The Joint Links are concerned that the consultation document over-emphasises the potential of reporting more failures than are actually occurring. This ignores well documented evidence of a positive bias in classification, due to the approach taken to standard setting, compliance regimes, inaccuracy of risk assessments and the limited biological monitoring. We welcome the revision of standards on the basis of improved scientific understanding. However, this effectively ‘shifts the goalposts’ and brings changes in classification of status which may distort overall trends status and whether or not a specific water body classification is changing due to improvements/deterioration in underlying chemistry/biology, or as the result of new standards. The agencies must, therefore, clarify how baselines have shifted in order to produce a representative picture of water body health over time. Throughout the consultation there appears to be an assumption that standards should be set in a way that minimises risk of failure rather than maximises environmental protection; this means that the consultation lacks an appropriately precautionary approach.
http://www.scotlink.org/files/policy/ConsultationResponses/JLINKUTAGRespEnvStandRBM.pdf