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.