Please add your general comments to the draft report here
I like the general layout. However, one of my main worries is the uncertainty associated with these assessments. This issue is tackled in the Methods section and anecdotally in different sections, however, given the seriousness of this topic on interpretation and extrapolation it might be appropriate to include a separate section towards the end on how to better understand and improve our measures and their uncertainties.
During the 3rd Advisory Board and Eionet meeting we discussed ecological status classification and biodiversity. As I mentioned, with primary producers we often see an increase in taxon richness with slight increases in nutrients. It would be interesting to compare beta diversity of Habitat sites and WFD sites (although, as I usually remind my "drier" colleagues, all water bodies are encompassed of the WFD!
I also thought of a Danish study that found a good relationship between their benthic invertebrate index (Danish Fauna Index) and Red Listed taxa.
During the meeting, we discussed uncertainty and expert judgment. From one of the participants I got the impression that experts were generally good at assessing quality with little or no quantitative data. This might be true, but the paper by Stoddard et al. (2006) showed that experts were not very good at selecting reference sites (see e.g. Fig 3 in Stoddard et al.)
As it was presented during the EIONET metting in Copenhagen (March) I would like to remain my proposal of adding an additional paragraph or a new section to present the scene of WFD water status assessment. It is very important to anyone reding the Report to fully understand that the picture of pan-european assessment of ecological statut is not as much comparative and coherent as it can be seen at first sight from the maps and graphs. In my opinion it should be clearly explain that the assessment system created by the directive as being based on ecosystem approach has a strong scientifical justification but as a administrative tool cannot be completed as soon and easily as it was planned. So the data presented in the Report are as much comparable as it was possible and the picture of water status is the best picture we could prepare in this particular moment of WFD implementation. But it doesn't meany that GES and GEP are exactly the same in different countries.
According to the deadline, it is impossible to check all the figures presented in the different tables but those that have been studied are correct. Nevertheless, we have two general comments :
- the water bodies in overseas territories (RBD FRJ-Martinique, FRL-Réunion, FRK-Guyane and FRI-Guadeloupe) are taken into account most of the time but sometimes not, for example, and it is normal, when the results are presented by marine region for coastal and transition water bodies. Perhaps it should be added as a note when the overseas water bodies are counted. There are 1086 surface water bodies and 40 groundwater bodies in French overseas territories;
- the percentages are calculated against the total number of classified water bodies. For France, it may have an impact since 34.1% of surface water bodies are in unknown chemical status and 2.2% for ecological status.
Major comments
Finland has reported comprehensively pressures to our coastal waters. The general interpretation is that Finnish coastal waters commonly receive loading from diffuse sources, especially from agriculture. If country-wise information in HELCOM's latest Pollution Load Compilation (HELCOM 2011) is compared, the conclusion is that nutrient loading (total or area specific) from Finland is generally not higher compared to many other countries (e.g. Sweden) around the Baltic Sea.
Certain Tables and Figures in the report (based on WISE-WFD data) will give a biased overview of pollution pressures of the Finnish coastal water bodies. The major concern is Figure 5.4: Even if it seems to be technically correctly produced and based on the reported data, it may give falsified general view of the pressures compared to other coastal areas of the Baltic Sea. The reasoning is based on two facts: A) countries have (e.g. in the Baltic Sea area) used different criteria in defining pressures, and B) countries have shortcomings in reporting the pressures. Now the reader cannot be sure, if the low number of affected water bodies in certain countries is due to shortcomings in reporting, or due to actual low pressure to coastal waters.
Our concerns have been also noted by the authors of the report: "In coastal waters more than 40% of the classified water bodies are reported to be affected by nutrient enrichment, which is twice as much as the proportion exposed to diffuse pollution. The reasons for this discrepancy is unclear, but may be related to reporting mistakes or other unidentified pressures."
We strongly encourage the authors to consider the following options: A) Remove the Figure 5.4. from the report, or B) Include only those countries which have comprehensively reported pressures. It should be also more clearly stated in the report how complete is the reporting by the different countries.
Another concern is the Figure 5.2. The classification is based on the number of water bodies. The result would be different if the classification had been based on areal basis instead of the number of water bodies (please see the attached file with Annexes 1a and 1b). Therefore we would like to include figures of ecological classification based on both the number of water bodies and the areal coverage.
References
HELCOM, 2011. The Fifth Baltic Sea Pollution Load Compilation (PLC-5) Balt. Sea Environ. Proc. No. 128.
I am aware that one of the principle objectives of the report is to give an overview and to synthesise the RBMPs in relation with the implementation of the WFD. Nevertheless, due attention should also be given to those EEA member states which are not part of the EU. Switzerland is a full member of the EEA and as such participates in the WISE SoE data reporting, with data which is mostly comparable in the field of chemical (and partly also) hazardous substances. It cannot be that in the EUropean maps showing chemical status of rivers, lakes and groundwater, there is a white gap for Switzerland. See specific comments in the respective chapters.