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
2.4. Ecological status and exemptions
The WFD defines its Environmental Objectives in Article 4 and sets the aim for long term sustainable water management. Article 4(1) defines the WFD’s general objective to be achieved in all surface and groundwater bodies, i.e. good status (for natural water bodies) or potential (for Artificial or Heavily Modified Water Bodies) by 2015, and introduces the principle of preventing any further deterioration of status. A number of exemptions to the general objectives are possible under certain conditions.
- Article 4(4) allows for an extension of the deadline beyond 2015.
- Article 4(5) allows for the achievement of less stringent objectives.
- Article 4(6) allows a temporary deterioration in the status of water bodies.
- Article 4(7) sets out conditions in which deterioration of status or failure to achieve certain of the WFD Environmental Objectives may be permitted for new modifications to the physical characteristics of surface water bodies, and deterioration from high to good status may be possible as a result of new sustainable human development activities.
The WFD provides the general framework on exemptions but there is scope for differences in understanding and implementation. From the outset of implementation, it was clear that the use of exemptions needed to be explained further and the rules for application had to be made clearer. These clarifications can be found in the CIS Guidance Document No. 20: Exemptions to the Environmental Objectives published in 2009.
Annex V of the WFD specifies how Member States are to monitor and present overall ‘status’ classification for each of their water bodies in all water categories, as well as the status for each of the Biological Quality Elements (BQEs) / Quality Elements (QEs) used.
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In chapter 2.4.3.2 of the guidance is written:
Reporting of the status assessment of Quality Elements (QEs) is expected not only where monitoring results are available for specific water bodies but also for all water bodies for which this information is available (e.g. through grouping or extrapolation). A status value should, therefore, be given for each of the relevant QEs that have been assessed for the water body and subsequently used to classify the ecological status or potential of the water body.
If the status of QEs is not reported then it is assumed that it is not used in the classification of the ecological status of the water body.
This last sentence isn't correct for the RBSP. In this table you only can report the failing substances, not the substances that are good. There is no distinction between unknown status, not applicable and good status.
Overall remark, a more technical guidance how to group/extrapolate the status values in the water bodies where there are no monitoring results would be very helpfull.
Class: SurfaceWaterBody
- 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;
swEcologicalStatusOrPotentialValue - Required(EcologicalStatusCode_Enum).
Indicate the ecological status or potential of the surface water body, based on the most recently assessed status of the surface water body.
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The understanding of the information would benefit by doing the codelist more 'human readable'. An easy way to make it more friendly is by adding the textual information to the number. We have detected several cases in which High status was reported as 5 instead of one, because in the local system of the RBD it was undestood that ecological status was a list ranging from 5 to 1 instead of 1 to 5. As a general comment for the whole guidance, when possible it should be 'self explanatory'.
Value 1 - High status or maximum potential. 2 - Good status or potential. 3 - Moderate status or potential. 4 - Poor status or potential. 5 - Bad status or potential. U - Unknown NA - Not applicable GENERAL COMMENT
In order to better understand and use the database, the quality or optimization of the database design must be sacrificed a little, giving more weight to its logical understanding.
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The understanding of the information would benefit by doing the codelist more 'human readable'. An easy way to make it more friendly is by adding the textual information to the number. We have detected several cases in which High status was reported as 5 instead of one, because in the local system of the RBD it was undestood that ecological status was a list ranging from 5 to 1 instead of 1 to 5. As a general comment for the whole guidance, when possible it should be 'self explanatory'.
Value 1 - High status or maximum potential. 2 - Good status or potential. 3 - Moderate status or potential. 4 - Poor status or potential. 5 - Bad status or potential. U - Unknown NA - Not applicable GENERAL COMMENT
In order to better understand and use the database, the quality or optimization of the database design must be sacrificed a little, giving more weight to its logical understanding.
NO supports ES
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Next checks should be implemented:
The value reported must not be lower than any qeStatusOrPotentialValue reported in QualityElement for the surfaceWaterBody. (Implementation of the one out - all out principle)
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The guidance requires 5 categories of ecological status/potential, including “High status or maximum potential” and “Good status or potential” categories. Different categories “maximum potential” and “good potential” are not WFD compliant – there is a “good or better potential” category only – and might lead to an incorrect interpretation. (The category “maximum potential” should be applied only on a quality element level.)
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In the WFD the higher ecological potential classification is “good and above”. We propose to modify the EcologicalStatusCode_Enum as:
‘1’ = High status or maximum potential.'2' = Good status or good and above potential
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We support the comment made by IT.
swEcologicalAssessmentYear - Required.
Provide the year on which the assessment of status or potential is based. This may be the year that the surface water body was monitored. In case of grouping this may be the year in which monitoring took place in the surface water bodies within a group that are used to extrapolate results to non-monitored surface water bodies within the same group. A period is possible (e.g. 2011--2013).
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When a period is reported (e.g. 2010--2013), this information could mean different periods:
- 2010-2011-2013
- 2010-2012-2013
- 2010-2011-2012-2013,
Is it neccesary to specify? o is it enough with the first and the last year of the period?
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From year - to year is good enough
swEcologicalAssessmentConfidence - Required(Confidence_Enum).
Indicate the confidence on the ecological status or potential assigned
‘0’ = No information.
‘1’ = Low confidence.
‘2’ = Medium confidence.
‘3’ = High confidence.
The criteria used by Member States to assess confidence vary considerably, but general guidance may be: Low = no monitoring data; Medium = supporting QE data and/or limited data on one BQE; High = good data for at least one BQE and the most relevant supporting QE.
In case surfaceWaterBodyCategory is 'TeW', '0' should be selected and interpreted as 'Not applicable'.
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We suggest to made the codelist 'self explanatory'. See comments to swEcologicalStatusOrPotentialValue
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We suggest to made the codelist 'self explanatory'. See comments to swEcologicalStatusOrPotentialValue
NO supports ES
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swEcologicalStatusOrPotentialExpectedGoodIn2015 - Required(YesNoNotApplicable_Union_Enum).
Indicate whether it is expected that this surface water body will achieve good (or better) ecological status or potential by the end of 2015.
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We suggest that swEcologicalStatusOrPotentialExpectedGoodIn2015 be changed into swEcologicalStatusOrPotentialAchievedGoodIn2015.
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It is proposed to include explanatory diagrams with the logic of reporting. ie
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If it is relevant for 2021 we propose to add „unknown“ option.
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The information reported here should be referring to 2021 and the name of the schema element should be modified accordingly.
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NO supports ES on adding diagrams
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The schema element: swEcologicalStatusOrPotentialExpectedGoodIn2015. Maybe the name and description of the schema element should be changed. Of course the WFD requires from MS reaching a good status of waterbodies in 2015 but this report will be sent in 2021/2…
swEcologicalStatusOrPotentialExpectedAchievementDate - Conditional(GoodStatus_Enum).
If good ecological status or potential will NOT be achieved by 2015 (swEcologicalStatusOrPotentialExpectedGoodIn2015 is No), report the date by which it is expected that it will be achieved in full. The methodology of this assessment should be clearly explained in the RBMP or background documents (reference reported under classification methodologies). If good ecological status or potential will not be achieved by 2015, exemptions should be applied. Please report the date by which it is expected that good ecological status or potential will be achieved in full, not the date relating to individual exemptions. However, please note the following:
Article 4(4) exemptions relate to the extension of deadlines. According to Article 4(4)c of the WFD, postponing the achievement of objectives beyond 2027 is only possible due to natural conditions.
If Article 4(5) exemptions apply, report the date by when the less stringent objective is to be achieved. If the less stringent objective has already been achieved then select 'Less stringent objectives already achieved'. If good ecological status or potential will be achived by 2015 (swEcologicalStatusOrPotentialExpectedGoodIn2015 is Yes) this element should not be reported.
This element should not be reported if surfaceWaterBodyCategory is 'TeW' (territorial waters).
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We suggest that alternative objectives be added in the enumeration (pick up) list taking into account the objectives set for the exemptions under Art. 4.7. (see CIS Guidance no. 36).
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We have introduce incoherent combinations in the access database without getting blockers
swEcologicalStatusOrPotentialExpectedGoodIn2015
swEcologicalStatusOrPotentialExpectedAchievementDate
Yes
2016--2021
Yes
2022--2027
Although in the XML generation this field is ignored, the Access file that is the source of information in Spain remains unchanged and produces many problems when using it for statistical analysis.
Would it be possible to include checks in this sense in the Access database?
Next check should be implemented:
If swEcologicalStatusOrPotentialExpectedGoodIn2015 is ‘Yes’ this element must not be reported.
GENERAL COMMENT
The Quality checks should include not only a conditional check requiring a value when the condition is fulfilled, but also requiring the field to be left empty "NULL" when the condition is not fulfilled.
It can be implemented in the Access database by adding in all codelist a 'Not applicable' value required when the condition is not fulfilled.
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This field does not solve the problem when a WB has both 4(4) (time extension) and 4(5) (less stringent objective) exemptions.
The current codelist do not allow identifying cases when a SWB has 'less stringent objective already achieved' but it is not in compliance with all environmental objectives because of other quality element (without less stringent objective) but with a time extension (ie 2022-2027).
We suggest to split the field in two. Leaving this field as it is now but removing from the codelist 'less stringent objective already achieved'.
A new field should be included in order to report the achievement of less stringent objectives for quality elements with a 4(5) exemption.
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We propose to delete or re-write the part of guidance on completion of schema element concerning exemption Art. 4(4) – it is not clear, if extension of deadlines would be possible only due to natural conditions. In addition, exemption 4(7) is missing.
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In Chapter 2 swEcologicalStatusOrPotentialExpectedAchievementDate is based on the achievement of Good only – there is no provision for the target to be set as high (entering good waterbodies with a future objective date will return an error). 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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Will the European Commission add new target for 2028-2033? What about reporting for Mayotte?
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NO finds it good as it is. For us it does not give a meaning to have both 4(4) and 4(5) for the same WB.
Class: FailingRBSP (child of SurfaceWaterBody)
- 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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We propose to add new Quality check
the guidance states:
Conditional check: Report if, in Class 'QualityElement', qeStatusOrPotentialValue='3' when qeCode='QE3-3 - River Basin Specific Pollutants'.
The previous check is insufficient because it only ensures consistency in one direction (from 'QualityElement' to 'FailingRBSP'), but it is also necessary to ensure it in the opposite direction (from 'FailingRBSP' to 'QualityElement'), that is:
This field should be left empty if
- in Class 'QualityElement', qeStatusOrPotentialValue<>'3' or
- in Class 'QualityElement', qeStatusOrPotentialValue='3' AND qeCode<>'QE3-3 - River Basin Specific Pollutants'.
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We propose to add new Quality check
the guidance states:
Conditional check: Report if, in Class 'QualityElement', qeStatusOrPotentialValue='3' when qeCode='QE3-3 - River Basin Specific Pollutants'.
The previous check is insufficient because it only ensures consistency in one direction (from 'QualityElement' to 'FailingRBSP'), but it is also necessary to ensure it in the opposite direction (from 'FailingRBSP' to 'QualityElement'), that is:
This field should be left empty if
- in Class 'QualityElement', qeStatusOrPotentialValue<>'3' or
- in Class 'QualityElement', qeStatusOrPotentialValue='3' AND qeCode<>'QE3-3 - River Basin Specific Pollutants'.
NO supports this
swFailingRBSP - Required (RBSP_Enum).
If the status or potential of QE 3-3 River Basin Specific Pollutants is less than good (as reported in class QualityElement, see below), select the code and name of the RBSP.
The RBSPs selected from the enumeration list must be included in the methodology schema (SWMET/SWRBSP/rbsp) where details of all RBSPs’ good-moderate EQS are reported, i.e. the RBSPs reported in this element are those that are failing their associated good-moderate EQS in this surface water body.
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Changes in the list of specific pollutants between cycles should be avioded or communicated early in the cycle. For instance the way some substances are grouped. If this changes in mid cycle when classifications are performed there will be much work in trying to report.
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There is no distinction between the good status of an RBSP and the unknown status of an RBSP in a SWB. At this moment, the conclusion in the assessment reports is : when there is no reported failing for a RBSP in a SWB, the status for this RBSP is good in this SWB.
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There is no distinction between the good status of an RBSP and the unknown status of an RBSP in a SWB. At this moment, the conclusion in the assessment reports is : when there is no reported failing for a RBSP in a SWB, the status for this RBSP is good in this SWB.
Please ad also the substances that are in a good status
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swFailingRBSPOther - Conditional.
Report CAS number and name of the RBSP failing if not on the enumeration list under swFailingRBSP.
Class: SWEcologicalExemptionType (child of SurfaceWaterBody)
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We suggest to simplify the reporting of some datasets, by excluding of the implicit information - not to report the SWBs without exemptions (“No exemptions” option ); to report only the SWBs for which exemptions are applied ( For Danube RBD in BG, 58% of the records in this table were reported as “No exemptions”)
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We suggest to simplify the reporting of some datasets, by excluding of the implicit information - not to report the SWBs without exemptions (“No exemptions” option ); to report only the SWBs for which exemptions are applied ( For Danube RBD in BG, 58% of the records in this table were reported as “No exemptions”)
EL supports the BG suggestion
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"No exemption" is also data and needed in the XML
swEcologicalExemptionType - Required.(ExemptionType_Enum)
Report which type(s) of exemption(s) apply if good ecological status or potential is not expected to be achieved by 2015. More than one exemption may apply to a surface water body.
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To report only the SWBs with exemptions and to eliminate the WBs with “No exemption”; we tried to not report/we try to eliminate the WBs with “No exemption”, but a reporting error occurred.
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It is required to fill-in all QEs , not only ones related to SWB for which exemptions are applied. We suggest to simplify the reporting - to report only the QEs, related to the SWB for which exemptions are applied – in order to avoid the reporting of a large amount of QEs for which “No exemption” was reported. (For Danube RBD in Bulgaria, the records containing QEs reported as “No exemptions” form 91% out of all 4953 records. )
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It is required to fill-in all QEs , not only ones related to SWB for which exemptions are applied. We suggest to simplify the reporting - to report only the QEs, related to the SWB for which exemptions are applied – in order to avoid the reporting of a large amount of QEs for which “No exemption” was reported. (For Danube RBD in Bulgaria, the records containing QEs reported as “No exemptions” form 91% out of all 4953 records. )
RO supports the BG suggestion.
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It is required to fill-in all QEs , not only ones related to SWB for which exemptions are applied. We suggest to simplify the reporting - to report only the QEs, related to the SWB for which exemptions are applied – in order to avoid the reporting of a large amount of QEs for which “No exemption” was reported. (For Danube RBD in Bulgaria, the records containing QEs reported as “No exemptions” form 91% out of all 4953 records. )
RO supports the BG suggestion.
EL supports the BG suggestion
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We support the comment from RO.
We reported only those WBs for which exemptions needed to be appied and a reporting error occurred for the WBs which had reached good status in 2015 and therefore no exemption was applied for them. Only the WBs with exemptions should be reported here.
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Should we add the following tests :
- If the water body is in good status, then the element should be "no exemption"
- If the water body is in unknown status, the element should be "no exemption" or we could add "unknown"
For Mayotte, is it possible to maintain the postposne of deadline?
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We want to keep it as it is.
swEcologicalExemptionPressure - Conditional. (SignificantPressureType_Enum)
If any Article 4(4), Article 4(5) and/or Article 4(7) exemptions apply to this surface water body for ecological status, report the significant pressure(s) that are causing failure in order to justify the exemption(s).
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To report only the SWBs with exemptions and to eliminate the WBs with “No exemption”; we tried to not report/we try to eliminate the WBs with “No exemption”, but a reporting error occurred.
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There are no adequate quantified results available on remediating actions (and related pressures) to achieve the good ecological status. Ecological status is a very complex process especially in waterbodies subject to multiple pressures (hydromorphological, physico-chemical and chemical pollution). There is no straight forward relation between pressure-status-effects of measures (ecological impact).
The level of detail to report is more detailed than requested by the WFD.
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There are no adequate quantified results available on remediating actions (and related pressures) to achieve the good ecological status. Ecological status is a very complex process especially in waterbodies subject to multiple pressures (hydromorphological, physico-chemical and chemical pollution). There is no straight forward relation between pressure-status-effects of measures (ecological impact).
The level of detail to report is more detailed than requested by the WFD.
RO supports BE Flanders point of view.
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We support the comment form BE-FI.
As detailled information on pressures are reported in schema element "swSignificantPressureType" we don't see the added value to report such information here. Besides the choice of exemptions to be applied is usually based on the whole "set" of pressures which a WB is subject to and therefore it is not always easy to link the exemption to a concrete set of pressure-driver (especially as we think that the list of pressure types in annex 1a is too detailled).
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We wish to keep it as it is.
Class: QualityElement(child of SurfaceWaterBody)
- 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 order to simplify the reporting, we suggest to:
- eliminate the table QualityElement_qeGrouping and to include this information as a schema element in the table Quality Element and
- to apply/create a conditionality, respectively QualityElement_qeGrouping be reported only if in the schema element qeMonitoringResults, the “grouping” is selected/used from the enumeration list.
Also we suggest that the structure of this table be similar to the one from the WISE – 1stRBMPlan (SWEco_StatusorPotential) where the information was presented in the column and not in the rows in order to be easier for visualing and tracking.
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GENERAL COMMENT
In order to better understand and use the database, the quality or optimization of the database design must be sacrificed a little, giving more weight to its logical understanding.
The concepts of the WFD: Ecological status SW, Chemical status SW, Quantitative status GW, Chemical status GW should have a similar treatment in the database.
In this case the class QualityElement for SW EcoStatus should be equivalent to SWPrioritySubstance for SW ChemStatus.
In the case of GW the equivalent classes should be GWPollutant for GW chemical status and an equivalent class for GW quantitative status that doen't exist as the information related to quantitative satatus is directly stored in the class GroundWaterBody.
The design is not incorrect but really difficult to be undestood.
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It is required to “select in turn each of the quality elements”; not only the relevant QE at SWB level.
We suggest to simplify this Class - only the QEs, relevant for the SWB-type, to be reported ( to avoid the reporting of “not applicable” QEs - for BG Danube RBD these records form 31,5% out of all 4864 records).
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Surface water bodies classified by grouping should not be included in this Class that should be compiled only for monitored quality element. The status derived by grouping should be assigned to the surfacewaterbody and not to each QE.
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We can keep it as it is, since we just pull the data from the database, though we get many rows - 536598 in all
qeCode - Required. (StatusQE_Enum)
Select in turn each of the quality elements once and provide the associated information.
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In the text of the guidance it would be more clear if we add in the Quality check the underlined text.
Quality checks: Information for all quality elements should be provided. Each quality element should be chosen only once per water body.
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The reporting requirements changed between cycles regarding elements. In reporting 2010 the element General conditions, Q3-1, were reported. In reporting 2016 it was changed to the 3 number level (QE3-1-1 to 5) and even to the 3 number level for nutrients (QE3-1-6-1). This affects the way these elements are classified. The method in Sweden för classifying nutrients does not distinguish between N and P. So it is not possible to report the status classification on nutrients in a proper manner.
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table Schema: SWB (continued); Schema element: qeCode, Field type / facets: StatusQE_Enum (see Annex 8h)
Proposed change:
We suggest adding quality element QE1-2-5 ‒ Macrophytes and phytobenthos to the table StatusQE_Enum in Annex 8h.
Explanation for the proposed change:
According to Slovenian methodology for ecological status assessment using phytobenthos and macrophytes, phytobenthos and macrophytes are defined as one biological element in accordance with Water Framework Directive. According to the methodology, classification of ecological status is not done separately for sub-elements but combination of both is used in the classification. Therefore, we cannot report ecological status for elements QE1-2-3 ‒ Macrophytes and QE1-2-4 ‒ Phytobenthos so we suggest adding element QE1-2-5 ‒ Macrophytes and phytobenthos to the table StatusQE_Enum in Annex 8h.
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table Schema: SWB (continued); Schema element: qeCode, Field type / facets: StatusQE_Enum (see Annex 8h)
Proposed change:
We suggest adding quality element QE1-2-5 ‒ Macrophytes and phytobenthos to the table StatusQE_Enum in Annex 8h.
Explanation for the proposed change:
According to Slovenian methodology for ecological status assessment using phytobenthos and macrophytes, phytobenthos and macrophytes are defined as one biological element in accordance with Water Framework Directive. According to the methodology, classification of ecological status is not done separately for sub-elements but combination of both is used in the classification. Therefore, we cannot report ecological status for elements QE1-2-3 ‒ Macrophytes and QE1-2-4 ‒ Phytobenthos so we suggest adding element QE1-2-5 ‒ Macrophytes and phytobenthos to the table StatusQE_Enum in Annex 8h.
We need macrophytes and Phytobentos separate, so we want to keep it as it is
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It should be avoided to report the QEs that are “Not applicable” for each surface water category.
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It should be avoided to report the QEs that are “Not applicable” for each surface water category.
There must be a distinguish between 'not applicable' and 'unknown'.
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qeStatusOrPotentialValue - Required. (QEStatusCode_Enum)
Indicate the results of the assessment of this QE for all relevant surface water categories.
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Same comment as for swEcologicalOrPotentialValue.
The understanding of the information would benefit by doing the codelist more 'human readable'. An easy way to make it more friendly is by adding the textual information to the number. We have detected several cases in which High status was reported as 5 instead of one, because in the local system of the RBD it was undestood that ecological status was a list ranging from 5 to 1 instead of 1 to 5. As a general comment for the whole guidance, when possible it should be 'self explanatory'.
Value 1 - High status or maximum potential. 2 - Good status or potential. 3 - Moderate status or potential. 4 - Poor status or potential. 5 - Bad status or potential. U - Unknown NA - Not applicable GENERAL COMMENT
In order to better understand and use the database, the quality or optimization of the database design must be sacrificed a little, giving more weight to its logical understanding.
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Supporting ES
qeMonitoringResults - Conditional. (MonitoringResults_Enum)
If the status is reported, indicate on what basis the status classification was derived:
'Monitoring': means the QE was monitored in this surface water body and the results are used as a basis for classification.
‘Grouping’: the QE was not monitored in this surface water body. Monitoring from other similar water bodies was used as a basis for classification, as described in the methodology for classification.
'Expert judgement': the QE was not monitored in this surface water body. Results from other similar water bodies were not used. The QE status is mainly based on expert judgement.
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Missing from Enum list: modelling and/or statistical analysis of pressure and impacts which is more accurate than expert judgement.
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We missed this one, so supporting HU
qeMonitoringPeriod - Conditional.
If the QE was monitored and the classification was derived from the monitoring data available, indicate the year/period of the monitoring data which was used in the classification.
qeGrouping - Conditional.
If no monitoring data is available for this surface water body and status has been derived through grouping by extrapolating monitoring data from other surface water bodies, indicate the codes of the surface water bodies which have been monitored and used in grouping.
For example, if the status of surface water body A has been determined by extrapolating monitoring data from surface water bodies B and C, then the euSurfaceWaterBodyCode for surface water bodies B and C should be reported in this element.
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Please, in order to avoid misundarstanding, add to the explanatory text, the text underlined:
If no monitoring data is available for this quality element in this surface water body and status has been derived through grouping by extrapolating monitoring data from other surface water bodies, indicate the codes of the surface water bodies which have been monitored and used in grouping.
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Please, in order to avoid misundarstanding, add to the explanatory text, the text underlined:
If no monitoring data is available for this quality element in this surface water body and status has been derived through grouping by extrapolating monitoring data from other surface water bodies, indicate the codes of the surface water bodies which have been monitored and used in grouping.
RO supports ES suggestion, it is useful to mention also "quality element" in the explanatory text.
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In this way it is reported that the classification is based on grouping and it is possible to se if the grouped water is of same category, type and pressure situation. And is situated in the same RBD. The groups ar only indirectly reported. Could be enough.
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In this way it is reported that the classification is based on grouping and it is possible to se if the grouped water is of same category, type and pressure situation. And is situated in the same RBD. The groups ar only indirectly reported. Could be enough.
In some cases, it is possible to group SWB for fysical-chemical QE, but not biological QE or hydromophological QE. So BE want to maintain the grouping by QE.
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To be in line with comment on class QualityElement, this schema element should be for surfacewaterbody and not for each QE of surfacewaterbody.
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Due to the large number of RBDs and because the grouping is performed at national level, in Greece there are several cases where the (monitored) surface water bodies which are used in grouping are part of a different RBD (different database). Could there be an option to indicate the codes of surface water bodies (used in grouping) of different RBDs, in order to avoid to include this information in Annex 0?
qeStatusOrPotentialChange - Required. (ValueQEX_StatusOrPotentialChange_Enum)
If the information is available and if there has been a change in classification since the first RBMP was reported, report that change. Otherwise, report ‘No_information’. This covers all cases in which it is not possible to identify a change between 2010 and 2016, for example, new Water Bodies, for which there is no correspondence in the 2010 reporting or new reporting (as is the case for Norway).
qeStatusOrPotentialComparability - Conditional. (SoPComparability_Enum)
If there has been a change in classification since the first RBMP was reported, indicate whether the reported change in status or potential is considered as being/due to the list of the EnumValues.
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They are missing from Enum list:
1. inconsistent due to changes to water body delineation;
2. inconsistent due to changes to limit value (in case of RBSPs)-
They are missing from Enum list:
1. inconsistent due to changes to water body delineation;
2. inconsistent due to changes to limit value (in case of RBSPs)RO supports HU suggestion. The option 1. inconsistent due to changes to water body delineation should be added to the enumeration list for qeStatusOrPotentialComparability.
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qeEcologicalExemptionType - Required. (ExemptionType_Enum)
Report which type(s) of exemption(s) apply to this surface water body and QE. More than one exemption may apply.
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Having in view the complexity of this issue on forecasting the exemptions at quality element level and the existing justified uncertainty regarding the pressures and biological responces we suggest either:
- to become optional or
- to allow a reporting similar to WISE of 1stRBMPlan at level QE0- Ecological, QE1-Biological, QE3-Chemical and physico-chemical, QE3-3 Non priority specific pollutants, Q E3-4 Other national pollutants or 3. to eliminate this table, having in view that this info was not relevant/included in the context of EC assessment of the 2nd RBMPlans.
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Usually exemption(s) apply if good status or potential is not expected to be achieved by 2015 (risk), and it is necessary to report the significant pressure(s) that are causing failure in order to justify the exemption(s).
In this case it is not necessary to report pressure (is it correct or a mistake??)
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Ecological status is a very complex process especially in waterbodies subject to multiple pressures (hydromorphological, physico-chemical and chemical pollution). There is no straight forward relation between pressure-status-effects of measures (ecological impact). The failing to achieve good status is in most cases a combination of disproportionate costs and technical reasons. Due to the uncertainty on the effects of different measures on different pressures it is not possible to generate information on the type of exemption per quality element. The level of detail to report is more detailed than requested by the WFD.
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Ecological status is a very complex process especially in waterbodies subject to multiple pressures (hydromorphological, physico-chemical and chemical pollution). There is no straight forward relation between pressure-status-effects of measures (ecological impact). The failing to achieve good status is in most cases a combination of disproportionate costs and technical reasons. Due to the uncertainty on the effects of different measures on different pressures it is not possible to generate information on the type of exemption per quality element. The level of detail to report is more detailed than requested by the WFD.
RO supports the BE Flanders point of view.
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We share the same position position as Belgium.
Ecological status is a very complex process especially in waterbodies subject to multiple pressures (hydromorphological, physico-chemical and chemical pollution). There is no straight forward relation between pressure-status-effects of measures (ecological impact). The failing to achieve good status is in most cases a combination of disproportionate costs and technical reasons. Due to the uncertainty on the effects of different measures on different pressures it is not possible to generate information on the type of exemption per quality element. The level of detail to report is more detailed than requested by the WFD.
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Ecological status is a very complex process especially in waterbodies subject to multiple pressures (hydromorphological, physico-chemical and chemical pollution). There is no straight forward relation between pressure-status-effects of measures (ecological impact). The failing to achieve good status is in most cases a combination of disproportionate costs and technical reasons. Due to the uncertainty on the effects of different measures on different pressures it is not possible to generate information on the type of exemption per quality element. The level of detail to report is more detailed than requested by the WFD.
We agree with this comment.
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to be consistent with comments on qeGrouping, also for the exemption is not possible to assign to each QE.
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We support the comment made by BE-Fl.
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We wish to keep it as it is
In chapter 2.4.2.1. the source of data and the way of thier aggregarion in oder to preparation report „Percentage of surface water bodies of unknown status” has not been provided and needs to be completed.
For reporting and data collection on nitrogen and phosphorus compounds "Trend in median (a) total ammonium, (b) total phosphorus, and (c) nitrate concentrations of river water bodies, grouped by the ecological status / potential class" national reporting methods of their measurements should be considered. The WISE system must enable the administration of test results, both in the form of N and P concentrations, as well as real ions (Poland reports the results as N and P concentrations, which allows better verification of the obtained results by increasing the quality of data). The reporting system must enable unambiguous definition of how to report these values, so that they can be correctly converted into reporting purposes.