National Stakeholder Forum - follow-up to
meeting of 16 November
1. Introduction
At our meeting on 16 November we presented a number of
proposals to you for consideration. We have now developed
those proposals further and would welcome your views on the
papers attached:
· Revised proposals for Controlled Activities
Regulations
· Draft general binding rules
· Draft regulatory impact assessment
2. Revised proposals for Controlled
Activities Regulations
This paper sets out in more detail the way the Executive
envisages the Regulations will deal with the different
activities and the different tiers of control. We would
welcome any comments on these general principles by
22 December.
Our solicitors are currently preparing a revised draft
of the Regulations and we aim to issue these as soon as
possible. We plan to hold a workshop on
1 February, at Victoria Quay, to discuss
the detail of the revisions, and would welcome your
participation at that workshop. An invitation with further
details will be issued nearer the time but I would be
grateful if you could keep this date free meantime.
3. Draft general binding rules
Revised proposals for the general binding rules are
attached. These are much simpler than previous drafts,
reflecting the many comments made in response to our
consultation. We would welcome any detailed comments by
22 December.
4. Draft regulatory impact
assessment
We welcomed your comments on the draft RIA presented at
the NSF meeting, and now attach a further draft for more
detailed comments. This draft does not as yet include the
costs to SEPA or the expected numbers of applications under
the different regulatory regimes. These are currently under
consultation with SEPA.
As part of the Regulatory Impact Assessment, we are
required to assess the impact on businesses of the
Controlled Activity Regulations. In order to give a well
informed picture, we would welcome your help in estimating
the likely costs that businesses will incur. In particular
we are interested in the costs to business
beyond the fees from SEPA, which may
involve the following costs:
· completing application forms
· environmental reporting
· professional fees, for example from consultant
work or legal fees
· metering/measuring equipment which is required
to monitor abstraction/impoundment volumes etc
The RIA in England on the Draft Water Bill estimated
various ranges for each of these compliance costs, which
may provide a starting point to this exercise
http://www.defra.gov.uk/environment/consult/draftwbill/pdf/wtr_appr.pdf.
We would welcome your general comments on the draft, but
more specifically would welcome any assistance you can
provide in estimating the above costs, by
31 January.
Thank you for your continued contribution to this
process. If you would like to discuss any of these issues
please do not hesitate to contact me.
Joyce Carr
Scottish Executive
2 December 2004