24 June 2010, LINK Marine Taskforce

Comments on Marine Nature Conservation Strategy

Scottish Environment LINK’s Marine Task Force (LINK MTF) welcomes the opportunity to comment on the draft Marine Nature Conservation Strategy. We are largely supportive of the draft strategy as presented and we believe that the strategy will provide an excellent framework for our approach to marine nature conservation. However, we have some outstanding concerns and these are set out in the detailed comments below...

24 June 2010, LINK Marine Taskforce

Comments on ‘Marine Protected Areas in the Seas around Scotland: Guidelines on the selection of MPAs and development of the MPA network’

Scottish Environment LINK’s Marine Task Force (LINK MTF) welcome the opportunity to comment on the draft guidance on the selection of MPAs and development of the MPA network. We are largely supportive of the draft guidance as presented and we believe that the draft guidance provides an excellent framework for meeting our international commitment of setting up a representative, ecologically coherent network of MPAs. However, we have some outstanding concerns and these are set out in the detailed comments below...

17 June 2010, LINK Agriculture Taskforce

LINK response to the Common Agricultural Policy debate

Agricultural practice continues to cause significant environmental damage e.g. artificial inputs, and a general decrease in habitat heterogeneity has led to declines in farmland species and reduced the quality of the landscape. The focus of agricultural payments on the more productive types of farming, has also contributed to the abandonment of land which was managed using some of Europe’s more “marginal”, farming systems which are likely to be of greater environmental value. In Scotland, crofting is an example of such a high nature value system. Its small scale and low intensity forms of agricultural land use, can create and maintain valuable wild life habitats and iconic coastal and upland landscapes for all to enjoy.  The majority of funds continue to be paid out through pillar 1 of the CAP which is insufficiently targeted to produce public goods. Distribution of pillar 1 is unfair and in many countries rewards those most who also receive the best returns from the market. It is important that in future, funds are directed towards encouraging the production of environmental goods.

28 May 2010, LINK Planning Taskforce

LINK's response to the consultation on the draft order to modify designation order on the Cairngorms National Park

LINK supports the proposed extension of the southern boundary into Perth and Kinross.

18 May 2010, Joint LINK

Pre-Consultation On The Draft UK Marine Policy Statement: A Paper For Discussion

Following requests at the Defra MPS workshop in March 2010 for detailed comments and where possible make suggestions for changes and additions to the document, we have produced a detailed response to the discussion document.

A joint response to the DEFRA preconsultation on the Draft UK Marine Policy Statement. by; The Wildlife and Countryside Link Marine Task Force, the Scottish Environment LINK Marine Task Force, the Wales Environment Link Marine Working Group and the Northern Ireland Marine Task Force.

28 April 2010, LINK

Independent Budget Review, Initial Call

Response to the Scottish Government Independent Budget Review: Initial Call for Contributions

We recognise that there will be a reduction in the Scottish budget in the face of the current economic situation and support efforts to ensure that public expenditure is sustainable...

8 April 2010, LINK Sustainable Land Use Taskforce

LINK response to the Land Use Strategy SEA Scoping Report

LINK members welcome the opportunity to comment on this consultation and to support the development of the Land Use Strategy (LUS). LINK produced its ‘Living with the Land’ report in 2009 which set out LINK’s proposals for the vision, principles and definitions which, LINK believes, should underpin the LUS. We believe that the LUS has the potential to, and should, move land use planning away from a sectoral approach to one which achieves multiple objectives. It must seek synergies and reward multi-benefit land use, and must aim to resolve conflicts. Decisions need to be based on principles of sustainable development, in which environmental and social goals have equal status to economic ones.

10 March 2010, LINK Agriculture Taskforce

Future Agriculture Support Inquiry: Interim Report Response

LINK's response to the Interim Report of the Inquiry into Future Support for Agriculture in Scotland: LINK's vision for the future of agricultural funding is for a series of tiered payments aimed at delivering public goods which are otherwise undersupplied by the market.  This payment system would include a base payment with a series of management requirements attached: payments for High Nature Value farming and organic farming systems; targeted agri-environment payments for meeting the requirements of environmental legislation where this demands significant locally differentiated changes in practice.  Whilst LINK supports the aim of the inquiry and the rationale for future payments elaborated in the interim report, we disagree with the proposed funding mechanisms.   

13 November 2009, LINK

Scotland’s Zero Waste Plan

Keeping to the broader principles for a zero waste strategy, we believe that if the Scottish Government is truly to deliver a Zero Waste Scotland they must...

12 November 2009, LINK Planning Taskforce

Scottish Planning Policy (SPP) Proposed Policy Changes Consultation

Scottish Environment LINK Planning Task Force consultation response to the Scottish Government Scottish Planning Policy (SPP) Proposed Policy Changes Consultation.

We broadly welcome the changes proposed and particularly welcome the introduction of much improved policy on climate change, sustainable development and flooding. However, we must make it clear that we retain doubts about the implications of the scale of reduction in background information proposed compared with the current suite of SPPs and NPPGs. We also have some concerns about the somewhat disjointed nature of the further consultation on proposed alterations to the consultation draft only, rather than consultation on a complete draft document...

30 October 2009, LINK Agriculture Taskforce

Pack Inquiry Response

Response to the The Brian Pack Inquiry into Future Support for Agriculture in Scotland

LINK believes that agricultural support should be directed towards promoting sustainable development in rural areas...

18 September 2009, LINK Planning Taskforce

Consultation response to the Scottish Planning Policy (SPP) Consultative Draft.

The consolidated SPP could well lead to less effective and consistent development and application of policy, and perversely to more delays and challenges.

3 September 2009, LINK Wildlife Natural Environment

Wildlife and Natural Environment Bill Consultation

Scottish Environment LINK response to the Scottish Government's consultation on the Wildlife and Natural Environment Bill.  This bill covers a wide range of areas including;  deer, game law, invasive non-native species, species licensing, snaring, badgers, muirburn and SSSI and protected area revisions. 

LINK also believes that this Bill allows the opportunity to look at legisaltion regarding permitted development and the biodiversity duty.

12 June 2009, LINK Agriculture Taskforce

Response to Consultation on the Implementation of the Common Agricultural Policy Health Check in Scotland.

We believe that the Scottish Government has opportunities to ensure payments are better directed towards the provision of environmental and other public services provided by particular types of land management.

8 June 2009, LINK Woodlands Taskforce

Letter to Forest Enterprise

Letter to Forest Enterprise about the conditions of sale imposed on purchasers of former FES plantations, in particular commitments to maintain woodland management to UKWAS and UK Forestry Standards.

26 May 2009, LINK Freshwater Taskforce

Consultation on the Scottish and the Solway Tweed River Basin Management Plans

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.

18 May 2009, LINK Agriculture Taskforce

Response to Consultation on the Implementation of the Common Agricultural Policy Health Check in Scotland: Response to questions on Article 68.

Article 68 provides an opportunity to redirect funds to specific systems seen to be of value for environmental reasons, where SRDP funds have already proved insufficient to maintain them.

1 April 2009, LINK Freshwater Taskforce

Scotland's Water: Future Directions

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.

8 February 2009, LINK Scottish Environmental Fundraising Forum Taskforce

The Big Consulation

This paper is a joint response to the BIG Consultation from the undernoted members of the Scottish Environmental Fundraisers Forum.

The Big Lottery Fund in Scotland, as a major funder, has a crucial responsibility to recognise the importance of, and to support, the natural and built environment  . We would also welcome a move to integrate natural environment issues as a cross-cutting theme across all grants, to help ensure sustainability (as, for example, with European Structural Funds)....

See also our additional response which answers questions that have not been asked in the consultation and emphasises key points made in the consultation.

30 January 2009, LINK Climate Taskforce

The Consenting Process for Thermal Power Stations in Scotland

We are concerned by proposals for new unabated coal capacity in Scotland, as coal is the most carbon intensive of all fossil fuels. LINK believes that, given the climate change targets to deliver an 80% reduction in greenhouse gas emissions, it is not justifiable to allow the building of any new fossil fuel power stations in Scotland which do not have full-scale Carbon Capture and Storage (CCS) installed and operating from the outset...

A response to the Scottish Government consultation on the guidance note on Section 36 of the Electricity Act 1989 under which Scottish Ministers determine consents for proposed thermal power stations, from the LINK climate taskforce

30 January 2009, LINK Planning Taskforce

Evidence on National Planning Framework 2

We welcome the statements for the vision of Scotland in 2030 that identify important aspects of landscape and wild land, and for greening the environment through “Green Networks” for wildlife and people. High quality natural environments not only benefit biodiversity but improve people’s quality of life and encourage inward investment, thereby increasing sustainable economic growth. Recognition of the value of landscapes for people, and the economic activity that they contribute, is therefore warmly welcomed.

However, whilst the NPF2 has identified these issues, it lacks clarity on the practical implementation which will move Scotland towards a more socially, environmentally and economically sustainable society. Importantly, there appears to be little co-ordination within the NPF2 to link sustainable development with economic growth.

30 January 2009, LINK Woodlands Taskforce

Climate Change and the National Forest Estate

Consultation on forestry provisions in the Scottish Climate Change Bill

In principle we welcome the fresh look at how the FCS can deliver for climate change but we are particularly uncomfortable, as we have highlighted before1, with woodland creation for carbon sequestration becoming the primary driver for the government and the National Forest Estate (NFE). LINK has repeatedly expressed its view that the best way to respond to climate change is to first reduce green house gas emissions by moving away from carbon based energy production, reducing energy consumption and energy loss. We see carbon sequestration as one of the secondary responses that feature further down the list of the multiple benefits forestry can provide...

16 January 2009, LINK Marine Taskforce

Legislative Consent Memorandum

Response to Consultation on Legislative Consent Memorandum. LINK Marine Taskforce are supportive of the principle of the Legislative Consent Motion as detailed in the Legislative Consent Memorandum in order to secure effective joint-working between the UK and Scottish Governments. However, we still have a number of concerns with the UK Bill/Legislative Consent Motion that are set out below and we also believe that there are several issues which may now not be covered by either the UK or Scottish Marine Bills.

15 January 2009, LINK Marine Taskforce

Marine Bill, SEA Environmental Report

The conclusion of the Environmental Report that it is likely that the overall effect of the Scottish Marine Bill on the environment will be positive appears to be based on the premise that the main purpose of the Scottish Marine Bill is to improve environmental protection and to develop a framework for the sustainable management of all marine activities. However, throughout Sustainable Seas for All: a consultation on Scotland’s first Marine Bill, there is reference to economic growth as the primary aim for the Bill...

2 January 2009, LINK Marine Taskforce

Marine Bill Regulatory Impact Assessment

We are disappointed that the focus of this document appears to be the growth of marine industries and balance of resource use and resource protection. We believe that the fundamental role that the ecosystem services delivered by marine biodiversity play in underpinning economic activity and social wellbeing should have a far higher recognition in this document.

11 December 2008, LINK Agriculture Taskforce

Less Favoured Areas Support Scheme in Scotland (2010-2013)

LINK believes that the current LFASS interim is not effective in securing additional public benefits from land management and is in need of urgent reform. The current scheme neither rewards land managers for the production of public goods nor truly recompenses for disadvantage.

In the longer term, LINK believes that a payment targeted to retaining HNV farming systems is justified. This could differ from traditional agri-environment payments in that a change in practice would often not be required in order to receive support but the continuation of land management that benefits the environment.

14 November 2008, LINK Agriculture Taskforce

A draft Honey Bee Health Strategy in Scotland

We believe that the proposed initiatives do not adequately take account of the broader issue of native pollinators, which may have far‐reaching consequences for the pollination of Scotland’s crops. Notable among a wide diversity of pollinating insect species are the bumblebees. There are also many species of solitary bee. The current draft strategy considers only the honey bee, and not the full complement of pollination services.

5 November 2008, LINK Marine Taskforce

Scottish Aquaculture – A Fresh Start

A response to the Scottish Government’s consultation on the Renewed Framework for Scottish Aquaculture.

6 October 2008, LINK Marine Taskforce

Scottish Marine Bill Consultation

Scottish Environment LINK’s Marine Task Force would like a Scottish Marine Bill with the environment at its heart, by which we mean it must result in protection and recovery of our marine environment in order to achieve a healthy, functioning marine ecosystem. The marine ecosystem is the foundation which underpins all human activities and therefore ensuring that this is a healthy, well-functioning ecosystem is essential for a sustainable economy. The bill should therefore be founded on the 5 principles of sustainable development: living within environmental limits; ensuring a strong, healthy and just society; achieving a sustainable economy; promoting good governance; and using science responsibly. In addition the Bill must fully transpose our international obligations under the Marine Strategy Framework Directive and meet international commitments under OSPAR and the World Summit on Sustainable Development.

30 September 2008,

Water Environment and Water Services; Development of Environmental Standards and Condition Limits

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.

15 September 2008, Joint LINK

Our Seas – A Shared Resource

The UK Links believe that shared HLMOs, which in turn will inform a UK-wide Marine Policy Statement (MPS), are essential to secure coherent marine management, and we urge all four Administrations to work together to take this forward. To this end, we urge the Scottish Government to participate in this joint process with the other UK Administrations

A jont response to DEFRA's consultation on High Level Marine Objectives by; The Wildlife and Countryside Link Marine Task Force, the Scottish Environment LINK Marine Task Force, the Wales Environment Link Marine Working Group and the Northern Ireland Marine Task Force.

15 June 2008, LINK Marine Taskforce

Draft UK marine Bill

Scottish Environment LINK’s Marine Task Force want to see protection for all of the UK’s Seas. We welcome the opportunity to respond to DEFRA’s consultation on the draft UK Marine Bill, but due to the mix of devolved and reserved matters both within and beyond 12nm we also recognise the vital importance of parallel marine legislation being developed in Scotland and Northern Ireland. We therefore strongly welcome the Scottish Government’s proposal to develop a Scottish Marine Bill. Scottish Environment LINK’s Marine Task Force is calling on all four administrations to ensure that these separate pieces of legislation are compatible, and that their implementation delivers comprehensive and coherent protection and management throughout UK seas.

5 June 2008, LINK Agriculture Taskforce

The Scottish Soil Framework

We believe that by widely promoting the importance of soils2, and delivering increased protection and management for Scotland’s soil resource, we will secure valuable socio-economic and environmental benefits in both rural and urban areas. We urge the Scottish Government to be ambitious in its efforts to secure these benefits from sustainably managed soils in the light of severe pressures from climate change in the coming decades.

LINK has 12 major comments on the framework which are set out in paragraphs 4 to 18 below. When then go on to briefly answer the questions posed in the consultation document...

16 May 2008, LINK Marine Taskforce

Shetland Draft Marine Spatial Plan

We welcome the draft marine spatial plan which has brought together a substantial body of information on the marine environment and is a significant step in developing a planning framework for Shetland. This plan could place Shetland in an excellent position in light of the forthcoming Scottish Marine Bill but there are a number of shortcomings that should be addressed in order to achieve the overall Aim.

The plan must be founded on the principles of sustainable development, where environmental limits set the boundary for economic activity and not vice versa. In particular, we feel that there is insufficient emphasis on the need to re-establish and secure a healthy, functioning marine ecosystem and on measures to protect nationally important species and habitats other than those mentioned under European legislation.

25 April 2008, LINK Climate Taskforce

Proposals for a Scottish Climate Change Bill

LINK believes that Scotland needs urgent action on climate change and have been calling for greenhouse gas reductions to be delivered in a sustainable manner and for adaptation measures to be put in place to help secure our natural and cultural heritage.

The Scottish Climate Change Bill should contain a duty on all public bodies to deliver climate change reductions in a sustainable manner in line with the national target.

Response to the Scottish Government Consultation on Proposals for a Scottish Climate Change Bill

25 April 2008, LINK Agriculture Taskforce

Choosing the Right Ingredients: The future of food in Scotland

We strongly support the idea of a joined up policy looking at all aspects of food production, processing, manufacturing and consumption although we would suggest that a “sustainable food policy” would be a more appropriate title. Our response will concentrate on the environmental aspects of such a food policy.

A response to the Scottish Government discussion paper "Choosing the Right Ingredients: The Future for Food in Scotland"

23 April 2008, LINK Freshwater Taskforce

The Future of Flood Risk Management in Scotland

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 not be restricted to people and economy, but will also benefit biodiversity and the wider environment.

This consultation response outlines the areas we believe any legislation should address.

9 April 2008, LINK Biodiversity Taskforce

Draft Guidance on How to Prevent the Spread of Ragwort

As a native species, Common Ragwort is part of our natural heritage and the UK Government has signed international agreements, such as the Convention on Biological Diversity, to ensure its conservation. It is found in a range of dry, sandy or limy or neutral grassy places and dunes but flourishes in overgrazed and disturbed areas. The guidance outlines the wildlife interests associated with the Common Ragwort and because of these wildlife interests, we are keen to ensure that any guidance issued by the Scottish Government is proportionate and has due regard to our native biodiversity, as enshrined in the Nature Conservation (Scotland) Act 2004.

2 April 2008, LINK Freshwater Taskforce

Significant Water Management Issues Report for Scotland River Basin District

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 the document this far. However, we do have a number of comments which we hope will improve the document still further. These relate to:

• What is ‘significant’ and the relationship between SWMIs and the first RBMP
• Issues relating to climate change
• Agricultural and forestry land drainage impacts on ecological status
• The effectiveness of some existing measures
• Further measures to deal with diffuse pollution from agriculture, morphological impacts and the use of new technologies
• Restoration of the water environment

2 April 2008, LINK

Scottish Government Action Plan on European Engagement (APOEE)

LINK believes that the draft APOEE has a very skewed emphasis on how Europe can increase Scotland’s economic growth (as measured by GDP) and fails to give sufficient priority to vital social and environmental issues.

7 March 2008, LINK Marine Taskforce

Marine Biodiversity Implementation Plan

Response to the Scottish Biodiversity Strategy Marine Biodiversity Implementation Plan 2008-2010.

We are keen to see a Scottish Marine Bill that delivers protection, restoration and enhancement of Scotland’s coasts and seas, including a halt to biodiversity loss by 2010 and an ecologically coherent network of marine protected areas by 2012, in turn helping meet impending requirements under the EU Marine Strategy Directive to deliver Good Environmental Status of our seas by 2020.

1 February 2008, LINK Deer Taskforce

Joint Agency Strategy for Wild Deer in Scotland

LINK Deer Taskforce consultation response to the Joint Agency Strategy for Wild Deer in Scotland 

15 January 2008, LINK Agriculture Taskforce

First Public Consultation on the CAP “Health Check”

The CAP distributes some £600 million per year in Scotland, through Pillar 1 (direct support) and Pillar 2 (rural development) payments. Its future is therefore important in determining what happens on the 75% of Scotland’s land area that is under agricultural management, and the unique countryside and wildlife associated with it. Scottish Environment LINK believes that the Commission’s proposals, although far from radical, may present some opportunities for distributing CAP funding in Scotland in ways that encourage increased delivery of environmental public goods, as a precursor to the more radical reforms anticipated for 2013. However, there are also environmental threats contained within the proposals, not least the proposal to abolish set-aside.

Response to the European Commissions 1st Public Consultation on the CAP “Health Check”

2 July 2007, Joint LINK

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 of the intercalibration exercise are published. Despite this, we have some concerns over the draft proposals for the phase 2 standards and conditions. Some of these concerns are general in nature, and some relate to specific standards, such as turbidity and temperature. Our major concern in relation to the UK TAG process is that scientific objectivity has been compromised by considerations of expediency, achievability, or the continuation of the status quo. We hope that our comments can be considered in drawing up the final standards.

A joint response from Wildlife and Countryside Link, Scottish Environment LINK, Northern Ireland Environment Link and Wales Environment Link

6 June 2007, LINK Climate Taskforce

Response to DEFRA Consultation on the Draft UK Climate Change Bill

The UK Government should develop its targets in full consultation with devolved administrations and ensure adequate representation on the Committee for Climate Change. Additional legislation at country level will be required by devolved administrations who may wish to set more ambitious targets, or make provision for specific mitigation measures.

Joint response from LINK and Stop Climate Choas Scotland

1 June 2007, LINK Marine Taskforce

A Sea Change.

Scottish Environment LINK response to the UK Marine Bill White Paper

22 March 2007,

Water Industry Commission's Approach to the 2010-14 Price review

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 of water resources, particularly in the presence of climate change, the Scottish Executive must recognise that: the water is not only an economic resource, but an environmental asset; water pricing must ensure sustainable use, not only efficient use; the cost of recovery must include the costs of damage to the environment .  Water pricing is a powerful tool to bring about more sustainable water use, and help to clean up our environment.

2 March 2007, LINK

Environmental Liability Directive Consultation

LINK members believe that by recommending that the Directive is transposed “without enhancement”, the Executive and Scottish Ministers will substantially fail to apply the principal aim of the Directive, namely to “make the polluter pay”. It will also fail to meet the aim of Scotland’s Sustainable Development Strategy which states that the “polluter pays principle will be embedded into policies

1 February 2007, LINK Agriculture Taskforce

Nitrogen Vulnerable Zones Action Programme

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. This will be required as part of the WFD and for simplicity, the two programmes should be combined. The links with cross compliance should also be strengthened and clarified. Certain elements such as a nutrient plan should be included as part of GAEC. The measures suggested will be difficult for farmers to adjust to. We therefore propose the following...

10 January 2007, LINK Marine Taskforce

Scotland's First Coastal and Marine National Park

Response to the SEERAD consultation on Scotland's first coastal and marine national park (CMNP).

LINK members would welcome a properly resourced CMNP with the appropriate tools, such as Marine Spatial Planning and Nationally Important Marine Area designations, to safeguard marine and coastal natural and cultural heritage features. The successful CMNP area would then be an excellent showcase of best practice, providing benefits for local communities and the environment.

20 December 2006, LINK Woodlands Taskforce

The Role of the Public Forest Estate in Scotland

Scottish Environment LINK’s view is that the primary role of Scotland’s national forest estate is the protection and enhancement the environment, through the provision of environmental and social public benefits. This is backed up by demonstrating exemplar best practice, and supporting local communities and economies.

12 December 2006, LINK Freshwater Taskforce

WEWS (Scotland) Act 2003 Consultation
Phase 1: Environmental Standards and Conditions

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 to achieve good ecological status in all water environments in Scotland and the UK. The WFD requires these standards to be purely based on technical consideration and not pre-judged on what may be socially and politically feasible or acceptable. All scientific definitions of high, good and moderate status should therefore be completed prior to the assessment of socio-economic considerations. We therefore find it difficult to understand why the UK administrations made a decision to undertake a regulatory impact assessment at this early stage in the development of WFD standards.

12 December 2006, LINK Freshwater Taskforce

Principles for the Objective Setting for the River Basin Management Plan

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.

6 October 2006, LINK Planning Taskforce

Scottish Planning Policy (SPP) 6: Renewable Energy

It is important that SPP6 links explicitly to complementary strategies, policies and targets for reducing demand and enhancing energy efficiency, since the current trend of increasing demand is otherwise likely to undermine progress to be achieved by renewables. We welcome the policy’s recognition of the potential range of renewable technologies and support the proposal to meet the 2020 target through a mix of these technologies. We are also pleased to see the policy’s recognition that renewables can provide more than just electricity, in particular its inclusion of heat at the small to medium scale.

However, the SPP does not answer a number of major concerns relevant to the task it sets local authorities...

5 October 2006, LINK Planning Taskforce

Draft Planning Advice Note: Community Engagement

We consider that environmental NGOs represent a key body of interest, collectively representing almost half a million concerned members of the public. Whilst working alongside communities at a local level we have directly experienced the challenges of the existing system. This is not simply a case of failure to secure our preferred outcomes but a genuine concern that on too many occasions the process of community involvement is undermined

1 October 2006, LINK Biodiversity Taskforce

Making a Difference for Scotland’s Species: a Framework for Action

Comments on the draft Species Framework. We broadly support the aims and objectives of the Framework and welcome the emphasis on conserving and managing species as “components of habitats and ecosystems.

29 September 2006, LINK Access Taskforce

Enjoying the Outdoors

This is the response of Scottish Environment LINK to the SNH consultation on Enjoying the Outdoors.

We would like to see Scotland drawing on experience in other countries – particularly in Scandinavia - to develop a closer relationship between the residents of Scotland and their landscape. Visits to the outdoors should be a regular part of people’s leisure time. Responsible access should be built into the school curriculum and other educational activities, with all schools participating in outdoor activities. This document should set the scene for this cultural shift to take place.

1 September 2006, LINK Access Taskforce

Cairngorms National Park Draft Outdoor Access Strategy

We support and endorse this strategy and hope that other access authorities will refer to it as a model of best practice that will inform and advise them in drawing up and reviewing their own access strategies. It covers access issues of importance to both residents of and visitors to the park in great detail.

13 July 2006, LINK

Scotland's National Transport Strategy

In its current form this strategy will do little to halt the growth in road traffic and the damaging environmental impacts made by carbon emissions, increased road building and air travel. We call on the Executive to produce a finished strategy that is a far-sighted and inspiring programme of measures to tackle oil dependency, reduce road traffic, protect the environment and improve the health of the nation and, in so doing, position Scotland at the forefront of eco-friendly transport in Europe.

Response to the Executives 'Scotland's National Transport Strategy: A Consultation'

29 June 2006, LINK Agriculture Taskforce

Rural Development Programme for Scotland 2007-2013 Consultation

The delivery of the SRDP represents a key function of the Scottish Executive and as such must comply with the Nature Conservation (Scotland) Act 2004 and further the conservation of biodiversity...

Response to the Scottish Government Consultation on the Rural Development Programme for Scotland 2007 - 2013

27 June 2006, LINK Woodlands Taskforce

Scottish Forestry Grants Scheme Review

Despite the Minister’s positive comments about the levels of funding available for forestry, we would like to register our concern over the apparent inadequate budget available to deliver the proposed Scottish Forestry Strategy and other associated Scottish Executive commitments such as targets within the Biodiversity Strategy...

1 June 2006, LINK Marine Taskforce

A Marine Bill

Marine Taskforce response to the DEFRA consultation

LINK supports the UK Marine Bill as providing a framework for marine management in UK waters, provided complimentary devolved legislation is forthcoming. LINK supports the UK commitment to a Marine Bill with sustainable development (in line with the Scottish Executive’s own Sustainable Development Strategy1), and Marine Spatial Planning at its heart, integrating conservation, energy and resource needs, which works within the natural limits of ecosystems (an ecosystem approach) and adopts the precautionary principle to protect the environment and its resources.

8 May 2006, LINK Woodlands Taskforce

Review of the Scottish Forestry Strategy – Second Consultation

We are supportive of the overall objectives and tenor of the draft Scottish Forestry Strategy. In particular the emphasis placed on the wide social and environmental roles that Scottish forestry can provide, including supporting biodiversity, improvements to peoples quality of life, economic development, and adaptation to climate change. But, we have a number of concerns...

20 April 2006, LINK Landscape Taskforce

Enhancing our Care of Scotland’s Landscapes

A response to the Scottish Executive consultation on national scenic areas; Enhancing our Care of Scotland’s Landscapes

Scotland’s precious landscapes face unprecedented threats. It is critical that this re-consideration of National Scenic Areas achieves its stated aims – as there will be no second chance.

18 April 2006, Joint LINK

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 made clearer. We believe that the Standards and Conditions should be revised and re-issued as part of a broader consultation on the entire WFD classification system.

Joint response from Wildlife and Countryside Link, Scottish Environment LINK, Northern Ireland Environment Link and Wales Environment Link

10 April 2006, LINK Sustainable Scotland Taskforce

Household Waste Prevention

We have long called for greater attention to be given to tackling waste arisings to complement the investment and progress that is being made in improving Scotland’s recycling record. Preventing waste at source will play an important part in meeting the aspirations of the Executive’s recently published Sustainable Development Strategy ‘Securing our Future’ to reduce Scotland’s footprint.

10 March 2006, LINK Freshwater Taskforce

Diffuse Water Pollution from Rural Land Use

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.

5 March 2006, LINK Planning Taskforce

Comments on Draft SPP6

We have been supportive of the renewable energy targets set by the Executive and recognise the tensions that have arisen across various sectors in trying to achieve these. In order to rationalise the policy approach to energy and climate change we have developed an energy hierarchy, which has already been incorporated into the SEA of the Scottish Climate Change Programme

9 November 2005, LINK

Environmental Assessment (Scotland) Bill Stage 3 Briefing

LINK warmly welcomes this legislation on Strategic Environmental Assessment (SEA). It is an essential tool to ensure that the environment is considered at the beginning of the decision making process.
 

1 October 2005, LINK Freshwater Taskforce

The Designation of Responsible Authorities

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. Such designation is a very important step in the delivery of good ecological status and in ensuring an integrated approach to water management in Scotland.

We believe that designating responsible authorities is a positive step forward, which will deliver a wide range of benefits. However, the consequences of such designation are far-reaching and will have significant impacts on day-to-day operations of the designated authority. It is therefore essential that responsible authorities be given advice from the Scottish Executive so as to what such designation means in practice and how to best implement it. Two such measures, as mentioned in the discussion paper, are guidance and staff training. Further clarification is required with regards to interactions between the existing planning systems and river basin management plans, especially in relation to the duties of local authorities.

1 October 2005, LINK Freshwater Taskforce

Strategic Review of Charges 2006 – 2010: The Draft Determination

LINK Freshwater Task Force (FTF) response to the consultation by the Water Industry Commissioner

21 September 2005, LINK Woodlands Taskforce

Review of the Scottish Forestry Strategy – First Consultation

There has been an increasing recognition that targets to increase woodland cover to 25% of Scotland are inappropriate. Scotland remains one of the least forested countries in Europe, and whilst we do not want to see planting on inappropriate sites (such as peatlands or important semi natural habitats), we would like to see native woodland expansion targeted in areas where there are the greatest concentrations of ancient or semi-natural woodlands. Public funds should be used to enhance Scotland’s historic landscapes and biodiversity...

7 September 2005, LINK Freshwater Taskforce

Strategic Review of Water Charges 2006 – 10: The Draft Determination

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 desirable must be met to achieve a degree of compliance with environmental regulation.
• This programme cannot be delivered without adequate funding, and strategic long-term planning.
• Efforts must be made in the forthcoming investment period to deal with the backlog of historic under investment in assets and infrastructure. The impact of not dealing with this backlog will result in great costs in future and a large increase in water charges in the next review period.

6 September 2005, LINK Planning Taskforce

Pitfalls in planning bill proposals

Following today’s legislative programme announcements by the First Minister, Scottish Environment LINK has responded by urging the Parliament to reconsider the decision in the Planning White Paper not to introduce a limited third party right of appeal into the planning system.

Together with the Association of Scottish Community Councils, LINK are organising a public petition that also insists that all planning decisions, especially those related to the proposed National Planning Framework, must be open to challenge and public inquiry.
 

31 August 2005, LINK Planning Taskforce

Response to Planning White Paper

We are concerned that there are a number of important omissions from the white paper, including that the White Paper does not provide a limited Third Party Right of Appeal nor a mechanism for the public to challenge the contents of the National Planning Framework (NPF), for example via a public inquiry or an examination in public.those identified above.
 

25 May 2005, LINK Agriculture Taskforce

Proposed new payment rates for agri-environment schemes by the Scottish Executive

We are extremely concerned about the potential impacts of significant decreases in payment rates for measures that have been shown to deliver much for biodiversity. In particular, measures for conservation headlands, hedgerow management, extensive cropping, unharvested crops, management of native woodland and aspects of the Organic Aid Scheme have all suffered severe downward changes in the payment rates proposed.
 

10 April 2005, LINK Freshwater Taskforce

Controlled Activities Regulations: Revised Proposals for General Binding Rules

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 impacts on the water environment.

31 March 2005, LINK Climate Taskforce

DEFRA consultation on the review of the UK Climate Change Programme

LINK members view climate change as the most serious problem facing the globe.  Urgent action is required to reduce the anthropogenic greenhouse gas emissions that cause climate change if we are to avoid the worst consequences.
 

31 March 2005, LINK Climate Taskforce

Scottish Executive consultation on the review of the Scottish Climate Change Programme

LINK members view climate change as the most serious problem facing the globe. Urgent action is required to reduce the anthropogenic greenhouse gas emissions that cause climate change if we are to avoid the worst consequences.

11 February 2005, LINK Woodlands Taskforce

Consultation on the National Forest Land Scheme

We support the transfer of forest land for sustainable management by communities and for affordable housing and believe it provides an excellent opportunity to contribute to creating a socially and environmentally sustainable forest economy and culture in Scotland.

However we feel strongly that FCS should ensure public benefits are maintained and enhanced through transfers and provide more support to communities in developing management plans, resources and skills to enable these multiple goals to be achieved.
 

6 December 2004, LINK Woodlands Taskforce

Response to Consultation on Draft Order: Amendment to Section 7 (10) of the Land Reform (Scotland) Act 2003

LINK supports the wording in the draft Land Reform (Scotland) Act 2003 (Modification) Order 2004.

We believe that the modification of the Act will contribute to the achievement of the aim of Part 1 of the Act to ‘create greater opportunity for people to enjoy the countryside’.
 

5 November 2004, LINK Agriculture Taskforce

Land Management Contracts

LINK Agriculture Taskforce has welcomed the proposal for Land Management Contracts (LMCs) and the introduction oflimited Tier 2 measures in 2005. We believe that the full Land Management Contracts, to be delivered in 2007 against the framework of CAP and the new Rural Development Regulation, must focus on the demonstrable delivery of public goods (environmental, social and economic). The Scottish Executive must take the lead in promoting this change. Such action will increasingly be demanded by taxpayers, who will not accept public money being spent on industry support for no apparent public gain.Submission to SEERAD consultation

30 October 2004, LINK Agriculture Taskforce

Draft Rural Development Regulation

Pillar II remains vastly under-funded, and cannot achieve its objectives unless funding is transferred rapidly and progressively from Pillar 1. A national strategy document for Scotland should identify priorities objectives, in line with current resourcing for Pillar II.

29 October 2004, LINK

Proposed Environmental Assessment (Scotland) Bill

This proposed legislation marks an important step towards putting the environment at the heart of government and is markedly better than the limited scope for SEA introduced by the Regulations and Directive. In seeking to broaden the application of SEA, we should avoid many of the long-term costs of having to rectify environmental damage arising from inappropriate policy decisions.

5 October 2004, LINK Biodiversity Taskforce

Scottish Biodiversity Strategy ‘It’s In Your Hands’

The LINK Biodiversity Taskforce welcomed the launch of the Scottish Biodiversity Strategy ‘It’s In Your Hands’ (SBS) and supports the concept of its focused delivery through detailed Implementation Plans. LINK members have been heavily involved in developing the Implementation Plans through the various working groups. While we believe the groups have succeeded in identifying what needs to be done, the plans still require a significant amount of further work to determine exactly how each issue is to be addressed.

30 September 2004, LINK Agriculture Taskforce

Land Management Contracts Menu Scheme

Agriculture policy has huge potential to shape the future of Scotland’s environment – either harmfully or beneficially. Scotland’s environmental losses to agriculture in the last 50 years have been catastrophic. They have largely been driven by the CAP. The future of most of Scotland’s remaining semi-natural farmland and woodland habitats, outside protected areas such as SSSIs, depends almost exclusively on changes to current agriculture policy.

1 September 2004, LINK Freshwater Taskforce

Pressures and Impacts on Scotland’s Water Environment

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 concerned by the exclusion of the NGO sector from the discussions about the ‘reference condition’, what is meant by ‘undisturbed’ conditions, and the meaning of ‘good ecological status’. The pressures and impacts report provides little explanation about how the reference condition was used to derive good ecological status, and how water bodies failed to meet good ecological status.

See also: Covering letter

24 August 2004, LINK

Charity law reform

Scottish Environment LINK members support the call by the Scottish Council for Voluntary Organisations for charity law reform.

31 July 2004, LINK Planning Taskforce

REsposne to Scottish Executive consultation on Rights of Appeal in Planning

An extended right of appeal must form a key component of the Executive’s wider programme of modernisation for the planning system.
 

31 July 2004, LINK Planning Taskforce

Response to Scottish Executive Consultation Making Development Plans Deliver

We are concerned that these proposals, taken together with other proposals for modernising the planning system, will act to the disadvantage of third parties unless a widened right of appeal is introduced. We remain to be convinced that proposals contained in the consultation will in them selves deliver a better planning system.

 

1 July 2004, LINK Sustainable Scotland Taskforce

Taking It On: Developing UK Sustainable Development Strategy Together

Response to the DEFRA consultation; Taking it on.

LINK believes that the UK and Scottish sustainable development strategies are central to preserving and enhancing our environment – and the biodiversity, countryside and cultural heritage that it sustains – and to reduce the adverse impact of UK consumption on other environments and societies around the globe. We therefore welcome the government’s plan to put in place a new UK strategic framework for sustainable development through to 2020, to provide both a consistent approach and focus across the UK and renewed action to deliver sustainable development goals. We particularly welcome the commitment to produce, in due course, a Sustainable Development Strategy for Scotland.

11 March 2004, LINK

Proposed Legislative Measures to Introduce Strategic Environmental Assessment (SEA) in Scotland

LINK believe that the commitment by the Scottish Executive in the Partnership Agreement to legislate to introduce SEA across the range of all new strategies, plans and programmes developed by the public sector in Scotland has the potential to bring environmental consequences to the heart of decision-making, thereby helping to secure a more sustainable environment for Scotland, but there are key elements which must be addressed in order to secure effective delivery and our long-term support.
 

1 March 2004, LINK Landscape Taskforce

Scotland's Future Landscapes?

A response to the Scottish Natural Heritage (SNH) consultation on Scotland's Future Landscapes.

LINK agrees with the integrative approach suggested within this paper, but emphasises that the European Landscape Convention must underpin all future policies and strategies in Scotland if landscape is not to remain very much undervalued as at present. An effective strategy for safeguarding and enhancing landscapes must be the outcome of not only this consultation but must also be reflected in the policy and strategies arising from the current reviews of agriculture, forestry and planning. Three landscape sectors need particular attention:-

• Stronger protection for those landscapes that might be recognised as being of global, European or National importance including National Parks, National Scenic Areas, and areas of wild land and cultural landscapes which are presently not designated.
• More effective management of the changing practices in agriculture and forestry to recognise the switch in emphasis from production to consumption and the opportunities afforded by new national planning provisions for biodiversity and water.
• Enhancement of 'green spaces' around and even within cities, towns and villages that afford opportunities for leisure and recreation and are vital to a sense of place and identity, historical continuity and community identity.

In addition, coastlines or seascapes need to be more closely recognised in line with the landscape principles set out in the paper.

28 February 2004, LINK Woodlands Taskforce

Review of Land Managed by Forestry Commission Scotland

Response to the Forestry Commission Scotland consultation on review of the land they manage.

5 February 2004, LINK Woodlands Taskforce

Refining the Scottish Forestry Grants Scheme

Woodland Taskforce response to the Forestry Commission consultation on refining the Scottish Forestry Grants Scheme (SFSG)

20 June 2001, LINK Access Taskforce

Land Reform - The Draft Bill
Access Legislation and the draft Scottish Outdoor Access Code

A number of the key technical issues and mechanisms in the Bill lead to an unbalanced approach and depart, significantly, from the consensus proposals worked out through long negotiation by the Access Forum, and substantially endorsed by Scottish Natural Heritage. The Bill, as it stands, with its proposals for ad hoc suspension of the right of access by landowners and for criminal sanctions, may substantially undermine even the established access currently enjoyed by visitors to the countryside. Furthermore, it could reduce future opportunities for enjoying the outdoors rather than enhancing these and extending them to a wider public.

28 May 2001, LINK

Freedom of Information Consultation

LINK members have three particular concerns about the draft legislation, which they believe run contrary to its aspirations, could represent a diminishment of the existing rights of access, and appear contrary to the founding principles of the Scottish Parliament.

21 September 1999, LINK Land Reform Taskforce

Land Reform – Proposals for Legislation

LINK members welcome the White Paper as a first step in the Land Reform process and look forward to further legislation in order to achieve the goal of land reform as set down in the consultation paper, Recommendations for Action - namely "to remove the land-based barriers to the sustainable development of rural communities".  THis response outlines the LINK concenus on a number of issues.