The European Commission’s proposed Environmental Simplification Omnibus
Publications: Environmental Democracy
This is a submission by Environmental Justice Network Ireland, a Belfast based network organisation dedicated to environmental justice in Ireland, Northern Ireland and at EU level. This attached submission highlights that the proposals in the Environmental Simplification Omnibus represent a substantial regression in the standard of environmental protection available under the current legislative framework and do not substantially improve the speed or efficiency of permitting, licensing and plan making processes targeted.
The package amends a wide range of recently adopted or revised instruments, including the Industrial Emissions Directive, Waste Framework Directive, Medium Combustion Plants Directive, INSPIRE Directive, the Water Framework Directive and proposals concerning environmental assessments and permitting. The cumulative effect of these changes is a significant reduction in transparency, public participation, environmental oversight, and access to justice.
“De‑thresholding” (by altering definitions and thresholds) is used to exempt tens of thousands of industrial installations and agricultural operations from permitting, monitoring, and reporting regimes. Broad presumptions of “overriding public interest” introduced for whole categories of spatial plans and projects undermine public participation and protections under the Habitats and Birds Directives. Restrictions on access to full substantive judicial review and public participation are introduced, alongside measures to remove hazardous substance inventories and assessments, and to dismantle key environmental data and transparency tools.
The Omnibus package does not substantially alter or improve the efficiency of permitting processes for the remaining operators over threshold, ignores opportunities to modernise participation through technology, and is accompanied by poor consultation practices. Most concerningly, no evidence-based assessments of the impacts on the environment and human health are presented, raising concerns about the soundness of the proposals and the extent to which the public are being enabled to make informed contributions to this consultation. The package conflicts with a range of EU Treaty and international law obligations.
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