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This analysis contrasts with the results of status assessment of the 2nd River Basin Management plan 2016 under the WFD, which show 0.5% of all surface water bodies failing good chemical status because of pesticides, and 15% of groundwater bodies (EEA 2018).
The report also lists a number of other data sources for pesticides, especially scientific research and emissons data. They are diverse and often have limited spatial coverage, which make such data less representative for a European status assessment.
The aim of this work is to provide a baseline for what we know of measured concentrations of pesticides in water at the European level.
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Perhaps explain the reason for this discrepany in paragraph 1
(Austria) If not anyhow foreseen, please provide a list of abbreviations.
Did the 2018 report use national EQS or the lowest available EQS to calculate chemical status?
In general, initiatives/actions of industry (e.g. product stewardship programs, e.g. for S-metolachlor, bentazone, chlorpyrifos) to farmer and advisory services, TOPPS Prowadis, Round Table Initiatives in DE and AT) to reduce/avoid entries of PPP in surface and groundwater are not mentioned
in this report.
There are numerous recommendations to improve water monitoring – generally considering the need for intensification, diversification and implementation of strategies for improving focus of monitoring, we note that these recommendations are more easily made and less easily resourced…
In our view improvements in monitoring focussing simply upon expansion of surveillance in the diverse databases discussed in the report without ability to obtain further information to place detections or exceedances into context is not necessarily a meaningful advancement
To address this there should be a companion emphasis on greater transparency (besides the analytical strategy issues which are considered in the report we would add the need for more transparency on aspects such as sampling strategy, location and temporal context) so that follow up efforts may be supported to better understand and address detections/exceedances. This is a frequent limitation and does not get the attention that it deserves in this report
There is also discussion about adjustment of focus of monitoring to consider metabolites more frequently – we would again, return to the need for greater transparency regarding context as discussed above and, in particular, the need for coherence with monitoring of parent substance(s) noting that some common metabolites arise from diverse individual active substances. When focussing upon metabolites there is an even greater need for background context.
There is some discussion about management of chemicals through “measures” schemes designed to reduce or eliminate occurrences or detections. We recommend that blunt and simplistic index measures are avoided and suggest the promotion of greater need for intensive interpretation of high quality monitoring datasets focussing on better understanding the issues arising in individual catchment and how these may support or adjust action to be taken – at a minimum for validation purposes
There is some discussion of schemes like this – a supporting discussion on how monitoring was used to validate these schemes would have been an appropriate and helpful addition in the context of these discussions.
It is noted that there is need for a companion discussion on funding mechanisms to promote or implement these measures. This is a commonly encountered issue with risk management – any discussions on implementation of measures must factor in farmer motivation. This is often side-stepped but is, in fairness, noted very briefly in this report with suggestion that this could be addressed as a component of revision of CAP. Further national case studies showcasing successful farmer support frameworks for action could be presented to support further discussions.