Consultation outcome

Summary of responses and government response

Updated 22 March 2023

Introduction

This document is the government’s response to the consultation on amendments to the Environmental Permitting (England and Wales) Regulations 2016 as applied to groundwater activities and related surface water discharge activities.

Groundwater is a very important national resource. It provides a clean and reliable source of drinking water for around a third of England’s public water supply and thousands of private drinking water supplies. It plays a vital role across many industry sectors, including food manufacturing, brewing, and bottled waters, as well as the agricultural industry where it is used for irrigation, food processing and livestock raising. It also supports important wetland ecosystem habitats and sensitive surface water environments, such as chalk streams. The natural capital value of benefits from groundwater across England is estimated to be between £8.9 billion and £13.5 billion per year. The government is committed to ensuring that the quality of our groundwater resources is protected. These amendments will help to protect and preserve groundwater quality for future generations.

Purpose of the consultation

Activities with the potential to impact on the quality of our groundwater resources are regulated through the Environmental Permitting (England and Wales) Regulations 2016 (EPR 2016), which provides ongoing supervision and controls by the Environment Agency (EA) as regulators of these activities. Through the consultation Defra proposed making nine amendments to the EPR 2016 as they apply to groundwater activities and some related surface water discharge activities. The objective of this consultation was to gather views on these proposed amendments, and to help us shape the final version of these amendments. This document highlights the key themes that emerged in the responses received during consultation and sets out the government response to these points. This document is not intended to be an exhaustive commentary on every response.

Analysis of responses

The consultation received 264 responses in total. 160 responses were submitted via the Citizen Space website, 103 responses were submitted via email, and 1 response was submitted via post. Of those that responded via email, not all directly answered the consultation questions. However, we have taken on board all responses and have used our judgement to attribute the comments to the questions that seem most relevant.

Q1: To what extent do you agree with the proposal to give the EA the option to issue Standard Rules Permits for groundwater activities where the generic risks are well-understood, assessed and mitigated?

The consultation proposed that the EA should be given the option to issue Standard Rules Permits for groundwater activities, which are a less-costly alternative to the currently used bespoke permits.

There were 112 responses to this question:

• 26 strongly agreed
• 48 agreed
• 25 neither agreed nor disagreed
• 6 disagreed
• 7 strongly disagreed

Key themes and response

Respondents broadly supported the proposal to give the EA the option to issue Standard Rules Permits for groundwater activities, with 66% of respondents agreeing or strongly agreeing.

A number of respondents noted that they would want the opportunity to see and comment on the conditions of any new Standard Rules Permit before it became available. The EA have a duty to consult on any proposed new Standard Rules Permit, so any interested parties would be able to provide comments as part of this process. A few respondents noted concerns around how the EA would ensure high levels of environmental protection through use of a Standard Rules Permit. The EA carry out a thorough environmental risk assessment before issuing any new Standard Rules Permit. In instances where the environmental risk assessment indicates that a Standard Rules Permit would not provide adequate protection for the environment, a bespoke permit – with further controls – can be issued instead. If an operator is found to be in breach of a Standard Rules Permit, the EA will take enforcement action.

Considering these responses, we will continue with this proposal and the EA will be given the option to issue Standard Rules Permits for groundwater activities. The quality of groundwater will be preserved by the adoption of site-specific Standard Rules permits given the protection these bring in appropriate locations.

Q2: To what extent do you agree with the proposal to give the EA the option to issue Mobile Plant Permits for groundwater activities where the generic risks are well-understood, assessed and mitigated?

The consultation proposed that the EA should be able to issue Mobile Plant Permits for some groundwater activities. A key benefit of this approach is that costs will be reduced for operators, but still ensures that local conditions and local risks have been considered. The adoption of a Mobile Plant Permitting approach will help to protect and preserve our groundwater quality by facilitating easier and faster clean-up practices in areas where groundwater has been contaminated.

There were 68 responses to this question:

• 18 strongly agreed
• 29 agreed
• 19 neither agreed nor disagreed
• 1 disagreed
• 1 strongly disagreed

Key themes and response

69% of respondents agreed or strongly agreed to the proposal to give the EA the option to issue Mobile Plant Permits for some groundwater activities.

Some respondents highlighted that they were unsure about the types of activities that would be permitted under Mobile Plant Permits and would like the opportunity to see and comment on these types of permits before they were issued. Like with Standard Rule Permits, the EA have a duty to consult on any proposed new activities to be covered by a Mobile Plant Permit, so any interested parties would be able to provide comments as part of this process. A few respondents noted concerns around delays to remediation activities where operators would have to apply for a permit. At present operators of groundwater activities must apply for a bespoke permit every time they undertake an activity at a new location. A Mobile Plant Permit, on the other hand, covers multiple locations. Rather than applying for a new bespoke permit at each location, the operator can undertake a site-specific risk assessment instead. This provides a less costly, more efficient alternative to bespoke permits for operators undertaking these kinds of activities and should therefore enable remediation activities to be undertaken much faster than at present. It also reduces the risk that groundwater pollution incidents are left unaddressed due to affordability issues. This will be a significant benefit to ensuring we preserve groundwater quality for the future. Some respondents had concerns about how the use of Mobile Plant Permits would ensure high levels of environmental protection. The EA carry out a thorough environmental risk assessment before issuing any new Mobile Plant Permit.

Considering these responses, we will continue with this proposal and the EA will be given the option to issue Mobile Plant Permits for groundwater activities.

Q3a: To what extent do you agree with the proposal to make General Binding Rules available for small-scale cemetery developments in low-environmental risk settings?

The EA apply a risk based and proportionate approach to environmental regulation and only permit the highest risk cemeteries. The consultation proposed that the EA should be able to issue General Binding Rules (an exemption from permitting) for small-scale cemeteries in low-environmental risk settings. These rules set out the circumstances (or exemption conditions) where cemeteries are considered very low risk to the environment, and therefore are exempt from needing a groundwater activity permit.

There were 178 responses to this question:

• 18 strongly agreed
• 64 agreed
• 29 neither agreed nor disagreed
• 12 disagreed
• 55 strongly disagreed

Key themes and response

Overall respondents supported the proposal with 46% of respondents either agreeing or strongly agreeing, while 38% disagreed due to concerns around the proposed exemption conditions set out in Annex B. These concerns have been addressed within the response to question 3b. Some respondents were unsure about the proposal due to concerns that it applies a blanket approach to cemeteries which can be quite varied in terms of size and location. Exemption conditions are not intended to take site-specific conditions into account. Rather, they set generalised minimum conditions that must be met for a cemetery or burial site to be exempt from requiring a groundwater activity permit. Considering these responses, we have amended our proposals as detailed below.

Q3b: To what extent do you agree that the draft exemption conditions for small-scale cemetery developments in low-environmental risk settings in Annex B are appropriate? If this question is not applicable to you, please select N/A.

Annex B to the consultation document set out 15 proposed exemptions that defined the circumstances where a cemetery does not need a permit.

There were 233 responses to this question:

• 4 strongly agreed
• 17 agreed
• 11 neither agreed nor disagreed
• 36 disagreed
• 165 strongly disagreed

Key themes and response

Respondents objected to the proposed exemption conditions for cemeteries with 86% disagreeing or strongly disagreeing.  Although some respondents commented that exemption conditions for existing sites represented good practice, the primary objection was that one or more of the conditions would be too difficult for existing cemeteries to comply with.

Most respondents disagreed with exemption condition: ‘A grave plot must not be less than 5m2 in area’. Concerns were primarily raised in relation to its impact on existing cemeteries, so removing its application to existing cemeteries will address these concerns but existing cemeteries should still aim to use the guidance for ‘Minimum good practice groundwater protection requirements’ on Gov.UK but it won’t be a legal requirement. By aiming to meet the guidance for good practice existing operators can play an important role in helping to protect our groundwater quality and preserve its use for future generations. The approach of using a grave area has also been reassessed in the exemption conditions for new or extended cemeteries in favour of a density figure of 2500 burials per hectare or pro rata, which will give operators the freedom to determine the spacing within their cemetery. Existing cemeteries will remain within the current standards and have no exemption conditions applying to them.

Many respondents disagreed with exemption condition: ‘A grave must be deep enough so at least 1 metre of soil will cover any part of the coffin or body’. This is considered good practice and similar depths of soil cover may be needed for other purposes. However, we have reconsidered this approach and removed it on the basis that its inclusion would not make a significant difference to groundwater protection outcomes.

Many respondents disagreed with exemption condition: ‘A burial within a cemetery must not be within 10 metres of any field drain, including any dry ditch’ on the basis that many existing cemeteries are in proximity to multiple field drains and ditches. This feedback has been addressed by applying the exemption conditions to only new cemeteries or new extensions because this a reasonable expectation for the planning process.   Existing cemeteries should still aim to use the guidance for ‘Minimum good practice groundwater protection requirements’ on GOV.UK but it won’t be a legal requirement to operate without a permit and will have no exemption conditions applying to them.

Many respondents disagreed with exemption condition: ‘A grave must have at least 1 metre clearance between the base of the grave and the top of the water table and must not have any standing water in it when dug’ on the basis that many existing cemeteries are located in areas where the water table is high, variable or hard to locate, or that it is hard to determine whether standing water is groundwater or surface water runoff during wet weather events. This concern has also been addressed by applying the exemption conditions to only new cemeteries or new extensions because this a reasonable expectation for the planning process. Existing cemeteries should still aim to use the guidance for ‘Minimum good practice groundwater protection requirements’ on Gov.UK but it won’t be a legal requirement.

Considering these responses, the proposed approach has been reassessed and the exemption conditions will only apply to new cemetery developments (including extensions) that are granted planning permission on or after the date that the updated regulations come into force. The updated proposed amendments will therefore not affect existing cemeteries who will not need to abide by the exemption conditions to operate without a permit. Existing cemeteries should still aim to use the guidance for ‘Minimum good practice groundwater protection requirements’ on GOV.UK but it won’t be a legal requirement.

These proposals will bring in a tier of proportionate regulation for most new cemetery developments which itself can help to ‘free-up’ cemetery space for future developments by significantly reducing the regulatory and permitting costs. Groundwater quality will be protected and preserved by this proportionate regulatory approach.

Q3c: To what extent do you agree with the proposal to make General Binding Rules available for closed loop ground source heat pump activities in low-environmental risk settings?

To avoid the proposed change in regulation (Q5) from affecting the use of closed loop ground source heat pump activities in low-environmental risk settings, the consultation proposed that the EA should issue General Binding Rules (exemption conditions) for this activity. If an operator can comply with the exemption conditions set out for the specific activity, the level of risk to the environment will be very low and therefore does not need to apply for a permit.

There were 61 responses to this question:

• 6 strongly agreed
• 23 agreed
• 21 neither agree nor disagree
• 9 disagreed
• 2 strongly disagreed

Key themes and response

Overall, respondents supported the proposal with 48% of respondents agreeing or strongly agreeing compared to 18% that disagreed.  Many respondents cited concern that the exemption should not impede the movement towards use of green technology in local communities. A few respondents noted that avoiding sensitive areas (e.g., near Sites of Special Scientific Interest) would impede the expanded use of this technology and number of respondents expressed that the conditions were too onerous. Some respondents also questioned the risk posed by closed loop heat pump activities due to their closed loop nature.

It is expected that this exemption will cover most closed loop ground source heating system proposals. Where the site is located near a sensitive groundwater receptor the activity is not prohibited but will require a bespoke risk assessment and permit to ensure that the sensitive groundwater environment is not impacted. This means that the use of green technology is still an option in those locations that cannot meet the exemption conditions and any potential impact to groundwater quality can be controlled.

The proposed amendments will only be applied to new closed loop ground source heat pump activities on or after the date that the updated regulations come into force and consideration of the exemption conditions would be dealt with during its planning and construction. If the system complies with the exemption conditions, then there will be no cost to the operator, and the EA does not need to be informed of the new infrastructure. We therefore do not consider this amendment to be onerous, but it allows for better protection of sensitive groundwater environments.

Considering these responses, we do not find it necessary to amend this proposal.

Q3d: To what extent do you agree that the draft exemption conditions for closed loop ground source heat pump activities in low-environmental risk settings in Annex C are appropriate?

Annex C to the consultation document set out 9 proposed exemptions that defined the circumstances where a closed loop ground source heat pump does not need a permit.

There were 54 responses to this question:

• 2 strongly agree
• 16 agree
• 19 neither agree nor disagree
• 15 disagree
• 2 strongly disagree

Key themes and response

There was a mixed response to the draft exemption conditions with 33% that agreed or strongly agreed, 35% neither agreed nor disagreed and 31% disagreed or strongly disagreed.  Some of the general comments aligned with those highlighted in Q3c, such as concerns that conditions were too onerous. These comments have been addressed in response to Q3c.

Some respondents objected to conditions 3, 4, 5, and 7 citing concern that this would limit options for local councils to consider this green technology. The exemption conditions would not prohibit the installation of closed loop ground source heat pumps within the distances cited in the draft exemption conditions but would require a permit to operate.

Condition 3 - The system must not be either entirely or partly within a groundwater Source Protection Zone 1 or within 50 metres of a well, spring or borehole used for supply water for domestic or for food production purposes. This condition aims to protect groundwater used as drinking water close to the abstraction point. Warming trends in the groundwater could cause proliferation of fauna within the formations that could reduce flow to the abstraction points or be detrimental to water quality.

Condition 4 attempts to protect designated wetland sites and the distance required is set based on generic travel times and scheme size. Schemes within those distances are not prohibited but require controls to ensure that the sensitive environment is not damaged by changes in temperature.

Condition 5 – The system must not be within 10m of a watercourse, has been reviewed and will be removed as no restrictions apply to closed loop schemes set in surface waters where dilution of the temperature is much faster, so it is not necessary to provide this protection.

Condition 7 requires schemes not to be adjacent to private sewage systems and the associated infiltration system. This is to prevent temperature increases that could encourage bacterial growth within the effluent and cause treatment systems to become inefficient or cause infiltration systems to become blocked causing effluent to back up.

Having reviewed the proposed conditions on the proposed exemption we are removing condition 5 as explained above. The other conditions are considered reasonable and proportionate at this time to protect groundwater quality and sensitive groundwater environments but we will keep them under review.

Q3e: To what extent do you agree that the draft exemption conditions for closed loop ground source heat pump activities in low-environmental risk settings in Annex C should apply to all sizes of such activities?

There were 54 responses to this question:

• 3 strongly agree
• 10 agree
• 29 neither agree nor disagree
• 8 disagree
• 4 strongly disagree

Key themes and response

There was a mixed response on if the proposed draft exemption conditions should apply to all sizes of closed loop ground source heat pump activities. 24% of respondents agreed or strongly agreed, 22% disagreed or strongly disagreed, while the majority 54% neither agree nor disagree.  The most cited opposition aligned with feedback from 3c and 3d that the conditions may impede a move towards green energy sources. The response to Q3c addresses this concern. Several respondents opposed application to all sizes of activity stating that tighter controls are needed for larger systems. Other respondents were unsure noting that further investigation was needed to understand if it was needed or not.

At this time there is limited evidence relating to scheme size and impacts, so further research work is being planned and undertaken. Considering these responses, we do not find it necessary to amend this proposal.

Q3f: If you think that the draft exemption conditions for closed-loop ground source heat pump activities in low-environmental risk settings in Annex C should include a size threshold (energy in kWh per year), what size limit do you think is reasonable?

No respondents provided a kWh per year figure in response to this question.

The limited response to this question reinforces the response to 3e that exemption conditions should apply to all sizes of activities and further research would be required if a size threshold were to be applied. Therefore, the EA has considered these suggestions, but by maintaining the proposal in 3e to apply exemption conditions to all sizes of activity, a size threshold will not be required.

Q4: To what extent do you agree with the proposal to enable the EA to apply regulatory controls for microbial pollutants where appropriate and to issue permits for groundwater activities with conditions to protect groundwater from microbial pollution?

The consultation proposal to apply regulatory controls to mitigate risks of microbial pollution to groundwater would align with the approach already in place to manage microbial pollution in surface, drinking and bathing water.

There were 93 responses to this question:

• 24 strongly agreed
• 31 agreed
• 36 neither agreed nor disagreed
• 0 disagreed
• 2 strongly disagreed

Key themes and response

Respondents supported the proposal with 59% of respondents agreeing or strongly agreeing.

Some respondents requested further information on the rationale for introducing these controls. The potential for microbial entities to cause pollution of groundwater is well documented, such as through the Drinking Water Inspectorate annual reports where on average 5% of private drinking water supplies in England fail on microbial contamination from tap sampling. Enabling the EA to apply permitting controls on discharges with the potential to introduce this type of pollution to groundwater is key to preventing harmful microbial pollution of groundwater, thereby helping to preserve our water quality. This is particularly the case where discharges are close to drinking water abstractions, such as in a groundwater Source Protection Zone 1.

Some respondents asked how the controls will be applied and others expressed concern around how cemeteries would be impacted given the likelihood of microbial entities being present in the ground. The presence of microbial entities alone does equate to a pollution incident. Microbial content limits are set by the Drinking Water Inspectorate Private Supply Regulations at a level that could cause human harm. Controls will only be put in place where there is evidence of actual microbial pollution or a significant risk of microbial pollution occurring.

Considering these responses, we do not find it necessary to amend this proposal.

Q5: To what extent do you agree with the proposal to enable the EA to apply regulatory controls for heat pollution where appropriate and to issue permits for groundwater activities with conditions to protect groundwater from heat pollution?

The EPR 2016 recognises heat as a form of pollution but does not provide for heat to be controlled as a pollutant. The consultation proposed to rectify this by enabling groundwater activities that might cause heat pollution to be regulated.

There were 58 responses to this question:

• 8 strongly agreed
• 27 agreed
• 19 neither agreed nor disagreed
• 3 disagreed
• 1 strongly disagreed

Key themes and response

60% of respondents agreed or strongly agreed with the proposal.

Some respondents requested further information on the rationale for introducing these controls and how the controls would be applied. This amendment will reintroduce the controls on heat in groundwater that were lost when transposing the original Groundwater Regulations into the Environment Permitting Regulations in 2010. This brings controls in line with surface water regulations on heat pollution. Controls will be applied for discharges to groundwater where a change in temperature may be harmful to the quality of aquatic ecosystems or groundwater dependant ecosystems, e.g., wetlands. In line with the way in which the EA control activities with the potential to introduce other types of pollutants to the groundwater environment, the EA will only apply controls where there is evidence of actual heat pollution or a significant risk of heat pollution occurring.  This will ensure that the Environmental Permitting Regulations are effective in protecting and preserving groundwater resources – and the ecosystems they support – from heat pollution.

Considering these responses, we do not find it necessary to amend this proposal.

Q6: To what extent do you agree with the proposal to add these new rules to the General Binding Rules for Small Sewage Discharges to ensure that multiple discharges should not be located in close proximity to each other?

Two new rules were proposed to be added to the existing list of General Binding Rules for Small Sewage Discharges to ensure that nearby groundwater quality will be better protected from the potential cumulative impacts of multiple discharges, and that adequate treatment facilities will be installed where the General Binding Rules cannot be complied with.

There were 70 responses to this question:

• 16 strongly agreed
• 27 agreed
• 18 neither agreed nor disagreed
• 8 disagreed
• 1 strongly disagreed

Key themes and response

Respondents broadly supported the proposal to add to and strengthen the existing General Binding Rules for Small Sewage Discharges with 61% agreeing or strongly agreeing.

Some respondents expressed concerns around the disproportionate impact this proposal may have on residents in areas that are not serviced by mains sewers. It is important to be clear that these additional rules will not prohibit small sewage discharges from being operated in these areas. Rather, the rules will ensure that such discharges are installed and operated in a way that is protective of groundwater and surface water environments thereby helping to preserve the quality of these valuable water resources.

These additional rules will only apply where new small sewage discharges are being proposed and will not apply retrospectively to existing discharges, which will remain under existing regulations. New small sewage discharges are frequently linked to new developments so the updated General Binding Rules will help ensure appropriately sized treatment system are installed.

Considering these responses, we do not find it necessary to amend this proposal.

Q7: To what extent do you agree with the proposal to require operators of Onshore Oil and Gas (OO&G) facilities to apply to surrender their groundwater activity permits, rather than to only provide a notification of surrender?

This proposal aims to ensure that OO&G operators will need to satisfy the EA that any pollution issues are remediated, and that there are no ongoing risks to the groundwater environment at the point of decommissioning or that may arise in future, before their permit can be returned.

There were 39 responses to this question:

• 12 strongly agreed
• 15 agreed
• 11 neither agreed nor disagreed
• 1 disagreed
• 0 strongly disagreed

Key themes and response

Overall, respondents strongly supported the proposal that operators of OO&G facilities should have to apply to surrender their groundwater activity permits. 69% of respondents agreed or strongly agreed and only 1 respondent disagreed.

One respondent suggested that OO&G operators who want to convert their oil and gas facility to low carbon geothermal should be exempt from surrendering permits in this instance. Where former oil and gas wells are repurposed for other uses the permits in place will need to be reviewed and surrender would only be agreed if no on-going or future pollution potential existed from the original activity.

Considering these responses, we do not find it necessary to amend this proposal.

Q8a: To what extent do you agree with the proposal to add remedial solution activities to the list of exemptions from the prohibition on direct discharges to groundwater, thereby enabling the EA to issue permits for these activities where appropriate?

Direct discharges of pollutants to groundwater are prohibited under the EPR 2016, but the Regulations provide a limited list of specific groundwater activities which are exempt from this prohibition, provided that certain measures are met. The consultation proposed to add discharges from remedial solution activities to the list of exemptions. The benefit of this proposal is that it will be easier for remediation activities to take place where pollution of groundwater has occurred and therefore improve groundwater quality.

There were 50 responses to this question:

• 12 strongly agreed
• 25 agreed
• 12 neither agreed nor disagreed
• 1 disagreed
• 0 strongly disagreed

Key themes and response

This proposal was strongly supported in the consultation response with 74% agreeing or strongly agreeing to the proposal and only one respondent disagreeing to the proposal. A few respondents commented that there needs to be further detail on the proposal and that permits should be consulted on prior to being introduced. The EA have a duty to consult on any proposed new permit, so any interested parties would be able to provide comments as part of this process.

Considering these responses, we do not find it necessary to amend this proposal.

Q8b: To what extent do you agree with the proposal to add fluid injection techniques to the list of exemptions from the prohibition on direct discharges to groundwater, thereby enabling the EA to issue permits for these activities where appropriate?

Like with Q8a, the consultation proposed to update the list from Schedule 22 of the EPR 2016 to add fluid injection techniques to the list of exemptions from the prohibition on direct discharges to groundwater, thereby enabling the EA to issue permits for these activities where appropriate. Issuing permits ensures that the groundwater in the vicinity of these activities can be appropriately protected.

There were 46 responses to this question:

• 9 strongly agreed
• 20 agreed
• 14 neither agreed nor disagreed
• 1 disagreed
• 2 strongly disagreed

Key themes and response

Overall, respondents supported this proposal with 63% agreeing or strongly agreeing and only 7% disagreeing or strongly disagreeing. Many respondents cited the value of EA regulating these activities to allow for formalised mitigations and controls to protect the groundwater environment and others from the OO&G sector welcomed the proposal which will allow them to use techniques that will increase the efficiency of hydrocarbon recovery and support the development of the geothermal energy sector.

Considering these responses, we do not find it necessary to amend this proposal.

Q9: To what extent do you agree with the proposed approach to clarify the defence for sewerage undertakers in breach of permit conditions?

The consultation document proposed to clarify the defence for sewerage undertakers in breach of their permit conditions due to specific circumstances beyond their control. The current wording of the EPR 2016 is unclear in that the defence applies only to Regulation 38(1) (operating without a permit) but not Regulation 38(2) (breaching a permit condition), which is more commonly the case.

There were 50 responses to this question:

• 10 strongly agreed
• 20 agreed
• 14 neither agreed nor disagreed
• 1 disagreed
• 5 strongly disagreed

Key themes and response

Overall respondents supported this proposal with 60% that agreed or strongly agreed compared to 12% that disagreed or strongly disagreed.

A few respondents disagreed with the proposal on the basis that sewerage undertakers should have controls and technology in place to manage any discharge to their system and should otherwise be liable and another respondent commented that there should be a requirement for operators to show that they could not reasonably have foreseen or have known about the discharge. Sewerage undertakers have a system to manage trade effluent discharges where limits are set on a range of substances that takes into account the nature of the treatment works. However, there may also be situations where a discharge to sewer occurs which is unauthorised or non-compliant with its consent, which is when they may seek to use the defence. For the EA to agree to allow the defence they will require the sewerage undertaker to prove that the permit breach was due to an unauthorised third-party discharge; and that they have taken all reasonable steps to prevent an unconsented discharge to sewer; or taken all reasonable steps to prevent the third-party from breaching their trade discharge consent.

Considering these responses, we do not find it necessary to amend this proposal.

Next steps

The proposed amendments will be laid before Parliament when parliamentary time allows.