INTRODUCTION

  (1)  The Quarry Products Association (QPA) represents the aggregate quarrying industry in the UK. Our members produce over 90 per cent of aggregates (sand and gravel and crushed rock) quarried in the UK. Our members have day to day dealings with the Environment Agency for many facets of their operation:

—  abstraction of water from quarries for dewatering and/or for processing uses

—  use of water in processing plants

—  discharge of abstracted or used water to water courses or aquifers

—  control and licensing of landfill

—  safeguarding of water courses

—  various air pollution and health and safety functions

  The need for an efficient and consistent approach by the Environment Agency are of considerable interest to QPA members. We thus have the following key points to offer.

DETAILS

  We have studied the report of the CBI—"Shaping Up—Report of the Environment Protection Survey"—June 1999 and find its conclusions consistent with the views we are receiving from our members in relation to the Environment Agency. We single out the following issues with which we particularly have common ground, supported by substantial evidence from the experiences of our own members.

CONSISTENCY

  Our members constantly encounter inconsistencies of approach between different EA regions. For companies which operate UK wide this clearly creates problems. Equally for our smaller member companies who are in direct competition with each other it is unfair for one in one EA region to receive a different control, enforcement and penal regime from the other in a different EA region. There is a need for a serious effort by the EA to co-ordinate its policy and control approaches for each of its functions country-wide.

  Our members also report considerable differences of approach between the various EA regions in both determination of waste management licence applications and in determining what requires a waste management licence. This is unacceptable.

FUNDING

  There is a need for a more transparent approach to implementing the various Agency charges to ensure that EA charges are fair. For instance it needs to be seen that charges for discharge licences are not being used to cross subsidise, for instance, waste licensing.

LICENSING

  Notwithstanding our concerns on funding there is a need for the EA to ensure prompt responses on applications for various licences and consents. Our members frequently ask us to intervene on their behalf where abstraction, discharge and waste management licences have been delayed. Unlike the planning system there does not seem to be any fall back appeal procedures when licences are delayed. Our members report increasing delays caused by EA in these respects.

ENFORCEMENT

  As stated above, there is a need for much greater consistency of enforcement between EA regions both in terms of policy application and staffing.

CONCLUSIONS

  Our members acknowledge that the Environment Agency is a relatively new creation. Most of its staff however were inherited from its predecessor bodies and should be experienced.

  There should be no reason why standards of policy application and of approach cannot be co-ordinated nation-wide as a matter of urgency. There should also be proper provision in the Agency's procedures for appeals in particular where licences/consents/authorisations are delayed or withheld. The Agency falls back on the precautionary principle far too often, seemingly to cover the inexperience of the case working staff. There is a need for both more professional, expert staff and for those to have greater commercial awareness. We would be happy to provide more evidence of some of these concerns if requested.

October 1999