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Class KeyTypeMeasureIndicator
- 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
In Denmark we particular had a problem using the KTM2 indicator "KA02 - Area (km2) of agricultural land required to be covered by measures to achieve objectives".
We do know how much agricultural land is required and covered by each measure in the Danish PoM. However, for one measure (eg. Wetlands), it is not possible to continue the agricultural production with crops, for another measure (eg. Catch crops) the agricultural production will continue.
Therefore, the KA02 will have two different contents/meanings in our reporting. Also we find a need to distinguish in relation to the effect on reducing nutrient pollution, while there is a big difference between the effectiveness and thereby the land needed using for example wetlands or catch crops
We asked Helpdesk if it was possible to make any distinction, and got the answer, that it was not possible for the moment.
We will therefore propose that the KA02 is subdivided according to whether there is a continued agricultural use and/or the effectiveness pr. km2 of the measure.
The focus of the WFD is to achieve good ecological and chemical status. It is reasonable to ask from memberstates to link certain (groups of) failing substances to certain pressures and to ask which KeyTypeMeasures will be used to bridge the gap to the objectives (if there is any). But again it is it is statistically not acceptable to quantify this with indicators. It suggest an accuracy which is just not there. We question the use and the comparability of this data between member states. And we do not think that the argument: ‘your educated guess is better than ours’ is valid to justify this kind of detailled reporting. We suggest to remove these quantitative indicators and replace it with a textual explanation
It is considered that the number of options available for keyTypeMeasureIndicator 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 difficulty of obtaining detailed information from the entities responsible for implementing the measures, or because how measures information is structured and available. Therefore, only the following type of filling was used for the keyTypeMeasureIndicator schema element: - KO99 - Other indicator, specifying Number of measures in each KTM to achieve the water bodies objectives as the keyTypeMeasureIndicatorOther schema element. In addition to this indicator being easily quantifiable for all measures, it has 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.
For each KTM, we cannot directly indicate the evolution of the state of a water body. The improvement of the state of water bodies depends on several factors. Brussels is an environment with many pressures where we cannot disaggregate the pressure by the measures. Example Instead, an indicator for the state (xx numbers of waterbodies affected or length affected,...) and the KTM used to improve the state of the waterbodies.
We suggest to label this item 'not required' since the EC itself indicates this is a challenging task, in particular for some pressure-measure relationships. This implies that filling in this field cannot be required.
We also think that the information to be provided for the class "KeyTypeMeasureIndicator" 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 consider the whole class as being "optional" or to add a new schema element where MS could provide a written comment in order to describe the information to be provided here.
If this class will be maintained as being "required" and 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 "keyTypeMeasureIndicatorValue2015", "keyTypeMeasureIndicatorValue2021" and "keyTypeMeasureIndicatorValue2027".
Further evaluation on the added-value of elaborating on two types of indicators (IndicatorGap and KeyTypeMeasureIndicator) should be sought, particularly noting that the pre-defined indicators may reflect the same scenario. There may therefore be scope for further alignment and simplification between the two classes. Should no added-value be attributed to having two separate indicators, schemas could be simplified through amalgamation of reporting fields.
We support PT, but we would use number KN30, area KA16 and lenght KL04. This will make it easier to compare MS