9. REPORTING AT RBD/SUB-UNIT LEVEL FOR RBMP (SCHEMA RBMPPOM) including 9.4
- Inventory of emissions discharged into surface waters, suggestion is to establish the possibility to report e.g. total PAH and also single substances for emissions from major polluters.
- Inventory methodology should be reported only for those substances/pollutants that pass the relevance criteria, if "relevance RBD Scale" is "Yes". For others it should be optional. Conditional check: report if relevanceRBDScale is "Yes".
- weiNational – should be reported at national level. RBMPPoM module refers to RBD level information
Previous comments
1.Regarding Comment no. 235 in "Talkback_comments_28.03.19.xls„, we do not agree with the proposal regarding the reporting of emissions at the level of polluters because the level of detail to report would be more detailed than requested by the WFD. Directive 2008/105/EC clearly points out that each Member State should establish an inventory of emissions, discharges and losses for each river basin district or part of a river basin district in its territory.
2.Regarding Comment no. 237 in "Talkback_comments_28.03.19.xls„, we agree with the proposed aspect, that reporting of substances that do not pass the relevance criteria, should be optional.
3.Regarding Comment no. 244 in "Talkback_comments_28.03.19.xls„, we agree with the proposal to report only at national level.