This is the HBF response to the third group of packages (8-10) in this informal consultation on Defra's proposals for environmental permits.
We are still concerned about how this regime would work in practice, particularly as it is proposed that the Environment Agency will be able to upgrade permits retrospectively.
Developers may be trying to sell houses on brownfield sites that are still subject to an environmental permit and therefore not eligible for a completion certificate. (A proposal for a partial surrender will not help the perception of blight).
The permit system is too inflexible: it does not allow for the changes as excavation reveals previously unknown ground conditions.
We are also concerned that 'pollution prevention and control' (PPC) will not replace 'waste management licensing' (WML) so the two systems may be run in parallel. This would increase the regulatory burden and delay the development process. In turn, this will have an impact on the government's housing targets.
The full text of the HBF response can be seen via the following link.