Aiming high

Written by: David Burrows | Published:

Scotland has been praised for its bold food waste reduction target, but is it actually achievable? David Burrows reports

Since 2009, Scotland has reduced its food waste by almost 8%.

“That’s a great start,” said former environment secretary Richard Lochhead last October when the figures were announced, “but I want to see more done.” So in February 2016 he set a national target to cut food waste a further 33% by 2025. “It’s the first of its kind in Europe,” Lochhead said proudly. Three months later he stepped down and left Roseanna Cunningham to deliver on his promise. Has she been handed a poisoned chalice?

The reaction from many of those involved in the waste sector in Scotland is “quite possibly”. Support for the target is strong, but many have been left wondering what happens now. How will prevention be measured? Will the target be mandatory or voluntary? What additional targets might be set for local authorities? Will there be a crackdown on businesses not complying with existing food waste regulations? All are questions buzzing around Scotland’s waste sector.

Off the starting block

So, where does Cunningham start? Top of her ‘to do’ list has to be answering the measurement question. That won’t be easy. “In the waste sector, there are constantly technological developments which improve processing and data collection,” explains Laura Tainsh, a partner at law firm Davidson Chalmers. “However, I am not as yet aware of any such developments that will accurately measure performance against the new target.”

Indeed, waste prevention is tricky to implement and enforce, admits Stephen Freeland, policy advisor at the Scottish Environmental Services Association (SESA). The Scottish Government’s circular economy strategy (within which the food waste target sits) is light on detail in this respect, but Freeland reckons that a change in ‘per capita food waste arisings’ will probably be used to measure progress towards the target.

Pulling that kind of data together could be another challenge. The good news is that food waste collected by councils and commercial waste management companies is measured through Scotland’s existing waste data strategy. The bad news is that there could be sizeable gaps to plug in the spreadsheets.

For example, around 1.4 million tonnes of food waste is generated in Scotland from all sources, according to government figures. However, the Scottish Environment Protection Agency (SEPA) data for 2014 shows that less than 320,000 tonnes of food waste was managed either by local authorities or the private waste management sector.

The challenge in terms of achieving the target will therefore be to understand where the remaining million tonnes or so arises, says Jamie Pitcairn, director for Ricardo Energy & Environment in Scotland, as well as to put in place prevention measures across both household and commercial and industrial streams.

Let’s start with local authorities

Councils have made a decent start on the residual side, with all of those required to provide a food waste collection service as part of the Waste (Scotland) Regulations now doing so.

What happens next, in terms of progress, depends partly on whether the 33% reduction target becomes mandatory or not, says Stratton MacDonald, service co-ordinator at South Ayrshire council and Scotland’s representative for the Local Authority Recycling Advisory Committee (LARAC).

A consultation is expected soon and it will throw up further questions. “If it’s to become a compulsory target, then will it apply to Scottish councils individually for their household and commercial food waste arisings?” MacDonald wonders. “And if so, would there be penalties [or] fines imposed on any council not achieving the target?”

Penalising local authorities in this way would be a step too far, he says: “There should be more responsibility accepted by the food producers. Householders also have their part to play by participating in council-run food waste recycling schemes, which to date they have been notoriously reluctant to do.”

Few would doubt that separate food waste collections are a good idea, economically and environmentally. But they can be hard to get off the ground – especially if corners are cut in marketing the services to residents. “Food waste producers must be required to play an integral role if a 33% reduction is to beachieved,”MacDonald continues.“There needs to be a massive communications campaign and some means of engaging householders to avoid food waste, or at the very least use their food waste recycling bins as they are intended to be.”

But who will pay for that? The costs of meeting the target remain unclear. The government has already put a £500 million figure on the savings for businesses and households, but a spokesman clams up when pressed about the funds available to deliver a 33% reduction in food waste by 2025. This is concerning.

“Funding is the main issue with the restricted budgets that local authorities are working with,”says Tainsh at Davidson Chalmers. That’s putting it mildly.

“Tuesday 9 February 2016 was a black day for local democracy in Scotland,”wrote Stephen McCabe, Labour leader at Inverclyde Council in a piece for The Guardian. That was the day council leaders were “forced” to sign the local government financial settlement for 2016/17,which amounted to a £350m cut and a continuation of the council tax freeze.

“Relations between the Scottish government and local government are at an all-time low,”
McCabe noted. A recent article in Holyrood, the current affairs magazine, also noted how
the “entente cordiale [previously enjoyed between the SNP and local government] has
begun to disintegrate”.

As good as it gets

According to the Accounts Commission’s report in March, recycling was actually among the services to deliver improved performance in 2014/15, in spite of the squeeze on finances. But there is a sense that that is about as good as it gets: the scale of challenge facing councils this year and beyond has “significantly increased”, the Commission’s chairman warned.

Funding restrictions are also creating issues for regulators. SEPA, for instance, has had to deal with a £2.4 million cut this financial year (about 7%). Terry A’Hearn, the agency’s chief executive and an economist by training, has said the cuts are manageable. He also said that it is better to set ambitious targets and nearly get there than to set unimpressive ones and get there.

That’s a mantra many pioneers of sustainability follow. Mike Barry, who heads up Marks & Spencer’s Plan A project, once told me: “If you’re meeting all your targets all of the time, then you’re not stretching yourself.” That makes sense; but a look at recent performance suggests Scotland has a record for stretching itself too far; getting nowhere near some of the targets it has set.

Possible blip

The country had missed its climate targets four years on the trot until figures for 2014, published earlier this year, showed CO2 emissions had fallen sufficiently. That might be a blip, however: warm winters and the loss of heavy industry could have contributed more significantly to the fall than bold government policy. It’s no secret that Scotland is also struggling to meet recycling targets: rates edged up to 44.3% in 2015, some way off the 50% target the government set for the end of 2013.

There are also concerns that SEPA hasn’t got the resources to enforce the Zero Waste Regulations, which require most food businesses to separate their food waste for collection. The agency has new powers to issue on-the-spot fines of up to £300 for non- compliance, while repeat offenders could face penalties of up to £10,000. Only one fine has been issued so far, however, and that was to a waste carrier, according to SEPA.

The approach has been soft touch, so far, which has been welcomed by the food industry.

SEPA is running a campaign until the end of March next year to help raise awareness, following which it will produce updated figures on compliance. Data compiled for April to September last year showed that 62% of the 6,752 premises sampled by 25 (out of 32) local authorities were fully compliant with the law. A further 20% were making efforts to comply, but 18% were still using a single general waste service.

Tainsh at Davidson Chalmers believes companies have had more than enough time to fall into line. Ricardo’s Pitcairn agrees – he suggests the focus should be on smaller outlets where compliance is “low” (the regulations initially targeted businesses producing 50kg or more of food waste per week, but the threshold has now been lowered to 5kg). “The majority of small food businesses – restaurants and cafés across the hospitality sector – are not complying with the regulations and this will need to change if both the landfill ban (by 2021) and the 33% food waste reduction target are to be met,”he explains.

The Institute of Hospitality didn't respond to requests for comment, but it is worth noting that food waste costs Scotland's hospitality sector £64 million a year, so there are considerable economic benefits for compliance. Indeed, the regulations may only place a duty on businesses to recycle their food waste rather than reduce it, but separation tends to lead to reduction, saving businesses money.

Business food waste

It is unclear what targets will be set for business food waste, but the food industry is likely to lean towards a voluntary agreement rather than a mandatory one. Ideally, it will also be aligned to the Courtauld Commitment 2025. “We hope there is consistency in measurement to ensure Scottish firms don’t have to report progress against two different targets, causing additional costs,” says a spokeswoman for Food and Drink Federation Scotland.

The food industry is likely to oppose the introduction of further legislation on food waste, but one area the government could well look at closely is food redistribution (a topic that has attracted plenty of media attention in the past 12 months). FareShare says it’s currently cheaper for businesses to send food waste to anaerobic digestion or the animal feed sector than to give it to redistribution charities. Gillian Kynoch, head of FareShare Scotland, is calling for a more “nuanced approach” from Scotland’s policymakers.

“Currently, we’re only able to access and redistribute a small fraction of surplus food,” she explains. “We’d like the government to ensure there’s a level playing field by introducing an incentive or tax break on charitable food redistribution, like there is in other countries.”

What policies are under consideration? The government’s spokesman gives nothing away: “We will shortly engage with stakeholders across sectors to discuss the way forward, including what regulatory measures, policy and infrastructure might be required,” he says.

Scotland has certainly set itself apart with its food waste target, part of a new circular economy strategy (let’s not forget that the European Commission erased a similar target from its Circular Economy Package). The strategy is called Making things last, but as Cunningham remarked at October’s Scottish Resources Conference: “Now we need to make things happen.” And quickly.

The target is from 2015 to 2025, so as you read this, we are already almost a year into a 10-year project


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