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In the case of surface waters, the WFD requires the identification of significant pressures from point sources of pollution, diffuse sources of pollution, modifications of flow regimes through abstractions or regulation and morphological alterations, as well as any other pressures. ‘Significant’ is interpreted as meaning that the pressure contributes to an impact that may result in the failing of Article 4(1) Environmental Objectives (see ’glossary’ below for further explanations).
The identification of significant pressures and their resulting impacts (which in turn lead to a reduced status) can involve different approaches: field surveys, inventories, numerical tools (e.g. modelling), expert judgement or a combination of tools. The magnitude of the pressure is usually compared with a threshold or criteria, relevant to the water body category and type, to assess its significance.
Reporting of pressures has to be seen in the context of the WFD planning process. The purpose of the Article 5 pressures and impacts analysis is to identify the water bodies which are at risk of failing to meet the Environmental Objectives of the WFD, either because they will not achieve good status or because their status is at risk of deterioration. Member States may have very comprehensive pressure inventories, but the purpose of reporting is focused on the ‘significance’ in relation to the WFD Environmental Objectives. Therefore, a pressure or impact should only be reported if it is significant, alone or in combination with others, because it puts the Environmental Objectives at risk. For example, the mere existence of point sources of pollution in a water body is not a reason to report point sources as a significant pressure. It should only be reported if these point sources put the achievement of the Environmental Objectives in the water body at risk. Significant pressures should only be reported for those water bodies which have been identified as being at risk.
The Article 5 pressures and impacts analysis is a crucial initial step in the planning process. The resulting risk assessment should then be used to design the monitoring programmes. One of the purposes of the monitoring programmes is to validate the risk assessment (see WFD Annex V section 1.3.1). This validation is then expected to feed into the risk assessment of the next planning cycle to refine the definition of ‘significance’ and improve the results. Indeed, in the first RBMPs, for the first risk assessment, Member States may have used certain pressure thresholds or criteria to define ‘significance’, but given the scarce impact data available at the time (the monitoring programmes had not yet started) it was not possible to establish a clear link to the impacts in terms of Environmental Objectives. For the second RBMPs, given the significant progress in terms of availability of information on pressures, impacts, responses, monitoring data and status, the pressures and impacts analysis and the risk assessment should have improved considerably, making this important first step of the planning process much more reliable.
This does not mean that the information on pressures and status at water body level should match one to one in all cases. It is expected that some water bodies may have been identified as being ‘at risk’ but their status is ’good’, either because the significant pressures identified are not large enough to cause the water body to be in less than good status in the given local conditions, or because the risk identified is a risk of deterioration. The opposite case (less than good status with no significant pressure) is seldom expected to happen, as the pressures analysis should be driven by a precautionary approach and be thorough enough to capture all potential pressures causing risk.
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In the guidance document it is mentioned that
It is quite unclear in the reporting data model which field or element should be used to identify a WB as being at risk. We have doubts and we think that the guidence uses different interpretations in different chapters.
The fields or elements for designating a SWB at risk we think should be:
when these conditions are true we have to report pressures(swSignificantPressureType) /impacts (swSignificantImpactType)
however in the guidance the quality checks are related to status fields:
could you please clarify this issue in the guidance?
HU: Risk assessment is not clear in the RBM planning procedure after the first cycle. Some countries are still making risk assessments during the revisions of the first plan, while others regard the status assessment and followed DPSIR method as substituting ways of work. There aren't clear guidance documents on the topic which often causes misunderstandings in transboundary cases or on other international level.
In addition there are many WBs where measures needed to prevent deterioration or to prevent increase of adverse effects of several insignificant and/or unknown pressures.
According to the guidance:
The achievement of WFD Article 4(1) Environmental Objectives implies
Currently these information is collected in different fields in SWB:
but how do we identify a SWB at risk because of not compliance of objectives in WFD protected areas?? Probably you need to search in the data model of Protected Area to find this information.
But the class SWAssociatedProtectedArea, has only six fields related to this issue, but with different perspective than the ones for ecological status ans chemical status:
Since this information is quite relevant, maybe it would be advisable to include an additional field indicating the swPAobjectivesExpectedgoodin2015 (2021) in SWB Schema.
This commment can be applied in other parts of the Guidance where there is a mixture of Chapters and Clasess in which current compliance is used versus others in which the forseen compliance in 2015 (now 2021) is used. A global revision of the Guidance to provide a uniform treatment of this issue though the whole guidance will be welcomed.
The guidance says 'Some Member States which have a large number of surface water bodies with low pressures group surface water bodies for the assessment of pressures and status. The information reported for the surface water bodies belonging to a group will therefore be identical.'
So when grouping is used, all the information of status, pressures and impacts should be identical to the information of monitored SWB?
The criteria used for grouping are clear: the same typology, pressures and the same impacts.
We agree with RO
In the guidance document it is mentioned that:
"The opposite case (less than good status with no significant pressure) is seldom expected to happen, as the pressures analysis should be driven by a precautionary approach and be thorough enough to capture all potential pressures causing risk."
There are several cases when DPSIR cannot be analysed well enough to make all relationships clear and that way not possible to capture all potential pressures causing risk. There are too many problems that require actions to plan measures for potentially significant problems.