Post a comment on the text below
Assessing status of water
EU Member States should aim to achieve good status in all bodies of surface water and groundwater by 2015 unless there are grounds for derogation. Only in this case may achievement of good status be extended to 2021 or by 2027 at the latest. Achieving good status involves meeting certain standards for the ecology, chemistry and quantity of waters. In general, 'good status' means that water shows only a slight change from what would normally be expected under undisturbed conditions. There is also a general 'no deterioration' provision to prevent deterioration in status. An overview of assessment the status of surface waters and groundwater according to the WFD is illustrated in figure 1.1.
Ecological status of the WFD assesses ecosystem health expressed by biological quality elements: phytoplankton, macrophytes, phytobenthos, benthic invertebrate fauna, and fish, supported by hydromorphological and physico-chemical parameters: nutrients, oxygen condition, temperature, transparency, salinity, and river basin specific pollutants (RBSPs). The Directive specifies which elements are to be assessed for each water category, and requires that all biological elements and supporting quality elements achieve at least good status.
The WFD aims to ensure good chemical status of both surface water and groundwater bodies across Europe. For surface waters, this goal is defined by limits on the concentration of certain pollutants relevant across the EU, known as priority substances. Good chemical status means that the concentrations of all priority substances do not exceed the environmental quality standards (EQS) established in the Environmental Quality Standards Directive 2008/105/EC and amended by the Priority Substances Directive 2013/39/EU[6]. EQS are set to protect the most sensitive species, including humans via secondary poisoning.
Good groundwater chemical status is achieved when there is no saline intrusion in the groundwater body, when concentrations of specified substances do not exceed relevant standards, and does not result in failure to achieve good status of associated surface water bodies, nor cause significant damage to terrestrial ecosystems which depend directly on the groundwater body[7].
Figure 1.1. Assessment of status of surface waters and groundwater according to the WFD
Good groundwater quantitative status is achieved by ensuring that the available groundwater resource is not exceeded by the long-term annual average rate of abstraction[8]. Accordingly, the level of groundwater may not lead to any diminution of ecological status of connected surface waters or any diminution of groundwater dependent terrestrial ecosystems. Furthermore, reversals of flow direction may not result in saline or other intrusions.
You cannot post comments to this consultation because you are not authenticated. Please log in.
Previous comments
“EU Member States should aim to achieve good status in all bodies of surface water and groundwater by 2015 unless there are grounds for derogation. Only in this case may achievement of good status be extended to 2021 or by 2027 at the latest.”. This is not correct and not in line with the documents approved by WD in 2017. A “derogation” (please avoid this word and use exemption, as derogation has to be requested (Nitrate Directive), while exemption has to be motivated in plans) is also possible beyond 2027, in case it can be motivated within WFD art 4.4.c.
“Good chemical status means that the concentrations of all priority substances do not exceed the environmental quality standards (EQS) established in the Environmental Quality Standards Directive 2008/105/EC and amended by the Priority Substances Directive 2013/39/EU”. This suggests that PSD2013 should have been applied in 2015. This is the case for NL (and I believe SW and LUX), but most countries used only PSD2008. This is correctly explained at p. 19. Please avoid misunderstanding, with the text on p. 13.
1. "Good groundwater chemical status is achieved when there is no saline intrusion in the groundwater body, when concentrations of specified substances do not exceed relevant standards, and does not result in failure to achieve good status of associated surface water bodies, nor cause significant damage to terrestrial ecosystems which depend directly on the groundwater body11. "
The sentence is very complex / complicated. Rephrase, please.
&
Please change "does not" in "do not".
2. The presentation of the ecological status / potential in figure 1.1 is to our opinion misleading.
a) There is no visible differentiation between biological quality elements and supporting physiical and chemical quality elements (including hydromorphology). As in Germany and to our knowledge in most MS the ecological status / potential is determined by the biological quality elements only. The physical and chemical quality elements (including hydromorphology) are only used supportive. Please change figure 1.1 accordingly.
b) The figure 1.1 contains a green field called "overall status". Basically the WfD consists for surface waters of a "ecological status /potential" and a "chemical status". Both have to be in at least "good status" - if not, measures are necessary in order to reach the good status/potential.
But the WfD contains no "overall status" per definition and the MS`s do also not report such an "overall status" to the EU- Commission. Therefore we recommend to delete the green box "overall status" from this figure.
The figure 1.1 is not 100% in line which the provisions of the WFD.
Ecological potential: The ecological potential classification only distinguishes 4 classes and these should be added to this figure.
Groundwater: According to the WFD groundwater quantitative and chemical status is good or poor but not ”failing to achieve good”. Besides the colour-code for good status is green and not blue.
Overall status: The WFD does not foresee such a status.
BE-FLA (RV): p. 12-13 All biological elements
This is an important requirement and the degree this is met should be reflected in the analysis.
"In general, 'good status' means that water shows only a slight change from what would normally be expected under undisturbed conditions." Does this imply no human activity?
"The Directive specifies which elements are to be assessed for each water category, and requires that all biological elements and supporting quality elements achieve at least good status."
This is wrong. There are no exact values for hydromorphology to achieve a good status or potential. Actually, even the classification guidance document includes the case when biological quality elements achieve a good status and physico-chemical elements do not, then modifying class boundaries of physico-chemical quality elements shall be considered.
It should be made clear in the Figure 1.1 that phy-chem and hydromorphology are not at the same level as BQE, but only constitute supporting elements.
(AT): Figure 1.1
AWB/HMWB Ecological potential is not mentioned at all. Ecological potential classes have to be included in the graph – only 4 classes are used for presenting potential (high does not exist), differnt coulour code is used (green/grey stripes,...)
Degoration--> term exceptions is used in WFD art.4
"Ecological status of the WFD assesses ecosystem health expressed by biological quality elements: phytoplankton, macrophytes, phytobenthos, benthic invertebrate fauna, and fish, supported by hydromorphological and physico-chemical parameters: nutrients, oxygen condition, temperature, transparency, salinity, and river basin specific pollutants (RBSPs)."
It is not clear how the RBSPs were assessed in the context of ecological status, and how the factors (biological diversity and hydromorphological) ranked when compared to physico-chemical analysis. It seems that RBSP are basically treated like Priority Substances, e.g. when failing the EQS, the whole water body will not achieve ‘good ecological status’. It may be helpful to have evidence of how many water bodies fail ecological status based on the biology and hydromorphology. We are concerned that the disproportionate attention paid to RBSP, and to metals in particular, is due in part to their natural occurrence, the easy and cheap methods for their detection, and possibly to the bias in sampling near areas of concern, which will unsurprisingly show high concentrations of metal. To our understanding, the evaluation of the ecological status and the causative factors explaining less than good ecological status on the one hand, and the management approaches that are considered to improve ecological status on the other hand are somehow disconnected. The analysis shows that a major source of deterioration of ecological status is “hydromorphological pressure”. However, there seems to be an assumption that improving chemical status alone will improve ecological status, and so that is the focus. And metals become the sub-focus because they are indeed easy to measure. But even if all waters show good chemical status, good ecological status will be difficult to attain because of impacts of non-contaminant stressors.
Please, add the following to the end of the 2nd Para :
"The results of the ecological status assessment can be significantly affected by the methodology applied by individual Member States."
Justification: the assessment methods in Member States, the practical use of CIS Guidance No. 13. e.g.: combination of quality elements ("one out all out" principle), the criteria of confidence (high, medium, low, not known) or that, how many biological quality elements and indicative quality element for pressures were monitorized in given waterbody give large variable picture among MSs. All this information could establish and give reasonable knowledge to compare results in consistent way. The impact of pressures all this above mentioned reasons could be describe in more cases in quality element level only and not in ecological status level.
PLease change the right part of Fig 1.1, since the "overall status" does not exist in the WFD