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SCOTTISH EXECUTIVE ENVIRONMENT GROUP

FARM WASTES AND NON-MINERAL WASTES FROM MINES AND QUARRIES
A CONSULTATION PAPER ON THE WASTE FROM MINES, QUARRIES AND AGRICULTURAL PREMISES (SCOTLAND) REGULATIONS 2004

EXECUTIVE SUMMARY

1. The Scottish Executive is consulting on proposals to ensure that wastes from mines, quarries and agricultural premises are covered by the regulatory regime generally applicable to wastes, which is designed to protect the environment and human health. At present these wastes are regulated only at the point at which they are disposed of to landfill: the proposals would ensure that regulation is more consistently applied. Since, however, the disposal of these wastes to landfill is already regulated, the changes will not require a complete change in operators’ waste management practices.

2. The changes proposed will finally remove the exemption of mines and quarries waste and agricultural wastes from the controlled waste regime. The effect of this will be principally to tighten up the handling and transportation of these wastes, since their disposal to landfill is already regulated.

3. At the same time changes are proposed to the law on household waste, which will ensure that householders dispose of waste in a safe and non-polluting manner, generally by handing over to a properly authorised waste disposal contractor, such as the local authority.

CHAPTER ONE: INTRODUCTION

Purpose

4. The purpose of this consultation paper is to set out the basis for and provide information on the proposed Waste From Mines, Quarries and Agricultural Premises (Scotland) Regulations 2004, and a related Commencement Order.

5. This chapter is mainly concerned with outlining the legislative background to the proposed regulatory regime, and provides information on the consultation process and the views being sought.

Scope of the Regulations

6. Subject to comments received during this consultation exercise, the Scottish Executive intends to introduce the proposed Regulations at the earliest possible opportunity. Similar measures are under consideration in other parts of the UK, where there will be separate consultation.

Legislative background

7. The Waste Framework Directive¹ provides a Europe-wide level playing field for waste recovery, treatment and disposal. It is designed to achieve the protection of human health and the environment against harmful effects caused by the collection, transport, treatment, storage and tipping of wastes. The Directive was designed to control a very comprehensive range of wastes, which is listed in the European Waste Catalogue². This makes for easy reference for operators throughout Europe. The UK’s own legislation, the Environmental Protection Act 1990³ and legislation thereunder, notably the Waste Management Licensing Regulations 1994⁴, established a regulatory regime throughout Great Britain, including Scotland, which conformed to the purposes and requirements of the Waste Framework Directive. However, Section 75(7)(c) and (8) of that Act effectively exempted waste from any mine or quarry and waste from premises used for agriculture within the meaning of the Agriculture (Scotland) Act 1948, from this regulatory regime. Non-mineral mines and quarries wastes and farm wastes have therefore been largely unregulated. Mineral wastes are separately regulated: no change is proposed to this regime in this paper. The minerals sector should be aware, however, that the European Commission is currently considering plans for a new Directive on waste from the extractive industries⁵.

8. As a result of the exemption, until recently most agricultural waste, for example, has been disposed of on-farm in an uncontrolled way – by open burning, by burial or by disposal in "farm dumps". Operators have generally attempted to ensure that their practices do not pose undue threats, but there may on occasion have been resulting risks to human health and to the environment.

9. The failure to regulate these waste streams has also led to enforcement action by the European Commission, on the grounds that this exclusion was a failure in transposition of the Waste Framework Directive and the related Landfill Directive⁶. The Commission has therefore applied to the European Court of Justice for a declaration that this exclusion is in contravention of these Directives⁷. The UK Government accepted that this exclusion contravenes the Directives and gave a commitment that authorities in the UK would introduce, following consultation, the Regulations necessary to comply – and so to ensure that the environment and human health are properly protected.

10. In Scotland, modern standards of protection for human health and the environment from inappropriate landfill operations have already been introduced by the Landfill (Scotland) Regulations⁸. These Regulations included mines and quarries wastes, and farm wastes, within controls on landfill by referring to the European Waste Catalogue rather than to the waste regime established by the 1990 Act. These wastes – following a transition period - will therefore be landfilled with the same care as waste streams from any other industry. The consultation prior to the making of these Regulations showed strong public backing for better controls. Similarly, in the Scottish Parliament the Regulations won cross-party support. The Regulations were developed with the assistance of a Farm Landfill Working Group, on which crofting, landowning and farming interests were represented. These sectors are keenly aware of the value to their industry of high environmental standards, and provided valuable input.

11. The landfill of these waste streams in Scotland is therefore controlled by regulations which meet best European standards of protection for human health and the environment. Similarly, the Waste Incineration (Scotland) Regulations 2003⁹ provide an appropriate form of control for incineration operations. Some aspects of the management of mines and quarries and farm wastes, however, remain uncontrolled. An example is the transport of waste. Because of the exemption in the 1990 Act, these wastes are not covered by the requirement to have their transport properly documented, or to be carried in appropriate vehicles. Such operations therefore continue to pose a greater danger to the environment and to human health than they would if they were controlled by the regime applicable to other forms of waste.

12. It is to deal with these remaining threats, as well as to carry out the UK’s commitment to observe our European obligations, that the Scottish Executive is now proposing the Waste From Mines, Quarries and Agricultural Premises (Scotland) Regulations 2004 and the related Commencement Order. Similar Regulations are under consideration in England and Wales.

13. It is recognised, however, that the cumulative effect of this and earlier changes will result in farmers, in particular, having fewer options for disposal of wastes than has hitherto been the case. For this reason a GB-wide producer responsibility scheme for non-packaging agricultural plastics is under consideration. It is accepted that such a scheme would have costs. Nevertheless, it could provide a dependable route for farmers to dispose of this material in a safe and environmentally friendly way. This scheme would be the subject of a separate consultation.

Manures and slurries

14. The Executive’s views on the regulatory treatment of manures and slurries under waste legislation are in line with those of the other administrations in the UK. Our views may be summarised as follows:-

(a) Where a farmer is using manure/slurry on the farm on which it is produced as a fertiliser or soil conditioner to meet the requirements of agricultural land (ie the use is beneficial to the land), then it is not being discarded as waste and does not fall within the WFD's controls.

(b) Manure/slurry may fall within the regulatory regime:-

(i) where a farmer uses it on the farm on which it is produced in quantities which exceed the requirements of agricultural land (ie it is not beneficial); or

(ii) it is transferred from the farm on which it is produced for use by someone else.

15. There are also circumstances in which manures and slurries are covered by the Animal By-products Regulation¹⁰ and its Scottish implementing legislation.

Exemptions

16 .Exceptions are proposed in the regulations which would permit farmers or mines and quarries operators, dealing only with their own waste streams, to continue to do so without applying the full force of regulations applicable to the transport of waste. It should also be noted that the movement of a farmer’s own manures and slurries for use on his or her own farm will not be a movement of waste, and will not therefore be subject to any waste controls.

17. It is also recognised that farmers and mines and quarries operators will continue to need simplified regimes to deal with their own wastes, where these may be permitted without detrimental environmental effects. A long list of activities is exempted from the need to have a waste management licence by the Waste Management Licensing Regulations 1994 (as amended). Farmers, in particular, may be interested in the exemption provided for burning agricultural wastes. It should be noted, however, that anyone proposing to make use of such exemptions must register with SEPA.

18. The Scottish Executive has recently consulted on further amendments to the 1994 Regulations¹¹. Further suggestions for exemptions which would meet the applicable criteria (for example, in the case of spreading, that it should demonstrably be for agricultural benefit or ecological improvement) would be welcome. We would also be interested on comments on how an exemption which would replace the old paragraph 23 exemption (now being revoked), which dealt with animal by-products, might be constructed in such a way as to meet the requirements of Scots and Community law.

19 .SEPA will be able to discuss exemptions potentially available in individual cases.

Household Waste

20. The 1990 Act permitted householders considerable discretion about what they did with their own wastes. Whereas the great majority of household waste is likely to be collected by local authorities, present legislation does not actually insist that householders dispose of their waste to either the local authority or any other waste contractor. In recent years there has been a greater awareness of the dangers of diffuse pollution, whereby a number of small sources of pollution may combine to present a serious problem. Household waste may be regarded in this light. It is possible that individual instances of burying rubbish in the garden, for example, may not have much environmental effect. But if several households in the same area did so, there would be potential for contamination of groundwater, for example, or of the soil.

21. The Scottish Executive therefore is considering tightening up the law applicable to the disposal of household waste. We are consulting on a draft amendment to s33 of the 1990 Act which will prevent householders treating, keeping or disposing of their waste in an environmentally harmful way.

22. The Scottish Executive is also currently minded to make an amendment to s34, which would place a duty on householders to take care to hand over their wastes only to persons who are properly authorised. In the great majority of cases (home composting is an example of an exception which will continue to be perfectly legal) householders hand over their wastes for disposal in accordance with best practice by properly qualified waste disposal contractors. In nearly all conceivable circumstances, this is, and would continue to be, the local authority. Under the 1990 Act local authorities are obliged to arrange for the collection of household waste, unless the costs of doing so would be prohibitively high and the authority were satisfied that the person controlling the waste could make adequate arrangements for its disposal. This might be the case, for example, where a householder in a remote area held a waste management licence for a business operated at or close to the house. Largely for this reason, the Scottish Executive does not consider it necessary or proportionate to put on householders the duty which falls on other categories of persons which may handle wastes to ensure the normal full chain of documentation. Nevertheless, by placing such a "duty of care" on householders the Scottish Executive would hope to combat the problems alluded to in paragraph 20, as well as making fly-tipping less likely.

23. This may be regulated on at a date later than the other proposals in this paper, depending on consultation replies. It is, however, a change the Scottish Executive is minded to make. In A Partnership for a Better Scotland the Executive committed itself to increase the use of doorstep collection and to the provision of recycling facilities in every community. It seems appropriate therefore, to move to prevent the uncontrolled disposal of wastes by householders.

Summary of proposals

24. The Scottish Executive intends to make amendments to various enactments and secondary legislation dealing with waste to:-

• amend the definition of waste in Scots Law to match that prevailing throughout the European Union;
• end the exemption of mines and quarries wastes and agricultural wastes from the controlled waste regime;
• improve controls on the disposal of household waste; and
• make consequential amendments to ensure that regulation of these wastes is not disproportionate.

25. The proposed changes are to ensure that waste streams from mines and quarries, and from agriculture, as well as household waste, are brought within the control of the regulatory regime for the protection of human health and the environment. This change should be enforced without causing undue difficulties for operators or householders.

Draft Regulations

26. Draft Waste from Mines, Quarries and Agricultural Premises (Scotland) Regulations, and a related draft Commencement Order, are attached at Annex A and B.

Regulatory Impact Assessment

27. A Regulatory Impact Assessment (RIA), identifying the costs, benefits and risks associated with options for regulatory change, is attached at Annex C. Comments will be very welcome.

Views being sought

28. As well as general comments on the proposals in this consultation paper, or any comments/opinions on specific aspects of the proposals, comments are invited on the following questions about the draft Regulations and Commencement Order:-

• Do the proposed Regulations set the right balance between protecting human health and the environment, meeting our European obligations, and the need to avoid excessive regulation?
• Are there any remaining areas of waste disposal whose regulation should be brought up to best European standards?
• Are there any further exemptions, which can be accommodated within the applicable environmental criteria, which should be permitted?
• In particular, would it be possible to construct a new exemption to replace the old paragraph 23 exemption, which met the requirements of Scots and Community law?
• Should householders be subject to a more explicit duty to transfer their wastes only to authorised persons?
• What further information would improve the Regulatory Impact Assessment?

Consultees

29. Those directly affected by these proposals primarily include farmers and the operators of mines and quarries, as well as contractors and others who are engaged in the agricultural or mining and quarrying business. There will also be consequences for local authorities and for other waste management operators, as well as trade associations for all of the foregoing. Environmental groups will also be interested.

30. Householders, to the extent that they do not dispose of their waste by having it collected by the local authority, may be affected by the provisions to tighten up household waste disposal.

31. A list of consultees is at Annex D. However, we would welcome comments from any interested party.

Timetable for introduction of Waste from Mines, Quarries and Agricultural Premises (Scotland) Regulations, and related Commencement Order

32. The Scottish Executive will consider whether any changes to the draft Regulations and Commencement Order or the RIA are required following consideration of the responses to the consultation.

33. The consultation period will run for 12 weeks, as is customary. Following consideration of any necessary changes, the proposed Regulations and Commencement Order will be laid before the Scottish Parliament and brought into force at the earliest opportunity thereafter.

Submission of responses

34. Comments are invited on the proposals, both for the Regulations and Commencement Order, should be sent by 19 April 2004 to:-

Ruth Campbell
Scottish Executive Environment & Rural Affairs Department
SEPA Sponsorship and Waste Unit
1-J(N) Victoria Quay
Edinburgh
EH6 6QQ

35. This consultation paper is available on the Scottish Executive website at:- www.scotland.gov.uk/views/views.asp

36. The e-mail address ruth.campbell@scotland.gsi.gov.uk also provides an alternative method of letting us have your views.

37. Respondents are invited to give their names and, where relevant, which organisation they represent. All responses will be acknowledged.

38. The Scottish Executive may wish to publish responses to this consultation paper in due course or to deposit them in its libraries. If this is done, all responses will be published or deposited unless a respondent specifically asks that his or her response should be treated as confidential. Confidential responses will, however, be included in any statistical summary of numbers of comments received or views expressed.

Enquiries and further copies

39. General enquiries and requests for further copies of the consultation paper should be addressed to Ruth Campbell at the above address.

40. Every effort has been made to write this consultation paper in line with the Scottish Executive’s Good Practice Guidance on Consultation (available on the Scottish Executive website).

CHAPTER TWO: PROPOSED LEGISLATIVE CHANGES

The Waste from Mines, Quarries and Agricultural Premises (Scotland) Regulations 2004

41. The numbering below refers to the numbering of the draft Regulations at Annex A.

42. Regulation 2 is designed to ensure that those who transport only mines or quarries waste, or agricultural waste, are not required to register as carriers of waste. This is intended to avoid disproportionate regulation and would, for example, save farmers from having to register before carrying loads of waste along a public road. This measure is included since the amendments under Regulation 3 would otherwise apply the full force of the Controlled Waste (Registration of Carriers and Seizure of Vehicles) Regulations 1991. Should SEPA or a local authority request in writing a note of the wastes transferred, however, the farmer or quarry etc operator would still have to provide a note in the statutory form within 7 days. Movement of manure and slurry for appropriate use on the farm of origin will not be subject to these controls.

43. It is anticipated that the waste contractors who actually deal with these waste streams will be registered in any case, since their waste contracting business will be wider than just mines and quarries waste, or agricultural waste. The provisions of, and the environmental protection provided by, the 1991 Regulations therefore would already apply to them.

44. Regulation 3 amends the Waste Management Licensing Regulations 1994 (as amended) to ensure that they take account of mines and quarries waste, and agricultural waste, becoming controlled waste streams. It applies standard European practice in relation to the definition of wastes, and their recovery and disposal, within the framework of the waste management licensing regime.

45. Many of the amendments are consequential upon this change, and much of this Regulation will chiefly be of interest to waste management contractors. However, a key item is Regulation 3(7), which is the provision to amend Schedule 3 to the 1994 Regulations. This deals with exemptions from the need to have a waste management licence. The proposed revocation of the former paragraph 23 exemption relating to animal by-products (Regulation 3(7)(a)) reflects the fact that the Animal By-Products Order, to which it referred, is now superseded. The new European legislation, under which in certain circumstances animal by-products do not come under the Waste Framework Directive, is the Animal By-products Regulation. Scottish legislation implementing this Regulation came into force on 1 October, and governs the disposal of these materials. We would welcome comments on whether an exemption to replace the former paragraph 23 exemption could be drafted to fit the requirements of Article 11 of the Waste Framework Directive.

46. The amendment to the paragraphs in Regulation 3(7)(b) relating to burning are to ensure that burning agricultural waste is an exempt activity. Regulation 4 ensures that there is a transition period for farmers and the operators of mines and quarries before they have to apply for a waste management licence for deposit, disposal or recovery activities which are brought within the framework of the licensing system by the end of the exclusion of these waste streams from the definition of controlled waste. For the most part deposit and disposal activities are already covered by the Landfill Regulations, and by the Waste Incineration Regulations (together with the exemption for burning) so this transition period is likely to be of particular interest in respect of recovery operations.

47. Another important item is Regulation 3(8). This contains several important matters, such as the provision to amend Part I of Schedule 4 (general provisions relating to the Waste Framework Directive etc.) This proposes, at Regulation 3(8)(a)(iv), the repeal of that provision of the Environment Protection Act 1990 (s75(c)) which excludes mines and quarries waste and agricultural waste from the controlled waste regime.

48. Regulation 3(8)(a) also carries the amendments to Sections 33 of the 1990 Act which will give householders a duty to ensure their waste is disposed of in a way which does not harm the environment. These amendments will curtail householders’ ability to treat, keep or dispose of wastes themselves, where this could cause pollution of the environment or harm to human health. For other potential changes see paragraphs 22 and 23 above.

49. Regulation 4 provides a transition period of up to 12 months to allow time to apply for the necessary permits for activities which have formerly been unregulated.

The Environment Act (Commencement No. [ ]) (Scotland) Order 2004

50. This incorporates the definition of waste current across Europe into the Environmental Protection Act 1990. This provides legal certainty and a level playing field for Scottish waste contractors.

ANNEX A

SCOTTISH STATUTORY INSTRUMENTS

2004 No.

ENVIRONMENTAL PROTECTION

The Waste from Mines, Quarries and Agricultural Premises (Scotland) Regulations 2004

The Scottish Ministers, in exercise of the powers conferred by section 2 of the Pollution Prevention and Control Act 1999(¹²), having, in accordance with section 2(4) of the Act consulted the Scottish Environment Protection Agency, such bodies or persons appearing to them to be representative of the interests of local government, industry, agriculture and small businesses respectively, and such other bodies and persons as they consider appropriate, and of all other powers enabling them in that behalf, hereby make the following Regulations, a draft of which has, in accordance with section 2(8) of the Act, been laid before, and approved by a resolution of, the Scottish Parliament:

Citation, commencement and extent

1.—(1) These Regulations may be cited as the Waste from Mines, Quarries and Agricultural Premises (Scotland) Regulations 2004 and shall come into force on [the day after the date on which they are made].

(2) These Regulations extend to Scotland only.

Amendment of regulation 2 of the Controlled Waste (Registration of Carriers and Seizure of Vehicles) Regulations 1991

2.—(1) Regulation 2 of the Controlled Waste (Registration of Carriers and Seizure of Vehicles) Regulations 1991(¹³) (exemption from registration) is amended as follows.

(2) After paragraph (1)(i) there is added–

"(j) a person who transports only mines or quarries waste or agricultural waste."

(3) In paragraph (2) the following definitions are inserted at the appropriate places–

"agriculture" has the same meaning it has for the purposes of the Agriculture (Scotland) Act 1948(¹⁴); and
"agricultural waste" means waste from premises used for agriculture;"
"mines or quarries waste" means waste from a mine or quarry.".

Amendment of the Waste Management Licensing Regulations 1994

3.—(1) The Waste Management Licensing Regulations 1994(¹⁵) are amended as follows.

(2) In regulation 1(3) (interpretation), the following definition is inserted at the appropriate place–

""mines or quarries waste" means waste from a mine or quarry;".

(3) In regulation 16 (exclusion of activities under other control regimes from waste management licensing)–

(a) in paragraph (1)(c) "and" is omitted;

(b) at the end of paragraph (1)(d) there is inserted–

"; and

(e) the recovery or disposal (otherwise than in a landfill) of agricultural waste under an authorisation under regulation 18 of the Groundwater Regulations 1998(¹⁶) .".

(4) In regulation 18 (registration in connection with exempt activities)–

(a) in paragraph (1) the words ", after 31st December 1994," are omitted; and

(b) for paragraph (1A), there is substituted–

(i) "(1A) Paragraph (1) above shall not apply in the case of an exempt activity falling within regulation 4 of the Waste from Mines, Quarries and Agricultural Premises (Scotland) Regulations 2004.".

(5) In regulation 20 (registration of brokers)–

(a) in paragraph (1) the words "after 31st December 1994" are omitted; and

(b) in paragraph (4)–

(i) in sub-paragraph (c) the word "or" is deleted; and

(ii) at the end there is inserted–

";

(e) arranges on behalf of another person (as dealer or broker) for the disposal or recovery of agricultural waste or mines or quarries waste only."

(6) In regulation 24 (amendment of the Controlled Waste Regulations 1992)–

(a) after paragraph (2) there is inserted–

"(2A) Regulation 1(4)(a) is revoked."

(b) at the end there is added–

"(10) In Schedule 3 at the end the following shall be added–

"19. Any other waste which is Directive waste, with the exception of any waste which is expressed by any other provision of these Regulations or section 75(5) or (7) to be household waste or commercial waste.""

(7) In Schedule 3 (activities exempt from waste management licensing)–

(a) [paragraph 23 is revoked];

(b) in paragraph 30–

(i) for sub-paragraph (1)(a) there is substituted "the waste consists of plant tissue;";

(ii) at the beginning of sub-paragraph (1)(b) there is inserted "it is agricultural waste or"; and

(iii) after sub-paragraph (3), there is inserted–

"(4) The incorporation into soil of ash from waste which is burned in reliance on the exemption conferred by sub-paragraph (1) above on the land where it is burned.".

(8) In Part I of Schedule 4 (general provisions relating to the Waste Framework Directive etc.)–

(a) in paragraph 9–

(i) in the heading for "Modifications of" there is substituted "Modifications and amendments of";

(ii) sub-paragraph (2) is omitted;

(iii) for sub-paragraph (6) there is substituted–

"(6) Section 33(2) is amended as follows–

(a) for "Subsection (1) above" there is substituted "Subsection (1)(a) or (b) above"; and

(b) at the end there are inserted the words "except in the case of the treatment, keeping or disposal of household waste by an establishment or undertaking""; and

(iv) at the end of sub-paragraph (10)( ¹⁷) there is added–

"(11) Section 75(¹⁸) (meaning of "waste" and related expressions) is amended as follows–

(i) at the end of subsection (6)(c) "or" is omitted; and

(ii) at the end of subsection (6)(d) there is added–

"; or

(e) any mine or quarry";

(iii) subsection (7)(c) is repealed; and

(iv) in subsection (8) for the words "but no regulations shall be made in respect of such waste as is mentioned in subsection (7)(c) above and references to waste in subsection (7) above and" there are substituted the words "and references to waste in";

(b) sub-paragraph 3 of paragraph 10 (modifications of Part I of the Control of Pollution Act 1974) is omitted;

(c) in paragraph 11 (references to "waste" in planning and water legislation) "1997" is substituted for "1992"; and

(d) in paragraph 12 (registration by professional collectors and transporters of waste, and by dealers and brokers)–

(i) for sub-paragraphs (1) and (2) there shall be substituted–

"(1) Subject to sub-paragraph (3) below, it shall be an offence for an establishment or undertaking falling within-

(a) sub-paragraph (a), (c), (f) or (g) of paragraph (1) of regulation 2 of the Controlled Waste (Registration of Carriers and Seizure of Vehicles) Regulations 1991; and

(b) sub-paragraph (j) of that paragraph after [commencement date plus in six months],

to collect or transport waste on a professional basis unless it is registered in accordance with the provisions of this paragraph.

(2) Subject to the sub-paragraph (3) below, it shall be an offence for an establishment or undertaking falling within–

(a) sub-paragraph (a), (b) or (c) of paragraph (4) of regulation 20; and

(b) sub-paragraph (e) of that paragraph after [commencement date plus six months],

to arrange for the recovery or disposal of waste on behalf of another person unless it is registered in accordance with the provisions of this paragraph."

(ii) in sub-paragraph (11) for "and "controlled waste" have the same meaning as they have" there shall be substituted "has the same meaning as it has".

Transitional and savings provision

4.—(1) [Subject to paragraphs (2) and (3)], any activity involving the deposit, disposal or recovery by any person at any premises of mines or quarry waste or agricultural waste (including any such waste which is special waste) carried on immediately before [commencement date] shall be deemed for the purposes of regulations 17 and 18 of the Waste Management Licensing Regulations 1994 to be carried out in reliance upon an exemption in Schedule 3 thereof].

(2) [The exemption which is deemed to be conferred by paragraph (1) shall cease to have effect-

(a) where the person carrying on the activity applies to SEPA for a waste management licence or a permit under regulation 7 of the Pollution Prevention and Control (Scotland) Regulations 2000 (¹⁹) in relation to that activity before [date 12 months after commencement], on the date on which the licence or permit applied for is granted, or if the application is (or is deemed to be) rejected, until the date on which–

(i) the period for appealing expires without an appeal having being made; or

(ii) any appeal is withdrawn or finally determined; or

(b) in any other case, on [date 12 months after commencement].

[(3) Paragraph (1) does not apply to an activity to which the Landfill (Scotland Regulations 2003 apply(²⁰).]

A member of the Scottish Executive

St Andrew’s House
Edinburgh

[                            ] 2004

ANNEX B

Scottish Statutory Instruments

2004 No.

ENVIRONMENTAL PROTECTION

The Environment Act 1995 (Commencement No. [   ]) (Scotland Order 2004

The Scottish Ministers in exercise of the powers conferred by section 125(3) of the Environment Act 1995(²¹) and of all other powers enabling them in that behalf, hereby make the following Order:

Citation and extent

1.-(1) This Order may be cited as the Environment Act 1995 (Commencement No. [   ]) (Scotland) Order 2004.

(2) This Order extends to Scotland only.

Provisions coming into force on [            ]

2. The following provisions of the Environment Act 1995 shall (in so far as not already in force) come into force on [                      ]–

(a) section 120(1), in so far as it relates to paragraphs 27(b) and (c), 88 and 95 of Schedule 22; and

(b) section 120(3), in so far as it relates to the repeal of–

(i) the words from "and for the purposes" of to the end of section 30(1) of the Control of Pollution Act 1974(²²); and

(ii) section 75(3) of the Environmental Protection Act 1990(²³).

A member of the Scottish Executive

St Andrew’s House,
Edinburgh

2003

ANNEX C

DRAFT REGULATORY IMPACT ASSESSMENT

THE WASTE FROM MINES, QUARRIES AND AGRICULTURAL PREMISES (SCOTLAND) REGULATIONS 2003

1. This Regulatory Impact Assessment is an evaluation of the costs and benefits for Scotland of the proposed Waste from Mines, Quarries and Agricultural Premises (Scotland) Regulations 2003, and the associated Commencement Order.

Purpose and intended effect of the measure

(i) Identify the issue and objective

2. In the UK environmental controls are placed on waste through the "controlled waste" regime set out in Part II of the Environment Protection Act 1990 (EPA 1990). The controlled waste regime ensures that waste is tracked from the point at which it arises to the point at which it is disposed of in accordance with stipulated conditions. Waste is not to be deposited, treated or disposed of other than in accordance with a licence. All those who import, produce, keep, treat or dispose of controlled waste or, as a broker, have control of such wastes, are to ensure that this prohibition is observed by themselves and others, that the escape of waste is prevented, and that any transfer is to an authorised person only, and accompanied by a proper written description. The controlled waste regime implements the Waste Framework Directive (75/442/EEC, as amended by 91/156/EEC (the Directive). The Directive provides an even degree of environmental protection across the EU, as well as a "level playing field" for industries which produce, process or dispose of wastes.

3. Not all wastes regulated by the Directive are covered by existing legislation in the UK. In particular, s75(7)(c) of EPA 1990 inhibits application of waste control regimes to farm wastes, or non-mineral wastes from mines and quarries. Furthermore, householders are exempted from controls. The objective of the proposed amendments is to comply fully with the Directive, and thus to provide protection to the environment and legal certainty to industrial sectors and others affected.

(ii) Risk Assessment

4. Pending full transposition of the Directive certain waste streams are not covered by the controlled waste regime created by EPA 1990. At the point of disposal by landfilling, or by incineration, recent changes to Scots law, through the Landfill (Scotland) Regulations 2003 and the Waste Incineration (Scotland) Regulations 2003 have improved this situation. Disposal of the wastes from mines, quarries and agricultural premises has now been brought under control. The Scottish Executive is currently consulting on amendments which would control "special" (ie hazardous) waste from these industries. Problems remain, however, in that the usual requirements of the controlled waste regime for the keeping, treatment and transport of wastes do not yet apply to the waste from mines, quarries and agricultural premises. Household waste, which may include quite hazardous wastes, such as garden pesticides and weedkillers, old batteries, paints etc. is practically uncontrolled. Even in cases where there have been no problems yet identified, for as long as they are not properly controlled there are still potential outstanding risks to the environment and human health, which in any event may be slow to show themselves. Furthermore, the lack of a system to track wastes makes fly-tipping easier.

5. While the desirability of controlling disposal of such wastes is evident, the impacts may not be readily quantifiable. Partly this situation arises from a lack of data. Any health impacts of these wastes are likely to be chronic, and it might be difficult to establish their cause.

Options

(i) Identify options

6. The following three potential options been identified for updating the controlled waste regime:-

Option 1: Do nothing.

This represents the base case of business as usual against which all other options are compared. The Directive is not implemented in full.

Option 2: Make Regulations amending the existing controlled waste regime to cover all waste streams and implement Community Law in full.

The Directive is fully implemented, but otherwise the regime for controlling wastes remains as close to its existing form as possible.

Option 3: Revise the entire controlled waste regime.

The controlled waste regime would be completely reviewed from a present-day standpoint. The new regime would fully implement the Directive.

7. These options will impact on the administrative and other costs of transporting, keeping, treating and in some cases disposing of those wastes which are not presently covered by the regime in EPA 1990. The main expense relating to waste management is disposal, which is already largely covered by Regulations on landfill and incineration. Consequently, for the most part costs will relate to the provision of an audit trail, and in some cases transport arrangements. The cost of treating these wastes (where this has been carried other than by licensed organisations) will also be affected. Administrative changes would also impact on the Scottish Executive and on SEPA. Administrative costs are as follows:-

8. Option 1 implies no change to any party and, in particular, continued non-compliance with the Directive. Such non-compliance would cause the EC to continue infraction proceedings which are already under way, and ultimately lead to a fine of up to several hundred thousand euros per day until compliance is achieved. The cost of such a fine would be met by Scotland, since other parts of the UK have indicated their intention to implement the Directive.

9. Option 2 requires amendments to be made to the EPA 1990 regime through new Regulations, incurring one-off public sector costs in drafting legislation and in providing amended guidance documents, and recurring public and private sector costs in transporting, treating, keeping and in some cases disposing of wastes newly brought under control.

10. Option 3 would require the drafting of a new regime and guidance documents. It may also require the establishment of a new IT system, the costs of which cannot at present be quantified. It would also result in one-off costs to waste disposers and managers in introducing a new system, the level of which would be dependent on the degree of change, and recurring public and private sector costs in transporting, treating, keeping and in some cases disposing of wastes newly brought under control. As a key aim of any new system would be to minimise compliance costs these might, but might not, be lower than for current arrangements.

11. The danger also exists that, by delaying establishing compliance with the Directive until a new system has been devised, infraction proceedings would continue and fines could be imposed.

(ii) Issues of equity or fairness

12. The additional cost of waste management resulting from the proposed changes will generally be reflected back to the waste producer through the charges levied by the waste management service provider, or SEPA’s regulatory charges. This is in keeping with the "polluter pays" principle. It provides an incentive to minimise waste production.

Benefits

(i) Identify the benefits

13. The principal benefit of the Directive is to ensure that wastes are properly accounted for and dealt with. This reduces risk to human health and to the environment, and increases the opportunities for recovery and recycling. The proposed Regulations would extend these benefits to waste streams which had previously been excluded from the controlled waste regime.

(ii) Quantify and value the benefits

14. The benefits for each of the three options have been identified below:-

• Option 1 – Do nothing – there are zero benefits attaching to this option beyond the present regime, only disbenefits. Compared with the other options, the benefits of maintaining compliance costs at existing levels is outweighed by the resulting risk of heavy fines continuing until changes to comply with the Directive were made. Here would also be continuing potential for damage to human health and the environment. This would arise from allowing wastes, which may be harmful to one or the other, or both, to continue to be transported, treated, kept, and in some cases disposed of with little or no control to ensure that these activities are carried out properly or that the wastes do not escape into the wider environment.
• Option 2 – Amend the controlled waste regime – this option would secure the health and environmental benefits of the Directive in relation to household waste, agricultural waste and non-mineral waste from mines and quarries. There would also be benefits to providers of waste services, in the form of further business opportunities. For example, research suggests that at present some 60% of farmers are taking scrap metal to dealers. This number could increase under the proposals.
• Option 3 – Introduce a new controlled waste regime – this option would also secure the health and environmental benefits of the Directive in relation to the full range of wastes. It could have further benefits in terms of improving the flow of information required by the Directive, depending on the characteristics of the new regime, and in taking the opportunity to streamline the processes by which waste is controlled.

Compliance and other costs for business, charities and other organisations

(i) Business sectors affected

15. The proposed amendments will impact on waste producers (including householders), private sector waste management contractors and, potentially, other organisations involved in managing the disposal of wastes, such as local authorities or Scottish Water. It will also impact on the Scottish Executive as legislator and SEPA as regulator.

16. For most of these sectors, the extent of the impact will be relatively small if Option 2 is followed, as proposed. The controlled waste regime with which they are familiar will continue. The difference will be that additional waste streams will be regulated under it so that, for example, farm wastes will be tracked from the point of arising to point of disposal. Therefore the chief impact will be felt by sectors whose wastes are at present not covered by the Regulations, notably farming, mining and quarrying. However, the impact, in most cases, will be limited to further documentary requirements and the (minimal) cost of preparing a waste transfer note, since improper disposal of wastes on farm or at site is already prevented by controls on landfill and incineration. Where these sectors have already come to arrangements with contractors to remove their waste it is likely that these contractors have been applying the new requirements already. No transfer note is needed when carrying one’s own waste. An exception from the documentary requirements is proposed to allow farmers, or the operators of mines and quarries, not to register as a carrier if carrying exclusively waste from mines, quarries or agricultural premises. The case where farmers and quarry operators would notice a more significant difference is where they treat or recover wastes on site. In these cases a range of exemptions will be available.

17. Householders will notice little, if any difference, since in the overwhelming majority of cases they will meet their obligations under the proposed amendments by handing over their waste for collection by their local authority, as at present.

18. Charities and voluntary organisations as waste recyclers. Charities, voluntary organisations and NGOs make a significant contribution to local schemes for recycling and re-use of certain household wastes. They may have an increasing role in niche markets, such as through not for profit companies in commercial waste recycling and local networks of waste exchanges with resultant additional paid and voluntary employment opportunities. It is unlikely the proposed changes will greatly affect their operations. They are already covered by the controlled waste regime.

(ii) Compliance costs

19. Compliance costs are estimated as follows:-

• Option 1 – Do nothing – Would have no additional compliance costs for industry or regulator, but would leave Scotland short of full implementation of the Directive. This could lead to significant fines on the UK (a potential €534,000 per day), that would be met from funds allocated to the Scottish Executive. This would clearly have significant impacts on Scottish Executive resources and ability to deliver public services. There would also be costs to human health and the environment which are, however, difficult to quantify.
• Option 2 – Amend the controlled waste regime – This option places additional costs on those producers of waste who are brought into the regulations for the first time. There are also minor additional costs for the regulator.

The degree of additional waste management charges will depend on the present waste practices, and how far these have to change to meet the new Regulations. Some of the newly included waste streams will be affected by forthcoming regulations, such as the End of Life Vehicles Directive and the Waste Electronic and Electrical Equipment Directive, which create producer responsibility schemes to deal with these wastes, and thus remove the burden from consumers. Moreover, other Regulations, such as the Landfill (Scotland) Regulations 2003 or the Packaging Waste Regulations 1997, already include a definition of waste that will cover these substances. Nearly all householders, in practice, will continue handing over their waste to the local authority, as at present. It is therefore likely that the increase in waste management costs that is due to these amendments to the controlled waste regime is in most cases no more than moderate, and will amount to less than £2m per annum. The most heavy costs will fall on any businesses which treat mines and quarries waste, or agricultural waste, and which would now need a waste management licence, which can cost some thousands of pounds. Transportation costs will relate to the much smaller costs of registration (though only in some cases) and the minimal costs of preparing notes.

There is no doubt, however, that a significant number of new businesses will be brought into the scope of the regime by the extension of the definitions. There are some 50,000 farm units in Scotland, including crofts. The number of quarrying businesses in Scotland is estimated as about two hundred. There are 19 open-cast coal mines in Scotland, 2 tourist mines and 2 other mines. These businesses are likely to have to keep records and prepare waste transfer notes at some time, although for many of these, this will only be very occasionally. We can estimate an additional one off cost of £2.5m for these businesses in finding out about the system (about £50, mainly relating to time costs, per business).

The additional costs faced by the regulator are likely to be small. The cost of changes which have the most significant impact – such as inspections – are recoverable.

• Option 3 – Introduce a new controlled waste regime – Under this option, the costs identified above would be incurred. In addition, there would be additional costs for the regulator in implementing a system (including IT costs), in producing new guidance for regulated sectors, and for the regulated in introducing and adapting to a new system. Set against these costs is the potential that there could be future savings if a new system was significantly more streamlined than the existing system.

Table: Summary of estimated compliance costs

Consultation with small business: the "Litmus Test"

20. As part of the present consultation small businesses, in particular, are invited to submit information on the potential costs of these changes.

Identify any other costs

21. As identified above, there will be costs to SEPA (which it may, at least in part, lay off onto waste managers through charging schemes) and to the Scottish Executive. The proposed changes will introduce additional burdens on SEPA in the following principal areas:-

• Examining documentation for waste streams not presently covered by the controlled waste regime;
• The licensing and permitting of additional facilities for the recycling and/or treatment of wastes from these streams, in accordance with the Directive and relevant Regulations; and
• The enforcement of prohibitions in respect of these waste streams.

22. SEPA currently charges for licensing and permitting on the basis that charge income should cover operational costs of this nature.

23. Amending the current controlled waste regime, as opposed to creating a new one, would obviate the costs for SEPA that setting up such a new system would entail. These would mainly relate to IT capabilities, but there would also be a requirement for training for staff, and new guidance. Option 2 is likely also to create one-off staff costs for SEPA in respect of refresher training and updating existing guidance (however, as SEPA already has a training budget these costs are more in the way of future costs brought forward than entirely new costs). These costs will be much smaller than if Option 3 were adopted. There will also be costs to the Executive in terms of drafting the legislation. These changes have not been costed for this document.

Result of consultations

24. A twelve-week consultation is being carried out with those listed in Annex D being specifically invited to comment on the proposed Regulations, Commencement Order and this RIA.

Summary and recommendations

25. The proposed Regulations and Commencement Order reflect the Directive’s intention to introduce a Europe-wide level playing field for the producers of a broad variety of wastes. They also reflect the Scottish Executive’s intention that waste should be more carefully managed in Scotland in future, whatever its source, and that best European practice should be applied to Scottish waste management.

26. The cost of failing to implement European law correctly are the health and environmental costs related to failing to control particular waste streams, which are difficult to quantify, and potentially fines imposed by the European Court of Justice of up to €534,000 (c. £360,000) a day. The costs of amendment would depend on whether a minimal approach was followed, as in Option 2, or a complete revision, as in Option 3. The costs for Option 2 would be small, and largely recurring, whereas there would be immediate, possibly substantial, non-recurring costs involved in Option 3, though recurring costs could then be lower. There has been no noticeable demand for an overhaul of the existing regime. If industry is indeed content with the status quo it would accordingly, be sensible to restrict change to the minimum necessary to secure full UK compliance with EC law. Accordingly, this paper recommends the adoption of Option 2.

Enforcement, sanctions, monitoring and review

27. SEPA, as the competent authority, would be responsible for enforcing and ensuring compliance with the new Regulations, just as in the case of the present regime. This duty is carried out at present, and would continue to be in the future, through a process of audit and spot checks of installations, registers etc. There is a duty on those handling wastes to maintain records and make these available to SEPA and, shortly, local authorities, on request. The controlled waste regime already has the sanction of appropriate maximum fines, which would not be affected by the proposed Regulations. SEPA’s charging scheme permits it to recoup the cost of enforcing at least some of the activities which the amending Regulations will require.

28. SEPA would also provide such guidelines and training as may be necessary to its officers, so that the proposed Regulations are implemented, monitored and enforced consistently and fairly across the country. The Scottish Executive and SEPA would monitor and review the effectiveness of the regime.

29. The costs of these regulations are closely related to some of the additional disposal costs imposed by the Landfill (Scotland) Regulations 2003, and the administration charges imposed by amendments to the Special Waste Regulations 1996, since all these measures bring waste from mines, quarries and agricultural premises within various aspects of the waste control regime. We are considering carrying out a joint review RIA of these sets of regulations once the full impacts of implementation are clear.

ANNEX D

LIST OF CONSULTEES

Local Authorities
Aberdeen City Council
Aberdeenshire Council
Angus Council
Argyll & Bute Council
City of Edinburgh Council
Clackmannanshire Council
Dumfries and Galloway Council
Dundee City Council
East Ayrshire Council
East Dunbartonshire Council
East Lothian Council
East Renfrewshire Council
Falkirk Council
Fife Council
Glasgow City Council
Highland Council
Inverclyde Council
Midlothian Council
Moray Council
North Ayrshire Council
North Lanarkshire Council
Orkney Islands Council
Perth and Kinross Council
Renfrewshire Council
Scottish Borders Council
Shetland Islands Council
South Ayrshire Council
South Lanarkshire Council
Stirling Council
West Dunbartonshire Council
West Lothian Council
Western Isles Council

Political Parties and MSPs
Conservative Party
Green Party
Labour Party
Liberal Democrats
Scottish National Party
Scottish Senior Citizens Unity Party
Scottish Socialist Party
Dennis Canavan MSP
Margo MacDonald MSP
Jean Turner MSP

Farm Contractors
Scottish Agricultural Contractors Association, Perth
John A Petrie, Stonehaven
Ringlink (Scotland) Ltd, Laurencekirk
William Watt, Banchory
A & M Wright, Banchory
Jack Reid, Ellon
Sandy Milton, Ellon
John Skinner, Maryculter
George Wood, Echt
R & W Wilson, Sauchen
W Clark, Ellon
Colville Contractors, Turriff
Eric Gibson, Maud
John Rennie, Turriff
I M Paterson, Kintore
W Paterson, Ellon
W Robertson, Ellon
A Sinclair, Udny
Ian Sim, Turriff
M Bell, Fraserburgh
John Junor, Peterhead
Low Brothers, Peterhead
Philip Paterson, Huntly
Peter Clemson & Sons, Larkhall
Central Farmers Ltd, Pitscottie
James Scougall, Inchture
Complete Weed Control (Scotland), Crieff
R H Sprot & Son, Berwick on Tweed
Feedmix Ltd, Turriff
Growing Concern (Scotland) Ltd, Dunning
Crop Services (Scotland) Ltd, Kelso
I A Mowatt, Evanton
John Bryson, Lesmahagow
Ronald Campbell, Ballantrae
D M Contracts, East Kilbride
W & M Craig, Drongan
A & A Drummond, Sorn
G Dunlop, Kilmacolm
James Forrest, Darvel
H Gilbert, Johnstone
Archie Kerr, East Kilbride
W Kirkpatrick & Sons, Ardrossan
David Laird, Cronberry
G & R Logan, Coylton
Craig MacFadzean, Newmilns
J MacFadzean, Kilmarnock
Jim Mair, Cumnock
Nisbet & Sons, Moscow
Seaton Bros, Lochwinnoch
J Smith, Kilmaurs
Alexander Watt, East Kilbride
J & W McNae, Tarbolton
Scottish Machinery Ring Association, North Kessock
CSG Landstar, Paisley
Snowie Ltd, Stirling
EMAC, Inverness
DM Carnegie, Kincardineshire
G Dalgarno & Sons, Angus
Derek Day, Port Elphinstone
J Elliss, Stonehaven
D Ewan, Kincardineshire
E Ewan, Kincardineshire
H McPherson, Kincardineshire

Mines and Quarries
Angle Park Sand & Gravel Co Ltd, Ladybank
Avondale Aggregates, Polmont
HJ Banks & Company Ltd, Coatbridge
Bardon Aggregates, North & Scotland, Carnforth
Barr Quarries, Ochiltree
W Bartlett, Muir of Ord
Barwinnock Peat Company, Newton Stewart
Bonnar Sand & Gravel Co Ltd, Cairndow
Boyne Bay Lime Co Ltd, Aberdeen
Brown, Westray
I & H Brown Ltd, Dunkeld
Bruce Plant Ltd, Inverbervie
Buchan Brothers, Longside
Caithness Stone Industries Ltd, Wick
Castle Plant, Aboyne
Causewaybank Quarries Ltd, Chirnside
Chap Quarries (Aberdeen) Ltd, Westhill
A Clark, Barry Buddon
Cloburn Quarry Company Ltd, Lanark
Coal Authority, Mansfield
Confederation of UK Coal Producers, Wakefield
John H Connon Ltd, Inverurie
J & J Currie Ltd, Dumfries
Dalgleish Associates, Dunblane
JR Dass, Burray
Dianglen Ltd, Coatbridge
Ennstone Thistle Ltd, Newburgh
A Falconer & Sons, Elgin
Faldane Ltd, Gorebridge
J Fenton & Sons (Contractors) Ltd, Perth
Fife Silica Sands Ltd, Tillicoultry
Garrick Quarries Ltd, Lerwick
George Garson, Stromness
D Geddes (Contractors) Ltd, Arbroath
KJ Gill, Fortrose
GM Mining Ltd, Airdrie
Granit Union, Inverness
Kenneth Grieve, Birsay
Gunns (Lybster) Ltd, Lybster
J & MJ Hamilton, West Calder
Highland Lime Co, Fort William
Hillhouse Quarry Group Ltd, Troon
Hoddam Contracting Co Ltd, Ecclefechan
Inkster & Henderson, Lerwick
Invergordon Sand & Gravel, Alness
Jackson Aggregates, Braco
GF Job Ltd, Nairn
Joss (Aberdeen) Ltd, Bridge of Don
Kier Scotland, Glasgow
Kinegar Sand & Gravel, Cockburnspath
Hugh King & Co, Kilwinning
Laird Aggregates Ltd, Forfar
LAW Mining Ltd, Hamilton
Gavin Lawrie, Prestwick
Ledmore Marble Ltd, Clackmannan
Leith’s Scotland Ltd, Aberdeen
MK Leslie Ltd, Lerwick
Limehillock Quarry Plant Ltd, Keith
Lochaber Aggregates, Fort William
Locharbriggs Sandstone Ltd, Dumfries
Lothian Mining (Scotland) Ltd, Newhouse
Lovie Ltd, New Pitsligo
Luce Bay Plant Hire, Dunragit
R Macaskill (Contractors) Ltd, Tarbert
JJ Macdonald, Lochboisdale
IA & C Maciver, Stornoway
Macaulay Askernish Ltd, Lochboisdale
J MacCuish, Malaclate
MacFadyens Contractors, Campbeltown
MacGregor’s Peat, Inverness
A Maciver Ltd, Stornoway
Alastair Mackay, Dornoch
John Mackay, Horgabost
Edward Mackay Ltd, Brora
John Maclachlan Ltd, Oban
Macleans Haulage Contractors, Carnon
John Maclennan Contractors, Castle Bay
C & W McAllister, Sliddery
JG McDowall, Auldgirth
J McMiken, Whithorn
Hector McNeil, Tangusdale
MI Great Britain Ltd, Aberfeldy
Moore Watson Ltd, Bonnybridge
Moray Stone Cutters, Birnie
P Munro, Alness
Natural Stone Quarries Ltd, Stirling
Nicholson Plant, Brae
Northern Peat & Moss Co, Peterhead
Orkney Aggregates Ltd, Kirkwall
Patersons of Greenoakhill, Coatbridge
John Patterson, Peterhead
Peterson Crane Hire, Lerwick
H & H Plant, Whalsay
George Raeburn (Minerals) Ltd, High Blantyre
James Reid & Co (1947), Kilmarnock
Riskend Quarrying Co Ltd, Kilsyth
RMC Russell, Uddingston
Alex Ross & Sons (Sand & Gravel) Ltd, Inverness
Alexander Sandison & Sons, Unst
SB Minerals Ltd, Hamilton
Scott Plant Hire, Newton Stewart
Scottish Mineral Officers Forum, Hamilton
A Sinclair & Sons, Wick
Skene Group Construction Ltd, Leslie
C & S Smith, Fordoun
Speyside Sand & Gravel Quarries, Rothes
Kenneth Stewart (Strathpeffer) Ltd, Strathpeffer
Peter D Stirling Ltd, Bellshill
A & D Sutherland, Wick
Frank Taylor, Strathdon
IR Taylor, Banchory
Les Taylor Contractors Ltd, Mintlaw
The Scottish Coal Company Ltd, Kelty & Alloa
Martin Thompson, Virkie
Wm Thompson & Son, Dumbarton
J Thomson Construction Ltd, Lamlash
Tillicoultry Quarries, Tillicoultry
Tinto Sand & Gravel Ltd, Biggar
Tulloch Capital Quarry Products Ltd, Bishopbriggs
Tulloch Construction Group Ltd, Inverness
UG Sand Developments Ltd, Alloa
Uist Builders Construction Ltd, Daliburgh
UK Coal Mining Ltd
United Fireclay Products, Armadale
Water of Ayr & Tam O’Shanter, Stair
Watermill Aggregates, Fraserburgh
George Watson & Sons, New Pitsligo

Interested Parties
Abertay University
Accounts Commission
Advocates’ Library
Aitken Associates
Anderson Strathern WS
Aspinwall & Company
Association of Scottish Chambers of Commerce
Association of Scottish C
Association for the Protection of Rural Scotland
Audit Scotland
BIFFA Waste Services Ltd
Bishop and Robertson Chalmers
Blairingone and Saline Action Group
British Energy Plc
British Geological Survey, Edinburgh
British Polythene Industries, Dumfries
Brodie Solicitors
Burness Solicitors
Caledonian Environment Centre
CBI Scotland
Central Farmers Limited
Centre for Environment & Business in Scotland
Citizens’ Advice Scotland
CIWM
Confederation of Landscape Industries in Scotland
CORDAH
COSLA
Crofters Commission
Cuthbertson Environmental Ltd
Department for the Environment for Northern Ireland
DEFRA
Dexter Nonwovens
DK Waste Services
EAG Environ
Ecos House
Effluent Enterprise
ENVIIROMAc
Environmental Assessment Group
Environmental Health Advisory Services
Environmental Services Association
Farm and Wildlife Advisory Group
Forth Valley Health Board
Forum of Private Business
Freight Transport Association
Freshfields WS
Friends of the Earth
Gas Measurement Instruments Ltd
Going for Green
Halcrow Fox
Highland Spring Ltd.
Holden Environmental Waste Management Services
Horticultural Trades Association
Inclusion Scotland
Ironside Farrar Ltd
IWM Caledonian Environment Centre
IWM Centre Kilmarnock
Keep Scotland Beautiful
Levenseat Landfill Ltd
Malt Distillers Association of Scotland
McGrigor Donald Solicitors
MLC
MLURI
NALGO
NFU Scotland
Robson Maclean WS
Royal Environmental Health Institute for Scotland
Royal Scottish Agricultural Benevolent Institution
SCOLAG
Scottish Agricultural College
Scottish Centre for Infection and Environmental Health
Scottish Chambers of Commerce
Scottish Civic Forum
Scottish Consumers Council
Scottish Council Development & Industry
Scottish Crofting Foundation
Scottish Environment Protection Agency
Scottish Landowners Federation
Scottish Power
Scottish Water
Shanks Group, Coatbridge
Small Landlord Association
Snowie Group
Unison
Women’s Forum Scotland

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