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Class IndicatorGap
- Please include here any comments which apply to all the schema elements in this Class.
- In addition to those general schema element level comments, we welcome your views on: a) whether you think this Class can be simplified; and b) whether you think the linkages with other reporting Classes or Schemas can be improved, and how;
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Previous comments
It is not possible to assess and to report the “IndicatorGapValue” ( 2015, 2021…) separately for each significant pressure type or chemical substance , due to the cumulative effect/ impact of all pressure sources.
It is considered that the number of options available for indicatorGap schema element is excessive, too specific and, therefore, hardly quantifiable. In fact, in most cases, their values are very difficult to ascertain, either due to the cumulative effect of several significant pressures and its impacts, or because how pressures information is structured and available. Thus, only the following two types of filling were used for the indicatorGap schema element: - PO99 - Other indicator – with Number of water bodies not achieving objectives because of this pressure as the indicatorGapOther schema element, whenever a quantitative pressure is in stake; PN21 - Number of water bodies failing EQS, for all other significant pressure substance failing. In addition to these two indicators being easily quantifiable for most pressures, they have the additional advantage of allowing a better comparability of this kind of data between river basin districts and between Member States, which facilitates the information analysis in order to produce knowledge that effectively contributes to define future strategies.
We also think that the information to be provided for the class "Indicator Gap" is very specific and it is not easy or not possible to provide reliable information for each significant pressure or chemical substance causing failure of good status. We therefore suggest to add a new schema element where MS could provide a written comment in order to describe the information to be provided here.
If it is not possible to add such a new schema element, we suggest to add the option "No information" or "Unknown" for schema elements "indicatorGapValue2015", "indicatorGapValue2021" and "indicatorGapValue2027".
We support PT, but would add lenght and area in addition to number of water bodies. PT has a good point on the ability to compare MS statistics.