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CHAPTER 4: VIEWS ON THE WATER FRAMEWORK DIRECTIVE
4.1 This chapter discusses views on the Water Framework Directive. While stakeholders already had considerable knowledge of the WFD, the general public were likely not to have heard of it. Thus they were read a short description before being asked their views.
Stakeholder views
4.2 Stakeholders were very positive about the extent to which the Scottish Executive and SEPA had communicated and consulted with them about the WFD and plans for implementation. The following views were typical:
…anybody that wanted to had an opportunity to comment on the process.
(Stakeholder 9)
We have been pretty closely involved. I think we have been kept pretty well informed.
(Stakeholder 7)
4.3 In terms of the implementation plans themselves, however, views were slightly more mixed. Most stakeholders were generally positive about the WFD. Specifically, they welcomed the holistic management of whole river basins and the fact broader environmental criteria than simply water quality would be taken into account. One stakeholder felt that problems would now be tackled before they reached 'crisis' point.
4.4 However, a small number of stakeholders raised concerns about whether the implementation would be proportionate to the problem. Their view was that, since most of Scotland's water environment is very good, the planned WFD implementation is unnecessary and will be too bureaucratic and costly. The following quote sums up that perspective:
There hasn't been an increase in problems of water or environment in Scotland that would justify the increasing of that size in an organisation looking after the environment. It's really very frightening. And all the time it's generating more and more regulation which is stifling in an industry, stifling innovation…And the UK does has a tendency to take legislation and make sure it complies with every last letter of it, whether or not it's appropriate.
(Stakeholder 5)
4.5 Even a couple of stakeholders who were generally in favour of the WFD used phrases such as ' gilding the lily' and ' using a sledgehammer to crack a nut'.
Public views
4.6 After having discussed perceptions of the water environment, uses, concerns and threats, focus group moderators gave participants the following brief description of the WFD and asked their reaction:
"The Water Framework Directive is a piece of European legislation designed to improve the quality of all the water environments across the European Union. There has been legislation to protect the water environment before - for example, laws about pollution, but the WFD is broader than that and aims to cover broader ecological issues - like the shape of water bodies, rate of flow and the impact on wildlife - and also take into account economic and social considerations. Some exceptions will be allowed but the aim is that all of the water environment will reach what's called "good ecological status" by 2015. Scotland has implemented this European legislation in the 2003 the Water Environment and Water Services Act."
4.7 The WFD was generally seen as being good in principle. Firstly, because the state of the water environment is important and, secondly, because it should help improve/maintain standards.
If it's improving [the water environment], then it has to be good.
(Glasgow, over 40, ABC1)
If the standard was set, then if there was a deterioration it would have to change to come back to that level. So it would act as a policeman.
(Scotlandwell, over 40, C2DE)
4.8 However, a number of caveats and concerns were evident. The apparent vagueness of some concepts used in the WFD was noted:
I'd like to see what the definition is of "good ecological status".
(Glasgow, over 40, ABC1)
…it's jargon words.
(Scotlandwell, over 40, C2DE)
4.9 Some also felt that, although good in theory, effective implementation was what mattered.
The legislation would have to have some teeth to be able to do something.
(Scotlandwell, over 40, C2DE )
It's just if it works. If it works.
(Aviemore, under 40, C2DE)
4.10 Concerns about the cost of implementation were also raised.
4.11 However, most comments related to the fact that it was a European Directive. The main concerns were about the level of local control and the following comments were typical:
… as long as the overall control, decision-making and all that about water in Scotland is made in Scotland and not in Brussels or wherever.
(Glasgow, under 40, C2DE)
There are so many countries now in the European Union, how on earth can they say one thing over the board, when there are all these local things that should be taken into account?
(Aviemore, over 40, ABC1)
What's the European Union got to do with Scottish Water?
(Scotlandwell, over 40, C2DE)
4.12 The importance of 'local knowledge' was also raised in relation to decision-making within Scotland - particularly by the Aviemore group who were concerned, not just about decisions being made in Brussels, but decisions being made in Edinburgh.
4.13 There was also scepticism about whether other countries would meet the same standards as Scotland and the rest of the UK.
How are they going to ensure that the countries follow this Directive?
(Aviemore, over 40, ABC1)
It's like you say, managing it and enforcing it…the countries that don't go by it, what happens to them?
(Scotlandwell, over 40, C2DE)
4.14 We sensed that these issues of local control and differing implementation in other countries would have been raised about any European Directive - regardless of the topic.
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