Scottish Government Consultation - Changes to Waste Management Services
North Ayrshire Council · 3 June 2025
Back to Cabinet — 3 June 2025 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
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NORTH AYRSHIRE COUNCIL 03 June 2025 Cabinet Title: Scottish Government Consultation: Changes to waste management services and the Call for Evidence (CfE) on the potential extension of the upcoming ban on landfilling biodegradable municipal waste. Purpose: To advise Cabinet of the Scottish Government Consultation on possible changes to household recycling collection services and the Call for Evidence on the potential extension of the upcoming landfill ban, and to seek Cabinet approval for the submission of the proposed response. Recommendation: That Cabinet: a) Notes the ongoing consultation and Call for Evidence; b) Grants authority to the Head of Service (Neighbourhood Services) to submit the Council’s response (Appendix 1 and 2); and c) Notes that responses to the consultation and Call for Evidence are also being submitted by other local authorities and COSLA; and d) Notes that further updates will be brought to Cabinet in the event that the Scottish Government introduce a change to the household recycling collection services detailed within the consultation. 1. Executive Summary 1.1 On 25 March 2025 Scottish Government launched the Changes to Waste Management Services online public consultation along with a Call for Evidence (CfE) on the potential extension of the upcoming ban on landfilling biodegradable municipal waste. 1.2 The Changes to Waste Management Services public consultation seeks to collect views on: • The approach to textile recycling, including whether to make kerbside collection of textiles by local authorities a mandatory service. • The current approach to the rural food waste exemption and whether that should continue in its current form, be amended or be discontinued.
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1.3 The Call for Evidence (CfE) on the potential extension of the upcoming ban on landfilling biodegradable municipal waste (household and commercial) seeks to support consideration of extending the landfill ban to include non-municipal biodegradable wastes. 1.4 This report seeks approval for submitting the draft response to the consultation included at Appendix 1 and the draft Call for Evidence response provided at Appendix 2. 2. Background 2.1 The Scottish Government’s Circular Economy & Waste Route Map was published in December 2024. The route map set out actions to develop a more circular economy in Scotland, supported by new powers set out in the Circular Economy (Scotland) Act 2024. The Route Map sets out the strategic direction for delivering a system-wide, comprehensive vision of Scotland’s circular economy from now to 2030. 2.2 The measures in the Route Map are grouped under four strategic aims, which reflect the span of the waste hierarchy: • Reduce and reuse; • Modernise recycling; • Decarbonise disposal; and • Strengthen the circular economy. 2.3 The Scottish Government Route Map contains 11 priority actions, which are: • Publish a Product Stewardship Plan to set out how to tackle the environmental impact of priority products by 2025/26; • Develop an intervention plan to guide long-term work on household food waste reduction behaviour change by 2026/27; • Develop with stakeholders effective options to implement mandatory reporting for food waste and surplus by businesses from 2025/26; • Support the development of a model for regional Scottish hubs and networks for the reuse of construction materials and assets from 2025-2027; • Facilitate a co-design process for high quality, high performing household recycling and reuse services, 2024 – 2026; • Review of compliance with commercial recycling requirements by 2026; • Co-design measures to improve commercial waste service provisions, commencing by 2030; • Develop a Residual Waste Plan to 2045 by 2027; • Facilitate the development of a Sector-Led Plan to minimise the carbon impacts of the Energy from Waste Sector by 2027; • Develop a circular economy strategy every five years, first one in 2026; and • Set new circular economy targets by 2027. 2.4 By 2030, Scottish Government aims to have a high-performing recycling system that has modernised recycling services for households and businesses across Scotland, optimised the performance of collection services, and can recycle most waste types to maximise diversion of waste from disposal.
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2.5 Increasing the number of materials recycled and the proportion of these recycled is expected to deliver carbon reductions, reduce the environmental impacts associated with extracting new raw materials, and create a range of important economic opportunities to reprocess and reuse materials. 2.6 The Circular Economy & Waste Route Map to 2030 prioritises the co-design of a new Code of Practice for household waste recycling under the strategic aim to Modernise Recycling. The co-design process to design the new Code of Practice will include key stakeholders from Scottish Government, COSLA, SOLACE and the Local Authority Waste Management Officers Network, as well as other relevant parties. 2.7 Under the Circular Economy (Scotland) Act 2024, adherence to the new statutory Code of Practice will become mandatory for local authorities, however, Scottish Government and COSLA have agreed that the new Code of Practice will be subject to the prior agreement of the COSLA Environment and Economy Board. 2.8 The main goal of the co-design process is to ensure the new mandatory Code of Practice sets out an approach to increase recycling that is practical, effective, and feasible for local authorities and other service providers, rather than enforcing a rigid, top-down model. 2.9 The co-design process aims to ensure the new Code of Practice is adaptable, considers differences in geography, demographics, housing, and existing infrastructure, while providing access to consistent recycling services, but recognising that different areas may require different approaches to service delivery. 2.10 This consultation is only one part of the engagement to establish an evidence base on which to co-design the new Code of Practice. The policy areas that are being consulted on are being explored in the context of the development of the new statutory Code of Practice and it may form part of the co-design process, depending on the findings of this consultation. Depending on future policy decisions, legislative change may also be required out with the new statutory Code of Practice. 2.11 The Changes to Waste Management Services consultation focuses on the approach to textile recycling, including whether to make kerbside collection of textiles by local authorities a mandatory service and the current approach to the rural food waste exemption and whether that should continue in its current form, be amended or be discontinued, and the approach. Household Collection of Textiles 2.12 The Council in partnership with a third-party organisation currently collects a wide range of textiles (clothes, shoes, hats, towels, linen, curtains, belts etc.) via a network of 38 textile banks throughout the area and the organisation that collects them also works closely with charities who benefit from the textile banks. The service also promotes the use of over 20 charity shops throughout the area for textile reuse, which rely on donations from the public.
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2.13 There is no cost to the Council for the current service for the provision and collection of textile banks across North Ayrshire. A small amount of income is also received from the textile bank provider. 2.14 A new requirement for local authorities to provide a mandatory kerbside collection of textiles is proposed within the consultation. This new requirement could potentially add significant unbudgeted capital and revenue costs to the Waste Service unless additional funding was provided to support the introduction of a new textile collection service. 2.15 Additional capital costs would be incurred for vehicles, containers and any infrastructure changes required at our waste sites to store textiles in a dry and clean manner, to maximise their ability for reuse. Additional revenue costs would be incurred for employees, fuel, vehicle maintenance costs, as the collection of textiles is not a waste stream that could be easily integrated within our current kerbside collection system. 2.16 Consideration would need to be given to the collection method utilised, as most councils already have a well-used network of textile banks and charity shops in place. Research and modelling would need to be carried out to establish if a kerbside textile collection service would be more efficient and effective than our current approach, and what the net cost and net carbon impact of introducing a new kerbside textile collection service would be, particularly in more remote areas. 2.17 The proposal could potentially have a significant impact on local charitable organisations and charity shops who rely on public donations of textiles for resale, which promotes their reuse. Mixed kerbside collections could reduce the textile material quality compared to donating to charity shops, impacting on textile reuse levels. 2.18 The draft responses to the consultation questions that relate to the proposed introduction of a new requirement for local authorities to provide a mandatory kerbside collection service of textiles is provided in Appendix 1, Questions 1 to 13 for the consideration of Cabinet. Rural Food Waste Exemption 2.19 The Council currently provide a fortnightly comingled food and garden waste collection service (brown bin) to all households on the mainland and Cumbrae. 2.20 An exemption currently applies to remote rural areas and islands, which includes the Island of Arran, as it was not deemed environmentally and economically practical to provide a segregated food waste collection service to these areas across Scotland. 2.21 The Environmental Protection Act 1990, amended by the Waste (Scotland) Regulations 2012, require local authorities to provide segregated food waste collections to householders and separately requires all food businesses producing more than 5kg of food waste a week to ensure they separate their food waste for collection, unless the rural exemption applies. 2.22 The proposals within the consultation relate to the current rural food waste exemption and whether that should continue in its current form, be amended or be removed.
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2.23 The proposed amendment to the exemption in the consultation relates to changing the basis for the areas and post codes covered from the Scottish Government’s 6-fold Urban/Rural Classification of 2009-10 to the Scottish Government Urban Rural Classification 2022. The exemption operates by not requiring local authorities to provide a receptacle for separate collection of food waste if properties are located in areas designated as ‘remote small towns’, ‘accessible rural areas’ or ‘remote rural areas’. 2.24 The 2022 classification includes fewer postcodes classified as rural due to demographic changes, such as population increase and areas of new building. Adopting the 2022 classification would result in fewer postcodes being eligible for the exemption. 2.25 On review of the proposed use of the 2022 classification, this would not require any changes to the current waste collection service provided by the Council. 2.26 A proposal to remove the food waste exemption would require a separate food waste collection service to be provided to all households on Arran. This would have significant capital and revenue budget implications as well as ferry capacity issues for the Council, which would need to be modelled and assessed for viability. 2.27 Additional capital funding would be required for new vehicles and containers. The site infrastructure that would be needed at the Arran Waste Transfer Station to facilitate the separate storage of food waste in accordance with animal by-product legislation would be challenging to create, due to space constraints within the site. A detailed feasibility study would be needed to determine the cost and viability of the existing site, should the proposal to remove the exemption be taken forward by Scottish Government. 2.28 The proposal would potentially increase recycling performance, however, additional revenue budget would be required for employees, fuel, vehicle maintenance costs and transport costs, albeit there would be a net reduction from existing waste processing costs. There is no current on-island solution for processing food waste, and this would need to be transported for processing to the Council’s contractor in South Lanarkshire. Additional funding would be needed for the capital and revenue costs required for implementing the proposal if this service was required by Scottish Government, which would need to be based on detailed modelling to assess the net cost and net carbon impact of the proposed change. 2.29 The draft responses to the consultation questions that relate to the proposals to retain, amend or remove the current rural food waste exemption is provided in Appendix 1, Questions 14 to 17 for the consideration of Cabinet. The draft responses to the general consultation questions are provided in Appendix 1, Questions 18 to 23. Call for Evidence on Extending the Landfill Ban 2.30 From 31 December 2025 a ban on landfilling biodegradable municipal waste comes into force. When landfilled, biodegradable waste breaks down to produce methane, a greenhouse gas that is around 28 times more potent than carbon dioxide. 2.31 Municipal biodegradable waste includes waste from households, such as paper and cardboard, food waste, wood etc, and waste that is similar in nature and composition to
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waste from households, which includes the commercial waste that the Council collects from businesses. 2.32 The Council has been prepared for the ban on the landfill of the biodegradable municipal waste that it collects for many years and has not relied on landfill as a disposal solution since before 2020, as we moved towards a more environmentally sustainable solution through the Clyde Valley Residual Waste Partnership. The Council’s own landfill site in Shewalton, Irvine closed for the acceptance of waste in March 2018. 2.33 The proposals within Scottish Government’s Call for Evidence on the potential for extending the landfill ban to include non-municipal biodegradable wastes has limited direct impact on the Council, as we only collect or manage a small amount of waste that is defined as non-municipal biodegradable waste, which is more relevant to the private waste management industry. The proposals include adding sorting residues from the mechanical treatment of wastes to the ban, which the Council does not manage, however the contractors that process our waste manage this as a by-product from their processes. 2.34 The non-municipal biodegradable waste types that are discussed in the Call for Evidence that the Council collects or manages includes ‘mixed construction and demolition wastes’, that can arise from activities carried out by Building Services. Larger construction and demolition projects initiated by Property Management and Investment carried out by private contractors may be impacted by extension of the ban, however these types of contracts already include clauses and measures to maximise the reuse and recycling of construction and demolition waste to minimise any waste that goes to landfill. 2.35 The Call for Evidence seeks to gather evidence on other wastes (such as mattresses), including those that are non-biodegradable, that could be banned from landfill to move the management of these wastes further up the waste hierarchy and to reduce the environmental impact of their disposal. 2.36 The draft responses to the Call for Evidence questions that relate to the potential extension of the upcoming ban on landfilling biodegradable municipal waste is provided in Appendix 2, Questions 1 to 24 for the consideration of Cabinet. 3. Proposals 3.1 That Cabinet: a) Notes the ongoing consultation and Call for Evidence; b) Grants authority to the Head of Service (Neighbourhood Services) to submit the Council’s response; c) Notes that responses to the consultation and Call for Evidence are also being submitted by other local authorities and COSLA; and d) Notes that further updates will be brought to Cabinet in the event that the Scottish Government introduces a change to the household recycling collection services detailed within the consultation.
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4. Implications/Socio-economic Duty Financial 4.1 There are no financial implications resulting directly from submission of the consultation response or Call for Evidence response, however, there may be financial implications for the Council if Scottish Government introduced a requirement for the mandatory kerbside collection of textiles or removed the current derogation for the collection of food waste in remote rural areas. Human Resources 4.2 None. Legal 4.3 There are no direct legal implications of the response itself, however, depending on future Scottish Government policy decisions, future legislative changes may be required out with the Household Recycling Code of Practice. Equality/Socio-economic 4.4 There are no equality/socio-economic implications resulting directly from submission of the consultation response. However, it is unclear if such implications could arise from the proposals in the consultation and Call for Evidence. The Scottish Government would be required to undertake the necessary impact assessments in relation to the introduction of any additional legislation. Climate Change and Carbon 4.5 There are no climate change and carbon implications resulting directly from submission of the consultation and Call for Evidence response. However, potential benefits for Climate Change and carbon reduction could potentially arise from the proposals in the consultation and Call for Evidence. Key Priorities 4.6 None. Community Wealth Building 4.7 None. 5. Consultation 5.1 The proposed response has been informed through consultation with Officers of the Council and COSLA. RUSSELL McCUTCHEON Executive Director (Place) For further information please contact Thomas Reaney, Head of Service (Neighbourhood Services) Background Papers 0
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Page 1 of 16 Appendix 1 Scottish Government Consultation Changes To Waste Management Services Closing Date: 17th June 2025 Household Collection of Textiles - 13 questions 1. Do you consider your current options for textile recycling to be efficient? ☒ Yes ☐ No ☐ Don’t Know 2. Do you consider your current options for textile recycling to be accessible? ☒ Yes ☐ No ☐ Don’t Know 3. If you do not consider your current options for textile recycling to be efficient and/or accessible, what improvements would you recommend? Please provide your answer here. 4. Do you believe household collection of textiles would provide benefits to householders? ☒ Yes ☐ No ☐ Don’t Know Not applicable.
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Page 2 of 16 5. What potential benefits do you consider household collection of textiles would provide to householders? Please provide your answer here. 6. Do you believe household collection of textiles should be a service supplied by local authorities? Extra note: A mandatory service would be a statutory requirement for all local authorities in Scotland to collect textiles separately as part of their waste collection services at household kerbsides. This may require a separate household recycling bin. (Strongly Agree/Agree/Neither Agree nor Disagree/Disagree/Strongly Disagree) ☐ Strongly Agree ☐ Agree ☐ Neither Agree nor Disagree ☐ Disagree ☒ Strongly Disagree Where householders are disposing of textile waste through residual/general waste, a separate household waste collection service for textiles would provide additional capacity and space for non-recyclable waste material within their residual/general waste containers, however this would potentially require householders receiving another wheeled bin container, where many householders do not want more wheeled bins, due to lack of storage space at their properties. The other option is to have a separate bag collection using a ‘milk-round’ type collection approach, however this option is likely to be sporadically used and therefore most likely to inefficient and not cost effective to operate, resulting in higher costs. Research and modelling would need to be carried out to establish if a kerbside textile collection service would be more efficient and effective than our current approach, and what the net cost and net carbon impact of introducing a new kerbside textile collection service would be, particularly in more remote areas.
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Page 3 of 16 Please provide your answer here. 7. If collections of textiles from households are not a service supplied by local authorities, do you think there should be a requirement for all local authorities to offer textile recycling through Household Waste Recycling Centres or other bring facilities? ☒ Yes ☐ No ☐ Don’t Know Please provide your answer here. 8. What is the estimated number of textile items you recycle/dispose of each year? ☐ I don't recycle my textiles ☐ 1 – 5 ☐ 6 - 15 ☐ 16 - 30 Most councils already provide a wide network of textile banks throughout their area. Research and modelling would need to be carried out to establish if a kerbside textile collection service would be more efficient and effective than the current approach, and what the net cost and net carbon impact of introducing a new kerbside textile collection service would be, particularly in more remote areas of Scotland. If this was a new requirement then it could potentially add significant unbudgeted capital and revenue costs to local authorities, unless additional funding was provided to support the introduction of a new textile collection service, potentially through the widening of Extender Producer Responsibility to include textiles. The proposal could potentially have a significant impact on local charitable organisations and charity shops who rely on public donations of textiles for resale, which promotes their reuse. North Ayrshire has areas of high deprivation, and many people rely on charity shops for obtaining quality low-cost clothing. Yes, as most local authorities already provide the ability for residents to deposit textiles in their Household Waste Recycling Centres or at other bring facilities, however, this may be more difficult and challenging in remote rural areas and islands. The implications of this potential additional requirement on local authorities should be explored further through the co-design process for the Code of Practice on Household Recycling.
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Page 4 of 16 ☐ 31 - 50 ☐ Over 50 ☐ Don't Know This question is not relevant to a local authority. 9. What services are currently available in your local authority area to recycle or dispose of textiles? ☒ Local Textile Bank in supermarket / car park ☒ Charity Shops – In Store ☒ Charity Shops – Household Collection ☒ Household Waste Recycling Centre 10. What services do you currently use in your local authority area to recycle or dispose of textiles? ☐ Local Textile Bank in supermarket / car park ☐ Charity Shops – In Store ☐ Charity Shops – Household Collection ☐ Household Waste Recycling Centre ☒ Other If other, please provide your answer here. 11. Do you foresee any barriers or unintended consequences to local authority collection of textiles at the kerbside becoming a statutory service? ☒ Yes ☐ No ☐ Don’t Know This question is not relevant to a local authority.
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Page 5 of 16 Please provide your answer here. 12. If your local authority offered household collection of textiles, how likely are you to utilise this service? ☐ Very likely ☐ Somewhat likely ☐ Somewhat unlikely ☐ Very unlikely ☐ Not sure This question is not relevant to a local authority. Yes. If this was a new requirement then it could potentially add significant unbudgeted capital and revenue costs to local authorities, unless additional funding was provided to support the introduction of a new textile collection service, potentially through the widening of Extender Producer Responsibility to include textiles. Research and modelling would need to be carried out to establish if a kerbside textile collection service would be more efficient and effective than the current approach, and what the net cost and net carbon impact of introducing a new kerbside textile collection service would be, particularly in more remote areas of Scotland. There over 20 charity shops in North Ayrshire which require a throughput of good quality clothes/textiles as well as other saleable goods. Any statutory service needs to ensure that these outlets which support the most vulnerable in society are not unduly impacted by any new collection service. As noted within the summary of the European Clothing Action Plan (ECAP) report that is highlighted in the consultation document, there is a significant element of textiles which would be of low value. Further research is required to ensure that there are viable markets for any additional textile materials collected.
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Page 6 of 16 13. Do you have any additional views, regarding household collection of textiles or what you would expect a useful service to look like? Please provide your answer here. Rural Food Waste Exemption - 5 questions 14a. Are you located in an area with a rural food waste exemption? ☒ Yes ☐ No ☐ Don’t Know 14b. What is your preferred approach to the rural food waste exemption in the future? ☐ Keep it as it is ☐ Remove it ☒ Other If other, please provide your answer here. The Council would have concerns around the risk of collecting low value textile materials with limited markets, which would impact the sustainability and effectiveness of any service. Research and modelling would need to be carried out to establish if a kerbside textile collection service would be more efficient and effective than the current approach, and what the net cost and net carbon impact of introducing a new kerbside textile collection service would be, particularly in more remote areas of Scotland. Our position with regards to the rural food waste exemption is that it should be discussed as part of the co-design work on the new Code of Practice with local authorities. There will be specific and potentially unique challenges of implementing food waste collection services and animal by-product compliant waste bulking and processing facilities in remote rural areas, such as islands. There will be significant additional revenue and capital costs for local authorities by implementing food waste collections in remote rural areas and this would need to be modelled, as well as the net carbon impact of any proposed change. Some remote rural areas may not have the necessary infrastructure to be able to support managing an additional waste stream (bulking facility space, available waste capacity and the ability to expand) and this would need to be explored further with each local authority.
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Page 7 of 16 15. If your local authority were to offer a kerbside food waste collection service, would you be likely to opt-in? ☐ Very likely ☐ Somewhat likely ☐ Somewhat unlikely ☐ Very unlikely ☐ Not sure This question is not relevant to a local authority. 16. If you live or operate a business in an area in which the rural food waste exemption is used, what do you currently do with your food waste? ☐ At-home composting ☐ Take it to local recycling centre ☒ Other If other, please provide your answer here. This question is not relevant to local authorities. As a local authority we promote and provide a comingled food and garden waste collection service except in areas which have an exemption from food waste collections, which only relates to the Island of Arran. In these exempt areas business will mainly dispose of their food through their residual/general waste collection services, although there may be some businesses who have implemented other adaptation or mitigating systems to reduce and manage their food waste, such as internal composting equipment for coffee grounds, plate waste from small-scale hotels, cafes and restaurants. The Council has been working with 3rd sector organisations and local businesses on Arran to explore and support options for both food waste and organic waste treatment on the island, however the cost of implementing on- island facilities has been prohibitive.
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Page 8 of 16 17. Do you have any other views regarding the rural food waste exemption? Please provide your answer here. Adopting the Scottish Government Urban Rural Classification 2022 would result in more postcodes being eligible for service in rural areas, although on review of the map provided within the consultation, all islands would still be exempt. If the rural classification was to be further altered, or the exemption was removed, additional animal by-product compliant waste treatment facilities would be required across rural and Island areas, whilst taking into consideration that the original exemptions were created to prevent the positive impact of food waste recycling being offset by negative impacts of collecting and transporting waste (including ferry transportation) from rural locations and islands. There will be significant additional revenue and capital costs for local authorities by implementing food waste collections in remote rural areas and this would need to be modelled, as well as ferry capacity and the net carbon impact of the proposed change.
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Page 9 of 16 All Consultation Topics - 7 questions 18. 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? Please provide your answer here. 19. 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? Please provide your answer here. 20. 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 additional impacts are evident. Charitable organisations and charity shops may be negatively affected by the proposed changes to introduce the mandatory collection of textiles at the kerbside, as they rely heavily on donations from the public. This would also affect users of charity shops who may rely on them for low-cost clothing. The proposal would pass on significant additional costs to local authorities to provide a kerbside collection service for textiles, which instead should be covered through the extension of existing Extended Producer Responsibility to implement the ‘Polluter Pays Principle’. Businesses within an area that is affected by altering the rural food classification and therefore removing the current exemption, are likely to have the opportunity to recycle more of their food waste, however access to services in remote rural areas may be challenging, and this requirement would pass on the additional costs of providing additional food waste collection services to local authorities. Whether this increases or reduces their costs may depend on their location, their existing suppliers and the distance to a licensed waste treatment facility. 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.
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Page 10 of 16 Please provide your answer here. 21. 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? Please provide your answer here. 22. 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? Please provide your answer here. 23. Environment: Do you think that the proposals contained in this consultation are likely to have an impact on the environment? Please provide your answer here. 24. Conclusion: 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. No additional impacts are evident. A proposal to remove the existing rural exemption for separate food waste collections in remote rural areas and islands may encourage investment opportunities for treatment facilities, if capacities and tonnages are appropriate for investment. This could support the delivery of on-island treatment solutions, although additional capital and revenue investment would be required to deliver appropriate collection services. No additional impacts are evident. The wider environment potentially could be improved by recycling more food and textiles, however the net impact of this would need to be modelled, as well as the net carbon impact of the proposed change. No further comments.
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Page 11 of 16 Appendix 2 - Scottish Government Call for Evidence on Extending the Landfill Ban to non-municipal waste 1. Which category in the following list best describes you? ☒ Local government 2. If you are replying on behalf of a business or representative organisation, please advise where your business is located, and an approximate size/number of staff (where applicable). 3. Do you produce or handle/dispose of EWC (European Waste Catalogue) 19 12 12 wastes? ☐ Produce from non-municipal sources ☐ Produce from municipal sources ☐ Produce from mixed non-municipal and municipal sources ☐ Handle/dispose of EWC191212 waste produced elsewhere ☒ No, I do not produce or handle/dispose of EWC191212 wastes 4. If you produce waste from mixed non-municipal and municipal sources, can you provide data on the proportion of EWC 19 12 12 wastes coming from non-municipal sources? ☐ Yes (please provide information in the box below) ☒ No 5. Do you have any data on the composition or characteristics (e.g., biodegradability) of EWC 191212 wastes sent to landfill at any point over the past 10 years? ☐ Yes (please provide information in the box below) ☒ No Not applicable. No, the Council do not produce or handle or dispose of EWC 19 12 12 (sorting residues from the mechanical treatment of wastes), however our contractors will handle this waste type as a by-product of their mechanical treatment processes. Not applicable.
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Page 12 of 16 6. Are there alternative treatment options available to you for sorting residues (EWC191212 wastes) that could reduce the environmental impact of managing or disposing of these wastes? Are there any barriers to adopting alternative treatment options? ☐ Yes (please provide information in the box below) ☒ No 7. Do you have any evidence about the need to continue landfilling sorting residues from the treatment of non-municipal waste? ☐ Yes (please provide information in the box below) ☒ No 8. Do you agree with the list of non-municipal waste that are likely to be biodegradable and maybe biodegradable wastes, are there other wastes you consider biodegradable and do you have evidence on the biodegradability of any of these wastes that you can share? ☐ Yes (please provide evidence if possible in the box below) ☒ No (please provide details and evidence if possible in the box below) 9. Are there biodegradable wastes, from Tables 6.2.1 (pg.11) and 6.2.2 (pg.12) or otherwise, that you think will need to be landfilled in the future? No. Not applicable. The Council has no evidence of such but is aware that some materials may still be required to be disposed of at landfill, due to their inability to be directly treated in an Energy from Waste (EfW) plant, such as items containing harmful, or hazardous material. The Council has no direct experience of managing the waste types noted in Table 6.2.1 of the Call for Evidence. The Council has no direct experience of managing the waste types noted in Table 6.2.1 and 6.2.2. of the Call for Evidence.
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Page 13 of 16 10. Our Circular Economy and Waste Route Map noted an intention to identify priority waste streams to mitigate environmental impacts. Which waste streams would you consider to be the priority waste streams to divert from landfill? 11. Are there treatment options available for biodegradable wastes, from Tables 6.2.1 (pg.11) and 6.2.2 (pg.12) or otherwise? Do you have evidence or thoughts on why these materials continue to be landfilled? 12. What are the potential positive and negative impacts of not including soil in an extended landfill ban? 13. Do you have any views and/or evidence on the suitability of TOC (Total Organic Carbon), AT4, Dynamic Respiration or loss on ignition tests to determine the biodegradability of non-municipal wastes? 14. Do you currently carry out biodegradability testing of non-municipal wastes and if so, are you able to share any evidence or information on the testing that you carry out? ☐ Yes, carry out testing and can share evidence/examples ☒ No 15. Would a ban on landfilling mattresses support increased recycling of end-of-life mattresses? ☒ Yes (Please provide further information in the box below) ☐ No (Please provide further information in the box below) Mattresses, carpets and furniture, should all be considered as priority waste streams to be diverted from landfill, due the value they can create within a Circular Economy. These waste types should also be considered for inclusion in an extension to existing Extender Producer Responsibility (EPR) requirements to implement the ‘Polluter Pays Principle’. The Council has no direct experience of managing the waste types noted in Table 6.2.1 and 6.2.2. of the Call for Evidence. Continuing to encourage the reuse and recycling of soils is essential due to the associated carbon benefits as noted within the consultation, however, soil will still be required for engineering purposes on landfill sites and therefore the proposal not to include soil in the ban seems a reasonable approach. The Council has no direct experience around data or evidence of the non- municipal waste types noted.
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Page 14 of 16 16. Would a ban on landfilling mattresses lead to the diversion of mattresses to incineration? ☒ Yes (Please provide further information in the box below) ☐ No (Please provide further information in the box below) 17. If mattresses could no longer be landfilled, what other barriers are there to increasing the recycling of mattresses? Yes, this would allow this material stream to be diverted from landfill or Energy from Waste through mattress reuse, or through the recycling of the materials which make up mattresses, such as metals and textiles. This approach should be led by the relevant sector which placed the items on the market, through potentially an Extended Producer Responsibility (EPR) system, to apply the ‘Polluter Pays Principle’. Consideration is required around the composition of future mattress waste, as the sector pivots from using existing materials, such as metals and textiles to foams, which will require suitable treatment facilities and end markets to enable them to be recycled. There are several mattress reuse initiatives in Scotland, including a successful project in North Ayrshire operated by Cunninghame Furniture Recycling Company that successfully divert mattresses away from disposal and would continue to divert from incineration. There are also several third parties, though limited, who provide recycling solutions for mattresses. However, given the vast numbers of waste mattresses produced in Scotland, it is likely that final disposal at Energy from Waste facilities would be required, as well as improved reuse and recycling solutions. The sector which placed the items on the market, should be responsible for developing reuse, recycling and disposal solutions, through Extended Producer Responsibility to apply the ‘Polluter Pays Principle’. Final disposal routes for mattresses would still need to be considered, as it is unlikely that all, or the majority of mattresses, could be reused or recycled by third parties, due to the low value of the materials when recycled. Limited capacity to treat the significant number of mattresses produced in Scotland would require various solutions to manage that waste stream. Support would be required to enhance the value and markets for the recyclable materials within mattresses, to enable the recycling supply chain to deliver a sustainable service and business model.
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Page 15 of 16 18. What other policies should be considered to encourage the continued diversion of waste, particularly biodegradable waste, away from landfill? 19. Are there changes to the Scottish Landfill Tax, or other fiscal leavers such as the forthcoming Scottish Aggregates Tax, that could incentivise the diversion of wastes away from landfill, particularly biodegradable wastes that will not fall under the landfill ban? 20. What could the Scottish Government do to incentivise investment in alternative treatment infrastructure? 21. If further waste streams were to be included in the landfill ban, what timescale for implementing the ban would allow for industry preparations? 22. Are you able to share information about the potential costs associated with diverting waste to alternative treatment options for the wastes detailed here (including for example costs of testing)? (Please provide details and impacts if possible) End markets require to be developed in Scotland to deal with the additional recyclates. This would support the reduction of emissions by treating locally, enhancing local investment opportunities and also improve employment opportunities in Scotland, contributing to a more circular economy. The Council has limited exposure to Scottish Landfill Tax (SLT), due to having previously secured a more environmentally sustainable Energy from Waste solution through the Clyde Valley Residual Waste Partnership, however, the continuation of the SLT scheme could further incentivise innovative solutions to divert more waste away from being landfilled. Research and pathfinder projects could be funded to secure an understanding of the benefits both financially and environmentally of new alternative treatment solutions. These solutions should be considered for utilisation in urban, rural and island settings. The Council does not rely on landfill for the management of its waste. The wider Scottish waste industry that still relies on landfill would need to provide views on the timescales required for them to find alternative solutions to landfill. The Council has no information available relating to the potential costs of diverting the waste types detailed in the consultation to alternative treatment options.
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Page 16 of 16 23. Do you have any evidence of other, unintended consequences of diverting waste, particularly biodegradable wastes, away from landfill (such as flytipping)? (Please provide details and impacts if possible) 24. Do you have any other comments or evidence that you would like to share on the potential expansion of the ban on landfilling biodegradable municipal waste? The Council does not have any direct evidence of the unintended consequences of diverting other types of waste away from landfill. There could be a cost impact for producers of waste, as processing to remove recyclable material and then sending the non-recyclable elements of waste to Energy from Waste facilities tend to be more expensive than landfill, although this margin may be reducing through recent increases in landfill tax, which incentivises producers to find more cost effective and environmentally sustainable solutions. The availability of sufficient alternative treatment capacity in Scotland would need to be considered through capacity modelling. Waste tourism should be considered if the landfill ban were to be extended, where the outcomes are that waste types that have limited markets, or they are of low value, are then diverted from landfill in Scotland to being landfilled in other parts of the United Kingdom.