- 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 increase in business costs for an additional half a billion containers within the scheme, from table 1 to table 2, of £34 million, in light of this being a 3% cost increase associated with a 23% increase in containers, how this cost was calculated, and how distance takeback services from online retailers have been factored into the calculations for the additional half a billion containers in the market place.
Answer
The economic model underpinning the figures in the amended final Business and Regulatory Impact Assessment takes account of a number of factors and costs and benefits do not necessarily increase in proportion to the change in input.
The modelled cost increase reflects the likelihood that there will be additional capacity within the system for return points to handle additional containers and the possibility of an increase in the frequency of collection rather than requiring additional reverse vending machines (RVMs). This would lead to additional running costs and staff time but not costs for additional RVMs. The scheme administrator is responsible for setting a suitable logistics schedule with retailers at an agreed frequency for the collection of materials, aligned with the capacity of the RVM and individual store requirements.
- 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: A Deposit Return Scheme for Scotland: Final Business and Regulatory Impact Assessment (BRIA) (www.gov.scot) .
- 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, regarding its proposed Deposit Return Scheme, whether it will provide the detailed calculations for how each of the figures were arrived at as set out in Table 3 on page (a) 15 of A Deposit Return Scheme for Scotland: Full Business and Regulatory Impact, published in July 2019 and (b) 20 of the Deposit Return Scheme for Scotland Final Business and Regulatory Impact Assessment (BRIA), published in December 2021, in particular in relation to the (i) costs and (ii) benefits for (A) local authorities, (B) business, (C) the regulator, (D) the system operator and (E) society.
Answer
The economic model underlying the analysis in the amended Business and Regulatory Impact Assessment (BRIA) for Scotland's Deposit Return Scheme was developed in line with best practice by Zero Waste Scotland on behalf of the Scottish Government. The key inputs to the model are set out at table 2 of the amended Final BRIA.
- 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 ( https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/938046/The_Green_Book_2020.pdf ) 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, 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: https://www.gov.scot/publications/deposit-return-scheme-scotland-final-business-regulatory-impact-assessment/ .
- 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, during the policy development period and leading up to the publication of the Deposit Return Scheme for Scotland Final Business and Regulatory Impact Assessment (BRIA), published in December 2021, the proposed Deposit Return Scheme was referred for consideration to the Scottish Government Regulatory Review Group, and if this is not the case, what the reasons are for its position on this matter.
Answer
The centralised BRIA quality assurance services provided by the Better Regulation team has ceased, their last meeting was in February 2018.
- 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, whether it will publish all (a) correspondence, (b) communication and (c) other documents between it and Circularity Scotland related to any conflict of opinion on the (i) detail of estimates of the number of (A) items to be recycled, (B) return locations and (C) Reverse Vending Machines required, and (ii) consideration of the wording and content of Annex F of the Deposit Return Scheme for Scotland Final Business and Regulatory Impact Assessment (BRIA), published in December 2021.
Answer
The position taken by Circularity Scotland Ltd (CSL) in respect of container and return point numbers, as I understand it, is set out at Annex F of the amended Business and Regulatory Impact Assessment (BRIA) for our Deposit Return Scheme (DRS) published in December 2021.
CSL’s position in respect of number of reverse vending machines is that they expect roughly 3,000 of these as set out in the Full Business Case for DRS.
CSL had no sight of the content of the amended BRIA in advance of publication.
- 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.