Memorandum submitted by Dairy UK
EXECUTIVE SUMMARY
Dairy UK represents milk processors, co-operatives
and bottled milk buyers throughout the UK.
Dairy UK believes that the Environment Agency
is improving in its role as enforcer of environmental regulation
and controls and largely aims to forge good relations with industry.
However, in certain regulatory areas, Agency fees are excessive.
The number of complex forms that members are required to submit
is reducing. There is an inconsistency of service from the Agency
at local level; however, this issue does not arise at central
level within the organisation. It is seen that levels of compliance
are not proportional to risk.
Evidence was requested on the following points:
— how successful the Environment Agency
has been in its role as enforcer of environmental regulation and
controls, and how well it manages its wide range of activities;
1. The view of Dairy UK is that the Environment
Agency is improving in this role and in the way it manages its
activities.
— whether the Agency operates efficiently
and provides good value for money;
2. It is the view of our members that the Environment
Agency does not provide good value for money. Too much of its
income is generated from industry. This is not in proportion with
the pollution risk that is posed by our members. Members experience
excess bureaucracy and additional costs in varying permits, alongside
high annual fees.
3. Our members believe that the ongoing fees
of the two main schemes, Pollution, Prevention and Control (PPC)
and EU Emissions Trading Scheme, are excessive.
— the Agency's relationship with non-Governmental
stakeholders and the general public, and how the Agency monitors
satisfaction with its services;
4. It is seen that the Environment Agency is
making it easier for industry to work with them. For example,
forms have become clearer and more user friendly. It is the experience
of Dairy UK that the Agency, at a policy and management level,
is willing to work with the industry body in a helpful and consistent
way. However, at a local level Agency staff is highly inconsistent
in terms of policy implementation and attitude and sometimes lacking
in interpersonal skills.
5. Dairy UK believes that the Environment Agency
should adopt a more consultative approach to pollution prevention,
rather than the current blunt legislative tool. Future regulations
should be proportional to risk.
6. Members report that the MCERTS tool is over
burdensome for business and does not focus on relative risk and
involves excessive implementation and replacement costs.
7. Within the EU ETS only 5% of EU ETS installations
are responsible for 80% of emissions within the scheme. Installations
caught by EU ETS in the dairy sector are an extremely small part
of the wider scheme, but are still burdened with over regulatory
compliance measures that have been designed with the top 5% installations
in mind.
Dairy UK
December 2005
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