Select Committee on Environment, Food and Rural Affairs Written Evidence


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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