This Confederation represents UK Coal Producers who collectively are responsible for more than 90 per cent of the UK total annual coal production.

  It has not been possible to collect data in sufficient volume to produce the suggested six pages of A4 script. Suffice it to say that, in summary, members' consensus could be confined to a single sentence—The Environment Agency does not work for the UK Coal Industry!

  However, I will continue in more formal vein.

  The Confederation welcomes this opportunity to comment, and also notes with satisfaction that the Select Committee has appointed Dr David Slater and Mr Stephen Tromans as specialist advisers.

  Confederation members note that The Agency is described as a "non-departmental public body" (NDPB) and as such does have broad freedom to exercise its responsibilities within a clearly defined framework. It is considered that this "broad freedom" is used to the disadvantage of commerce.

  The Board of the Agency is appointed by Ministers and to whom the Board is accountable, but as a public body the Agency is ultimately responsible to Parliament, through the Secretary of State for the Environment.

  This Confederation believes that direct links with the public and commerce for consultation and feedback of information are weak and ineffective.

  It may be of little interest, but this office for example has never been contacted by the Environment Agency's Regional Representative. The Regional General Manager is supposed to be the "link man", but we do not consider that this contact is sufficient, nor is it "policed" by the Agency's head office.

RESOURCES AND FUNDING

  We find it confusing that the Agency spends 44 per cent of its total allocation on flood defences, and that 74 per cent of this originates from "charging schemes". As an NDPB it is not unusual that such a large proportion of its available revenue should be channelled into what is after all a national responsibility?

PERFORMANCES AND TARGETS ETC

  Under the umbrella of "Climate Change", the Confederation notes that CO2 reduction still features as a target item and that The EA intends to continue to reduce CO2 emissions and will introduce new incinerators and power stations, counteracted by the closure of coal-fired power stations around the country.

  We have not been consulted in any way—are Government aware of this strategy?

  It does not conform to the findings of the White Paper nor the "diverse, secure and sustainable" format indicated therein.

  The Confederation's motto is "Consultation, not confrontation" and we believe the lack of consultation with the major industrial players in the UK is one of the greatest failures to be placed at the door of The EA. As members of the CBI, the Confederation have consulted on The EA operations and it is apparent that the UK coal industry is not alone in its condemnation of this lack of co-operation.

  Perhaps Government did not provide an adequate brief when establishing The EA but it is quite clear that without "sharp end" contribution, the work of The EA will always be suspect—in The EA's annual report covering 1998-99 they refer, on page 22, to "the need for collaboration".

  We are always available to collaborate!

  The ball is in The EA court!

CLIMATE CHANGE

  The Confederation notes The EA's intention to address climate change more thoroughly when Government has fully developed its Climate Change Programme. We can only re-iterate what we have already mentioned earlier—any programme or further research undertaken by The EA should include collaboration with the UK coal industry.

  The main gases in the earth's atmosphere are:

Nitrogen	78 per cent
Oxygen	21 per cent
Argon	0.9 per cent
CO2	0.03 per cent

  In the 1950's UK coal burn was over 250 million tons. In 1998 this figure had fallen to 63 million tonnes. Since 1994, global CO2 has increased by 0.4 per cent. The UK coal burn in the same period reflects the 1950-1998 statistics—a 75 per cent reduction. It is obvious therefore that as far as the UK is concerned, continued "blame" for CO2 emissions cannot be laid at coal's door!

  Further supportive statistics are available but not included with this memorandum.

  Nature is the ruling factor here, not man, and Pinaturbo, a Philippine volcano, in 1991 emitted 20 million tonnes of gas and ash into the stratosphere where they discernibly influenced the climate system at the time!

AIR QUALITY

  The Confederation understands that The EA have also targeted coal-fired power stations as being the main source of SO2 emissions. New targets have been proposed, and to date no firm indication has been given as to the eventual limits that will be applied. This uncertainty has persisted for some three years now. Again there was a distinct lack of consultation at the beginning and only when the 1999 consultation paper was published was the UK coal industry afforded a real opportunity to comment. SO2, like CO2, is essential to support certain life forms, in particular plants and crops of brassicas etc.

  The present proliferation of algae growth on structures is indicative of the lack of SO2 in our atmosphere, and farmers are having to resort to crop dusting with sulphur in order to maintain viable yields.

  Unacceptable and impractical SO2 targets for solid fuel users will not fall within the BATNEEC concept, and a realistic interpretation of the limits is needed. This should be undertaken with all speed as forward planning for coal production requires an indication of the type of coals necessary to produce compliance.

G. A. Mousley

October 1999