Letter from Lord Tordoff, Chairman of the Committee,
to James Clappison, MP, Parliamentary Under-Secretary of State,
Department of the Environment
The European Communities Committee and its Sub-Committee
C (Environment, Public Health and Consumer Protection) have considered
the Commission's Green Paper on Noise and your Explanatory Memorandum
of 10 December 1996. We have also seen the Report by the House
of Commons' European Legislation Committee
We consider that the Green Paper raises a number of important
issues which might well merit an enquiry at a later stage. In
particular, the application to the Commission's proposals of the
principle of subsidiarity will require critical examination,
since, as the Memorandum says, they open up a new field of potential
Community action. We agree with the Government that for the most
part dealing with noise is a matter for national and local initiative.
However we feel it would be an over-simplification to dismiss
the idea of a Directive on noise assessment and possible noise
exposure targets as being per se contrary to Article 3b
of the Treaty. There are also competition and single market considerations
to be taken into account. Indeed, successful pursuit of the policy
of integrating environmental considerations into other areas of
policy - such as health, for instance - must, in our view, inevitably
lead to some enhancement of the Community role in setting common
standards which nevertheless respect relevant national cultural
differences.
Like the Government and the Commons' Committee, we are very
concerned about the absence of any proper scientific and cost-benefit
analyses to support the Commission's proposals. We too would wish
to see the results of the assessments by the Department of Trade
and Industry, including a formal compliance cost assessment, as
soon as they are ready. Depending on the conclusions from this
further work, we recommend that the Government should discourage
the Commission from proceeding too far with its consultation exercise
without first having produced a much more rigorous scientific
and technical justification for its proposals, and a proper assessment
of the costs and benefits to the Community and to Member States.
The unsatisfactory standard of argument in the document also
raises the question whether the Commission has the capacity, with
all its other commitments, to enter this new territory at the
present time.
Meanwhile, we are maintaining the scrutiny reserve on this
document, at least until we have had an opportunity to study
the information commissioned by the Commons' Committee from the
Parliamentary Office of Science and Technology.
7 February 1997
Letter from James Clappison, MP, Parliamentary Under
Secretary of State, Department of the Environment to Lord Tordoff,
Chairman of the Committee
Thank you for your letter of 7 February, reporting on consideration
of the EC Green Paper on future noise policy and related documents
by the European Communities Committee and its Sub-Committee C.
I have noted the Committees' concerns, particularly on subsidiarity
and the lack of scientific and cost-benefit justification for
many of the Green Paper proposals. Our formal response to the
Green Paper will reflect the strength of concern expressed on
these issues. We will also be expressing concern to the Commission
that the assumptions underlying the Green Paper proposals fail
to take account of the complex interaction between noise and
health. Your Committee will see that this point is made in the
Parliamentary Office of Science and Technology paper. Our response
to the Commission will describe our own proposal to seek a consensus
view on the health impacts of noise from scientific experts and
to identify further areas for research in this area. Investigation
of noise and health issues by the Commission as part of its suggested
enhanced role in relation to research and exchange of best practice
could usefully complement our own national action.
I will of course keep the Committee informed of the future
progress of the Green Paper, following submission of our formal
response in March, and is made aware of any further information
that becomes available.
20 February 1997
