Mr. Philip Nugent:

We certainly would not like to give the impression we are concerned only about the monetary impacts of the draft directive. The Department of the Environment, Community and Local Government is concerned about the environmental impacts of the environmental impact assessment directive.

We are concerned about proportionality. We are not yet sure that the Commission has demonstrated how the new proposals significantly lead to enhanced protection of the environment, bearing in mind the administrative burden that will arise for competent authorities and project sponsors. There is little gain for a considerable administrative burden.

I am not sure how this proposal squares with other communications from the European Commission over recent years to try to simplify procedures. I do not mean to be glib but the Senator would probably have to ask the European Commission. It is telling that it took the environment side of the Commission longer than anticipated to get the draft proposals through its internal assessment board. That is an important issue.

Our main concerns relate to the mandatory scoping. We do not understand why the arrangement should be mandatory and we do not yet see the benefit. This concern is shared by two thirds of member states. We are also concerned about the extent to which the accreditation system that is to be introduced will lead to an improvement in the protection of the environment. It could be extremely complicated. Does one seek a planning qualification or an environmental engineering qualification? What are the different standards of qualifications among member states and states outside the Union? How does one ensure that people entering from outside the Union will have the requisite skills to become accredited? These questions concern pretty much all member states.

There are requirements associated with new factors that must be assessed. Planning authorities would not have the in-house expertise to assess the implications in all cases. An example relates to issues associated with climate change and biodiversity. This would be complicated. It would be very costly to the public system to ensure all local authorities and planning authorities had the expertise in-house.