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It is also possible to review River Basin Specific Pollutants to identify those which might have European wide relevance (table 5.2). RBSPs most often exceeding their EQSs are shown, with the range in EQS values used (derived from Member States RBMP reporting).

Table 5.2 Selected River Basin Specific Pollutants with largest numbers of countries reporting failures; Comparison of minimum and maximum national standards for annual average EQS.

Note: Data from RBMP reporting differ from those reported by Irmer et.al. (2014) which were derived from voluntary reporting.

– 1 country had standards for both free and total cyanide, hence 8 countries reported in table 2.1.
Source https://tableau.discomap.eea.europa.eu/t/Wateronline/views/WISE_SOW_FailingRBSP/SWB_FailingRBSP_Europe?:embed=y&:display_count=no&:showVizHome=no  (30 Aug 2018)

Decisions on what substances are proposed as priority substances are made through the collaborative process under the WFD, prior to a Commission proposal subject to the co-decision process. It is currently unclear when the next revision to the list of priority substances may be made.

Guidelines for EQS derivation are set in the technical guidance document for environmental quality standards (EC, 2011b). Although such documents should promote coherence and harmonisation, EQS values can differ by up to 10 000 times for the same substance (e.g. phenol, glyphosate) (Irmer, et al, 2014).

As well as variation in values of EQS, there can be significant differences in numbers of RBSPs between Member States – between 1-136 RBSPs were reported as causing failure in the 2nd RBMPs[1]. This has an influence on the likelihood of an RBSP failing to meet an EQS, and so the likelihood of a water body being able to achieve good ecological status. More RBSPs make it more likely that a water body may not meet the EQS.

Looking forward, it would seem that improving consistency (or harmonising) RBSP EQS values would improve comparability between river basin districts. It would not address differing numbers of substances for which standards are set, and, given the variation across Europe of substances meeting the RBSP definition, it seems difficult to overcome that issue. Consideration should be given to including all chemicals information in one place, e.g. chemical status, reflecting actual water management, if other ways are found to better integrate chemical and ecological status.

Previous comments

  • Annalisa Bortoluzzi (invited by Caroline Whalley) 28 Sep 2018 16:23:20

    Eurometaux 

    "It is also possible to review River Basin Specific Pollutants to identify those which might have European wide relevance (table 5.2). RBSPs most often exceeding their EQSs are shown, with the range in EQS values used (derived from Member States RBMP reporting)."

    This passage seems to suggest that zinc, copper, and other RBSP with large number of exceedances should become PS. This assessment looks simplistic. In fact, in 2014-2016 the Commission, the Joint Research Centre and the Sub-Group Review have looked holistically at thousands of chemicals with the aim to review the list of priority substances (JRC, 2016. Monitoring based exercise: Second review of the Priority Substances list under the Water Framework Directive). Robust and objective criteria were used to assess the Spatial distribution, Temporal frequency, and Extent of the exceedances (STE criteria) – i.e. much more refined criteria than simply the “number of exceedances” as presented on page 67. This work allowed to screen substances which are of Community-wide concern using harmonized criteria. The outcome of this robust exercise was clearly different than the list in Table 5.2.

    Therefore, we suggest removing from the text the possibility “to review RBSPs to identify those which may have European wide relevance (table 5.2). Concretely:

    • The text should reference the above report by the JRC.
    • The sentence “It is also possible to review River Basin Specific Pollutants to identify those which might have European wide relevance (table 5.2)” should be removed, since the data shown in Table 5.2 are a poor indicator of EU-wide relevance (the STE criteria in the JRC report do a better job).
    • The need for and ongoing joint efforts to improve the assessment of metals in water should be acknowledged and the preparation of the new CIS Technical Guidance for implementing bioavailability-based Environmental Quality Standards (EQS) for metals mentioned in this report. In fact, we believe that until now, a correct EU-wide assessment has not been made for metals.
  • Annalisa Bortoluzzi (invited by Caroline Whalley) 28 Sep 2018 16:24:37

    Eurometaux

    "Table 5.2 Selected River Basin Specific Pollutants with largest numbers of countries reporting failures; Comparison of minimum and maximum national standards for annual average EQS."

    Table 5.2 and corresponding text p. 67-68:

     

    The range of EQS values are difficult to interpret correctly with the limited available information. The number “0” is clearly a numerical rounding. For copper and zinc, the range of EQS reflects differences in bioavailability (e.g. due to water bodies with different physico-chemical characteristics in terms of pH, hardness, and dissolved organic carbon) rather than differences in EQS between Member States. We suggest adding this information, otherwise the ranges shown in Table 5.2 have little relevance and risk being interpreted wrongly.

  • anderas0 (├ůsa Andersson) 28 Sep 2018 22:27:08

    Minimum AA-EQSs for Zn, Cu, As and Cr given in table (0 µg/l) cannot be correct.

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