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2.5. Methodology
A detailed description of the methodology on pesticides indicator development is provided in the methodology paper.
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In the documents on the indicator methodology and the data in Annex 3, it is not clear whether the indicator takes into account a) incomplete reporting form MS (for example not all relevant sites are reported) b) the diversity in reporting pesticides (not all countries are reporting the same pesticides and countries have very often different definitions of non-relevant pesticides). This is partially explained in the section on Uncertainties but to what extent can these uncertainties be translated into a +/- % and ideally be displayed within the figures presented.
It seems that for the substances included to the Watch List considering the maximum acceptable detection limit as a base for establishing the effect threshold value isn't always relevant. The fact that particular substance occurs in water environment in detectable amounts not always means its concentration causes negative environmental effect. So, only these Watch List substances should be taken into account which are recognised by any Member States as RBSP and have EQS (or good ecological status/potential boundaries) established by MS.
For RBSP: the scope of substances as well as EQS derivation methods differ between MS. Moreover, the situation may occur that the same substance may have more than one AA-EQS or more than one MAC-EQS (or good ecological status/potential boundary) value established, if considered EU-wide (or EEA-wide). It seems that calculation of the effect threshold value for RBSP will become fully reliable when common methods/guidelines for RBSP designation and RBSP EQS derivation are adopted by CIS WFD working groups (most probably WG Chemicals).
Maybe it´d appropriate to evaluate the values of all countries with the same threshold value, even if it is the most restrictive, but it would be necessary to indicate that this is the most conservative criterion. The EQS have not necessarily been defined in each country with the same criteria, and it would not be possible to make comparisons based on values that could be very different.
Could the mean value of RBSP EQS values be used instead of the lowest ones. The RBSP EQS values vary between countries. E.g. MCPA has values from 0.01 to 100 µg/l. This indicates a need for EU wide harmonization.
Perhaps new treshold values could be derived for the missing ones from pesticide registration data (or PPDB pesticide property database).