Scottish Government

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ACKNOWLEDGEMENTS

1. The Scottish Executive is grateful to all those who responded to its consultative draft revised guidance on opencast coal ( SPP 16). This summary report highlights the main issues raised by respondents and gives the Executive's response to these issues. A detailed summary of the amendments made to the draft as a result of the comments received is at Annex A. The finalised version of SPP 16 is available on the Executive's website at www.scotland.gov.uk/Topics/Planning-Building/Planning/15243/1415. A paper copy of SPP 16 can be obtained by telephoning 0131 244 7543.

EXECUTIVE SUMMARY

2. The consultation period closed on 3 December 2004 although a number of responses were received after the closing date. These were all taken into account in finalising the guidance. The Communities Committee of the Scottish Parliament subsequently took evidence from all the main stakeholders on the consultation paper on 2 and 9 March 2005 and the issues raised during these discussions have also been taken on board when finalising the SPP.

3. All the main stakeholders were represented in the responses submitted on the consultation paper. The unanimous view of the industry, and those employed within the industry, including trade unions, was that the Executive's proposals would have significant consequences for the future viability of the opencast coal industry in Scotland. Local authority respondents were generally content with what was being proposed, although clarification on a number of detailed points was often sought. Community and environmental interests also generally welcomed the proposals although many felt that the policies in draft SPP 16 did not go far enough in specific areas.

4. The main concerns of industry interests were in relation to the proposed "presumption against" at paragraph 8 of the draft; the proposed changes to separation distances at paragraph 11; and the proposed new definition of communities at paragraph 12. These concerns are considered further below. The industry also felt that the tone of the document was negative although most of the specific criticisms related to wording carried forward from NPPG 16.

5. The Executive has considered all the responses very carefully and, where appropriate, have amended the draft. The "presumption against" remains in place. The Executive take the view that this is not a major change in policy. This view is supported by independent research into the operation and effectiveness of existing policies (this can be viewed at www.scottishexecutive.gov.uk/library5/planning/oenppg16-00.asp); the responses of Scottish planning authorities to the consultation paper; and the conclusions of the Communities Committee following its consideration of oral evidence presented by all the main stakeholders. These all generally agree that the "presumption against" is policy neutral and should not make it any easier or more difficult for developers to obtain planning permission. However, the adoption of this wording should provide significant reassurances to Scottish communities that similar planning frameworks for considering opencast applications are in place north and south of the Border. The impact of the "presumption against" will be monitored.

BACKGROUND

6. Draft SPP 16 was issued for public consultation on 2 September 2004. The draft was distributed to all local authorities and opencast operators in Scotland, a wide range of public bodies, non governmental organisations ( NGOs), professional bodies, industry and business interests and members of the public. The document was also made available on the planning page of the Scottish Executive website and further copies were sent out to bodies and individuals on request. A copy of the consultation paper, including the initial distribution list, can be viewed at www.scotland.gov.uk/consultations/planning/occd-00.asp. Paper copies of the consultation paper can be obtained by telephoning 0131 244 7543.

7. Draft SPP 16 set out the Executive's proposed new national planning policy framework for the working of opencast coal. The draft updated, revised and clarified the contents of National Planning Policy Guideline 16: Opencast Coal and Related Minerals to reflect developments in policy, legislation, etc and also drew on practical experience of implementing earlier policies. In doing so, account was taken of earlier research on the operation and effectiveness of NPPG 16. This endorsed NPPG 16's policy objectives and made recommendations that were intended to build on its strengths. Most of these recommendations were implemented when preparing draft SPP 16. The main changes were:

RESPONSES RECEIVED

8. The Executive received 294 responses to draft SPP16. Responses were received from a wide range of interested parties and can be categorised as follows:

9. A full list of respondents who have agreed to make their names available can be found at Annex B. Requests from respondents not to make their comments public have been respected. Although names and addresses are withheld, the views expressed are still taken into account in preparing this Summary.

10. The Executive has analysed all the responses received and, where appropriate, made amendments to the guidelines in the light of the comments made. This overview summarises the key issues raised and is not intended to provide a comprehensive report on every comment received. Copies of individual responses can be viewed at http://www.scotland.gov.uk/library5/planning/spp16cr-00.asp or at the Scottish Executive Library, Saughton House, Broomhouse Drive, Edinburgh EH11 3XD. The Executive's digest of comments made by individual respondents is also available at http://www.scotland.gov.uk/library5/planning/spp16dcr-00.asp.

KEY ISSUES EMERGING FROM RESPONSES

PART 1: GENERAL RESPONSES

11. Around 75% of all responses received were from individuals with employment links to the opencast industry who were concerned about the likely impacts of a "presumption against" in Scotland. Comparisons were made with the situation in England and it was felt that a similar approach would lead to the loss of jobs in Scotland, both within the industry and with associated suppliers. This would affect families and local communities. Many commented that the industry provides much needed employment in areas where there were few alternatives; that there were benefits in coal being sourced locally and that it is for the planning system to provide a framework for the industry to operate. Most of these responses were made using proforma letters.

PART II: COMMENTS ON DRAFT SPP 16

Summary

12. The summary in the draft SPP is intended to provide an overview of the policy but not to express the policy itself. Various issues were raised in relation to the original text, particularly by the industry which generally felt that the importance of indigenous coal was understated and that the industry was being portrayed in a negative light when compared with other extractive industries. Responses from other extractive industries generally supported existing wording.

INTRODUCTION (paragraph 1)

13. This paragraph set out the context in which the review was being undertaken and confirmed that the proposed policies should apply equally to the extraction of other minerals that occur in association with coal extraction. Limited comment was made on this paragraph, mainly relating to the need to make explicit that the SPP only applies to opencast coal and to those minerals that occur in association with coal extraction.

POLICY CONTEXT

SPP objectives (paragraph 2)

14. This paragraph confirmed that the wider policy objectives of the Scottish Executive should be applied to opencast coal proposals. It was suggested that specific reference should be made to Environmental Justice.

Energy issues (paragraph 3 to 6)

15. These paragraphs set out the UK Government's energy policies and was prepared following consultation with the Department of Trade and Industry. The industry felt that the importance of indigenous coal was again understated, as was the contribution of Scottish coal to UK energy markets. Coal contributes to one third of generated capacity. This is beyond the role of meeting peak demands suggested in the paper and, as a result of competitive prices, coal burn is increasing. Coal was also reliable. The industry warned that increasing the dependence on imports would threaten security of supply and result in exporting environmental impacts/jobs to countries with less rigorous control regimes. There would also be balance of payment implications. The value of the lower-sulphur characteristics of Scottish coal was also pointed out. The SPP should also make clear that the future of Scottish coal-fired power stations is unclear. Carbon abatement technology has an important role in reducing carbon dioxide emissions.

16. No common themes were raised by other respondents although the issues highlighted included the need for a greater strategic steer; the need to refer to energy issues in planning guidance; the impact of greenhouse gas emissions; the need to ensure that impacts on communities and the environment are paramount. It was felt that the role of imports should be highlighted and that Scotland was a net exporter of energy with enough supplies to last to 2015.

Environmental justice (paragraph 7)

17. This paragraph highlighted the Scottish Ministers' commitment to environmental justice and how this should be taken into account when considering opencast coal proposals. The opencast industry made the point that concentration of existing developments had arisen as a result of the policies in NPPG 16. It was pointed out that the industry already had an environmental duty; that policies were likely to result in sterilisation of resources; that EIA determines the acceptability of proposals; and the need to reconcile the benefits to society of an opencast coal industry. It was also considered discriminatory to apply these policies solely to opencasting although the aggregates industry questioned linkages to quarrying. One respondent felt that the policies would prevent the industry from improving brownfield sites.

18. The inclusion of this policy was generally welcomed by other respondents although some felt that what was proposed did not go far enough. It was suggested that more context needed to be given and that the barriers preventing full community participation and how this should work must be addressed. The relevance of providing jobs was questioned and a number of respondents felt that the policies should do more to address the continuous economic and social deprivation endured by some communities over a number of years.

PLANNING POLICY

The general principle (Paragraph 8)

19. These paragraphs clarified what was originally meant by the "two tests" in NPPG 16 and made clear that there should be a "presumption against" developments that do not meet either of the two tests. This is clearly the most emotive issue raised in the consultation paper so it is important to place the proposal within a historical context.

20. Following the General Election in May 1997, the new Labour Government announced its intention to review national planning policies for opencast coal. The purpose of the review was to take forward pre-election commitments, the most significant being to "prohibit opencast working except where it is of benefit to the local community and local environment." Reviews took place north and south of the Border. In Scotland, the outcome of the review was National Planning Policy Guideline 16: Opencast Coal and Related Minerals (published March 1999). At the same time, Minerals Planning Guidance ( MPG) 3: Coal Mining and Colliery Spoil Disposal was published in England. Although these documents differed in drafting content, the policy intention was intended to be identical.

21. Paragraph 2 of NPPG 16 confirmed that the policy intention of the guidelines is "to ensure that full weight is given to the effect on and potential disturbance to local communities as well as other environmental considerations including nature conservation and impact on the landscape. Where a proposal would cause demonstrable and material harm, the guidance is clear that permission should not be granted except where the benefits of the development proposal to the community would outweigh the potential harm." This policy objective is the starting point for the review of NPPG 16 and one to which the Scottish Ministers remain committed.

22. The comparison between Scottish and English guidance was considered specifically in the independent research commissioned to inform the review. This was because the issue of whether Scottish guidance is as robust as MPG 3 has been raised on a number of occasions over the past five years. Most attention has focussed on whether the absence of a "presumption against" in Scotland has made it easier for operators to obtain planning permission. The Executive has always rejected such claims. The existing policy in NPPG 16 states that:

"If the proposal does not satisfy one or other of the above tests (i.e. relating to environmental acceptability and community benefits) it should be refused planning permission"

23. In England, MPG 3 states:

"The Government believes there should normally be a presumption against development unless the proposal would meet the following (i.e. almost identical) tests."

24. The difference between the two texts rests on the interpretation of "refused" and "presumption against". The independent research took the view that "there is no difference in effect between the existing terminology and a clear statement that there will normally be a presumption against". The research suggests that adoption of the "presumption against" in Scotland would "not alter the intention of Government, nor would it make it easier or more difficult for developers to obtain planning permission". A recommendation was made in the research to adopt a "presumption against" in Scotland because it "may be seen to address the concerns of those who claim that the Scottish guidance is "weaker" than its English equivalent".

25. The industry does not share this view and believes that "a presumption against" is far from "policy neutral" and would deliver a devastating blow to the industry in Scotland. Its general view was that this proposal would repeat the sharp decline in opencasting, as happened in England when a similar policy was introduced. Approvals are now virtually non-existent and this has resulted in massive consequences for the industry and its employees. Some respondents felt that there was political opposition to opencasting south of the Border and this has resulted in proposals not being properly considered. It was also felt that opencasting was being unfairly singled out and that a "presumption against" ran contrary to the fundamental principles of the planning system. Many believed that the "two tests" did not properly recognise all the benefits that opencasting brings, locally and nationally. Some took the view that the independent research was flawed as it did not look at the consequences of a presumption against in Scotland. More generally, the "presumption against" was widely linked to a massive reduction in coal production, higher electricity prices, job losses, increases in imports and a severe effect on balance of payments.

26. The views in the above paragraph, or similar concerns, were shared by around 220 respondees, mostly employees of the industry, a mining consultant, CBI Scotland, the Coal Authority, Dalgleish Associates. Christine May MSP and RMC Scotland and South East. The British Ceramic Confederation and Freightliner Heavy Haul were concerned about the impact of a "presumption against" on their industries.

27. In the local authority responses, the Scottish Society of Directors of Planning noted that "the presumption against brings Scottish policy into line with England and should help stem the perception by promoters and objectors of the industry that Scotland's policy framework is balanced in favour of opencasting." East Ayrshire Council took the view that "the revised wording and emphasis does not, however, represent any major change in the thrust or direction of the overall policy objective." Glasgow and Clyde Valley Structure Plan Joint Committee believed that the proposal was "over restrictive and would be better expressed as a support for opencast mining". South Ayrshire Council commented that "the draft SPP does not differ in intent from the existing policies in NPPG 16". South Lanarkshire Council believed that "the consultation document updates, through an amendment to the wording, rather than any change in policy direction, the principle test". West Lothian Council indicated that "the concept of a presumption against" is most appreciated and places the draft on a similar statutory footing to its equivalent south of the border." Clackmannanshire, Fife, Midlothian and North Lanarkshire Councils did not raise the "presumption against" as an issue in their responses.

28. Of the other respondents, The Brethrens Gospel Trust; ruralScotland, SNH and Upperward Against Pollution welcomed the general presumption against opencasting. Fauldhouse Against Tipping At Levenseat and Councillor Neil Findlay believed it "vital that there should be a presumption against planning permission where disbenefits outweigh benefits. This will bring Scottish planning guidelines into line with England. Recently greater production in Scotland has been seen as being a reflection on the ease which planning permission can be gained in Scotland." The East Lothian Constituency Party of the Scottish National Party, Friends of the Earth Scotland, Mining & Environment Group Ayrshire, the Royal Institute of Chartered Surveyors, SEPA, SAving Vogrie's Environment and Scotland Opposing Opencast did not highlight the "presumption against" as a specific issue although the latter produced an industry publication which claimed "while rivals in England have been chasing those elusive planning consents, Scottish Coal has been taking advantage of the more favourable circumstances north of the Border". Karen Gillon MSP believed "that there are clear criteria set out in the paragraph in relation to community benefit and employment both of which will enable opencast to continue if the case is made effectively. These are both considerations that are taken into account at the moment and should continue to be material planning considerations if the case can be made." After taking oral evidence from all the main stakeholders, the Communities Committee shared the view that this proposal was policy neutral and that "there is currently no evidence that this would lead to a decline in the industry in Scotland".

Working with communities (paragraphs 9 to 10)

29. These paragraphs set out how the Executive expect local communities to be involved at all stages of the planning process. These proposals were generally welcomed although a number of industry respondents took exception to drafting generalisations in relation to community views on opencasting and highlighted some positive community perceptions of the industry. Others supported the principles of what was proposed but were concerned about the ability of communities to participate properly due to the time involved and the knowledge required. The need to oversee community involvement was also raised as was the expected role of the planning authority since authorities have to act on the planning merits of proposals and cannot be seen to be the "mouth piece" of communities. It was pointed out that some concerns may not always be able to be addressed and that communities may not wish to become involved in proposals granted against their wishes. This can put local authorities in a difficult position since planning decisions may not necessarily reflect the views of communities.

Separation distances (paragraphs 11 to 12)

30. These paragraphs confirmed that the 500 metres separation distance should now extend from site boundaries to local communities and that it was for local authorities to determine, locally, what constituted a "community". The industry opposed both proposals. It believed that there was no objective evidence to suggest working within 500 metres was unacceptable and that separation distances were something that should be determined by Environmental Impact Assessment. The proposal would simply sterilise workable resources and make it very difficult for operators to identify future sites. It was also suggested that the proposal would result in a 500 metres no go area around all houses and that the policy may have the effect of unfairly eliminating a site where only landscaping and nature conservation works were being proposed within 500 metres of a community. One operator indicated that consent was received, without complaint, to work within 50 metres of a community.

31. Others generally welcomed the proposal although many wanted to see the separation distance either fixed at 500 metres or extended further. It was felt that overburden bunds were one of the most damaging aspects of opencasting.

32. On the proposed definition of a community, operators argue for the current "10 houses or more" definition to be maintained as this would make it difficult to find future sites. Others welcomed the proposal, although some wanted further guidance on what should constitute a community and what protection should be afforded to those that live outwith communities.

Cumulative impacts (paragraphs 13 to 14)

33. These paragraphs introduced the concept of a "cumulative impact" assessment and the distances that should be applied to such assessments. Industry responses took the view that the 5 km distance was arbitrary and should be reduced. It was felt that the only possible negative impact that would accrue at the proposed distance would relate to traffic but there would be positive impacts, such as employment. Communities may be unaware of sites this far away. Research needs to be carried out to assess the likely impact of this proposal. This policy should apply to other forms of development, such as quarries and landfill sites. The role of EIA in determining whether proposals were acceptable was also highlighted.

34. Others generally welcomed what was proposed although many sought further clarification of the terms used. It was suggested that definitions should be extended to cover other forms of development or land condition and that effects produced over time should be recognised. It was also suggested that assessments should be commissioned by planning authorities and paid for by applicants. The aggregates industry was concerned about the implications for their members. The need to clarify what was meant by "restoration" was also highlighted.

Safeguarding environmental resources

35. Paragraphs 15 to 21 set out how the natural and built heritage should be protected and how workable coal resources should be safeguarded. A number of respondents were concerned that these paragraphs only offered protection to designated sites. Various comments were made in relation to the appropriateness of green belt sites and agricultural land for opencasting. Others noted that Historic Gardens and Designated Landscapes, greenspace, woodlands, peat and sport were not mentioned in these paragraphs. On sterilisation, the industry generally felt that more thought needed to be given to ensure that resources were not sterilised unnecessarily and that coal interests should be consulted on developments on coal resources and when areas are being considered for designation.

OTHER CONSIDERATIONS

Characteristics

36. Paragraphs 22 to 29 highlighted the environmental effects that proposals should address. A number of comments were made. The main concerns related to the paragraphs relating to air quality. The industry raised particular concerns about the perception that unresolved concerns should be a material consideration and others felt that the existing knowledge base on health impacts was incomplete. Elsewhere, respondents asked for the responsibility of the various control bodies to be clarified and for SPP 16 to make clear that compliance with the environmental duty does not override the need to comply with development plans/ SPP 16.

SAFEGUARDING LOCAL COMMUNITIES AND THE ENVIRONMENT

37. Paragraphs 30 to 44 set out the requirements and considerations that should be applied to specific planning applications. The industry was particularly concerned about the presumption against further applications being approved if information submitted with the original application proved to be inaccurate. It was argued that such matters were often outwith the control of the applicant and that circumstances change over time. Elsewhere, various suggestions were made in relation to the suggested benefits and disbenefits.

REGULATING DEVELOPMENT

38. Paragraphs 45 to 57 set out how planning authorities should ensure that rigorous arrangements are in place to ensure that approved applications are properly regulated and monitored. This clearly remains a considerable concern for local communities. It was generally accepted that the existing guidance in the proposed draft needed to be supplemented by additional powers in relation to both monitoring and enforcement. However, when taking evidence, the Communities Committee were impressed by a scheme that had been put in place in Fife. Extension of these arrangements merit further consideration.

FURTHER APPLICATIONS

39. Paragraphs 58 to 60 set out arrangements for considering repeat applications. Various suggestions were made in relation to the time limits for considering repeat applications with alternative timescales suggested.

DEVELOPMENT PLANNING (paragraphs 61 to 67)

40. Respondents highlighted the importance of development planning in providing certainty to both operators and local communities. The industry raised concerns over the possibility of further coal resources being identified and the need to ensure that such sites were allowed to be worked.

NOTIFICATION OF APPLICATIONS (paragraph 68)

41. No comments were made on this paragraph although it has been amended to reflect the revised notification direction issued to accompany the publication of SPP 16.

CONCLUSIONS (paragraph 69)

42. CoalPro believed that this paragraph was a clear steer to planning authorities to reject proposals if they can find reasons to do so and that it should indicate instead that proposals should be approved unless there are reasons not to do so.

THE COAL AUTHORITY (Annex A)

43. The Coal Authority pointed out a number of structural changes that have take place within the Authority since the publication of NPPG 16.

CONCLUSION

44. The views of stakeholders continue to be highly polarised. The purpose of the policies in SPP 16 is to ensure that policies strike the right balance between the interests of local communities, the need to maintain Scotland's environment and the ability of operators to bring forward acceptable proposals. Helpful comments were made in response to the consultation paper. The contribution of the Communities Committee to the consultation process has also enabled all the relevant stakeholders to provide oral evidence in an open and independent environment. This has ensured that all the main issues have been subject to close scrutiny and debate. Concerns clearly remain about the impact of the "presumption against". The Executive will ensure that the policies in SPP 16 are monitored closely so that their impact on both local communities and employment are as intended.

ENQUIRIES

45. Enquiries about this Summary Report should be addressed to Ian Mitchell (0131 244 7062), Scottish Executive Planning Division, 2-H, Victoria Quay, Edinburgh, EH6 6QQ or (e-mail: ian.d.mitchell@scotland.gov.uk).

ANNEX A
AMENDMENTS MADE TO DRAFT SPP 16: OPENCAST COAL

ANNEX B
LIST OF RESPONDENTS

Anderson, David
Annandale, Michael
ATH Resources Ltd, Richmonds House, white Rose Way, Doncaster, DN4 5JH
Bennett, George
BLB Developments Ltd, PO Box 186, Wetherby, LS22 6UF
Bogle, Brian, 28 Grassmillees Way, Mauchline, Ayrshire, KA5 6EJ
Boyd, Robert
Brash, Ian, Farside Cottage, Tranent, EH33 2LE
Bretherens Gospel Trust, 1A King Edward Road, Bedford, MK41 9SF
British Aggregates Association, 1 Fir road, Doune, Perthshire, FK16 6HU
British Association of Colliery Management, 17 South Parade, Doncaster, DN1 2DR
British Ceramic Confederation, Federation House, Station Road, Stoke-on-Trent, ST4 2SA
Buchanan, Alastair, Old Schoolhouse, Cousland, By Dalkeith, EH21 2NZ
Burke, Tom, Sybrig House, Donibristle Industrial Park, Dunfermline, KY11 9JN
CBI Scotland, 16 Robertson Street, Glasgow, G2 8DS
Clackmannanshire Council, Lime Tree House, Castle Street, Alloa, FK10 1EX
Clarkson, James
Coal Authority, 200 Lichfield Lane, Berry Hill, Mansfield, Notts, NG18 4RG
Confederation of UK Coal Producers, Thornes Office Park, Denby Dale Road, Wakefield
Connal, R Craig QC, McGrigors, 70 Wellington Street, Glasgow, G2 6SB
Cox, Andrew, 192 Sandyford Road, Newcastle upon Tyne, NE2 1RN
Craig, John, 10 Main Street, Newbigging, Carnwath, Lanark, ML11 8LZ
Dalgleish Associates Ltd, Cathedral Square, Dunblane, FK15 0AH
Davidson, Raymond
Dunlop, Gordon
East Ayrshire Council, Council Offices, 6 Croft Street, Kilmarnock, KA1 1JB
East Lothian Constituency Association of the Scottish National Party, Innerwick, Dunbar
Falkirk Council, Abbotsford House, David's Loan, Falkirk, FK2 7YZ
Fauldhouse Against Tipping At Levenseat, 12 Earl's Place, Fauldhouse, West Lothian
Ferguson, Gerald
Fife Council, Fife House, North Street, Glenrothes, Fife, KY7 5LT
Findlay, Councillor Neil, Fauldhouse Ward, West Lothian Council
Forestry Commission Scotland, Silvan House, Edinburgh
Freightliner Heavy Haul, Aire Valley Depot, Stranglands Lane, Ferrybridge, WF11 8RA
Friends of the Earth Scotland, Lamb's house, Burgess Street, Leith, EH6 6RD
Gillies, J, 3 Argle Cresecent, Edinburgh, EH15 2QQ
Gillon, Karen MSP, The Scottish Parliament, Edinburgh, EH99 1Sp
Glasgow and Clyde Valley Structure Plan Joint Committee, 10 Killermont Street, Glasgow
Glennie, G
Good, F
Gow, John, 4 Caroline Crescent, Alva, FK12 5BT
Grosart, James, 22 Phillips Wynd, Cumnock, KA18 3BT
Hall Construction, Stotforth House, Windlestone, Rushyford, Co Durham, DL17 0NF
Hamilton, Scott, 13 Hearth Place, Cumnock, KA18 1HZ
Harper, William, 14 Broomfield Street, Netherburn
Harrington, Mark
HJ Banks and Co Ltd, Inkerman House, Bishop Auckland, Co Durham, DL13 4HG
I & H Brown, PO Box 51, Dunkeld Road, Perth, PH1 3YD
J Fenton and Sons, Blackfaulds, St Martins, Perth, PH2 6AG
Kier Mining, Tempsford Hall, Sandy, Bedfordshire, SG19 2BD
Kettles, Norman, 4 Serfs Grove, Clackmannan, FK10 4SP
Law, Teryy, 17 Manse Road, Crossgates, by Cowdenbeath, Fife
Law Society for Scotland, 26 Drumsheugh Gardens, Edinburgh, EH3 7YR
Livingstone, Marilyn MSP, Carlyle House, Carlyle Road, Kirkcaldy, KY1 1DB
Lyell, L
May, Christine MSP, Scottish Parliament, Edinburgh, EH99 1SP
McClelland, A
McMillan, J
Mining and Environment Group: Ayrshire, 8 Main Road, Waterside, by Kilmarnock
Midlothian Council, Midlothian House, Buccleuch Street, Dalkeith, EH22 1DJ
Munro, Dr John, Dower House, Backhill, Carberry, Nr Musselburgh, EH21 8QD
Murdoch, H, 4 Emrys Avenue, Cumnock, Ayrshire, KA18 1EL
Naitby, Paul, 3 Wardneuk Court, Irvine, KA11 1RH
North Lanarkshire Council, Fleming House, 2 Tryst Road, Cumbernauld, C67 1JW
Paton, A
Quarry Products Association, Park Lane House, 47 Broad Street, Glasgow, G40 2QW
RMC Scotland and North East, Tannochside Park, Uddingston, G71 5PH
Royal College of Physicians of Edinburgh, 9 Queen Street, Edinburgh, EH2 1JQ
Royal Institution of Chartered Surveyors in Scotland, 9 Manor Place, Edinburgh, EH3 7DN
Rural Scotland, 3 ^rd Floor, Gladstone's Land, 483 Lawnmarket, Edinburgh, EH1 2NT
Russell, A M, 12 Dykes Court, Darvel, KA17 ONH
SAving Vogrie's Environment, 54 Edgehead Village, Pathead, Midlothian, EH37 5RJ
Scotland Opposing Opencast, 3 Bankton Glade, Murieston, Livingston, EH54 9DG
Scottish Badgers, 13 Eddie Avenue, Brechin, DD9 6YD
Scottish Coal, Castlebridge Business Park, Gartlove, Nr Alloa, FK10 3PZ
Scottish Council for National Parks, The Barony, 2 Glebe Road, Kilbirnie, KA25 6HX
Scottish Environment Protection Agency, Erskine Court, Castle Business Park, Stirling
Scottish Health Campaigns Network, PO Box 23678, Edinburgh, EH6 4WU
Scottish Natural Heritage, 12 Hope Terrace, Edinburgh, EH9 2AS
Scottish Society of Directors of Planning, 41 Gilloch Crescent, Dumfries, DG1 4DW
Smith, David, 25 Oaktree Square, Kirkcaldy, Fife, KY11 2LL
Smith, Derek
Shetland Islands Council, Grantfield, Lerwick, ZE1 0NT
South Ayrshire Council, Burns house, Burns Statue Square, Ayr, KA7 1UT
South Lanarkshire Council, Montrose House, 154 Montrose Crescent, Hamilton, ML3 6LB
Sportscotland, Caledonia House, South Gyle, Edinburgh, EH12 9DQ
Steedman, Brian, 19 Gardner Terrace, Stoneyburn, West Lothian, EH47 8DQ
Strategic Rail Authority, 55 Victoria Street, London, SW1H 0EU
Transport & General Worker's Union, 128 Theobald's Road, Holborn, London, WC1X 8TN
Tulip, Colin, 151 Merrick Drive, Dalmellington, KA6 7TN
UK Coal Mining Ltd, Harworth Park, Blyth Road, Harworth, Doncaster, DN11 8DB
Upperward Against Pollution, 13 Main Street, Douglas, South Lanarkshire, ML11 0QW
Wagstaff, Brian, 19 Coyle Crescent, Rankinston, KA6 7HQ
Ward, G
WBB Minerals, Brookside Hall, Sandbach, Cheshire, CW11 4TF
West Lothian Council, County Buildings, Linlithgow, West Lothian, EH49 7EZ
Wilson, A B, Chesterhall House, Longniddry, East Lothian, EH32 0PQ