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Switzerland has no comments to the report
DE-SH:
The title raises expectations with respect to management and protection of inland waters; however the content of this draft mainly contributes to the field of monitoring. Please consider a title which better reflects the scope of the paper.
POLAND
Thank you for the report - it is a very interesting cross-sectional analysis.
As the title says "improving protection", it suggests such evidence confirming improvement is emphasized. As it is not, perhaps a title could be modified.
We suggest to complete the draft with the section clarifying the suggested outcome of this report in terms of water policy, chemical policy, impact on WFD Common Implementation Strategy and other directives. It is also important to clarify how the results and conslusions drafted in the report are going to impact water policy and chemicals policy at the EU level if this document is going to be used by policy makers.
DE-UBA IV 1.2:
General remark: the meaning of the word pesticides is sometimes not clear. Sometimes pesticides is used for plant protection products (PPP) and sometimes pesticides cover even PPP as well biocidal products (which would be correct).
Please, be clear in the wording!
DE-UBA II 2.5:
DENMARK
We welcome this report that gives grounding for what is known about key pollutants and how surface waters might be better protected in the future. A report dealing with similar issues is about to be prepared by the INTERREG Baltic Sea Region. This report analyses the interfaces, linkages and gaps between key EU legislation concerning the use and releases of hazardous substances. A number of issues from this report might be relevant here as well.
In the report ‘Improving protection against chemical risks to European inland waters’ there is an overview of how chemical status of surface waters under the WFD is performed, also there is a schematic overview of the chemical status for the different member states. However, there is no mentioning and discussion of the issues of EQS’s established for the water matrices and the fact that monitoring is performed in other matrices due to substance specific properties. We find that this issue should be mentioned in the report as a number of priority substances most likely will bioaccumulate and sorb to sediment and therefore it would make sense to establish EQS’s for these matrices in addition to the ones for the water phase. Different member states handle this issue in different ways and this is also reflected by the large percentage of unknown chemical status in surface water bodies. Furthermore there is no mentioning in the report about accumulation in sediment and biota of harmful substances and how this is dealt with in relation to the WFD.
Another issue that could be included in the report is leaching of chemicals from polluted soil from former industrial areas and deposits. This pathway might be a significant point source of hazardous substances that should not be neglected.
EurEau welcomes this report. However we would like to see the description of urban waste water treatment plants as pathways for pollutants more than point source pollution. As referred in the notes several times, and rightly mentioned in section 3.5 of the report: "treatment plants are recipients of contaminants from upstream uses and discharges, providing a known pathway into the aquatic environment, rather than they themselves being the user of hazardous substances". The report should reflect this statement, which is not the case for the moment.
The level of treatment is governed by the UWWTD. As soon as WWTPs are compliant with the requirements, they should not be considered as polluters because they accomplish the level of treatment they are designed for. It is not sustainable to always increase the level of treatment because there are new substances in the waste water. Upstream measures and control at source should be favoured.
Eurometaux
Thank you for considering our comments and acknowledging our concerns. We believe there is still room for improvement with respect to how metals are evaluated at the EU continental scale. In fact, without bioavailability normalization, conclusions about exceedances for metals are not possible. To that end, given that the exceedance rate of metals is very low (e.g. 0.5% for Ni), it may not be possible to statistically confirm decreases or increases in the exceedance rate. There is no measure of the variability in terms of exceedance, and without this knowledge, setting a target is difficult. This is particularly true for naturally occurring metals, where setting a target of zero exceedances is not warranted.
We believe the report should acknowledge that metals are measured most frequently by most countries. The number of exceedances as such is therefore function of the number of measurements; the use of absolute number of exceedances is potentially misleading.
Also, in general, treatment of “mining” throughout is simplistic; e.g.
We appreciate submitted, very comprehensive document which contains evaluations based on the second cycle of RBMP reporting and also overview of new methods and assessment carried out under WFD.
We fully agree with all constructive comments in all chapters from Germany, Poland, Denmark.and we encourage to incorporate them into the submitted material.
here in the report is used expression „pesticides“. There in the report should be used correct terminology – please note - not to use term „pesticides“, but „active substances“.
Proposal for a cooperation (suitable also for presentation in the conclusions): For the next future we suggest to cooperate together with experts responsible for authorisation of Plant protection products (PPP) , who have the best knowledge about properties and behaviour of active substances in environment (soil, groundwater, surface water). Experts could also help with the description of behaviour of individual active substances and their metabolites (chapter 3.7.1-3.7.2).
One from the procedures within the PPP authorisation is the comparative assessment – introduced with the aim to reduce the risk and identify alternative products or methods that are safer (such harmful active substances are defined as “candidates for substitution” and they are then replaced with safer substances in the PPP. This is one from the examples how the protection against chemical risk could be solved.
For any question regarding previous Belgian (Wallonia) comments inserted in the different comments boxes (Chapters 1 to 5), please contact the Walloon water expert Elisabeth Chouters (elisabeth.chouters@spw.wallonie.be) + NFP team in cc (nfp@irceline.be)
Coördinated comments from the Netherlands
Subject: EEA Assessment on ‘Improving protection against chemical risks to European inland waters’.
(version 1.5), date 2018/09/05.
Dear colleagues, dear Caroline,
Further to your request to consider and review this draft and provide comments, please find below our contribution.
As stated, the report builds on the EEA’s recent report “European waters - Assessment of status and pressures”, and considers the messages that you can draw from the reporting.
Apart from minor issues, like the definition of chemical status, which is not limited to Priority Substances, but also encompass ‘certain other pollutants’ (page 7, 9); the missing headers in Table 3.1 d, e and the reference to Fig 2.1D instead of 2.2D –which will all be corrected in the completion of the report -, the messages drawn from the reporting is clear. In general the message is supported. The availability of proper monitoring data is key to a perform a proper analysis.
The reference to the work of Malaj et.al on p. 16 also shows that the expected risk increases with the availability of more chemical monitoring data. The more one monitors, the bigger the chance of not meeting the objectives. One cannot assess what one does not know. This also means that if one fulfils the monitoring obligations under the WFD in a “lean and mean-way”, risks might be “overlooked”. Especially as regards the River Basin Specific Pollutants (RBSP) it is clear that there is a different approach between the MS, both with respect to the number of RBSP and the EQS. Instead of the adoption of EU-wide EQS’s for RBSP – making them Priority Substances – one could propose to use the xth –percentile (x= 5 or 10) of the range of EQS’s used by MS as a maximum EQS or the introduction of a peer-review of national standards could also narrow the range of EQS’s used.
As said, the drawbacks of the current approach and conclusions drawn on the basis of the analysis are supported in general, as are the suggestions for improvement (establish the link between chemical and ecological status; combined effects/mixture toxicity/use of bio-assays; improve emission inventories and pay attention to diffuse sources, how can one show progress/keep support from politicians and stakeholders).
As regards showing progress, it is important - also from the side of the EEA - to present the figures and charts in reports and presentations that show this progress, i.e. those based on individual substances and biological quality elements (BQE) instead of the figures and charts based on the contra productive one-out-all-out approach. Feeding this into the review process of the WFD and subsequently formalizing it in an updated version of the WFD is deemed necessary.
The call for attention as regards bio-assays and mixtures is not new. Somehow it seems difficult to make it work in practice. Although progress has been made in the past years, there are still questions to be answered. What mixture should one assess? What (battery of) bio-assays should one use? It seems too early to make the use of bio-assays obligatory– especially in addition to current monitoring obligations. However steps need to be taken. Introduction of these new techniques, including the use as a screening method, could be facilitated if these replace current monitoring obligations. It would contribute to a better link between chemical and ecological status and lead to a better informed assessment. If the current WFD already allows for these bio-assays it should be clarified, if not, an updated version should give flexibility to MS to use these methods instead of the current obligatory monitoring. Simply adding these to the current monitoring obligations would increase the already substantial monitoring expenses.
The substance by substance approach and the associated monitoring data serve as a feedback to other chemical legislation. A better coherence between the pieces of legislation concerned, needs to be established.
To conclude, we in general support the assessment and conclusions drawn on the basis of this assessment. We also support the plea for an EU-wide improvement of the implementation of already obligatory monitoring requirements and emission inventories. This is necessary to get EU-wide comparable results. As regards the way forward, work on mixtures and bio-assays should continue. The focus however should be on implementation in practice.
We trust that the comments with respect to the report will be taken into account and that suggestions with respect to new developments and improvements will be taken on board ass well or will be passed to the Commission in the light of the review process of the WFD.