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Please add your general comments to the draft report here
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Previous comments
The Netherlands appreciates the opportunity to comment on the draft EEA report. In general we welcome the report and took note that the EEA took on board our earlier comments as regards the ranking of Member States, based on datasets of different quality. To our opinion the EEA tried to present a detailed picture on the basis of which Member States can be compared and trends can be shown. The attempt to highlight improvements is welcomed, but should not be overdone and better balanced with other findings. Furthermore, we do not agree with presenting the ecological status of water bodies without assessment of any biological quality element. As far as we can check, the EEA did make use of the correct data reported by The Netherlands.
The German water authorities like to thank for the opportunity to comment on the draft EEA report. In principle we like to applaud the authors to the draft of the EEA report. The present draft of the report gives a very good overview about the status of european waters under the water framework directive. We checked the German data as far as possible and found no significant differences in the results. We conclude that the EEA did make use of the correct German data reported.
Some principle comments from Germany can be found in the following text.
BE-FLA (RV):
BE supports the comment made by NL: “To our opinion the EEA tried to present a detailed picture on the basis of which Member States can be compared and trends can be shown. The attempt to highlight improvements is welcomed, but should not be overdone and better balanced with other findings”. Furthermore, we do not agree with presenting the ecological status of water bodies without assessment of any biological quality element.
BE-FLA (RV):
The document is well structured and written in a comprehensive and clear way. Additional data and information provided through links to tables and figures is very appreciated as they disclose a high amount of reported data. The drawback of this, however, is the lack of a clear explanation of the methodology applied in terms of uncertainty, differences in methods, and data gaps.
EA: The report seems fine in its representation of measures although I think we have some great examples that might have been included in terms of action to restore flow or manage hydromorphology pressures. But that’s just omission rather than error and I am sure they will have had numerous examples to choose from.
The Union of the Electricity Industry - eurelectric is the sector association which represents the common interests of the electricity industry at pan-European level, plus its affiliates and associates on several other continents. We currently have over 34 full members, representing the electricity industry in 32 European countries. eurelectric has two dedicated working groups on the topics of environmental protection as well as on hydro. Our comments are based on the feedback of these working groups on the available EEA report.
We are really happy that we have the opportunity to provide feedback on the EEA report. We highly appreciate the work and effort done in this report, which is very interesting and useful. We welcome that the 5 parts on status and pressures are based on real data and reflect the report’s aim and title.
Unfortunately, the last part about progress achievement and future challenges is less well argued than the previous ones and not always supported by data. We have the feeling that some statements have been taken from previous reports without any respective data evidence. We have tried to highlight these problems in our following comments. It seems particularly important in the context of the upcoming evaluation of the WFD to aim for as much objectivity as possible.
Summary of our main findings:
Northern Ireland: As the assessment is at MS level we do not have any specific comments on the report for Northern Ireland. Our review of the data tables appears to be consistent with the data we reported. There does appear in some cases to be different approaches/inconsistency used in selecting categories across the UK and MS as a whole, which will make comparisons difficult in some cases. (eg hydromorphology categories). It would be helpful if definitions could be refined for future reporting to improve consistency.
Also I note that % good chemical status waterbodies are only reported as good where there is data. Given that monitoring is targeted using a risk based approach, we assume that no data is good. Hence NI % at high/good chemical status is reported as 95%; the EEA approach gives NI 51%, with 44% unknowns. This also makes comparison difficult.
Northern Ireland: As the assessment is at MS level we do not have any specific comments on the report for Northern Ireland. Our review of the data tables appears to be consistent with the data we reported. There does appear in some cases to be different approaches/inconsistency used in selecting categories across the UK and MS as a whole, which will make comparisons difficult in some cases. (eg hydromorphology categories). It would be helpful if definitions could be refined for future reporting to improve consistency.
Also I note that % good chemical status waterbodies are only reported as good where there is data. Given that monitoring is targeted using a risk based approach, we assume that no data is good. Hence NI % at high/good chemical status is reported as 95%; the EEA approach gives NI 51%, with 44% unknowns. This also makes comparison difficult.
SEPA: There doesn't appear to beany information for Surface water bodies significant pressures or significant pressures reported as other for the Scotland River Basin.
Environment Agency: I have checked the figures for all RBDs and there seems to be an issue with the Severn RBD figures shown in the majority of tables/graphs that I have checked(although not all figures). The figures shown are inconsistent with the figures reported as part the RBMP submission. It would be good to see the base data for the Severn figures. Just so that I can check in more detail.
Enviroment Agency: A more general observation is that there is more positivity in acknowledging the progress being made by MSs by looking at improvements at the element level and not just overall status- which is helpful.
Slovakia:
We consider the EEA State of Water Report 2018 as very good and desirable. The report is written in a clear and understandable manner. Authors have very well coped with presentation of amount of data and information collected in WISE SoW database as an outcome from RBMPs 2016 reporting. We appreciate very much that report provides also explanation of MSs’ specific situation, e.g. WBs status vs. mercury, monitoring programs and environmental quality standards. Explanations why some results can be/ cannot be compared between 1st and 2nd RBMPs cycle are very well in place. The added value of the report is mainly the WISE visualisation tool which is very much welcomed. It is comprehensible, well-structured and it would be beneficial also for data sharing among the countries.
The EEA State of Water Report 2018 summarizes the main results of the WBs status and pressures assessment. The report proves that the WFD is very important and effective tool to achieve the improvement of water status on national and international level and contribute also to the coherent policy in the water sector.
SEPA: For the tables 'Good ecological status expected achievement date', 'Surface water bodies: signifcant pressures' and 'Surface water bodies: Significant pressures reported as 'Other'. There is no drop down option for UK01 suggesting no data is available. Is this correct?
Belgian comments have been provided by several experts:
Contributors BE-FLA: Michel Boucneau, Katrien Bursens (KB), Veronique Van Den Langenbergh (VVDL), Rudy Vannevel (RV), Wendy Verlé (WV), Alistair Fronhoffs
Contact for BE-FLA: Rudy Vannevel - r.vannevel@vmm.be
Contributors for BE-WAL: Bénédicte Bastin, Catherine Généreux, Pierre-Nicolas Libert, Nicolas Fermin, Elisabeth Chouters
Contact for BE-WAL: Elisabeth Chouters - elisabeth.chouters@spw.wallonie.be
Belgian National Focal Point: nfp@irceline.be
Natural Resource Wales:Iit is difficult to keep track of the numbers and they seem to conflict in different places for the same thing which left me confused – e.g. I’ve noticed for surface waters chemical status in the report it quotes 38% and 41% compliance depending on which section of the report you look at. Then different % again seem to be in the tables pdf and graphs pdf. Section 6.1 seems to have different figures
Eurometaux would like to thank the EEA for this report - and its supporting figures and statistics - as well as for providing us with the possibility to comment on. Our comments are mainly focused on the metals’ EQS compliance assessment; however, please allow us to provide also some more general remarks together with specific comments on some paragraphs.
Regarding the EQS compliance assessment for the metals made in this report (both as PS and RBSP) Eurometaux wants to emphasise on the following points:
It is anticipated that the non-compliance rates of the metals mentioned in the present report will be significantly lower when the factors mentioned above are properly being taken into account.
As general remarks, please allow us to point out that:
Also, the report notes that in most Member States improvements for individual substances are made because sources of contamination are tackled. However, as the EEA report remarks, this is not reflected in the general evaluation of overall quality status under the WFD showing only marginal improvements. This discrepancy is largely because of the “one out all out” principle. Because of this principle, the conclusions reached on the water quality under the WFD do not reflect the real status of the water and in fact hide most of the improvements that are achieved by the Member States. As a result, the EU citizen gets the message that the state of the waters is poorer than it actually is. It is suggested that this issue, also of public communication, is considered in the ongoing evaluation of the WFD.
Sweden appreciates the opportunity to comment on the draft EEA report. Several experts have contributed to comment on the report (coordinated by Anneli Harlén and Klara Eklund, SwAM). The attempt to highlight improvements is welcomed, but should not be overdone. Some information is repeated several times in the report, i.e. information about ecological status and significant pressures. In executive summary text and key messages in chapter 2 - Ecological status and pressure text and key messages, in chapter 6-Overall status, progress and future and future challenges in text and key messages. The report would benefit from a layout that minimized the number of repetitions. If not, at least the numbers in the different places should be the same.
Unfortunately, data on groundwater volume are scarce, but it may be mentioned that presenting statistics based on groundwater area instead of volume is a simplifying adjustment.
Switzerland:
We thank you for the opportunity to comment on the draft.
However, we are surprised by the fact that the report only presents the WFD data of the EU member states. Initially, it was communicated that the report will include data of all Eionet member countries, and the priority Eionet data flows were adapted accordingly. We are completely aware of the methodological differences between Switzerland and the member countries implying the WFD. However, as a full Eionet member country, delivering our data to the EEA annually, we are expecting the inclusion of our data in the EEA reporting.
For this reason, we did not review the report und do not provide any further comments on it.
The Czech Republic welcomes the opportunity to comment on the draft EEA report. Most of the statistics and graphs are available in the "interactive tool in WISE" because the document itself is very comprehensive. This is basically a good solution. However, we have several comments on the graphical form and content of this tool.
The solution that each table or chart needs to be opened separately is uncomfortable (overall content map or list of links is not available) especially since the names of individual tables and charts are not unambiguous. The interactive form of graphs and tables could be valuable, but their control is rather difficult and it is often problematic to find out what the graph or table actually shows. Some of the displayed percentage data in tables is misleading as it always refers to a different base that is not often listed.
Example: table of CZ Surface water bodies: Quality elements status. For each of the biological components, the percentage is calculated from the water bodies being assessed, so that while for macrozoobentos (benthic invertebrates) the WB in status ranked as “moderate” is 283, which is 31%, for the fish components are in good condition 55 WB, which is 29% (if the percentage was calculated from ALL surface water bodies, it would be 25% and 5% respectively). However, the information that the percentage is calculated only from the water bodies being assessed by the EQ is missing.
The way in which individual charts and statistics are linked online with a database can be also problematic. This may significantly change the day-to-day outputs (depending on how the data is added to the database). Maybe it would be advisable to work with individual versions that would be guaranteed on a certain date.
Unlike the previous cycle, downloading the displayed data is bit complicated, and the downloaded text files have a slightly different structure each time, so any further use of the data is very difficult.
The visualization tool does not have any instructions or manual on how to use it.
Bulgaria:
In the process of the EEA’s draft report review few additional inaccuracies in the BG-WFD reporting data have been identified. The corrected data are already uploaded to WISE. Bulgaria undertakes a commitment for formal resubmission together with providing explanation and/or justification of the changes in the reported data.
Thank you for the opportunity to comment on the report “European waters – assessment of status and pressures 2018”.
General comments
Specific comments
The Frech comments are provided by several experts from EIONET + Statistic Service + Division for Water and Biodiversity (in wharge of the WFD), after harmonization.
France welcomes this useful , rich and interesting document, that adopts a positive formulation.
A summary with all key messages would add value, instead of multiplying the summaries - all the more so because sometimes there are discrepancies between these summaries
It is very meaningful to give results by area / km for rivers.
Please specify if the water bodies from overseas are taken into account. If yes, please insert them in adequate maps
(Note : Please harmonize the rules for rounding the figures in the Tables)