Delivering Scotland’s Circular Economy: A Route Map to 2025 and Beyond
Package 1: Promote responsible consumption, production and re-use
- To what extent do you agree with the measures proposed in this package to promote responsible consumption, production and re-use?
Please provide evidence to support your answer if possible.
- Strongly Agree
- Agree
- Neither agree nor disagree
- Disagree
- Strongly disagree
Supporting evidence:
RTPI Scotland supports the proposed package for its promotion of responsible consumption, production, and re-use. RTPI Scotland believes that the planning system can make a significant contribution to the aims of a circular economy through promoting the adaptive reuse of buildings and the recycling of construction waste. The planning system also plays a significant role in coordinating waste and recycling infrastructure through national and local development plans. This can be achieved, for example, through identifying appropriate sites in industrial areas, ensuring existing facilities are safeguarded from new development (through an agent of change type approach) and ensuring new waste produced by new developments is planned for. As set out in our response to the accompanying Circular Economy Bill consultation, planning should not just be seen as a key function for delivering these vital components of a circular economy but should be recognised as an integral and overarching means by which we can reduce resource consumption in society. The purpose of planning is to manage the use and development of land in the long-term public interest. Land itself should be considered as material or commodity that, through a functioning planning system can be either protected, developed, redeveloped, or managed in a manner that contributes to a functioning circular economy. This can be seen with policies that encourage re-use of vacant and derelict land and disincentivises greenfield development. Further to this, what development is permitted on this precious resource will also impact upon consumption rates, with for example, more densely populated areas consuming on average less materials[1]. Therefore, through by creating dense and walkable places with high quality placemaking through the implementation of 20 minute neighbourhoods, planning can reduce societal resource consumption whilst also addressing a plethora of other outcomes such as reducing health inequalities and meeting net zero carbon targets[2].
We note that the recently published draft NPF4 has an updated and expanded policy on zero waste requiring plans to identify locations for new infrastructure and supports development in line with the waste hierarchy. We also note the addition of a new policy relating to the climate emergency which requires that all developments should be designed to minimise emissions over their lifecycles, in line with the decarbonisation pathways set out nationally. We welcome the clear recognition that planning system is a critical player in delivering circular economy ambitions, but in our response to the draft NPF4 we ask for further strengthening of Climate Emergency policy to better include circular economy principles such as considering embodied carbon[3]. It should be noted that for several years RTPI Scotland has been promoting the re-use first principle and has pressed for its inclusion in the NPF4[4]. The re-use first principle is where previously used land, buildings, places, materials, and infrastructure are given preference over new resources.
We have also advocated for the publication of guidance and an assessment template to explain how the assessment of carbon emissions should be approached and presented. As a new duty RTPI Scotland would also like to raise awareness of the potential additional resource implications of managing new assessments, alongside the need to upskill planners’ climate literacy, which we suggested could be achieved through a nationwide training programme. Regarding the zero-waste policy, as with a number of other policy areas in the NPF4, we have expressed concerns with the length of this policy and that requirements for compliance with it need more clarity, especially in relation to the proposed preparation of a decarbonisation strategy. It is crucial that the final NPF4 creates national planning policy that supports planners in delivering the aims of the circular economy and that this makes a large contribution to delivering the proposed route map as set out; recognition of which should receive greater emphasis in proposals.
- Are there any further measures that you would like to see included in the Route Map to promote responsible consumption, production and re-use?
Further measures to include:
As set out in response to Q1, RTPI Scotland believes that the planning system can make a significant contribution to the promotion of consumption, production, and re-use in the built environment. To do so, it is critical that planners have the skills, resources, and clear policy frameworks necessary to implement such aspirations. However, research from RTPI Scotland[5] has revealed significant concerns around the resourcing of planning services with:
- Nearly a third of planning department staff have been cut since 2009
- Planning authorities’ budgets have diminished in real terms by 42% since 2009
- In 2020 local authorities only spent 0.38% of their total net revenue budgets
- Planning application fees only cover 66% of their processing costs
- There are 91 new and unfunded duties in the Planning (Scotland) Act, which could cost between £12.1m and £59.1m over 10 years
Research has also shown that planning has demographic and succession challenges with a limited pipeline. Only around 9% of staff in planning authorities are under 30 and there is an estimated replacement demand of around 500 planners over the next 15 years. Therefore, RTPI Scotland calls on Scottish Government to ensure that resource is also made available to increasing the pipeline of planners and to develop the necessary skills in our existing workforce to support the transition to a circular economy. Our recently published ‘Future Planners’ report has a number of actions to address workforce and skills issues in the industry[6]. Therefore, we recommend that the Skill and Training section be strengthened through specific reference to the critical role planners will play transition to a circular economy. We welcome close collaboration with Scottish Government, Skills Development Scotland and Zero Waste Scotland to develop a strong pipeline of future planners with the skills necessary to deliver a circular economy.
The Institute also recognises the opportunities to embed circular economy principles through the decision-making process through the modernising of the planning system with Scottish Government’s digital planning strategy[7]. The first mission set out in the strategy is to unlock the value of planning data. RTPI Scotland notes that in particular, the development of toolkits supporting Whole Life Carbon Assessment and the establishment of a Built Environment Carbon Database would be two clear tangible ways in which a modernised digital planning service could better help deliver a circular economy for Scotland.
Package 2: Reduce food waste
- To what extent do you agree with the measures proposed in this package to reduce food waste?
Please provide evidence to support any identified opportunities and challenges associated with the measures in your answer if possible.
- Strongly Agree
- Agree
- Neither agree nor disagree
- Disagree
- Strongly disagree
Supporting evidence:
No further comment.
- Are there any further measures that you would like to see included in the Route Map to reduce food waste?
Further measures to include:
No further comment.
Package 3: Improve recycling from households
- To what extent do you agree with the measures proposed in this package to improve recycling from households?
Please provide evidence to support your answer if possible.
- Strongly Agree
- Agree
- Neither agree nor disagree
- Disagree
- Strongly disagree
Supporting evidence:
No further comment.
- Are there any further measures that you would like to see included in the Route Map to improve recycling from households and incentivise positive behaviours?
Further measures to include:
RTPI Scotland believes that this section could be strengthened through clear recognition of the role that quality design of the built environment can play in improving recycling from households and incentivising positive behaviours. This could be, for example, through ensuring adequate space in kitchens for all bins is provided, or that accessible bin storage for higher density buildings is well considered.
Package 4: Improve recycling from commercial businesses
- To what extent do you agree with the measures proposed in this package to improve recycling from commercial businesses?
Please provide evidence to support your answer if possible.
- Strongly Agree
- Agree
- Neither agree nor disagree
- Disagree
- Strongly disagree
Supporting evidence:
No further comment.
- Are there any further measures that you would like to see included in the Route Map to improve waste recycling from commercial businesses?
Further measures to include:
RTPI Scotland particularly supports the commitment in this section to co-design measures which improve commercial waste service provisions that drive waste prevention and reuse.
However, we hold some reservations on the choice of language of ‘zoning’ in reference to exploring the establishment of commercial waste zones. One of the key features of the planning system in Scotland is the use of discretionary development control for planning applications and permissions. This differs from the approach in many other countries where regulatory zoning plans are used as the principle means to control development. The RTPI have recently published research regarding the merits and disadvantages of zonal planning[8]. Clarification on how proposals would relate to the planning system would be valuable for this proposal.
Package 5: Embed circular construction practices
- To what extent do you agree with the measures proposed in this package to embed circular construction practices?
Please provide evidence to support your answer if possible.
- Strongly Agree
- Agree
- Neither agree nor disagree
- Disagree
- Strongly disagree
Supporting evidence:
As construction and demolition waste accounts for such a large proportion of all waste produced in Scotland, RTPI Scotland welcomes the inclusion of Package 5, but we believe that this section needs to be strengthened and expanded. We welcome specific reference to the important role of planning in this section and the key opportunity to support planners through the development of NPF4. Please refer to our response to Q1 and Q2 for consideration of how we can empower planners with the skills, resources, and clear policy frameworks necessary to implement such aspirations.
- Are there any further measures that you would like to see included in the Route Map to embed circular construction practices?
Further measures to include:
Whilst consideration has been made of how planning policy at a national level can embed circular construction practices, it is worth noting that regarding waste planning, strategic planning at a regional level is often the appropriate spatial scale to consider interventions. Therefore, this section could be strengthened with considerations of the potential of the emerging role of Regional Spatial Strategies (RSSs) and how preparation of Local development Plans can set out local priorities.
The scale of the change in this sector necessary to support the ambitions of a circular economy cannot be understated. This may necessitate the need to produce a clear and specific strategy relating to the construction sector. It is also critical that we support stakeholders with this transition through the publication of detailed and comprehensive guidance. RTPI Scotland recognise that some resources are currently available such as the Zero Waste Scotland’s ‘Designing Out Construction Waste’ guide for project design teams, but we believe that such guidance could be better embedded in the planning system through provision of national planning guidance on the matter. We note that the industry standard for such guidance can be found in the Greater London Authorities (GLA) London Plan Guidance on circular economy[9]. Guidance would also be beneficial to support standardisation of methodologies on areas such as Whole Life-Cycle Carbon Assessments. We note the GLA has also produced guidance[10] and an assessment template[11] on the matter. We await publication of the Construction Client Guide on Sustainability that was due Q1 2022.
Package 6: Minimise the impact of disposal
- To what extent do you agree with the measures proposed in this package to minimise the impact of the disposal of residual waste?
Please provide evidence to support your answer if possible.
- Strongly Agree
- Agree
- Neither agree nor disagree
- Disagree
- Strongly disagree
Supporting evidence:
No further comment.
- Are there any further measures that you would like to see included in the Route Map to minimise the impact of disposal?
Further measures to include:
No further comment.
Package 7: Cross-cutting measures
- To what extent do you agree with the measures proposed in this package to support action across the circular economy?
Please provide evidence to support your answer if possible.
- Strongly Agree
- Agree
- Neither agree nor disagree
- Disagree
- Strongly disagree
Supporting evidence:
As discussed throughout this response, RTPI Scotland sees the planning system as central to delivering a circular economy. By its nature, planning provides the cross-cutting spatial oversight for physical interventions that will support our move towards a circular economy. Therefore, how planning relates to a proposed Circular Economy Strategy, how data and research should be utilised to drive evidence-based decision making, and how we can develop the planning skills and workforce necessary to achieve ambitions of a circular economy all need careful consideration and should be made explicit in this section.
- Are there any further measures that you would like to see included in the Route Map to support action across the circular economy?
Further measures to include:
The successful operationalisation of circular economy principles will require the collaborative work across a wide range of stakeholders in the public sector, private sector, third sector and in the communities themselves. Consideration of circular economy principles needs to be applied to a range of public-sector decision-making areas such as planning, community planning, asset management, street maintenance, investment, health and education service provision. This could be achieved through a place-based approach which considers all aspects of a place when considering an intervention. The Place Principle could support such collaborative place-based action. The Scottish Government and COSLA have agreed to adopt the Place Principle to help overcome organisational and sectoral boundaries. This includes improving coordination between stakeholders, enhancing collaboration and communication across local authorities’ departments, key agencies, NGOs, and private sector. Therefore, whilst RTPI Scotland welcomes the consideration of cross cutting measures in this package we believe that this section could be strengthened with specific reference to and consideration of, the Place Principle and place-based approaches to delivering the circular economy. Supporting this, the principle of using a place-based approaches to promote the development of the circular economy at the local level has been set out in Zero Waste Scotland’s Circular Cities and Regions programme[12]. As a key emerging policy area set out in the draft NPF4, this section could be strengthened with reference to the opportunity to align circular economy ambitions with the principles and objectives of Community Wealth Building[13].
Beyond 2025
- To what extent do you agree with the principles proposed to underpin future circular economy targets?
Please provide evidence to support your answer if possible.
- Strongly Agree
- Agree
- Neither agree nor disagree
- Disagree
- Strongly disagree
Supporting evidence:
RTPI Scotland strongly support the ambitious nature of targets set by the Scottish Government, and how they will support the achievement of net zero carbon targets by 2045. As set out in response to Q9 and Q10, RTPI Scotland believes the role of the planning system and the wider built environment professions are integral to this transition.
Impact assessments
- Please provide any further information or evidence that should be considered in the accompanying Equalities Impact Assessment.
Further information:
No comment.
- Please provide any further information or evidence that should be considered in the accompanying Fairer Scotland Assessment.
Further information:
No comment.
- Please provide any further information or evidence that should be considered in the accompanying Island Communities Impact Assessment.
Further information:
No comment.
- Please provide any further information or evidence that should be considered in the accompanying Business and Regulatory Impact Assessment.
Further information:
No comment.
- Please provide any further information or evidence that should be considered with regards to the environmental impact of proposals outlined in the Route Map.
Further information:
No comment.
[1] European Environment Agency, Urban sustainability issues: what is a resource-efficient city?, Publications Office, 2016, https://data.europa.eu/doi/10.2800/389017
[2] https://www.rtpi.org.uk/research/2021/march/20-minute-neighbourhoods/#:~:text=20 minute neighbourhoods are a,within a 20 minute walk.
[3] https://www.rtpi.org.uk/consultations/2022/march/draft-national-planning-framework-4-consultation-response/
[4] https://www.rtpi.org.uk/media/5209/npf-4-rtpi-scotland-position-paper-final-cmcl-200506.pdf
[5] RTPI Scotland (2021) Resourcing the Planning Service: Key Trends and Findings 2021. June. Available here: https://bit.ly/3s5h4Yc
[6] https://www.rtpi.org.uk/research/2022/july/future-planners-project-report/
[7] https://www.gov.scot/binaries/content/documents/govscot/publications/strategy-plan/2020/11/transforming-places-together-scotlands-digital-strategy-planning/documents/transforming-places-together-scotlands-digital-strategy-planning/transforming-places-together-scotlands-digital-strategy-planning/govscot:document/transforming-places-together-scotlands-digital-strategy-planning.pdf
[8] https://www.rtpi.org.uk/research/2020/september/planning-through-zoning/
[9] https://www.london.gov.uk/sites/default/files/circular_economy_statements_lpg_0.pdf
[10] https://www.london.gov.uk/sites/default/files/lpg_-_wlca_guidance.pdf
[11] https://www.london.gov.uk/sites/default/files/lpg_-_wlca_assessment_template_planning_-_25_march_2022.xlsx
[12] Zero Waste Scotland (2018) Circular economy in cities and regions. Available here: Circular economy in cities and regions | Zero Waste Scotland
[13] https://www.gov.scot/policies/cities-regions/community-wealth-building/
