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swTypeSpecificReferenceConditionsForHyMoQEs - Required.(AllSomeNone_Enum)
Indicate whether type-specific reference conditions have been established for this surface water type for all relevant hydromorphological QEs.
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The terminology is wrong. They are not called 'type-specific reference conditions' for HyMoBQE.
Those are 'type-specific HyMo conditions'.
They are not "reference" values, as the boundaries for the classification of ecological status are not established as a deviation from those type-specific values. (They are thresholds and values).
This is not a minor problem.
Refer to the text of the WFD Annex II.1.3.i and Guidance document Nº10 on reference conditions or Nº 13 on the assesment of ecological status for further explanation.
RO supports the ES comment in relation to terminology.
By asking type-specific reference conditions Commission have made misinterpretation that Finland doesn’t have any reference condition for HyMoQEs (text below). Our reference conditions for HyMoQEs are based on water categories, not types.
European Overview - River Basin Management Plans, SWD(2019) 30 final p.6 :
“Progress has been made since the first RBMPs in the establishment of reference conditions, however gaps still remain, as in most Member States, reference conditions have not been established for all water body types (rivers, lakes, transitional and costal) and for all quality elements and for all quality elements. A few Member States have established all reference conditions, including Austria, Hungary and Poland. The quality elements whose type-specific reference conditions showed the most significant gaps for surface water body types were found to be the hydro-morphological ones, as most Member States established reference conditions only for some water categories, and 8 Member States did not establish reference conditions for any water category (including Denmark, Finland, France, Croatia, Italy, Latvia and Malta).”