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.
In the guidance document it is mentioned that
- '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
- Significant pressures should only be reported for those water bodies which have been identified as being at risk.'
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:
- swEcologicalStatusOrPotentialExpectedGoodIn2015=No OR
- swChemicalStatusExpectedGoodIn2015 = No
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:
- If SWB/SurfaceWaterBody/swEcologicalStatusOrPotentialValue is ‘3’, ‘4’ or ‘5’, at least one significant pressure type must be selected from the enumeration list (can include option ‘8 Unknown pressures’). The option ‘No significant pressure’ is not a valid selection.
- If SWB/SurfaceWaterBody/swChemicalStatusValue is ‘3’, at least one significant pressure type must be selected from the enumeration list (can include ‘8 Unknown pressures’). The option ‘No significant pressure’ is not a valid selection.
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 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.
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.
Class: SurfaceWaterBody
swSignificantPressureType - Required.(SignificantPressureType_Enum)
Indicate the significant pressure type(s) from the enumeration list.
The codelist of Annex 1a shouldn't be splitted by drivers as usually the relation pressure- driver is 1:n
As an example, for dams the list of pressure-driver combinations is:
4.2.1 - Dams, barriers and locks - Hydropower |
Energy – hydropower |
|
4.2.2 - Dams, barriers and locks - Flood protection |
Flood Protection |
|
4.2.3 - Dams, barriers and locks - Drinking water |
Urban development |
|
4.2.4 - Dams, barriers and locks - Irrigation |
Agriculture |
|
4.2.5 - Dams, barriers and locks - Recreation |
Tourism and recreation |
Small dams are used in rivers to create recreational areas (bathing waters) and also angling areas |
4.2.6 - Dams, barriers and locks - Industry |
Industry, Energy - non-hydropower |
Dams are sometimes created to provide freshwater for large industry e.g. typically for cooling purposes |
4.2.7 - Dams, barriers and locks - Navigation |
Transport |
|
4.2.8 - Dams, barriers and locks – Other |
|
|
4.2.9 - Dams, barriers and locks – Unknown or obsolete |
|
|
In Spain there is a clear register of dams, but most of them (almost all) are multipurpose. Reporting them as it is proposed now creates duplication of information. A WB maybe affected by one dam with several objectives or uses or in the sense of this field drivers (irrigation, drinking water, hydropower and recreation). With the current schema we have to report four types of pressures for that particular WB. This creates important misunderstandings, than can be easily solved by splitting the list and using a list of pressures and a list of drivers, but not a combination of both.
The codelist of Annex 1a shouldn't be splitted by drivers as usually the relation pressure- driver is 1:n
As an example, for dams the list of pressure-driver combinations is:
4.2.1 - Dams, barriers and locks - Hydropower
Energy – hydropower
4.2.2 - Dams, barriers and locks - Flood protection
Flood Protection
4.2.3 - Dams, barriers and locks - Drinking water
Urban development
4.2.4 - Dams, barriers and locks - Irrigation
Agriculture
4.2.5 - Dams, barriers and locks - Recreation
Tourism and recreation
Small dams are used in rivers to create recreational areas (bathing waters) and also angling areas
4.2.6 - Dams, barriers and locks - Industry
Industry, Energy - non-hydropower
Dams are sometimes created to provide freshwater for large industry e.g. typically for cooling purposes
4.2.7 - Dams, barriers and locks - Navigation
Transport
4.2.8 - Dams, barriers and locks – Other
4.2.9 - Dams, barriers and locks – Unknown or obsolete
In Spain there is a clear register of dams, but most of them (almost all) are multipurpose. Reporting them as it is proposed now creates duplication of information. A WB maybe affected by one dam with several objectives or uses or in the sense of this field drivers (irrigation, drinking water, hydropower and recreation). With the current schema we have to report four types of pressures for that particular WB. This creates important misunderstandings, than can be easily solved by splitting the list and using a list of pressures and a list of drivers, but not a combination of both.
RO supports the proposal of ES, to have in view more clar the aspects of pressure-driver combinations.
We suggest that a column (with pick up options: ecological status and chemical status) be added in order to differentiate between a significant pressures in relation to ecological status and a significant pressures in relation to chemical status because sometimes the same pressure could be relevant for both ecological and chemical status.
Since the guidance says 'Significant pressures should only be reported for those water bodies which have been identified as being at risk'
we propose to extend the quality check (not only check consistency with status but with risk aswell)
Within-schema check: If (SWB/SurfaceWaterBody/swEcologicalStatusOrPotentialValue is ‘3’, ‘4’ or ‘5’ or SWB/SurfaceWaterBody/swEcologicalStatusOrPotentialExpectedGoodIn2015=No), at least one significant pressure type must be selected from the enumeration list (can include option ‘8 Unknown pressures’). The option ‘No significant pressure’ is not a valid selection.
Within-schema check: If (SWB/SurfaceWaterBody/swChemicalStatusValue is ‘3’ or SWB/SurfaceWaterBody/swChemicalStatusExpectedGoodIn2015=No), at least one significant pressure type must be selected from the enumeration list (can include ‘8 Unknown pressures’). The option ‘No significant pressure’ is not a valid selection.
It was hard to implement the new list of pressure and impact types in mid cycle. The pressure and impact analysis was already performed with the old types at that stage and had to be corrrected/transformed to fit the reporting demands.
We would welcome if the list of pressure types in annexe 1a could be simplified. As the list is very detailed and we hadn't subdivided our pressures into that detail we weren't always sure which information should be reported.
The suggestion from ES to split the list of pressures and the list of drivers could be a way to facilitate the reporting. This would also allow to add some information on the drivers if the option "other" (e.g. 1.9 - Point - Other) is choosen.
In any case, if the list of pressure types will be modified this should be done rapidly as this list will be the basis for the article 5 assessment that need to be done until the end of this year.
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.
We support ES, RO an LU.
In any case, if the list of pressure types will be modified this should be done rapidly as this list will be the basis for the article 5 assessment that need to be done until the end of this year.
swSignificantPressureOther - Conditional.
If ’7 – Anthropogenic pressure – Other’ is selected from the enumeration list and reported under swSignificantPressureType, provide details of any other anthropogenic pressure types which are relevant in this element. This element should only be reported if the pressure type is not included in the enumeration list under swSignificantPressureType.
swSignificantImpactType - Required.(SignificantImpactType_Enum)
Indicate the impact type(s) from the enumeration list.
We have detected several reporting isuess related to this list in Spanish RBDs reporting, that could be solved by doint the list more 'human readable'. An easy way to make it more friendly is by adding a numerical code to each impact that relates it with the type of pressure that can produce it. As an example the first digit can represent 1.Pollution, 2.Hydrological changes 3. Morphology.... A proposal in this sense is shown below
Impact type | Relevant SW | Relevant GW |
1.1 - NUTR - Nutrient pollution | Y | Y |
1.2 - ORGA - Organic pollution | Y | Y |
1.3 - CHEM - Chemical pollution | Y | Y |
1.4 - SALI - Saline pollution/intrusion | Y | Y |
1.5 - ACID - Acidification | Y | N |
1.6 - TEMP - Elevated temperatures | Y | N |
1.7 - MICR - Microbiological pollution | Y | Y |
2.1 - HHYC - Altered habitats due to hydrological changes | Y | N |
2.2 - HMOC - Altered habitats due to morphological changes (includes connectivity) | Y | N |
3.1 - QUAL - Diminution of quality of associated surface waters for chemical / quantitative reasons | N | Y |
3.2 - INTR - Alterations in flow directions resulting in saltwater intrusion | N | Y |
3.3 - LOWT - Abstraction exceeds available groundwater resource (lowering water table) | N | Y |
4.1 - ECOS - Damage to groundwater-dependent terrestrial ecosystems for chemical / quantitative reasons | N | Y |
4.2 - LITT - Litter (an impact under the MSFD) | Y | N |
5.1 - OTHE - Other significant impact type | Y | Y |
6 - NOSI - No significant impact | Y | Y |
7 - NOTA - Not applicable | Y | Y |
8 - UNKN - Unknown impact type | Y | Y |
We have detected several reporting isuess related to this list in Spanish RBDs reporting, that could be solved by doint the list more 'human readable'. An easy way to make it more friendly is by adding a numerical code to each impact that relates it with the type of pressure that can produce it. As an example the first digit can represent 1.Pollution, 2.Hydrological changes 3. Morphology.... A proposal in this sense is shown below
Impact type Relevant SW Relevant GW 1.1 - NUTR - Nutrient pollution Y Y 1.2 - ORGA - Organic pollution Y Y 1.3 - CHEM - Chemical pollution Y Y 1.4 - SALI - Saline pollution/intrusion Y Y 1.5 - ACID - Acidification Y N 1.6 - TEMP - Elevated temperatures Y N 1.7 - MICR - Microbiological pollution Y Y 2.1 - HHYC - Altered habitats due to hydrological changes Y N 2.2 - HMOC - Altered habitats due to morphological changes (includes connectivity) Y N 3.1 - QUAL - Diminution of quality of associated surface waters for chemical / quantitative reasons N Y 3.2 - INTR - Alterations in flow directions resulting in saltwater intrusion N Y 3.3 - LOWT - Abstraction exceeds available groundwater resource (lowering water table) N Y 4.1 - ECOS - Damage to groundwater-dependent terrestrial ecosystems for chemical / quantitative reasons N Y 4.2 - LITT - Litter (an impact under the MSFD) Y N 5.1 - OTHE - Other significant impact type Y Y 6 - NOSI - No significant impact Y Y 7 - NOTA - Not applicable Y Y 8 - UNKN - Unknown impact type Y Y
RO supports the proposal of ES that can better clarify the type of significant impact.
We have detected several reporting isuess related to this list in Spanish RBDs reporting, that could be solved by doint the list more 'human readable'. An easy way to make it more friendly is by adding a numerical code to each impact that relates it with the type of pressure that can produce it. As an example the first digit can represent 1.Pollution, 2.Hydrological changes 3. Morphology.... A proposal in this sense is shown below
Impact type Relevant SW Relevant GW 1.1 - NUTR - Nutrient pollution Y Y 1.2 - ORGA - Organic pollution Y Y 1.3 - CHEM - Chemical pollution Y Y 1.4 - SALI - Saline pollution/intrusion Y Y 1.5 - ACID - Acidification Y N 1.6 - TEMP - Elevated temperatures Y N 1.7 - MICR - Microbiological pollution Y Y 2.1 - HHYC - Altered habitats due to hydrological changes Y N 2.2 - HMOC - Altered habitats due to morphological changes (includes connectivity) Y N 3.1 - QUAL - Diminution of quality of associated surface waters for chemical / quantitative reasons N Y 3.2 - INTR - Alterations in flow directions resulting in saltwater intrusion N Y 3.3 - LOWT - Abstraction exceeds available groundwater resource (lowering water table) N Y 4.1 - ECOS - Damage to groundwater-dependent terrestrial ecosystems for chemical / quantitative reasons N Y 4.2 - LITT - Litter (an impact under the MSFD) Y N 5.1 - OTHE - Other significant impact type Y Y 6 - NOSI - No significant impact Y Y 7 - NOTA - Not applicable Y Y 8 - UNKN - Unknown impact type Y Y
RO supports the proposal of ES that can better clarify the type of significant impact.
NO supports ES and RO
Since the guidance says '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
we propose to extend the quality check (not only check consistency with status but with risk aswell)
Within-schema check: If (SWB/SWEcologicalStatus/SwEcologicalStatusOrPotentialValue is ‘3’, ‘4’ or ‘5’ or SWB/SurfaceWaterBody/swEcologicalStatusOrPotentialExpectedGoodIn2015=No), at least one significant impact type or the option ‘UNKN - Unknown impact type’ must be selected from the enumeration list . The option ‘NOSI - No significant impact’ is not a valid selection.
Within-schema check: If (SWB/SurfaceWaterBody/swChemicalStatusValue is ‘3’ or SWB/SurfaceWaterBody/swChemicalStatusExpectedGoodIn2015=No),, at least one significant impact type or the option ‘UNKN - Unknown impact type’ must be selected from the enumeration list. The option ‘NOSI - No significant impact’ is not a valid selection.
In order to make the list of impact types more readable, an option could be to delete the abbreviations and only keep the description of the impact type.
BE supports ES, LU and RO
swSignificantImpactOther - Conditional.
If ’ OTHE - Other significant impact type’ is selected from the enumeration list under swSignificantImpactType, provide details of any other impact types which are relevant in this element. This element should only be reported if the impact type is not included in the enumeration list under swSignificantImpactType.
(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.
Indicate whether over the years, a reduction or surplus of inflows due to natural causes have been noted (less/more annual precipitation, temperature rise…).
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?