LINK is extremely supportive of the proposals regarding tougher enforcement of environmental regulation and stronger sanctions for environmental crime. We agree that SEPA should be given powers to recoup costs from successful prosecutions. We are concerned about proposals relating to the targeting of SEPA resources towards high-risk activities which must not result in SEPA expending less resource on tackling environmental deterioration arising from activities that are considered to be low risk but that, cumulatively, have a detrimental environmental impact. We are concerned about proposals to reduce inspections and monitoring. The impact and success of any changes to the regulatory regime must be properly measured against environmental outcomes. It is crucial that any changes do not negatively affect biodiversity or the wider environment.
http://www.scotlink.org/files/policy/ConsultationResponses/LINKBetterEnvReg0211.pdf