The European Commission very much welcomes this document and hopes that soon after this consultation it will be published so that it can be referred to in the forthcoming new Euratom Basic Safety Standards. I would like to make the following observations:
1) DCRL's are a band of consideration Reference levels, but should be used as points of reference for the optimisation (Executive Summary (c), paragraph (36); this may cause confusion (should it be a point, chosen within a broad range reflecting our lack of knowledge?).
2) ERL's for a single source are the actual means for setting targets to specific industries; however, while the ERL should be at or near the lower boundary of the DCRL's, there should rarely be a need to set it much lower to allow for multiple past or present sources (paragraph (38)). Whenever an ERL is set much below the DCRL it will most probably be on a precautionary basis. Please note that in Fig. 3 the term "potential" seems to serve no purpose.
3) Where the ERL's should be a benchmark for planned exposure situations, the optimisation in existing exposure situations is not so clear. In general, the means for intervention for the protection of biota will be very limited (providing clean fodder, fencing, removal?) and contrary to wild-life preservation policies. Hence it may be disproportionate to claim that the "level of ambition should be to reduce exposures to within the band of DCRL's (paragraphs (42) and (A49), Executive Summary (f)) and that even within the band optimisation should continue to be applied. It should instead be emphasized that there is a priori no ground to reduce exposures down to below the DCRL's (since contrary to the protection policy for human health there is no room for the LNT hypothesis).
4) With regards to emergency exposure situations the levels of exposure to be considered in emergency planning should be one or two orders of magnitude above the DCRL's". This seems reasonable, but regulators would have benefit from a more firm statement by ICRP; could it be envisaged to recommend precise values (Emergency Environmental Reference levels) for different RAP's?
5) It is not clear whether the DCRL's include exposure to natural radiation sources, which for some RAP's and specific environments may be orders of magnitude higher than the exposure of human beings; some discussion is warranted. In paragraph (15) the term "additional" exposure is included; does it mean additional to natural radiation?
6) Chapter 2.3 puts a lot of emphasis on the use of natural resources; it could be emphasised even more strongly that environmental protection is a means to guarantee not only future use of these resources but also, in particular for long-lived radionuclides, the protection of future human generations. Indeed, pathways of exposure to man that can be dismissed today, may be important in future.
7) The same chapter puts emphasis on the objective of prevention rather than protection; this distinction is important not only in practice (e.g. discharge authorisations are a matter of prevention rather than protection) but it also affects the legal basis for addressing the issue. While there is a wealth of EU legislation on the protection of the environment, there is no intention to duplicate this with a policy for protection against ionizing radiation. An important example of EU legislation, which has not been included in the references, is the Marine Strategy Framework Directive (2008/56/EC) which makes explicit reference to radionuclides, but acknowledges the primary role of the Euratom Treaty in managing radioactive discharges.
8) I recommend to delete paragraph (53) and the sentence in (A87) relating to back-calculation from pre-defined environmental dose rates to look into authorised discharges; while this is a useful screening exercise, it should not be part of a system of protection; it could be misinterpreted as a "permission to pollute" up to the capacity of the environment to cope with such pollution.
9) On the other hand, it goes too far to allow for the consideration of people's objections against any presence of radionuclides in the environment, as is suggested in (A75). ICRP's advice should be based on science, for the protection of health and the environment, and, while recognising other societal factors, not give undue credit to such factors.
10) The document refers in several places to an ecosystem approach, but very little substantiates how this would affect the system of protection. Further references should be included, for instance to the recent IUR publication (F. Bréchignac).
11) Finally, while it is o.k. for each publication to refer to other publications and explain the overall approach, there seems to be room for making reference to the system for human exposure both less detailed (e.g. in chapter 2.2) and with less approximation where it matters, for instance, in (A35) it is suggested that in "actual" exposure situations the Representative Person should be "real", in fact the dose assessment is not for each individual person but for a model person with pre-defined habits (delete: "as in actual exposure situations").