Response from the Freshwater Taskforce to the SEPA/EA consultation on Draft Second Cycle River Basin Management Plan, June 2015.
Response to the Scottish Government’s consultation on the Improvement of the Physical Condition of Scotland’s Water Environment, by LINK’s Freshwater Taskforce, 21 May 2015.
LINK Freshwater Taskforce response to the SEPA consultation on the draft Second Cycle River Basin Management Plan for Scotland. March 2015
LINK Freshwater taskforce response to SEPA’s consultation on the Water Scarcity Plan for Scotland. February 2015 LINK Water Scarcity Consultation Response Final 02-15
LINK Freshwater Taskforce response to the consultation Implementing the Water Environment and Water Services (Scotland) Act: Environmental Standards for the Water Environment, 31 January 2014 Env Standards consultation_SE LINK response Final
Response to the Scottish Government / SEPA consultation on revising the Scottish Pollutant Release Inventory pollutant list and reporting requirements
Freshwater TF response to the consultation. LINK supports streamlining of legislation only when it does not compromise existing levels of environmental protection and enhances it.
LINK welcomes the opportunity to comment on the propsals for SEPA’s future funding arrangements. We are generally supportive of steps that are being taken to intergrate regulation to make it more resource-efficient and we recognise that the funding regime will be adapted to take this forward.
The Water Resources Bill must ensure that any developments of Scotland’s water resources is sustainable; LINK is concerned by the emphasis on development for economic gain. We seek clarity on the intention of the provisions relating to large-scale abstractions and urge that appropriate steps are in place to ensure full accountability of Ministerial decisions.
Response to the consultation ‘Investing in and paying for your water services from 2015: an invitation to engage with the Government and to provide your views’ from LINK’s Freshwater taskforce.
LINK is broadly supportive of any steps that can be taken to integrate and streamline regulation provided that this does not happen at the expense of environmental protection.
Response from LINK’s Freshwater Taskforce to the Scottish Government’s consultation on the ‘Hydro Nation’ vision and proposals for the Water Resources Bill. 10 pages 12 March 2012
Flooding in Scotland: A Consultation on Potentially Vulnerable Areas and Local Plan Districts, response prepared by LINK Freshwater Taskforce. We are please that SEPA has amended the proposed boundaries of Local Plan Districts and reduced the number of local groups following concerns from stakeholders such as LINK. We appreciate the considerable effort that SEPA have … Read More »
LINK is extremely supportive of the proposals regarding tougher enforcement of environmental regulation and stronger sanctions for environmental crime. We agree that SEPA should be given powers to recoup costs from successful prosecutions. We are concerned about proposals relating to the targeting of SEPA resources towards high-risk activities which must not result in SEPA expending less … Read More »
LINK is extremely concerned by the poor reference to the environment and sustainable development in the consultation document. We believe that the principles proposed to guide the future development of Scottish Water are lacking and should be revised to ensure that they are consistent with principles of sustainability. As a public body, Scottish Water has … Read More »
Response to SEPA’s Flood Risk Management (Scotland) Act 2009 consultation: ‘Planning for floods – planning for the future’ We welcome SEPA’s ‘Planning for floods – planning for the future’ consultation and appreciate the considerable effort that SEPA has invested in considering the best options for flood risk management planning. However, we feel that some of … Read More »
LINK Freshwater Taskforce response to SEPA consultation on the Scottish and the Solway Tweed River Basin Management Plans (RBMPs). We are concerned that the draft RBMPs lack in the consideration of a full range of measures that can help deliver objectives. The Plan still has the appearance of being more informative than aspirational.
LINK Freshwater Taskforce response to consultation on Implementing the Water Environment and Water Services (Scotland) Act 2003, Scotland’s Water: Future Directions. LINK is disappointed by the projected level of improvement in ecological status of 6% by 2015, which is amongst the lowest rates of improvement in Europe.
LINK Freshwater Taskforce response to the Scottish Government Consultation on Implementing the Water Environment and Water Services (Scotland) Act 2003: Development of Environmental Standards and Condition Limits, Phase II. Ten areas of concern are summarised, plus general points and detailed points are given.
The Freshwater Taskforce of the Scottish Environment LINK welcomes the Scottish Government consultation on the future of flood risk management in Scotland. We see this as an opportunity to make progress from the current fragmented approach to flooding towards a more sustainable, modern approach that works with, rather than against the natural processes. Benefits will … Read More »
A response by the Freshwater Taskforce of the Scottish Environment LINK to the SEPA Significant Water Management Issues report for Scotland RBD. We are generally content with the progress that has been achieved with the identification of the most widespread water management issues and appreciate the efforts of the SWMI team has made in getting … Read More »
UKTAG Consultation on Proposals for Environmental Quality Standards and Conditions – Phase 2: Surface water standards and conditions
The Standards and Conditions that will be required to meet Good Ecological Status (GES) are an essential part of the Water Framework Directive (WFD). We welcome the effort that has been put into developing these standards, and recognise the difficulties in developing new environmental standards from scratch across the UK, and before the full results … Read More »
A response to the Water Industry Commission’s (WIC) Approach to the 2010-14 Price review consultation by the Freshwater Taskforce of Scottish Environment LINK. We believe that it is unacceptable for the customers of Scottish Water to be paying for the cleanup of pollution caused by other activities outwith their direct control To achieve sustainable use … Read More »
LINK is broadly supportive of the measures suggested in the consultation. We believe that the proposals should not be weakened in any way. It is important that the Directive is implemented properly now so that constant re-adjustment is not required. For this reason, we would also be keen to see a phosphorus action programme included. … Read More »
Comments on Proposals on environmental standards and conditions – Phase 1. Link Freshwater Task Force response to the Scottish Executive consultation on the implementation of the WEWS (Scotland) Act 2003 The introduction of environmental standards is a key aspect of implementing the Water Framework Directive. Ecological standards will guide the improvements that may be necessary … Read More »
Freshwater Task Force response to the Scottish Executive consultation on the implementation of the WEWS (Scotland) Act 2003; Principles for the objective setting for the River Basin Management Plan. The objective setting process must protect against the unnecessary degradation of environmental objectives, and ensure appropriate use of economic tools to guide the objective setting process.
UK Technical Advisory Group on the Water Framework Directive – Draft Report on UK Environmental Standards and Conditions (Phase 1)
While standards and conditions proposed by the UK Technical Advisory Group (UKTAG) display considerable progress, we believe a number of important revisions need to be made before they can be accepted as final. The relationship between these standards and the broader classification and objective-setting process for the Water Framework Directive (WFD) also needs to be … Read More »
The Diffuse Pollution Strategy will play a very important role in delivering the objectives of the European Water Framework Directive (WFD), and have major benefits for wider environment and the society.
LINK Freshwater Task Force (FTF) response to the consultation by the Water Industry Commissioner
We greatly welcome proposals to designate local authorities, Scottish Water, Scottish Natural Heritage, Forestry Commission, National Park Authorities, District Salmon Fishery Boards, British Waterways and Port Authorities as designated authorities under the WEWS Act. The designation order will give these authorities important functions, which are necessary to ensure the delivery of WFD aims and objectives. … Read More »
LINK Freshwater Task Force response to the consultation by the Water Industry Commissioner on Strategic Review of Water Charges 2006 – 10 We urge the Water Industry Commission and Scottish Ministers to ensure that Scottish Water is able to meet its legal environmental obligations, as well as obligations towards sustainability. All Ministerial objectives, essential and … Read More »
LINK welcomes the Scottish Executive’s attempt to simplify General Binding Rules (GBRs), and introduce higher flexibility to ensure effective and practical regulations. We already mentioned in our previous responses that we greatly welcome the introduction of ‘soft licencing’ instead of registration GBRs that would allow SEPA better control over small-scale activities that could have cumulative … Read More »
Response to SEPA consultation. While we are generally pleased with the format of the report, and the presentation of complex and technical results, we are concerned by the lack of explanation of the underlying processes used to derive the good ecological status, and methods used to classify water bodies into risk categories. We are especially … Read More »