107.The role of the OEP in scrutinising Environmental Improvement Plans (clause 14) has been discussed in Chapter 3. This Chapter discusses the scrutiny and advice functions set out in clauses 12, 15 and 16 and the enforcement functions in clauses 17 to 29.
108.Clause 15 sets out requirements for the OEP to monitor and report on environmental law. Professor Richard Macrory QC said this would provide a useful picture on the implementation and enforcement of environmental law in different areas. While nearly every EU Directive has systematic provisions to make reports, it has never been done before in UK environmental law. Professor Maria Lee from University College London, considered clause 15 could be very important, as it could open a dialogue with public authorities on whether they are taking the “most effective, most ambitious, most efficient way of implementing the law”. She suggested that it should be strengthened so that public authorities should be required to report on their ‘implementation’ of environmental law, which could then tie into the OEP’s investigation and enforcement mechanisms.
109.Professor Liz Fisher, from the University of Oxford, was concerned that the Bill placed greater onus on environmental improvement plans rather than environmental law, as the obligations in clause 15 are far less significant than those in clause 14 (monitoring and reporting on environmental improvement plans). She recommended that clause 15 be strengthened in-line with clause 14 to place a duty on the OEP to report on environmental law.
110.We heard concerns that the scrutiny and advice functions could overlap with existing bodies. Clause 12 requires the OEP to set out in its strategy how it intends to avoid any overlap of its monitoring, reporting and advising functions with those of the Committee on Climate Change (CCC). Chris Stark, chief executive at the CCC, said that while the scrutiny of climate change adaptation would be the main source of overlap between the OEP and the CCC, it would not cause a problem as long as the relationship is clearly laid out in “both the statute and in a memorandum of understanding”.
111.Emma Howard Boyd, Chair of the Environment Agency and Alan Law, deputy chief executive at Natural England, said that the role of their organisations in providing evidence to support the OEP’s scrutiny should also be set out in specific memoranda of understanding. When asked about the possible overlap with other bodies, Michael Gove said:
I do not think it will be a turf war. We have sought to delineate pretty clearly what functions the OEP would fulfil. As we say, some are functions that the Commission currently fulfils, and there is also learning from the experience of the Parliamentary Commissioner for the Environment in New Zealand and others.
Dr Coffey added that the OEP will be taking a more strategic role than looking at “individual decisions on one particular piece of advice or another”.
113.Further memoranda of understanding should be considered to avoid duplication of the scrutiny and advice functions of the Office for Environmental Protection and existing bodies such as the Environment Agency and Natural England. These need not be set out on the face of the Bill.
114.Clause 31(5) provides a delegated power to the Secretary of State to amend the definition of “environmental law” by regulations. Clause 16 requires the OEP to give advice to Ministers on any proposed changes to environmental law or any matter relating to the natural environment that a Minister requires. Debbie Tripley, director of environmental advocacy and policy at WWF, said this “could be bolstered” to mirror the way the CCC provides advice to Government. Instead of the OEP publishing the advice, it could be laid before Parliament, with the Secretary of State then having to respond and explain whether the advice will be followed, and give their reasoning. Yet Andrew Bryce, former Solicitor and Chair of UKELA, did not think it was appropriate for the OEP to be required to advise the Minister on environmental law matters as it could conflict with the OEP’s duties to complainants and in reviewing EIPs. He said it would be more appropriate for the OEP to be consulted on new environmental law proposals.
115.We recommend that clause 16 should require the Office for Environmental Protection to be consulted on any changes to environmental law, rather than having a duty to give advice. The Office for Environmental Protection’s response on changes to environmental law should be published, with the Secretary of State required to lay before Parliament a response to this advice.
116.Clause 17 sets out that the scope of the OEP’s enforcement functions relating to “failures by public authorities to comply with environmental law”. This includes “failing to take proper account of environmental law” or “unlawfully exercising, or failing to exercise, any function it has under environmental law”.
117.Professor Lee explained that she thought the scope for enforcement action was “very tightly drawn” and would leave “the OEP with little to get its teeth into”. She said under these provisions, as with judicial review, the threshold for failure will be dominated by questions of procedural lawfulness. Andrew Bryce agreed clause 17 was “unduly restrictive”. Professor Scotford, from University College London, was also concerned that enforcement would be limited to administrative compliance (the Wednesbury test), rather than achieving environmental standards, which she said was a departure from the enforcement procedure of the European Commission.
118.Another departure from the Commission’s approach is that the Bill makes individual public authorities responsible, rather than the Government as a whole. Professor Scotford said, since environmental problems are often collective with multiple causes and multiple agencies needed to remedy breaches, it was “strange” to make individual public authorities accountable. She recommended that the enforcement functions should make the Government accountable as this “focusses minds and resources at the highest level” and is what makes the current enforcement mechanism by the European Commission so powerful. Tim Buley QC, barrister at Landmark Chambers, agreed with collective accountability for collective environmental problems, and the UK Sustainable Investment and Finance Association (UKSIF) said it should then be for the OEP to determine whether Government or another public authority is responsible. Professor Macrory argued that an additional power to direct its enforcement action at the Secretary of State would be “invaluable” to ensure that the OEP is focused on systematic or very serious breaches.
119.We asked the Minister whether it would be better to make the whole of Government responsible for complying with environmental law, as is the case with the European Commission. Dr Coffey said that from the European Union perspective, “it is the UK Government, but in effect it is the Department [Defra] that is responsible for that [and] will respond to and in fact lead on any infraction proceedings”. She added that it could be either a Department or public body:
The intention is that the OEP has the possibility to go further and hold all public bodies accountable, but they do not have to. There could be an element of their choice.
120.As drafted, the definition of failure to comply with environmental law narrows the scope of the Office for Environmental Protection’s enforcement powers to look solely at process. It does not achieve equivalence with the European Commission’s powers, nor does it reflect the integration principle.
122.We recommend that clause 17 sets out that the Office for Environmental Protection’s enforcement functions relate to failure to achieve environmental targets and standards (the framework for which will be established in part two of the Bill), rather than questions of administrative compliance. Government as a whole should be accountable for the achievement of environmental standards and targets, rather than individual public authorities, as is the case with the European Commission’s infringement procedure. This would require different areas of Government (central Government, local Government and public bodies) to work together cooperatively to address an environment problem. We welcome the Ministers’ acknowledgement that the Office for Environmental Protection will be able to decide which authority is responsible and take enforcement action.
123.The European Commission allows individuals to raise complaints on breaches of EU law free of charge. Clauses 18 and 19 set out the OEP’s complaints process. A person may make a complaint to the OEP if they believe a public authority has failed to comply with environmental law. The OEP will then investigate to ascertain whether the public authority has failed to comply with environmental law and the failure is ‘serious’.
124.As in clause 17, we consider that it should not be for the individual to decide which authority is at fault or what law has been breached. UKSIF said the individual should be able to approach the OEP with what s/he believes is an illegally poor environmental outcome, and it should be for the OEP to then investigate and determine whether the Government or another public authority is responsible.
125.We also heard that the threshold for determining failure was significant. Professor Fisher explained:
Just the threshold, “serious”, again that is a word open to interpretation, but it is not just that it is serious. It is also that it “must indicate”—so the complaint must indicate, it is not just an allegation. It must be that the complaint put in indicates that there has been a serious breach of environmental law, which again is quite a significant hurdle.
126.Professor Fisher said that the Human Rights and Equality Commission can investigate alleged conduct. Andrew Bryce and Professor Macrory said that to minimise disputes between complainants and the OEP as to what is or is not serious, the consideration of complaints should specifically link to OEP’s enforcement policy. This would give a clearer indication to members of the public of the types and nature of complaints it is likely to investigate.
127.The National Trust was concerned that while the OEP is given the power to “do anything” it considers appropriate in accordance with its function, it is not given a specific power of investigation that the European Commission has. The explanatory notes state that the OEP can take enforcement action, “if it has some other reason to suspect there has been a serious breach (for example, based on information presented in a report on the implementation of a law, or arising from a parliamentary inquiry or other source)”. Yet this is not set out on the face of the Bill. Greener UK recommended that the OEP should have the power to undertake formal investigations into potential breaches of environmental law and the power to conduct inquiries into systemic problems.
128.The enforcement procedure is also constrained by a 12 month time limit for complainants to make a complaint (clause 18(6)), which is not the case with complaints to the European Commission. Yet there is no time limit for the OEP, between receiving a complaint and acting, or between receiving a response to an information notice and taking further action. This is a serious and significant weakness.
129.Clause 21 sets out how the OEP should coordinate its activities with other bodies that have an investigative remit, such as the Local Government and Social Care Ombudsman (LGSCO) and the Parliamentary and Health Service Ombudsman (PHSO). It requires the OEP and these bodies to jointly prepare a memorandum of understanding (MoU) regarding the coordination of investigations. The LGSCO and PHSO agreed that there could also be an overlap as complaints may not fall neatly into one category. However, they considered that the requirement for a MoU should not be on the face of the Bill as it would probably be on a case by case basis. Instead the Ombudsmen told us that the OEP should set out how it would avoid overlap - in the same way as the need to avoid overlap is set out with the Committee on Climate Change - in clause 12. They recommended that the OEP should be required to publish its criteria for investigation, along with a requirement to consult on and review those criteria at regular intervals so they can be adjusted in light of operational experience.
130.Serious damage may sometimes take years to become apparent. We cannot understand the justification for a time limit on complaints. This is not used by the European Commission and should be removed. Clause 18(6) which specifies time limits to complaints and 18(7) which says that out of time complaints can be considered in exceptional circumstances, should be removed.
131.Clause 19(1) should provide a power for the Office for Environmental Protection to be able to instigate its own investigations and not just those that it receives a complaint on. It should also be able to investigate alleged breaches rather than those that are, in its view, ‘serious’. Clause 19(1) should have the following subclause added: “(c) and is consistent with its enforcement policy”.
132.Clause 12(3) requires that the Office for Environmental Protection must set out how it will avoid any overlap in functions with the Committee on Climate Change and a similar duty should be included to set out how it will avoid any overlap with the Local Government and Social Care Ombudsman and Parliamentary and Health Service Ombudsman complaints-handing functions. The Office for Environmental Protection should also be required to consult on, publish and review its criteria for investigation.
133.The enforcement process against public authorities begins with an information notice. The recipient of an information notice must respond in writing and provide the OEP with the information requested in the notice within two months or by the date set. If the OEP is satisfied that on the balance of probabilities an authority has failed to comply with environmental law and this failure is “serious”, it will be able to issue a decision notice. This sets out the steps the OEP considers the public authority should take in relation to the failure (this may include actions to remedy, mitigate or prevent reoccurrence of that failure). The authority will be required to respond to a decision notice in writing within two months, but it will not be compelled to carry out the steps detailed in the notice. As a final step, the OEP may apply for judicial review from the High Court (in England, Wales and Northern Ireland) or an application to the supervisory jurisdiction of the Court of Session in Scotland.
134.Many witnesses suggested that the enforcement powers of the OEP are limited or narrow. We heard that the combination of clause 17, the failure to comply with environmental law, and the enforcement procedure in clause 25, mean that many environmental obligations of result (such as achieving good water status or air quality standards) do not come within the scope of its enforcement provisions.
135.Several witnesses were concerned that the “review” proposed under clause 25 looks at whether the original conduct of the public body was a breach of environmental law, not at the decision notice or the failure to comply with it. ClientEarth said that this “is a very weak enforcement power” and “may even be narrower than simply bringing a traditional judicial review”. Professor Macrory said the use of judicial review as a final step is not equivalent to the way the European Court of Justice (CJEU) approaches infringement cases.
136.Judicial review is concerned with the interpretation of law and whether the right procedures have been followed, rather than the outcome of a process and whether those were ‘right’, (the Wednesbury test). Professor Macrory explained that the CJEU is prepared to apply a proportionate approach and engage in quite complex evidential issues, rather than just looking at the process of the decision. He suggested that the Government had chosen to use judicial review as it is what it is most comfortable with; “they know the limitations and the courts will not go too far”. Dr Tom West, Law and Policy Advisor, from ClientEarth explained that the drawbacks to judicial review are underlined by the court cases brought by ClientEarth against the Government on air quality, where even though there has been action, the UK is “still in breach of air quality limits”. He was also concerned that claimants may have to have exhausted the OEP’s procedures before being able to bring their own judicial review.
137.We asked Michael Gove whether it would be better to comply with environment standards rather than procedural correctness. He considered environmental standards could be upheld by the OEP:
No, I think if we fail, then it is clearly the case that we can be challenged by the OEP and, if necessary, taken to court.
138.We heard that there will be strategic policy failures that can be dealt with over a period and those where an urgent remedy may be required. Tim Buley QC, from Landmark Chambers, and Professor Fisher said it may be inappropriate to try to design “a one-size-fits-all mechanism for enforcement” since failure to comply with environmental law comes in many different forms.
139.The UK Environmental Law Association (UKELA) told us the proposed notice procedures are very slow, with two-month time periods for response. It said that if a breach is serious or ongoing, this could be too long a delay before court action can be taken by the OEP. Tim Buley agreed that since the time limit for judicial review is very strict, “three months ordinarily, six weeks in some environmental contexts”, it would not be appropriate to have it at the end of the process while the OEP has been conducting its investigation and the harm may have already happened. UKELA supported the OEP having a power to make an emergency application for judicial review and Tim Buley said the OEP should have the ability to bring a judicial review at the start of the process. Professor Macrory outlined that it would be helpful for the OEP to have an additional power to be able to intervene in environmental judicial reviews undertaken by other parties. He said that the Equality and Human Rights Commission (EHRC) which has such powers under Equality Act 2006, has made very effective use of them.
140.Natural England and many environmental organisations supported making decision notices legally binding. ClientEarth said that the Government had claimed this would be inappropriate, but pointed out that there is already precedent as both the EHRC and Information Commissioner’s Office have comparable powers. Professor Macrory cautioned against binding notices as he thought this could encourage litigation, when the aim should be to resolve cases out of court (90 per cent of cases at the European Commission are resolved out of court through discussion with Member States). He said that, provided the measures in the Bill (information notice, decision notice and judicial review) were ratcheted up over time, then there was no need for binding notices. When asked whether the Government would consider binding notices, Dr Coffey stated that it would completely undermine regulatory independence if the OEP were to overrule a regulator such as the Environment Agency.
141.The Government has chosen not to include fines within its enforcement process. We heard mixed views on fines, with some supporting their use as a deterrent and to achieve equivalence with the CJEU process, and others cautioning that this would take resources away from public bodies. Professor Macrory explained that the CJEU issues fines for failure to comply with its judgments, rather than having a direct power to fine. He said it is “like contempt of court” and that there are sufficient powers in the courts to hold the Government to account. Yet Professor Macrory claimed that the Government’s proposals “lack imagination” and said the Government should create something new, avoiding “all the baggage of [judicial review]”. ClientEarth also argued that a bespoke enforcement process was necessary.
142.Professor Macrory suggested that the role of the First-tier Tribunal, which deals with appeals from executive agency decisions, could be expanded and included as a step in enforcement before reaching judicial review (see box). He added that it has a much more informal procedure which means it can resolve things “very quickly if need be”.
The Tribunal System
The current tribunal system is part of the court system and was created in 2008. It consists of two main tiers: The First-tier Tribunal and the Upper Tribunal.
The First-tier Tribunal currently consists of seven chambers structured around subject areas. Environment is dealt with in the General Regulatory Chamber which handles appeals in about 44 areas of environmental law. The tribunal combines legal members with expert members, who have expertise in environmental science.
The First tier Tribunal currently handles appeals against decisions made by local authorities and Government regulatory bodies. This includes appeals against civil sanctions issued by the Environment Agency, Natural England or another regulator. There are 28 days to appeal a decision. The full written decision by the tribunal is usually provided within four weeks of the hearing.
The Upper Tribunal generally hears appeals arising from the First-tier Tribunal. The Administrative Appeals Chamber hears all appeals from the General Regulatory Chamber including appeals from the environment tribunal. Appeals to the Upper Tribunal are only available on a point of law. It has the equivalent status to the High Court, meaning that it can both set precedents and enforce its decisions. It is also the only tribunal to have the power of judicial review. Appeals from the Upper Tribunal are to the Court of Appeal.
143.Tim Buley explained two possible ways an expanded environmental tribunal approach could work:
144.The first option would be more in line with the current European Commission procedure, whereas the second may suit the Government, as Ministers have said they do not want the OEP to issue binding notices. ClientEarth supported an approach between the two options, where the OEP issues binding notices with a range of possible sanctions, the public authority must then comply with these or set out proportionate reasons why not. The onus would then be on the OEP to challenge the decision not to comply with the notice at the tribunal. The tribunal would then undertake a substantive review of the authority’s decision not to comply with the notice. ClientEarth argued that this bespoke enforcement procedure would allow for a more thorough review of decision-making:
While the ambition is always for matters to be resolved through mutually agreed solutions arrived at via transparent and deliberative processes, it must also contain the possibility of harder legal measures.
145.Tim Buley noted that the benefit of a tribunal is that it has expert members who would be able to conduct their own factual findings. Professor Macrory said the tribunal should be able to consider both whether there has been a breach of environmental law duties (if there is still an issue) and the credibility and timeliness of the steps being taken to deal with the failure. He added that if the First-tier Tribunal approach was adopted then it would be sensible to include an explicit provision that failure to comply with a decision of the tribunal could amount to contempt and be referable to the Upper Tribunal (for a precedent see The Data Protection Act 2018). He also suggested another option instead of using the First-tier Tribunal, where the OEP could go straight to the Lands Chamber in the Upper Tribunal which has the status of the High Court.
146.We asked Michael Gove whether he was considering an expanded role for the First-tier Tribunal. He said it was “genuinely arguable whether that is a more effective means of providing justice”, and that the Government had sought to replicate an easily understandable process, as far as possible.
147.As we have already set out, the Office for Environmental Protection’s enforcement procedure does not achieve equivalence with the European Commission’s powers as it is limited to administrative compliance rather than achieving environmental standards and outcomes.
148.We recommend that, following the changes suggested to clause 17 (that the enforcement mechanism must go beyond that of traditional judicial review), the references in clause 25 to judicial review should be deleted and 25(1) should refer to failing to achieve environmental targets and standards set out in section 17.
149.A one-size-fits-all approach to enforcement is not appropriate since the failure to comply with environmental law comes in many different forms. The procedure set out in the Bill is also slow and could preclude other, swifter forms of enforcement and remediation.
151.Overall, the enforcement procedure lacks imagination and the Government must consider alternative mechanisms. We have heard compelling evidence that there should be an expanded role for the First-tier Tribunal. This would help to resolve more cases before the need to apply for judicial review.
152.We recommend the Government looks further into a bespoke enforcement procedure and an expansion of the role and remit of the General Regulatory Chamber in the First-tier Tribunal. For example, where the Office for Environmental Protection is able to issue notices (at first advisory, then latterly binding) with a range of compliance recommendations, to which the public authority must then comply, or set out proportionate reasons why not. The Office for Environmental Protection would then be able to challenge a decision not to comply with the notice at the tribunal. The tribunal would undertake a substantive review of the authority’s decision not to comply with the notice. Any failure to comply with a decision should amount to contempt and be referable to the Upper Tribunal. Section 202 of the Data Protection Act 2018 provides a useful guide as to how this could be achieved in the legislation.
153.Clause 26 sets out that any person whose functions are of a public nature must cooperate with the OEP in connection with an investigation, and information and decision notices. Professors Lee and Macrory said there should also be an obligation on public authorities to cooperate specifically in respect of monitoring and reporting on the implementation of environmental law (clause 15), since the OEP may require information from them to carry out its duties.
154.Clause 27 seeks to enable public authorities to share information with the OEP, however it is limited to the OEP’s enforcement functions. UKELA recommended that the power should be extended to clauses 14, 15 and 16 to enable the OEP to have all relevant information in performing its scrutiny functions. Greener UK said it was important that the OEP has the power to require information from competent bodies, especially where this relates to information that may be commercially sensitive or not in the public domain. The LGSCO and PHSO were concerned that restrictions within their respective legislative frameworks would constrain their ability to share information with the OEP. They recommended that clause 27 be amended to also cover the OEP’s function to investigate complaints under clause 19. This would ensure the relevant provisions in the Local Government Act 1974 and the Parliamentary Commissioner Act 1967 amount to an obligation of secrecy within the meaning of clause 27.
155.Clause 28 sets out the prohibitions on disclosure of information. The LGSCO and PHSO said that clause 28 could inhibit coordination of investigations between themselves and the OEP. They recommend clause 28 is amended to include reference to the provision of information which facilitates coordination between LGSCO, PHSO and the OEP.
193 Oral evidence taken before House of Lords Select Committee on the European Union Energy and Environment Sub-Committee 6 February 2019
194 Professor Maria Lee ()
195 Professor Maria Lee ()
196 E.g. ; see also ClientEarth ()
197 National Farmers’ Union ()
198 Clause 12(3)(b)
204 See also Agricultural Law Association ()
205 Andrew Bryce (); see also Emeritus Professor of Environmental Law Richard Macrory ()
206 Clause 17(2)
207 Professor Maria Lee ()
208 Andrew Bryce (); see also UK Sustainable Investment and Finance Association ()
209 , Thomson Reuters practical law.
210 ; ; Professor Eloise Scotford (DEB0095)
212 Professor Eloise Scotford ()
214 UK Sustainable Investment and Finance Association ()
215 Emeritus Professor of Environmental Law Richard Macrory ()
218 Clause 19(1)
219 UK Sustainable Investment and Finance Association (); Professor Eloise Scotford (DEB0095)
220 UK Sustainable Investment and Finance Association ()
221 ; see also Unicef UK (); RSPB (); Newcastle Law School ()
223 Emeritus Professor of Environmental Law Richard Macrory () and Andrew Bryce (); Clause 12(3) says that the OEP will set its complaints and enforcement policy
224 Emeritus Professor of Environmental Law Richard Macrory ()
225 National Trust ()
226 Explanatory note clause 22
227 Greener UK ()
228 The Woodland Trust (); Subsection 7 provides that in exceptional circumstances the OEP may consider a complaint made outside of this time limit
229 UK Sustainable Investment and Finance Association ()
230 LGSCO and PHSO (); The OEP’s remit is to investigate breaches of environmental law and their respective jurisdictions investigate maladministration or service failure
231 LGSCO and PHSO ()
232 Clause 22
233 Clause 23(2)
234 Clause 23(3) and 23(4)
235 Clause 25(3)
236 E.g. [Professor Macrory] Aldersgate Group (); Brexit and Environment (); ClientEarth (); Greener UK (); Unicef UK (); APPG on Air Pollution (); National Trust (); Newcastle Law School (); Professor Maria Lee (); WWF (); UKELA ()
237 Professor Eloise Scotford (DEB0095)
238 ; UKELA (); See also ClientEarth (); ClientEarth ()
239 ClientEarth (); see also [Andrew Bryce]
240 Emeritus Professor of Environmental Law Richard Macrory ()
241 UKELA Conference. A First Response to the Environment Bill: The New Body, the Courts and the Future of UK Environmental Law. 14 Jan 2019; Emeritus Professor of Environmental Law Richard Macrory (); , Thomson Reuters practical law.
242 Emeritus Professor of Environmental Law Richard Macrory (); See also [Tim Buley]
244 ClientEarth has taken the Government to court three times since 2010 as a response to the UK’s failure to meet the requirements of the EU’s Ambient Air Quality Directive which came into force in 2008.
245 Oral evidence taken before House of Lords Select Committee on the European Union Energy and Environment Sub-Committee 6 February 2019; see also
246 ClientEarth (); see also
248 ; see also [Tim Buley]; WWF ()
249 ; ;
250 UKELA ()
251 ; see also [Dr David Wolfe]
252 ; UKELA ()
253 Emeritus Professor of Environmental Law Richard Macrory (); Equality Act 2006 section 30
254 Natural England (); APPG on Air Pollution (); Greener UK (); Newcastle Law School (); Professor Maria Lee (); WWF ()
255 ClientEarth ()
259 Environmental Services Association (); Wyeside Consulting Ltd (), Wildlife and Countryside Link ()
260 ; Environment Agency (); Newcastle Law School (); UKELA ();
262 ; UKELA Conference. A First Response to the Environment Bill: The New Body, the Courts and the Future of UK Environmental Law. 14 Jan 2019
263 ClientEarth ()
264 [Professor Macrory]
265 [Professor Macrory]
266 The gives the Environment Agency and Natural England (the regulators) the power to impose civil sanctions for a range of environmental offences. Civil sanctions include compliance notices, restoration notices, enforcement undertakings, fixed monetary penalty notices, stop notices.
267 HM Courts and Tribunals Service. 2015.
268 Tribunals, Courts and Enforcement Act 2007, .
272 ClientEarth ()
273 ClientEarth ();
275 Data Protection Act 2018, ; Emeritus Professor of Environmental Law Richard Macrory (); see also [Debbie Tripley]
276 Emeritus Professor of Environmental Law Richard Macrory ()
278 Clause 26 (1)
279 Professor Maria Lee (); see also Emeritus Professor of Environmental Law Richard Macrory (); see also National Trust ()
280 LGSCO and PHSO ()
281 UKELA (); see also Aldersgate Group () and Emeritus Professor of Environmental Law Richard Macrory ()
282 Greener UK ()
283 LGSCO and PHSO ()
285 LGSCO and PHSO ()
Published: 25 April 2019