Scottish Government

Scottish Executive Environment Group
Scottish Environment Protection Agency
Policy and Financial Management Review
A Consultation
July 2002: Paper 2002/21

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CONTACT

Please send any comments you may have by 9 September 2002 to:

Jim Welsh
SEPA PFMR Team
Scottish Executive Environment & Rural Affairs Department
Area 1-J
Victoria Quay
Edinburgh
EH6 6QQ
E-mail: separeview@scotland.gsi.gov.uk

How to obtain further copies of this paper

Further copies of this paper may be obtained from the above address. It is also available on the Scottish Executive website at: www.scotland.gov.uk

POLICY AND FINANCIAL MANAGEMENT REVIEW OF THE SCOTTISH ENVIRONMENT PROTECTION AGENCY

1. Introduction

1.1 This consultation paper seeks views on the Scottish Environment Protection Agency (SEPA) and the work that it does to protect and improve Scotland's environment. It is being published as part of the Policy and Financial Management Review (PFMR) of SEPA that is currently being undertaken by the Scottish Executive. The review enables everyone with an interest in the Scottish environment, including those who look to SEPA to protect the environment, those who are regulated by SEPA and those with responsibilities of their own for protecting the environment, to contribute to the review.

1.2 The paper comprises:

1. information about the review, including the terms of reference that Ministers have set for it;
2. a description of SEPA's aims and functions;
3. a series of questions about SEPA that reflect the terms of reference and the views of a cross section of stakeholders in SEPA; and
4. information about how to participate in further consultation opportunities, including plans for meetings that will be open to anyone with an interest in the environment.

1.3 The responses to the questions set out in this paper will be a key source of evidence about SEPA's performance in protecting and enhancing the Scottish environment and its readiness to deal with the challenges of the future. An important principle of the PFMR process is that it should deliver recommendations to a set and relatively tight timetable so as to avoid prolonged uncertainty as to their outcomes. We are committed to concluding this review by summer 2003. To help us achieve this, and to ensure that we give full consideration to your comments, we should be grateful if all responses could reach us by no later than Monday 9 September 2002. Your responses should be sent to:

Jim Welsh, SEPA PFMR Team, Scottish Executive Environment and Rural Affairs Department, Area 1-J, Victoria Quay, Edinburgh, EH6 6QQ or to separeview@scotland.gsi.gov.uk

2. Background to the Policy and Financial Management Review of SEPA

2.1 Policy and Financial Management Reviews are an established means of ensuring that the public bodies accountable to the Scottish Executive are delivering the Executive's policies and priorities effectively, economically and efficiently. PFMRs are commissioned by Ministers who then report their outcomes to the Scottish Parliament.

2.2 PFMRs focus on ensuring that public bodies like SEPA provide an accessible, consistent and high quality service to all their customers; that they contribute effectively to the delivery of the Scottish Executive's objectives; and that they are innovative and forward-looking. PFMRs do not review the Executive's policies, which are matters for Ministers. Accordingly, this review will not be considering the Executive's policies for protecting the environment.

2.3 The Scottish Executive's Public Bodies Review ¹ in 2001 examined over 180 public bodies, including SEPA, to assess whether each had a distinct role and function to perform in delivering the Executive's policies and priorities. The review concluded that SEPA was still required as a public body in its current form. In light of that finding, the PFMR of SEPA will not be addressing the question of whether SEPA is still required as a separate public body.

2.4 Allan Wilson MSP, Deputy Minister for the Environment and Rural Development, announced the PFMR of SEPA on 28 May 2002 in response to a question in the Scottish Parliament. The full text of the question and Mr Wilson's answer are attached at Annex A. The terms of reference for the PFMR that Mr Wilson set out in the answer are for the review to:

1. consider how effectively SEPA has performed since it was established and seek the views of stakeholders on its performance;
2. consider how well SEPA responds to the policies and priorities of the Scottish Ministers and if the level of delegation to SEPA from the Scottish Executive is sufficient and appropriate;
3. examine the role of SEPA in relation to other bodies with responsibilities for environmental protection and regulation;
4. identify ways of improving the service that SEPA provides to communities and regulated organisations;
5. examine the policies and practices of SEPA in relation to the charges it levies for its regulatory service;
6. look at ways of streamlining the system of environmental permits and emissions monitoring; and
7. identify the key issues that need to be addressed to allow SEPA to meet the challenges posed by the shifting focus of environmental legislation.

3. The Scottish Environment Protection Agency ²

3.1 SEPA is the public body responsible for environmental protection in Scotland. Its main aim is:

"to provide an efficient and integrated environmental protection system for Scotland that will both improve the environment and contribute to Scottish Ministers' goal of sustainable development".

3.2 SEPA was established under the terms of the Environment Act 1995 as a non-departmental public body (NDPB) that is accountable to Ministers and, through them, to the Scottish Parliament. It became fully operational on 1 April 1996. It assumed, and brought together, the functions formerly exercised by the River Purification Boards, Her Majesty's Industrial Pollution Inspectorate and the waste regulation and certain air pollution powers held by Scotland's district and islands' councils.

3.3 SEPA is one of the largest NDPBs in Scotland. It employs over 850 people in 22 offices across Scotland. Its functions include the regulation of:

i. potential pollution of natural waters and the air;
ii. the storage, transportation and disposal of controlled waste;
iii. the keeping and disposal of radioactive materials; and
iv. operating a flood warning network.

3.4 SEPA also has a broader duty to improve the Scottish environment. In order to do this, it provides extensive guidance and advice to many of the organisations that it regulates and works with others to ensure improvements in the environment. In addition, the Water Environment and Water Services (Scotland) Bill, currently before the Scottish Parliament, provides for additional functions to be conferred on SEPA.

3.5 A Board, appointed by Ministers, and currently chaired by Mr Ken Collins, is responsible for determining SEPA's strategic direction. In addition, SEPA has three regional Boards (covering the East, West and North of Scotland), the chairmen of which are members of the main Board. These regional Boards advise the main Board on environmental issues in their respective areas.

3.6 The responsibility for the day-to-day management of SEPA lies with the chief executive, Ms Patricia Henton. In April 2001, SEPA moved away from its original regionally-based structure to a functional structure of four directorates:

i. Strategic Planning;
ii. Operations;
iii. Public Affairs and Corporate Communications; and
iv. Finance and Corporate Support.

Together with the chief executive, the heads of these directorates constitute SEPA's corporate management team.

3.7 SEPA has two sources of income from which to meet its costs (see below):
i. public expenditure in the form of grant in aid from the Scottish Executive.
ii. fee income from charges levied on those that SEPA regulates.

* From 12.10.95

3.8 SEPA set itself a suite of outcome objectives which contribute to its main aim (see paragraph 8). These objectives are:

i. providing an excellent environmental service for the people of Scotland: regulation and the environment;
ii. improving sustainable use of natural resources by minimising waste, recovering value and ensuring best management of disposal;
iii. maintaining and restoring all water environments;
iv. ensuring good air quality;
v. promoting respect for the environment in Scotland; and
vi. creating the environmental framework for the economic well-being of Scotland.

3.9 SEPA's key targets for 2002-03 and 2003-4 are set out in its Corporate Plan and are:

* RIMNET: Radioactive Incident Monitoring Network

4. The Consultation Questions

4.1 In conducting the review, we need to gather evidence about various aspects of SEPA's functions and performance. In order to assist us in that exercise and to allow those with an interest to contribute to the review we have identified 21 key questions. They reflect the terms of reference and discussions at a seminar on 17 June 2002 for a representative cross section of those affected by or interested in the work of SEPA. (A list of those invited to the seminar is attached at Annex B.)

4.2 Your views and comments on some, or all, of the questions below are invited. It would be very helpful if you could provide evidence or examples to support any points you wish to make in response to the questions. In addition, it would be valuable if you could specify your name and, where appropriate, the name of your organisation and the nature of your interaction with SEPA in your response. Your responses will be made available publicly unless you ask for them to remain confidential.

4.3 SEPA was established in 1996 to deliver an integrated system of environmental protection and its main aim was defined as being "to provide an efficient and integrated environmental protection system for Scotland which will both improve the environment and contribute to Scottish Ministers' goal of sustainable development".

Q1: How do you rate SEPA's performance in delivering its main aim of providing an efficient, integrated system of environmental protection?

4.4 SEPA's main aim challenges it to contribute to sustainable development and the Scottish Executive has issued statutory guidance to SEPA that outlines its role in this area ( see Annex C).

Q2: How do you rate SEPA's performance in responding to the Executive's guidance on sustainable development?

4.5 SEPA's statutory responsibility is to act as an environmental regulator. However, it also acts as a champion for broader environmental issues in order to raise awareness and to support its regulatory function.

Q3: What do you think SEPA should be doing in its role as environmental champion and how effective do you think it has been in this role?

Q4: How do you think SEPA should maintain its dual roles of environmental regulator and environmental champion?

4.6 The Scottish Executive determines environmental policies and priorities. SEPA is responsible for the execution of some of these. Therefore the relationship between SEPA and its sponsor department in the Environment and Rural Affairs Department of the Scottish Executive is critical. As a part of this relationship, the Scottish Executive frequently draws on SEPA's skills and experience to ensure that environmental policy and legislation is technically and scientifically credible and enforceable under current legislation. The review will explore the efficacy of this relationship to assess whether there are clear lines of accountability, responsibility and communication.

Q5: Are there any ways in which you think that the respective environmental protection responsibilities of the Scottish Executive and SEPA could be made clearer?

Q6: Do you think that SEPA's role as an advisor to the Scottish Executive in the development of environmental policy is appropriate?

4.7 The majority of modern environmental legislation originates from European Union directives or international agreements. The United Kingdom's Department of Environment, Food and Rural Affairs has the UK policy lead in international negotiations on environmental policy. The Scottish Executive actively contributes to the development of the UK position and SEPA, as an expert in environmental policy, advises the Scottish Executive to ensure that EU legislation and international obligations are transposed effectively and proportionately into Scottish law.

Q7: What should SEPA do to ensure that it can provide the best advice on international environment policy to the Scottish Executive?

4.8 Environmental protection is a complex and technical area and SEPA requires a diverse range of skills and expertise in order to perform its functions effectively. Environmental legislation is continuously evolving in order to address complex issues such as diffuse pollution. In the future, addressing such issues may require markedly different skills and approaches from more traditional environmental regulation.

Q8: Are there any ways in which SEPA's organisational structure, skills and expertise could be altered to help it perform its existing regulatory functions more effectively and to meet future environment protection needs?

4.9 SEPA is not alone in having responsibility for protecting the environment. A wide range of other bodies (e.g. local authorities, the Health and Safety Executive, Nuclear Industries Inspectorate, the Fisheries Research Service and Scottish Natural Heritage) share that responsibility.

Q9: In your view, is the allocation of responsibilities between SEPA and other bodies for protecting the environment clear and effective?

Q10: Do you think that there are ways in which SEPA's relationship with other regulatory bodies could be developed in the interests of protecting the environment more effectively?

4.10 It is important for the review to assess the quality of service that SEPA provides to all those who for whatever reason need to come into contact with it.

Q11: In your opinion does SEPA provide a fair, efficient, proportionate and consistent service to regulated bodies?

Q12: In your experience is SEPA accessible to those wishing to make contact with it?

Q13: In your experience of SEPA, do you think it is open and transparent?

Q14: Do you think SEPA responds effectively to the needs of local communities and what role should SEPA's local offices and regional boards have in ensuring that the interests of communities across Scotland are properly taken into account by SEPA?

4.11 SEPA operates a number of environmental licensing systems under a wide range of regulatory regimes. The review will look at the scope for SEPA to improve environmental licensing, while ensuring that it retains and if possible improves the effectiveness with which it protects the environment.

Q15: In what ways do you think the efficiency of the SEPA's existing system of environmental licensing could be improved, while enhancing environment protection?

4.12 SEPA is steadily extending the use of risk assessment to guide the level of regulatory activity to be deployed in particular circumstances. The review will consider whether there is any evidence available regarding the success of such approaches in focusing regulatory action and the burden of regulatory costs on operations that pose a high risk for the environment. The review will assess the scope that exists for improving SEPA's use of risk assessment and of cost benefit analysis to achieve environmental objectives efficiently, and also to prioritise environmental problems.

4.13 SEPA allows some operators to conduct self-monitoring of emissions with regular audit checks by SEPA. This reduces the level of regulatory activity whilst in theory encouraging operators to take more responsibility for their actions. The review will consider whether self-monitoring has been a success and look at whether it can be expanded into other areas of regulation.

Q16: In what ways do you think SEPA should adapt its regulatory activities in the interests of enhancing and protecting the environment more effectively?

4.14 At present, SEPA derives almost half its income from charges levied on those that it regulates. The other half of its income comes from grant-in-aid from the Scottish Executive. The review will consider the general principles that underpin SEPA's charging schemes and the impact that they have on the regulated sector. It will also consider how SEPA's charges compare with those set by the Environment Agency for similar services in England and Wales.

4.15 At present, SEPA does not charge for the costs of those of its activities that support its regulatory activity (e.g. guidance on policy development, environmental monitoring), nor does it incorporate incentives into charging schemes to reward best environmental practice.

Q17: How do you think SEPA's charging schemes should be structured in order to guarantee effective environmental protection without placing an undue burden on the regulated sector or the taxpayer?

Q18: In your experience, is there any inconsistency between SEPA's charges and those set by the Environment Agency in England and Wales?

4.18 SEPA has the ability to refer breaches of environmental legislation to Procurators Fiscal. The review will examine how SEPA decides whether or not to present evidence to the Procurator Fiscal and the systems that SEPA has for preparing such evidence. The review will consider the effectiveness of prosecution as a tool in securing environmental protection.

Q19: Do you think that prosecutions for breaches of environmental legislation provide an effective means of ensuring environmental protection?

Q20: Do you think that SEPA should have powers to enforce fixed penalties for certain breaches of environmental legislation?

4.19 In conjunction with Audit Scotland's report ³, the review will consider SEPA's efficiency as a business (as distinct from its environmental performance) and how any efficiency savings have been re-deployed. Many organisations have generated significant efficiencies or improved the service they provide to their customers by using new technology and this is a key part of the Modernising Government agenda.

Q21: In your view is SEPA making best use of technology to improve efficiency, effectiveness and service provision?

4.20 In its recently published corporate plan for 2002-03, SEPA shifted the focus in assessing its performance from activity measurement to assessment of environmental outcomes. In addition to the areas identified above, the review will consider, in co-ordination with existing work by Audit Scotland, the overall effectiveness of SEPA's corporate planning systems. It will also assess the steps being taken by SEPA to align its budget to environmental outcomes.

5. Further Consultation Opportunities

5.1 We have attempted to identify a wide range of interested groups and bodies for participation in this review. A full list of those to whom copies of this paper are being sent is attached at Annex D. Further copies of the paper are available on the Scottish Executive website ( http://www.scotland.gov.uk) and on request. If there is anyone else who wants to receive a copy of the paper, please direct them to the website, let us know, or ask them to contact us directly.

5.2 We intend to supplement the written evidence gathered in response to the questions with a series of meetings to be held with interested groups and individuals. This will include meetings with SEPA staff and their representatives; SEPA's main and regional board members; SEPA management; other bodies with environment protection functions; and other key stakeholders.

5.3 We also propose holding a number of seminars for particular sectors and groups. These will be held at a number of venues across Scotland during September and October. The provisional programme for these seminars is:

i. regulated industries [Glasgow];
ii. agriculture [Dumfries];
iii. aquaculture [Inverness];
iv. local authorities and community groups [Edinburgh]; and
v. non-governmental organisations [Perth]

If you wish to participate in one of these events, please inform us of this as soon as possible, indicating which of the groups you wish to participate in. Further information about the seminars will also be provided on the Scottish Executive website during August.

5.4 We can be contacted at SEPA PFMR Team, Scottish Executive Environment and Rural Affairs Department, Area 1-J, Victoria Quay, Edinburgh, EH6 6QQ or at separeview@scotland.gsi.gov.uk.

ANNEX A

Sarah Boyack (Edinburgh Central) (Lab): To ask the Scottish Executive what the terms of reference will be of the policy and financial management review of the Scottish Environment Protection Agency.

Allan Wilson: The Executive is committed to ensuring that each public body is subject to a regular policy and financial management review. A review of the Scottish Environment Protection Agency (SEPA) will start in June 2002. The terms of reference for the review will be:

To examine the role and functions of the Scottish Environment Protection Agency and the effectiveness and efficiency with which these functions are carried out.

The review will:

• consider how effectively SEPA has performed since it was established and seek the views of a range of stakeholders on its performance;
• consider how well SEPA responds to the policies and priorities of the Scottish ministers and if the level of delegation to SEPA from the Scottish Executive is sufficient and appropriate;
• examine the role of SEPA in relation to other bodies with responsibilities for environmental protection and regulation;
• identify ways of improving the service that SEPA provides to local communities and regulated organisations;
• examine the policies and practices of SEPA in relation to the charges it levies for its regulatory service;
• look at ways of improving the system of environmental permits and emissions monitoring, and
• identify the key issues that need to be addressed to allow SEPA to meet the challenges posed by the shifting focus of environmental legislation.

The review will be expected to make recommendations to the Scottish ministers in all of the key areas outlined above.

The review will be informed by other relevant reviews, in particular the recent quinquennial review of the Environment Agency in England and Wales and the December 2000 Audit Scotland report A Measure of Protection. These terms of reference take account of the outcome of the 2001 Public Bodies Review, which concluded that there was no fundamental change needed to the functions and structure of SEPA. The Public Bodies Review made cross-cutting recommendations relevant to all public bodies; the implementation of these recommendations in relation to SEPA will be considered as part of the review. As an essential part of the review process, officials will be consulting widely with interested parties. It is intended to hold a stakeholder event early in the review to help define the detailed scope and identify the key questions to be answered in the review, within the broad terms of reference.

ANNEX B
INVITEES TO 17 JUNE 2002 SEMINAR

Akzo Nobel Diosynth
Alcan Chemicals Europe
Association of British Pharmaceutical Industries
Association of Scottish Shellfish Growers
AstraZeneca
Audit Scotland
Babcock Rosyth
Blue Circle
BP Grangemouth
British Energy
British Foundries Association
British Plastics Federation
British Recovered Metals
CBI Scotland
Chamber of Commerce
Chartered Institution of Water &
Environmental Management
Chemicals Industries Association
Convention of Scottish Local Authorities
Corus
Crown Estate Office
Department for Environment, Food & Rural Affairs
Department of the Environment, Northern Ireland
Dunstaffnage Marine Laboratory
Engineering Employers Federation
Envirocentre Scotland
Environment & Heritage Services Northern Ireland
Environment Agency
Enviros Aspinwall
ERM
Exxon Mossmorran
Federation of Small Businesses
Fisheries Research Services
Food & Drink Federation
Friends of the Earth Scotland
GE Plastics ABS
GlaxoSmithKline
Greenpeace
Guinness UDV
Health & Safety Executive
Highlands & Islands Enterprise
Institute of Chemical Engineers
Institute of Directors (Scotland)
Institute of Environmental Management & Assessment
Institute of Waste Management
Law Society of Scotland
Maritime & Coastguard Agency
National Assembly for Wales
National Association of Waste Disposal Contractors
National Farmers Union (Scotland)
National Society for Clean Air
Nuclear Installations Inspectorate
Papermills Environment Group in Scotland
Radioactive Waste Management Advisory Committee
Roche
Royal Environmental Health Institute of Scotland
Scottish & Southern Energy
Scottish Centre for Infection & Environmental Health
Scottish Civic Forum
Scottish Coastal Forum
Scottish Enterprise
Scottish Environment Link
Scottish Environment Protection Agency
Scottish Environmental Services Association
Scottish Landowners Federation
Scottish Natural Heritage
Scottish Quality Salmon
Scottish Water
Scottish Water
ScottishPower
Shell UK Exploration & Production
Shetland Salmon Farming
SNIFFER
Sustainable Scotland Network
The Forum of Private Businesses in Scotland
The Malt Distillers Association of Scotland
The Royal Town Planning Institute
The Scotch Whisky Association
Transport & Environment Committee
UK Petroleum Industry Association
UKAEA
UNISON
Water Industry Commissioner for Scotland
WWF Scotland

ANNEX C
SEPA AND SUSTAINABLE DEVELOPMENT

This document provides the guidance referred to in section 3] of the Environment Act 1995, which requires the Secretary of State to give the Scottish Environment Protection Agency (SEPA) guidance on its aims and objectives and on the contribution it should make, by the performance of its functions, towards sustainable development.

Statutory Powers

1. Under Section 31 of the Environment Act 1995:

"the Secretary of State shall from time to time give guidance to SEPA with respect to aims and objectives which he considers it appropriate for SEPA to pursue in the performance of its functions."

The guidance:

"must include guidance with respect to the contribution which, having regard to SEPA 's responsibilities and resources, the Secretary of State considers it appropriate for SEPA to make, by the performance of its functions, towards the objective of attaining the objective of sustainable development."

In performing its functions, SEPA shall have regard to such guidance.

2. The following is guidance given under these provisions.

3. In this guidance "regulated organisations" means those organisations, bodies and individuals which are subject to regulation by SEPA.

THE AIMS AND OBJECTIVES OF SEPA

4. The Secretary of State has decided that the principal aim of SEPA shall be:

"to provide an efficient and integrated environmental protection system for Scotland, which will both improve the environment and contribute to the Government 's goal of sustainable development."

5. This principal aim is subject to the provisions of the Environment Act 1995, including section 39 in relation to having regard to the likely costs and benefits in exercising its powers, and to any other enactment under which SEPA may operate.

6. The Secretary of State has decided that the principal objectives of SEPA shall be to:

• adopt, across all its functions, an integrated approach to environmental protection and enhancement, which considers impacts of substances and activities on all environmental media and on natural resources;
• work with all relevant sectors of society, including regulated organisations, to develop approaches which deliver environmental requirements and goals without imposing excessive costs (in relation to benefits gained) on regulated organisations and society as a whole.
• adopt clear and effective procedures for serving its customers, including developing single points of contact through which regulated organisations can deal with SEPA;
• operate to high professional standards, based on sound science, information and analysis of the environment and of processes which affect it;
• organise its activities in ways which reflect good environmental and management practice and provide value for money for those who pay its charges and taxpayers as a whole;
• provide clear and readily available advice and information on its work; and
• develop a close and responsive relationship with the public, local authorities and other representatives of local communities, and regulated organisations.

CONTRIBUTION TO ACHIEVING SUSTAINABLE DEVELOPMENT

7. This section contains the guidance, which the Secretary of State is required to include in any guidance he issues under section 31(1) on the contribution he considers it appropriate for SEPA to make, by the performance of its functions, towards attaining the objective of achieving sustainable development.

8. SEPA needs to take a holistic approach to the protection and enhancement of the environment. It should therefore strive through its actions to optimise benefit to the environment as a whole, taking proper account of all likely costs and benefits. Where practicable and permissible, it should carry out its various functions - whether relating to the environmental media of air, land or water - so as to take account of the impacts of pollutants from different sources across the different media or within any medium, and the interactions of pollutants from different sources. Where practicable and permissible, the Agency should seek to exercise its functions in combination so as to contribute to sustainable development.

9. Because it needs to take a long term perspective in considering sustainable development SEPA should seek to take properly into account any longer term implications and effects, particularly those which appear likely to be irreversible, reversible only at high cost over a long timescale or which would raise issues of inter-generational equity.

10. Conserving and where practicable enhancing biodiversity and protecting the natural heritage is an essential element of sustainable development. When considering proposals affecting areas which are important for biodiversity or nature conservation, the Agency should pay particular attention to its statutory obligations with respect to conservation. The need to protect species habitats and ecosystems is in accordance with Government policy and the obligations of the Biodiversity Convention and other international nature conservation laws and agreements. This is true for species protected by law, sites protected by official designation - such as Sites of Special Scientific Interest, Special Protection Areas, Special Areas of Conservation and Ramsar sites - and for those non-designated sites which are nevertheless important for nature conservation.

11. Another essential element of sustainable development is protecting the global atmosphere. SEPA should have regard to the Government's commitments under the UN Framework Convention on Climate Change on reducing emissions of greenhouse gases, and under the Montreal Protocol on limiting the use of ozone depleting substances.

12. In the areas for which SEPA is responsible there will be considerable scope for reconciling the needs of the environment and those of development by regulated organisations adopting improved technologies and management techniques as an integral part of their industrial and commercial investment. The Agency should therefore where possible discharge its regulatory functions in partnership with regulated organisations in ways which maximise the scope for cost-effective investment in such technologies and techniques. In particular it should seek to take advantage of companies' planned investment cycles where this can be done within the Agency's overall timetables for meeting environmental standards. In general, the Agency should seek:

• to establish clear and consistent policy parameters so that regulated organisations can plan for the future;
• to encourage regulated organisations to adopt plans and management techniques - such as those envisaged in BS 7750 , ISO 14001 and the EU EcoManagement and Audit Scheme - to enable them to meet the policy parameters referred to above and to seek innovative ways of meeting environmental objectives. In doing so it should bear in mind that different approaches may be appropriate in different business according to their size and organisation;
• to encourage regulated organisations fully to exploit the potential for environmental initiatives to result in cost savings, thus enhancing their own and the UK's competitive position;
• to encourage regulated organisations to take voluntary action to improve their environmental performance beyond regulatory requirements, where cost effective, for example by co-operating with business organisations such as the Advisory Committee on Business and the Environment and the CBI; and
• to encourage knowledge and understanding, particularly in regulated organisations, of best available techniques not entailing excessive costs for the prevention and minimisation of pollution, including the efficient use of resources, such as energy, and the minimisation of waste.

13. Achieving sustainable development will involve contributions from many different groups in society - such as local communities working towards Local Agenda 21. How the Agency carries out its functions will affect these wider developments. So it should strive to develop close and responsive relationships with the public, local authorities and other representatives of local communities, regulated organisations and public bodies with environmental responsibilities. It should also strive to work in partnership with all such groups.

14. High quality information and advice on the environment is an important element in taking forward strategies for sustainable development. The Agency should therefore strive within its areas of responsibility:

• to become a recognised centre of knowledge and expertise; and
• to provide and promulgate clear and readily accessible advice and information on its work and on best environmental practice.

ANNEX D
LIST OF CONSULTEES

Aberdeen City Council
Aberdeenshire Council
Action of Churches Together in Scotland
Akso Nobel
Alcan
Allied Distillers
Anglers Clearwater Association
Angus Council
Argyll & Bute Council
Association for the Preservation of Rural Scotland
Association of British Insurers
Association of British Pharmaceutical Industries
Association of Conservation Officers
Association of Environmental Consultancies
Association of Port Health Authorities
Association of Salmon Fishery Boards
Association of Salmon Fishery Boards
Association of Scottish Chambers of Commerce
Association of Scottish Community Councils
Association of Scottish Shellfish Growers
Association of Scottish Stillwater Fishery Managers
Association of West Coast Fisheries Trusts
AstraZeneca
Atlantic Salmon Trust
Babcock Rosyth
BIFFA Waste Services Ltd
Blairingone & Saline Action Group
BP
British Energy
British Foundries Association
British Marine Finfish Association
British Medical Association
British Nuclear Fuels Limited
British Oil Spill Control Association
British Plastics Federation
British Recovered Metals
British Trout Association/Scot Trout
British Waterways
Carnie Consultancy Fisheries & River Engineering
CBI Scotland
Central Scotland Countryside Trust
Centre for Environment and Business in Scotland
Centre for Environmental Management & Planning
Chartered Institution of Water and Environmental Management
Chemical Industries Association
Citizens Advice Scotland
City of Edinburgh Council
City of Glasgow Council
Clackmannanshire Council
Coal Authority
Comhairle nan Eilean Siar
Convention of Scottish Local Authorities
Crofters Commission
Crown Estate Office
Deeside Water Company Ltd
Department for Environment, Food and Rural Affairs
Department of the Environment, Northern Ireland
Disability Rights Commission
Drinking Water Quality Regulator
Dumfries & Galloway Council
Dundee City Council
East Ayrshire Council
East Dunbartonshire Council
East Lothian Council
East Renfrewshire Council
EnviroCentre
Environment Agency
Environment and Heritage Service Northern Ireland
Environmental Data Services Ltd
Environmental Industries Commission
Environmental Services Association
Enviros Aspinwall
Equal Opportunities Commission
ERM
Evangelical Alliance (Scotland)
Exxon
Falkirk Council
Farming and Wildlife Advisory Group
Federation of Highland Angling Clubs & Associations
Federation of Small Businesses
Fife Council
Fisheries Research Services
Fisheries Research Services
Food Standards Agency Scotland
Forestry Commission
Forum for the Future
Forum of Private Businesses in Scotland
Forward Scotland
Friends of the Earth Scotland
General Assembly
GlaxoSmithKline
Green Alliance
Greenpeace
Guinness UDV
Health and Safety Executive
Highland Council
Highlands and Islands Enterprise
Historic Scotland
ICI
Innogy
Institute for European Environmental Policy
Institute of Chemical Engineers
Institute of Directors (Scotland)
Institute of Environmental Management and Assessment
Institute of Fisheries Management
Institute of Waste Management
Institution of Civil Engineers
Inverclyde Council
John Muir Trust
Keep Scotland Beautiful
Lafarge Cement United Kingdom
Law Society of Scotland
Macaulay Land Use Research Institute
Malt Distillers Association of Scotland
Maritime and Coastguard Agency
Members of the Scottish Parliament
Midlothian Council
Moray Council
National Assembly for Wales
National Association of Waste Disposal
National Farmers Union (Scotland)
National Radiological Protection Board Scotland
National Society for Clean Air
National Trust for Scotland
Natural Environment Research Council
North Atlantic Fisheries College
North Ayrshire Council
North Lanarkshire Council
Nuclear Installations Inspectorate
Ordnance Survey
Orkney Islands Council
Papermills Environment Group in Scotland
Perth & Kinross Council
Public Health Institute Of Scotland
Radioactive Waste Management Advisory Committee
Railtrack Scotland
Recycling Advisory Group Scotland
Remade Scotland
Renfrewshire Council
River Don Liaison Committee
River Earn Liaison Committee
River Leven Trust
River Lunan Liaison Committee
River Tay Liaison Committee
River Tummel Liaison Committee
River Tweed Commissioners
Roche Products
Royal Academy of Engineering
Royal Commission on Environmental Pollution
Royal Environmental Health Institute of Scotland
Royal Institute of Chartered Surveyors in Scotland
Royal Town Planning Institute in Scotland
RSPB Scotland
Rural Forum Scotland
Salmon & Trout Association (Scotland)
Salmon Net Fishing Association of Scotland
Scotch Malt Whisky Society
Scotch Whisky Association
Scottish Agricultural College
Scottish and Southern Energy plc
Scottish Anglers National Association
Scottish Association of Marine Science
Scottish Borders Council
Scottish Centre for Infection and Environmental Health
Scottish Chambers of Commerce
Scottish Churches Parliamentary Office
Scottish Civic Forum
Scottish Coastal Forum
Scottish Conservative and Unionist Party
Scottish Consumer Council
Scottish Council for Development and Industry
Scottish Crofting Foundation
Scottish Crop Research Institute
Scottish Enterprise
Scottish Environment LINK
Scottish Environment Protection Agency
Scottish Environmental Education Council
Scottish Environmental Industries Association
Scottish Environmental Services Association
Scottish Federation of Coarse Anglers
Scottish Fishermen's Federation
Scottish Food and Drink Federation
Scottish Green Party
Scottish Labour Party
Scottish Landowners Federation
Scottish Law Commission
Scottish Liberal Democrats
Scottish Members of Parliament
Scottish National Party
Scottish Natural Heritage
Scottish Pharmaceutical Federation
Scottish Quality Salmon
Scottish Scenic Trust
Scottish Socialist Party
Scottish Trades Union Congress
Scottish Waste Awareness Group
Scottish Water
Scottish Wildlife Trust
ScottishPower
Sea Fish Industry Authority
Seafish Aquaculture
Shanks
Shell
Shell UK Exploration & Production
Shetland Islands Council
Shetland Salmon Farmers Association
Shetland Salmon Farming
SNIFFER
Snowie's
Society of Chemical Industry
Society of Directors of Environmental Health
South Ayrshire Council
South Lanarkshire Council
sportscotland
Stirling Council
Surfers Against Sewage
Sustainable Development Commission
Sustainable Scotland Network
Town and Country Planning Association
UK Environmental Law Association
UK Offshore Operations Association
UK Petroleum Industry Association
UKAEA
UNISON
Valpack
Visitscotland
Wastepack UK Ltd
Water Industry Commissioner for Scotland
Water UK
West Dunbartonshire Council
West Lothian Council
Wildfowl and Wetlands Trust
WWF Scotland

Small changes in the way we perform everyday tasks can have huge impacts on Scotland's environment.

Walking short distances rather than using the car, or being careful not to overfill the kettle are just two positive steps we can all take.

This butterfly represents the beauty and fragility of Scotland's environment. The motif will be utilised extensively by the Scottish Executive and its partners in their efforts to persuade people they can do a little to change a lot.

1. Public Bodies: Proposals for Change. Scottish Executive. June 2001.
2. Further background information about SEPA and many of its publications are available on the SEPA website (http://www.sepa.org.uk/) or from SEPA, Erskine Court, Castle Business Park, Stirling, FK9 4TR.
3. A Measure of Protection: A baseline report on preformance measurement in the Scottish Environment Protection Agency. Audit Scotland, December 2000.