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UEPC position paper on EIAD

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UEPC position paper on EIAD


The European Union of House Builders and Developers (UEPC) takes a close interest in the European Parliament’s discussions on the draft Report by Mr Andrea Zanoni on the Environmental Impact Assessment Directive, and followed the first discussion in the Environment, Public Health and Food Safety Committee on 6 May.

In this regard, UEPC has submitted suggested amendments to the Rapporteur and Shadow rapporteurs.

UEPC is pleased to note from the draft report that the Rapporteur has already tabled amendments to take on board two of its initial concerns regarding the European Commission proposal, namely that:
  • where a deadline is exceptionally extended the competent authority must inform the developer in writing (Rapporteur’s Amendment 24),
  • removing the obligation for technically competent experts to be accredited (Rapporteur’s Amendments 28-32) since this would involve considerable implementation difficulties for the Member States and for economic operators who often already have valid internal expertise.
In other areas of the Directive, particularly in relation to the deadlines for granting of approvals and extensions, UEPC considers that the Commission’s proposed maximum timeframes – which the Rapporteur supports – are too long and threaten the viability of certain projects.

UEPC is also concerned that proportionality must be respected, and considers that the screening procedure is not necessary when it concerns projects that are the implementation of:
  • plans and programmes  which determine the use of small areas at local level and
  • minor modifications to plans and programmes under the condition that it has been determined that  these plans and programs  are not likely to have significant environmental effects in conformity with  Directive 2001/42/EC.
UEPC was pleased to note that, in the debate, a number of the Shadow Rapporteurs suggested that more must be done to reach a balance between protecting the environment and burdening developers and national authorities with additional administrative burdens and processes, and that there was a danger that these procedures were becoming an obstacle.

Regarding the Rapporteur’s suggestion that developers should bear responsibility to undertake corrective measures in the form of additional mitigation and and/or compensation measures (Amendments 6 and 41), UEPC notes that at the monitoring stage the developer, in most cases, does not have rights anymore to the project as in many cases the project will already be sold to investors or directly to private or public clients. We therefore suggest that this aspect requires further consideration in future committee discussions.

To read the full position paper: http://uepc.org/uploads/875f0b43a48e4d0043c34dae4438c229.pdf