Post a comment on the text below

Chapter 4 considers some strategies and practical approaches as examples of the development of water and chemicals policies. The final chapter then draws some conclusions:

Most failures in chemical status of surface waters can be attributed to 3 groups of substances: mercury, PAHs and pBDEs. Specific actions targeting these priority substances are:

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.

Emissions data on pollutants as reported in Europe (for WFD, E-PRTR or WISE-SoE) could give an important overview on emissions, impact of measures and trends. However, they are incomplete and inconsistent and too often exclude diffuse sources. Improvements to our understanding of emissions could be achieved by:

Streamlining 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.

For some priority substances, low numbers of water bodies failing to achieve good chemical status suggest that, assuming monitoring and reporting are accurate, measures have been effective in preventing the entry of these chemicals into surface waters. This is a success for European water and chemicals policies.

If these substances were no longer priority substances, resources spent on them could instead be used monitoring substances currently considered to present a risk.

The success of measures against gross chemical pollution means that we increasingly look to ensure the good ecological status of water bodies. Scientific advances have identified sub-lethal effects caused by chemicals which can harm the healthy functioning of an organism. Applying such techniques in the assessment of ecological status would be one way to  improve protection from harmful chemicals under the WFD.

Previous comments

  • bednamal (Malgorzata Bednarek) 25 Sep 2018 16:52:55

    POLAND

    "Improvements to our understanding of emissions could be achieved by: Streamlining emissions reporting, so that robust data collected for one obligation would satisfy European emissions reporting requirements". If this statement is to be treated as a recommendation to the European Commission or Member States, it needs to be clearly explained and communicated to the Member States and the system needs to be consulted amongst experts working in various working groups within the CIS WFD as well as under MSFD and EEA. It also needs to fulfil the INSPIRE Directive requirements. Our understanding is that all of the other reporting obligations will be eliminated and replaced by one obligation gathering the information from different directives if this recommendation is going to be implemented. If this is the case, the obligation in terms of the frequency of reporting and the sufficient amount of data needs to take into account the differences between directives and slightly different approach at Member State level.

    "(…) assuming monitoring and reporting are accurate". We kindly ask to withdraw this part of the text from the draft. EEA has the measures to check the accuracy of the data reported via WISE.

  • sommelin (Linda Sommer) 26 Sep 2018 09:32:17

    DE-BY:

    Chapter 4 considers some strategies and practical approaches...

    Please replace 'practical' by 'scientifical'

    The mentionned strategies and approaches are not yet tested in routine monitoring but only in scientific projects. There is a lack of specialists and accredited laboratories.

  • sommelin (Linda Sommer) 26 Sep 2018 09:32:31

    DE-BY:

    Chapter 4 considers some strategies and practical approaches...

    Please replace 'practical' by 'scientifical'

    The mentionned strategies and approaches are not yet tested in routine monitoring but only in scientific projects. There is a lack of specialists and accredited laboratories.

  • sommelin (Linda Sommer) 26 Sep 2018 09:32:31

    DE-BY:

    Chapter 4 considers some strategies and practical approaches...

    Please replace 'practical' by 'scientifical'

    The mentionned strategies and approaches are not yet tested in routine monitoring but only in scientific projects. There is a lack of specialists and accredited laboratories.

  • sommelin (Linda Sommer) 26 Sep 2018 09:34:50

    DE-BY:

    pBDEs are mainly from diffuse sources, please add this aspect

  • sommelin (Linda Sommer) 26 Sep 2018 09:34:57

    DE-BY:

    pBDEs are mainly from diffuse sources, please add this aspect

  • sommelin (Linda Sommer) 26 Sep 2018 09:36:49

    DE-NW:

    also see comment above, for mercury, please substitute ' from urban waste water treatment plants' with other hot spots of emission.

  • sommelin (Linda Sommer) 26 Sep 2018 09:39:17

    DE-NW:

    'Improvement in the monitoring and reporting of diffuse sources, to ensure that pressures are correctly understood and measures can be appropriately targeted.'

    We would appreciate a reference to the use of modelling.

  • sommelin (Linda Sommer) 26 Sep 2018 09:40:17

    DE-BY:

    'Applying such techniques in the assessment of ecological status would be one way to improve protection from harmful chemicals under the WFD.'

    The ecological status is defined in relation to reference conditions based on species and abundances. Before changing this system in the WFD it should be proved that the recent assessment methods of the biological status are not able to tackle with chemical pressures.

  • sommelin (Linda Sommer) 26 Sep 2018 13:11:01

    DE-UBA II 2.2:

    a) mercury is not a substance group throuout the text it could be 'mercury and its compounds'

    b) It sounds as if UWWTPs are most important pathways. As far as we know mercury emissions to atmosphere caused by combution processes are very (most)important. UWWTPs are just one pathway for urban areas. In Germany storm water discharges and overflows from combined sewer systems are more important for mercury.

  • anderas0 (├ůsa Andersson) 28 Sep 2018 21:45:40

    "Further effort to reduce emissions of mercury from urban waste water treatment plants, either upstream or before discharge, seems necessary."

    Why is only urban waste water plants mentioned here when the main sources specified on p 4 includes coal burning and chemical industry?

    “For some priority substances, low numbers of water bodies failing to achieve good chemical status suggest that, assuming monitoring and reporting are accurate, measures have been effective in preventing the entry of these chemicals into surface waters.” 

     Correct if the EQS is protective in line with the aims of the framework. Some EQSs have been adopted from older legislation. The EQS for DDT for example do probably not consider protection of top predators.

  • hatfisim (Simon Hatfield) 05 Oct 2018 11:01:13

    P5, 3 bullets: The first action seems at the local scale whereas the other two – for PBDEs and PAHs - are more general. Could this be expanded on briefly, please?

    The last section hints at deselection of “redundant” PS. This is something COM started to explore then stopped. Could this be expanded on here, i.e. summarising further section 5?

    P5, second from last paragraph: One proposal might be that for those PS that are no longer an EU wide-scale risk issue, but that are not necessarily problems in <4 member states, could be recommended for RBSP in affected MS following deselection as PS.

You cannot post comments to this consultation because you are not authenticated. Please log in.