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Rationale uncertainty

In surface waters, ecotoxicologically-based effect thresholds were determined to assess exceedance rates at monitoring sites. Those thresholds indicate potential pollution by pesticides affecting communities in aquatic ecosystems. Using the lowest ecotoxicologically-based effect threshold is the most conservative criterion. The EQS have not necessarily been defined in each country with the same criteria as used here, which makes comparisons with this indicator difficult. 

In groundwater, exceedances were assessed against the 0.1ug/L quality standard set out in the Groundwater Directive. No regulated quality standards for non-relevant metabolites are available and so they were excluded from the assessment. 

The indicator demonstrates a need to harmonise limit values (including nationally set river basin-specific pollutant EQS values).  

Previous comments

  • gomesfer (Fernanda Gomes) 05 Sep 2022 16:49:55

    PT: It is considered important to clarify the text, namely that the EQS (or threshold) set by Member States are relate to specific pollutants. While the EQS in the Priority Substances Directive are mandatory for all Member States.

    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.

    The EQS referred in the 3rd paragraph are related to the specific pollutants. This paragraph concerns surface water, so should be placed above groundwater.

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