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Environment, waste and water

This page sets out in chronological order recent consultation responses submitted by the Mineral Products Association on behalf of its member companies within the fields of the environment, waste and water.

Check back regularly to take advantage of this new archive.

For more information, contact Hilary Arrowsmith at the MPA on 020 7963 8000.

 

 
 
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Consultation on the draft Environment Agency drought plans

24/10/11

The EA consult on their drought management plan every three years.  In total there are eight plans; one for each of the six Environment Agency regions of England; one for Wales and one plan covering the Head Office and National teams. Read MPA's repsonse here..

Nicola Owen 103kb
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Standard Rules Consultation no. 7

22/07/11

MPA explains its grave concerns that the introduction of a 500m Great Crested Newts(GCN) criterion could render a large number of inert waste operations unviable and jeopardise delivery of the Government’s recycled aggregates objectives.

Nicola Owen 103kb
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Biodiversity Offsetting Consultation

31/01/11

MPA makes several key points in this consultation, including that the principle of offsetting, to ensure development results in no net loss and preferably a net gain, for biodiversity is good, but needs to apply to those types of development that are not fully contributing to biodiversity enhancements and BAP targets; and, also, that the mineral products industry in the UK is already leading the field in terms of delivering net biodiversity gains through our development activity.

Nicola Owen 135kb
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Call for Evidence - Review of Waste Policy

30/10/10

The response focuses on the use of inert waste for restoration of quarries and that it is our opinion that it should be classified as a recovery activity not landfill.  It also suggests that a more balanced approach to inert waste regulation should be taken.

Nicola Owen 96kb
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Consultation - Fairer and Better Environmental Enforcement: Implementing the New Civil Sanctions

07/05/10

MPA agrees with the principal of introducing a fairer and better environmental enforcement system to regulate businesses and the incidental environmental pollution that may occur.  MPA also understands that the one of the key outcomes of the Hampton Review was to introduce a more balanced enforcement system and MPA understands how this can be accomplished through the use of civil sanctions. However, we are concerned that the civil sanctions are being brought into action far too early and before the new regulatory system is fully set up and operating.

Nicola Owen 96kb
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Consultation on the Legal Definition of Waste

26/03/10

MPA recognises the benefits of providing guidance on the legal definition of waste and its application.  We agree that there should be guidance to provide assistance for businesses and other organisations to take the right decisions about the classification of substances as waste.

Nicola Owen 91kb
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Consultation on the transposition of the Revised Waste Framework Directive

10/09

MPA responds to the proposed transposition options of the Revised Waste Framework Directive.  MPA raises concerns that the Directive with regards to CD&E Waste and its classification has not been considered during the consultation.

Nicola Owen 90kb
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Consultation on Odor Management

10/09

MPA responds to the consultation on the proposed EA guidance on odour management.

Nicola Owen 89kb
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Consultation - Fairer and Better Environmental Enforcement

Consultation Questions

10/09

MPA considers that the implementation of additional powers for the Environment Agency and Natural England should be delayed to allow industry to catch up with the flood of new regulations.

Nicola Owen 95kb
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Modernizing Landfill Tax

03/08/09

MPA met with HRMC to discuss the consultation and raised concerns over the removal of the exemption from quarry restoration.  There were also concerns that the increased tax on some wastes would prove difficult for aggregate recycling and other operations.

Nicola Owen 105kb
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EPP2 Consultation on draft guidance re: Mining Waste Directive

29/07/09

MPA's response to the consultation on the draft guidance on the Ming Waste Directive.

Nicola Owen 116kb
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Amendment to the Conservation Regulations

24/07/09

MPA responded to the consultation on the amendments that would be made to the Conservation Regulations with general support.  However MPA were disappointed not to be thought of as a key stakeholder for the consultation.

Nicola Owen 110kb
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Waste Duty of Care

24/07/09

MPA continue to support the Environment Agency in preventing waste crime.  The provisions in the consultation document continue to improve and strengthen preventative measures against waste crime.

Nicola Owen 116kb
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Time Limiting of Abstraction Licences

22/07/09

MPA responds to the consultation, relaying our concerns on time limiting all abstraction licences.  In our response we suggest that long duration licences should be issued to quarry operations and should be subject to the planning conditions.

Nicola Owen 143kb
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Consultation on implementing the abstraction elements of the Water Act 2003

22/07/09

MPA's key concrens raised in this consultation response are:
- The majority of our operations are non-consumptive, simply dewatering to allow the dry working of mineral below the water table.
- Unlike other industries, our operations have to be situated where there is an accessible mineral resource and this, in turn, is dependent on geology, amongst other factors.  We are unable to relocate to a more suitable location (in terms of CAMS) due to this.
- Industry and regulators require clear, effective Technical Guidance so that there is clarity of requirements between the regulator and the regulated.
- The implementation date of October 2009, with applications required by October 2010, is almost impossible to meet.  It is unlikely that both the Environment Agency and Industry will be able to meet this schedule and it should be extended. If this is unachievable, the opportunity to stagger the applications may be an alternative and, if agreed, this should be done in consultation with industry.  
-The cut off date for compensation (6 October 2024) should be removed.  We consider that in some cases compensation claims may continue after this deadline.

Nicola Owen 129kb
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