Assesses the importance of "R (on the application of David Edwards) v Environment Agency, First Secretary of State, Secretary of State for Environment, Food and Rural Affairs and Rugby Limited" ([2005] EWHC 657 (Admin)). The claimant was granted permission to apply for judicial review of a decision of the first defendant , Environment Agency (EA), in 2003 to allow the Rugby Cement works in Rugby to burn waste tyres on a trial basis. It was held that although the 2003 decision was legally valid, EA should have made available an internal report on air quality assessment during the consultation period. Public consultation procedures on controversial Pollution Prevention and Control applications are likely to take longer after this judgment and EA will certainly need to review its practice on disclosure of internal reports during consultation procedures. The claimant is likely to seek leave to appeal from the Court of Appeal.