Guidance on how IEPAW decides which submissions to prioritise.
Contents
Introduction
The Interim Environment Protection Assessor for Wales (IEPAW) receives numerous submissions over the course of a year and cannot commit to producing a report in relation to each of them, even where they are in the scope of the IEPAW process. When deciding which submissions to prioritise, the IEPAW will have regard to the following principles:
Impact
The IEPAW aims to focus its resources where they will add the most value. As such, priority will be given to concerns where a change to the law may result in significant improvements for the environment. Where the IEPAW considers that the impact of their recommendations is likely to be limited, then a report is less likely to be warranted.
Wider context
The IEPAW will consider whether it is the best body to respond to a submission, or whether the issue is better dealt with by a different body, such as an environmental regulator. When considering whether to produce a report, regard will also be given to whether similar action is already being taken, or has recently been taken, by another body. For example, a Senedd Committee. In such cases, the IEPAW may choose not to write a report, or may choose to tailor its response in a way that complements, rather than duplicates, the work of the other body.
Risk
The IEPAW will aim to focus its resources on deficiencies in the law that are likely to have a significant environmental impact if not addressed. Issues with a low potential impact are less likely to be taken forward, even if there do appear to be deficiencies in the legislation. Similarly, issues with a pan-Wales or cross-border impact are more likely to be subject to a report than those where the impact is more localised.
Resources
The IEPAW will seek to investigate issues only where it is proportionate to do so. The amount of resource required is likely to differ for different issues, as will the potential benefits of the IEPAW’s recommendations. When deciding whether to investigate, the IEPAW will consider the cost and the likely duration of the investigation, along with the impact this may have on the resources available for other work.
When the IEPAW chooses not to produce a report on a given issue, it will usually keep the decision under review in case further submissions on the issue are received or new evidence comes to light in the future. For example, the IEPAW may decide to produce a report on an issue that it had previously discounted if it became aware of evidence of significant environmental harm at a later date.