According to the WFD, EU Member States should aim to achieve good status in all bodies of surface water and groundwater by 2015 unless there are grounds for exemption. Only in this case may achievement of good status be extended to 2021 or 2027 or less stringent objectives be set. 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 (i.e. with a low human impact).
Compared to the first RBMPs, there are for all four measures of status[3] a higher proportion of water bodies in good status in the second RBMPs. However, there are also for surface waters a higher proportion of water bodies in less than good status. Both the changes in proportion of good and less than good status are due to improved knowledge of the water environment (i.e. fewer water bodies have unknown status).
Ecological status has improved for many biological quality elements from the first to the second RBMPs. For chemical status, a very low proportion of surface water bodies (3 %) is reported to fail to achieve good status, if ubiquitous substances, especially mercury, is discounted, and only few priority substances are causing poor chemical status (mainly heavy metals like cadmium, lead and nickel). Improvement in status for several priority substances shows that Member States are making progress in tackling sources of contamination.
There are several possible explanations of the limited improvements in overall status from the first to the second RBMPs.
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"....if ubiquitous substances, especially mercury, is discounted " Please replace "is" by "are".
"Overall status and overall progress since the first RBMPs" it would be helpful to explain what you understand by ”overall status” as the WFD doesn’t use such a concept.
"Compared to the first RBMPs, there are for all four measures of status a higher proportion of water bodies in good status in the second RBMPs. However, there are also for surface waters a higher proportion of water bodies in less than good status." These 2 sentences are a bit confusing and it is not clear whether the proportion of water bodies in good status in the 2nd RBMPs is higher or lower than in the 1st RBMPs...
"Second, for some water bodies some quality elements have improved in status, but there has been no improvement in the overall status." could be replaced as follows "Second, for some water bodies some quality elements have improved in status, but due to the one-out-all-out principle there has been no improvement in the ecological status/potential, the chemical or quantitative status."
BE-FLA (RV): p. 7, §1 1 p. 12, §7 Good status
High status compares with a small deviation from undisturbed (= pristine) conditions. Good status means that the observed status meets the EQSs or other requirements. (Note: Good status EQSs reflect an acceptable level of harm, and not (almost) undisturbed states).
BE-FLA (RV): p. 7, §1 Ecological status
Ecological status must be first defined as the combined status of biological + hydro-morphological + physico-chemical status
BE-FLA (KB): p. 7, §3 Ecological status has improved for many biological quality elements from the first to the second RBMPs. For chemical status, a very low proportion of surface water bodies (3 %) is reported to fail to achieve good status, if ubiquitous substances, especially mercury, is discounted, and only few priority substances are causing poor chemical status (mainly heavy metals like cadmium, lead and nickel). Improvement in status for several priority substances shows that Member States are making progress in tackling sources of contamination.
Very optimistic conclusion. The results rather tend to reflect the differences between the monitoring programs of the member states. It is obvious that heavy metals exceedings are expected, as they are largely monitored.
it is suggested that
........Compared to the first RBMPs, there are for all four measures of status a higher proportion of water bodies in good status in the second RBMPs.
to be changed into
......Compared to the first RBMPs, there is for all surface water bodies categories and groundwaters a higher proportion of water bodies in good status in the second RBMPs.
Concerning the overall status , it would be helpful to explain this concept as the WFD does not provide it
(AT) The 2nd para 'Compared to the first....'
difficult to understand, should be simplified, e.g. improved knowledge of the water environment (i.e. fewer water bodies have unknown status) results in a higher proportion of water bodies in good but also in less than good status
"Ecological status has improved for many biological quality elements"
But it is not seen clearly in the overall status because of the one-out-all-out rule.
SK: Page 7, 2nd paragraph: Add the following words to the sentence “...due to improved knowledge of the water environment and improved water monitoring programmes (i.e. fewer...”.
SK: Page 7, 4th paragraph, second bullet: There is mentioned “status” and also “overall status” in one sentence. Although this is outlined in the Figure 1.1, the explanation of term “overall status” should be mentioned in the text as well, because the term “overall status” is not officially used and defined in the WFD.
"and only few priority substances are causing poor chemical status (mainly heavy metals like cadmium, lead and nickel)."
Please, erase “heavy” and keep only “metals”. The term “heavy metals” is poorly defined and should not be used – this comment applies throughout the report. Also, were these metals (Ni, Pb) assessed appropriately, accounting for bioavailability? If not, or if this was not assessed, then this needs to be explicitly stated – the EQS is not failed if the EQS has not be used appropriately, i.e. as shown in the directive. This would be the same for any other operationally derived standard (e.g. biota-based for mercury or PAHs). We suggest this point to be explicitly made in Section 1.3.
"There are several possible explanations of the limited improvements in overall status from the first to the second RBMPs"
As mentioned in the ’general comments’, it is important for those metals with a Biotic Ligand Model to include a bioavailability correction, and for the background concentrations to be incorporated.
CZ: One of the reasons for little improvement may also be incomparable sets of pollutants assessed and also different EQS or threshold values applied in 1st and 2nd RBMPs.