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Industry representatives said the 100% offsets requirement had not been raised in its consultations with the EPA and would impose unreasonable costs compared with developments in other states and countries.
The charity said across the 10 countries, less than half of the children seen in its consultations were properly immunised against tetanus, measles, mumps and rubella and more than half pregnant women had not had access to antenatal care until they were well into their second trimester.
"I believe that the council has not properly considered the alternatives to closure, the likely effect on the local community and the transport arrangements in its consultations on these school closures.
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In its consultation paper, it has suggested taking into account local digital radio stations which are provided on numerous local multiplexes, and have quasi-national coverage.
The report said it dismissed privatisation, with most of more than 10,000 individual submissions in its consultation opposing it, thousands of which were generated by supporters of the Campaign for Better Transport and We Own It campaigns.
They created a list of answers to the 20 questions the regulator posed in its consultation paper that users could copy, paste and email to it in just three clicks.
The government's case is outlined in its consultation paper.
"The government's offer in its consultation is simply not good enough.
In its consultation document, the government acknowledged the potential impacts on the landscape.
Defra acknowledged in its consultation that "potential distortions in the wider policy landscape" have given diesel an "unfair advantage".
Questions asked of parents by the Harris academies chain in its consultation for a new free school in East Dulwich, south London, seem designed to avoid negative responses.
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Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com