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As you say the self regulation of your DoWCOP work undoubtedly has teeth,  but only IF it is audited and enforced by the Environment Agency.  Hence, by definition it is not "self regulation”.

What is being proposed here is self regulation of contaminated land practitioners where the only audit of practitioners work and performance is undertaken by the practitioners themselves.  Not at all the same thing.   Now if it is proposed that the  Environment Agency/HPE (risk assessment work) audited practitioners work and performance and had powers to revoke registration without appeal, then you might have a case, but that is not what is being proposed...

In addition and for interest, how many of the (1000?) DoWCOP submissions have been audited by the Environment Agency?
I am of course very mindful that the Environment Agency is woefully under resourced and may have its priorities elsewhere.
David E Jackson
Sometime Freelancer