2.1. RIA is the trade association for UK based suppliers to the UK and world wide railways. It has over 300 companies in membership covering all aspects of rolling stock and infrastructure supply and covering a diverse range of products and services. As well as most of the Tier 1 contractors and large, multi national companies, over 60% of RIA’s membership base is comprised of Small and Medium Sized Enterprises (SMEs).
2.2. RIA Scotland supports rail suppliers across the nation, providing a voice for the sector. RIA Scotland is led by a Leadership Group, consisting of Scottish rail suppliers, and provides its members with extensive services, including:
1.
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2. BACKGROUND TO RIA AND RIA SCOTLAND
• Provision of technical, commercial and political information;
• Export promotion including organising UK pavilions at key rail exhibitions overseas.
• Decarbonisation: The rail supply chain stands ready to deliver the 2035 rail services decarbonisation target and to support the wider decarbonisation of Scotland by 2045.
1 https://www.riagb.org.uk/RIA/Newsroom/Publications%20Folder/OE_2021.aspx
• Efficient delivery: Rail suppliers recognise the imperative, now more than ever for the rail industry to be efficient and cost effective.
2.3. A 2021 report ‘The Economic Contribution of UK Rail’1 found that in Scotland, rail contributes £3.2bn Gross Value Added to the economy, 56,100 jobs, and £1bn in tax revenue.
• Supporting innovation through the Unlocking Innovation programme and university partnerships;
2.4. RIA Scotland members have identified four key priorities to work on together with the Scottish Government, Transport Scotland and other key stakeholders:
Delivering Scotland’s circular economy – route map to 2025 and beyond INTRODUCTION
1.1. This submission constitutes the response from the Railway Industry Association (RIA) and RIA Scotland to the consultation on the proposals for a Route Map to 2025, a strategic plan to deliver Scotland’s zero waste and circular economy ambitions.
• Providing opportunities for dialogues and networking between members;
• Innovation: Innovation can support decarbonisation ambitions and the need to deliver quicker, better and cheaper while also contributing to economic growth and creating export opportunities.
• Skills: Skills and people are necessary for the rail sector to grow and deliver successfully and young people need to see the rail sector as an attractive workplace. These priorities will be supported by a clear and stable pipeline of opportunities.
• Representation of the supply chain industry’s interests to the Scottish Government, Transport Scotland, ScotRail, rail clients and other key stakeholders;
RECOMMENDATION
RECOMMENDATION
RECOMMENDATION
1: Provide industry with a clear strategy and plan any changes in plans or funding will make it more difficult for industry to deliver on circular economy targets. In order to best support the rail industry’s adoption of circular economy practices, the Scottish Government should focus on:
4: Rail can support green jobs across all of Scotland. Provide a clear pipeline of work to allow rail suppliers to invest in skills including apprenticeships, training programmes, and circular economy schemes. Include the rail sector in the Circular Economy skills audit.
RECOMMENDATION
RECOMMENDATION
3: For the rail industry, the most effective compliance mechanism is a voluntary one where good performance on circular economy schemes is recognised in the procurement process and in tender evaluations. This allows ‘good actors’ to be rewarded without creating a new barrier to entry to companies wanting to enter the sector. Suppliers and industry should be consulted at the earliest possible stage ahead of the introduction of any mandatory compliance measures and adequate transition periods allowed for.
6: Outcome focused procurement and early supplier engagement allows suppliers and clients to work together to achieve circular economy ambitions.
2: To fully unlock the potential of the rail industry to support a circular economy, the Scottish Government should work with rail suppliers and stakeholders to ensure that solutions are innovative, economically viable, and delivering the maximum benefits. This includes working with SMEs as well as larger companies.
RECOMMENDATION
• Funding: Fund and support skills development and innovation in rail.
• Innovation: Provide industry with outcome focused objectives to allow rail suppliers to innovate.
5: Innovation in the rail sector can support the circular economy, both for rail and for other sectors. Innovation funding should focus on both development and deployment, and clear challenge statements and outcome based procurement will allow the private sector to put forward innovative solutions. An open by default approach to data can encourage innovation. Modern methods of construction can be supported as outlined in section 17.8.
• Procurement: Award good performance on circular economy in procurement.
• Pipeline: Transparent information on the expected pipeline of opportunities to allow suppliers to invest in their people and their circular economy initiatives.
2 / 11 3. SUMMARY OF RECOMMENDATIONS FOR DELIVERING SCOTLAND’S CIRCULAR ECONOMY
https://consult.gov.scot/environment forestry/scotlands circular economy routemap/ 3 https://consult.gov.scot/environment forestry/scotlands circular economy legislation/
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4.2. Simultaneously, the Scottish Government is also consulting on proposals for legislation to develop a Circular Economy Bill for Scotland. 3 The Circular Economy Bill sets out the legislative powers that would be used to deliver a circular economy, and this includes some of the interventions proposed in this consultation on the Route Map to 2025.
5. QUESTION 1: 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. 2
4.3. RIA Scotland’s submission to the consultation on the Route Map to 2025 is as follows. As RIA Scotland is a trade association this submission will only include responses to those questions relevant to the rail supply industry.
4. CONTEXT 4.1. The Circular Economy Division of the Scottish Government is consulting on a proposal for a Route Map to 2025, a strategic plan to deliver Scotland’s zero waste and circular economy ambitions.2 The existing and proposed measures are summarised below.
4 / 11 5.1. N/A 6. QUESTION 2: Are there any further measures that you would like to see included in the Route Map to promote responsible consumption, production and re use? 6.1. N/A 7. QUESTION 3: 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. 7.1. N/A 8. QUESTION 4: Are there any further measures that you would like to see included in the Route Map to reduce food waste? 8.1. N/A 9. QUESTION 5: 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 9.1. N/A 10. QUESTION 6: 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? 10.1. N/A 11. QUESTION 7: 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. 11.1. N/A 12. QUESTION 8: Are there any further measures that you would like to see included in the Route Map to improve waste recycling from commercial businesses? 12.1. N/A 13. QUESTION 9: 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.
13.1. ☐ Strongly agree ☐ Agree
• Assessing railway projects using the RSSB Rail Carbon Tool4 and the Social Value Tool5 with a specific requirement to consider circular economy opportunities when evaluating options using these tools. This could be facilitated by clients ascribing values to the avoidance of waste.
• Procurement: Award good performance on circular economy in procurement.
13.2. RIA Scotland welcomes the high level of ambition with regards to achieving circular economy goals and targets. By working together, industry and the Scottish Government can accelerate the progress already being made and set the pace and ambition for others to follow. As a major player in the construction sector, the rail industry can and must play a role in establishing a circular economy
• Use low carbon concrete and recyclable materials in the refurbishment of stations and other infrastructure projects.
5 / 11 ☐ Neither agree nor disagree ☐ Disagree ☐ Strongly Disagree
13.3. The rail industry builds and maintains both rolling stock and infrastructure. This means that a variety of materials and products are handled including steel, concrete, track ballast, electrical wiring, sleepers, and train interiors. Progress can be furthered by working with Transport Scotland and ScotRail to embed circular economy practices in procurement, in particular by:
13.5. RECOMMENDATION 1: Provide industry with a clear strategy and plan any changes in plans or funding will make it more difficult for industry to deliver on circular economy targets. In order to best support the rail industry’s adoption of circular economy practices, the Scottish Government should focus on:
• Efficient design for the life cycle from construction, use, refurbishment and deconstruction of both rail infrastructure and rolling stock.
4https://www.rssb.co.uk/en/sustainability/rail carbon tool 5 https://www.rssb.co.uk/sustainability/social sustainability/the rail social value tool
• Increased focus on ‘do minimum’ options to retain as much as possible of existing infrastructure (or rolling stock) in new work This avoids unnecessary demolition and waste.
• Re use of materials including recycled ballast and sleepers made of recycled materials.
13.4. RIA Scotland welcomes the integration of the route map with other existing programmes and strategies, including the National Planning Framework 4 and BE ST (Built Environment Smarter Transformation). Sector specific programmes, such as the Rail Services Decarbonisation Action Plan for the rail sector, should also be considered as a wider range of plans that industries are being asked to support. It will remain key that ambitions are aligned so that the private sector does not receive mixed messages a clear strategy from the Scottish Government will provide the private sector the certainty it needs in order to invest in resources and skills.
• Surplus materials from the East Kilbride project were reused elsewhere.
• Use of recycled steel in bridges have saved carbon in the construction of HS2.9
13.8. RIA Scotland agrees that improving collaboration between Government and industry will be necessary to understand how interventions will work in practice and to mitigate any unintended consequences. The Scottish rail supply chain consists of both large Tier 1 companies as well as SMEs and start ups and it is important that circular economy initiatives remain economically viable across the whole supply chain. It is therefore good to see that the consultation document recognises the fact that the construction sector often relies on tight margins and a high reliance on public sector clients. This further strengthens the case for collaboration and supplier engagement.
• Rail suppliers have developed sleeper pads made from resin bonded rubber and sourced from the circular economy.8
• Funding: Fund and support skills development and innovation in rail.
• Scotland’s Railways and the rail industry are working to develop and adopt science based targets6 this is an efficient way to encourage good performance and should be included in procurement and tendering.
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13.7. RIA Scotland also welcomes the ambition to work with industry to accelerate the adoption of best practice standards and to identify barriers to change and innovation. In the rail sector, this will mean close collaboration between suppliers and other key stakeholders including Transport Scotland, Scotland’s Railway, and ScotRail. The rail supply chain has many examples of best practice. Additionally, many rail supply companies work across several sectors and countries and can therefore provide best practice examples to learn from other industries and parts of the world. Some examples of best practice are listed below, and these also serve to illustrate the way in which circular economy policies would be relevant to the rail supply industry:
13.6. The above could take the form of a collaboratively developed long term plan for Scotland’s Railways which includes, in addition to the investments to benefit transport users and the wider economy, the supply chain initiatives to deliver continuous improvement including on the circular economy.
• Innovation: Provide industry with outcome focused objectives to allow rail suppliers to innovate.
• 98% of demolition waste from Glasgow Queen Street Station was re used and recycled.
• Works on the Aberdeen to Inverness line were able to re use 35,000 tonnes of ballast. See footnote 5 for more on the above.7
13.9. Initiatives such as the Scottish Construction Leadership Forum, the Circular Economy Investment Fund, the Supply Chain Sustainability School, and BE ST are welcomed initiatives 6 https://sciencebasedtargets.org/ 7 https://www.networkrail.co.uk/blogs/scotlands railway the ticket to greener travel/ 8 https://www.riagb.org.uk/RIA/Newsroom/Stories/Learning_from_Major_Projects.aspx 9 https://www.riagb.org.uk/RIA/Newsroom/Stories/Learning_from_Major_Projects.aspx
• Pipeline: Transparent information on the expected pipeline of opportunities to allow suppliers to invest in their people and their circular economy initiatives.
13.15. RIA Scotland cautions against the use of recycling bonds for the rail industry. There will add costs and inefficiencies to the industry by stifling cash flows this is particularly difficult for SMEs and companies which rely on a steady cash flow to maintain skills and jobs.
13.11. RECOMMENDATION 2: To fully unlock the potential of the rail industry to support a circular economy, the Scottish Government should work with rail suppliers and stakeholders to ensure that solutions are innovative, economically viable, and delivering the maximum benefits. This includes working with SMEs as well as larger companies.
13.12. While mandatory compliance may be suitable for other sectors, RIA Scotland recommends that it is not the most efficient mechanism for the rail industry. However, RIA Scotland also recognises that voluntary compliance might mean that desired targets and progress aren’t met. Therefore, compliance should be incentivised through the procurement and tendering processes held by Transport Scotland and ScotRail.
13.13. This means that when Transport Scotland and ScotRail are procuring rail projects and rolling stock, rail suppliers will have to demonstrate a commitment to circular economy practices when bidding for work, meaning that a good performance will lead to a greater likelihood of securing contracts. A blanket mandate for the whole sector may risk creating inefficiencies prescriptive policies leave little room for innovation and for improvement beyond what is being asked for. The competitive environment of bidding can bring out the best of the private sector.
14.1. See our other responses.
13.10. RIA Scotland and the Scottish rail supply chain stand ready to assist in the progression of the route map, and can for instance act as a platform for industry led groups. RIA Scotland can also offer support for the industry consultation on expanding salvage and reuse, by providing evidence and feed in from the rail supply chain.
13.14. RECOMMENDATION 3: For the rail industry, the most effective compliance mechanism is a voluntary one where good performance on circular economy schemes is recognised in the procurement process and in tender evaluations This allows ‘good actors’ to be rewarded without creating a new barrier to entry to companies wanting to enter the sector. Suppliers and industry should be consulted at the earliest possible stage ahead of the introduction of any mandatory compliance measures and adequate transition periods allowed for.
7 / 11 to foster collaboration and innovation. Alongside larger companies, SMEs must also be involved in such conversations and fora. Given the skills and capabilities sitting within these organisations, we recommend the development of a series of CE focussed events and training sessions, highlighting examples of good practice and tools to assist CE activity, such as the PORTAL Tool from BE ST.
14. QUESTION 10: Are there any further measures that you would like to see included in the Route Map to embed circular construction practices?
• Sustainability professionals: Increased resources may be needed to maximise the impact of this initiative including to develop processes and evaluate options
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15.1. N/A 16. QUESTION 12: Are there any further measures that you would like to see included in the Route Map to minimise the impact of disposal?
17.3. For rail, the specific skills needed are:
15. QUESTION 11: 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.
17.2. Apprenticeships, such as those run by suppliers, Network Rail, and ScotRail are good examples of programmes that aim to increase the number of young people joining the rail sector. These should be linked up with initiatives such as the Climate Emergency Skills Action Plan, the Green Jobs Skills Hub, the Rail Cluster Builder11 , and the Green Workforce Academy. For all of the proposed initiatives, rail can act as an excellent sector to help develop circular economy skills in. Rail should also feature in the proposed Circular Economy Skills audit and RIA Scotland and rail suppliers stand ready to support this.
• Digital: For the circular economy, digital skills in rail are needed to further modern methods of construction and sustainable design principles
16.1. N/A 17. QUESTION 13: 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.
17.4. Certainty and visible programmes of work allow industry to better support skills development, as suppliers are able to invest in apprenticeships, training programmes, and future projects. The industry will welcome any long term plans and strategies as these 10 https://www.riagb.org.uk/RIA/Newsroom/Publications%20Folder/OE_2021.aspx 11 https://www.scottishengineering.org.uk/railcluster/
• Sustainability Trainers/ Training Facilities/ On line learning: It will be necessary to train the whole workforce on the principles of the circular economy and on their individual responsibilities.
17.1. RIA Scotland supports the focus on innovation and skills both will be essential in order to meet circular economy and climate targets A focus on skills will not only provide benefits for the circular economy, but also wider economic and social benefits in terms of economic growth and productivity. In 2019, the Scottish rail sector contributed with 56,100 jobs, £3.2bn in economic growth, and £1bn in tax revenue.10 Rail is green and contributes to both the climate change agenda as well as connectivity, and it remains a key sector for opportunities to grow the green skills base in Scotland.
• Supporting and encouraging the use of modern methods of construction including having an open mind to new and non traditional techniques.
• Procuring in sufficient volume on a design and build basis to allow these techniques to be delivered efficiently and to support the necessary investment in off site facilities.
RIA Scotland welcomes the focus on research and innovation, but innovation is not just about new ideas, of which there are plenty in Scotland, but also about implementing those ideas to create real positive change. The main issue at the moment is therefore the need to remove barriers to implementation To address this, a 2022 RIA report12 on unlocking the innovation capabilities of the UK rail supply chain sets out six key asks:
• Increase government investment in Rail Research, Development, and Innovation
12 https://www.riagb.org.uk/RIA/Newsroom/Publications%20Folder/A_Railway_Innovation_Strategy.aspx
• Lead a concerted cross industry effort to identify and overcome barriers to successful adoption
9 / 11 provide certainty. However, when strategies and plans are not coupled with sufficient funding it will become difficult for suppliers to invest in skills.
17.6. The ambition on the circular economy and decarbonisation is and should remain high. Innovation can support these ambitions and the need to deliver quicker, better, and cheaper.
17.5. RECOMMENDATION 4: Rail can support green jobs across all of Scotland. Provide a clear pipeline of work to allow rail suppliers to invest in skills including apprenticeships, training programmes, and circular economy schemes. Include the rail sector in the Circular Economy skills audit.
• The railway needs whole system and long term innovation thought leadership
17.7. One example of where innovation has been encouraged has been through the output requirements in the Rail Services Decarbonisation Action Plan. This has allowed industry to invest in machinery with digital capabilities. In the past, this has been difficult as there has not been a visible pipeline of future work. The certainty and output focused approach of the Decarbonisation Action Plan has also meant that work can be carried out more efficiently, as rail suppliers have the confidence to invest in plant and skills needed to achieve decarbonisation. This serves to demonstrate that if suppliers are given certainty of future work and plans, and output requirements, it will be easier for them to deliver on circular economy objectives.
• Support skills development and the creation of an innovation culture
• Considering working with industry to facilitate shared off site facilities.
• Strengthen support during the innovation rollout phase
17.8. Innovative modern methods of construction and modular design can reduce the amount of material consumed during a rail project by using intelligent digital solutions, including digital twins. This also allows for design for deconstruction principles to be used, ensuring the sustainability of rail infrastructure. These approaches often reduce site time and therefore reduce disruption to rail users. They also improve quality and reduce re work. Modern methods of construction and similar innovations in the rail industry can be supported by:
• Provide a pathway and funding for radical innovation
17.13. RIA Scotland supports the proposal for a Scottish programme for reuse of materials and assets. For rail, relevant products and materials would be:
17.10. RECOMMENDATION 5: Innovation in the rail sector can support the circular economy, both for rail and for other sectors. Innovation funding should focus on both development and deployment, and clear challenge statements and outcome based procurement will allow the private sector to put forward innovative solutions. An open by default approach to data can encourage innovation. Modern methods of construction can be supported as outlined in section 17.8
• Rolling Stock structures are largely recyclable metals. All other materials should be chosen considering the circular economy
17.11. RIA Scotland welcomes the integration of circular economy ambitions with procurement practices. In order to unlock the greatest value from the supply chain, procurement should be outcome focused and any targets should be carefully designed. To avoid unintended consequences, the supply chain should be engaged early in the procurement process. This will unlock innovation potential and ensure efficient delivery.
• Concrete and steel from bridges, structures, stations can be recycled. There is the opportunity to increase the use of sustainable timber and/or composites in, for example, new stations.
17.12. RECOMMENDATION 6: Outcome focused procurement and early supplier engagement allows suppliers and clients to work together to achieve circular economy ambitions.
• For track, rail and ballast are readily recycled, there are opportunities to improve the recycling of concrete sleepers and replace wooden sleepers with recycled composites Sleeper pads can be made from reused material including resin bonded rubber
• Copper and other metals including electronic waste from electrification and signalling systems
18.1. N/A 19. QUESTION 15: 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.
18. QUESTION 14: Are there any further measures that you would like to see included in the Route Map to support action across the circular economy?
• See also 13.3 above
17.9. As recognised in the consultation document, data can play an important role in understanding where the greatest opportunities for improvement are. RIA Scotland recommends that an open by default approach to data should be taken. Rail suppliers have strong capabilities in the digital and data realm, and if data is open and shared suppliers can use it to improve circular economy capabilities throughout the rail sector.
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11 / 11 19.1. N/A 20. QUESTION 16: Please provide any further information or evidence that should be considered in the accompanying Equalities Impact Assessment. 20.1. N/A 21.
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QUESTION 17: Please provide any further information or evidence that should be considered in the accompanying Fairer Scotland Assessment N/A QUESTION 18: Please provide any further information or evidence that should be considered in the accompanying Island Communities Impact Assessment N/A QUESTION 19: Please provide any further information or evidence that should be considered in the accompanying Business and Regulatory Impact Assessment. N/A 24. QUESTION 20: Please provide any further information or evidence that should be considered with regards to the environmental impact of proposals outlined in the Route Map. N/A Railway Industry Association Scotland August 2022 If you would like further information, please contact RIA Scotland Lead and RIA Technical Director David Clarke at david.clarke@riagb.org.uk and +44 (0)20 7201 0777
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