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Fig 1 Percentage of monitoring sites with threshold exceedances in surface waters and groundwater in Europe
a) Surface waters
b) Groundwater
Note:
The figures show the percentage of monitoring sites with exceedance of effect thresholds or quality standard, set by European or national regulatory standards, with a country weighting factor to reduce the impact of uneven data reporting:
∑ Percentage of monitoring sites with exceedances per country [%] x country area [km²]
∑ Area of countries with reported monitoring sites per year [km²]
For surface waters, European environmental quality standards and (in absence of those) national regulatory standards were used, reflecting the lowest ecotoxicologically-based effect threshold. Effect thresholds were identified for 114 out of 217 pesticides (53%). Exceedances included here refer to these 114 pesticides.
For groundwater, the Groundwater Directive quality standard of 0.1µg/l was used to identify exceedance. 12 non-relevant metabolites (nrM) were excluded from the assessment. Further information on methods of indicator development can be found in the supporting information for the indicator.
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Alternatively, the EQS exceedances can be calculated for each country with the respective national EQS value.
Further information is needed regarding the exclusion of non-relevant Metabolites from the assesment. These metabolites are a part of the CIS Voluntary Groundwater Watch List Process and they are not yet required by the Groundwater Directive.
For groundwater, the treshhold value of 0.1 µg/L was used to set an indicator value. Note however that in the BPR (Annex IV, Article 68) it is written that:
“The evaluating body shall conclude that the biocidal product does not comply with criterion (iv) under point (b) of Article 19(1) where, under the proposed conditions of use, the foreseeable concentration of the active substance or any other substance of concern, or of relevant metabolites or breakdown or reaction products in groundwater, exceeds the lower of the following concentrations:
— the maximum permissible concentration laid down by Directive 98/83/EC, or
— the maximum concentration as laid down following the procedure for approving the active substance under this Regulation, on the basis of appropriate data, in particular toxicological data,
unless it is scientifically demonstrated that under relevant field conditions the lower concentration is not exceeded.”
This means in practice that if e.g. toxicological threshold values for some substances are lower than the trigger value of 0.1 µg/L, then the lower threshold value is used in the assessment.
Note that the same principle applies also for plant protection products! The text in the BPR was in fact copied from the regulation on plant protection products. This means that for the indicator setting you may overlook some critical substances when looking only at the trigger value of 0.1 µg/L…
1) Fig1 „Percentage of monitoring sites with threshold exceedances in surface waters and groundwater in Europe“
The presented exceedances are only from reported monitoring sites, not from all monitored sites and this should be added also in the title, together with infrmation about using weighting factor, e.g.: Fig1 Percentage of reported monitoring sites with threshold exceedances in surface waters and groundwater in Europe based on a country weighting factor
2) It would be appropriate to add the table to the Fig 1 for surface water and groundwater - for each year to present substances that exceeded the limits. These substances that exceeded the limits should be further assessed for their risk.
3) Figure1 Groundwater: The descriptions on the Y axis should correspond to the formula in line 82. Now there are only pure percentages but there should be percentages affected by the country weight index according to the formula in line 82. Proposal to modify the title for Figure 1: Surface waters and groundwater in Europe based on a country weighting factor.
4) Page 4, Line 85: European environmental quality standards: We propose to add reference to EU directives
5) Page 4, Line 89-90: What criteria were defined for the non-relevancy of metabolites excluded from the assessment?
6) Page 5, line 94, 95, Figure 2.:
a / Are the percentages for surface waters calculated in this table in the same way as the percentages in Figure 1? I. e. Is the percentage multiplied by the weighting factor of the land area? If so, this table should indicate what the actual units are and whether the data in Figure 1 and Figure 2 are comparable.
b / The evaluation given in Figure 2 is based on data from SELECTED REPORTED sites. There are few countries that report all monitoring sites within WISE. Therefore, we think that if the weighting factor is used in the table and the area of the landscape is taken into account, the situation is distorted here.
c / Is the data for groundwater for SK correct? We soppose it shoud be 10% according to the data in the file PiRLG_4_reported_data_and_exceedance_rates_by_country_and_year.xlsx. (?)
d) There in this table are presented „only“ reported monitoring sites, not all monitored sites. Therefore the results could be indicative.
7) Could be made available a list of all assessed substances (with active substance/metabolite resolution)?
The weightning by country area assumes that results from monitoring sites could be exrapolated into the whole country. This is not the case e.g. in Finland where monitoring is focused in the potential risky areas - while areas with no presseures are not monitored (some sites included into screenings to demonstrate no detections).
=> perhaps river basin specific weighting instead of country specific?
Moreover, it seems that no weighting is given to data quality (number of analyzed substances, LOQs, sampling frequencies). It should be added - but i have no ideas how ot do it.