Environment – Environment Agency. In the case of new works involving entry onto land or premises, absent consent from the landowner, the Environment Agency was not confined by s 165(6) of the Water Resources Act 1991 to its compulsory purchase or compulsory works orders powers under ss 154 or 168. The Court of Appeal, Civil Division, held that, instead, the Environment Agency was entitled to exercise the powers of entry conferred by s 172.