While the Council fully supports the overarching aim of the Bill; to deter and address the most serious forms of environmental harm, we wish to highlight several areas of concern where the Bill, as currently drafted, could create significant uncertainty and unintended consequences for local authorities acting within their statutory duties. 1. Consented or Licensed Activities The Bill does not appear to provide an explicit defence for activities carried out under statutory consents or licences, including planning permissions, Roads Construction Consents, flood protection works authorised under the Flood Risk Management (Scotland) Act 2009, or permits and licences issued by SEPA or NatureScot.