Table of contents
3) Question and general comments
Question: Additional information on national or international EQS values
If you have further sources of information for EQS values in surface waters, beyond those set out in Annex 4 (xls file), please provide the links.
-
In Sweden, EQS values in surface water can be found on page 29-30 and 77-81 in this document https://www.havochvatten.se/download/18.4705beb516f0bcf57ce1c145/1576576601249/HVMFS%202019-25-ev.pdf
-
Thanks for the report. We want to note that he data given for Cyprus are correct and the report reflects the situation we see as a competent national authority in CY for monitoring pesticides in SW and GW.
Please also note that in the link: https://cdr.eionet.europa.eu/cy/eu/wfd2016/documents/colwepvog/envwepvtq/
at report: “Classification_suppl_CY_2015” (page 27) you can find EQS values for pesticides defined as specific pollutants for surface water in Cyprus.
-
Switzerland:
The Swiss Ecotox Centre provides proposals for quality criteria for surface waters in Switzerland: https://www.ecotoxcentre.ch/expert-service/quality-criteria/quality-criteria-for-surface-waters/.
Furthermore, the Annex 2 of the Swiss Waters Protections Ordinance defines numerical requirements for the concentrations of organic pesticides (https://www.fedlex.admin.ch/eli/cc/1998/2863_2863_2863/en). For the organic pesticides not explicitly mentioned in the ordinance, the general requirement of 0.1 µg/l applies.
General comments
If you have further comments on e.g. methodology, data availability, further improvement of the indicator, please provide your recommendations, expectations and ideas.
-
PT: Regarding the document "Indicator on pesticides in European waters.Technical paper" we would like to comment the following:
The Groundwate Directive sets quality standards for pesticides in Annex I, for "Active substances in pesticides, including their relevant metabolites, degradation and reaction products". In this context we consider that the non-relevant metabolites should be assessed with this EQS while the Directive is not reviewed (Chapter 2).
It is considered that only disaggregated data should be used for assessment, despite the analysis period is shorter (Chapter 3.1.1).
The Directive 2009/90/EC sets out the requirements for EQS and LoQs and is mandatory for all Member States. MS can use different analytical techniques as long as the compliance with the above-mentioned Directive is accomplished (Chapter 3.1.3).
(Chapter 3.2.1 - Surface water):
It is important to clarify that they are not two pesticides but two groups of pesticides including several active substances.
It is considered that substances on the Watch List should not be included in this assessment. These are preliminary data which may or may not be incorporated in the Directive reviewed. The purpose of the detection limit is to make this preliminary data comparable at European level, but does´t mean threshold values or EQS.
According to the WFD and taking into acount the PS Directive and RBSP, the exceedances are referred to the Pesticide EQS stablisheted.
In this report Portugal has exceedances regarding the imidachloprid insecticide in the context of the watch list for two sampling sites. In this two exceedances the reference value is the maxium aceptable detection limit, not comparable to EQS values, so is not possible to consider exceedances in this case.
Furthermore, one of the objectives of the watch list mechanism is to get good quality monitoring data for the future priority substances, not compliance with detection limit values.
-
MT: According to the documents provided, the EEA is extracting data from the WISE-6 dataflow. The data reported on CDR (https://cdr.eionet.europa.eu/mt/eea/wise_soe/wise6/) is not being featured for MT.
-
AT (Katharina Lenz)
The background information for the indicators is a highly appreciated first step to obtain an overview on pesticides occurrence, specific pesticides in different countries and the respective EU-wide and national regulations/ environmental quality standards. As regards surface waters, the information provided in the Annexes gives a comprehensive and detailed overview, which was not available in that level of detail beforehand.
The methodology paper mentions that Figure 1 (Percentage of reported monitoring sites with pesticides exceeding thresholds per year in a) surface waters and b) groundwater in Europe weighted by country area) was calculated by weighting the percentage of monitoring sites with pesticide exceedance by country area. It is furthermore argued that the country weighting reduces any imbalance as regards the numbers of monitoring sites and pesticides reported.
We agree that the weighting reduces the imbalance as regards the number of monitoring sites per country and the number of exceedances, but it does not reduce the imbalance as regards the number of pesticides monitored. Figure 1 and 2 show the number of monitoring sites with exceedances. Under the assumption of a constant number of monitoring sites, few exceedances may be achieved in case only few pesticides with many exceedances are monitored or in case many pesticides with only few exceedances are monitored.Already at the level of countries, the information for one country is not consistent as regards the number and location of sampling sites as well as the number of substances investigated. Therefore, a timely comparison over several years is not possible for an assessment of trends, neither on country- nor on EU-level. The comparison over time does not indicate, whether the total amount of pesticides increases or decreases. This should be mentioned prominently on the website. At the moment it is mentioned that “…a trend will become apparent in the next few years.” In case the data collection does not change in order to have more comparable database, a trend as regards the risk from chemical pesticides will not be evaluable.
In the example of AT, we are facing a differing number of monitoring sites and a differing number of pesticides monitored. Therefore, the results cannot be compared over time.
E.g. Austria:
Year
2013
2014
2015
2016
2017
2018
2019
2020
Number of sites
0
0
30
6
6
23
0*
0
Number of pesticides reported
0
0
8**
1 (Tri-allat)
1 (Tri-allat)
31***
0*
0
Number of sites with exceedances
0
0
2 (one with 2 pesticides exceeding, one with 1 pesticide exceeding)
0
0
1 (one with 1 pesticide exceeding)
0
0
% of number of sites exceeding
0
0
2 out of 30 = 6,7%
0
0
1 out of 23 = 4,3%
0
0
*Metaflumizone was reported under the WatchList at the sampling sites ATFW8022404 (Dornbirnerach), ATFW40505037 (Antiesen), ATFW40907057 (Donau), ATFW10000027 (Wulka/ WGEV-Stelle Seehof) and ATFW73200987 (Inn). This data seems to be missing in the EEA database
**Acetamiprid, Thiacloprid, Imidacloprid. Thiamethoxam, Oadiazon, Methiocarb, Chlotianidin, Tri-allat
***Cypermethrin, Omethoat, Dicofol, Heachlorbenzene, Simazin, Quinoxifen, Trifluralin, Alachlor, Atrazine, Phosalone, Chlorpyrifos, Alpha-HCH, Beta-HCH, Delta-HCH, Gamma-HCH (Lindan), Epsilon-HCH, Diuron, Isoproturon, Bifenox, Chlorfenvinphos, DDT.p,p’, Heachlorcyclohexane, Dichlorvos, Sebuthylazin, Aclonifen, Quintozene, Terbutryn, Alpha-Endosulfan, Total cyclodien pesticides, Total DDT, Heptachlor and heptachlorepoxid
Figure 1 (Percentage of reported monitoring sites with pesticides exceeding thresholds per year in a) surface waters and b) groundwater in Europe weighted by country area) shows that in 2015 20% of monitoring sites in surface waters exceeded thresholds, whereas in the dashboard 1 it is shown that in 2015 from out of a total 3.231 surface water monitoring sites 1.246 monitoring sites exceed threshold values. This would be 39%. When selecting the year 2015 in dashboard 5 it is shown that in total 596 out of 3.231 monitoring sites show exceedances, which is 18%. Is this difference somehow caused by the weighting factor? An explanation (with examples) would be helpful.
The supporting document “Pesticides in European rivers, lakes and groundwaters-Data asessement (ETC/ICM Technical report 1/2020)” mentions that there are large differences between different European countries in terms of the number of substances reported to the EEA and the number of monitoring stations and that the reported data is currently insufficient to support a thorough assessment of the risk posed by pesticides.
We support this statement. The European Green Deal sets targets to reduce the use of and risks from chemical pesticides by 50% by 2030 in the zero pollution action plan, farm to fork strategy and biodiversity strategy, with a focus on protecting ecosystems and improving biodiversity. Therefor it is important to define indicators, which allow an assessment, whether this target is achieved. The presented indicator 1 does not allow for an assessment of such a trend over time.Figure 2 (Percentage of reported monitoring sites with pesticides exceeding thresholds in surface waters, different sized rivers, lakes and groundwater in European countries, 2013 – 2019) summarizes data from the years 2013 – 2019. As reporting to the Waterbase is strongly driven by the Water Framework Directive, the investigated time period should be identical with the WFD reporting cycle (6 years).
For the pesticides of the WatchList, the assessment for surface water was elaborated against the maximum acceptable detection limit according to the WatchLists. This assessment should also be done against the proposed environmental quality standards given in the draft EQS dossiers
For the River Basin Specific Pollutants, the reported concentrations were assessed against the lowest reported ecotoxicollogically-based EQS available. This may lead to a completely different result than the assessment under the Water Framework Directive.
Maybe it would also be interesting and helpful to link to the WFD and briefly mention the results of the status reporting in the current RBMP cycle concerning pesticides.
-
Thanks for this report. I'd like clarify a couple of things in relation to Ireland's data.
- Malathion data for surface water was incorrectly uploaded for 2019. We have been in contact regarding this and we understand it won't be used for this report and will correct the data in the next WISE upload. Also the method used for Malathion analysis was not sufficiently sensitive to meet the EQS set out in Annex 4 of 0.008ug/l therefore the % exceedances highlighted for 2013, 2016 and 2017 are correct. We would prefer if Malathion data was not used for this report as the data is fit for purpose if the EQS of 0.008ug/l is applied. Malathion is not used in Ireland and has not been for many years.
- The substances Thiamethoxam and Acetamiprid were analysed as part of our Watch list monitoring programme which consists of only three sites. We are not satisfied that this table fairly reflects the Irish situation in relation to these compounds. Should there be a minimum number of waterbodies monitored before including in these assessments ?
- MCPA is known to be an problem in Irish surface waters however, if the EQS of 0.1ug/l as per Annex 6 was applied our % exceedances would be appox 33%. In applying the lowest EQS set by a member state (0.01ug/l) to our data this % exceedance increases dramatically (61.7% in 2019). As there is currently no mandatory EQS for MCPA the manner in which the % exceedances are highlighed seems to exaggerate the issue.
-
POLAND
The data from all the countries used to assess the state of European waters seem to be too inconsistent to let the EEA to draw any reliable conclusions. According to the WAT009_...xlsx the number of countries reporting active substances varies largely - from one to a dozen or so (there are active substances reported by only 1 country) and in most cases it is a few countries. Moreover, the density of monitoring sites is very diverse. Therefore it is not possible to present these data as the EEA did in this indicator assessment: for example to put together at one graph the data from subsequent years or comparing the number of detections of pesticides in water between the countries or monitoring sites as it is misleading.
Moreover the Ministry of Agriculture and Rural Development possess the data on the remains of pesticides / plant protection products that were not included in this monitoring. Therefore for developing such an indicator it seems also other sources of data (it refers to all the countries) should be used and the methodology needs to be reconsidered.
Comments referring to groundwater
Quite a big number of data is missing although reported via WISE SoE. The majority of determinants is below LOQ so the value of calculated substances is 0.
Exceedances by Year - Map and Bar Chart
2013: we reported 90 monitoring sites, this tableau site shows 83
2014: we reported 100 monitoring sites, this tableau site shows 72
2015: ok
2016: no data on the graph and map although we reported 151 sites
2017: no data on the graph and map although we reported 106 sites
2018, 2019, 2020: ok
Exceedances by Pesticide by Year - Map and Bar Chartthe numbers for the indicators are in line with the 'Exceedances by Year - Map and Bar Chart' therefore the data for 2016 and 2017 are missing and for the years 2013 and 2014 there are the differences
Exceedances by Pesticide by Year - Overview Table
the table is missing the calculations for 2016 and 2017
Exceedances by Country by Year - Overview Table
the table is missing the calculations for 2016 and 2017
Exceedances by Pesticide - Line Chart
the data for 2016 and 2017 are missing
In Estonia, EQS values in surface waters are point out here: https://www.riigiteataja.ee/akt/131122021003?leiaKehtiv (regulation of the Minister of Environment)