Past Master Peter Matthews reports that the Worshipful Company of Water Conservators has responded to the Defra consultation on new penalties for breaches of permits by water companies. The Company restricted most of its comments to technical and management implications in a broader context. The new dynamism on breaches must be extended to other dischargers and government itself needs to review what actions it should be taking
A critical point is clarity on what constitutes an actionable breach.  The Company suggested a code of practice as part of a new integrated Water Regulatory Position statement, which it has advocated previously. If this is not founded on a sound basis there could be unsafe convictions, long legal arguments and misdirected expenditure. The Company supported action where there has been a clear breach of management diligence and a lack of agreed investment.
The response is archived on the Company website
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