Annex V and Article 4 of the WFD specify how Member States are to monitor groundwater, and present and report the results of the quantitative status assessment and the methodology used to classify groundwater bodies.
Article 4(4-9) of the WFD allows Member States to extend the deadlines for the achievement of good status or to set other, less stringent objectives under certain specified circumstances. Additional information can be found in the CIS Guidance Document No. 20: Guidance Document on Exemptions to the Environmental Objectives . Article 4(4-9) goes on to require Member States to provide information regarding such extensions or other objectives, and reasons, in the River Basin Management Plans.
Class: GroundWaterBody (quantitative status)
In the recent and ongoing review of the implementation of the directives by the European commission there seem to be concerns about grouping of groundwater bodies. Statistics in the reports on eg monitoring coverage do not consider grouping. At the same time grouping is explained to be the key for increasing monitoring coverage in the case when MS have a very large number of GWBs due to the natural hydrogeological conditions. Grouping must therefore be reported and presented in a different manner.
The cause of confusion about grouping is probably due to unclear reporting schemas. In the first management cycle reporting of grouping was much more straight forward, where each GWB were related to a group identification number. This coming cycle it is necessary that this reporting is re-introduced with a possibility to have different groups for chemical and quantitative purposes, i.e. each GWB could relate to different group identifiers.
gwAtRiskQuantitative - Required.(YesNoCode_Enum)
Report whether the groundwater body is at risk of failing to be of good quantitative status.
The information on GWB at risk was not properly used in RBMPs evaluation. We propose to delete it.
If the reported data regarding the risk evaluation are not used in the assessments, we would also suggest to delete it and to report "only" data regarding the status evaluation.
gwReasonsForRiskQuantitative - Conditional. (QuantitativeFailure_Enum)
If the groundwater body is at risk of failing to be of good quantitative status, select reasons from the enumeration list.
The information on GWB at risk was not properly used in RBMPs evaluation. We propose to delete it.
Missing field type: alteration of groundwater level.
If the reported data regarding the risk evaluation are not used in the assessments, we would also suggest to delete it and to report "only" data regarding the status evaluation.
gwEORiskQuantitative - Conditional.(GWEORiskQuantitative_Enum)
If the groundwater body is at risk of failing to be of good quantitative status, select the Environmental Objective related to the risk from the enumeration list
The information on GWB at risk was not properly used in RBMPs evaluation. We propose to delete it.
If the reported data regarding the risk evaluation are not used in the assessments, we would also suggest to delete it and to report "only" data regarding the status evaluation.
gwQuantitativeStatusValue - Required.(StatusCode_Enum)
Indicate the quantitative status of the groundwater body, based on the most recently assessed status of the groundwater body.
We suggest to made the codelist 'self explanatory'. See comments to swEcologicalStatusOrPotentialValue
gwQuantitativeReasonsForFailure - Conditional.(QuantitativeFailure_Enum)
If the groundwater body is of poor quantitative status, select reasons from the enumeration list
gwQuantitativeAssessmentYear - Required.
Provide the year on which the assessment of status is based. This may be the year that the groundwater body was monitored. In case of grouping this may be the year in which monitoring took place in the groundwater bodies within a group that are used to extrapolate results to non-monitored groundwater bodies within the same group. A period is possible (e.g. 2011--2013).
gwQuantitativeAssessmentConfidence - Required. (Confidence_Enum)
Indicate the confidence on the quantitative status assigned.
The different classes in the confidence table need to be elaborated on (maybe exemplified further) for a better basis for MS interpretation.
gwQuantitativeStatusExpectedGoodIn2015 – Required.(YesNoCode_Enum)
Indicate whether it is expected that this groundwater body will achieve good quantitative status by the end of 2015.
If it is relevant for 2021 we propose to add „unknown“ option.
The new date to be considered will be 2021.
Maybe the name and description of the schema element: gwQuantitativeStatusExpectedGoodIn2015 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… The same for surface water bodies.
gwQuantitativeStatusExpectedAchievementDate - Conditional. (GoodStatus_Enum)
If good quantitative status will not be achieved by 2015 (gwQuantitativeStatusExpectedGoodIn2015 is No), report the date by which it is expected that it will be achieved in full.
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 GWB 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.
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 gwQuantitativestatusExpectedGoodIn2015 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.
Is it possible to set up new targets 2028-2033?
see previous comment about Mayotte.
In the schema element: gwQuantitativeStatusExpectedAchievementDate it is not clear which answer should be chosen when a less stringent objective is expected to be achieved in the future
gwQuantitativeExemptionType - Required.(ExemptionType_Enum )
Report which type(s) of exemption(s) apply if good quantitative status is not expected to be achieved by 2015. More than one exemption may apply to a groundwater body.
We propose to delete or re-write the part of guidance on completion of schema element concerning on 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.
See previous comment about Mayotte.
gwQuantitativeExemptionPressure - Conditional.(SignificantPressureType_Enum)
If any Article 4(4), Article 4(5), Article 4(6) and/or Article 4(7) exemptions apply to this groundwater body for quantitative status, report the significant pressure(s) that are causing failure in order to justify the exemption(s) .
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, the pressure is not related to the exemption type but with the GWB directly (is it correct or a mistake??)
As detailled information on pressures are reported in schema element "gwSignificantPressureType" 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).
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 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.
For SWB the class QualityElement for SW EcoStatus should be equivalent to SWPrioritySubstance for SW ChemStatus.
The design is not incorrect but really difficult to be undestood.