Determining Responsibility For Contaminated Land

Have you ever wondered who is responsible forfrom Bawtry and District Gas Company and
contaminated land when the original polluter noSouth Yorkshire and Derbyshire Gas Company to
longer occupies or owns the land? The currentthe British Gas Corporation. The site was later
position of the law is that the polluter who causedsold to Kenton Homes Ltd and then to Kenneth
or knowingly permits the contamination of theJackson Ltd, which applied for and obtained
land should pay for the remediation caused by hisplanning permission to build houses on the site.
actions. However, if the polluter can no longer beFollowing this eleven residences were built , seven
traced, then the owner or occupier of theof which were, for a time, owned by the
contaminated land in question may be classified asSecretary of State for Defense but subsequently
an appropriate person regarding the remediationall eleven passed into private ownership. According
of the contamination.to the section 78F of the Environment Act,
The issue of an appropriate person was raised inBawtry and District Gas Company and South
the National Grid Gas Plc case, where the pollutersYorkshire and Derbyshire Gas Company, and East
could not be traced and the Environment AgencyMidlands Gas Board were classified as appropriate
exercised it discretion not to pursue any of thepersons, as were Kenton Homes Ltd and Kenneth
current owners or occupiers on the contaminatedJackson Ltd for knowingly permitting the
land. Rather the agency directed its cost recoverycontamination to remain. But all these companies
efforts against National Grid Gas Plc (previouslyhave been dissolved! The present owners and
Transco), being a company which had beenoccupiers of the eleven residences could also be
established as part of the corporate reorganizationclassified as appropriate persons but the
of British Gas Plc a few years after theEnvironment Agency decided not to pursue them,
privatisation of the Gas industry. This was basedrather they decided to pursue the National Grid
on the argument that the person who caused orGas Plc based on the proposition that the statute
knowingly permitted the contamination should beincludes every person who became by statute
construed to include every person who becamethe successor to the liabilities of the actual
by statue the successor to the liabilities of thepolluters.
actual polluter.The courts held that National Grid Gas Plc had not
The history behind this case was that Bawtry anditself caused or knowingly permitted the presence
District Gas Company and South Yorkshire andof the contaminating substances, since it had only
Derbyshire Gas Company constructed the gascome into existence 20 years after the site had
works on the site that caused the pollution. Thebeen sold for housing; and there is nothing in the
gas industry was then nationalised by the Gas ActAct to impose on a company innocent of any
1948 which provided that all property, rights,polluting activity a liability to pay for remediation
liabilities and obligations of Bawtry and District Gasof the contamination caused by a polluter. Despite
Company and South Yorkshire and Derbyshirebeing the statutory successor to the original
Gas Company be brought under the ownershippolluters, National Grid Gas Plc is not an
and control of the East Midlands Gas Boards. Gasappropriate person within the meaning of the Act.
production on the site was then discontinuedThus an appropriate person according to the Act
shortly after nationalisation. The Gas Act of 1972shall include the original polluters that caused the
then transferred the property, rights, liabilities andcontamination, persons who knowingly permit the
obligations of the Area Gas Boards to the Britishcontamination, the current owners or occupiers
Gas Corporation. This transferred any liabilities ofwhere the polluter cannot be identified - but would
the East Midlands Gas Board arising out of itsnot include the statutory successor of the polluter.
previous ownership of the contaminated site orThis article is free to republish provided this
inherited under section 17(1) of the 1948 Actresource box remains intact.