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The Impact Assessment (IA) looked generally well-prepared, covering many of the impacts that needed to be measured. The benefits assessment has been undertaken in a conservative manner minimising the risk of optimism. However, it is important that steps are taken to ensure that the benefits are actually realised.
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We are concerned that Statutory Instruments (SIs), and the IA, may not have recognised that the geographic area relevant to the Directive is wider than the UK – the Directive includes all areas where the UK has or exercises jurisdictional rights. Hence, for example, it appears to include surrounding sea areas and the atmosphere above them. The position of other areas, such as the Falklands (and surrounding areas), Gibraltar and the Channel Islands is not clear.
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For clarity, the SIs should note that INSPIRE includes data held on behalf of Public Authorities – thus data collected by the private sector may well be included if it is part of a statutory requirement.
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As a clarification, the Consultation Document should have made clear, in Annex 5 (on Related UK legislation) that the EIR does not require all information to be made available electronically and hence INSPIRE will not apply to such information.
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The underpinning idea of providing better access to information is strongly supported by APPSI; however this approach can easily become over-bureaucratic and expensive so safeguards to avoid this are essential.