Chapter 3 provides an overview of two influential pragmatic approaches to reference: Accessibility theory and the Givenness Hierarchy. Both accounts have been claimed to be compatible with relevance theory. However, it has also been claimed relevance theory alone cannot account for the full range of data and that these auxiliary scales of activation are necessary additions. In this chapter these claims are examined, and some objections are raised. The more general objections relate to the nature of the relevance-theoretic approach to utterance interpretation and how scales of encoded activation might fit with this. More specific objections relate to how the activation scale accounts deal with stylistic or so-called special uses of referring expressions. Finally, some examples of proper names in English are briefly discussed to illustrate how highly context sensitive the choices made by speakers can be, and to demonstrate the crucial role played by considerations of style and genre.