Further supplementary memorandum submitted
by the Environment Agency
SUPPLEMENTARY MATERIAL
Q337 (transcript): Could you provide a figure
for the costs involved in providing planning advice, specifically
in relation to the number of planning applications and the potential
increase in such applications?
1. Total costs associated with the Environment
Agency's work in support of planning and development control are
currently estimated to be around £8 million per annum. This
covers the direct costs of the planning liaison workforce, IS/IT
systems development and support, plus management support and overheads.
2. The Environment Agency responded to around
65,000 consultations from Local Planning Authorities (LPAs) in
2004, and around 54,000 in 2005. This reflects our focus on "higher
risk" consultations (around 65% of workload) in order to
free resource to deal with the expected rising workload of Local
Development Frameworks.
3. We expect the number of higher risk,
complex applications to continue to rise so that it becomes an
ever-higher percentage of our workload as we reduce lower risk
consultations through tools such as standing advice. Current trends
indicate a workload of 50,000 per annum (almost all high risk
and complex) by 2008. In 2005 we responded to almost 1,500 consultations
on new style local plan documents, including sustainability appraisals.
We expect this workload to rise steeply as increasing numbers
of English LPAs start preparing their Local Development Frameworks
under the new system.
4. As well as investing in IT, the Agency
has recently taken the decision to increase its annual expenditure
on planning staff in order to deal with rising complex workload
and the expected increase in workload for local (strategic) plans.
This will be reviewed as the reduction in strategic plan work,
and the increased use of IT systems and e-Planning, allows us
to reconsider resource use.
Q350 (transcript): The argument was about taking
gravel from one side of a weir and putting it on the other side
which might be a good bed for fish spawning, so why did the gravel
have to be treated as waste?
5. During oral evidence we offered to provide
more information on this issue. In the absence of a specific example
from witnesses, we are providing some general information on our
policy on gravel removal from rivers.
6. The Environment Agency has a policy on
the removal of gravel from rivers. This states that we are generally
against the removal of gravel, other than where specifically allowed
for navigation or proven to be essential in specific locations
for flood risk management or water supply purposes. We developed
this policy to safeguard river geomorphology and channel habitats
upon which many birds, invertebrates, plant communities and fish
depend. We recognise that historic gravel dredging activities
caused a legacy of problems including channel destabilisation,
bank erosion, poor water and sediment quality and a consequent
reduction in biological diversity. This is also why we would expect
any proposal to move gravels within a river to be carefully evaluated
to ensure that it is both sustainable and environmentally acceptable
over the long term.
7. The question of whether gravel removed
from a river is defined as waste would depend on the circumstances
and the intentions of the person removing it. If the gravel is
being sourced for another purpose then it may not be waste, whereas
surplus gravel that needs to be discarded would be waste. As we
do not know the case in question we are unable to speculate as
to what might have been the problem. We do have an obligation
to ensure that we provide all sectors with a consistent regulatory
approach to definition of waste issues. This is not pursued dogmatically
and we act mindful of public interest.
8. There are examples in "flashy"
rivers (those that experience large and rapid changes in flow)
where in-situ gravels become shifted over time and could beneficially
be moved within the river to re-create riffles and spawning beds
for fish. Under these circumstances the gravel would not be a
waste.
Q355 (transcript): Can you provide some commentary
on the process of risk assessment in terms of planning and flood
protection?
(Please note that in providing this response
we have considered "planning" to mean the Town and Country
Land Use Planning system and not the broader catchment planning
aspects of flood risk.)
9. Planning Policy Guidance Note 25 (PPG25)—Development
and Flood Risk, provides current Government guidance on risk assessment
in terms of town and country planning and flood protection. PPG25
is currently under review and ODPM are consulting on Draft Planning
Policy Statement 25 (PPS25) which strengthens the role of spatial
planning in managing and reducing flood risk as well as the process
by which flood risk is considered at all stages of planning. Draft
PPS25 also strengthens the links between spatial planning, flood
risk management planning and emergency planning. Catchment Flood
Management Plans and Shoreline Management Plans are seen as providing
essential information to and dialogue with the planning sector
to deliver cross-organisation sustainable flood management.
10. PPG 25 and DRAFT PPS25 emphasise the
need to adopt a precautionary approach to the issue of flood risk,
avoiding it where possible and managing it elsewhere. The uncertainties
inherent in flood prediction are recognised, together with the
likely increase in flood risk due to climate change, which introduces
even greater uncertainty. PPS25 also encourages Local Authorities
to seek opportunities to reallocate existing development to areas
of lower risk and utilise opportunities that regeneration and
growth provides to reduce risk through making space for water.
When allocating land in development plans or deciding applications
for development at any particular location, those responsible
for the decision are expected to demonstrate that there are no
reasonable options available in a lower-risk category.
11. Local planning authorities should follow
the sequential approach set out in PPG 25 (paragraph 30) as below:
30. The Government looks to local planning
authorities to apply the risk-based approach to the preparation
of development plans and their decisions on development control
through a sequential test. Developers seeking sites for housing
and other development should also have regard to this test. Accordingly,
in drawing up or revising policies in development plans and in
considering applications for development in cases where plans
do not yet reflect the following, local planning authorities should
give priority in allocating or permitting sites for development,
in descending order to:
(i) areas with little or no potential
risk of flooding (annual probability less than 0.1%)—These
areas would have no constraints on development other than the
need to try to secure that development does not increase run-off
from the site to greater than that from the site in its undeveloped
or presently developed state;
(ii) areas with low potential risk
of flooding (annual probability between 0.1% and 1.0% for rivers,
0.1-0.5% for coastal areas) —These areas would be suitable
for most development but essential civil infrastructure, such
as hospitals, fire stations emergency depots etc, would require
guaranteed access in times of emergency due to extreme flooding;
(iii) areas with high potential risk
of flooding (annual probability greater than 1.0% for rivers,
0.5% for coastal areas), which are already extensively developed—In
practice, large parts of these areas are likely be at only low
to moderate risk of flooding because they are already adequately
defended. These areas will generally be suitable for further residential,
commercial and industrial uses, provided there are adequate flood
defences, that buildings are designed to resist flooding, that
there are suitable warning and evacuation procedures in place
and that new development does not add to flood risk downstream.
Such areas will generally not be suitable for essential civil
emergency infrastructure unless access can be guaranteed in times
of flood;
(iv) areas with high risk of flooding
(annual probability greater than 1.0% for rivers, 0.5% for coastal
areas), which are currently undeveloped, including the functional
flood plains defined in paragraph 24—These areas are
generally not suitable for residential, commercial and industrial
uses unless a particular location is essential, eg for navigation
and water-based recreation uses and essential transport and utilities
infrastructure. Where residential and other uses are permitted
they should be provided with adequate flood defences, be designed
to resist flooding and suitable warning and evacuation procedures
should be in place. Residential uses should generally be limited
to job-related accommodation, such as caretakers and operational
staff. General-purpose housing or other development comprising
residential or institutional accommodation should not normally
be permitted. However, exceptions may need to be made where extensive
areas of land fall into this category, eg in low-lying parts of
eastern England, and in other locations where alternative sites
in areas at lower risk are not available. In such areas, further
development may be needed to avoid social and economic stagnation
or blight, or to allow existing development to be adequately protected.
Authorities in these areas should, however, pay particular attention
to design and mitigation issues and warning and evacuation arrangements,
in full consultation with the Environment Agency, other operating
authorities and the emergency services;
(v) areas at highest risk from flooding
(including those areas behind defences that offer a standard of
defence less than 1% for rivers or 0.5% for coastal areas or elsewhere,
where there is a significant risk that failure could lead to rapid
inundation by fast-flowing water) —These areas may be
suitable for recreation, sport, amenity and conservation uses
provided adequate warning and evacuation procedures are in place,
and for essential transport and utilities infrastructure. Industrial,
or commercial development should not normally be allowed. Further
residential uses should only be permitted in wholly exceptional
circumstances, where no alternative is possible, eg the operational
uses noted in (iv) above, and these must be subject to fully suitable
mitigation design and warning/evacuation conditions. There should
be a general presumption against any extension of general-purpose
residential land uses in such areas.
12. The new draft PPS25 strengthens the
risk based sequential test by adding a new table D2 which considers
land use vulnerability. Local Planning Authorities undertaking
the sequential test are now steered to allocating land in lower
flood risk areas first, and then ensuring that any development
planned in areas of flood risk are compatible with that flood
risk. Highly vulnerable developments, such as hospitals with A&E,
Emergency services which need to operate at times of flood and
sheltered accommodation, are "not to be permitted" in
flood zone 3, high probability.
13. The new Draft PPS25 proposes an exception
test as set out below:
In areas where there are no alternative sites
for development in lower risk areas because there are either constraints
on those areas or because areas of higher risk are extensive,
new development may well be essential to maintain the viability
and vitality of the community and deliver sustainable development.
The new exception test in PPS25 provides a way of managing flood
risk in a transparent and consistent way so that necessary but
safe development can go ahead in such areas.
The exception test can be used where the sequential
test has shown that it is not possible for the development to
be located in zones of lower probability of flooding or the vulnerability
of the proposed use needs further consideration. The exception
test should be applied as early in the planning process as possible.
In Local Development Documents it can be used to allocate the
location of development and for drawing up criteria-based policies
against which planning applications can be considered.
14. The exception test has four criteria,
each of which must be satisfied:
— The development must make a positive
contribution to sustainable communities;
— It is on developable brownfield land
where this is available;
— A Flood Risk Assessment shows that
the residual flood risks are acceptable and manageable within
the general level of risk applicable to the area; and
— The development makes a positive
contribution to reducing or managing flood risk in the area concerned.
15. Where development is proposed in a flood
risk area (zone 2 and 3) or a development greater than 1ha for
flood zone 1 (to take on-board surface water and increasing risk
elsewhere), a Flood Risk Assessment (FRA) must be submitted with
a planning application to ensure no inappropriate development
takes place and that occupants remain safe in times of flood.
16. The Environment Agency is a statutory
and non-statutory consultee for various elements of the spatial
planning process. We are a "Key" consultee for the Regional
Spatial Strategy and Local Development Framework processes, along
with their associated Sustainability Appraisals. This allows us
to ensure all new plans and strategies include appropriate policies
on a number of key issues, including Flood Risk.
17. In addition, we are a statutory consultee
for a number of individual planning applications, dependent on
their type and/or location. These are set out in Article 10 of
the General Development Procedure Order 1995. At present we are
not a statutory consultee for flood risk, although we are a statutory
consultee for "development involving the carrying out of
works or operations in the bed of or on the banks of a river or
stream". Local planning authorities are simply advised in
PPG25 to consult us when an application for development raises
flood risk issues. Most local authorities do appear to consult
us, but there is a danger that we may not always be consulted
when there is a flood risk issue. ODPM is at present consulting
on a proposal to make us a statutory consultee when development
is proposed in areas of flood risk as part of the PPS25 consultation
package.
Do you consider the existing mechanisms of evaluating
and responding to risk messages to be as good as they should be?
18. The principal method of evaluating and
responding to risk messages is through the production of an appropriate
Flood Risk Assessment (FRA).
Whilst PPG25 (Appendix F) provides information
on what an appropriate FRA should consider, our experience has
shown that local authorities and developers constantly seek further
guidance from the Environment Agency. ODPM plan to release a Practice
Guide in support of the new PPS25 and this document will help
provide more information and assistance.
19. Unfortunately, four years after the
publication of PPG25, large numbers of consultations are still
being submitted to local planning authorities (and then the Environment
Agency) without an appropriate/satisfactory FRA. This deprives
us of important information we need to determine our response
to flood risk issues. The lack of a satisfactory FRA accounted
for over half (53%) of all Environment Agency sustained objections
on flood risk grounds to planning applications in 2004-05. Draft
PPS25 however provides greater clarity and stronger policy on
FRAs, requiring Regional FRAs and Strategic FRAs as part of Regional
Spatial Strategies and Local Development Frameworks, and site-specific
FRAs to accompany individual planning applications for development
in flood risk areas. In addition ODPM are proposing to introduce
a standard planning application form which would require developers
to submit an appropriate FRA before a planning application could
be registered.
20. Some local planning authorities continue
to grant planning consents in flood risk areas where the Environment
Agency has lodged a formal objection on flood risk grounds. ODPM
are currently seeking views on proposals for a standing flooding
direction in respect of major developments for which a planning
authority proposes to grant permission, despite there being a
sustained objection from the Environment Agency on flood risk
grounds. If adopted, this standing flooding direction will help
ensure appropriate responses to flood risk messages where new
development is concerned.
21. There is always room for improvement
in mechanisms and responses in respect of planning and flood risk.
However, the proposed PPS25, together with Government, local authorities,
developers and the Environment Agency learning from experience
will all contribute to this goal.
ADDITIONAL QUESTIONS
1. Why have 40% of permits issued to waste
operators to meet the IPPC and Landfill Directives been subject
to appeal?
22. Our records show that around 26% of
the landfill permits determined have been subject to appeal. It
should be noted that nearly 50% of the total number of landfill
appeals were against our refusal to permit. Our revised generic
landfill permit will lead to the majority of these operator appeals
being largely resolved.
23. The landfill sector does have a high
appeal rate compared with other sectors brought into IPPC. The
transition of long-established landfills into a new style of regulation
(PPC), whilst also needing to meet the tougher standards set down
by the Landfill Directive was always going to be challenging for
all concerned. Many existing sites are either not able to meet
the Landfill Directive requirements, or would require prohibitively
expensive works and a number have closed as a result. A number
of fundamental policy issues arise from the need to implement
the Landfill, IPPC and Groundwater Directives at the same time.
Some of these will be determined through proceedings in the High
Court, others are being resolved through the appeal process. 29
of the 48 appeals against conditions are currently held in abeyance,
meaning that we are working with the operator to seek resolution.
This does not represent the mass permitting problems alleged by
some.
Why have less than half of the applications been
issued?
24. We did not receive all the applications
at the same time. Applications were phased in "tranches"
so that we dealt firstly with the higher risk, more complex sites.
25. Many of the outstanding applications
were received in recent tranches and are therefore still within
their determination timescale. We did recognise the challenges
that PPC permitting presented to us and the industry, and establishment
of our Strategic Permitting Groups has helped to cut the average
determination time for landfill applications by 20%. Communication
with industry has also improved as the re-permitting process has
progressed, which is also assisting in resolving permitting issues
more quickly.
What are the current costs to the Agency of this
"administrative inefficiency"?
26. The grant of a PPC permit is not a simple
administrative process. We have to make a detailed technical determination
of a site specific landfill proposal that, if approved, will be
relevant to that local environment for many decades. Noting this
and the landfill sector's difficulties with PPC-style regulation,
it is perhaps not surprising that in seeking to discharge our
obligations to the environment we sometimes find ourselves at
odds with some of the applicants. We have done our best to resolve
the conflicts without unnecessary expense, but there remain several
fundamental differences of view. These stem primarily from a lack
of clarity in the Directives, and it is necessary—and in
everyone's best interests—that these are resolved through
the formal mechanism of appeals or judicial reviews. We believe
that our revised generic landfill permit, developed in light of
experience and further understanding from Government, will lead
to the majority of operator appeals being largely resolved. We
do not accept that this process has been subject to "administrative
inefficiency".
2. The Government is currently consulting
on the content of the proposed Home Information Packs. Do you
believe a flood report for the property should be included within
these Packs?
27. Yes. Across England and Wales there
are over five million people in two million homes at risk of flooding,
yet two-fifths of people are unaware of the threat to their lives
and their property. We therefore believe an assessment of the
risk of flooding to a property is an essential element of the
conveyancing process.
— If so, would the Agency charge
for providing the relevant data?
28. We understand from our discussions with
ODPM that Home Information Packs (HIPs) will be provided by a
number of commercial organisations. We would charge for the incorporation
of our data in these commercial products based on their use of
our Intellectual Property.
29. As we understand it, the intention is
that HIPs will be provided in the form of commercial products
tailored to the needs of the vendor, rather than vendors making
individual enquiries to owners of specific data sets. It would
therefore be unlikely that we would be asked to provide data direct
to an end user for the purposes of HIPs.
— How does the Agency calculate
the charges it makes for providing data? Are individuals and businesses
charged the same rates?
30. We charge commercial royalties on businesses
who re-sell our data. We calculate such charges by reference to
market forces and in accordance with the Reuse of Public Sector
Information Regulations (ROPSI), the Treasury "Wider Markets"
initiative and other relevant competition law.
— Where else other than the Agency
can this data-if required-be obtained?
31. As the statutory body responsible for
managing flood risk, we have invested heavily in understanding
flood risk and we are recognised as the authoritative source of
flood risk information for England and Wales.
32. We currently license the data relating
to flood risk to many commercial providers of property search
products, many of whom we expect to become providers of HIPs.
All resellers of our data receive it on equal and transparent
terms (in accordance with the RoPSI Regulations and the OPSI's
Information Fair Trading Scheme).
33. Our flood risk information is also provided
to some 500 government, public and not-for profit bodies, including:
— Association of British Insurers,
and through them to insurance companies
— Central Government Departments
— Welsh Assembly and Government Offices
— Local Authorities for spatial and
development planning
— Emergency services and emergency
planners for planning and responding to floods
34. We make our information as widely available
as possible so there is a clear and consistent message on flood
risk from rivers and the sea in any location across England and
Wales, and that message is based upon the best available data.
3. To what extent is your increasing involvement
in policy-making a consequence of having to interpret broadly
written and poorly-defined primary legislation?
35. We feel that there is much that could
be done to codify and define the structure of regulation. We see
enormous advantages in developing a simpler, consolidated regulatory
framework that will reduce the burdens on both business and ourselves.
36. EU environmental legislation is often
drafted in "piecemeal" fashion, resulting in incoherence,
inconsistency and overlapping requirements. This can lead to primary
legislation that is poorly defined. As an example of confusion,
even the term "pollution"" is defined differently
in different EU Directives.
37. This has the effect that EU law is transposed
into national legislation in a piecemeal fashion and cannot be
easily integrated into existing legislation. Together, this silo
approach at EU and national level results in legislation that
is piecemeal, overly complex and leads to delayed or ineffective
implementation.
38. We believe that the EU should adopt
a common regulatory code for the environment. A common code could
cover such issues as definitions, permitting, consultation periods,
and monitoring arrangements. A first step would be to start with
Waste legislation. This would reduce the administrative and financial
burdens on the public and business, since the legislation would
be clearer and easier to understand. It would also make transposition
easier for Member States.
39. There is much that can be done at a
national level too. Again, the norm is for legislation to be developed
in separate regulatory silos. The result is a different format
each time, with different administrative requirements. A common
regulatory framework would avoid this.
40. We are now working with Defra on developing
a common regulatory framework for two major licensing systems[28]
from differing EU directives. We are seeking to extend this to
other regimes (and other EU directives) in the future.
41. Given the incoherence and inconsistencies
in legislation, the EA from time to time fills a policy void as
we have to take the regulations, apply them at an operational
level and make them fit real life situations. A purely legalistic
view cannot do this.
42. We think it is time to re-visit the
policy/delivery interface with Defra. We would like to see greater
delegation to the EA of operational policy and regulatory decisions,
for example exemption-making powers. We think this would allow
us to reduce inconsistencies across different regimes and increase
the effectiveness and responsiveness of the regulatory system.
It would also be more transparent to the public and business.
43. In the meantime, and based on our regulatory
experience, we have put forward numerous specific simplification
proposals, as potential regulatory reform orders, to improve specific
pieces of legislation.
4. How satisfied are you that Defra consults
you often enough in the initial stages of discussions?
44. We are encouraged that there is an increasing
commitment from Defra to involve us earlier in the decision-making
process. We are seeing improvement.
45. Historically, Defra regarded EA as merely
technical support and did not engage us in policy discussions.
In the past there was a difference in focus between Defra and
the EA with Defra's focus sometimes on avoiding infraction.
46. This can lead to a compressed timescale
to plan for implementation, additional administrative burdens
and increased business uncertainty.
47. However, as stated above, there is now
recognition of the need to bring the EA to the table earlier.
There have been two very positive initiatives. Firstly, a programme
and project management (PPM) approach has been introduced for
developing policy, regulation and negotiating positions. This
allows a more systematic involvement of key stakeholders, including
the EA at the earlier stages of policy development. Secondly,
we have signed a Concordat on EU & international Relations
with Defra, which encourages the earlier involvement of the EA
in EU decision-making.
48. We have already seen the benefits of
these approaches, for example, in the work on the revision of
the Emissions Trading Directive. In our experience, joint project
management has resulted in better working between the EA and Defra;
effective joint planning; open communication and a greater focus
on deliverables.
49. The initial PPM projects have been a
good step forward but for it to make a real difference, the discipline
of PPM has to be rigorously applied throughout Defra. It is not
sufficient for it to be adopted selectively.
5. The Committee received evidence that suggests
the Agency is failing to meet its deadlines for implementation
of the Habitats Directive. Why are you failing to meet your targets
on creation of saltmarsh and other wetland habitats?
50. Our annual flood risk management performance
to create saltmarsh and other Biodiversity Action Plan habitats
depends on the size and number of schemes being progressed in
any particular year. Consequently, there will be years when a
major scheme is completed and the target is more than achieved
and others when schemes have not yet delivered habitat increase.
51. For example, the Paul Holmes Stray managed
retreat scheme on the North shore of the Humber estuary in 2003
created 80 hectares of saltmarsh, whilst the Alkborough managed
retreat scheme (also on the Humber) will create about 400 hectares
of saltmarsh in the next two to three years. There will also be
years when schemes which, because of limited opportunities, create
only small areas of habitat creation are completed. The result
is a "spikey" performance and years when the 200 hectares
annual target is missed.
How can this be rectified?
52. We recognise that more needs to be done
to maximise opportunities and establish a more effective cumulative
habitat creation programme. To help with this, we are developing,
with English Nature's advice, detailed Regional habitat creation
targets. This will mean that habitat creation targets are built
into flood risk management programmes at an early stage and responsibility
for delivery is firmly delegated to a more local level, within
an overall national strategic plan. This should help to improve
delivery because up until now there have not been formal local
targets to deliver proactively, rather than just opportunistically,
the necessary actions.
Should Natural England have direct responsibility
for all Habitat Action Plans, with the Agency taking an advisory
role where these coincide with flood risk management responsibilities?
53. We recognise that the UK Biodiversity
Action Plan (UKBAP) process is a complicated one, but giving Natural
England direct responsibility for all 45 Habitat Action Plans
would not improve performance. This is because delivery would
still depend on actions by the operational organisations, which
have the biggest influence on specific habitats. The Environment
Agency leads on key wetland habitats since we have the biggest
influence on the key issues of water quality, quantity and flood
risk management. The current arrangement, whereby lead responsibility
reflects the influence of operating authorities such as the Environment
Agency, increases the chances of action being delivered, because
there is a corporate responsibility to deliver a Government target.
6. Further information on Environment Agency
Charging—how the EA responds to requests from business for
detailed information on the breakdown of charging, including details
of generic and web-based documents and specific responses.
54. The Environment Agency provides an extensive
range of communications and opportunities to discuss charges in
an open and transparent way:
a. Consultation document—this provides
details of the impact of cost increases on different types of
charges, for groups of chargepayers, and breaks down the various
elements of any charge increases.
b. Leaflets—where there are significant
changes to schemes or charges we send out leaflets with bills
for annual charges which provide an explanation of the reasons
for the changes and a breakdown of the elements which make up
any increases (see Annex A)[29].
c. Website—we publish detailed information
on the principles and processes involved in developing our charging
schemes and setting charges, as well as providing details of the
charges for each of our schemes. More specifically, regarding
the breakdown of our charges:
— For our main charging schemes, we
publish leaflets that break down the reasons and impact of any
charge increases.
d. Stakeholder fora—we engage with
our stakeholders through a number of standing groups (eg EP Charges
Review Group) and ad hoc meetings with trade associations (eg
ESA) where we respond to requests for information, including on
the make up of charges.
e. Specific requests—requests received
from individuals are usually concerned with the individual's own
charges. These are usually channelled through our National Customer
Contact Centre phoneline (NCCC), our Finance Departments (Exchequer
and Financial Accounting Service (EFAS) or EA Wales Finance) or
come direct to the Charges Team, either via stakeholder fora,
by e-mail (we advertise a specific e-mail query address in our
consultation documents and leaflets) or post.
Where a query relates to the basis or calculation
of the charge, this is usually dealt with by EFAS or EA Wales
Finance, with reference to local (Regional) Environment Officers
where the query is of a technical nature. Other charging queries,
or where the basis of the charge is disputed by the chargepayer
and cannot be resolved locally, are referred to the Charges Team
in Head Office for a decision and response. This ensures a consistent
approach and response to chargepayers.
Examples of recent specific requests
Received through stakeholder groups:
— COMAH Charging Review Group—breakdown
of the hourly charge out rate, supplied at the meeting on 26 October
2005 (Annex C)
— Advisory Committee on Packaging—presentation
to committee on 6 October 2005, breaking down the costs and charges
for producer responsibility (Annex D)
Received from individual chargepayers/businesses:
— Typical query received via the NCCC
re the method of charging for disposing of sewage effluent (Annex
E)
See the attached documents for more information
(please note that customer details have been removed from the
attached response to a typical query).
We believe we provide transparent information
about changes and how they are reached. Regulated industry may
not like the final outcome but they are fully involved in the
process.
Environment Agency
February 2006
28 The Environmental Permitting Programme is aiming
to combine the major licensing regimes of Pollution Prevention
& Control (PPC) and Waste Management Licensing. Back
29
Not printed. Available at: http://www.environment-agency.gov.uk/business/444669/587179/504799/508992/?version=1&lang=_e Back
30
Not printed. Available at: http://www.environment-agency.gov.uk/commondata/acrobat/costs_and_charges_1017235.pdf Back
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