Questions
1. Do you agree with our proposal in Section 4 of the consultation document to update the river fish statistical assessment method?
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2. Do you agree with our proposal in Section 5 of the consultation document to update the river phytobenthos assessment method?
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3. Do you agree with our proposal in Section 6 of the consultation document for a new loch fish (eDNA) assessment method?
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4. Do you agree with our proposal in Section 7 of the consultation document to update the loch morphology bank protection assessment method?
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5. Do you agree with our proposal in Section 8 of the consultation document to the introduction of spatial standards for fish barrier assessment?
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If you answered yes or no, please provide any further comments in the text box below:
We note that Section 8 of the consultation document considers spatial standards for river barriers. There will be instances, however, where the barrier in question only covers a short section of a river - such as a weir or dam - but where that barrier may cause an adverse impact on the river’s ecology, such as forming a barrier to migratory fish.
We therefore question whether using a spatial standard is the correct approach to assessing the impacts of barriers, when it may not necessarily be the length of the barrier which determines the effect of the impact.
As such, it may be more appropriate to use spatial standards as more of a balancing consideration in a matrix of factors when assessing the effect of a barrier.
We also consider that it may be appropriate to give heightened consideration in rivers which are Special Areas of Conservation in terms of the Habitats Regulations, and where the qualifying species may be at particular risk to barriers.
We therefore question whether using a spatial standard is the correct approach to assessing the impacts of barriers, when it may not necessarily be the length of the barrier which determines the effect of the impact.
As such, it may be more appropriate to use spatial standards as more of a balancing consideration in a matrix of factors when assessing the effect of a barrier.
We also consider that it may be appropriate to give heightened consideration in rivers which are Special Areas of Conservation in terms of the Habitats Regulations, and where the qualifying species may be at particular risk to barriers.
6. Do you agree with our proposal in Section 9.1 of the consultation document to update river flow standards to include artificially increased flows in high hydrological status waterbodies?
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7. Do you agree with our proposal in Section 9.2 of the consultation document to update river flow standards to allow for short term flow deviation?
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8. Do you agree with our proposal in Section 10 of the consultation document for a new nitrogen standard for lochs?
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9. Do you agree with our proposal in Section 11 of the consultation document to update the invasive non-native species list?
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About you
Are you responding as an individual or an organisation?
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The Law Society of Scotland