Scotland the Hydro Nation - Prospectus and Proposals for ... - RSPB

Scotland the Hydro Nation - Prospectus and Proposals for ... - RSPB

RSPB Scotland response March 2012

companies across the UK, for example the Sustainable Catchment Management Programme

(SCaMP) 15 which is successfully underway in the north of England. We remind Government

that one of the objectives of the Land Use Strategy is delivery of multiple benefits, something

which water industry could make a substantial contribution to achieving.

We believe that Scottish Water should do more to facilitate sustainable land use and catchment

management. This could include positive management of our upland and peatland areas, from

where approximately 70% of drinking water supply arises. The IUCN UK Commission of

Inquiry on Peatlands demonstrates the benefits of peatland restoration for water quality 16 . The

amount of Dissolved Organic Carbon (DOC), which gives ‘peaty water’ its brown colour, is

increasing. The process to remove DOC from water can result in a chemical reaction that

produces trihalomethane compounds which are harmful to human health. In addition, the

removal of DOC can be costly for water companies either through operating expenditure or

new investment into treatment processes. Peatland restoration, including measures such as

grip blocking, can reduce the levels of DOC in water courses and thus can be cost-effective for

water industry.

We believe that stronger duties are needed on Scottish Water and others to ensure that a

sustainable catchment management approach is pursued. To do this, RSPB Scotland would like

to see:

A duty on Scottish Water to deliver and facilitate sustainable catchment management.

An appropriate body (or bodies) assigned the responsibility of overseeing Scottish

Water’s delivery of sustainable land management. This might involve a role for WICS

and SEPA on aspects of economic benefits and compliance with WFD and other

environmental benefits, respectively.

We recognise that Scottish Water cannot deliver a sustainable catchment management

approach on its own. For example, SEPA and SGRPID have existing responsibilities in

enforcing regulations (e.g. CAR, cross compliance) that aim to protect water quality.

Therefore, this duty should extend to all relevant bodies and agencies who can

contribute to a catchment management approach, including Scottish Ministers, SNH,

Forestry Commission Scotland and the National Parks.

We would support the proposal to give powers for Scottish Water to access land to take water

samples for the purposes of identifying the source of the problem.

3.3 Prescribed Substances

We are supportive of the proposals to give Scottish Water greater powers to undertake work in

drainage catchments and to identify pollution sources. However, it is proposed that such an


16 Bain, C.G. et al. (2011) IUCN UK Commission of Inquiry on Peatlands, IUCN UK Peatland Programme,



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