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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 archive.

For more information, contact Elizabeth Clements at the MPA on 020 7963 8000.

 

 
 
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Consultation Title - Click to Download Date Notes MPA Contact File Size  

MPA submission to the informal consultation "Performance Regulation for EPR"

28/05/17

An MPA consultation response to the "Performance Regulation for EPR".

Nicola Owen 148kb
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MPA Response to European Protected Species Policy Consultation, April 2016

15/04/16

An MPA consultation response to the European Protected Species Policy Consultation, April 2016.

David Payne 94kb
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Consultation on Changes to Water Abstraction Licensing Exemptions in England and Wales: New Authorisations

13/04/16

An MPA consultation response on Changes to Water Abstraction Licensing Exemptions in England and Wales: New Authorisations.

Download the appendices here.

Nicola Owen 110kb
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Consultation on the Business Impact Target, Growth Duty and Small Business Appeals Champion

22/03/16

An MPA consultation response to the EC Fitness Check of the Nature Directives. The public consultation is largely in the form of a simple questionnaire with limited opportunity for additional comments.  The MPA response, and the additional comments submitted, reflect the responses of Cembureau and UEPG.

Nicola Owen 88kb
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MPA response to the consultation on the EC Fitness Check of the Nature Directives

16/07/15

An MPA consultation response to the EC Fitness Check of the Nature Directives. The public consultation is largely in the form of a simple questionnaire with limited opportunity for additional comments.  The MPA response, and the additional comments submitted, reflect the responses of Cembureau and UEPG.

David Payne 92kb
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MPA submission to Defra “Waste crime: consultation on proposals to enhance enforcement powers at regulated facilities; and call or evidence on other measures to tackle waste crime and entrenched poor performance in the waste management industry”

06/05/15

An MPA consultation response to the Defra “Waste crime: consultation on proposals to enhance enforcement powers at regulated facilities; and call or evidence on other measures to tackle waste crime and entrenched poor performance in the waste management industry”

Nicola Owen 100kb
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MPA submission to EA Consultation “Standard Rules Consultation No. 14”

 

20/03/15

An MPA consultation response to the EA Consultation “Standard Rules Consultation No. 14”.

Nicola Owen 100kb
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MPA submission to Request for input to the UK Climate Change Risk Assessment Evidence Report

 

28/01/15

During 2014 MPA met with various Government officials from the Climate Change Committee (CCC) to provide input into the document “Managing climate risks to well-being and the economy”.  In particular this focused on the potential risk to the quarrying and mining industry due to lack of available water resources.  The study identified that although mineral sites on the whole are non-consumptive, it is essential that the ability to dewater and use water consumptively (for activities such as mineral washing) remains.  Representation was also made on the inability for mineral sites to re-locate to catchments where more water is available as minerals can only be extracted where they lie.  This document can be found online here.

Following this MPA were then invited to make further submissions to the CCC for the business section of the UK Climate Change Risk Assessment Evidence (CCRA) Report which will inform the Defra report “Climate Change Risk Assessment”, which is due during 2017.  As the CCRA has a wider remit than the original study the MPA response contains evidence from other sectors, including cement and concrete. 

Nicola Owen 191kb
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MPA submission to HMRC consultation “Landfill Tax- Liability of waste ‘fines’

         

MPA submission to HMRC consultation “Landfill Tax- Liability of waste ‘fines’

19/09/14

An MPA consultation response to the HMRC consultation “Landfill Tax- Liability of waste ‘fines’.

Nicola Owen 245kb
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MPA submission to Welsh Assembly Government (WAG) Consultation - “A Water Strategy for Wales"

30/07/14

An MPA consultation response to the Welsh Assembly Government (WAG) Consultation - “A Water Strategy for Wales".

Nicola Owen 215kb
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Making the Most of Every Drop: Consultation on Reforming the Water Abstraction Management System

31/03/14

The MPA recognises that the abstraction licensing system in England is outdated and requires modernising to ensure that water can be provided for the environment, industry and public water supply as required.  The sustainable use of water is essential to preserve water resources for present and future generations. Equally, aggregate extraction is essential to the economy and our way of life.  The management of water is a critical element of quarry development, which can only take place where the minerals lie. To read more click on the link.

Nicola Owen 250kb
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Towards the Sustainable Management of Wales’ Natural Resources
Environment Bill White Paper – Consultation Response

15/01/14

MPA's views and comments on the Welsh Government's proposals for an Environment Bill.

Nicola Owen 271kb
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MPA submission on guidance - Landfill Tax - draft further guidance on lower rating

20/10/13

MPA has made numerous representations through meetings between industry and Government and written representations last year on the issue of lower rated tax. Read MPA's consultation response here.

Nicola Owen 199kb
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MPA Response to the Consultation on the Waste Management Plan for England

04/09/13

An MPA consultation response to the 'Waste Management Plan for England'. MPA agrees that waste should be prevented at the source but also raises concerns about the data that has been reported in the plan.

Nicola Owen 202kb
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MPA Comments on the Defra Discussion Paper "Triennial Review of Environment Agency and Natural England'

04/02/13

The MPA response details the ongoing concern MPA have with the overlapping duties of the Environment Agency and the Planning Authorities and the numerous licenses and permits required to operate.  Scenario 2 is broadly supported with concerns raised over disruption to services during the reorganisation of the two organisations. 

Nicola Owen 214kb
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MPA Response to "Consultation on our charges from 2013"

9/11/12

An MPA consultation reponse to "Consultation on our charges from 2013". The consultation looked to establish the way in which damage to the environment would be measured to determine whether the damage is serious for the purposes of section 27 of the Water Act 2003.  In general the proposals set out in the charges document lack detail. Further workshops and stakeholder engagement is expected before the proposals are agreed on and MPA have indicated their involvement in any future discussions.

Nicola Owen 194kb
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MPA Response to the consultation 'Building a Better Environment'

Technical Appendix

19/10/12

An MPA consultation response to 'Building a Better Environment'. The response considers the document a good starting point for developers who are initiating a planning application or needing to consider input from the Environment Agency, Natural England or the Forestry Commission.  It provides a clear guide as to when the separate bodies should be contacted to provide advice to the planning process and indicates to developers where to go for further information.

Nicola Owen 229kb
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Reporting Guidance for Business on Environmental Key Performance Indicators: a consultation on Guidance for UK Businesses

 

17/10/12

An MPA consultation response to the 'Reporting Guidance for Business on Environmental Key Performance Indicators: a consultation on Guidance for UK Businesses'. It notes that although the majority of industry firms are not required to report under the Companies Act 2006, MPA are aware that there is a separate chapter for aggregates under the Key Performance Indicator- Materials. BMAPA (British Marine Aggregate Producers Association), part of the MPA family, have submitted a separate response that provides additional detail on the specific points related to the marine aggregates industry. For more detailed feedback and comments, click on the link.

Nicola Owen 265kb
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Smarter Environmental Regulation Review

24/08/12

MPA's response to the Review picks up on the impact and duplication of environmental regulation and where we consider improvements could be made.  The response reviews some of the main parts of our members’ operations that operate under distinctly different regulations. A section on general improvements to be considered is also included.

Nicola Owen 198kb
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The draft Regulatory Position Statement (RPS)

22/08/12

MPA members consist of operators who would be required to manage their operations under the proposed RPS.  It is difficult to understand why firstly there is a need for the RPS and secondly why more research was not done to discover current industry practice.  Once MPA can understand this we will be a position to further help the EA with an RPS.  

Nicola Owen 221kb
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Consultation- Draft Guidelines for developments requiring planning permission and environmental permits

22/06/12

An MPA consultation response which explains how minerals can only be extracted where they lie and are therefore by their very nature a very unique type of development.  The scope for considering alternative locations is very limited.  Although a site can be operational for 30 + years in some situations, the development is not permanent.  Mineral developments are typically a high volume low value business with high upfront investment.  It is essential, therefore for the reasons stated, that operators have a high degree of certainty that they will be able to obtain the required planning and non-planning consents to operate their site for it’s lifetime. 

Nicola Owen 99kb
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DEFRA consultation on the Water Act 2003: Withdrawal of compensation on the grounds of serious damage.

30/04/12

MPA request a transparent, risk based methodology for identifying water abstractions that are causing serious damage to the environment.  It is considered essential that all abstractors and other extraneous influences, such as climate change, are considered and that the Environment Agency are able to prove, beyond reasonable doubt, that it is the abstraction in question causing serious damage to the environment.

Nicola Owen 99kb
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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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