John Comber - Associate

• LLB (Exhibitioner, King’s College, London University)
• Barrister (Lord Justice Holker Exhibition, Gray’s Inn)
• Over 30 years of experience within government of domestic and community legislation and specialising in environmental law for 21 years
• Head of the Environment (National) and Water Divisions of Department of the Environment (“DOE”), Department for Environment, Transport and the Regions (“DETR”) and Department for Environment, Food and Rural Affairs (“Defra”) from 1986 to 2003
• Government lawyer involved in 21 major Government Bills with lead responsibility for the legal team for 14 of these
• Extensive experience of the preparation and implementation of domestic legislation and negotiation and implementation of European Community legislation
• Succesful record of judge proofing and defending important and controversial decisions of the Government

2003 to date
• Consultancy with Defra Legal in connection with the final parliamentary stages of the Water Act 2003, the drafting of the form of the new water supply licences and the implementation of the Water Framework Directive
• Consultancy with Defra Waste Management Division in connection with guidance on the meaning of waste in the Waste Framework Directive
• Consultancy with the Department for Regional Development (Northern Ireland) in connection with their Water Reform Project
• Major contributor to an internal review carried out by the Department for Regional Development (Northern Ireland) in connection with their Water Reform Project
• Appointment by the Secretary of State to decide the first appeal under the Waste Packaging Regulations
• Consultancy with Environment Agency in connection with waste protocols project

1986 to 2003
Head of the Environment (National) and Water Divisions of the Legal Branch of DOE, DETR and Defra with responsibility for advising and preparing primary and secondary legislation in relation to:

• climate change levy
• emissions trading schemes
• the regulation of the privatised water industry
• drinking water quality
• water and sewerage law
• the management of water resources, including the control of water pollution
• reservoirs
• air pollution
• integrated pollution prevention and control
• the control of radioactive substances and waste
• waste management
• sponsorship of National Rivers Authority and subsequently the Environment Agency

Projects completed during this period included:
• work on the Climate Change Levy (energy intensive installations) and Climate Change Agreements with industry
• preparation of the first UK national emissions trading scheme
• the implementation of the Reservoirs Act 1960
• the implementation of the water discharge licensing system in Part II of the Control of Pollution Act 1974
• the establishment of joint waste disposal and waste regulation authorities and implementation of the waste management system in Part I of the Control of Pollution Act 1974
• the preparation and implementation of Public Utilities and Water Charges Act 1988
• water metering trials
• the preparation and implementation of the Water Act 1989
• the establishment of the National Rivers Authority, OFWAT and the Drinking Water Inspectorate
• the privatisation of the water industry
• the establishment of Her Majesty’s Inspectorate of Pollution and the implementation of integrated pollution and air pollution controls in Part I of the Environmental Protection Act 1990
• the implementation of the drinking water directive and surface water abstraction directive
• the implementation of the dangerous substances directive (and various daughter directives), the freshwater fish directive, the shell fish directive and the bathing waters directives
• the consolidation of the water industry, water resources and statutory water companies legislation
• the preparation and implementation of the provisions relating to the water industry in the Competition and Service Utilities Act 1992
• the transposition of the Waste Framework Directive and the implementation of the waste management provisions in Part II of the Environmental Protection Act 1990
• the implementation of the landfill directive
• the preparation and implementation of the Environment Act 1995
• the establishment of the Environment Agency
• the preparation and implementation of the Water Industry Act 1999
• the consolidation of radioactive substances legislation
• the consolidation of clean air legislation
• the negotiation and implementation of the Water Framework Directive
• the negotiation and implementation of the IPPC Directive
• the implementation of the Dangerous Substances and Groundwater Directives
• the implementation of the Air Framework Directive and the first daughter Directive
• the preparation of the Water Act 2003

1982 – 1986
Head of housing division of DOE Legal with responsibility for the preparation of and advice in relation to right to buy legislation, housing defects and building regulations and advice to the Property Services Agency and Crown Suppliers on contractual and other matters.

1977 – 1982
Senior Legal Assistant in DOE Legal advising and preparing legislation in relation to housing, local government finance and local government superannuation.

1975 – 1977
Cabinet Office – preparation of Scottish and Welsh Devolution legislation.

1973 –1975
Joined DOE Legal as direct entrant Senior Legal Assistant advising on and preparing legislation on housing.

1970 – 1973
Council of Legal Education – Senior Lecturer in Law.

1967 – 1970
Greenwood & Co, accountants.