PPD-Nitrates Directive Actions Program

Mrs Rachael Patterson

Department of the Environment
Sustainable Development Division
River House
48 High Street
Belfast
BT1 2DR

Dear Ms Patterson,

Re: Public Participation Directive (PPD) 2003/35/EC Consultation on proposed approach to transposing PPD in relation to the Nitrates Directive action programme

Thank you for the opportunity to comment on the above consultation.

Having considered the proposals in the consultation paper, Council takes the view that the approach outlined appropriately implements the requirements of the PPD in the context of preparation, modification or review of the Nitrates Directive action programme. Council also notes the position on costs but has no comments to make in that regard.

Related observations:

1. Council would like to commend the Departments for their endeavours to engage all stakeholders in relation to the full implementation of the Nitrates Directive and particularly the action programme. In the latter context the provision of the Summary Booklet to give a simplified overview of the AP measures is to be commended.

2. As for Paragraph 2 on Page 5 Council waits with interest receipt of the new general guidance document for written consultations.

3. As regards the requirement to review the 2005 ND action programme at least every four years provision should be made for a preliminary discussion with CNCC (within its Statutory Advisory Council role) as soon as the review process is embarked upon. As reference to the Council's response to the (current) action programme consultation will show, it has considerable reservations about the likely effectiveness of the proposed closed period/storage levels mainly in the context of delivering 'good ecological status' of NI waters by 2015 under the Water Framework Directive.

Yours Sincerely

Dr Lucinda Blakiston Houston
Chairman