 Fawr, wrth gwrs, ac yn fawr i'r gwaith y ddylai'r gwaith yng nghymru yn 2023 o'r Ffynans i ddweud o'r ddefnyddio ar gyfer y ddym ni'n gweithio. Fawr, ddyddai'r gwaith ar gyfer ddyddai'r gwaith ar gyfer ddyddai'r gwaith yng nghymru i'r rôl yng Nghymru, ac yn ystod yn ddylidio'r jamie Halcro John sain oedd yn gyfweld i'r ddylidio. Fawr, ddyddai'r gwaith yng nghymru ar gyfer ddyddai'r gwaith, ac mae'n cymdeithasgol o fy gweithio fel y Dynolol, mewn gweithio i Gynlygu Cymru. I welcome to the meeting Charlie Devine, service manager, waste partnership, Dundee City Council, Kirsty Maguire, waste manager, South Lanarkshire Council and Jim Jack, head of operational services, Westlawden Council. I welcome you all to the meeting and I intend to allow up to 75 minutes for this session. We have your written submissions so we will move it straight to the questions. I think that actually Mr Devine, I will go to you first. The reason I'm going to go to you first is because we sent out a number of set questions that we do for all financial memoranda, and unlike your colleagues, you've actually completed the first three, so if we're going to put you on the spot first, but then, of course, if your colleagues wish to chip in, then they're more than happy for them to do so. Basically, when you were asked to comment on the financial assumptions made, you talked about insufficient financial detail, and you said that the Scottish Government should consider the impact of additional capital and revenue costs required to implement, manage and maintain the required changes at a time of considerable budgetary pressure for local authority. I'm just wondering if you can actually enlighten us as to what these additional capital and revenue costs would be. I certainly would. I suppose that in the first instance is obviously infrastructure. Infrastructure is obviously quite considerably expensive for waste management and treatment, so having to sort of put new infrastructure in place. I recognise that the recycling infrastructure fund is available for local authorities to bid into, so that was obviously one helmet of that, but that wouldn't be, in terms of the £70 million that's there, going to be sufficient, I don't think, for all of Scotland, and certainly for if we were to do something considerably different from what we're doing at the moment, whether the money would be available to do that. Obviously, if we do make that investment, then obviously there's the cost of running those particular infrastructure facilities, for instance. That was where we sort of had that fairly general comment came from, so it was really about if we do go down a lot of recommendations that are within the circular economy bill, in which Dundee is actually quite far down the road in terms of the household waste recycling charter and fully adopting that. Some of the changes that are there will require additional facilities and additional money to manage those facilities, so it was really just to highlight that to the committee in the first instance and just to make them aware of that. I suppose to the point that I always try to get the full suite of infrastructure that isn't there at the moment to do a lot of the changes, so it was just to sort of highlight that to you in that instance and obviously give you an opportunity to discuss that and see where it could go from there. Back in 1981, Claire Grogan in the film Gregory's Guild said that boys think in numbers, and I'm one of those people, so I wonder if you can put some numbers on what we've said, given that the financial memorandum is all about the numbers, in fact. Oh, God, I couldn't give you that level. That's probably the best estimates, isn't it, really? I suppose you'd be talking about developing an additional household recycling facility, for instance. It could be £1.5 million to £2 million for a very basic facility, so that would obviously increase the ability for people to bring material, for us to sort material, but obviously you would then have to staff that, which could be anywhere from five to ten staff. That could deal with that. Sorry, this would be essential to deliver this bill in your view. It would be a key component part of it, along with other things as well. Wouldn't it solve the number of additional items that we would need to deal with on its own, but it would be part of a wider plan? I'm just wondering if your colleagues Jim and Kirsty will get anything to say on that particular issue, which is about additional resources that might be glad to deliver that. I haven't made any comments on that, but I'm picking up from Charlie's point on additional costs for infrastructure. We have been looking at putting in additional infrastructure, because it's something that South Lanarkshire is pretty short on, given the geography of the area. I'd say that £1.5 million is probably quite conservative, especially when you're looking at purchase of land on top of that. You also didn't specifically comment on those early questions, but I'm sure you've got some thoughts on that. In terms of the recycling improvement fund, West Lothian has benefitted quite a bit from that. We are progressing a twin-stream recycling at the moment, but that's been a major behaviour change exercise. That's what's required for the circular economy bill as well. That takes a significant input in terms of education, coercing, coaxing along, whatever way you want to put it with our communities. We have two pilots running at the moment, which are taking four staff working in those areas just to do that education and engagement as we go in front of the collection service to reduce contamination, which is a significant cost to the council as well. The bill is talking about £2.95 a household or something like that for education, behavioural change, etc. Is that a figure that you recognise? At the moment, we are probably above that. I haven't looked at it in that level of detail. As I said, we have some resource there that we'll be able to put in, but that didn't come from the recycling improvement fund. That's capital based, so it paid for the infrastructure, the new bins and the stuff that was required there. The programme that we've got on the go at the moment has got a target for reducing contamination and a saving to the council, and I'm netting off the staff costs from that. Back to you, Mr Devine. In the second question, you said that some of our responses to the initial consultation are irrelevant or require further review and updating, and you touch on forthcoming lifelift changes such as the deposit return scheme, in which, or at least, they were considered to be forthcoming, and the extent to producer regulations. I'm just wondering if you see where the changes have been made and what the implications of that for Dundee? Definitely. If those two, well, I'm supposed to deposit return, if you like to take that as the first example, so that would remove a set volume of material from local authority handling it, so that would change how the service would operate, for instance, and obviously with the delay that's there. Probably one of the key elements for that, which obviously wasn't considered at the time with our response, would be the removal from glass from the system, which, in terms of volume, constituted quite a significant part to that, so the local authority would continue to handle that material. So, again, we need to go back and re-look at it in terms of how we would forecast that in terms of the extended producer responsibility. Again, that's a UK-wide piece of legislation, and it will be dealt with in that particular aspect. So, how the money that's going to be given up from the producers and how that's distributed to local authorities isn't clear, and how that would be there. Obviously, if packaging, for instance, changes, or reduced volumes of it, or how the package has actually made changes as well, so that would have to be considered in terms of how recycling systems were set up, and how sort of the back-end contracts that could sort and then recycle on that material would work. So, there's quite a few unknowns there, which made it really difficult, and again, probably if you asked me the same question again, given what we've got, we'd probably give you more detail and probably be better, but are there a place to give an accurate response? Yes. The extended producer responsibility is expected to bring in about £1.2 billion a year across the UK, so that's £100 million across, you know, £100 million perhaps for Scotland, so that might be £2.3 million for somewhere like Dundee, but it doesn't, you're right. I mean, it's very hard to kind of pin down at this stage. I mean, just moving on to your optimism, Gwai. One of the issues, of course, that's come up and mentioned is the littering issue, whereby people who litter from cars will be potentially fined, and the financial memorandum talks about the cost of actually placing that, and I'm dealing with that at between £34 and £102 per notice, but all of you have expressed concerns about the kind of, about how collectible that is. What are your concerns about those of South Lanarkshire? Those are the number of concerns. First is that, again, due to the size and the geography of South Lanarkshire, we don't believe that the numbers of enforcement officers are realistic if we really want to deliver on that. Secondly, it's the cost, so it's difficult for us to recruit officers. We're struggling to recruit enforcement officers, environmental health officers, and so we're having to pay officer rates. We feel as if the estimates for how much Scotland costs us are on the low side. We also think that it's important to perhaps be realistic about the incomes that we are predicted to get from fines. There's a prediction that we would get 100 per cent of fines to come back into us, and that's not the case. Between 10 and 15 per cent of fines are paid for offences at the moment, and if we don't get paid, then it's a report to procurator fiscal, and if the procurator fiscal does take the case, then it generally will result in a fiscal fine. None of that money that comes from a fiscal fine actually goes into local authority budgets. That's a concern for us. Looking at everyone else's responses, we're all saying the same thing, that what we really want is an education programme, we want communications, we want to invest in our waste education teams from a South Lanarkshire perspective. I think probably across local authorities and savings have had to be made that waste education teams have been one of the teams that have been affected by cuts, and because of that councils do not have the resources to do the education awareness raising that is required to make this successful. I think that we've got very similar concerns. A part that I would add is the demographic that is likely to be fined or some of the hardest customers that we've got to engage with to bring forward this type of behavioural change, and then they face the dilemma, I suppose, between paying fines and paying rent, put bluntly. I think that one of the issues, in fact, indeed, specifically talked about that, but, Mr Rathbone, that's an issue for yourself or, indeed, for Mrs McGuire in terms of what's loading in South Lanarkshire about recycling and trying to increase it from flats, for example, rather than just, you know, your garangated properties. How do you think that this bill will help to be able to deliver that, or do you think that there's an overestimation in terms of the amount of waste that will be collected in appropriate receptacles from this bill? I think that, Mr Rathbone, speaking from the experience of West London, we're looking at flat properties just now as part of that recycling improvement fund that we were funded for. Some of the difficulties that we're having is multi-ownership of the flats, from individual tenants to housing associations and others, and the council itself. You'd think that it would be easier to engage in terms of our own tenants, but, again, they tend to be, in some cases, a quick turnaround, so there is concerns there about just how effective that engagement is. The other side, as well, is making sure that the additional receptacles that we put into segregate waste don't just simply become another great bin, and the process that goes with that, and that's taken quite a bit of time to work through. Most of our flat properties only offer, at the moment, either a grey bin general waste collection or a mixed, co-mingled paper card in tins and cans, and we're hoping to change that. However, as Kirstie said, it takes a lot of upfront time to make that change, and then a lot of input time to keep the messaging consistent. Ms Maguire, what about South Lanarkshire in terms of flat properties? South Lanarkshire is our biggest concern as our flat properties. A number of years ago, we did a campaign, we introduced a new service standard, and we became less tolerant of contamination with our recycling bins. It was quite labour intensive. It took many months, negotiations just to get by our elected members in the first instance, and then actually to do the education and awareness raising with members of the public. We did benefit from a pretty significant increase in the quality of the material that was collected in our recycling bins, but conversely it ended up with a lower recycling rate. What had happened was that everything that was in the recycling bins was being counted as recyclet. After we cleaned up recyclable material, our tonnages went down, so it looked as if we were performing less well than they had been. There was an improvement in terms of the quality of the material. That could only work with properties where we had four bin system, and we had back and front doors. Unfortunately, we have over 30 per cent of our properties are multi-occupancy, and we also have a very high proportion of terraced properties. There is difficulty there in providing bin infrastructure. There is difficulty for people bringing out bins because they do not have access from their back garden to the front garden to where the collection point is. A lot of the time, we have had to revert back to sack collections, which are not helpful when you are looking to improve the amount of recycling that you are collecting. It also gives you issues with refuse accumulation and refusing back areas. Sometimes you have to revert back to a weekly residual waste collection, which does not help. The point is that our flats are our biggest challenges. Even though there is an option there to issue fixed penalty notices, the difficulty with flats is who do you issue the fixed penalty notice to. If they do not pay it, who do you refer to the procurator first of all? That is something that you touched on, Mr Devine, in terms of trying to chase people on that. One of the things that Ms Maguire has raised is the issue of how much the financial memorandum seems to believe that local authorities have to pay in order to hire additional staff in order to monitor that. You have talked about, for example, the assumptions in terms of the full-time equivalent enforcement officer being nowhere near the actual real cost. If you could touch on that, because your colleagues are obviously concerned about that. The costings that we looked at were based on a grade 3 officer level and an officer level within the council would be someone who would be responsible for enforcement, so general environmental enforcement. With on-costs, which we usually take to about 30 per cent, our estimates are that it would be around 55,000 per year per full-time equivalent for enforcement. We also do not have a post, which is administration for enforcement. That, again, must have to be undertaken by an enforcement officer. Those are hidden costs, which are not really considered by the financial memorandum. Mr Devine is nodding there as well. Mr Devine, the recycling improvement fund of £70 million, £53 million has been allocated to 17 local authorities. Do you feel that that means that there is not enough left in order to cope with the kind of changes that are now going to have to take place given the changes to DRS, etc. What has happened there? I will speak from a slightly more informed position, because it was part of the team that pulled the recycling infrastructure fund together in a previous role. We knew some of the work in the background for that. The real cost for that is considerably more, but that was available within the Scottish Government capital funding part of that. It was trying to make that fit anywhere where the biggest priorities were. It really just spends for each local authority where they are within their infrastructure requirements in the moment, whether they have been part of a previous investment cycle in terms of either some funds that have come from Zero Way Scotland or the Scottish Government Direct for that. The biggest issue is that it is probably more than double the requirements for making sure that everybody had the same type of infrastructure and could offer the same service. The other challenge was that, until all the local authority services are aligned, it is difficult for everybody to use similar type of infrastructure. The code of practice for household waste recycling was the key to that. If not a mandatory or statutory role within a circular economy bill, it is important to align each service to produce similar type of material. That makes infrastructure more common. There are challenges in the interim period. If each of your local authorities received funding, is it interesting that 17 out of the 32 local authorities have received totaling £53 million? Obviously, local authorities are different sizes, etc. I wonder whether each of your local authorities has received that funding, or is there something in discussion with the Scottish ministers about using any of their custody? In terms of Dundee City Council, one of the early adopters received around £90,000 to modernise telekinetics and telecommunications within vehicles to improve service and service availability. We are in the position that we are preparing a further bid for some capital work within our household waste recycling centre. It is live at the moment for us, whether the funding can, if there is sufficient money left by the time that we have made the submission that is assessed to do that or the timeline that suits the funding that is available. South Lanarkshire has not. That is predominantly down to the timing issue. Our service review, which is in the middle of a service review at the moment for waste services, was timed to go inside with introduction to the deposit return scheme. Charlie had touched on the fact that, if glass is included, there would have been an opportunity for us to make some efficiencies because glass is about 60 per cent of material that we collect in our container bin, which is glass, plastics and cans, so we could see some efficiencies there. The whole timing of our review was based around the deposit return scheme. Obviously, the delay has had an impact on us, and we have to also think about the introduction of the extensive use of responsibility for packaging regs and what an efficient waste service would look like. It has been pretty difficult, and it has been pretty challenging for us to get a direction of how our service is going to look. Until we know what our service is going to look like, we do not know what we are applying for funding for. If we had applied for large-scale funding, it would not have been a good time for us because we would have potentially made different decisions based on how things are going strategy-wise at the moment. That is interesting, given that the legislation is going through, Mr Jack. We received a significant amount of money from the Recycle Improvement Fund. Part of that was timing for where we were with service changes, principally driven by the requirement to make revenue savings across the council, including operational services. We were able to fund the roll-out from a coal mingled plastics card, paper and tin plastic bottles collection to splitting that, and a lot of the funding that we got went towards that. Equally, there was an allocation for flatted properties, which is a work that we are working through just now. There was some money there, as Mr Devine said, for in-carb improvement technology, to allow us to better understand the presentation of bins and to deal with complaints as well. That was, as I said earlier, capital funding. I had to make significant savings within way services revenue-wise, and that included moving to a seven-day collection service. The timing of that review and the funding helped to progress that. I am concerned about where we are in the future and what the journey continues to look like for way services and our ability to be light enough on our feet to be funded to achieve what we need. Is our council's principal concern that we should be no worse off through this? I will ask a final question in a minute. I just want to ask about co-design. One of the things that the bill talks about—it is not the first bill that this committee has dealt with—is that it has discussed the issue of co-design. To me, co-design is always somewhat woolly, and it means that much of the delivery of the bill will come through second legislation. Can the panel give me individual views on that? That has been a concern for our council and my colleagues that have been looking at it. As I said earlier, understanding where we end up in terms of what the co-design service will look like, but equally, I suppose, what the market looks like for the products that we have. We have a general waste contract going out now, due to return in January. The early indication is that the cost pressures and that could be very significant. As colleagues have said earlier, none of us, certainly our council, agree with the principles. It is just how the market reacts and where the cost element and the risk, I suppose, sits and how local authorities are funded through that. I think that co-design is where we want to be. We want to have an input and local authorities want to have an input behind the services that will look like. I think that the difficulty is that there is so much variety in terms of collection services and that is because of local conditions. What suits one local authority does not necessarily suit another. We do not have infrastructure. We are really dependent on the processors that are on our doorstep because we do not bulk, so we have to direct delivery. That influences what material types you will collect. There are some local authorities who are reluctant to move away from a single stream recyclable collection and believe that the way forward for other local authorities is to have the same. That would work in a lot of properties where there is insufficient space. There are older properties and refuse collection was a last thought in the architecture of our properties, but it does not suit us because we get income from our waste streams. There is a lot more discussion that is required to find some sort of a compromise. It makes me wonder whether there is one size that fits all, whether we can be as prescriptive as we have been in the past with the code of practice, where we have asked for a separate glass collection, where we have asked for certain items to be collected at the same time, where frequency of residual waste collection has been not mandated but recommended. We really have to consider local circumstances. My colleagues have said that it is the challenge of getting everybody to do things in harmony with each other. I think that there are a number of steps that have been able to present consistent materials to the marketplace in some instances and be able to tie up ways of working in terms of rural and urban. The other part to consider is that, in the EPR regulations, those that place packaging in the marketplace want to get that packaging back in some way. That should be a pool on how the systems are designed to get the best quality material back into the market. Also, from that point of view, we have to try to get a better price back for local authorities for doing that. Where are the mechanisms within the EPR will help that and that would then become part of the design of the system, co-designing it not just with each other but with the market to make sure that the materials are there. Probably the way that it is set up is that we are trying to recover as much recycling as possible, but that might not be the recycling that the market wants. We do not get the best prices for it at the time or we put a lot of effort into the material and it will not have the best carbon impact but it is the best for logistics and waste handling. There are quite a few challenges in the co-design, and I think that that would be quite a large part of taking this forward in terms of not just harmonising between local authorities but harmonising the waste system and the system for materials use. Obviously, can I close that circular economy look that everybody is trying to do at the moment? The Scottish Government is determined to make this work because it says that the Scottish ministers will be unable to impose statutory recycling targets among local authorities with financial penalties. If targets are not met in Wales, a local authority can be levied with a fine of £200 per ton of waste by which it falls short of the target amount. The financial memorandum talks in detail about savings, for example, from paper cups going to landfill and letting fines in this, that and the other. What is the kind of net—I know that you have all said that any additional costs should be met fully by the Scottish Government—what is the net outcome in terms of the bill for your local authorities? Mr Devine, you are quite hesitant in talking about pounds, shillings and pens at the beginning of the question session, but where are we in terms of the parameters for a city like Dundee in order to deliver this financial memorandum? Would it cost the city an extra half a million and a million to me? Obviously, we have to look at the whole point of financial memorandum as best estimates so that we can look at the impact on the public birth. Where would you be for that? I am going to ask the same question to your colleagues. In terms of Dundee, a compact city, it is very challenging conditions to have a really efficient and cost effective household waste recycling and collection system. That is reflected in terms of where recycling rate is. We have really worked hard to get it and we still find it difficult to get anywhere near where the target recycling rate is at the moment. That is a major challenge for us to get that as a big investment, not just in infrastructure that we have made over the years but also in terms of communication, a lot more people on the ground to do that and engage. I know that we did not ask that earlier, but we are over 50 per cent of communal properties in Dundee in some really challenging traditional housing types for the introduction of a comprehensive sort of a separated waste system. We have a lot there and a lot of investment going forward as well, but a lot of that will be not just in some of the capital things but more people on the ground over and above that. Saving for mislegislation is clear, so I am just wondering what the net position is. Obviously, it is hard for us to say that local authorities want more money. We really need to try and pin it down to some kind of ballpark figure. Surely Dundee has considered how much additional funding, if it needs additional funding, it would require to deliver this bill in over what time period? I definitely had a bit of a number on it just now because we have done lots of different scenarios. The main one is, if you do not pay to dispose of the waste, then that frees up that money to be invested elsewhere. Even moving recycling on the market costs money, so it is not as easy to net it off as it would be against the cost of waste disposal versus the cost of recycling. It changes quite a lot in terms of market values, so that can be a bit of a difficult one to cost up. I think that we need a steady level of staff and level of engagement to be able to address the issues there. Is there enough money that will come from some of the changes to net that off within the council's revenue budgets for the staff requirements? It is really short of putting matches on your fingernails. I am not going to get any cash figure from you, Mr Dundee. To be honest, I think that there is a lot. We need a lot more information than we are going forward. I think that the financial memorandum is really helpful because it is giving us much more scope for where to think, but I just do not think that it is the finished article at the moment that we could give to Parliament to consider. I agree with Charlie. There is just too much uncertainty and there is not enough detail behind things at the moment. I can see that there will be savings in terms of litter clearance and litter disposal, but everybody else has to be investment. We are looking at improving our recycling rate. South Lanarkshire's recycling rate last year was 40.3, so we are not even at average, so we are 3 per cent below average. Even getting to that, we are going to need to invest in communal bin infrastructure, which we are looking at putting in a bid to the small grant fund for RIF. We are looking at a pilot where we have our communal bins that have see-through panels to encourage our residents to take a wee bit more ownership for the waste that goes in the bin, but we need capital investment for those things. Mr Jack, you are my last hope. Sorry, chair, to disappoint, but, like my colleagues, when we considered this at committee, we really struggled to be able to articulate what you want to elective members as well because of the uncertainty that is there. I have said earlier that some of the changes that we have made have involved moving to a seven-day collection, which is a significant change for the council, and that was to save a sum in the region of about £340,000 just based on vehicle reductions, so we have had to make some big decisions on waste services and what it looks like for our community. My concern around it is that I would like to give you a figure, but we are struggling to do so. As I said, the RIF fund has helped us with some of the infrastructure, but if that model changes a bit, then that money has been used and we will need to reapply for something else, which is an additional cost again. I am going to open up the session to colleagues around the table and the first to ask a question and be a deputy convener. Michael, before by John. I am conscious that the waste management process in various councils has changed dramatically over the past decade, so you have been through a lot of change processes in the period up to now. You have described some of them in part in terms of the changes that you have made. In layman's terms, we are not going to get a figure, but does it feel realistic in terms of the costs that are being set out here? Given your experience of change management and the costs of making those changes, does it feel realistic to you? I think that the big thing for me is that we spoke about a figure for communications to £95 per household. You also need back office staff for communications, so you have to have someone who develops that communication so that there is resources in there and you have to have people who deliver that communication. You have to have accompanying education programmes that go with that. There is quite a bit that that is missing for me from the costs that we are looking at. We know that local authorities, from experience, cannot issue communication because people just put it in the bin. You also have to have the staff behind that and the engagement behind that. The financial memorandum sets out that there will be costs of £227,000 across three years for a local authority. That seems to me to be a vanishingly small. The first answer that we had today was from Mr Devine, who said that he was looking at a £1.5 million to £2 million capital investment and five to ten additional staff to set up one waste management centre to deal with this, but the allocation is £227,000 across three years. Is that realistic? No. From our own experience with the change management stuff that we are in at the moment, as colleagues have said, the education and engagement part of that, in my view, would be higher. We would need more. It is not something that you can do in a fortnight and then not need to revisit again if we cycle and rate is dip. I think that we all sign up to the message. We all think that we are doing better than we actually are, but if you look at the national figures, there is so much recyclable material in the grey bins, despite all the campaigns of late. It is very difficult to shift that. The section 48 of the memorandum states that Zero Waste Scotland have calculated the cost of implementing the current code of practice at £88.4 million. Do you know where that figure has come from? I can make an educated guess having been a former employer there. I will be through a lot of assumptions, research and some comparators with other nations. I know that we tend to mention Wales a lot, because Wales is obviously a higher performer. The Welsh model has been a completely different investment cycle in a different collection system. It is not quite comparable to the previous investment that is there to get it. The other assumption from the costs is that we assumed that we had a fully functioning back office at the moment, so that was really just topping up what we needed to implement the bill. From what my colleagues have said, that is not there in terms of its entirety, so it is not just starting from a level playing field where it is having to go back the way and reinvest again to get back to where we should be before we move on to where the bill is at the level engagement. You are making some of those well educated assumptions in terms of where some of that might have come from, but it has not been set out to colleagues as to where that figure has come from. Do you have any detail on it? There was a lot of papers that went with it in a lot of research that the Zewis Scotland has done. A lot of that could be desktop based as well, and looking across Europe where things can be quite different from where they are, considering things like PSG throw, for instance, could distort things. It is not a direct variable charging that is not there. We are working from whatever was collected via the council tax bans. There are lots of challenges there and it does not make it fully comparable where we are trying to go from at the moment. Are colleagues aware of any discussions between your local authorities and the Zewis Scotland or the Scottish Government about that figure, about where it has come from? Have you had any detail set out? No. In section 48, it sets out some detail around the extended producer responsibility. The convener touched on that already, saying that that will be one of the areas where there will be an income stream to try and offset some costs. Are you aware of any discussions as to the scale of that, how much money might come in and how that would be distributed across the different local authorities? I can probably speak from my own authority at that point. Obviously, we take part in the different organised research for that. There is quite a lot of work going on in the background in terms of trying to work out what that figure should be for each material stream in each local authority. Ultimately, when that money is there, it will go to the Scottish Government and, unless it is ring-fenced, it could become an additional fund that can be invested into any part of the service. Some issues there, even though, if it may generate additional money for us, is whether that money becomes, as I see it, a ring-fenced fund that local authorities can benefit from directly for waste management or it becomes a treasury transaction that the money becomes part of the overall cost system. I understand why that would happen, either way. No clarity so far. You are shaking your head, Christa, as well. You do not know whether we have anything in terms of whether it is going to go into the block grant or whether it might be a fund to be bidded into. Or whether it will replace an element of the block grant. It has not even been confirmed yet whether the local authorities will receive that additional money. That is obviously a major concern because there is an assumption that we will receive the money from the APR, but we may not. That is very useful. My next question is about the distribution effect of some of that. Given what has just been said, we do not have real clarity or understanding of it. However, as a Dondonian, I have sympathy with Mr Devine's position regarding the challenge of collecting waste in a local authority with the tightest boundaries in the UK, 50 per cent of which is flattered. Is there any indication or discussion with Government about the recognition of those challenges? I suppose that we have made them that many times for different things, but I think that it is there within the performance rates and how much money we are investing in not to have a high-performance system. I think that that should be recognition on its own, but I think that we do raise those points quite a lot in any submissions that we put in as you will see. We are trying to highlight those challenges for us to deliver those things. I do not think that the ambitions to be as good as we possibly can. It is not a lack of effort. There are probably just circumstances and then trying to find a way around those circumstances. I recognise that, but there is no direct recognition within the discussions around the bill or otherwise in terms of why those rates are so low. I suppose that part of the answer to the convener around the fines that might be levied on local authorities for not making a recycling rate over the long term. If we want to see Dundee City Council find for not being able to make a recycling rate, which is a factor of the boundaries that it has set for them by the Scottish Government, not about any performance by individuals or the group that you work in. Is that something that the council has expressed? Is there any recognition of that in how the financial aspects of that might be dealt with? I suppose that discussions have been in group discussions with Scottish Government colleagues in that particular team. There is a recognition that in terms of demographics and achievability might not be there in terms of a flat recycling rate for all local authorities. Some local authorities might be better placed to achieve higher rates and some lower rates, depending on those particular circumstances. There is a recognition for that. I have not seen any models or documentation that would back that up other than positive comments from Scottish Government colleagues. It is something that we will have to consider. That might be part of secondary legislation as it comes through. I think that that would be very important. Mr Jack, you mentioned in your previous answers about the challenges around the area of deprivation, potentially, about reclaiming fines. Is there any recognition that you see as a local authority about how deprivation and the challenges of reclaiming fines and change of behaviour in those areas might be recognised in any of the financial structures? I think that we only certainly could comment on that chair. We would be round about littering fines and we have a lot of difficulty in the local authority getting them pursued in those kind areas and they have become a cost to us if we can actually get to a point where we can try to recover the money. That raised a concern that the income side of it seems to be predicated on almost 100 per cent payment to fines. I am not aware of that being achieved in terms of littering, certainly not within my own authority. Factors such as deprivation or the choice of where you pay the fine or pay your rent has been said to me in the past when we have been pursuing that. You mentioned, Kirsty, the savings that you thought might be realisable around littering and litter reclamation. I know that street cleaning in Dundee has been cut to the bone. There have been several rounds of cutbacks due to the cuts that the local government £6 billion has taken out over the last decade across Scotland. Is it realistic to think that we can actually scale back those services any further? There will always be some level of residual waste if we take coffee cups out of it. It does not feel to me like we have a service that is actually up to scratch, as it is at the moment in lots of parts of Scotland, let alone the idea that we might then be able to scale it back further. Are those the kind of jobs and savings that you are identifying? No, that is solely on disposal costs from street cleansing. We are under pressure to make significant savings through street cleansing and through our ground services. It is likely that there will be a reduction in service provision as a consequence of that, if the savings are taken. We will have less bodies in the ground for street cleansing services. I do not see any savings as a consequence of the bill in terms of employees or vehicles, but I recognise that, if there is less weight in the bins, there is less disposal costs. Thank you. Just one point. Dondi's Boundaries will set a pre-develation. John, to be followed by Liz. Following on, some of the points that have been made already, you said that Mr Devine said that the financial memorandum was helpful and that it goes into a bit more detail than you had before. Is there enough detail in it, or are you accepting that there has to be uncertainty because of the further discussions that have to take place, or should there be more certainty within the financial memorandum? I think that there needs to be more certainty from that, but I have to recognise that there are changes in transit at the moment, and some we do not have any control over in terms of being set from Westminster, for instance, in terms of the EPR. There is that level uncertainty. There always has been some, but I think that the thing is that there is not really any headroom to do anything with it if there are some changes. The other thing is that we have to enter into long-term contracts, and that is really difficult if halfway through the contract something changes. Waste disposal is probably the most prominent one, but even for the off-takes or recycling, we are entering into short-term contracts where we don't benefit, because DRS was a good example. We couldn't go beyond August this year with that material stream, and then all of a sudden we have to go back to the market again with another short-term. It can be quite challenging for that point of view, and it is hard for the financial memorandum to account for that, but we know that it can go out and get a much slower income from material and a much higher cost for processing, all within just a very short period of time, so it is very difficult, I suppose, to have a live situation. That is difficult to get into that level of detail within a document like that, but I think that there needs to be recognition that market rates will change depending on how certain things are for us. We, as a committee, have to go back and say that this is a good financial memorandum or that it is a bad financial memorandum, so which do you think we should say? I think that we would just like a wee bit more detail about how the assumptions that are being made, where they come from, I suppose, are neutral. Chairman, I think that it is sitting on the fence, and I think that from our point of view we would difficultly just understand and be able to articulate back to elected members and others as to whether we would be no worse off, and that has been the concern that we had, and I totally get Mr Divine's point about there has to be some indication given, there has to be some means of measuring what the cost of this and what the benefits would be, but I think that the uncertainty in the market, and I did mention earlier that we were about to go back and say, to tender to one of our biggest contracts, and we are expecting there will be a significant price increase in that, which is partly due to uncertainty. Okay, thanks. Again, some of those points have come from the Dundee papers, that's why I'm focusing on that, but you make the point that on disposal of unsold goods there is no budget at all put in for councils, should there be? I think that, yes, but there should be recognition of that. I suppose the point when I put it in there is that we probably don't deal in that retail type environment, so again, but it would be where that material gets passed on to, for disposal for instance, so if that's through a household disposal system then we would pick up the cost for that, and one of that might be giving stuff away at the retail level to a householder who then doesn't need it or want it, and then it finds its way back into the waste system. That's quite common at the moment in terms of buy one get one free type things in food for instance, where when there is a campaign for that you can see the food waste arises going up significantly, because it's free, you might not take it, but when it's not wanted they're required then they go through, so I think that need to be considered how that works. It's a slightly different angle, but on that same subject in the financial memorandum, the costs that SEPA might get or need on this same subject of disposal of unsold consumer goods are ranging from 30,000 to 200,000 being if they were more proactive. I find that interesting because it's a very wide range, and it brings in the issue about being proactive. I didn't particularly see that elsewhere either for councils or for anyone else, but it raises the wider question of do you want to be more proactive, do you need to be more proactive and would that really cost like seven times doing the minimum? It's funny, it's where that's at obviously, in my personal view, that it looks if it's targeted towards retail and wholesale type market rather than household waste. I do recognise that household waste would be affected by that at some particular point as an example that I'd given. I'm even thinking wider than just the unsold consumer goods that going through all of this do you think the costs and the finances and the expectation is that you will do the minimum or do you think there's an expectation or do you hope to be more proactive in this whole area? I think we need to be more proactive to be realistic because in terms of reuse for instance, that's a major element of what we're trying to do, not just about managing waste, but reuse is part of that as well in terms of unsold goods and whether they friend its way back to a useful life within either household or wider markets for that. Probably the most, the example at the moment is probably food waste because of the perishability aspect of it, so elsewhere legislation is pushing for wholesalers and retailers to put that food material back into use again rather than disposal route for various reasons, but in terms of other household goods I think that would be quite challenging because it could be anything really. I mean, Mr Jack, I think it was you that said that there's quite a lot of waste going into residual waste and I think there's a figure somewhere that said 60% of residual waste could have been recycled and I mean it seems to me where I live in Glasgow or my part of Glasgow at least, you know that some of it's a lack of education so people put lots of things in a plastic bag and put the plastic bag in the recycling whereas as I understand that the plastic bag shouldn't go in the recycling, the paper and the cans should just all be recycled. So there's a bit of an education thing, there's also a bit of confusion between different councils because some of us who live close to other councils, my mother used to live in South Lanarkshire, they did things differently from the way Glasgow does them. It used to be the case here in Parliament for Edinburgh that I had to put both the plastic bottle and the top into the recycling bin whereas in Glasgow you don't put the top in, you only put the bottle in. So, you know, there is quite a lot of confusion here for one thing which would presumably mean that we need education but on the other hand I mean some people, there's a kind of macho image at least in Glasgow that you know you don't put litter in the bin, that's kind of, you know, it doesn't give you the right image, it's not cool and then you certainly don't put split your rubbish up between different bins because that's not cool either. So, can the councils do more, should the councils been doing more and will that cost more if you were to start challenging some of these things? I think, chair, in terms of being proactive around that message, I think local authorities generally are, I mean certainly within my own council the waste disposal budgets and within my remit is heady service which includes a number of frontline services in West Lothian, I mean it's a concern to me that we have to pay to get rid of waste, you know you want to reduce that cost as much as you could so that the work I mentioned earlier about where we were in our journey West Lothian was recycling pretty well. There was changes made to the reporting frameworks which show our recycling rates has been lower principally because we're using more energy from waste in terms of the contracts that go through. So we are proactive in what we're doing and as I said earlier we've benefited for the refund to help with that. The issue around about the market certainty and the customer use I suppose as simple as you can make it would be best for the customer but to get clean products back to the market then we have to split our waste into different streams and there is difference across councils. I think Charlie commented on that earlier as well so I don't think there's a standard fit. The messaging needs to be talked up regularly and I think that's the journey that we're on again at the moment and these trials that I mentioned earlier, much as they're intense for these two communities we're in, I don't think the journey finishes at the end date of the trial, we'll need to keep going back. I think that I and some of my neighbours, what we need is somebody to come round from the council and say, look at that bin, that shouldn't be in it. In all the time that we've had recycling in Glasgow I've never seen that happen or have a leaflet through my door or anything. It's just every week the wrong stuff goes into the wrong bin and it just carries on. I can maybe answer that in terms of West Lothian then that wouldn't be your experience with us. We are using a tagging system, the education staff at the moment are out in front of the refuse collection wagons, they are looking at the content of the bin as best they can, they're door knocking where they can, there are letters that we're dropping to help and encourage people to recycle. That message is labour intensive to get through and can be contentious. We're seeing an increase in adverse customer reaction, albeit in the minority, to our staff who are only doing their job to help everybody recycle for a message that the majority of people get and might not be fully complying with. Some people are fanatical, hopefully my sister is not watching but she takes the labels off the jam jars and everything, I mean just what I would consider ridiculous but anyway. Ms McGuire, following on that? No, it's a similar situation in the south Lanarkshire so I had to touch on earlier on that we had introduced a tagging campaign and that was because our material on our recycling bins had changed contractor and we realised that what we thought was good quality wasn't in fact good quality. We continue to do that so if our crews identify that there is their own items within the bin we will tag it and we won't lift it and our refuse collection crews will include that information in our incubation system so that that goes to our contact centre and then if someone in the contact centre gets a call from a resident to say that their bin has been missed which is quite common. Not that their bin has missed, just that the report that the bin has missed because we haven't lifted it because they've contaminated it and then right away the resident can say that it's already the contact centre can say that it's because they've put their own items in the bin and we can arrange a follow up visit from a resident. That sounds positive. Mr Devine, in the cities is that just not possible at level of involvement? It's really difficult in terms of commuro because it's difficult to identify if it's a single offender within a block of six flats or everybody's the same or if somebody's just walking past in the street and doing something in it. There's what we call wish cycling as well so people are not quite sure so they put it in the recycling bin we deal with that. That's one thing but it's just deliberately contaminating the material it's the most difficult for us and it's lots of time and effort. Again, probably Dundee is an example to get quite a big transient population in terms of the people coming into the city for the study of universities so we get a short burst of new people coming in and then having to educate them and work with the various landlords and housing associations to do it. It's quite challenging for that. We've got a system which has been pretty stable for the last seven or eight years as part of a previous investment and it offers those within the communal properties and those within a back and front door will win exactly the same system so it really just needs to try and avoid that confusion element for it. Again, it still becomes challenging and probably the contamination element, the vast majority of that is within the communal system at the moment so we know where the challenges are for that. On another subject or angle, I picked up the point that you'd made that you might not be allowed to charge for uplift of specific items like garden waste in future. Now Glasgow's just started doing that and I think other councils have been doing that. Can you explain to us what the issue is there? I mean, it was some work that's been done, I think it was through Zero Waste Scotland but it was really that one of the barriers to recycling was that if you charge for something, so obviously local authorities charge for garden waste at the moment because it's not a prescribed item so they can charge for it and similar for bulky items. So the issue for that particular within some councils we're on the same but that's been the case for a number of years so now it's an established revenue stream. There is recognition that obviously some material could slip into the residual waste stream so there's other ways of dealing with that in terms of different frequencies for residual bins etc. But again that at the moment gives us the opportunity one cover the cost of that opt-in service but also to be able to continue to support the other services within the scheme as well so quite challenging if that was to be taken away which it was. The example that I looked at wasn't just that study but also what had been taken place in terms of the wider UK waste research that was there so we wanted to include that really just to flag it up to the committee that it could be a potential issue for that but I do realise that that position has changed down south as well as far as I know that they're no longer going to give councils the option if they want to charge for that. The other thing I suppose is that we actually process our own garden waste so we produce a product that we can use and market as well so it's trying to protect that so I suppose self-sufficiently we have in dealing with those materials. Ms McGrath, Mr Jack, are you just kind of the same or do you want to add anything on that picture? No really, anything the same I think. We're just uncertain to over whether that will come in or not. I mean she just alluded to Glasgow just recently into just the charge for garden waste uplifts. If we knew that that was 100% happening then I suspect that wouldn't have happened but it's another area of waste that is uncertain to him which makes it pretty difficult to make anything different. I mean we don't charge for garden waste at the moment but we have food waste and garden waste combined and we're not alone in that as a local authority and some others do charge in relation to that combined service so our council has looked at it and it's not to say that we'll not need to look at it again. I mean just to pick up another point you made Mr Jack I think you've referred to grey bins now I don't know what you put in grey bins in your council in our area grey bins is just for food I think that's probably not the case. Could the councils not work together and get the same colour of bins? Would that help? I think that there was some work done on that as part of some previous legislation that was out. I'm not sure if it was a way Scotland regulations 2012 for that harmonisation part and it was a considerable cost it was in the hundreds of millions so it kind of took it out. It would be good if somebody didn't have a service that they had rolled out yet and when they did invest that they harmonised in terms of that bin colour but I think it was quite open. It's difficult because it means cross boundary communications for instance if you stay quite close to two councils as you mentioned yourself you can get the wrong message you put the wrong stuff in the wrong bin simply through something on the radio or something pop-through. I accept that that's a problem and the final issue I want to just to was the littering from vehicles. I mean I just find it hard to get my head round it how this can possibly work because unless somebody's there with a camera would it have to have a camera to photograph the person actually dropping the litter out the vehicle or what would the cost of that be because it does suggest I think in the financial memorandum that it could be self-financing is that possible? I don't think that it will be self-financing and that's just from previous experience I mean the South Lanarkshire Council has in the past we have issued fines for people who have dropped litter from cars and that's been based on reports that we've received because we've taken that as being we have a reason to believe and if someone has provided evidence to suggest that they have seen litter dropping from a car. That's a difficulty and that's where you get the difficulty in terms of recovery. If you find someone for littering then there's corroboration required, if you're caught speeding with a camera there's no corroboration required and that's the difficulty we have as local authorities so the small team environment wardens that we have will have cameras but we have to put them out in pairs to do the corroboration so that impacts on the cost points that we've put forward in the memorandum as well. If you need corroboration then if you're funny for two people they're working together. I'll leave it at that, thank you very much. Thank you very much Liz. Thank you, you've all been extremely helpful in telling us where you think the costs might have an underestimate in some of the difficulties that we have to look at from the financial memorandum perspective. Are you clear or do you think that there is more clarity about where the responsibility for the costs will fall, namely between national government, local government and SIPA? Do you think that there is sufficient clarity about who will be responsible for which costs or do we need more clarity on that? I didn't pick up there were any issues on that, I thought it was clear to me but that's me just, you guys may have a different opinion. I think that probably because I don't come from a regulatory background probably clarity would be good for me for a personal point of view because it did look as if it was like everybody had a role in it but nobody who was actually going to lead on that. I'm just asking the question because I know at the net zero committee when you're looking at the bill there were some questions about who was going to be liable for specific costs and whether we need to have a little bit more clarity within the financial memorandum or whether it's just a numbers game. Probably the way it works at the moment for instance where we know where the boundaries are between SIPA and local government for instance when it comes to an offence having taken place or whatever but when it comes to some of the multi agency approach type things it might need, I'm not quite sure who would be the lead on that unless it was designated and obviously that would then become the financial issue with them. I'm going to be something that we can pursue. Just going back to this issue about behavioural change which I think is absolutely critical to the whole debate. Do you feel that when it comes to recycling centres that we need to do more to try to encourage use of these recycling centres and that they will be open at the times, that they say that they'll be open? I mean certainly in my own local authority there are issues about staffing for that. There are two or three local centres that are going to be closed for certain times during the week and the hours are going to be cut. Do we need to do more to encourage people to use these recycling centres? Pretty well used in South Lanarkshire and I know that because I tend to get complaints about queues. I think that what it is is that people try to use them all at the same time so that you have times throughout the day where they are not well used and you can understand that because people are at work or college or university or whatever and then everyone goes at the same time. I think that from South Lanarkshire point of view it doesn't seem to be an issue for us. We're open from making the morning until 7 at night all our sites during summer hours and from 8 to 4.30 I think or 8 to 5 o'clock during winter hours so we have quite long generous operating hours. Is there an increase in the number of people who are using these centres? Everyone experienced through the pandemic there was a massive increase and it causes all serious issues. We've just returned back to normal usage now so I think that it's pretty steady. Presumably there's some scope for cost reduction if there is greater use of these recycling centres. You just get costs just move to somewhere else and actually it's probably for us it's probably more expensive to take waste through our recycling centres than it is through our care site. That comes back to the question about responsibility for costs. I agree with all the previous speakers I've asked about behavioural change because I think it is so critical to solving a lot of this issue. I think that we've got a big job to do to get people to understand quite a lot of the implications of not taking responsible attitudes when it comes to waste management. I agree with the point that there is a lot of confusion out there. As in I can speak from a Perth and Kinross angle where two new excellent bins have appeared for cans, plastics and tins but that covers exactly two other existing bins which took the same thing plus cardboard and paper. We've got other bins for those as well but all those bins now exist and nobody is quite sure where to put anything. I cite that as an example where I think it would be helpful for local authorities to be extremely clear as to what goes where because that must have an implication on costs. I think that we're all agreed on that communication as the key to this. Just quickly before we leave the city site or the HWRC topic, I think that there's a role for civic community sites in bringing in materials that we don't accept at the care site. I think that that's really important for recycling. Batteries, for example, electrical goods or larger white goods, we're having an obviously across the country issue with lithium-ion batteries so having somewhere to take that are gas bottles because gas bottles end up in the back of our CVs because it's major issues that work and our energy from waste facilities so there's definitely a role there. When it comes to public information education about this issue, what have you found to be the most successful channel of ensuring that people adhere? Is it leaflets around the doors or is it people telling that the bins have been contaminated? What has been the most effective way of communicating? For us recently, we've invested more in door-knocking exercises. We have problems in flatted areas where residents will just put out rubbish and just expect it to be removed so they won't phone for a bulk-up lift despite the fact that South Lanarkshire still provides one free to each household every year. We've had to basically, and it's really laboured intensive, but we've found that there's been a benefit. We've sent our waste education team out and they've knocked doors and they've delivered leaflets and they've given one-on-one advice and it has made a difference, but it is costly and it is not feasible for us to do it across the wider area because the area is far too big. Is it possible to distinguish between the more rural areas where you can't possibly expect it to go door-knocking, just too difficult to do that, and the urban areas? Have we got a better public information campaign in the urban areas than we have in the rural areas? I would say so because a lot of the communication issue will be South Lanarkshire-wide through social media platforms. On a website, we have a publication called The View that has stories in there, but the door-knocking, we will concentrate on the areas where we have a real problem. Often or not, those tend to be in our more built-up areas. That's very helpful. Good morning. Thank you for giving all the information that you have done so far. Of course, what this session has brought out is a considerable uncertainty and complexity and what we're doing with that. As the convener pointed out earlier, the point of an FM, but also adding on to that, an FM should show the margins of uncertainty for any estimate. I often search in keywords on things just to get a picture of it. There isn't really any particular disclaimer of uncertainty, but there is quite a lot of, if you search in the word, range. When you look at the ranges, the ranges are vast in the estimates. Some of the figures are like for regulation from £30,000 to £200,000, and you're going to basically the bigger the range, the higher the uncertainty and the less accurate the estimate. I just wanted to get your sense of that from a confidence point of view. Are there any particular areas, because I accept that there's a lot of information coming out this morning, where you think that the range of estimate expressing uncertainty is so utterly huge as to be really not worth very much at all, in addition to what you've already said this morning? You smiled at me so you could go first. I was just thinking that we're working in that world. We start off with a really broad range and as you get more information, you start to narrow that range down to something that you can live with. That tends to be where we are, but the range is vast, as you say. Obviously, from all local authorities, everybody is in a slightly different place, so everybody has a different idea of it. As we mentioned, probably where we are is that we need to invest money in certain parts of the service in terms of communications, for instance, and how we do that. Where are the balance of having more communications and less enforcement? Obviously, personally, if you have to enforce something and everything else has failed, it's always been a big challenge for that. I have 10 people out there pushing the message and one person dealing with that sort of gives you the idea of where the range would come into it for that. It's quite challenging to do that and really have more information. The only way that you've got more information is to speak quite far down the line where we are, probably beyond financial memorandum. I'm going to come on to that. To either Kirstie or Jim, I want to bring out where you think that one or a number of ranges are so vast by quantum that you think that they're almost worse than useless. You've put a lot of information on the table today, but I suppose I'm trying to establish where the ranges are so vast that you think that this now becomes largely meaningless. The bit for me would be round about where the interventions work best. I think that that's the bit where I'm in the local authority point. If you're a bit uncertain, the chain or the circular economy gets the point that if everybody plays a part, you must have something better at the end. For introducing the local authority bit in the middle of the chain and there's not the upstream or downstream changes, that makes it hard for us and that's certainly a bit that I struggle with just reading through it to see what it means specifically for our council. I appreciate that that's not answered your question fully. It's maybe introducing something new into the mix, but there is a bit about the sequencing of the changes. I think that I've probably made my point about the vast ranges and both Charlie Jack, you've alluded to the behavioural changes and that's the uncertainty element in terms of this bill. I want to pick up on something that my colleague John, earlier asked where he used the terminology good and bad, but I'm going to make it a little more academic and say on a scale of 0 to 10 where 0 is no confidence in the estimates and 10 is high confidence in the estimates. I think that we can fairly reflect that you expressed considerable uncertainty in also what it means for you. That isn't meant to be a portioning blame. I'm just trying to reflect where we are in process. What number would each of you give to this FM where 0 is nid pois, literally, and 10 is a high degree of confidence? I'm going to go under 5. Is that a 4 then, just to be specific? I understand why it's pretty difficult to attribute costs when you've not got the full picture. We don't know what the secondary legislation is going to look like. We don't know what the other legislation, what form it's going to take. We don't know what the form that the EPR stuff is going to take. It makes it pretty difficult to be fair to the people who have written a financial memorandum to put any meaningful figures in here. I'm trying to avoid sitting in the fence here. Exactly, that's why I'm asking a number. I think that I'm in the same area as Kirsty, to be honest. We're attempting to say 5, but that doesn't achieve what you want. No, I'm not looking for any. I'm just trying to get a measure on the table. You can choose to say 4 to 5. This is not a trick question. I'm slightly more optimistic. I think that there's a lot of work. I think that there's more work to go there, but I think that it's on the right track. I just think that a bit more work in the background and a bit more understanding of what the other costs are, rather than the ones that I'm just trying to address. I don't think that you can narrow it down to a single function that you want to identify because it's part of a chain of events that happens within local authorities to get to that stage. I think that there's a bit more understanding about what the chain of events are and what the actual cost is for that would be helpful. You've led me on to my final question. In an ideal world where we go from here that recognises all the evidence that you've given this morning, in terms of co-design that was brought up earlier by the convener, what, ideally, would you like to see happen to get to something that up-see scores where we can all have more confidence in the FM and fully accept the uncertainty and complexity and all the differential points you've made about councils? Is it fundamentally about a continued exercise of co-design and the production of an updated FM? Or are you happy for this extra work to slip under secondary legislation? If you had a choice what would you choose and why? It's a difficult one. To address the co-design at this particular level, I think that it would be really difficult and it would probably lint in the process considerably, but we'll need to make sure that if it did become part of secondary legislation and the work was done there that it was recognised at this level that it could bring other changes. The co-design thing is as big and complicated as you want to make it for that. What's happened, you'll probably see from other examples in the UK, is that they've spent a lot of time and effort to go back to basics again. I think that it's to recognise that it's involving all the partners in making sure that it would play by proper partners in the circular economy but also to make sure that it is viable and workable on the ground and obviously the citizens can actually contribute to that system rather than just being some... It's still true. The same question to Kirsty and Jim. What do you think should happen now to move us on from where we are in terms of co-design or secondary legislation? That is in whether we rework the financial memorandum at this stage or whether we wait until there is secondary legislation. That is an option. I think that if we get to the stage where there is secondary legislation then we at least know the direction that we are travelling in. The uncertainty now makes it really difficult as I'd said previously and it may be that once we know more about what's happening in the waste sector we'll be able to come up with some better assumptions and some more relevant costings. Final comment, Jim. I think that I'm of the same mind and that the secondary legislation is the area that maybe creates us the biggest concern at the moment because we don't know what it looks like. We totally appreciate the point that Mr Devine made as well about needing to progress and have some parameters to work to and I suppose the concern for all of us would be that one part isn't locked down in isolation of the other which is back to your point about the scale between the two figures is quite large. I think that I'd be bided to go that way. Thank you very much. That's concluded the questions from the committee. I think that circular economy is one of those phrases that just appeared and I don't think that the public really know a lot about it. It's like when Tony Blair came in in 97 and social exclusion suddenly became the phrase that everybody used so I think that there's some education in terms of circular economy. I just want to say one thing. Even the financial memorandum itself points out that it's not got all the answers. For example, it says in section 33, it's not possible at this stage to provide definitive estimates about the extent of any additional costs or benefits to local authorities. They've associated with the introduction of enforcement tools for local authorities in relation to householders recycling obligations. The financial memorandum itself admits that it's not the full answer there. I want to thank all three of you for giving your evidence today. It's really greatly appreciated and we'll take evidence on the circular economy bill from the Scottish Government at next meeting on 7 November. With that in mind, I'm just wondering if there's any final points that any of our witnesses would like to prefer. We might not have touched on that you feel we should have or any specific points that you want to make sure we don't omit when the minister comes before us in a couple of weeks. OK, thank you very much. That concludes the public work for today of the committee. We now move into private sessions to consider our work programme. I'll just call a wee break till 5-11 to enable our witnesses and the official vote to leave.