calculating the impact of our Deposit Return Scheme (DRS) on local authorities, the economic model in the final Business and Regulatory Impact Assessment (BRIA) uses compositional data on the tonnage (‘dirty’ weights) that Local Authorities actually manage, both recycled and in the residual waste stream, rather than the number of containers placed on the market. This aligns with the (weight-related) costs local authorities actually incur.
Hence the benefit to local authorities set out in table 3 of the amended final BRIA does not change in the sensitivity analysis presented in Annex F. The amended final BRIA can be reviewed here: .
- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Thursday, 24 March 2022
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Current Status:
Answered by Lorna Slater on 22 April 2022
To ask the Scottish Government, regarding the Final Business and Regulatory Impact Assessment (BRIA) for its Deposit Return Scheme, published in 2021, in light of the original BRIA including an estimate of 1.7 billion containers within the scheme, which has been increased to 2.2 billion containers in the Final BRIA, which represents an increase of half a billion containers within the scheme, and in light of an increase in return points from approximately 17,000 to 37,000, which represents a 118% increase in return points, how the 7% increase in costs in table 3 was calculated, and what incentives there are for businesses to create facilities within their premises for the scheme.
Answer
When calculating this increase, it has been assumed that the additional return points are manual return points, which have a lower cost than those with reverse vending machines.
Zero Waste Scotland carried out an intensive data-gathering process to arrive at the figure of 17,000 which remains our best and final estimate of the number of return points, prior to implementation. Although we modelled the figure of 37,000 to provide a sensitivity analysis for the economic case for our Deposit Return Scheme (DRS), we are confident that we have identified all the larger retail sites, and if these additional return points did exist, they would overwhelmingly be manual return points. Circularity Scotland Ltd, the scheme administrator for our DRS who provided the figure of 37,000, agrees with this assessment.
- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Thursday, 24 March 2022
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Current Status:
Answered by Lorna Slater on 22 April 2022
To ask the Scottish Government, regarding the Final Business and Regulatory Impact Assessment for its Deposit Return Scheme, published in 2021, in light of it including an additional half a billion containers within the scheme and additional 20,000 return points, how it was calculated that the costs to regulators will remain the same, and how this calculation has been validated.
Answer
The cost to the regulator is estimated based on the number of businesses to be regulated; it is therefore unaffected by any increase in the number of containers.
- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Thursday, 24 March 2022
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Current Status:
Answered by Lorna Slater on 22 April 2022
To ask the Scottish Government, regarding its planned Deposit Return Scheme (DRS) and the current Packaging Recovery Note (PRN) system, how the DRS scheme will work alongside the PRN scheme; whether it anticipates that the DRS will result in more or fewer glass bottles being made from recyclate through the remelt process; whether it will publish the full details of its analysis of this aspect of recycling, and whether it will provide details on how its Deposit Return Scheme will "significantly increase the quantity and quality of glass recyclate" as referred to by the Minister for Green Skills, Circular Economy and Biodiversity in evidence to the Net Zero, Energy and Transport Committee on 25 January, 2022 (Official Report, c. 6).
Answer
The Scottish Government is clear that deposit return schemes (DRS) are a form of extended producer responsibility (EPR). Therefore, producers will not have to purchase Packaging Waste Recycling Notes (PRNs) or Packaging Waste Export Recycling Notes (PERNs), or pay producer fees under packaging EPR once that is operational, for containers collected through our DRS. We are working with the other UK administrations to legislate to give effect to this position.
On the member’s questions regarding quantity and quality of glass collected through our DRS, I refer him to the answer to question S6W-07104, answered on 18 March 2022. Increased quantity and quality of glass cullet means more glass available to go to re-melt and we would expect Scotland’s glass industry to benefit from this economic opportunity.
All answers to written Parliamentary Questions are available on the Parliament's website, the search facility for which can be found at /chamber-and-committees/written-questions-and-answers .
- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Thursday, 24 March 2022
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Current Status:
Answered by Lorna Slater on 22 April 2022
To ask the Scottish Government, regarding the Final Business and Regulatory Impact Assessment for its Deposit Return Scheme, published in 2021, which includes an additional half a billion containers within the scheme and additional 20,000 return points, which is a 118% increase on its initial estimate of the number of return points, for what reason there is no corresponding increase in costs to reflect this.
Answer
The cost increases within the model are not proportional increases. There may be additional collections but there is also additional capacity within the system.
- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Thursday, 24 March 2022
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Current Status:
Answered by Mairi Gougeon on 12 April 2022
To ask the Scottish Government, in relation to the comment of the Minister for Green Skills, Circular Economy and Biodiversity, on 13 March 2022, that “it’s a no” in response to the request made by NFU Scotland to relax rules to enable land to be brought back into use for food production, whether the Minister, prior to making her comment, had (a) spoken with, met or otherwise engaged with, NFU Scotland and (b) consulted with the Cabinet Secretary with responsibility for farming on the topic of the NFU Scotland request.
Answer
As Cabinet Secretary for Rural Affairs and the Islands, I made the decision not to suspend the greening rules on Ecological Focus Areas relating to fallow land and field margins following the request from the NFUS. I remain clear in my commitment to supporting farmers and crofters to produce more of our food more sustainably, nevertheless we must continue to acknowledge to ensure agriculture continues to play its part in cutting emissions, mitigating climate change and restoring and enhancing nature and biodiversity.
- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Tuesday, 15 March 2022
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Current Status:
Answered by Lorna Slater on 29 March 2022
To ask the Scottish Government, regarding its estimates as set out in the Deposit Return Scheme for Scotland Final Business and Regulatory Impact Assessment (BRIA), published in December 2021, and as contained in Annex F: Industry Assumptions, whether specific allowance is made for the additional costs of approximately 3,000 Reverse Vending Machines (RVM), as referred to in table 2 on page 19 of the same document, and, if this is not the case, what its position is on whether the 2021 BRIA is defective.
Answer
As Table 2 of the amended final Business and Regulatory Impact Assessment (BRIA) for our Deposit Return Scheme (DRS) makes clear, the economic modelling in the BRIA assumes that there will be 3,021 reverse vending machines (RVMs) in operation.
Annex F of the amended final BRIA shows that the economic case for DRS remains strong if higher numbers of containers and return points, suggested by industry, are adopted. As we have seen no evidence for higher numbers of RVMs than 3,021, this is also the figure modelled in Annex F.
- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Monday, 14 March 2022
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Current Status:
Answered by Lorna Slater on 29 March 2022
To ask the Scottish Government, in relation to A Deposit Return Scheme for Scotland: Full Business and Regulatory Impact, published in July 2019, whether it will provide full details of the evidence base it used for its estimates for the number of (a) items in scope, which was estimated at 1.7 billion containers and (b) return points which was estimated at 14,386 manual and 3,021 automatic; whether these estimates were based on a consultants report, and, if so, whether it will publish that report and details of the evidence base used for that report.
Answer
The information presented in the version of the Business and Regulatory Impact Assessment (BRIA) published in July 2019 has been superseded.
Please refer to the amended Final BRIA published in December 2021 which can be accessed here: .
- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Monday, 14 March 2022
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Current Status:
Answered by Lorna Slater on 29 March 2022
To ask the Scottish Government whether allowance has been made in the calculation of the costs of the Deposit Return Scheme for the VAT that will be levied and, if this is the case, whether it can provide the details of how such costs have been incorporated into its calculation, and, if this is not the case, what the reasons are for its position on the matter.
Answer
The economic modelling in the amended Business and Regulatory Impact Assessment for Scotland’s Deposit Return Scheme does not account for any VAT being levied on deposits. That is in line with best practice as set out in HM Treasury’s Green Book ( ) because VAT is considered to be a transfer payment that does not affect the output or consumption of resources.
- Asked by: Fergus Ewing, MSP for Inverness and Nairn, Scottish National Party
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Date lodged: Monday, 14 March 2022
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Current Status:
Answered by Lorna Slater on 29 March 2022
To ask the Scottish Government, regarding its proposed Deposit Return Scheme, what its position is on (a) the estimates by Circularity Scotland that (i) 2.7 billion items would require to be recycled, (ii) 37,000 return points are needed and (iii) 6,000 Reverse Vending Machines are required and (b) whether its conclusion, as set out in Annex F, paragraph 5, page 152 of the Deposit Return Scheme for Scotland Final Business and Regulatory Impact Assessment (BRIA), published in December 2021, stating that “We remain committed to the assumptions set out in Table 3 as our final and best, estimate of the costs and benefits” remains valid, and what information it has on the position of Circularity Scotland regarding the figures used by the Scottish Government in Table 2 on page 19 of the Deposit Return Scheme for Scotland Final Business and Regulatory Impact Assessment (BRIA), published in December 2021.
Answer
As set out in Annex F to the amended Business and Regulatory Impact Assessment (BRIA) for our Deposit Return Scheme (DRS), published on 15 December 2021, we consider that there is a degree of uncertainty attached to the figures proposed by Circularity Scotland Ltd (CSL) for the number of scheme articles and return points under DRS. For that reason our final and best estimate remains that set out on p19 of the amended BRIA.
Nevertheless, as Annex F shows, even if we were to adopt these two figures there would continue to be a strong economic case for DRS.
We have seen no evidence for higher numbers of RVMs than the roughly 3,000 assumed in the Full Business Case Addendum and I understand that CSL is continuing to work from this figure. That is therefore the figure modelled in the updated Final BRIA that was published in December last year.