Advice re 'object' in context of Planning Act 2008 process

Further to our telephone conversation on 26 September 2012, I've set out below the key points regarding statutory parties' (for example, CCW's) ability to 'object' under the Planning Act 2008 (2008 Act) regime if they become an interested party during the examination of an application for development consent.
It would, of course, be possible for such bodies to also raise their concerns about a proposed application with developers at the pre-application stage, for example in their responses to s.42 consultation, and to inform the Planning Inspectorate of these concerns.
Relevant statutory parties' role under the 2008 Act, during examinations, is to participate in the examination and let the Examining Authority (ExA) know what their views are on the merits and impacts of a proposed scheme. This could be in their relevant and written representations, in response to ExA questions, through statements of common ground with applicants, and in oral representations at any hearings.
The 2008 Act does not contain any powers for any statutory bodies to issue a holding objection as bodies such as CCW can do under the TCPA 1990. In other words their role is purely 'advisory' in relation to a DCO application and the decision made on it, although they may still be the decision maker in relation to any other consent or licence that an applicant may require in connection with a particular proposal.
In expressing their views to an ExA on a DCO application a statutory party need not make a judgement on whether they consider an application should be granted or refused. This judgement is ultimately for the relevant Secretary of State to make, as decision maker, after they receive the report of recommendation from the ExA. However, this does not preclude a statutory party from letting an ExA know what their views are on whether an application should be granted or not.
In the interest of clarity, in helping matters to be examined within the statutory deadlines, and to avoid any 'surprises' at the decision stage, it would seem helpful if statutory parties could be as clear as possible in expressing their views on an application. This may therefore include them being explicit and clear on whether they consider that impacts/issues raised on an application are so severe (and/or proposed mitigation is insufficient and/or unsecured etc.) that unless specific points are addressed they are advising the ExA to recommend refusal. In this context statutory parties could use terms such as 'object' or 'oppose' as an expression of their assessment of the severity of the situation.
At the same time it is important that should a statutory party state in their representation that it 'objects' to or 'opposes' a proposal then it should provide sufficient reasons for this stance which the ExA can then consider and/or explore.
I hope this advice is helpful and clarifies the situation for you and CCW.