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
2.5. Chemical status of surface waters, exemptions and Mixing Zones
‘Good surface water chemical status’ means the chemical status required to meet the Environmental Objectives for surface waters established in Article 4(1)(a) of the WFD, that is the chemical status achieved by a body of surface water in which concentrations of pollutants do not exceed the environmental quality standards (EQS) established in Annex IX and under Article 16(7), and under other relevant Community legislation setting EQS at Community level. It should be noted that under Article 2(1) of the WFD, territorial waters are included for the assessment and reporting of chemical status.
Decision 2455/2001/EC of the European Parliament and of the Council of 20 November 2001 established the list of Priority Substances in the field of water policy. The Decision identified the substances for which EQS were to be set at Community level which was implemented by means of Directive 2008/105/EC (the EQS Directive (EQSD)). Eight other pollutants that were regulated by Directive 76/464/EEC were also incorporated into the assessment of chemical status.
The EQSD includes a number of other obligations relating to Priority Substances, in particular the trend monitoring of certain Priority Substances in sediment or biota (Article 3(3) EQSD) and the establishment of an inventory of emissions, discharges and losses (Article 5 EQSD, see also Section 9.2).
Directive 2009/90/EC (the QA/QC Directive) on the quality and comparability of chemical monitoring specifies minimum performance criteria to ensure the quality of the analytical results. The deadline for transposition of the QA/QC Directive into national legislation was 21 August 2009, just before the adoption of the first RBMPs.
Directive 2013/39/EU, amending the WFD and EQSD as regards Priority Substances, was adopted on 12 August 2013. The revised EQSs for existing Priority Substances should be taken into account for the first time in RBMPs covering the period 2015 to 2021. The newly identified Priority Substances and their EQSs should be taken into account in the establishment of supplementary monitoring programmes and in preliminary Programmes of Measures to be reported by Member States by the end of 2018.
With the aim of achieving good surface water chemical status, the revised EQSs for existing Priority Substances should be met by the end of 2021 and the EQSs for newly identified Priority Substances by the end of 2027. This is without prejudice to Article 4(4) to (9) of the WFD, which includes inter alia provisions for extending the deadline for achieving good surface water chemical status or achieving less stringent Environmental Objectives for specific bodies of water on the grounds of disproportionate cost and/or socio-economic need, provided that no further deterioration occurs in the status of the affected bodies of water.
The determination of surface water chemical status by the 2015 deadline laid down in Article 4 of the WFD should be based, therefore, only on the substances and EQSs set out in the EQSD in the version in force on 13 January 2009 unless those EQSs are stricter than the revised EQS under Directive 2013/39/EU, in which case the revised (less strict) EQSs should be applied.
However, Directive 2013/39/EU requires Member States to achieve good chemical status by 2021 for those existing substances for which a more stringent standard has been adopted. This would require that an assessment is included in the second RBMPs to be adopted in 2015 on the basis of the new EQSs and, if necessary, measures should be included in the Programmes of Measures to be operational by 2018 at the latest.
Directive 2013/39/EU allows that, with regard to the presentation of chemical status for the purposes of the update of the Programmes of Measures and the RBMPs to be carried out in accordance with Article 11(8) and Article 13(7) of the WFD, respectively, Member States should be allowed to present separately the impact on chemical status of newly identified Priority Substances and of existing Priority Substances with revised EQSs. This is so that the introduction of new requirements is not mistakenly perceived as an indication that the chemical status of surface waters has deteriorated. In addition to the obligatory map covering all substances, additional maps could be separately provided covering newly identified substances, existing substances with revised EQSs, substances behaving like ubiquitous PBTs, and all other substances.
The EQSD also contains a provision regarding the possibility of designating Mixing Zones (Article 4 EQSD). This is linked with the so-called ‘combined approach’ (Article 10 WFD). Effluent discharge control regimes are normally designed to ensure that concentrations of Priority Substances or other pollutants in the receiving water do not exceed the EQS. However, if their concentration in the effluent is greater than the EQS value at the point of discharge there will be a zone of EQS exceedance in the vicinity of the point of discharge. Article 4 of the EQSD allows Member States to permit such zones of exceedance in water bodies when a number of criteria are met:
- Mixing Zones may be designated adjacent to points of discharge within which concentrations of one or more substances listed in Part A of Annex 1 of the EQSD may exceed the relevant EQS provided that they do not affect the compliance of the rest of the surface water body with those EQS.
- The Mixing Zones should be restricted to the proximity of the discharge and be proportionate.
- Certain information (such as on the approaches and methodologies applied to define such Mixing Zones; and on the measures taken with a view to reducing the extent of the Mixing Zones in the future) should be provided in the RBMPs (see also Section 4).
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The whole chapter should be updated, because the Directive 2008/105/EC will not be relevant.
Supported by NO
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The whole chapter should be updated, because the Directive 2008/105/EC will not be relevant.
Supported by NO
supported by BE
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Yes, the situation regarding chemichal status cycle 2 were a bit troublesome. The EQS changed for some substancess which disturbed the classification process and the reporting were also made complicated regarding what EQS version should be starting point. And in practise classification had to be done with both versions to be able to compare. These kind of changes should be syncronized with the management cycles. Performing the tasks of the management cycle is a verry big job. The prerequisite need to be set at in due time before or at the latest in the start of a management cycle. The reporting demands must be clear in advance of the end of the managment cycle when ther are changes that affects the way the management should be carried out. Verry hard to modify the performed management in order to be able to report.
Class: SurfaceWaterBody (SWB chemical status)
- 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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Comment on reporting chemical status for water matrix and for biota
The whole chapter should be complemented with the options to report separately chemical status for water matrix and separately for biota.
Products, proposed in chapter 2.5.2 are not comperable between countries, because some MS already have biota monitoring and other use different approaches for the assessment (for example: modelling on the basis of pressures).
Comparison of chemical status of surface waters in EU countries, obtained on the basis of different data (with and without biota monitoring), is not appropriate and can be misleading.
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Comment on reporting chemical status for water matrix and for biota
The whole chapter should be complemented with the options to report separately chemical status for water matrix and separately for biota.
Products, proposed in chapter 2.5.2 are not comperable between countries, because some MS already have biota monitoring and other use different approaches for the assessment (for example: modelling on the basis of pressures).
Comparison of chemical status of surface waters in EU countries, obtained on the basis of different data (with and without biota monitoring), is not appropriate and can be misleading.
HU: Agreed, Hungary supports
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We support the comment made by Sl.
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If the chemical status without ubiquitous substances should be reported, one could add a schema element in this class (e.g. swChemicalStatusValueWithoutUbiquitousSubstances). Besides, if a change in the evaluation of the chemical status appears, a second schema element could be added in order to indicate which ubiquitous substances are leading to the failure of good chemical status.
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NO finds the SL proposal to be a too drastic change in the data model. We do not support the change
swChemicalStatusValue - Required.(StatusCode_Enum)
Indicate the chemical status of the water body.
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The Guidance should clarify how ubiquitous substances are considered.
If 'Poor status' is due to ubiquitous substances, it can be reported as:
- Good status and expresing in another field that it is Good but with problems due to ubiquitous substances
- Poor status, expressing in another field that it is only due to ubiquitous substances
Both aproaches have advantages and disadvantages, but it should be clearly stated how to deal with this issue.
The solution adopted should be in line with the one taken in Class SWPrioritySubstance/swPrioritySubstanceCausingFailure
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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
HU: It is advantageous if the code list is self-explanatory, but it is more important to be the same throughout all WISE and EEA reporting!
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In order to avoid any confusion, we suggest to use, derived from the enumeration list used for ecological status, the following options:
2 = Good status
5 = Failing to achieve good status
Unknown = Unknown status
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We want to keep it as it is
swChemicalAssessmentYear - Required.
Provide the year on which the assessment of status 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).
swChemicalAssessmentConfidence - Required. (Confidence_Enum)
Indicate the confidence on the chemical status assigned.
swChemicalMonitoringResults - Conditional. (MonitoringResults_Enum)
Indicate on what basis the status classification was derived.
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is it possible to add in the enumeration list combination monitoring/ grouping?
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This is cross checked with the monitoring schema.
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Missing from Enum list:
modelling and/or statistical analysis of pressures and impacts-
Missing from Enum list:
modelling and/or statistical analysis of pressures and impactsEL supports this comment
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Missing from Enum list:
modelling and/or statistical analysis of pressures and impactsNO supports this
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swChemicalStatusGrouping - 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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Gropuping is not carried out at WB level but at QE (for ecological status), or priority substance level (for chemical status).
The element should be moved to the Class: SWPrioritysubstance (but as it is now it does't either fit in SWProritysubtance class because it is not the equivalent to the Qualityelement Class for Ecological status), an the explanatory text should be changed adding the underlined text to:
If no monitoring data is available for this Priority Substance 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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Gropuping is not carried out at WB level but at QE (for ecological status), or priority substance level (for chemical status).
The element should be moved to the Class: SWPrioritysubstance (but as it is now it does't either fit in SWProritysubtance class because it is not the equivalent to the Qualityelement Class for Ecological status), an the explanatory text should be changed adding the underlined text to:
If no monitoring data is available for this Priority Substance 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.
HU: Reporting of grouping should be allowed at both aspects: between WB-s and at QE levels, e.g. chemical status or supporting physico-chemical status.
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It is true that grouping will be at QE and/or substance level (or group of substances) Leaving this element in the current class gives no clear information to report because the reported list of waterbodie(s) code(s) it is unknown which parameters are used for grouping. But it may not be the bests sollution to move this element, it will be to much detailled reporting. Maybe it can be considered to delete this element. Then the previous element swChemicalMonitoringResults gives an indication for the status assessment whether grouping is used or not.
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Due to the large number of RBDs and because 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 incude this information in Annex 0?
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If it can be done easily, NO supports the ES proposal
swChemicalStatusExpectedGoodIn2015 - Required. (YesNoCode_Enum)
Indicate whether it is expected that this surface water body will achieve good chemical status by the end of 2015.
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The new date to be considered will be 2021.
swChemicalStatusExpectedAchievementDate - Conditional. (GoodStatus_Enum)
If good chemical status will NOT be achieved by 2015 (swChemicalStatusExpectedGoodIn2015 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 chemical status will not be achieved by 2015, exemptions should be applied. Please report the date by which it is expected that good chemical status 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 two further updates of the river basin management plan 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 chemical status will be achieved by 2015 (swChemicalStatusExpectedGoodIn2015 is Yes) this element should not be reported.
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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 have introduce incoherent combinations in the access database without getting blockers
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 swChemicalstatusExpectedGoodIn2015 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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It could be interesting to have new achievement date for new chemicals 2028-2033 and 2034-2039 (and also in the case of exemptions for natural conditions).
How do we report for Mayotte, cuold we adopt the same system as previously : 2022-2027 meaning 2028-2033, 2028-2033 meaining 2034-2039, etc.?
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We want to keep it as it is. A WB cannot logically have both exemptions 4(4) and 4(5)
swMixingZones - Optional. (YesNoCode_Enum)
Report whether Mixing Zones have been designated in the surface water body.
swMixingZonesProportion - Optional.
Report the percentage of length or area of the surface water body that has been designated as a Mixing Zone.
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The same mixing zone can cover or be part of more than one WB, it’s not reported.
Class: SWPrioritySubstance (child of SurfaceWaterBody - chemical status)
- 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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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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The reporting would be much easier to understand if the valid cycle EQS was stated and the base. Then an extra reporting element could have been some thing like "status according EQSD 2013" relevant only for the quality elements with altered eqs.
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There is no distinction between the good status of an PS and the unknown status of an PS in a SWB. At this moment, the conclusion in the assessment reports is : when there is no reported failing for a PS in a SWB, the status for this PS is good in this SWB.
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There is no distinction between the good status of an PS and the unknown status of an PS in a SWB. At this moment, the conclusion in the assessment reports is : when there is no reported failing for a PS in a SWB, the status for this PS is good in this SWB.
Please ad the option 'unknown'
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It was rather difficult for us to report data for this class as different "concepts" had been included and had been combined. We would suggest to split it up (e.g. a separate class for reporting the effect of new EQSs on the status assessment) and include one class per "concept" that needs to be reported.
swPrioritySubstanceCode - Required. (PS_Enum)
Select each priority substance for which one or more of the circumstances defined in the list of EnumValues occur in the relevant water body
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The list of Priority Substances in PS_Enum (Annex 8d) is not the Directive 2013/39/EU compliant: benzo(g,h,i)-perylene (CAS_191-24-2) is missing – listed only as „EEA_32-24-6 - Total Benzo(g,h,i)-perylene (CAS_191-24-2) + Indeno(1,2,3-cd)-pyrene (CAS_193-39-5)“ as in the Directive 2008/105/EC.
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Enumeration list need to be updated.
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Enumeration list need to be updated.
RO supports the proposal of NL.
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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. The PAHs and cyclodiene pesticides as examples.
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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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
- swChemicalStatusValue <>'3'
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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
- swChemicalStatusValue <>'3'
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.
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It would be easier to have one reporting element for status according EQSD 2008 and another according EQSD 2013
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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.
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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
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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").
swPrioritySubstanceExceedanceType - Conditional. (EQStandardType_Enum)
For each Priority Substance exceeding EQS, indicate which EQS is exceeded.
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It should be added ''biota EQS'' in pick-up list.
Please see the provisions of art. 2 of the Directive 2013/39 ("For the substances numbered 5, 15, 16, 17, 21, 28,
34, 35, 37, 43 and 44 in Part A of Annex I, Member States shall apply the biota EQS laid down in Part A of Annex I). So, in the table "SWPrioritySubstance", we suggest including additional ' Biota EQS' in pick-up list of the column "swPrioritySubstanceExceedanceType" , such as: 'AA EQS' = Annual Average of the EQS; 'MAC EQS' = Maximum Allowable Concentration of the EQS; 'Both' = Both and ' Biota EQS'. -
We support the comment from RO (see our comment under "swPrioritySubstanceCausingFailure").
swPrioritySubstanceImprovingChemicalStatus - Required.(YesNoCode_Enum)
Report whether the Priority Substance improved from poor to good chemical status since the first RBMP. For the Priority Substances for which the EQSs have changed in the 2013 amendment of the EQS Directive (2013/39/EU), the improvement should refer to the 2008 EQS.
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Risk analysis was performed in a way to estimate risk of failure of chemical status. However the analysis was not provided for certain causing substance but as a whole chemical status.
For reporting chemical status improvement in case that there is estimation of risk of failure of chemical status in one planning cycle and results of the priority substance level in other planning cycle the comparison can be done only generally for chemical status as a whole.
swPrioritySubstanceEffectStatusNewThresholds - Required. (YesNoNotApplicable_Union_Enum)
If the priority substance is one of the seven for which more stringent EQSs were adopted in Directive 2013/39/EU, indicate if the new standard caused the status of the surface water body to appear to deteriorate. If not one of the seven report ‘Not applicable’.
The assessment of failure according to the new, more stringent standards is relevant for the purpose of meeting the 2021 good chemical status objective as set in Article 3 paragraph 1a(i) of EQS Directive 2008/105/EC as amended by Directive 2013/39/EU.
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the individual substances included in PAH should be referenced in guidance (we have reported EEA_32-24-6 - Total Benzo (g, h, i) -perylene (CAS_191-24-2) + Indeno (1,2,3-cd) -pyrene (CAS_193- 39-5).
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the individual substances included in PAH should be referenced in guidance (we have reported EEA_32-24-6 - Total Benzo (g, h, i) -perylene (CAS_191-24-2) + Indeno (1,2,3-cd) -pyrene (CAS_193- 39-5).
We agree with ES comment.
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swPrioritySubstanceExceedanceInMixingZone - Optional. (YesNoCode_Enum)
Report whether the Priority Substance exceeds or is expected to exceed the EQS within the Mixing Zone in the surface water body.
Class: SWChemicalExemptionType (child of SWPrioritySubstances)
- 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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This class is at a Surface Water Body - Substance level (in combination with Pressures): the results potentially in a lot of reported exemptions depending on the amount of monitoring. In 2.5.2.1 Products from reporting > 11 Reasons behind article 4(4) exemptions / SWChemicalExemptionType: exemptions needed for each priority substance failing, the number of exemptions should be expressed as a percentage of the total assessed substances.
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We want to keep it as it is
swChemicalExemptionType - Required. (ExemptionType_Enum)
Report which type(s) of exemption(s) apply if good chemical status is not expected to be achieved by 2015 for that priority substance. If there are exceedances of the EQSs made more stringent in 2013 (for substances Anthracene, Brominated diphenylethers, Fluoranthene, Lead and its compounds, Naphthalene, Nickel and its compounds and Polyaromatic hydrocarbons (PAH)), report which type(s) of exemption(s) apply if good chemical status is not expected to be achieved by 2021. More than one exemption may apply to a surface water body.
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-> not Required
The level of detail to report is more detailed than requested by the WFD.
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Exemptions should still be possible for new substances and substances with new EQS. Exemptions for natural conditions should also be possible in all cases.
For Mayotte, the deadlines for exemptions are one cycle later than for the rest of France. We would need to be able to report accordingly.
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We want to keep it as it is
The whole chapter should be updated, because the Directive 2008/105/EC will not be relevant.