This supports ERCS’s position that incorporation of the right to a healthy environment is not a substitute for urgent access to justice reforms, including legal aid reform, the replacement of Protective Expenses Orders (PEOs) with Qualified One-Way Cost Shifting (QOCS), and the establishment of a dedicated Scottish Environment Court, that are necessary to achieve full compliance with Article 9. • Para 59 states that the Scottish Government’s court fee exemption in the Court of Session is ‘positive progress’, but the ACCC echoes ERCS’s position in recommending the introduction of a similar exemption for cases heard in other courts. • In Para 63, the ACCC welcome the Scottish Civil Justice Council (SCJC)’s review of PEOs, but ‘expresses concern’ that the review is still not completed so close to the 1 October deadline. ERCS remains concerned that new...