We welcome the restatement of the Commission''s fundamental protection aim of reducing "the frequency of deleterious radiation effects to a level where they would have a negligible impact on the maintenance of biological diversity, the conservation of species, or the health and status of natural habitats, communities and ecosystems" and the focus on protection of communities, species, habitats and ecosystems.
We also welcome the clarity within the document that the proposed Dose Consideration Reference Levels (DCRL''s) are not intended to be applied as dose limits. We agree with the arguments advanced by the Commission as to why the use of dose limits would be inappropriate.
However, DCRLs are defined in the document as, "A band of dose rate within which there is likely to be some chance of deleterious effects of ionising radiation occurring to individuals of that type of reference animal or plant." This inevitably raises questions regarding the consistency of setting DCRL''s on the basis of individual effects to an objective of protection at population and ecosystem level.
While we appreciate the challenges involved in defining guidance levels for the protection of populations and ecosystems, we feel the document does not sufficiently clearly justify that this definition of DCRL''s or the numerical values proposed in the document are consistent with the Commissions stated objective. We feel it is important that the final document should clearly demonstrate it will proportionately deliver the intended objective.
Similarly we feel there are a number of key elements of the proposed approach set out in the document around the arguments that are not sufficiently well explored or justified in the current draft and which need to be covered more fully in the final document. This is particularly important given some of the significant differences between the approach proposed by the Commission and other equivalent environmental protection regimes.
The areas which we believe need to be more fully covered and explained in the final document include the:
- appropriate and equitable use of Environmental Reference Levels;
- relevance of the approach where potential exposures are highly localised;
- use of the approach with respect to exposures of short duration or variable nature, and
- proposed application of the approach to emergency situations.
Finally, at a number of areas in the document it is suggested proposals are only relevant to major nuclear or similar institutions. We believe the final document should be clearer that the application of the proposed framework, like other environmental regimes, should apply proportionately and consistently based on potential impact.
We hope that these comments will be of value in informing the Commissions work in this area.