Table of contents
- Guidance to the reader
- General comments
- Executive summary
- 1. EEA State of Water assessment and EU water policy context
- 2. Ecological status and pressures
- 3. Chemical status and pressures in surface waters
- 4. Groundwater chemical status and pressures
- 5. Groundwater quantitative status and pressures
- 6. Overall status, progress achieved and future challenges
Executive summary
Executive summary
Key messages
- This report presents results on the status of EU waters based on the second River Basin Management Plans (RBMPs). It shows the pressures that continue to affect the quality and quantity of water and what progress has been achieved during the first RBMP cycle (2009-2015).
- European waters remain under pressure from water pollution, over-abstraction and structural change from a range of human activities. These pressures often act at the same time and affect the good functioning of ecosystems, contribute to biodiversity loss, and threaten the valuable benefits water provides to society and the economy.
- Marked efforts have been made by Member States to improve water quality or reduce pressure on hydromorphology. Some of the measures have immediate effect; others will result in improvement in the longer run. Results are usually visible at the level of individual quality elements or pollutants but often do not translate into an overall improved status.
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- regarding 'others will result in improvement in the longer run': Although that is the case for some measures, it should be emphasised as well that the reason for minor improvement is the lack of adequate measures and effective tacking of pressures. That should be explained in the summary. This should give the correct picture of water management in Europe and lack of ambition is an important part of that picture.
- on 'Results are usually visible at the level of individual quality elements or pollutants but often do not translate into an overall improved status': at the same time would be useful to emphasise the importance of 'one-out-all-out'.
- Of the different types of waters recognised by the Water Framework Directive across Europe, groundwaters generally have the best status. Good chemical status has been achieved for 74 % of them, while 89 % achieved good quantitative status.
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BE-FLA (WV): p. 4, 5 Of the different types of waters recognized by the Water Framework Directive across Europe, groundwaters generally have the best status. Good chemical status has been achieved for 74 % of them, while 89 % achieved good quantitative status.
% mentioned is “by area”, important to note that.
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p 4,5 it is suggested to be changed into
Of the different surface water categories and groundwaters recognised by the Water Framework Directive across Europe, groundwaters generally have the best status.
because for the GWs the WFD does not indicate the type differentiation
- For surface waters (rivers, lakes, transitional waters and coastal waters) the percentage in good ecological status is around 40 %, while only 38 % of surface waters are in good chemical status.
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Please clarify if his information is ”only” referring to ecological status or also to ecological potential. The differentiation between ecological status and potential is not always very clear in the document and this should be further specified in order to avoid any misunderstandings.
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BE-FLA (KB): p.4, 5 Key messages. For surface waters (rivers, lakes, transitional waters and coastal waters) the percentage in good ecological status is around 40 %, while only 38 % of surface waters are in good chemical status.
These figures seem too optimistic, as they are based on only a single, or even none biological quality element.
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Please clarify/indicate if the percentage refers both to natural WBs and HMWBs and AWBs.
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We wonder if the same waterbodies are included for those with ’good status’. I.e. if a waterbody fails good chemical status, can it still pass ecological status, and vice versa? What is the correlation between failure of good ecological and good chemical status? We believe it would be interesting to check on the correlation between the two, as well as to know for the ecological status those water bodies that passed all RBSP, but failed on biology.
We also wonder whether the precision of these data really facilitate differentiation of these values: around 40% as compared to 38%. There are inevitably errors associated with measuring, reporting and modelling data. A welcome addition to this report throughout, and an anchor back in reality, would be an acknowledgement of these uncertainties. Without, decision makers are left wondering if the percentage differences are significant, and if so by how much. “Confidence” in the report is not related to quantitative confidence. Perhaps a statement in Section 1.3 in this regard. For example, Figures 4.4 and 4.5, error bars here would be most helpful, are these changes significant at any level? It is at the moment difficult to interpret the multiple figures and graphs throughout the report without the appropriate context in regard to how important the changes reported might be, beyond qualitative indications.
- Compared to the first RBMP, this results in a marginal improvement in the overall quality status because if one of the elements fails, the entire water body quality fails (one-out-all-out rule). The same rule applies to chemical status: if one priority substance poses a risk, the chemical status is identified as bad.
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The criteria to evaluate the chemical status should be reviewed and modified. Because, if a single parameter is out of range, the whole water body is qualified as bad chemical status.
Then the global picture is worst than the real one and most of the improvements are hidden.
While, in fact, it is possible that other parameters improved in the period.
So a finer tune methodology is needed to better show improvements and to better evaluate the situation in Europe. -
We suggest to delete this sentence.
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It is suggested to be changed into
Compared to the first RBMP, this results in a marginal improvement in the overall quality status because if one of the elements fails, the entire water body status
qualityfails (one-out-all-out rule). -
(AT) The last sentence should be deleted because it is not particular for chemical status. Anyhow, don’t mix ’risk’ with ’status’ and ’bad’ is not a WFD term.
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It is important to emphasise that the water body is considered healthily only if all elements are in good status. Report now gives an impression that ‘one-out-all-out’ principle should be challenged and it is because of this principle that state of waters is less than good. Although the real reasons are elsewhere (eg ineffective management measures).
- In most Member States, a few priority substances account for much of the poor chemical status. Improvements for individual substances show that Member States are making progress in tackling sources of contamination. The substance most commonly causing failure in good chemical status is mercury. If mercury and other ubiquitous priority substances are not considered, only 3 % of surface water bodies would fail to achieve good chemical status.
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BE-FLA (KB): p. 4, .7 Key messages. In most Member States, a few priority substances account for much of the poor chemical status. Improvements for individual substances show that Member States are making progress in tackling sources of contamination. The substance most commonly causing failure in good chemical status is mercury. If mercury and other ubiquitous priority substances are not considered, only 3 % of surface water bodies would fail to achieve good chemical status.
Only a few member states applied an extrapolation of Hg exceedings in biota, as a means to explain the bad chemical state. Omitting this extrapolation, however, does not mean other chemical substances do not cause any problem. A reliable assessment requires to consider the monitoring program of other substances. When filling in the table on ‘Chemical monitoring’, substances had to be reported for each surveillance monitoring station. Therefore, conclusions should be restricted to that set of monitoring stations.
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(AT) In the 1. sentence: ’for much of the poor status’ does not sound very English.
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We recognize that Mercury causes a lot of waters to fail. A potential challenge highlighted by this bullet seems to be the need to assess small changes in status from other pressures beyond mercury and other persistent historic chemicals. How in the future does the EEA see tackling this in order to identify the relative small scale chemical pressures?
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It says here that "only 3 % of surface water bodies would fail" but in chapter 6; key messages, it says 4 %. Which one should it be?
- Since the previous RBMPs were published, our knowledge of Europe's waters has grown significantly, providing a better understanding of the status, the pressures causing failure to achieve good status, and the measures implemented to generate improvement.
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It should be noted that there is no real European benchmark on the implementation of the directive while there is a need to be able to compare the effectiveness of national water management methods country by country. As the Directive is to be implemented in the same way in each EU Member State, the data should be comparable and assessable.
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What could be mentioned here or in the text below that this is the result of the WFD; eg that WFD brought about a significant shift in how RBAs comply with the EU water requirements, availability of information for public, understanding of status and pressures as well as measures to achieve improvement
Background
The main aim of the European Union’s (EU) water policy is to ensure that a sufficient quantity of good quality water is available for people's needs and for the environment. Since the first water directives in the 1970s the EU has worked to create an effective and coherent water policy. The Water Framework Directive (WFD), which came into force in 2000, establishes a framework for the assessment, management, protection and improvement of the quality of water resources across the EU.
Since December 2015, EU Member States have been publishing the second River Basin Management Plans (RBMPs) for achieving the environmental objectives of the WFD. They are an update of the first RBMPs that were published in 2009. In summer 2017, 25 Member States had reported into Water Information System for Europe (WISE). The WISE-WFD database includes data from the first and second RBMPs. In 2018, the European Commission will publish its report on the assessment of the second RBMPs and will start the process of evaluating the Water Framework Directive[1]. To accompany and inform this process, the EEA has produced this report on the 'State of Europe's water' along with presentation of more detailed WFD results in WISE.
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BE-FLA (RV): p. 4, §3 Production SOW report
Please add that chapters 1-5 are completely based on the WFD RBMPs and not on other data bases or information sources. Chapter 6 provides additional information obtained from other EU directives reportings, EEA data sets, Eurostat etc.
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it is suggested to be changed into
........The Water Framework Directive (WFD), which came into force in 2000, establishes a framework for the assessment, management, protection and improvement of the status quality of water resources across the EU.
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it is suggested that the below sentence be clarified -it is about reviewing process of WFD?
In 2018, the European Commission will publish its report on the assessment of the second RBMPs and will start the process of evaluating the Water Framework Directive
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(AT) First sentence:
Since December 2015, EU Member States have been publishing the second River Basin Management Plans (RBMPs) for achieving about the achievment of the environmental objectives of the WFD.
Improvements in monitoring and assessment
The results show that with the second RBMPs the quantity and quality of available evidence on status and pressures has grown significantly. Many Member States and River Basin Districts have invested in better or new ecological and chemical monitoring programs with more monitoring sites, more quality elements and more chemicals. Surface waters and groundwater have been monitored at over 130 000 monitoring sites over the past six years. Many more assessment methods for different quality elements have also been developed and intercalibrated[2]. This has resulted in a marked reduction of water bodies with unknown status and a clearly improved confidence in status assessment in the second RBMPs, as well as a better understanding of the status ecological, chemical and quantitative status, the pressures causing failure to achieve good status, and the needed measures.
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..."well as a better understanding of the status ecological, chemical and quantitative status,..." Please delete the first "status" (it is double)
Ecological status of surface waters
Ecological status is an assessment of the quality of the structure and functioning of surface water ecosystems, including rivers, lakes, transitional and coastal waters. It shows the influence of both pollution and habitat degradation. Ecological status is based on biological quality elements, and supporting physico-chemical and hydromorphological quality elements.
During the first RBMP cycle (2009-2015), Member States have introduced better or new ecological monitoring programs with more sites and more quality elements. Many new assessment methods for biological quality elements have been developed. Overall, this has reduced the proportion of water bodies in unknown ecological status from 16 % to 4 %, and has improved the proportion of water bodies classified with high or medium confidence from one third in the first RBMPs to more than half in the second RBMPs. Higher confidence is also ensured through intercalibration of good ecological status. Since 2008, the number of intercalibrated biological assessment methods has generally increased three-fold for rivers, lakes and coastal waters making results much more comparable than for the first RBMP.
In the second RBMPs more than two thirds of all water bodies are classified with at least one biological quality element. For most of the remaining water bodies status assessment is based on supporting physico-chemical and hydromorphological quality element. All in all, these improvements mean that the ecological status classification results are now a better interpretation of the general health of the water environment.
Overall, 40 % of the surface water bodies have good or high ecological status, with lakes and coastal water bodies having better status (ca. 50%) than rivers and transitional waters bodies (ca. 30-35%). The northern countries show a high proportion of water bodies in high or good ecological status. In contrast, the central European river basin districts, as well as some of the southern RBDs show the highest proportion of water bodies not achieving good ecological status or potential. There is improvement in the ecological status of some of the biological quality elements, while the overall ecological status has not improved since the first RBMPs.
For surface water bodies, the main significant pressures are hydromorphological pressures (41 %), atmospheric deposition (40 %) and diffuse source pollution (37 %), followed by point source pollution (18 %) and water abstraction (7 %). The main impacts on surface water bodies are nutrient enrichment, chemical pollution and altered habitats due to morphological changes.
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If ecological potential is covered by this chapter, it would be helpful to clearly indicate this in the title of the chapter and in the text.
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We are not sure if we should consider status assessments which are based on only one BQE as a real improvement.
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BE-FLA (VVDL): p. 5, §5 Ecological status SW: in the second RBMPs more than two thirds of all water bodies are classified with at least one biological quality element
Ecological status is the combination of all biological quality elements and requires the evaluation of more than ‘at least 1’ biological quality element. § needs to be completed with the share of water bodies for which at least (f.e.) 4 or all relevant quality elements were assessed.
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BE-FLA (RV): p. 5, §6 Significant pressures
Share of point sources pressures is only 18% and much lower than atmospheric deposition (40%) and diffuse pollution (37%). Needs to be explained. There are serious doubt about the basis of these figures. Tick boxes will reveal the frequency/occurrence of (significant) pressures, which is different from a quantification of pressures.
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It is essential to understand that the term "pressure" is not necessarily synonymous to “degradation”. The example of the large reservoirs of France today constitutes places of high biodiversity value, associated with a good chemical quality of water. The same is true for rehabilitated gravel pits along the major stream beds that are now recognized as an integral part of the landscape and regional biodiversity.
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In chapter 6 Key messages:
"Diffuse sources (62 %) and hydromorphological pressures (40 %) are the main significant pressures on surface water bodies, followed by point sources (21 %) and abstraction (7 %)."Which percentages are OK?
Here, hydromorphological pressures are the most significant pressure and in the other hand, in chapter 6, most significant pressure is diffuse source pollution. This need some clarification.
Maybe other order:
altered habitats, chemical pollution and nutrient enrichmentBecause hymo-pressures 41%, atmos.depos. 40% and diffuse sourse and point source 37% and 18%
Or if the significant pressure list is more like stated in chapter 6 Key messages, then the order should follow that list.
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Page 5 – it mentions water abstraction 7% yet in the narrative we said 6% - difficult to tell if its completely the same context, guess the document is referring to 7% of all WBs for member states?
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- Second paragraph seems to suggest that all MS have improved their monitoring programmes; we question the accuracy of this assessment. For example in ES no advancement has taken place regarding the monitoring programs. Moreover, most of the 2nd RBMPs argued that due to the economic crisis suffered in ES in the last few years monitoring programs were stopped or not fully operational, resulting in assessment of the WBs status refering to data from 2009-2010 for the mot part. Most updated data is from 2014 and for only some groundwater bodies and not in all river basins.
- Third paragraph: However, it should be emphasised that methods used by MS rarely respond very specifically to hydromorphological pressures or that hymo parameters are not even attempted to be measured. To be sure that hydromorphological pressures and their effects do not remain undetected, it is therefore very important to measure hymo parameters and use hymo classification methods alongside the BQEs.
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"Two thirds of WB are classified with...": this proportion is weak. It raises the question of robustness of data and their comparability. An explanation/comment would be useful here.
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"Atmospheric deposition (40%)": The figure is surprisingly high for atmospheric deposition. Can you detail more precisely how it was obtained and analyse further how the MS have interpreted such a pressure? (In France we did not identify such a high pressure).
Chemical status of surface waters
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).
Compared to the previous assessment results in first RBMPs there have been marked improvements in the monitoring and classification of chemical status with a clear reduction in water bodies in unknown chemical status.
The percentage of surface water bodies in good chemical status within the EU is 38 %, while 46 % are not achieving good chemical status and 16 % of the water bodies have unknown chemical status.
In many Member States, relatively few substances are responsible for failure to achieve good chemical status. Mercury causes failure in a high number of water bodies. Omitting widespread pollution by ubiquitous priority substances including mercury, the proportion in good chemical status improves to 81 % of all water bodies, and 3 % do not achieve good chemical status and 16 % have unknown chemical status. The main pressures leading to failure of good chemical status are atmospheric deposition and discharges from urban waste water treatment plants.
Since the first RBMPs were published, Member States have made progress in tackling priority substances, significantly reducing the number of water bodies failing standards for substances such as several priority heavy metals (cadmium, lead, and nickel) and pesticides.
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"The percentage of surface water bodies in good chemical status..." in order to avoid any confusion, it would be helpful to indicate if the EQS set in directive 2008/105/EC or those set in directive 2013/39/UE have been used.
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BE-FLA (RV): p. 6, §5 Progress priority substances
Quantify progress, please.
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Very last sentence: How is the result obtained, especially for pesticides ?
Chemical and quantitative status of groundwater
The WFD requires Member States to designate separate groundwater bodies and ensure that each one achieves “good chemical and quantitative status”. To meet the aim of good chemical status, hazardous substances should be prevented from entry into groundwater and the entry of all other pollutants (e.g. nitrate) should be limited to prevent pollution.
Good quantitative status is to be achieved by ensuring that the available groundwater resource is not reduced by the long-term annual average rate of abstraction. In addition, impacts on surface water linked with groundwater or groundwater dependent terrestrial ecosystems as well as saline intrusions should be avoided.
Knowledge and information on assessing groundwater status have increased over the first RBMP cycle with the proportion with unknown chemical status and quantitative status decreasing to low levels of 1 %, respectively.
In the EU, 74 % and 89 % of the area of groundwater bodies is in good chemical and quantitative status, respectively. Since the first RBMPs were published, there has been small improvement in groundwater chemical and quantitative status.
Agriculture is the main driver causing failure of good chemical status to EU groundwater, causing diffuse pollution by nitrates and pesticides. Other significant sources are discharges not connected to a sewerage system and contaminated sites or abandoned industrial sites. Nitrate is the main pollutant affecting over 18 % of the area of groundwater bodies. In total 160 pollutants caused failure to achieve good chemical status. Most pollutants were reported in few Member States and only 15 pollutants were reported by five or more Member States.
Water abstraction for public water supply, agriculture and industry is the main significant pressure causing failure of good quantitative status.
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BE-FLA (WV): p. 6, §9 In the EU, 74 % and 89 % of the area of groundwater bodies is in good chemical and quantitative status, respectively. Since the first RBMPs were published, there has been small improvement in groundwater chemical and quantitative status.
% mentioned is “by area”, important to remark that.
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BE-FLA (RV): p. 6, §10 Agriculture
Agriculture is the main pressure
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(AT) 2nd sentence: Good quantitative status is to be achieved by ensuring that the available groundwater resource is not reduced exceeded by the long-term....
In addition, impacts on surface water linked with groundwater or groundwater dependent terrestrial ecosystems as well as saline intrusions should be avoided. This sentence needs rewording. Please check with the provisions in WFD Annex V.
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"To meet the aim of good chemical status, hazardous substances should be prevented from entry into groundwater and the entry of all other pollutants (e.g. nitrate) should be limited to prevent pollution."
The criteria for assessing good chemical status of groundwater is defined in article 3 in the groundwater directive (2006/118/EC). This sentance is referring to article 6 of the GWD and it´s aim is to prevent and limit the inputs of pollutants into groundwater.
Overall status and overall progress since the first RBMPs
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.
- First, additional biological and chemical monitoring was put in place after 2009 and the classification methods were improved and in some cases the standards were tightened.
- Second, for some water bodies some quality elements have improved in status, but there has been no improvement in the overall status.
- Third, the second RBMPs generally show status classification up to 2012/13 and at that time, many measures were only in the process of being implemented and there may be a lag time before the pressures are reduced and there are improvements in status.
- Finally, some pressures may have been unknown in 2009; and the measures implemented may not have been sufficient and as effective as expected at reducing all the pressures.
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"....if ubiquitous substances, especially mercury, is discounted " Please replace "is" by "are".
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"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.
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"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...
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"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."
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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).
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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
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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.
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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.
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Concerning the overall status , it would be helpful to explain this concept as the WFD does not provide it
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(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
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"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.
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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...”.
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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.
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"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.
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"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.
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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.
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- Third paragraph: It would be useful to outline whether the chemical status monitoring is adequate enough across all the EU MS to make such a statement without any doubt or whether there is uncertainty or low confidence in the data submitted. Reading the text further down doesn’t suggest that the chemical status is as good as presented with this statement. Please reflect this also in the summary box.
- Paragraph four: We believe this is a limited set of reasons that needs to be complemented with others to give a more adequate picture of the situation in the EU. The most important elements that are missing are the following: - RBMPs/PoM were not ambitious enough and the necessary measures to achieve the WFD good status/potential objectives or prevent deterioration have not been taken; - Lack of regulatory measures and overreliance on voluntary measure for main pressures; - Overuse and misuse of exemptions (for postponement of deadlines, but also Art 4.7 ones); furthermore in the case of the latter it should also be mentioned that deterioration is not picked up, which allows projects with negative impacts for water status to be implemented. It could also be useful to add the number of exemptions applied to demonstrate the problem. These aspects should also be reflected in the summary box.
- Paragraph four, point two: However, it is important to point out that the water body is considered healthily only if all elements are in good status. We would not want the report giving an impression that ‘one-out-all-out’ principle should be challenged.
Pressures causing failure to achieve good status
The results from the second RBMPs show that European waters remain under multiple pressures from water pollution, over-abstraction and structural change from different human activities. These pressures affect the good functioning of water-related ecosystems, contribute to biodiversity loss, and threaten the long-term delivery of ecosystem services and benefits to society and the economy. To ensure sustainable management of water resources, better policy implementation will be needed to improve the coherence between economic, societal and environmental goals.
There are ample possibilities for improving water management to achieve the objectives of the WFD, through stringent and well‑integrated implementation of existing legislation and introducing supplementary measures that reduce the pressures causing failure to achieve good status. In the following paragraphs, the challenges in water management and the measures needed to progress towards good status are summarized.
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We agree that “better policy implementation will be needed to improve the coherence between economic, societal and environmental goals”. However, we disagree that policy integration can be one-directional only, i. e. the requirements of water policy to be integrated into other sector-policies. For coherence of policies also the goals of other sector policies need to be integrated into water policy. This is essential to inform the designation of HMWBs and the use of exemptions like Art 4.7.
Pollution and water quality
A range of pollutants in many of Europe's waters threaten aquatic ecosystems and may raise concerns for public health. Reducing pollution to meet the objectives of the WFD requires that several other directives and regulations are implemented.
Over the past few decades, clear progress has been made in reducing emissions from point sources. Implementation of the Urban Waste Water Treatment Directive (UWWTD), together with national legislation, has led to improvements in waste water treatment across much of the European continent. These positive trends reflect increased connections to sewers, improvements in waste water treatment and reducing some substances at the source.
Agricultural production is a major source of diffuse pollution, mostly associated with excessive emissions of nutrients and chemicals such as pesticides. Further drivers include rural dwellings, run-off from urban areas, and forestry. EU action on curbing diffuse nutrient pollution has a long history. A large number of measures are currently used by Member States, including farm-level nutrient planning, fertiliser standards, appropriate tillage, nitrogen-fixing and catch crops, buffer strips, and crop rotation. During the last decades, mineral fertilizer uses and nutrient surpluses of agricultural origin have progressively decreased in the EU and the average nitrate concentration declined by 20 % in European rivers between 1992 and 2012, while groundwater nitrate concentrations in 2011 had almost returned to the 1992 level.
Contamination caused by hazardous substances is a major environmental concern in European waters and consequently is addressed by a number of EU legislative measures and policies. Reducing hazardous substances in water requires strong implementation of the current legislation, but also the adoption of more sustainable production and use of chemicals, both in Europe and beyond.
Improved efforts to retain these chemicals in waste water treatment plants with better waste water treatment should go hand in hand with clear efforts to reduce them at source, by raising consumer awareness and adjusting consumption as well as longer term initiatives, such as those towards a non-toxic environment and a circular economy.
Although considerable success has been achieved in reducing the discharge of pollutants into Europe's waters in recent decades, challenges remain for urban and industrial waste water and pollution from agricultural sources. The implementation of existing EU water emission legislation, including the UWWT, Nitrates and EQS directives in all Member States, will improve the quality of water. Waste water treatment must continue to play a critical role in the protection of Europe's surface waters, and investment will be required to upgrade waste water treatment and to maintain infrastructure in many European countries. In some regions, diffuse pollution from agriculture in particular remains a major cause of the poor water quality and measures to tackle agricultural pollutants may be required.
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BE-FLA (RV): p. 8, §2 Progress emission reductions
Quantify or show this progress
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BE-FLA (RV): p. 8, §6 Reduction of pollutant discharges
Quantify or show this reduction
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(AT) 3rd paragraph: the last half sentence needs explanation: ...while groundwater nitrate concentrations in 2011 had almost returned to the 1992 level.
Was there an increase or decrease? – are data at European level comparable or only representing few countries/GWBs? Is this (few mg/l) a significant change of concentrations?
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BE-WAL (EC): p. 8 §3
1) Add: emissions from households not connected to sewage (cfr p61 for better understanding)
2) Explain why “forestry” can be a source of pollution: cfr p76
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Slovakia: Page 8, 2nd paragraph: Add “..in urban waste water treatment..”.
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Slovakia: Page 8, 6th paragraph: Pesticide directive (2009/128/EC), old Integrated Pollution Prevention Directive (2008/1/EC) and new Industrial Emission Directive (2010/75/EU) could be mentioned in this paragraph too.
Hydromorphological pressures
For decades, humans have altered European surface waters (straightening and channelization, disconnection of flood plains, land reclamation, dams, weirs, bank reinforcements, etc.) to facilitate agriculture, produce energy and protect against flooding. These activities have resulted in damage to the morphology and hydrology of the water bodies.
In the second RBMPs, hydromorphological pressures are the most commonly occurring pressures on surface water bodies affecting 41 % of all surface water bodies. In addition, 17 % of European water bodies have been designated as heavily modified (13 %) or artificial water bodies (4 %).
The WFD requires action in those cases where the hydromorphological pressures affect the ecological status, interfering with the ability to achieve the WFD objectives. If the morphology is degraded or the water flow is markedly changed, a water body with good water quality will not achieve its full potential as aquatic ecosystems.
The restoration of hydromorphological conditions includes:
- measures related to river continuity with removal of obstacles and the installation of fish passes;
- measures focused on restoration of aquatic habitats, such as improving physical habitats;
sediment management that ensures sediment transport along the length of the river; - reconnecting backwaters and wetlands to restore lateral connectivity between the main river channel, the riparian area and the wider floodplain;
- natural water retention measures that restore natural water storage, for example by inundating flood plains and constructing retention basins;
- restoring the natural water flow regime such as setting minimum flow and ecological flow requirements [4]; and
developing master plans or conservation plans for restoring the population of threatened fish species.
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"...a water body with good water quality will not achieve its full potential as aquatic ecosystems" A part of the sentence seems to be missing here.
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In reference to "These activities have resulted in damage to the morphology and hydrology of the water bodies": In the European Union, a vast majority of aggregates extraction sites are dealing with inert materials such as sand, gravel and crushed rock, and produce inert wastes according to EU definitions and criteria included in EU Directives. The industry’s production process and treatment plants do not include the use of chemicals, as in most of the cases the processes are based on mechanical crushing, milling, grinding, and size grading. The Aggregates Industry does not represent a threat for water quality. Moreover, in the aggregates industry, it is possible to create wetlands during and after the extraction phase, according with the permit granted by the administration (including environment and water management authorities, and in many cases under the EIA scheme). Most of those new wetlands or lakes are designed according to suitable hydromorphological parameters, to achieve a new (artificial) water body that is able to grant water quality parameters and biodiversity requirements for their life time. Some of them have flood protection designs or even good quality water supply to urban areas for human consumption. Recent studies from different countries (Denmark, Austria, France, UK, Germany, Spain) are demonstrating that water quality is by far better in these artificial wetlands linked to quarries and sand and gravel pits extaction sites, compared to natural lakes. The rise of biodiversity is, again, a living proof of that. These facts have received recognition by the European Commission, research institutions, and a number of environmental NGOs.
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The aim of the WFD is to meet a Good Environmental Status (GES). Hydromorphology shall be the kind, that GES is possibly to meet. Hydrology or morphology has no individual role in classification, though. Proposal: "Altered hydrology and morphology caused by these activities have affected the ecology of water bodies."
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For a GES of the WFD it is not required to achieve a full potential as an aquatic ecosystem, but hydromorphology to be consistent with the achievement of values of biological quality elements. This sentence aims at nature conservation. The same approach can be seen in other parts of documents, too. Proposal: " ...with good water quality could fail to achieve good ecological status" (potential can be met, because it shall be defined by considering mitigation measures which do not have significant adverse effect on a specific use)
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Restoration refers to aiming at original conditions. Proposal: "The hydromorphological mitigation measures can include"
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(AT) 3rd paragraph:
It is not clear what is meant with this sentence. Is this a reference to HMWB?
It is necessary to better explain the concept of HMWB in the text and to make references to good potential in the tables and graphs! The report is only mentioning status classes and ignores the category of HMWB/AWB
Implementation of measures
To meet the objective of good status, the WFD requires an assessment of all the pressures in a river basin, and the development of a Programme of Measures (PoMs) to tackle them. The first RBMPs contained a large number of diverse measures. By now, many of the several thousand individual measures in the first RBMPs will have been completed. However, some measures have been delayed or even not started mainly due to funding constraints, while other measures have been difficult to implement.
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BE-FLA (RV): p. 9, §3 Measures completed
Having read the report, this leads to the conclusion that, after completion of numerous measures, little has changed (cf. p. 21: limited improvement of ecological status) and it is still waiting for the effects.
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With regard to the implementation/funding of measures it should be mentioned that Member States should aim for cost-efficient measures and that Member States can justify exemptions in case of disproportionate costs.
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For a reader it will not be clear if ‘several thousands’ is a lot or actually not even enough. It gives an impression that MS have planned all the necessary measures, which is not the case.
Referring also to the sentence that follows, many times measures that have been planned are not adequate or appropriate for the pressure they are targeting. It is also not clear what is meant by ‘difficult to implement’; often it is due to lack of political will, which either leads to not adequate measures planned, or them being delayed (due to use of exemptions) or simply not implemented, or them not being funded.
Integrated water management
Sustainable and integrated water management plays a substantial role in the UN 2030 Agenda for Sustainable Development, the EU 7th Environment Action Programme (7th EAP), and the achievement of the EU’s Biodiversity Strategy. Three areas are offering substantial opportunities to improve implementation and support to the achievement of WFD objectives and they are highlighted below.
Protection of Europe's aquatic ecosystems and their services
Concern has grown over the past decades about the rate at which biodiversity is declining and its consequences for the functioning of ecosystems and the services they provide. Many opportunities exist for improving implementation and maximizing synergies between environmental policies relevant for the protection of the water environment. In particular, EU policies on water and the marine environment, nature and biodiversity are closely linked, and together they form the backbone of environmental protection of Europe's ecosystems and their services.
The use of management concepts such as the ecosystem services approach and ecosystem based management can offer ways to improve coordination by setting a more common language and framework to evaluate trade-offs between the multiple benefits that healthy water bodies offer.
Restoring degraded water ecosystems
Nowadays, water management increasingly includes ecological concerns, working with natural processes. This is in line with the objective of the 7th EAP 'to protect, conserve and enhance the Union's natural capital'. It is also consistent with Target 2 of the EU's Biodiversity Strategy that aims to ensure maintenance of ecosystems and their services by establishing green infrastructure and restoring at least 15 % of degraded ecosystems by 2020.
Restoring aquatic ecosystems such as 'making room for the river', river restoration or floodplain rehabilitation, 'coastal zone restoration projects' and integrated coastal zone management has multiple benefits for the water ecosystems. Synergies between policies can be important in restoring aquatic ecosystems.
Integration of water aspects into sector policies
From the assessment of status, and in particular from the assessment of pressures and impacts, it is evident that the driving forces behind achievement or non-achievement of good status are activities in sectoral areas like agriculture, energy or transport. This integration throughout the river basin is enhanced, for example, by better cooperation between competent authorities, better involvement of stakeholders and early participation of the public.
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"Synergies between policies can be important in restoring aquatic ecosystems."
... but different legal obligations may end in different requirements regarding restoration a/o modification.
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"Integration of water aspects into sector policies":
Early involvement of all concerned stakeholders, definition of precise measures incl. implementation obligations (and incl. financial support)
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SK: Page 10, last paragraph: Industry should be also mentioned as a driving force in a sectoral areas.
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- 'Integrated water management' section: It would be good to emphasise the importance of full implementation of the WFD for the EU to be able to comply with its international commitments, including the SDGs but also Paris Agreement. Without it, it will not be possible for the EU to reach the SDGs (and not only the SDG6). This is the other way around as is suggested in the sentence that follows.
- 'Protection of Europe's aquatic ecosystems and their services' section, sentence 'management concepts such as the ecosystem services approach and ecosystem based management': which is promoted by the WFD.
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"...aims to ensure maintenance of ecosystems and their services by establishing green infrastructure and restoring...": This message is very apreciated, putting the water policy into perspective in the biodiversity policy.
[1] https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2017-5128184_en
[2] EC 2008: Water Note 7: Intercalibration: A common scale for Europe's waters http://ec.europa.eu/environment/water/participation/pdf/waternotes/water_note7_intercalibration.pdf
[3] Surface water ecological and chemical status; and groundwater chemical and quantitative status.
[4] CIS guidance no. 31: Ecological flows in the implementation of the Water Framework Directive. http://ec.europa.eu/environment/water/water-framework/facts_figures/guidance_docs_en.htm