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  • The reporting is restrictive in being state rather than risk based. Suggestion: to accommodate the possibility to assign measures on the basis of risk which incorporates status
  • Measures related to SW should not be separated from those related to GW as measures are common in many cases. e.g. diffuse sources of pollution from agriculture affect both SW and GW so the measures to reduce them will be the same.
  • Gap and KTM Indicators
  • There is no provision for the target to be set as high (only achievement of good status) therefore the provision to have environmental objectives as high needs to be provided for throughout the reporting database.

 

Previous comments

  • SE - Sweden (invited by kristpet (disabled)) 02 May 2019 11:12:02
    The reporting is restrictive in being state rather than risk based. Suggestion: to accommodate the possibility to assign measures on the basis of risk which incorporates status SE: No. We do not entirely agree with the statement that reporting is based on state and not risk. Helpful if the guidance can clarify
    Measures related to SW should not be separated from those related to GW as measures are common in many cases. e.g. diffuse sources of pollution from agriculture affect both SW and GW so the measures to reduce them will be the same. SE: Yes. We agree that there is a problem with the separation, further discussion on a solution is needed
    Gap and KTM Indicators  
    There is no provision for the target to be set as high (only achievement of good status) therefore the provision to have environmental objectives as high needs to be provided for throughout the reporting database.  
  • IE1 - Ireland (invited by kristpet (disabled)) 03 May 2019 17:26:50

    IE Stated the need to include objectives for high status sites (KTM and gap indicators).  However, one of the solutions forwarded by Peter was to define gap - as GAP TO OBJECTIVE rather than gap to good status. (this would allow high status to be included).  Across the EU high status sites are being lost and this needs focus as they are of more value than good sites.

  • SI - Slovenia (invited by kristpet (disabled)) 03 May 2019 21:49:03

    1.Regarding Comment no. 247 in "Talkback_comments_28.03.19.xls„, we agree with the proposal.

    2.Regarding Comment no. 250 in "Talkback_comments_28.03.19.xls„, we disagree with the aspect set out in the comment regarding deleting the schema element "surfaceWaterOrGroundwater".  We propose to update the enumeration list with an option "Surface and ground water" because in same cases the measures can be common for both surface and ground water bodies.

    3.Regarding Comments no. 250, 256, 257, 258, 260 and 261 in "Talkback_comments_28.03.19.xls„ we agree with the aspects set out in these comments that reporting as it is set now is not appropriate because it is incomparable. It is necessary to find appropriate technical solution.

    4.Regarding Comment no. 262 in "Talkback_comments_28.03.19.xls„ we cannot agree or disagree on the comment because it is not clear what is proposed.

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