National Stakeholder Forum

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Day 1

Session 1 - Characterisation

Key issues from stakeholders:

need definition of 'good status'
need better understanding of European inter-calibration exercise
risk assessment process needs to be simplified
once water bodies at risk have been identified, need to set priorities for action
need to take account of future developments and changes in population and type of industry
costs of remediation may be high in socio-economic terms - need to maintain balance
need to introduce robust process for making derogations and for resolving conflict

Session 2 - River Basin Planning

Key issues from stakeholders:

perceived need for Advisory Groups at a local level but queried funding arrangements
possible evolution of National Stakeholder Forum into national Advisory Group for basin planning
possibility for stakeholders opting in/out as required at local level, with targeting of particular groups/organisations for specific aspects of the process

Session 3 - Economics

Key issues from stakeholders:

opportunity to be forward thinking and move away from small sectoral approach towards wider society issues
need to take environmental and resource costs into account
important to use the same interpretation of "Cost of Water Services" and "Adequate Contribution" Europe-wide
difficulty of putting a price on environmental costs - need to have the best available information in order to make an informed choice
need a robust process to ensure balance is struck between social, financial and environmental costs
needs to be a level playing field within Scotland - taxes, levies and rateable values vary for different types of water user

Session 4 - Charging scheme

Key issues from stakeholders:

need to consider whether it is appropriate to apply a cap on SEPA's maximum charge
need to be transparent so that information base can be challenged
concerns about differing pressure on domestic charges compared with non-domestic charges
concern about the impact on Scottish Water's costs/pricing policy
need open audited process and reporting mechanism
concern over potential additional cost burden on water users - to minimise these concerns, need to provide indicative costs as soon as possible
support for the wider environmental objectives, but should widen charging issue to consider development of an integrated approach to achieve environmental objectives, eg other incentives such as tax rebates
concerns about introduction of new charging scheme in 18 months - tight timetable
primary industries will be affected most - need to pass on these costs, and this must be taken into consideration

Day Two

Session 1 - Regulations

Key issues from stakeholders:

appeals - the issue is not who makes the decision on the appeal, but that there is timely action on reaching a decision
concern that Regulations do not specify grounds for appeal - explanatory memorandum is needed
need clarity on timetables and review process
PPC authorisations may have to be reviewed as part of WFD
members would like a detailed memorandum to accompany Regulations to ensure clarity of purpose/timing and to provide an idea of reasonableness/certainty; but need to bear in mind that Regulations do not stand alone and must be read in context with the WEWS Act

Session 2 - Abstraction/Impoundment

Key issues from stakeholders:

need to integrate with other processes such as PPC
management agreements - should be scope to work together, certainly for smaller users; but this issue needs to be covered in more depth in appeals process
concern whether national abstraction thresholds are appropriate for agriculture - needs to be flexibility to address local issues
thresholds - sound principles, but needs to be dialogue with stakeholders as GBRs being developed to ensure these are comprehensible and flexible
costs should be spread across all applicants
should introduce incentives for efficient water use, such as encouraging storage of run-off rainwater

Session 3 - Engineering Works

Key issues from stakeholders:

keep definition simple and flexible, although some believed it should include reference to ecology and morphology
need to make distinction between maintenance and new works
maintenance of existing structures could be done by GBRs
issue of scale (eg farmer clearing ditches) - could start with voluntary approach before moving to Regulations
GBRs - there need to be guidance notes that are proportionate to the activity
SEPA should provide advice not just be regulatory body
need to differentiate between one-off activities and repeated activities by same company
concept of accredited operators who would be subject to audit
GBRs need to be site specific, so developing GBRs which could apply nationally could be difficult
transition issue - if on-going works expected to progress beyond Nov 05 then licence should be required; but unreasonable to challenge ongoing work at transition point
SEPA should be consulted though through planning process and could set conditions in advance of 1 November.

Session 4 - Point source

Key issues from stakeholders:

marine aquaculture industry would wish to get involved in development of GBRs
would GBRs be applied to both salt and freshwater aquaculture
need to achieve objectives, legislation is less flexible than codes of good practice.
operators would prefer single licence (even if some activities were under GBR)
would GBRs include provisions to enable conditions to be attached to consents to guarantee good management practices, e.g. 1) single year class management; 2) synchronous treatment; and 3) integrated pest management etc?
would there be a capacity to underpin existing Codes of Practice with regulatory teeth?

NSF - Next Steps

The presentations and summary of discussions would be posted onto the Executive's WFD Team website
Executive expressed a genuine wish to be open and participative and stakeholders expressed a desire to participate
Key tension is achieving balance between certainty and flexibility

The NSF will continue, perhaps twice yearly, further consideration will be given to appropriate membership