Overview of comments presented at WG DIS

• SE - Sweden (invited by kristpet (disabled)) 02 May 2019 11:00:17

  Names of features (e.g. surface water body, ground water bodies, monitoring sites)  in national language	SE: Yes. Names in  English should not be a requirement.
  Quality checks to be added
  To introduce also checks in the Access database	SE does not use the Access tool
  Review enumeration lists/codelists to make them more “human readable” and/or update them where necessary	SE: No.  Do not change if not necessary as it will only creates confusion. Better to keep constant.
  Having error codes accompanied with an English explanation	SE: There is a list of error codes available
  Harmonise the terminology in the guidance
  Adding “information not available”	SE: In conjunction with annex zero? An empty element commented in annex 0 should work?
  All GML data to be included in XML	SE: No. We do not recommend double reporting.
  A document with all validation checks would be needed	SE: Exists all ready
  Update the guidance including quality checks (documented in http://cdr.eionet.europa.eu/help/WFD/WFD_521_2016/QA-QC/QC%20Rules%206.0.6(XMLs).xlsx)
  In order to make the reading of the guidance easier, it would be appropriate to make hyperlinks to the corresponding Annex

• SI - Slovenia (invited by kristpet (disabled)) 03 May 2019 22:06:10

  Aditional comment: Data that can be summarized from spatial analyzes (lengths of water bodies, area of RBD, ...) should not be duplicated regarding its inclusion into gml or xml reporting schemes.

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• SE - Sweden (invited by kristpet (disabled)) 02 May 2019 11:03:45

  hmwbWaterUse- Conditional. For HMWBs only, report the water use for which it has been designated- this is not the meaning of Art 4(3) of the WFD. (The designation of a WB as HMWB is related to the use that will be significantly affected if restoration measures were put in place.)
  Use of option “No” for transboundary water bodies with non – EU countries; at present the guidance states: “Transboundary water bodies are those Crossing the border between countries or constituting part of the border between two countries for a certain length”
  Codelist of Annex 1a should not be split by drivers as usually the relation pressure-driver is 1 to n	SE: No. We do not agree

• SI - Slovenia (invited by kristpet (disabled)) 03 May 2019 09:56:58

  1. The aspect given in Comment 13 in "Talkback_comments_28.03.19.xls" is important, but it does not fall within this reporting scheme, therefore we do not agree with the remark.
  2. If you consider that it is necessary to upgrade the Enum list in shema "surfaceWaterBodyTransboundary" as indicated in Comment 24 in "Talkback_comments_28.03.19.xls" , it is in our opinion more appropriate to upgrade the Enum list with the use of wording "transboundary water bodies with non-EU countries".
  3. We agree wit the aspect given in Comment no. 31 in "Talkback_comments_28.03.19.xls". We propose that the codelist of Annex 1a is upgraded with adding an option from which "Dams, barriers and locks - multipurpose" can be selected.

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• SE - Sweden (invited by kristpet (disabled)) 02 May 2019 11:04:36

  Adding quality element QE1-2-5 – Macrophytes and phytobenthos to the table StatusQE_Enum (or merging the 2 and leave only one element)	SE: No. We do not agree, we do not understand the purpose of changing
  Missing from MonitoringResults_Enum modelling and/or statistical analysis of pressure and impacts	SE: No.  A change may be confusing in relation to expert judgements/assessments
  Update the chemical part of the guidance to take into account that reporting will be done according to Directive 2013/39/EU	SE: Yes. An update is necessary and crucial
  qeEcologicalExemptionsType(multi-pressure environment) - suggestion:
  - to become optional, or
  - to allow reporting similar to WISE of the 1st RBMP
  - to eliminate this table since this info was not relevant in the context of EC assessment

• SI - Slovenia (invited by kristpet (disabled)) 03 May 2019 09:57:39

  1.Regarding Comment no. 67 in "Talkback_comments_28.03.19.xls" on "qeCode„ we have to insist on upgrading the codelist in Annex 8h in such a way that the content of the reporting, as it is reported in „qeCode“ schema, will comply with the requirements of the provisions set out in WFD. By adding quality element „QE1-2-5 ‒ Macrophytes and phytobenthos“ to the table „StatusQE_Enum“ in Annex 8h, the existing separate reporting of quality elements will not be changed.

  2.Regarding Comment no. 69 in "Talkback_comments_28.03.19.xls„ we agree with the proposal to upgrade the enumeration list.

  3.Regarding Comment no. 74 and 76 in "Talkback_comments_28.03.19.xls" on "qeEcologicalExemptionType„ we agree with the aspect that the level of detail to report is more detailed than requested by the WFD and that reporting should eliminated or at least to be classified as "optional".

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• SE - Sweden (invited by kristpet (disabled)) 02 May 2019 11:05:21

  Very few simplifications suggested i.e. excluding “No exemptions” in the ExemptionType_Enum
  Option to report separately chemical status for water matrix and for biota: a solution proposed is to introduce in the list “biota EQS”
  Grouping of water bodies: 1) more guidance, 2) at WB level as it is now or QE or PS level	SE: No. We do not agree as we do not understand the purpose of the change
  Add in the MonitoringResults_Enum a combination monitoring/grouping	SE: No. We do not agree as we do not understand the purpose of a combination

• SI - Slovenia (invited by kristpet (disabled)) 03 May 2019 09:58:25

  1.Regarding Comment no. 55 and 56 in "Talkback_comments_28.03.19.xls" on paragraph SWEcologicalExemptionType, in our opinion it is not necessary to eliminate "No exemption".

  2.Regarding Comment no. 80 in "Talkback_comments_28.03.19.xls" on "SurfaceWaterBody (SWB chemical status)„, the issues, as presented, was also  pointed out in the scope of discussion on the content of EEA draft report "European waters Assessment of status and pressures 2018", which took place in the period 2017-2018. In our opinion the proposal in Comment no. 100 deals with the same aspects as given in Comment no. 80. If the reporting of chemical status would be done separately for  water matrix and separately for biota then the reported data would enable presentation of the results as "where is the problem - in biota or in water?" and the proposal from Comment no. 100 would be taken into account.

  3.Regarding Comment no. 86 in "Talkback_comments_28.03.19.xls" on "swChemicalMonitoringResults„, we do not agree with the proposal.

  4.Regardnig Comment no. 87 in "Talkback_comments_28.03.19.xls" on "swChemicalStatusGrouping „,  we do not agree with the proposal to group at QE and/or substance level (or group of substances). In addition we support the suggestion that maybe it can be considered to delete this element.

  5. Regarding Comment no. 83 in "Talkback_comments_28.03.19.xls" on "swChemicalMonitoringResults„, we do not agree with the proposal.

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• SE - Sweden (invited by kristpet (disabled)) 02 May 2019 11:06:09

  To be added reference to the identifier specifications included in the GIS guidance	SE: Yes. We agree
  GWB layers not very useful  - to discuss with WG Groundwater	SE: Yes. We agree
  GW exemptions – when a WB has both 4(4) (time extension) and 4(5) (less stringent objective), the current GoodStatus_Enum does not help  – suggestion to modify by removing from the codelist 'less stringent objective already achieved‘ and adding a new field in order to report the Achievement of less stringent objectives for quality elements with a 4(5) exemption.	SE: Yes. We agree
  Very few simplifications suggested e.g. delete the information on GWB at risk	SE: No. We do not agree as we are of the opinion that GWB at risk is important imformation

• SI - Slovenia (invited by kristpet (disabled)) 03 May 2019 09:58:59

  Regarding Comments no. 123, 124, 126 and 130 in "Talkback_comments_28.03.19.xls„, we point out that reporting must be consistent for bouth, SWB and GWB (i.e. if it is deleted in GWB schemas then it should be deleted also in SWB schemas).

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• SE - Sweden (invited by kristpet (disabled)) 02 May 2019 11:07:10

  Split the monitoring aspects into SW and GW (the table ”Chemical Monitoring” is very hard to manage due to its length)
  'xxxLastMonitored' = 9999 if not yet monitored, but reporting is not about future monitoring	SE: Yes.  We are positive to an omission
  Filling in the frequency and cycle for each site separately time consuming. Suggestion: to do this by program or per group of sites	SE does not agree, is an administrative burden
  Very few simplifications suggested (e.g. class MonitoringPurpose redundant because it is also reported in the GML. hence to be deleted)	SE is of the opinion the class should be deleted from the GML

• SI - Slovenia (invited by kristpet (disabled)) 03 May 2019 09:59:24

  1.Regarding Comment no. 154 in "Talkback_comments_28.03.19.xls„, we agree with the aspects regarding the splitting of monitoring aspects into SW and GW Scheme.

  2.Regarding Comment no. 149  and 166 in "Talkback_comments_28.03.19.xls„, we agree with the aspects pointed out in bouth comments that reporting is not intended to include information regarding future monitoring programs or planned changes.

  3.Regarding Comment no. 177 and 178  in "Talkback_comments_28.03.19.xls„, we agree and strongly support the aspects pointed out in bouth comments regarding the monitoring frequency and cycle. We point out that reporting approach must be consistent for booth, chemical and ecological status.

  4.Regarding Comment no. 181  in "Talkback_comments_28.03.19.xls„, we agree with the aspect set out in the comment. Double reporting represents an additional administrative burden which is not acceptable.

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• SE - Sweden (invited by kristpet (disabled)) 02 May 2019 11:08:06

  Link to the EEA vocabulary list protected area
  Logic of SW ecological status for example i.e.   swEcologicalStatusOrPotentialExpectedGoodIn2015 and swChemicalStatusExpectedGoodIn2015	SE:  No. We do not agree
  Should be followed when talking about protectedXXXObjectivesMet
  Shellfish Directive vs Regulation on products of animal origin intended for human consumption (The monitoring and control of microbial contamination seems stricter according to the regulation than the old Shellfish directive.)	SE: Yes. We agree with the original wording of the suggestion, see talkback comments

• SI - Slovenia (invited by kristpet (disabled)) 03 May 2019 09:59:52

  1.Regarding Comment no. 187  in "Talkback_comments_28.03.19.xls„, we agree with the aspect set out in the comment.

  2.Regarding Comment no. 188 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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• SE - Sweden (invited by kristpet (disabled)) 02 May 2019 11:08:39

  Information on Competent Authorities should be reported at RBD level not at Member State level

  SE: No. We do not agree

• SI - Slovenia (invited by kristpet (disabled)) 03 May 2019 10:00:24

  Regarding Comment no. 193 in "Talkback_comments_28.03.19.xls„, we can only comment that during the reporting exercise we did not detect the problem pointed out in that comment.

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• SE - Sweden (invited by kristpet (disabled)) 02 May 2019 11:09:32

  TypeSpecificReferenceConditionsforHyMoQEs, terminology is wrong, should be 'type-specific HyMo conditions' - further look into it before discussing
  Indicate whether a surface water body is a natural or a heavily modified or artificial water body (add a schema element)	SE: No. We do not agree as this information should not be part of the method schema, and it is already reported in SWB
  Delete Schema SWSupportingQE as the same information is provided Quality Element schema	SE: No. We do not agree, as different information is reported in the two classes
  Suggestion for an option to indicate if the classification boundaries for a certain supporting QE and the class boundaries for sensitive BQE are reported in accordance with/are relevant to the water category	SE does not understand the problem or suggestion for modification

• SI - Slovenia (invited by kristpet (disabled)) 03 May 2019 10:00:55

  1.Regarding Comment no. 199 and 200  in "Talkback_comments_28.03.19.xls„ we agree with the aspect set out in bouth comments regarding the terminology (the terminology should be revised).

  2.Regarding Comment no. 203  in "Talkback_comments_28.03.19.xls" on Class BQEMethod, we cannot agree with the aspect set out in the comment because it would represent double reporting (the content already reported in Schema element: naturalAWBHMWB) and because the content as reported in Class BQEMet represents RBM level (not on WB level).

  3.Regarding Comment no. 204  in "Talkback_comments_28.03.19.xls„, we do not agree with the aspect set out in the comment

  4.Regarding Comment no. 205  in "Talkback_comments_28.03.19.xls„, we agree with the aspect set out in first part of the comment (an option to indicate if the classification boundaries for a certain supporting QE and the class boundaries for sensitive BQE are reported in accordance with/are relevant to the water category) and disagree with the aspect set out in the second  part of the comment. Adding an information regarding natural or an artificial or a heavily modified water body to the supportingQESensitivityBQE shema would represent  double reporting (the content already reported in Schema element: naturalAWBHMWBB).

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• SE - Sweden (invited by kristpet (disabled)) 02 May 2019 11:10:01

  Look at the consistency with the CIS Guidance on implementing metals EQS	SE: Yes. We agree
  The list of possible significant hydromorphological pressures should be revised to be more consistent with the WFD:	SE: Yes. We agree
  −abstractions and water flow regulations (pressures that have impact on hymo element "hydrological regime“ e.g. water abstractions, impoundments etc),
  −interruptions of river continuity (pressures that have impact on hymo element "river continuity“ e.g. i.e weirs, dams, etc),
  −morphological alterations (pressures that have impact on hymo element "morphological conditions” (e.g. river engineering works, dredging etc).

• SI - Slovenia (invited by kristpet (disabled)) 03 May 2019 10:01:22

  1.Regarding Comment no. 213  in "Talkback_comments_28.03.19.xls„, we do not agree with the aspect set out inthe comment.

  2.Regarding Comment no. 214 in "Talkback_comments_28.03.19.xls„, it is our opinion that the aspect set out in comment has no added value.

  3.Regarding Comment no. 215  in "Talkback_comments_28.03.19.xls„, we do not agree with the aspect set out inthe comment.

  4.Regarding Comment no. 216 in "Talkback_comments_28.03.19.xls„, it is our opinion that the aspect set out in comment has no added value.

  5.Regarding Comment no. 218 in "Talkback_comments_28.03.19.xls„, we emphasize that the proposal was prepared in the light of WFD provisions and we still suport it.

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• SE - Sweden (invited by kristpet (disabled)) 02 May 2019 11:10:53

  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.	SE: No We do not agree as we are of the opinion that any changes in the lists should not be possible inbetween cycles
  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".	SE: No. We do not agree
  weiNational – should be reported at national level. RBMPPoM module refers to RBD level information	SE: No. We do not agree

• SI - Slovenia (invited by kristpet (disabled)) 03 May 2019 21:46:07

  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.

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• SE - Sweden (invited by kristpet (disabled)) 02 May 2019 11:11:21

  Clarification requested: if the term abstraction is always to be understood as “net consumption” as stated in chapter 9.4. If this is the case, it should be made clear in the description of pressure 3.5 – Abstraction or flow diversion – Hydropower Energy ‐ hydropower in Annex 1a that this is a reference to consumptive water use. If this is not the case, please make the necessary clarifications in chapter 9.4.

  SE: Yes. We agree

  (water abstractions) reportedUnderSoEQuantity – Required(YesNo) ought to show in WISE SoE data depository

  SE: Yes. We agree

• IE1 - Ireland (invited by kristpet (disabled)) 03 May 2019 17:22:21

  Ireland proposed the focus on risk for POMs. This has clear benifits  - for example we use it if a nutrient trend is approaching  a boundary we might assign a POM before the status declines. This is more proactive than waiting for an ac tual decline in status.

• SI - Slovenia (invited by kristpet (disabled)) 03 May 2019 21:48:03

  1.Regarding the Comment no. 242 in "Talkback_comments_28.03.19.xls„, we agree with the proposed.

  2.Regarding Comment no. 243 in "Talkback_comments_28.03.19.xls„, we agree with the aspect set out in the comment that the information is already available in WISE SoE data depository.

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• 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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• SE - Sweden (invited by kristpet (disabled)) 02 May 2019 11:12:39

  KTMs should be reviewed to incorporate MFSD KTM as measures for coastal waters are shared by both directives and those shared measures should not be classified in different KTM depending on the directive they relate to.	SE: Yes. We agree a revision would be helpful
  KTM enumeration list should be spread to KTMs used by countries beyond RBMP2 enumeration list.
  KTM enumeration list should be spread to KTMs used by countries beyond RBMP2 enumeration list.
  Distinction to be made within “supplementary measures” as follows:	SE: No. We so not understand the purpose of a change, it will increase the administrative burden
  −Supplementary measures - achievement of objectives
  −Supplementary measures - additional protection

• SI - Slovenia (invited by kristpet (disabled)) 03 May 2019 21:49:33

  1.Regarding Comment no. 267 in "Talkback_comments_28.03.19.xls„ we do not agree with the proposal.

  2.Regarding Comment no. 269 in "Talkback_comments_28.03.19.xls„ we cannot agree or disagree on the comment because it is not clear what is proposed.

  3.Regarding Comment no. 271 in "Talkback_comments_28.03.19.xls„, we do not object to the proposal, but different aspects as proposed in the comment, must be explained and clearly defined in the reporting guidance in such a way that there will be no uncertainty in the meaning of measures.

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• SI - Slovenia (invited by kristpet (disabled)) 03 May 2019 21:49:59

  1. Regarding Comment 272 in „Talkback_comments_28.03.19.xls“ we agree with the proposal.
  2. Regarding Comment 273 in „Talkback_comments_28.03.19.xls“ it is our opinion that option ‘landlocked country’ refers to geographical characteristics of the river basin for which the data is reported.

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• SE - Sweden (invited by kristpet (disabled)) 02 May 2019 11:13:02

  Separation of different types of cost

  SE: We are is of the opinion that the wording in the reportings guidance needs to be revised and clarified

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