Memorandum submitted by Prudential Property
Investment Managers Limited
INTRODUCTION
1. We welcome the opportunity to submit
evidence on a number of two of the Committee's terms of reference:
The structure, governance and accountability of
the Agency
2. In our experience there is a lack of
clarity as to the scope of the responsibility which the Secretary
of State for Environment, Food and Rural Affairs has for the work
which the Environment Agency carries out. In respect of a recent
matter relating to the Agency's role in the planning process we
wrote both to the relevant minister within DEFRA and the relevant
minister within the ODPM. In the same post we received responses
from both, each indicating that the other Department was the appropriate
Department to address the issue.
3. The Agency has an important role to play
with regard to delivery of the Government's sustainable communities
programme. In view of this role it is right that the ODPM as well
as DEFRA should have oversight of the Agency's activities, but
there should be close co-ordination between both Departments so
that issues do not fall between the cracks.
The Agency's relationships with DEFRA, DEFRA-sponsored
bodies and the rest of Government, including the Agency's role
in the planning system
4. The Agency has an advisory role with
regard to planning matters. Paragraph 18 of PPG25 states that
the "Environment Agency has a supervisory duty for all matters
relating to flood defence".
5. In our experience, the Agency interprets
its role as wider than that of a provider of expert advice, but
will on occasion, where it is sufficiently concerned as to a proposal
or its policy implications, actively seek to ensure that the Government
and local planning authorities accept the Agency's standpoint
on the matter, without regard to the need to balance the issues
with which the Agency is properly concerned against other considerations.
This approach is potentially harmful to the democratic process
and to the achievement of national and local planning policies
in so far as a variety of considerations will need to be taken
into account in respect of any major development proposal, some
of which fall out with the Agency's remit.
FURTHER INFORMATION
6. We would be happy to discuss these issues
in more detail or provide more detailed supplementary evidence
if this would assist.
Prudential Property Investment Managers Limited
December 2005
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