Two thoughts relating to town and parish councils:
1) The main intention behind the "land owned by the authority" line in the
statutory guidance was to provide a peg for the authority to demonstrate that
it was going to be even-handed about its own land. There is a bit of a
"judge and jury in its own case" issue otherwise. This particular question
does not arise in the same way for land owned/polluted by other tiers of
local government.
2) There is of course an interesting question on funding issues for
remediation on land owned by town and parish councils. The basic "issue" is
that they are not entitled to receive supplementary credit approvals in their
own right. However, DETR, on a few occasions in the past, provided an SCA to
the borough/district council to pay for remediation on things like
parish-owned recreation grounds. This presents DETR with no problems - and
is the "normal" way that this type of capital funding gets to towns and
parishes.
JMLowe
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