Environmental Law News Update

In this latest Environmental Law News Update Christopher Badger and William Upton consider ClientEarth’s recent successful air quality case against the government and the publication of the Environment Agency’s corporate scorecard.

 

Air Quality: ClientEarth 4, HM Government 1

As the national press noted last week, ClientEarth has yet again succeeded in court in its case against the government about the Air Quality Plan for tackling roadside nitrogen dioxide concentrations. The judgment makes it clear that it is likely that the Court will make a mandatory order requiring the urgent production for England of a Supplement to the 2017 Plan containing measures sufficient to rectify the deficiencies identified. It will also direct that the 2017 Plan remains in force whilst the Supplement is produced – in order to avoid yet more delay in its implementation. The Court is also considering allowing the ClientEarth a continuing liberty to apply.

The deficiencies relate to 45 local authority areas. The expectation that they will achieve compliance with the statutory NO2 limit values by 2021 is not soon enough. There was some comfort for the Government, as the Court did not declare that the measures that relate to the five cities that will have to introduce Charging CAZs, and the 23 other authorities (plus London) that are likely to have to do so, are unlawful, even though compliance in those areas will not be achieved until after 2021. Even so, the failure by the Welsh Government to have any proper AQ Plan is unlawful, and further steps will be required there as well.

As Garnham J explained in his November 2016 judgment, and had to repeat again here, “the proper construction of [the EU Directive] imposes a three-fold obligation on the Secretary of State; he must aim to achieve compliance by the soonest date possible; he must choose a route to that objective which reduces exposure as quickly as possible; and that he must take steps which mean meeting the value limits is not just possible, but likely. It follows that the Secretary of State must ensure that there is in place a plan for each zone which meets the three-fold obligation”.

Garnham J also emphasised that the importance of this case is about the substance of the issue as well as about the prolonged failure by the government to comply properly with the law:

“5. Proper and timely compliance with the law in this field matters. It matters, first, because the Government is as much subject of the law as any citizen or any other body in the UK. Accordingly, it is obliged to comply with the Directive and the Regulations and with the orders of the court. Second, it matters because, as is common ground between the parties to this litigation, a failure to comply with these legal requirements exposes the citizens of the UK to a real and persistent risk of significant harm. The 2017 Plan says that “poor air quality is the largest environmental risk to public health in the UK. It is known to have more severe effects on vulnerable groups, for example the elderly, children and people already suffering from pre-existing health conditions such as respiratory and cardiovascular conditions”. As I pointed out in the November 2016 judgment, DEFRA’s own analysis has suggested that exposure to nitrogen dioxide (NO2) has an effect on mortality “equivalent to 23,500 deaths” every year.”

This “UK plan for tackling roadside nitrogen dioxide concentrations” has not had a happy history since the first one was published in 2011. The document before the court this time was the third attempt by the UK to meet its obligations, and the fifth time the matter has been in court since the Supreme Court made a mandatory order requiring the Secretary of State to prepare a new air quality plan by 31 December 2015. ClientEarth are up 4:1 on these cases.

The Courts have themselves come a long way in their own attitude to the issue. The recent intervention by Garnham J can be contrasted with the situation in the first case, decided on 13 December 2011, when Mitting J decided that the government’s concession that it accepted that it would be in breach of its obligations was enough. Back then, he decided that it was inappropriate for the High Court to grant any declaratory relief, that it was not appropriate to grant any mandatory order requiring compliance and that it was for the European Commission to take any enforcement action (which, we can note, it now has).

This is of course the latest skirmish in a long war about air quality issues. The case only concerns the “UK plan for tackling roadside nitrogen dioxide concentrations” and its associated documents, and there are many other pollutants that are of significant concern – especially particulate matters. Whilst ClientEarth can only fight on so many fronts at any one time, their litigation is a healthy reminder of the need for action across the board to meet the UK’s air quality obligations. The implications of this case will continue to play out across a wider field.

 

Environment Agency publishes corporate scorecard

On 21 February 2018 the Environment Agency published its corporate scorecard for the second quarter of 2017/2018. It has been a mixed bag of results this quarter.

In particular, the EA missed its target to reduce the number of high-risk illegal waste sites. Whilst illegal and problem waste sites are treated as a high priority, operational resource remains under pressure to work through a backlog of historic reports of illegal activity and support major investigations to close down well organised criminal operations. A total of 280 illegal waste sites are recorded in the scorecard, outside of the target of 238 set by the EA and 6 more than the previous quarter. Part of the actions that the EA has adopted include the development of an enforcement strategy for waste to help embed alternative approaches to reducing levels of waste crime but it is not forecast to improve its ‘red’ score by the end of the year.

In contrast the scorecard records that the EA continues to secure improvements to the water environment, continues to reduce serious pollution incident from a high of 696 in Q4 2013/2014 to 394 in Q2 2017/2018 and continues to reduce its own carbon footprint.

In total there are 12 corporate measures for the EA. These are:

  • the water environment is healthier
  • the EA protect people, the environment and wildlife by reducing serious pollution incidents
  • the EA create new habitats
  • the EA reduce the number of high risk illegal waste sites
  • the EA reduce the risk of flooding for more households
  • the EA maintain our flood and coastal risk management assets at or above the target condition
  • the EA have a first class incident response capability
  • the EA manage our money efficiently to deliver our outcomes
  • the EA respond to planning applications within 21 days
  • the EA reduce our carbon footprint
  • the EA have a diverse workforce
  • the EA provide a safe place to work

The corporate scorecard can be found here

 

Have you seen our NEW Environmental Law Video Newscast – a monthly round-up of the latest developments in environmental law. January’s edition can be viewed here. Future editions will be available at the end of each month on our website.

To keep up-to-date follow us on Twitter @6pumpcourt or contact bridget.tough@6pumpcourt.co.uk to be added to the mailing list. If you have any comments or suggestions please feel free to contact us.

 

Environmental Law News Update

In this latest Environmental Law News Update, Christopher Badger, Mark Beard and Antony Bartholomeusz consider the Supreme Court’s decision in Mott v Environment Agency, a proposed Brexit bill amendment to maintain EU law environmental principles, and landfill tax on unauthorised disposals.

 

Environment Agency liable to pay damages for breach of Convention Rights

On 14 February 2018, the Supreme Court handed down judgment in R (Mott) v Environment Agency [2018] UKSC 10, dismissing the Environment Agency’s appeal against the Court of Appeal’s ruling that it was liable to pay compensation under section 8 of the Human Rights Act 1998 for breaching Respondent’s right to peaceful enjoyment of his possessions under Protocol 1 Article 1 (“A1P1”) of the European Convention on Human Rights (“ECHR”).

The Respondent, Mr Nigel Mott, a septuagenarian fisherman held a leasehold interest in a fishery on the Severn Estuary. The fishery was a “putcher rank”, a traditional fishing technique involving the use of conical baskets to trap adult salmon as they returned to a river from the open sea to spawn. Catching salmon using this method was a commercial operation which had been Mott’s full-time occupation since 1979, requiring a licence granted annually by the Agency.

From 2012 the Agency imposed a condition on his licence limiting his annual catch very substantially. The Agency judged the conditions necessary to protect salmon stocks in the River Wye, a Special Area of Conservation designated under the Habitats Directive. Although the catch limit conditions limited the Mr Mott’s catch by 95%, the Agency paid him no compensation.

Mr Mott sought judicial review of the Agency’s decisions to impose the conditions claiming that the conditions made his fishery wholly uneconomic to operate. He also claimed that the decisions were irrational and in breach of his property rights under A1P1. In the Administrative Court, the Judge held that the decisions were irrational and that, under A1P1, the Agency could not properly have imposed the conditions, if otherwise lawful, without payment of compensation. The Court of Appeal allowed the Agency’s appeal on the issue of irrationality, but dismissed the appeal under A1P1.

The Agency’s appeal to the Supreme Court was limited to the A1P1 ground. The issues arising in the appeal were: (i) whether the conditions imposed by the Agency amounted to control or de facto expropriation under A1P1; (ii) if the former, whether the fair balance required compensation to be paid; and (iii) if the latter, whether exceptional circumstances justified the absence of compensation.

The Supreme Court unanimously dismissed the Agency’s appeal. Lord Carnwath gave the lead judgment with which the other Justices (Lady Hale (President), Lord Kerr, Lady Black, Lord Briggs) agreed.

The Court held that the ECtHR case law showed that the distinction between expropriation and control was neither clear-cut nor crucial to the analysis in the instant case (see Hutten-Czapska v Poland (35014/97) (2007) 45 EHRR 4). The need to attach special importance to the protection of the environment did not detract from the need to draw a fair balance between public and private interests. Nor did it detract from the potential relevance of compensation.

The Supreme Court was unable to fault the judge’s analysis of the applicable legal principles in this case. The fact that the conditions imposed by the Agency were closer to deprivation than mere control was clearly relevant to the fair balance. The Agency gave no consideration to the particular impact on Mr Mott’s livelihood, which was severe, and it was doubtful whether the leasehold interest retained any value.

The Court emphasised that this was an exceptional case on the facts, because of the severity and the disproportion (as compared to others) of the impact on Mr Mott. The Court reiterated that national authorities have a wide margin of discretion in the imposition of necessary environmental controls, and A1P1 gives no general expectation of compensation for adverse effects. Furthermore, where (unlike Mr Mott’s case) the authorities have given proper consideration to the issues of fair balance, the courts should give weight to their assessment.

Mark Beard represented Mr Mott in the Administrative Court, the Court of Appeal and was led by Stephen Hockman QC in the Supreme Court

The judgment and press summary are available on the Supreme Court’s website.

 

Proposed Brexit Bill amendment to maintain EU Law environmental principles

Three peers, Baroness Jones of Whitchurch, Lord Krebs and Baroness Bakewell of Hardington Mandeville have proposed an amendment to the Brexit bill to incorporate EU law environmental principles into English law post Brexit. It is headed ‘Maintenance of EU environmental principles.’ It must be noted that this is a proposal that does not presently form part of the bill and would need to be accepted by both houses of Parliament in order for it to become the law.

The amendment has four parts. Firstly, it requires public authorities to ‘have special regard to, and apply’ five European environmental principles. These are:

  • the precautionary principle;
  • the preventative action principle;
  • the principle that environmental damage should be rectified at source;
  • the polluter pays principle; and
  • the principle that environmental protection requirements should be integrated into policies, with a view to promoting sustainable development.

This duty on public authorities would be broader than present. Currently, EU law contains these principles, but they are focused on regulating the EU’s activities: they only apply to the Member States when they are implementing EU law. Consequently the proposers of this amendment would influence the basic principles underlying the UK’s post-Brexit environmental policy, rather than simply replicating the present substantive legal position.

Secondly, the amendment requires that public authorities would take into account the public interest in environmental protection in various specific ways. There is reference to promoting sustainable development in the United Kingdom and overseas, promoting international measures to tackle regional or global environmental problems such as climate change, guaranteeing participatory Aarhus-type rights (although Aarhus will continue to apply post-Brexit), and taking into account technical and scientific data.

Thirdly, there is a proposed requirement that public authorities take a high level of protection as a base and take into account new scientific facts when making proposals concerning environmental protection.

Finally, the amendment allows courts to make a ‘declaration of incompatibility’ when it determines that primary or subordinate legislation is incompatible with the environmental principles. Clearly the proposers sought to mirror the mechanism for a declaration of incompatibility contained in the Human Rights Act 1998. But much of the detail found in that act is not replicated here: it is not clear, for example, what the consequences of a declaration of incompatibility would be, nor is the concept of primary or subordinate legislation defined.

What is clear, however, is the intent that the environmental principles should be justiciable, rather than mere political commitments. The problem may be whether the words “have special regard to, and apply” are strong enough to meet the objectives of the proposers of the amendment. Declarations of incompatibility ordinarily require a fundamental norm to have been defined. Perhaps they should consider a mandatory obligation on local authorities to “contribute to the pursuit of” specific environmental goals, rather than having regard to principles.

 

Landfill tax on unauthorised disposals

The Landfill Disposals Tax (Tax Rates) (Wales) Regulations 2018 were published on 31 January 2018 and come into force on 1 April 2018. They introduce the first rates for the landfills disposals tax, which is a devolved landfill tax for Wales. These are:

  • Standard rate of £88.95
  • Lower rate for qualifying disposals of £2.80
  • A new third category for unauthorised disposals of £133.45.

For a taxable disposal made at an authorised landfill site, tax is to be calculated by reference to the weight and type of material disposed of. For a taxable disposal made at a place other than an authorised landfill site, tax is to be calculated by reference to the weight of the material alone.

This new third category could be significant. In confiscation proceedings brought against operators responsible for illegal disposals, is not uncommon to debate what would it have cost the operator to dispose of this waste at an authorised landfill site. Working out the answer brings into play such questions as what the operator could have done with the waste, i.e. could he have had the waste sorted such that only a small proportion would have had to be landfilled? On the face of it, this third category for unauthorised disposals removes that debate and fixes a financial liability for unauthorised deposits. The only live issue will be how much waste was disposed of.

The Finance Bill is currently making its way through Parliament. It addresses the liability to landfill tax of those that dispose of waste an unauthorised landfill sites but it has no reference to a third category of tax for unauthorised disposals. As a result, the type of waste concerned and what could have been done with that waste remain relevant issues in the context of avoided costs. Devolution has created a divergent approach to unauthorised landfill sites, whether such divergence is justifiable is another matter.

 

Have you seen our NEW Environmental Law Video Newscast – a monthly round-up of the latest developments in environmental law. January’s edition can be viewed here. Future editions will be available at the end of each month on our website.

To keep up-to-date follow us on Twitter @6pumpcourt or contact bridgettough@6pumpcourt.co.uk to be added to the mailing list. If you have any comments or suggestions please feel free to contact us.

2018 and the great ‘ambition’ divide

Posted by: Frances Lawson

Two recent items of international climate change news have placed into stark focus one of the issues set to take centre stage later in the year. After a controversial ‘leak’, the draft of the Intergovernmental Panel on Climate Change’s (IPCC) much awaited report on the 1.5 degree warming target in the Paris Agreement, and on the consequences of not meeting that target, have unexpectedly entered the public realm. Embarrassed, the IPCC has stated that its findings and recommendations could alter ‘substantially’ between the first and the final draft. But at the moment, its message is clear, albeit not particularly new; even 1.5 degrees will have severe consequences for poor and coastal regions in particular, and is likely to see ocean reefs deprived of coral and the Arctic relieved of ice. If we only constrain global warming to 2 degrees, an extra 10cm rise in sea level is expected over the course of this century relative to 1.5 degrees of warming. Those are just selected excerpts from a grim set of scientific predictions – see the report here

Endeavouring to keep to 1.5 degrees of warming therefore is set to be the IPCC’s headline message when the final report is published in May. Meeting the 1.5 degree target, however, will require what the draft report describes as a level of global cooperation hitherto unknown in the history of mankind.

And that’s where we look ahead to the next major international climate change conference – COP24, to be held in Katowice, Poland. What are the prospects of Katowice delivering an unprecedented level of global cooperation in furtherance of the 1.5 degree objective? Judging by the early pronouncements coming from the Polish government, the prospects are slim indeed. Two weeks ago, Poland’s lead negotiator gave a public statement saying that at COP24, his country will put “common sense over calls for ambition”. In case one should be optimistic in thinking that Poland’s idea of “common sense” might align with that of the IPCC, he went on to add that this means prioritising poverty eradication and energy security over what he called “enthusiasm”. The global warming limits contained in the Paris Agreement are, he said, “unattainable” see more here

On this basis, COP24 looks likely not only to fail to secure the global cooperation needed for any chance of limiting warming to 1.5 degrees, but also for meeting the 2 degree target, too. If ever there was a need for a new legal approach to international climate change, that time looks set to be upon us.

Environmental Law News Update

In this latest Environmental Law News Update, Christopher Badger considers new draft waste enforcement regulations, the sentence imposed on the operator of an illegal landfill site and a report requested by the European Commission on financing a sustainable economy.

 

Draft Waste Enforcement (England and Wales) Regulations 2018

Draft Regulations have been laid before Parliament that allow the Environment Agency to serve a notice on the occupier of land requiring them to remove waste that is being illegally stored on land, irrespective of whether or not the waste was illegally deposited in the first place.

On appeal, a court must quash the requirements imposed by the notice if it is satisfied that the appellant did not keep or dispose of, or knowingly cause or knowingly permit the keeping or disposal of the waste or if there is a material defect in the notice and, in any other case, may modify the requirements or dismiss the appeal.

It will be a criminal offence to fail to comply with such a notice. Where there is no occupier of land, or the occupier cannot be found without incurring reasonable expense, the notice can be served on the landowner.

The same draft Regulations also enable Regulators to restrict access to a waste site by physical means where an authorised person is satisfied that there is actual, or risk of, serious pollution or serious harm to health at a waste site and that the notice is necessary to prevent that risk from continuing. This can be done either though a restriction notice that has effect for up to 72 hours or a restriction order issued by a court that can have effect for up to six months. Strict time limits apply to applications to the Magistrates’ Court and appeals are to be made to the Crown Court.

The Regulator can apply to the courts for reimbursement of expenditure for the purpose of securing premises in respect of which a restriction order is in force. However, the Regulator can also be ordered to pay compensation to either the occupier or owner of premises to which access was impeded by a restriction notice or a restriction order, where the Court considers that it is appropriate to do so.

The risk that landowners may find themselves financially at risk for the removal of waste legally brought on to their land may encourage the development of greater scrutiny of the financial circumstances of tenants and enhanced financial provision. Waste crime has been identified by the Government as one of the most urgent problems in the environmental sector. These new powers are part of the Government’s 2015 waste crime action plan and are just one element of the proposed extension of powers for the Environment Agency, other proposals being the current subject of consultation.

The draft Regulations can be found here

 

Suspended sentence for illegal landfill site

Eric Hale of Bank Top Farm near Frodsham has been sentenced to 12 months imprisonment suspended for two years, disqualified from driving, ordered to do 200 hours unpaid work and has had a three month curfew of 8am to 6pm imposed on him for operating an illegal landfill site. He has also had to pay £100,000 in costs. Two others received a conditional discharge for two years after pleading guilty to dumping and landfilling controlled waste.

A lengthy Environment Agency investigation identified significant amounts of waste brought on to the farm, linked to the activities of Eric Hale Skip Hire Ltd. Eric Hale, Steffan Street and Denis Whiting were all seen driving large waste vehicles which delivered, deposited and disposed of mixed waste, demolition waste including plasterboard and other waste including carpets and mattresses. Trommel fines, a by-product of recycling and consisting of wood, aggregate, ceramics and organics were also dumped at the Farm.

A 12-month sentence of imprisonment is the starting point for a deliberate category 2 offence. In this case 19 acres of Cheshire farmland was blighted by the illegal waste activities of the landowner. The Judge acknowledged that there were substantial personal mitigating circumstances in the case of Mr Hale that might explain why the sentence of imprisonment was suspended. The fact that the others received conditional discharges is a clear indication that the Court considered their roles to be demonstrably subordinate to Mr Hale’s role, although their imposition is a departure from the Guideline itself.

The Environment Agency’s press release can be found here

 

Final report on Sustainable Finance

The European Commission’s High-Level Expert Group on Sustainable Finance published its final report in financing a sustainable economy on 31 January 2018.

The Group was set up to provide advice on how to steer the flow of capital towards sustainable investments, identify steps that financial institutions and supervisors should take to protect the financial system from sustainability risks and deploy these policies on a pan-European scale.

Unsurprisingly, there is no single lever that will achieve these ambitions. The report recommends:

  • Establishing an EU “sustainability taxonomy”, starting with climate change, to define areas where investment is needed most;
  • Clarifying investor duties that will bring a greater focus on ESG factors into investment decisions;
  • Upgrading disclosures to make sustainability opportunities and risks transparent;
  • Enabling retail investors to invest in sustainable finance opportunities;
  • Developing official European sustainability standards;
  • Deploying development capacity in EU member states for infrastructure necessary for a more sustainable economy; and
  • Integrating sustainability firmly into the governance of financial institutions as well as in financial supervision.

There are a number of headwinds. Short-termism in financial markets can have a negative impact on long-term corporate investment and development. Ordinary citizens do not often have the opportunity to engage with sustainable finance, nor is there much by way of financial market transparency or guidance on this issue. More needs to be done to promote better disclosure of ESG information.

The report recognises that its aim is not to increase the regulatory burden on businesses but to facilitate more investment. There is a clear appetite to make sustainable finance a permanent feature of both the financial markets and policy-making. However, the report recognises that it will take considerable time to make sustainable finance the norm across Europe. It is proposed that the Commission will now come forward with an action plan on sustainable finance drawing on the recommendations in the report. Success will be measured on the extent to which sustainable finance begins to affect investment decisions and becomes a permanent feature of the investment landscape.

The full report can be found here

 

Have you seen our NEW Environmental Law Video Newscast – a monthly round-up of the latest developments in environmental law. January’s edition can be viewed here. Future editions will be available at the end of each month on our website.

To keep up-to-date follow us on Twitter @6pumpcourt or contact bridgettough@6pumpcourt.co.uk to be added to the mailing list. If you have any comments or suggestions please feel free to contact us.

Environmental Law News Update

In this latest Environmental Law News Update, Christopher Badger, William Upton and Mark Davies consider the impact in the UK of China’s ban on imported waste, a human rights claim for flood damage, and the launch of our monthly environmental newscast.

 

China says our “foreign garbage” is a waste of space

In July of 2017 the Chinese Government informed the World Trade Organisation that it intended to introduce a ban on the importation of certain types of yang laji (or “foreign garbage”, waste). That ban came into force on 1 January and includes all unsorted mixed papers, eight types of plastic waste (including PET plastic bottles), eleven types of textile waste (excluding clothing) and four types of metal slag; it is anticipated that, in particular, the ban on waste unsorted paper and plastics will have far reaching implications for everyday householders in the UK.

The ban is set to be complemented by the introduction of new Chinese standards on imported waste in April of this year which will limit all recycled materials to a maximum contamination level of 0.5%, a standard that many believe will be simply impossible to meet.

Industry commentators have warned that the ban is a ‘massive crisis’ and that we may see higher gate fees, more waste going to landfill, and increases in council tax as local authorities struggle to deal with the increased costs of household recycling waste.

Finally, it must be said that the ban has been introduced at an interesting time for the waste industry in the UK; statements from the UK Government in recent months, including renewed commitments to minimise waste in the 25 Year Environment Plan and proposals to introduce fixed-penalties for householders who breach their waste duty of care, would suggest that the policy landscape and attitudes to waste are shifting – we will have to wait and see how the Chinese ban will impact upon those policies in the long term.

 

A human rights claim for flood damage

The High Court has dismissed a case taken by landowners in Gloucestershire who claimed that the Environment Agency had breached their human rights by allowing their farmland to flood to protect urban areas (King v Environment Agency [2018] EWHC 65 (QBD)). The case is notable for several reasons.

Firstly, there was no claim in negligence or nuisance before the court. It was only argued as a claim for compensation for a breach of the right to property and personal discrimination (Art 1 of Protocol 1 and Article 14 of the European Convention of Human Rights).

Secondly, the Court did find that there was an implicit Agency policy to use the claimants’ land for the purpose of floodwater storage in order to help protect the city of Gloucester, despite their denial.

Thirdly, the judge did not consider that this policy constituted a “control or interference” with the claimants’ property under A1P1. That is an odd conclusion, given that there was clearly an implicit interference with the claimants’ property rights to defend their own land as they saw fit. The better conclusion is the one the Court went on to make, by holding that “there had in any event been a fair balancing of the claimants’ rights with those of the general interest, as required by A1P1.” Flood management is clearly a matter of public policy, and a choice has to be made about what areas should be defended and to what level of defence, as well as about the amount of public money that can be spent on it. Both parties placed considerable reliance on Marcic v Thames Water Utilities Ltd [2004] 2 AC 42 as regards striking the fair balance. There will be instances when this does impose a disproportionate burden on certain individuals in the public interest.

Fourthly, the judge also ruled that there was no basis to the claim that the landowners had been the subject of unlawful discrimination contrary to Art.14 of the Convention. The claimed discrimination “was not on the basis of a personal characteristic”, and there was a clear difference between the claimants’ position and flood defence schemes where the Agency had compensated the landowners. This is perhaps one of the less satisfactory parts of the case, not helped by the fact that there had been a failure by the Agency team to disclose relevant information as a responsible public body should do. It was only on cross-examination of the Agency’s witness that it was learnt that there were some 150-200 schemes where compensation had been paid, despite earlier requests for such information.

 

Environmental Newscast launches

In association with Lexis PSL, Six Pump Court has launched a monthly environmental newscast. The video is intended to pick up on the month’s three biggest environmental law stories, providing comment and insight in a different format to our written weekly blog.

The newscast is hosted on Lexis PSL’s YouTube channel and we will provide a link from our website and via twitter.

For the latest update broadcast last week click here

Any comment or feedback is extremely welcome, so please do feel free to contact us with any suggestions.

 

To keep up-to-date follow us on Twitter @6pumpcourt or contact bridgettough@6pumpcourt.co.uk to be added to the mailing list. If you have any comments or suggestions please feel free to contact us.