Freshwater Taskforce

9 January 2013, , Consultation Responses

LINK Consultation Response on Proposals for Future Funding Arrangements for SEPA

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.

2 October 2012, , Consultation Responses

Water Resources (Scotland) Bill - Stage 1 Written Evidence from LINK

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.

11 September 2012, LINK Freshwater Taskforce, Consultation Responses

LINK response to the Water Services consultation

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.

7 August 2012, , Consultation Responses

Consultation on Proposals for an Intergrated Framework of Environmental Regulation August 2012

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.

9 July 2012, LINK Freshwater Taskforce, Consultation Responses

LINK Freshwater Taskforce response to Action Programme for Nitrate Vulnerable Zones (Scotland) Regulations 2008 – Proposed Amendments

Scottish Environment LINK seeks a reduction in diffuse nitrate pollution from agriculture because of the long-term impact that this nutrient poses to biodiversity, ecosystem services and climate change mitigation. While we recognise and welcome the effort that is being invested by some land managers to reduce the input of nutrients to land, we are not aware of any data to indicate that nitrate levels are showing consistent or significant signs of improving. Therefore, any relaxation of requirements associated with the Action Programme and with the overall implementation of the Nitrates Directive would be wholly inappropriate at this stage.

30 June 2012, LINK Freshwater Taskforce, Consultation Responses

Flood Risk Management (Scotland) Act 2009: The Designation of New Responsible Authorities

We agree with the proposal to designate Forestry Commission Scotland and the National Parks as responsible authorities under the Act and we urge that Scottish Natural Heritage and the British Waterways Board are also designated. In addition, LINK would like to know what processes are in place to check that all those who are currently responsible under the Act (including all emanations of Scottish Ministers, such as Marine Scotland, Transport Scotland and all Government directorates) are fulfilling their duties.

15 March 2012, LINK, Consultation Responses

Scotland the Hydro Nation: Prospectus and Proposals for Legislation - LINK response

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

1 August 2011, LINK Freshwater Taskforce, Consultation Responses

Flooding in Scotland: A Consultation on Potentially Vulnerable Areas and Local Plan Districts

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 invested in developing the National Flood Risk Assessment, however, we have concerns about some of the proposals and there are a number of points on which we seek clarification.
 

8 March 2011, LINK Freshwater Taskforce, Consultation Responses

Building a Hydro Nation - Consultation Response

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 statutory obligations in respect of biodiversity, climate change and sustainable development and, therefore, all of its operations and functions should reflect this. LINK would like to see a water industry that invests in sustainable solutions to improve water quality, reduces leakage, and focuses further on climate change mitigation and adaptation measures. Scottish Ministers have a strong role in securing a sustainable water industry and we hope that this will be demonstrated in the Statement of Ministerial Objectives for the next investment period.

14 February 2011, LINK Freshwater Taskforce, Consultation Responses

SEPA's Better Environmental Regulation - consultation response

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 resource on tackling environmental deterioration arising from activities that are considered to be low risk but that, cumulatively, have a detrimental environmental impact.  We are concerned about proposals to reduce inspections and monitoring.  The impact and success of any changes to the regulatory regime must be properly measured against environmental outcomes. It is crucial that any changes do not negatively affect biodiversity or the wider environment.

15 October 2010, LINK Freshwater Taskforce, Consultation Responses

Planning for Floods – Planning for the Future

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 SEPA’s proposals, particularly those in relation to the set up of local plan areas, will fall short of achieving sustainable flood management that is integrated with wider catchment issues, such as those relating to water quality, land use, biodiversity and climate change adaptation. In addition, we are concerned that the proposals will impede stakeholder engagement which could in turn result in poor implementation of the Flood Risk Management (Scotland) Act 2009.

We urge that SEPA gives further consideration to the alternatives that would reduce the number of local plan areas and that would better align the areas with existing structures, such as the River Basin Management Planning Area Advisory Groups. This will be essential to achieve not only sustainable flood management but other objectives that will deliver multiple benefits at a catchment scale.

9 March 2010, LINK Marine Taskforce, Parliamentary Briefings

Aquaculture Briefing

The LINK marine taskforce believes all aquaculture legislation should ensure development within the industry is founded on the five guiding principles of sustainable development (in line with the Scottish Government’s own Sustainable Development Strategy): living within environmental limits; ensuring a strong, healthy and just society; achieving a sustainable economy; promoting good governance; and using science responsibly.

A briefing prepared by the LINK Marine taskforce for the Scottish Parliament debate on Aquaculture on the 10 March 2010

26 May 2009, LINK Freshwater Taskforce, Consultation Responses

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.

13 May 2009, LINK Freshwater Taskforce, Press Releases

Welcome for New Flooding Bill

Sustainable flood management, good for people and biodiversity! LINK welcomes the passing of the new Bill on flooding. This is a major opportunity to have more sustainable approaches for the management of flood risk.

12 May 2009, LINK Freshwater Taskforce, Parliamentary Briefings

Notes on the Marshalled List of Amendments for the Flooding Bill

LINK notes on the Marshalled List of Amemdments selected for stage three of the Flood Risk Management (Scotland) Bill. This document offers a more detailed briefing on the amendments, as tabled.

11 May 2009, LINK Freshwater Taskforce, Parliamentary Briefings

Briefing on Stage 3 of the Flooding Bill

The Flood Risk Management (Scotland) Bill already represents a significant improvement to flood management in Scotland. This LINK freshwater briefing looks at proposed amendments that would improve the Flood Risk Management Bill legislation still further at stage three.

The key amendments for stage 3 include strengthening provisions for the consideration of natural flood management, ensuring that Ministers provide adequate funds to responsible authorities and SEPA to implement the new Act, and addressing the issue of sustainability of the Water Industry Commission and Scottish Water.

1 April 2009, LINK Freshwater Taskforce, Consultation Responses

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.

22 January 2009, LINK Freshwater Taskforce, Parliamentary Briefings

Briefing on Stage One of the Flooding Bill

LINK Freshwater Taskforce Briefing for Stage One of the Flood Risk Management (Scotland) Bill. The new Bill must ensure a sustainable approach to flood management, incorporating sustainable principles in the general provisions and indeed throughout the Bill. The provisions for natural flood management should be strengthened and a new duty introduced to ensure the implementation of flood risk management plans. Amendments to the Bill on these issues will bolster the Bill’s purpose of securing flood management that is long-term, sustainable and fit to deal with climate change impacts.

26 November 2008, ,

Oral Evidence on Stage One of the Flooding Bill

Mike Donaghy provides oral evidence to the Scottish Parlaiment's Rural Affairs and Environment Committee in Stage One of the Flood Risk Management (Scotland) Bill proceedings, on behalf of the LINK Freshwater taskforce.

11 November 2008, LINK Freshwater Taskforce, Parliamentary Briefings

Written Evidence to Stage One of the Flooding Bill

Stage one written evidence on the general principles of the Flood Risk Management (Scotland) Bill to the Scottish Parlaiment's Rural Affiars and Environment Committee

11 November 2008, LINK Freshwater Taskforce, Parliamentary Briefings

Flooding Bill Financial Memorandum

Financial Memorandum. Written submission by the Freshwater Taskforce of Scottish Environment LINK on the financial implications and the costs and benefits of the Flood Risk Management (Scotland) Bill.

30 September 2008, , Consultation Responses

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.

30 August 2008, LINK Freshwater Taskforce, Position Papers

A Vital Step for Scotland: Flood Risk Management (Scotland) Bill

New legislation represents a new opportunity to introduce sustainable management of flood risk. However, it will only be achieved if three key principles are placed at the heart of the new legislation. This leaflet produced by LINKs Freshwater Taskforce outlines the required principles.

28 August 2008, LINK Freshwater Taskforce, Position Papers

Natural Flood Management

Natural Flood Management (NFM) is part of a Sustainable Flood Management approach. It is a series of techniques that involves working with rivers and coasts using natural processes within the framework of land use planning.

This literature review looks at what can be learned from past studies and experiences in other countries. Also, it helps fill in the knowledge gap in NFM.

26 June 2008, LINK Freshwater Taskforce, Parliamentary Briefings

Flooding and Flood Management – the way forward for Scotland

A briefing by the Freshwater Taskforce of Scottish Environment LINK for the Rural Affairs and Environment debate on flooding and flood management

Scottish Environment LINK’s Freshwater Taskforce welcomes the recommendations of the Rural Affairs and Environment Committee’s Inquiry into Flooding and Flood Management. Flooding is a big issue and likely to get worse due to climate change. Scotland is set to get wetter and stormier, and some coastal areas are likely to experience sea level rise, increasing the risk of both the coastal and inland flooding. The traditional approach for managing flood risk is proving inadequate in the face of changing climate. The forthcoming flooding legislation is promising to modernise the way we deal flooding, and introduce an integrated, sustainable way of managing the risk. The new flooding policy should aim to:

• Introduce integrated, catchment based flood risk management
• Ensure that natural flood management is part of response to flood risk management
• Introduce a new way of funding flood measures that supports long-term management
• Ensure accountability and delivery of flood measures on the ground

23 April 2008, LINK Freshwater Taskforce, Consultation Responses

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.

2 April 2008, LINK Freshwater Taskforce, Consultation Responses

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

1 March 2008, LINK Freshwater Taskforce, Parliamentary Briefings

Flooding and Flood Management Inquiry, further evidence

Further evidence to the Rural Affairs and Environment Committee for their Flooding and Flood Management Inquiry. Additional information with regards to natural flood management techniques and the role of natural habitats in storing and slowing down the flow of water and further evidence of the current practices of building on floodplains.

See also our inital inquiry response and oral evidence

12 December 2007, LINK Freshwater Taskforce, Parliamentary Briefings

Flooding and Flood Management Inquiry

The Freshwater Taskforce warmly welcomes the remit of this inquiry and we hope that the evidence we provide will be helpful in informing the future flooding policies. This written evidence focuses on key issues in relation to the new Flooding Bill and sustainable flood management; and the role of natural flood management in that process.

This document highlights our 5 asks in relation to the new Flooding Bill:

• Review, streamline and where necessary amend the existing legislation on flooding
• Clarify and where necessary strengthen the responsibilities for flood management and ensure better co-ordination between ‘responsible’ authorities
• Transpose the requirements of the EU Directive on the Management of Flood Risk
• Ensure close links with river basin management planning under the WFD including public participation, with regional and national advisory flood groups
• Put in place a more flexible, integrated funding for hard and soft-engineering measures linked with the delivery of catchment flood management plans.

See also Letter to the Committee and Annexes

3 August 2007, Joint LINK, Position Papers

Review of UKTAG proposed standard for suspended solids

an APEM Scientific Report for WWF-UK and Wildlife & Countryside Link partners reviewing the UKTAG proposed standard for suspended solids

2 August 2007, LINK Freshwater Taskforce, Parliamentary Briefings

Towards sustainable flood management in Scotland

A briefing prepared by the Freshwater Taskforce of the Scottish Environment LINK on the implementation of Sustainable Flood Management (SFM) through primary legislation.

Climate change predictions suggest that Scotland is set to get wetter and stormier, increasing the risk of flooding. Therefore floods that are currently considered ‘extreme’ will become more common in future. The current flooding policies have seen millions of pounds invested into concrete flood prevention schemes, which only provide short-term solutions and often increase the risk of flooding elsewhere. An intention to introduce a new Flooding Bill was announced by the First Minister on 5 September. We see this as a major opportunity to implement a modern, sustainable approach to flood management. Sustainable Flood Management (SFM) is not a new concept in Scotland – it was embedded in the WEWS Act through a duty on Scottish Executive, SEPA and ‘responsible’ authorities to ‘promote SFM’. However, 4 years on and nothing has actually happened on the ground. Much work needs to be done to prepare for the Flooding Bill, which is discussed here in further detail.

2 July 2007, Joint LINK, Consultation Responses

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

22 March 2007, , Consultation Responses

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.

3 February 2007, LINK Freshwater Taskforce, Parliamentary Briefings

Briefing on Sustainable Flood Management

Flooding is a natural phenomenon, but one that is also exacerbated by human mismanagement of the environment. One of the results is that more and more people, particularly the vulnerable, are living in fear of flooding. The problem of flooding has been made worse by the way we construct and defend ourselves against floods, and the way we manage catchments.

1 February 2007, LINK Agriculture Taskforce, Consultation Responses

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...

12 December 2006, LINK Freshwater Taskforce, Consultation Responses

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, Consultation Responses

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.

1 June 2006, LINK Freshwater Taskforce, Parliamentary Briefings

Living within Environmental Limits

In order to keep our water environment healthy, we need reliable and sustainable water services. However, in some parts of our country, the amount of water being abstracted and lost through leakage is unsustainable, and damaging to wildlife and the environment. Some areas of Scotland still suffer from pollution caused by inadequate treatment of sewage and by sewer flooding. Scottish Environment Protection Agency (SEPA) estimates that 2062km of rivers, coastal waters and estuaries are at risk from sewage pollution and other Scottish Water (SW) related activities.

1 May 2006, LINK Freshwater Taskforce, Parliamentary Briefings

Implementation of the WEWS (2003) Act, Annual Report 2005

Evidence to the Environment and Rural Development Committee on progress of implementation of the Water Environment and Water Services Act (WEWS Act) in Scotland, the Act that transposed the European Water Framework Directive (WFD), the most important piece of European environmental legislation aiming to protect and enhance the water environment.

18 April 2006, Joint LINK, Consultation Responses

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 March 2006, LINK Freshwater Taskforce, Consultation Responses

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.

1 February 2006, LINK Freshwater Taskforce, Press Releases

Scottish Water Conflict Bad News for the Environment

The delivery of a large investment programme requires good co-ordination and communication between the government agencies, economic regulators and Scottish Water. The resignation of Scottish Water's chair signals an ongoing conflict between these agencies, which could prove damaging for the environment, biodiversity and the Scottish people.

1 October 2005, LINK Freshwater Taskforce, Consultation Responses

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, Consultation Responses

Strategic Review of Charges 2006 – 2010: The Draft Determination

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

7 September 2005, LINK Freshwater Taskforce, Consultation Responses

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.

19 July 2005, LINK Freshwater Taskforce, Position Papers

Abstraction and Impoundment Charging Scheme

The Regulatory Stakeholder Forum gives an opportunity for all interested parties to provide input into the development of the charging scheme. We would like to emphasise that similar approach should be taken to all areas of work on WFD implementation. The Freshwater Taskforce supports the principles of charging as outlined in the consultation document, and our main comments are written below...

10 May 2005, LINK Freshwater Taskforce, Position Papers

Controlled Activities Regulations Proposals for Regulation

These regulations provide an effective and proportionate framework for regulation of activities that pose risk to the water environment, and which will ensure the well-being of our rivers, lochs, coasts and wetlands for generations to come. These will complete an important part of the implementation of the secondary legislation, following the acclaimed primary legislation delivered by the Scottish Parliament, of the Water Framework Directive. The approval of these regulations will safeguard water as an important asset for Scotland's economy, wildlife, tourism and people.

7 May 2005, LINK Freshwater Taskforce, Position Papers

Water Framework Directive and Flooding – Implications for Flooding Policies in Scotland

The Water Framework Directive (WFD) came into force in December 2000. It is widely recognised as one of the most far-reaching pieces of environmental legislation ever to emerge from Europe.

The WFD has substantial legal and administrative implications for the future of flood risk management in the UK. In Scotland, these implications were recognised and the Water Environment and Water Services (Scotland) Act 2003 introduced a new duty on Scottish ministers, SEPA and ‘responsible’ authorities to promote sustainable flood management.

10 April 2005, LINK Freshwater Taskforce, Consultation Responses

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.

1 September 2004, LINK Freshwater Taskforce, Consultation Responses

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

1 March 2003, LINK, Position Papers

For Better or Worse? Environment Policy in the First Four Years of Scotland’s Parliament.

The establishment of the new Scottish Parliament in 1999 brought not only new political institutions to Scotland, but also new aspirations and expectations of what might be achieved through the devolution settlement. Certainly the principle of devolution, and the specific powers vested in the Parliament, meant that it could address issues of importance to Scotland quicker than was previously the case, and with policies tailored specifically to Scottish needs and priorities.

This report, with input from many of the key players such as the Minister and Deputy Minister for Environment and Rural Development, examines the way in which the Scottish Parliament and Executive have risen to the particular challenges posed by the issues of Environment and Sustainability, whether through legislation, policies, strategies, initiatives, action plans, reports or debates.