Table of contents
- 2. REPORTING AT SURFACE WATER BODY LEVEL (SCHEMA SWB)
- 2.3. Pressures and impacts on surface waters
- 2.4. Ecological status and exemptions
- 2.5. Chemical status of surface waters, exemptions and Mixing Zones
- 3. REPORTING AT GROUNDWATER BODY LEVEL (SCHEMA GWB)
- 3.3. Pressures and impacts on groundwater
- 3.4. Quantitative status of groundwater and exemptions
- 3.5. Chemical status of groundwater and exemptions
- 4. MONITORING (SCHEMA MONITORING)
- 5. PROTECTED AREAS (SCHEMAS SWB AND GWB)
- 6. REPORTING AT MS LEVEL: COMPETENT AUTHORITIES, RBDS AND SUB-UNITS (SCHEMA RBDSUCA)
- 7. REPORTING AT RBD/SUB-UNIT LEVEL FOR SURFACE WATER (SCHEMA SWMET)
- 7.3. Methodologies classification ecological status and potential
- 7.4. Methodologies classification chemical status
- 7.5. Overall management objectives (nutrients, river continuity)
- 7.6. Definition of significant pressures and impacts
- 7.7. Methodologies exemptions
- 8. REPORTING AT RBD/SUB-UNIT LEVEL FOR GROUNDWATER (SCHEMA GWMET)
- 8.4. Definition of significant pressures and impacts
- 8.5. Methodologies exemptions
- 9. REPORTING AT RBD/SUB-UNIT LEVEL FOR RBMP (SCHEMA RBMPPOM)
- 9.4. Water abstractions and exploitation of water resources
- 10. PROGRAMME OF MEASURES REPORTED AT RBD/SUB-UNIT LEVEL (SCHEMA RBMPPOM)
- 10.2. Targeted questions on basic measures and other aspects
- 10.3. Estimates of cost of measures
- 10.4. Co-ordination of measures in international RBDs
- 10.5. Progress with and achievements of the programme of measures for the first planning cycle
- 11. REPORTING AT RBD/SUB-UNIT LEVEL FOR ECONOMIC ANALYSIS AND COST RECOVERY (SCHEMA RBMPPOM)
- Overview of comments presented at WG DIS
- WISE spatial data presentation at WG DIS
10. PROGRAMME OF MEASURES REPORTED AT RBD/SUB-UNIT LEVEL (SCHEMA RBMPPOM)
The WFD requires that, within each RBD, a Programme of Measures (PoM) is established to address the significant issues identified and to allow the achievement of the objectives established under Article 4. The Directive further specifies that the PoM shall include as a minimum ‘basic measures’ and, where necessary to achieve objectives, ‘supplementary measures’.
Basic measures as a minimum must comprise:
- Measures required to implement existing Community water legislation and other environmental legislation (set out in Article 10 and in Part A of Annex VI – detailed below).
- Measures to implement Article 9 (cost recovery).
- Measures to promote efficient and sustainable water use.
- Measures to protect drinking water quality and reduce level of treatment required.
- Measures to control abstraction from surface and groundwater.
- Measures to control recharging of groundwater.
- Measures to control point source discharges.
- Measures to prevent or control inputs of diffuse pollutants.
- Measures to address any other significant impacts on status, in particular the hydromorphological condition.
- Measures to prohibit direct discharges to groundwater.
- Measures to eliminate or reduce pollution by Priority Substances.
- Measures to prevent accidental pollution.
Legislation in Article 10 and in Part A of Annex VI:
(i) The Bathing Water Directive (76/160/EEC).
(ii) The Birds Directive (79/409/EEC).
(iii) The Drinking Water Directive (80/778/EEC) as amended by Directive (98/83/EC).
(iv) The Major Accidents (Seveso) Directive (96/82/EC).
(v) The Environmental Impact Assessment Directive (85/337/EEC).
(vi) The Sewage Sludge Directive (86/278/EEC).
(vii) The Urban Waste Water Treatment Directive (91/271/EEC).
(viii) The Plant Protection Products Directive (91/414/EEC).
(ix) The Nitrates Directive (91/676/EEC).
(x) The Habitats Directive (92/43/EEC).
(xi) The Integrated Pollution Prevention Control Directive (96/61/EC).
Supplementary measures are those measures designed and implemented in addition to the basic measures where they are necessary to achieve the Environmental Objectives of the WFD as established in Article 4 and Annex V. Supplementary measures can include additional legislative powers, fiscal measures, research, educational campaigns that go beyond the basic measures and are deemed necessary for the achievement of objectives.
According to Article 11(5), additional measures may be necessary when a water body is unlikely to achieve the objectives under Article 4, after the adoption of the measures under the first RBMP. If the implementation of an additional measure lasts longer than one river basin management planning cycle this measure becomes either a basic or supplementary measure.
Measures should be targeted in terms of their type and extent to ensure that pressures are addressed and that this will deliver improvements towards achieving good status or potential in individual water bodies. The measures should be designed based on the assessment of the actual status of the water body, supplemented with the information from the analysis of pressures and impacts affecting the water body.
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Risk is not relevant in this cycle
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We use risk so that POMs can be assigned before an actual decline in status. e.g. If a signifiant increasing trend towards a nutrient boundary is detected then this waterbody can be subject to a POM/further characterisation to prevent a decline. The approach is therefore more proactive.
Class PoM
- 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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It is not clear for us why this class is included here as the information to be reported in this class doesn't seem to be linked to other classes from this reporting chapter. We suggest to delete this class.
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We wish to keep this
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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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.
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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.
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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.
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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.
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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.
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We support the RO comment
surfaceWaterOrGroundwater - Required.(SWBorGWB_Enum)
Select surface water or groundwater in turn from the enumeration list where measures are required to achieve the WFD Environmental Objectives.
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We propose to delete this item as it it doesn't introduce any added value to the information, but it does introduce noise and confusion.
Measures related to SW shouldn't be separated from those related to GW as measures are common in many cases.
e.g. diffuse sources of pollution from agriculture affect both SW and GW so the measures to reduce them will be the same.
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We propose to delete this item as it it doesn't introduce any added value to the information, but it does introduce noise and confusion.
Measures related to SW shouldn't be separated from those related to GW as measures are common in many cases.
e.g. diffuse sources of pollution from agriculture affect both SW and GW so the measures to reduce them will be the same.
RO suggest to mantain this item having in view that even the measures are common for surface and groundwaters bodies, the measures shall be correlated with the pressures and indicators for pressures.
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If the class "PoM" will be kept (see our comment regarding the class "PoM"), we suggest to add the option "Surface water and groundwater". This options could be chosen for those measures that apply to surface waters as well as groundwater.
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We support the RO comment
Class SignificantPressureSubstanceFailing
- 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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Similar comment to SWsignificantPressureType
The codelist of Annex 1a shouldn't be splitted by drivers as usually the relation pressure- driver is 1:n
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Similar comment to SWsignificantPressureType
The codelist of Annex 1a shouldn't be splitted by drivers as usually the relation pressure- driver is 1:n
RO agrees.
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It should be clarified if GW significant pressures should be included also and the same with pollutants causing failure in GW chemical status
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We support the comment from ES.
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Will these tables be automatically filled by the EC based on previous round reporting? In that case, it could be interesting to give MS the possibility to add or modify indicators.
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We wish to keep this as it is, since a lot of information would be lost if it was simplified. We see the problem with many drivers per pressure type in a WB, but then it is better to add several pressure types. An example is a dam for drinking water and hydropower. The measures here will be different, and we wish to keep them separate to be able to point to the right sector.
significantPressureOrSubstanceFailing - Required.(SignificantPressureOrSubstanceFailingType_Union_Enum)
Select in turn:
- each significant pressure type in turn from the enumeration list that is, by itself or in combination with other pressures, significant in terms of Environmental Objectives not being met (i.e. is causing failure of good ecological status or potential or failure of good chemical status),
- each Priority Substance that is causing failure of good chemical status
- each RBSP that is causing failure of good ecological status or potential
and for which measures are required to reduce the pressure to a level and extent that enables the Environmental Objectives to be met. More than one significant pressure type may be selected.
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we propose to implement the following quality check:
The option ‘No significant pressure” is not valid.
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It is not clear if pollution by Priority substancess and river basin specific pollutants should be reported double. As a consequence of a significant pressure leading to need of measures and/or as lines of its own whith different measures (KTMs) to remedy the problem? With seperat lines för the chemical pollutants, the pressure causing the problem will not be noted. And chemical pollutants reported under sigificant pressures views the whole chain from pressure to measure. And it is fully possible to evaluate the need of measures per chemical substance any way, since it is reported as indicatorGap. Not good to have different ways to report like this.
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"- each significant pressure type in turn from the enumeration list that is, by itself or in combination with other pressures, significant in terms of Environmental Objectives not being met (i.e. is causing failure of good ecological status or potential or failure of good chemical status),..."
Using this term ’i.e.’, this phrase can be interpreted as we do not deal with significant pressures causing failure of good quantitative status of groundwater bodies. However, in the Hungarian WISE2016 report for example, water abstractions from groundwater were also considered as a pressure "causing failure of good quantitative status". If this was the correct interpretation, then we propose to clarify it in this guide.
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In order to facilitate reporting, it would be very helpful if only the substances and pressures causing failure of good status that have been previously selected by the MS would be included in the drop-down list and not the whole lists of substances and pressures.
significantPressureOrSubstanceFailingOther - Conditional.
If ‘significantPressureOrSubstanceFailing’ is ‘EEA_00-00-0 Other chemical parameter’ please indicate in this field the CAS number (if relevant) and the name of the pollutant or indicator.
useArticle45Beyond2027 - Required.(useArticle45Beyond2027_Enum)
For each significant pressure type and chemical substance reported, select the estimated percentage of water bodies from the enumeration list for which it is expected that less stringent objectives will be set under WFD Article 4(5) in the third cycle, i.e. the percentage of water bodies that are not expected to achieve good status or potential by 2027. If the information is not available, select ‘No information’.
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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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.
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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.
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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".
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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.
indicatorGap - Required.(IndicatorPressure_Enum)
For each significant pressure type or chemical substance reported, select the pre-defined quantitative indicator of the scale and extent of the pressure or chemical substance that is to be reduced by measures to achieve Environmental Objectives. This is the gap to be filled to meet objectives. At least one of the pre-defined quantitative indicators must be selected from the enumeration list although more than one may be appropriate for the situation in the RBD.
Select the ‘PO99 – Other indicator’ option from the enumeration list to report details of additional quantitative indicators developed by the Member State in the relevant schema elements.
For indicative purposes, the pressures and chemical substances have been mapped to the pre-defined Key Types of Measure (KTMs) (see Annex 3). Quantitative indicators have been proposed for each pressure or chemical substance causing failure and the relevant KTMs.
All indicators are defined in terms of what needs to be done to achieve Environmental Objectives (i.e. good ecological status or potential or good chemical status). This means that the value of the indicator will be reduced with time as measures are implemented. A value of 0 is comparable with 100 % good ecological status or potential or good chemical status. Any ‘Other’ indicator reported by Member States should be constructed in the same way.
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In Denmark the available information on pressures is only partly structured and disaggregrated in a way to respond to the pre-defined quantitative indicator of the scale.
Focus in Denmark has been how to achieve good ecological status in the different types of water bodies (rivers, lakes, costwaters etc.) and we have traced the source to pressuretype where possible, although there sometimes is more than one relevant pressure.
In the WISE reporting the quantitative indicators is also very specific concerning the actual use including a wish to disaggregrate data whether the alterations of water bodies is caused by agricultural, aqua cultural or other specific purposes, and for some pressures it's not possible to disaggregate data to this extend.
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Similar comment to SWsignificantPressureType
The codelist of Annex 1a shouldn't be splitted by drivers as usually the relation pressure- driver is 1:n
In the same sense indicators should not be splited by pressure-driver
As an example, the following indicators should be grouped in one to avoid double accounting the effects of 'hydrological alterations' that are multipurpose (almost all):
The new indicator should be:
- PA07bis- Area (km2) of water bodies where hydromorphological alterations are preventing the achievement of objectives
The existing indicators are:
PA07 – Area (km2) of water bodies where hydromorphological alterations for agricultural purposes are preventing the achievement of objectives
PA08 – Area (km2) of water bodies where hydromorphological alterations for aquaculture purposes are preventing the achievement of objectives
PA09 – Area (km2) of water bodies where hydromorphological alterations for hydropower production are preventing the achievement of objectives
PA10 – Area (km2) of water bodies where hydromorphological alterations for other purposes are preventing the achievement of objectives
PA11 – Area (km2) of water bodies where hydromorphological alterations for public water supply purposes are preventing the achievement of objectives
PA12 – Area (km2) of water bodies where hydromorphological alterations for transport purposes are preventing the achievement of objectives
It is the same case with indicators PL02 to PL09. We propose a new one:
- PL02bis - Lenght (Km) of water bodies where hydromorphological alterations are preventing the achivment of objectives
The same happends with indicators PN01 to PN09. We propose a new indicator:
- PN01bis - Number of dams/ weirs/ barriers and locks that have conditions not compatible with the achivment of objectives
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Similar comment to SWsignificantPressureType
The codelist of Annex 1a shouldn't be splitted by drivers as usually the relation pressure- driver is 1:n
In the same sense indicators should not be splited by pressure-driver
As an example, the following indicators should be grouped in one to avoid double accounting the effects of 'hydrological alterations' that are multipurpose (almost all):
The new indicator should be:
- PA07bis- Area (km2) of water bodies where hydromorphological alterations are preventing the achievement of objectives
The existing indicators are:
PA07 – Area (km2) of water bodies where hydromorphological alterations for agricultural purposes are preventing the achievement of objectives
PA08 – Area (km2) of water bodies where hydromorphological alterations for aquaculture purposes are preventing the achievement of objectives
PA09 – Area (km2) of water bodies where hydromorphological alterations for hydropower production are preventing the achievement of objectives
PA10 – Area (km2) of water bodies where hydromorphological alterations for other purposes are preventing the achievement of objectives
PA11 – Area (km2) of water bodies where hydromorphological alterations for public water supply purposes are preventing the achievement of objectives
PA12 – Area (km2) of water bodies where hydromorphological alterations for transport purposes are preventing the achievement of objectives
It is the same case with indicators PL02 to PL09. We propose a new one:
- PL02bis - Lenght (Km) of water bodies where hydromorphological alterations are preventing the achivment of objectives
The same happends with indicators PN01 to PN09. We propose a new indicator:
- PN01bis - Number of dams/ weirs/ barriers and locks that have conditions not compatible with the achivment of objectives
RO agrees.
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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. But it is statistically not acceptable to quantify this with indicators the way it is now.
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The available information on pressures is not structured in the way to fill in this table. Brussels is an environment with many pressures where we cannot disaggregate the pressure by the measures.
We suggest to label this item 'not required' since the EC itself indicates certain pressures are more difficult to quantify, or it is difficult to disaggregate pressure-measure relationships in certian RBDs. This implies that filling in this field cannot be required.
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based on the achievement of Good only – there is no provision for the target to be set as high. - The provision to have environmental objectives as high needs to be provided for throughout the reporting database. It will also need to be included in future article 15 reporting.
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based on the achievement of Good only – there is no provision for the target to be set as high. - The provision to have environmental objectives as high needs to be provided for throughout the reporting database. It will also need to be included in future article 15 reporting.
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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.
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Is the problem pointed out by ES real. Does anyone sum up the indicators?
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- IE stated the need to include objectives for high status sites (KTM and gap indicators). One of the solutions forwarded by Peter at the meeting was to define gap - as GAP TO OBJECTIVE rather than gap to good status. (this would allow high status to be included). The decline in EU high status sites deserves more attention.
indicatorGapOther - Conditional.
If ‘PO99 – Other indicator’ has been reported in indicatorGap, report a short name and description of the quantitative indicator of the scale and extent of the pressure or chemical substance that is to be reduced by measures to achieve Environmental Objectives. This is the gap to be filled to meet objectives. More than one ‘Other’ indicator may be reported.
indicatorGapValue2015 - Required.
For each pre-defined quantitative indicator selected in indicatorGap, report the expected value of that indicator at the start of the second cycle in 2015.
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See our comment regarding the class "IndicatorGap".
indicatorGapValue2021 - Required.
For each pre-defined quantitative indicator selected in IndicatorGap, report the expected value of that indicator at the start of the third cycle in 2021.
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See our comment regarding the class "IndicatorGap".
indicatorGapValue2027 - Optional.
For each pre-defined quantitative indicator selected in IndicatorGap, report the expected value of that indicator at the end of the third cycle in 2027.
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See our comment regarding the class "IndicatorGap".
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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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.
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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
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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.
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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.
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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".
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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.
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We support PT, but we would use number KN30, area KA16 and lenght KL04. This will make it easier to compare MS
keyTypeMeasure - Required.(KTM_Enum)
For each significant pressure type and chemical substance reported, report the pre-defined Key Types of Measure (KTMs) that will be made operational to reduce the pressure or chemical substance.
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KTMs should be reviewed to incorporate MFSD KTM as measures for coastal waters are shared by both directives and those shared measures should't be classified in different KTM depending on the directive they relate to. The same exercise neeeds to be carried out for Floods directive.
The names of the KTM will benefit from a review to made them more self explanatory.
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Please note that this covers some ubiquitous chemicals which already have a wider international agreement to limit their use.
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KTM enumeration list should be spread to KTMs used by countries beyond RBMP2 enumeration list. Structure of the PoM should be changed to neglect duplicate calculation of measures due to complex implementation of actions. Horizontal measures like adaptation to climate change either pricing policy or monitoring should be separated from specific KTMs and one to more link can be chosen.
keyTypeMeasureOther - Conditional.
For each significant pressure type and chemical substance reported, report the name of Key Types of Measure (KTMs) if the pre-defined KTMs are not appropriate that will be made operational to reduce the pressure or chemical substance. More than one new KTM may be reported.
keyTypeMeasureIndicator - Required.(IndicatorKTM_Enum)
Select the pre-defined quantitative indicator from the enumeration list that relates to each pre-defined KTM reported in keyTypeMeasure. The indicator selected should give an indication of the remaining measures that will need to be made operational to achieve Environmental Objectives.
keyTypeMeasureIndicatorOther - Conditional.
If ‘KO99 – Other indicator’ has been reported in keyTypeMeasureIndicator, report a short name and description of the quantitative indicator relating to the KTMs. More than one ‘Other’ indicator may be reported.
keyTypeMeasureIndicatorValue2015 - Required.
For each pre-defined quantitative indicator relating to the KTMs selected in keyTypeMeasureIndicator, report the expected value of that indicator at the start of the second planning cycle in 2015.
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See our comment regarding the class "keyTypeMeasureIndicator".
keyTypeMeasureIndicatorValue2021 - Required.
For each pre-defined quantitative indicator relating to the KTMs selected in keyTypeMeasureIndicator, report the expected value of that indicator at the start of the third cycle in 2021.
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For some of the pressures, where the IndicatorGAP value for 2021 is more than "0", Denmark has not decided which measures should be used after 2021 to reach the goal for the IndicatorGap. This is because we want to await the result of the implemented measures and possibly new knowledge.
Because of the fact that precise measures have not yet been decided for the pressures, Denmark can only report the 2015 and 2018 values of the KTMindicator as an expression for the goal to reach in the second period of the RBMP and not as an expression to reach good ecological status or good chemical status.
Denmark had asked Helpdesk how to handle this, and the answer was to estimate the needed area to cover by the measures in order to reach good status.
The problem to this solution is that the estimated area depends on the decided measures. For example is the area needed very different whether we use Catch Crops, wetland or maybe something far more efficient. Also the stakeholders will wonder, if they can see that we in Denmark is reporting specific measures for the 3rd RBMP before they are political decided.
The problem above arises as a result of reporting of the 2nd RBMP and will not be a problem in a last period of the WFD.
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See our comment regarding the class "keyTypeMeasureIndicator".
keyTypeMeasureIndicatorValue2027 - Optional.
For each pre-defined quantitative indicator relating to the KTMs selected in keyTypeMeasureIndicator, report the expected value of that indicator at the end of the third cycle in 2027.
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See our comment regarding the class "keyTypeMeasureIndicator".
Class KTM
- 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;
keyTypeMeasure - Required.(KTM_Enum)
Select each appropriate pre-defined Key Type of Measure (KTM) or ‘KTM99 – Other key type measure reported under PoM’ in turn from the enumeration list used to reduce significant pressures in the RBD.
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In order to facilitate reporting, it would be very helpful if only the KTMs selected by the MS in class "KTM" would be included in the drop-down list and not the whole list of KTMs. In that sense, it would be important to first report the class "KTM" and only afterwards the class "KeyTypeMeasureIndicator".
keyTypeMeasureOther - Conditional.
For each significant pressure type and chemical substance reported, report the name of Key Types of Measure (KTMs) if the pre-defined KTMs are not appropriate that will be made operational to reduce the pressure or chemical substance. More than one New KTM may be reported.
Class: Measure
- 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;
measureCode - Required.
For each pre-defined or new KTM report the unique code of each national or RBD specific measure incorporated into the KTM.
measureName - Required.
Provide the name for each national or RBD measure. This should reflect the pressure that is being tackled by the measure.
measureType - Required.(: MeasureType_Enum)
For each pre-defined or new KTM indicate whether each national or RBD specific measure incorporated into the KTM is a basic measure as required under Article 11(3)(a) or Article 11(3)(b-l), or a supplementary measure as required under Article 11.4 when basic measures are not enough to tackle specific significant pressures.
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The information gathered will benefit a lot if a distinction is made within 'supplementary measures', in the sense of art 11.4 of the WFD.
- Supplementary measures are those measures designed and implemented in addition to the basic measures, with the aim of achieving the objectives established pursuant to Article 4. Part B of Annex VI contains a non-exclusive list of such measures.
- Member States may also adopt further supplementary measures in order to provide for additional protection or improvement of the waters covered by this Directive, including in implementation of the relevant international agreements referred to in Article 1.
Our proposal is to differentiate:
- Supplementary measures - achievment of objectives
- Supplementary measures - additional protection
Only the first group of measures, that is, the measures necessary to achieve the objectives, must be taken into account when analyzing the gap to the objectives, so this distinction is of great importance.
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We support ES
basicMeasureType - Conditional.(BasicMeasureType_Enum)
For each national or RBD specific measure incorporated into the KTM which is a basic measure, select from the enumeration list to which type of basic measure it corresponds. More than one option may be selected per measure.
msfdRelevance - Required.(YesNoLandlocked_Union_Enum)
For each national or RBD specific measure incorporated into the KTM, report if it is relevant for the purpose of the Marine Strategy Framework Directive or not.
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French oversea territories are not concerned. Is it possible to answer "not applicable"?
measureReference - Required.(ReferenceType )
Provide references or hyperlinks to the relevant documents and sections where specific information on the national or RBD specific measures can be found. Guidance on what should be included in this document is provided in Section 10.1.9.
Guidance on the contents of RBMPs/background documents
(Please see the full text of this sub-section in the WFD Reporting Guidance 2016 or above chapter)
Include here any comments that relate to the information contained in this sub-section of the Reporting Guidance, namely concerning information you think could/should be reported electronically and information which you believe should not be included in the River Basin Management Plans or background documents.
The reporting is restrictive in being state rather than risk based. We assign measures on the basis of risk (which incorporates status), and not status alone, so it would be useful to have a bit more flexibility to accommodate that.