Table of contents
- Executive Summary
- 1. Introduction
- 2. "Known unknowns” – unregulated micropollutants and chemical mixtures
- 3. Known risks: Key pollutants and their sources
- 4. Strategies to reduce chemical pollution of water
- 5. Improving protection against chemical risks in water
- 6. References
- 7. Annex A: Derivation of emissions data for figures in chapter 2
- 8. General comments
Executive Summary
EU and international policy have been tackling water and environmental pollution for nearly 50 years. Gross chemical pollution, exemplified by “dead rivers”, has been successfully addressed in many cases. However, in its recent report, “European waters — Assessment of status and pressures 2018”, based on data from Member States on the implementation of the Water Framework Directive (WFD), the European Environment Agency (EEA) found that despite action to reduce chemical pollution over many years, only 38 % of EU surface water bodies are in good chemical status. 46 % are not achieving this status, and 16 % are in unknown chemical status (EEA, 2018a).
The risk presented by hazardous substances is assessed under the WFD by comparing concentrations in the environment with environmental quality standards (EQS) for single substances. Some of the substances show high toxicity directly to organisms in the water, while others accumulate up the food chain and may therefore harm predators, which includes humans eating fish. This single substance approach has been used for many years, and fits well with regulation which seeks to control chemicals at source.
However, our understanding of the complex interactions between chemicals and living organisms has greatly increased over the last 20 years. At concentrations lower than those which kill directly, harmful chemicals may exert more subtle effects on organisms, for example limiting their ability to reproduce. Concern has been raised in relation to “the cocktail effect”, referring to mixtures of substances which may be present at low concentrations and which may combine in complicated ways to affect health. Achieving good status in surface waters may therefore require a better understanding of the subtler links between ecological and chemical status. Some approaches to improving this understanding are described in chapter 2.
Improving protection against chemical risks means we need to know what the risks are. Returning to what monitoring and reporting currently provide, chapter 3 gives more specific information on the chemicals recently reported as causing failure under the WFD. It describes fate, status and pollution, and provides examples of measures for the 15 substances most commonly causing failure across Europe under the WFD, and a further 15 identified at Member State level as River Basin Specific Pollutants.
Among these substances, those described as “ubiquitous” cause the most failures. They are persistent and toxic substances, distributed worldwide, in many cases over many years. Mercury is the major cause of failure: nowadays in Europe its main sources from human activities are from coal burning for power generation and the chemical industry, while substantial amounts are also released from urban waste water treatment plants (EEA, 2018b). Brominated diphenylethers (pBDEs), which were used as flame-retardants, and polycyclic aromatic hydrocarbons (PAHs) which arise both naturally and from human sources during the burning of organic matter, are also leading causes of poor surface water quality. If these ubiquitous substances are omitted, only 3% of surface water bodies in Europe fail to achieve good chemical status.
Several other substances used in products enter surface water, mostly via urban waste water treatment plants. Examples are nonylphenols, used as surfactants, and the plasticiser DEHP. Historically, pollution by metals was caused by industry and mining, but significant sources now include our homes, buildings and untreated storm water discharges. Agriculture is the major user of pesticides, though we have limited data to show that as a source, while municipal and domestic uses can be significant in urban waste water. The herbicides isoproturon, metolachlor, MCPA and terbuthylazine are discussed, as is the insecticide lindane, already heavily regulated but a very persistent and volatile substance. Some biocides, like tributyltin were used to protect vessels from “fouling” by mussels and other water organisms.
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DE-BY,NW
'relseased from urban waste water treatment pants': According to MoRE model emissions of urban waste water treatment plants are about 2% of the total Hg-Emissions into german rivers - this amount is not seen as a "substantial amount". Hence, on page 5 the conclusion 'further effort to reduce...' this source should be reconsidered.
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DE-UBA II 2.2:
'Historically, pollution by metals was caused by industry and mining, but significant sources now include our homes, buildings and untreated storm water discharges.'
Please add combustion processes.
Is storm water discharge meant as source or as pathway? Because of emissions coming from combution processes (causing atmospheric deposition) storm water discharges are an important pathway for metalls. Furthermore, it doesn´t seem to be a complete new source/pathway.
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DE-UBA IV 1.2:
'Agriculture is the major user of pesticides,'
Is there a literature source available, if so please amend.
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EurEau
UWWTP are not source of pollution but pathways from the urban areas. They are treating what they are designed for. Specific pollutions should be tackled at source to apply the polluter pays principle.
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P4, 1st paragraph: Please consider referencing changing standards here as this is quite an important reason for the current status as analysed. Without this context, the statement may be misleading.
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.
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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.
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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.
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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.
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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.
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DE-BY:
pBDEs are mainly from diffuse sources, please add this aspect
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DE-BY:
pBDEs are mainly from diffuse sources, please add this aspect
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DE-NW:
also see comment above, for mercury, please substitute ' from urban waste water treatment plants' with other hot spots of emission.
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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.
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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.
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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.
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"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.
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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.
POLAND
All of the abbreviations should be explained in the document, particularly those which are not used commonly, such as names of pollutants - e.g. DEHP.
"Historically, pollution by metals was caused by industry and mining, but significant sources now include our homes, buildings and untreated storm water discharges. Agriculture is the major user of pesticides, though we have limited data to show that as a source, while municipal and domestic uses can be significant in urban waste water. The herbicides isoproturon, metolachlor, MCPA and terbuthylazine are discussed, as is the insecticide lindane, already heavily regulated but a very persistent and volatile substance. Some biocides, like tributyltin were used to protect vessels from “fouling” by mussels and other water organisms." - Literature sources needed to give more in depth information and explain the context of the mentioned statements. The statement about agriculture needs rewording or withrawal as it seems vague and looks like there was not enough research done on that subject.