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Full implementation of standards for chemical status assessment
The Directive 2008/105/EC on Environmental Quality Standards (EQS Directive 2008/105/EC)[12] is fully in force for the second RBMPs and means stricter standards for some priority substances compared to the first RBMPs. The Directive also requires Member States to report an inventory of emissions, discharges and losses in their second RBMPs.
During our analysis, it has become clear that Member States have used a variety of approaches to determine chemical status, for instance,
- In how they extrapolate monitoring results. Several Member States (Austria, Belgium, Germany, Sweden, Luxembourg and Slovenia), having found that the environmental quality standard for mercury is exceeded in all monitoring samples, have extrapolated the assessment “failing to achieve good” to all surface water bodies.
- Using different standards for chemical status. According to the WFD2016 reporting guidance, Member States should have reported chemical status for 2015 using the standards laid down in the EQS Directive 2008/105/EC, but some Member States have reported chemical status by using the stricter standards in the 2013 amendment to the Priority Substances Directive.
As regards the Groundwater Directive, the assessment of trends of pollutants in groundwater will be possible for the first time in the second RBMPs, by comparing the monitoring results with the results in the first RBMPs.
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last sentence:
Please replace "will be" by "are" or "were".
(Why future tense is used here?)
In Luxembourg the EQS for the sum Benzo(g,h,i)-perylene + Indeno(1,2,3-cd)-pyrene was systematically exceeded and therefore we assumed that the chemical status was ”failing to achieve good” status in all surface water bodies.
(AT) end of 2nd bullet point '.. Priority Substances Directive.'
Include reference to Directive 2013/39/EU
SK: Page 19, 4th paragraph: Use official reference via Eur-lex: http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1517936846370&uri=CELEX:32008L0105 as a reference for EQSD in footnote.
SK: Page 19, second bullet: We are not sure whether the English is correct in the sentence ”... amendment to the Priority Substance Directive. We suppose that there should be written ”...amendment by Priority Substance Directive” because Directive 2013/39/EU have not been amended yet. On the contrary, the Directive 2008/105/EC (EQSD) was amended in 2013 by directive 2013/39/EU (Priority Substance Directive).
SK: Page 19, 6th paragraph: Add reference on Groudwater Directive, as a 2006/118/EC (http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1517937438209&uri=CELEX:32006L0118).
p. 19 We suggest to slightly reformulate "Using different standards for chemical status. According to the WFD 2016 reporting guidance, Member States should have reported... Priority Substances Directive". This sounds like the countries that used stircter standards limits have made wrong. We followed our legislation and current directive of priority substances and were unable to reclassify about 20,000 water bodies for reporting. We propose:
Using different standards for chemical status. Some Member States applied the revised, generally stricter, EQS set out in the 2013 amendment to the Priority Substances Directive while most countries used those from the 2008 version of the Directive and also according to the WFD2016 reporting guidance.