1. Environmental Objectives and Exemptions under the Water Framework Directive SCG meeting May Marieke van Nood, Unit D.2, DG Environment, European Commission

2. Comments discussion document
Outline
Copenhagen workshop
Discussion document
Comments discussion document
Common grounds
Major open points
COM questions
Way forward towards WD meeting
Notes for the Speaker:
More information on the Directive, the implementation process and also the guidance documents are available on the internet.

3. Do you miss comments in presentation?
Questions to SCG
Do you miss comments in presentation?
Do you agree with presented common grounds and major open points?
What should be main questions for WD?
Do you agree with proposed way forward for WD meeting?
Notes for the Speaker:
More information on the Directive, the implementation process and also the guidance documents are available on the internet.

4. Copenhagen workshop

5. Summary and conclusions on following topics:
Copenhagen workshop
20 case studies
Summary and conclusions on following topics:
General approaches
Affordability
Alternative financing mechanisms
Public budget constraints
Costs and benefits / cost recovery
Transparency
Notes for the Speaker:
More information on the Directive, the implementation process and also the guidance documents are available on the internet.

6. Copenhagen workshop
All presentations, an input paper, summary and conclusions are available on Circa:
Notes for the Speaker:
More information on the Directive, the implementation process and also the guidance documents are available on the internet.

7. Discussion Document

8. Version 1.0 Discussion Document
Workshop summary and conclusions
Using agreed slides, no more detail added
Ch3: points agreed at workshop and - with intention to narrow down discussions - proposals were made for further discussion.
Notes for the Speaker:
More information on the Directive, the implementation process and also the guidance documents are available on the internet.

9. Version 1.0 Discussion Document
Comments received from 8 countries and 5 stakeholders/NGOs
Only direct comments on CH3 listed in version 2.0
All comments available on Circa
In next slides, main received comments listed
Notes for the Speaker:
More information on the Directive, the implementation process and also the guidance documents are available on the internet.

10. Discussion Document - Comments

11. Version 1.0 Discussion Document
Comments - 1
Although many commonalities in approaches were identified in Copenhagen, there is urgent need for further guidance. Further work could include an operational procedure, guiding principles, need for a holistic view of disproportionality.
A ‘too strict’ interpretation may interfere with making incorrect decisions
Notes for the Speaker:
More information on the Directive, the implementation process and also the guidance documents are available on the internet.

12. Version 1.0 Discussion Document
Comments - 2
Prioritisation/screening is in line with Directive (as indicated in environmental objectives paper).
Implementing the institutional framework to allow for alternative financing mechanisms needs time and may justify an extension of the deadline
The extensive use of alternative financing mechanisms might go against the polluter pays principle
Notes for the Speaker:
More information on the Directive, the implementation process and also the guidance documents are available on the internet.

13. Version 1.0 Discussion Document
Comments – 3
‘The WFD sets environmental objectives and the budget should follow’ should include exemptions in objective setting.
Public budget is not unlimited.
Affordability should focus on vulnerable groups or economic activity in deprived areas, not on whole sectors
Notes for the Speaker:
More information on the Directive, the implementation process and also the guidance documents are available on the internet.

14. Summary comments – common grounds
In addition to already agreed points in Copenhagen:
Alternative financing mechanisms should be looked into at a broad scale, not looking only at local water users
Non-action by one player does not automatically lead to an exemption for other players within the same sector …
Notes for the Speaker:
More information on the Directive, the implementation process and also the guidance documents are available on the internet.

15. Summary comments – major open points
Role public budget limitations
Use of prioritisation approaches in justification of exemptions
Administrative/legal constraints in implementing alternative financing mechanisms
Role of affordability in Article 4.5
Notes for the Speaker:
More information on the Directive, the implementation process and also the guidance documents are available on the internet.

16. Commission Questions

17. Major open points – COM questions - 1
Role public budget limitations
How does this fit with the fact that costs for ‘old water legislation’ cannot be taken into account?
How can it be guaranteed that business does not stay as usual in unsustainable cases?
How is a comparable implementation guaranteed?
Use of prioritisation approaches in justification of exemptions
How are criteria defined, e.g. does budget availability play a role in prioritisation approaches? If so, see above
Notes for the Speaker:
More information on the Directive, the implementation process and also the guidance documents are available on the internet.

18. Major open points – COM questions - 2
Constraints in implementing alternative financing mechanisms
National/regional administrative/legal constraints: not clear how this fits with justification according to WFD – (technical) feasibility/disproportionate costs
Role of affordability in Article 4.5
Not clear how this can be justified according to the Directive
Notes for the Speaker:
More information on the Directive, the implementation process and also the guidance documents are available on the internet.

19. Way forward

20. Proposed way forward At SCG
Discuss and agree major open points and points for common understanding
Prepare questions for debate Water Directors
After SCG
Update discussion document according to discussions SCG and with questions for debate WD
Notes for the Speaker:
More information on the Directive, the implementation process and also the guidance documents are available on the internet.

21. Do you miss comments in presentation?
Questions to SCG
Do you miss comments in presentation?
Do you agree with presented common grounds and major open points?
What should be main questions for WD?
Do you agree with proposed way forward for Water Directors meeting?
Notes for the Speaker:
More information on the Directive, the implementation process and also the guidance documents are available on the internet.