THEMATIC STRATEGY ON SOIL PROTECTION (13401/06)
Letter from the Chairman to Lord Rooker,
Minister of State for Sustainable Farms and Food, Department for
Environment, Food and Rural Affairs
At its meeting on 22 November 2006 Sub-Committee
D considered your Explanatory Memorandum dated 17 October 2006
on this subject.
We share the concerns which your EM expresses
about these proposals. Indeed, we remain to be convinced of the
need for regulation—as distinct from training and education—in
this area.
We share your concerns also about the costs
which are likely to be involved and we note that you are commissioning
a Regulatory Impact Assessment. Your EM states that "an initial
view suggests that the Commission has underestimated implementation
costs." In fact, the Commission document itself states (Paragraph
10) that the costs could be in the region of €250 million
a year during the first 25 years of the Directive's life and that
only thereafter would they fall to the €2 million mentioned
in your Explanatory Memorandum. These are very significant costs
indeed and we would be interested to hear whether your RIA confirms
them.
In the meantime we shall be retaining this proposal
under scrutiny and would be grateful if you would forward a copy
of the RIA when it is available.
22 November 2006
| 
