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3.9. Summary
With the exception of mercury, pBDEs and some of the PAHs, Member States are making significant progress in tackling concentrations of individual priority substances in surface water bodies (EEA, 2018a). This should be seen as a success for European water and chemicals policies stretching back several decades.
Looking deeper, we can see some gaps in the data. Most priority substances have been regulated for many years, with monitoring, analysis and discharge permitting being well-established. It is therefore perhaps surprising that for many of the most frequently-reported priority substances, there is a core set of 8-12 Member States reporting failures of those substances. It is unclear whether this accurately reflects pollution across the EU - that in other countries the priority substances are not a problem - or instead reflects the approach to monitoring and reporting. For instance, at least one country did not report any priority substances as causing failures to achieve good chemical status.
Similarly, at EU level, comparable information on emissions is limited to only a few substances. Table 3.2 gives an overview of the number of Member States reporting for the year 2010 for the different source groups: industry, UWWTPs and diffuse sources. When different datasets are reported (E-PRTR, WISE, WFD), the dataset with the highest number of Member States reporting is shown, i.e. “the best case”, summarising the information available on emissions of 15 priority substances. In the table, where emissions data are available for at least 14 countries, the cell is coloured green indicating sufficient data availability. Between 7-14 countries, the cell is yellow, indicating moderate data availability. If data are available for fewer than 7 countries, the cell is red.
Table 3.2 : Data availability for emissions of the 15 priority substances most frequently causing failure to achieve good chemical status
It can be seen that there is rather limited emissions information available at European level, even for well-established pollutants like priority substances from point sources. Information on emissions from diffuse sources is poor: as point sources become better controlled, the significance of diffuse sources is getting higher.
These data gaps make it difficult to track progress in reducing emissions at the European level, as required by the WFD, and to assess the effectiveness of chemical source control legislation in protecting the environment.
One of the challenges with chemical status is that once a persistent substance is in the aquatic environment, it may be there for a long time after emissions have ceased. This may lead to continued failure to meet good chemical status, and a potential mis-match with the pressures. In the case of transboundary pollution, there is also a poor fit with the river basin approach promoted by the WFD, which works on the basis that management processes will influence local/regional water quality. In the case of persistent, hazardous chemicals, particularly those which can be transported in the atmosphere, international chemicals legislation is also needed to underpin environmental protection. Evidence on the trend in emissions may be used to better inform the pressures assessment.
Looking forward to the next RBMP reporting, there are some new priority substances and some existing priority substances have revised EQS to reflect updated scientific knowledge. It is likely that these changes will make the achievement of good chemical status in surface waters more challenging.
Specific actions proposed to improve protection of waters.
Further effort to reduce emissions of mercury from urban waste water treatment plants, either upstream or before discharge, seems necessary.
Improved understanding of pressures from emissions reporting needed to be able to implement effective measures to reduce pollution of water by PAHs.
Improved understanding of the environmental pathways of pBDEs, to identify whether measures can be implemented which would limit further dispersal.
Streamlining of emissions reporting, so that robust data collected for one obligation would satisfy European emissions reporting requirements.
Improvement in the monitoring and reporting of diffuse sources, to ensure that pressures are correctly understood and measures can be appropriately targeted.
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Previous comments
POLAND
The source of the data needs to be added to the description of the table.
Specific actions - This section needs a very thorough explanation of reasons behind these suggestions. The purpose of putting the suggestions should be mentioned as well.
DE-NW:
'Specific actions proposed to improve protection of waters.'
Please revise according to the comments above in the text
DE-NW/SH:
'Further effort to reduce emissions of mercury from urban waste water treatment plants, either upstream or before discharge, seems necessary.'
Please delete! See comments above.
Please give better examples in text and choose more specific.
DE-NW:
'Improvement in the monitoring and reporting of diffuse sources, to ensure that pressures are correctly understood and measures can be appropriately targeted.'
Please, consider use of modelling....
DE-SH,BB:
'measures and timelines to reduce risks for human health and the environment by the end of 2012.'
Please, add more information on the effectiveness of these measures.
In the following (before the list) it should be:
'These include: -...., -....'
DE-UBA:
Table 3.2
Isotproturon should also be written with a capital letter.
DE-UBA IV 1.2:
'One of the challenges with chemical status is that once a persistent substance is in the aquatic environment, it may be there for a long time after emissions have ceased. This may lead to continued failure to meet good chemical status, and a potential mis-match with the pressures.'
For information: That's why we are interested in monitoring pesticides and reporting not only values above EQN. The regulators should have the opportunity to find an appropriate mitigation measure before EQN is exceeded.
DE-UBA:
The legend for Table 3.2 is missing. In the legend it should be (for red colouring) 'less than 7 MS reporting'.
'Please substitute then with than.
DENMARK
Where tertiary treatment of waste water is applied at most WWTPs, improved treatment is not necessarily the best effort. Reduction of mercury emissions from other sources could be more effective.
With the exception of mercury, pBDEs and some of the PAHs, Member States are making significant progress in tackling concentrations of individual priority substances in surface water bodies (EEA, 2018a). This should be seen as a success for European water and chemicals policies stretching back several decades.
Comment Belgium (Wallonia): a lot of data and trends on emissions and monitoring (especially in biota) are still missing for already drawing up this very optimistic assessment. It should be more nuanced.
Page 59 : Specific actions proposed to improve protection of waters
Comment Belgium (Wallonia): No link is made here with chapter 2 and the effect based monitoring ! Effect based monitoring is also very useful for emissons (eg whole effluent assessment), for a better understanding of the link between pressures and impacts in the DPSIR approach and to assess the efficiency of program of measures carried out on these pressures.
Limited information on point source discharges is also due to differences in emission regulations of Member States. The minimum monitoring requirements related to hazardous substances were determined and coherent for surface waters but this is not the case for point sources. We agree on the suggested specific actions based on the previous data analyses of the report.
P59, Summary action points: All of the general action points are sensible based on the interpretation of the data in the chapter and can be supported.