The process under which integrated pollution prevention and control licences should be determined has been twice considered in detail by the Oireachtas in the context of the Environmental Protection Agency Act 1992 and the Protection of the Environment Act 2003.
Both enactments confirmed the role of an expert, management body, the Environmental Protection Agency, EPA, in operating integrated pollution prevention and control licensing of complex installations. Both also provided a system of review of draft licence determinations by EPA itself, following due consideration of submissions and observations by all parties rather than the establishment of an external official mechanism.
I consider that these arrangements agreed by the Oireachtas are consistent with the principles of administrative justice. It would be impractical to operate an external appeal arrangement in this area given the scarcity of relevant expertise which exists in a small country like Ireland and the difficulties in terms of cost and organisation arising from this. For these reasons, I have no proposal to amend existing legislation on this matter.