Hans Vanmarcke on behalf of the Belgian Society for Radiation Protection (BVS-ABR) A working group of the Belgian Society for Radiation Protection (BVS-ABR) posted in 2004 and 2006 comments on the chapter about the protection of the environment in the ICRP draft recommendations. The current extensive draft report is written along the same lines. Although the report contains interesting information on the calculation of dose conversion factors and radiation effects in the 12 selected reference animals and plants, our basic question remains: why limiting the protection of the environment to plants and animals? ICRP promised for the radiological protection of the environment a harmonized approach with other non-radiological pollutants… but the proposed protection system, which is based on a few reference animals and plants, is similar to the existing ICRP-system for the protection of humans (reference man). The working group took the view that the countless number of living species cannot be reduced into a manageable number of reference animals. It is e.g. questionable whether a pine tree is a good reference for a tropical mangrove or a rat for an elephant. Environmental protection is much more than safeguard plants and animals. It also includes sustainability, pollution control, land use, abiotic compartments (atmosphere, deep sea, geological layers and even outer space). The BVS-ABR working group suggested replacing the reference animal and plant approach by an integrated environmental approach, mainly based on a set of ambient activity concentration levels.