19/04/06
Water UK welcomes the opportunity to respond to UKTAG’s consultation on its proposed UK Environmental Standards and Conditions (Phase 1). We consider the development of appropriate environmental standards to be a critical aspect of the implementation of the Directive. The proposed standards have implications for water companies’ water resources (quantity) as well as the quality.
The water quality standards recommended in the report have been developed by a range of methods including statistical analysis of existing environmental data, expert advice and comparison with other countries. However it is clear that in many areas there is lack of adequate data and hence considerable uncertainty as to the suitability and implications of the proposed standards.
Although the Agencies may have high degree of confidence in some standards and therefore consider the use of the direct method and thus effectively ruling out the need for verification, it remains important to verify them against environmental data on an ongoing basis. The indirect approach is more obviously consistent with the WFD philosophy although it is also more complex and will need to be applied in a transparent fashion which demonstrates even handedness.
Water UK is also keen to see inclusion of standards for drinking water protected areas needed to meet objectives of the Directive in future revision of the Environmental Standards Reports.
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