euSubUnitCode - Conditional.
If applicable, report the unique EU code of the Sub-unit. If there are no sub-units this element does not need to be reported and the reporting of the information is done at RBD level. Sub-units are only relevant for surface water.
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Previous comments
In the most cases there is no differences in PoM at subunit level thus the reporting in subunits only a repetition of the same measures. It would be easier to report in a linking table whether in which subunit that measure relevant or not relevant.
RO considers that the reporting having as linkage the subunits is useful to easly identify the corresponding measures, even these measures are the same; perhaps some particularisation of name of the measures can be made.
Chapters 10 and 11 of the guidance relate to economics, progress, etc. We were obliged to report per RBD but Ireland manages this information on a national basis. We had to therefore report the same national figures three times - once for each RBD.
RO considers that it is a particular approach in Ireland on aggregation of data and information about measures and cost at the national level. WFD requires to assure these topics at the river basin level, as Romania reported.
Luxembourg has the same problem than Ireland. In order to facilitate reporting and to keep things clear, it could be helpful to add a schema element where MS can indicate that the information is only available at national level and not at RBD level.
We support the RO comment