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swPrioritySubstanceCausingFailure - Required. (YesNoCode_Enum)
Indicate if the priority substance is causing failure to achieve good chemical status.
Information on exceedances from ubiquitous substances should be reported.
For substances for which EQS were made more stringent in the 2013 amendment of the EQS Directive (Anthracene, Brominated diphenylethers, Fluoranthene, Lead and its compounds, Naphthalene, Nickel and its compounds and Polyaromatic hydrocarbons (PAH)), exceedances of either the 2008 EQS or the 2013 EQS, or both, should be reported here. Exceedances of the latter should be reported even when swChemicalStatusValue is good on the basis of the less stringent 2008 standards, in order to enable the reporting of swPrioritySubstanceExceedanceType and, if appropriate, of swChemicalExemptionType and swChemicalExemptionPressure. The substances causing exceedances to the 2013 EQSs but not to the 2008 EQSs should also be reported under schema element swEffectStatusNewThresholds. See table at the end of this section of the guidance on different scenarios for these substances and the corresponding reporting values.
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Previous comments
We propose to add a new Quality check
the guidance states:
If swChemicalStatusValue is ‘3’, at least 1 substance should be reported as ‘Yes’ in swPrioritySubstanceCausingFailure.
The previous check is insufficient because it only ensures consistency in one direction (from 'SurfaceWaterBody' to 'SWB_SWPrioritySubstance'), but it is also necessary to ensure it in the opposite direction(from 'SWB_SWPrioritySubstance' to 'SurfaceWaterBody'), that is:
Every surfacewaterbody being reported as ‘Yes’ in this element must be reported as swChemicalStatusValue=‘3’.
This field swPrioritySubstanceCausingFailure should be='No' if
In our opinion, it is not necessary to add other quality check. Surface water body code is included in both table, so it is enough for quality check.
It would be easier to have one reporting element for status according EQSD 2008 and another according EQSD 2013
HU: Agreed, Hungary supports and in addition if new amendments will be adopted than this rule should be consequently applied.
We suggest to change the text, considering the fact that the 2021 chemical status should be assessed according to the 2013 EQS, e.g exceedances of the 2013 EQS should be reported
In order to be able to compare the data reported by the MS, it would be helpful do add the information if the PS leading to the failure of good status had been monitored in water or biota (e.g. add a new schema element or add the option "Biota EQS" in schema element "swPrioritySubstanceExceedanceType").