1. DG Environment WG DIS, 9 – 10 April 2019, Copenhagen (DK)
Reporting guidance preliminary discussion on the comments received from WG DIS
DG Environment
WG DIS, 9 – 10 April 2019, Copenhagen (DK)

2. Summary of the consultation process
WG DIS agreed to use Talkback system of the EEA
Consultation started on 12 February 2019, the initial deadline 22 March 2019 but extended to 27 March 2019
almost 300 comments from 16 Member States (MS) and 2 stakeholders
1 stakeholder outside Talkback system
after the deadline 2 MS (FR and MT)

3. Number of comments per Member State/stakeholder

5. General comments on the reporting guidance
Names of features (e.g. surface water body, ground water bodies, monitoring sites) in national language
Quality checks to be added
To introduce also checks in the Access database
Review enumeration lists/codelists to make them more “human readable” and/or update them where necessary
Having error codes accompanied with an English explanation
Harmonise the terminology in the guidance

6. General comments on the reporting guidance (cont.)
Adding “information not available”
All GML data to be included in XML
a document with all validation checks would be needed
update the guidance including quality checks (documented in
In order to make the reading of the guidance easier, it would be appropriate to make hyperlinks to the corresponding Annex

7. 2. REPORTING AT SURFACE WATER BODY LEVEL (SCHEMA SWB) including 2
2. REPORTING AT SURFACE WATER BODY LEVEL (SCHEMA SWB) including 2.3, 2,4 and 2.5
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
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 – comment 13 in Talkback_comments_ xls
- Transboundary - Use of the option “No” for transboundary water bodies with non – EU countries; comment 24 in Talkback_comments_ xls
- Codelist of Annex 1a should not be split by drivers as usually the relation pressure-driver is 1 to n : comment 31 in Talkback_comments_ xls

8. 2. REPORTING AT SURFACE WATER BODY LEVEL (SCHEMA SWB) including 2
2. REPORTING AT SURFACE WATER BODY LEVEL (SCHEMA SWB) including 2.3, 2,4 and 2.5 – cont.
Adding quality element QE1-2-5 – Macrophytes and phytobenthos to the table StatusQE_Enum (or merging the 2 and leave only one element)
Missing from MonitoringResults_Enum modelling and/or statistical analysis of pressure and impacts
Update the chemical part of the guidance to take into account that reporting will be done according to Directive 2013/39/EU
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
- Adding quality element QE1-2-5 – Macrophytes and phytobenthos to the table StatusQE_Enum : comment 67 in Talkback_comments_ xls
- Missing from MonitoringResults_Enum modelling and/or statistical analysis of pressure and impacts: comment 69 in Talkback_comments_ xls
- qeEcologicalExemptionsType(multi-pressure environment): comments 74 and closely related 76 in Talkback_comments_ xls
- to become optional, or
- to allow reporting similar to WISE of the 1st RBMP
- to eliminate this table

9. 2. REPORTING AT SURFACE WATER BODY LEVEL (SCHEMA SWB) including 2
2. REPORTING AT SURFACE WATER BODY LEVEL (SCHEMA SWB) including 2.3, 2,4 and 2.5 – cont.
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
Add in the MonitoringResults_Enum a combination monitoring/grouping
Very few simplifications suggested i.e. excluding “No exemptions” in the ExemptionType_Enum: comments 55, 56 in Talkback_comments_ xls
Option to report separately chemical status for water matrix and for biota: comment 80 in Talkback_comments_ xls, a solution being proposed by comment RO to introduce in the list “biota EQS” (comment 100)
- grouping of water bodies: more guidance, at WB level as it is now or QE or PS level: comment 86, 87 in Talkback_comments_ xls
- Add in the MonitoringResults_Enum a combination monitoring/grouping: comment 83 in Talkback_comments_ xls and touches comment 86

10. 3. REPORTING AT GROUNDWATER BODY LEVEL (SCHEMA GWB) including 3
3. REPORTING AT GROUNDWATER BODY LEVEL (SCHEMA GWB) including 3.3, 3,4 and 3.5
To be added reference to the identifier specifications included in the GIS guidance
GWB layers not very useful - to discuss with WG Groundwater
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.
Very few simplifications suggested e.g. delete the information on GWB at risk
- 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‘: comment 130 of Talkback_comments_ xls
- Very few simplifications suggested e.g. delete the information on GWB at risk: comments 123, 124, 126 in Talkback_comments_ xls – we do not agree as risk should be the source of taking the measures, part of the GW Directive a

11. 4. MONITORING (SCHEMA MONITORING)
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
Filling in the frequency and cycle for each site separately time consuming. Suggestion: to do this by program or per group of sites
Very few simplifications suggested (e.g. class MonitoringPurpose redundant because it is also reported in the GML. hence to be deleted)
- Split the monitoring aspects into SW and GW: comment 154 in Talkback_comments_ xls
- 'xxxLastMonitored' = 9999 if not yet monitored, but reporting is not about future monitoring: comments 149 and 166 in Talkback_comments_ xls
- Filling in the frequency and cycle for each site separately time consuming. Suggestion: to do this by program or per group of sites: comments 177 and 178 in Talkback_comments_ xls
- Very few simplifications suggested (e.g. class MonitoringPurpose redundant hence to be deleted): comment 181 in Talkback_comments_ xls

12. 5. PROTECTED AREAS (SCHEMAS SWB AND GWB)
Link to the EEA vocabulary list protected area
Logic of SW ecological status for example i.e. swEcologicalStatusOrPotentialExpectedGoodIn2015
swChemicalStatusExpectedGoodIn2015
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.)
- Link to the EEA vocabulary list protected area: comment 187 in Talkback_comments_ xls
- Logic of SW ecological status for example should be followed when talking about protectedXXXObjectivesMet: comment 189 in Talkback_comments_ xls
- Shellfish Directive vs Regulation on products of animal origin intended for human consumption: comment 188 in Talkback_comments_ xls

13. 6. REPORTING AT MS LEVEL: COMPETENT AUTHORITIES, RBDS AND SUB-UNITS (SCHEMA RBDSUCA)
Information on Competent Authorities should be reported at RBD level not at Member State level
- Information on Competent Authorities should be reported at RBD level not at Member State level: comment 193 in Talkback_comments_ xls

14. 7. REPORTING AT RBD/SUB-UNIT LEVEL FOR SURFACE WATER (SCHEMA SWMET) including 7.3, 7.4, 7.6 and 7.7
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)
Delete Schema SWSupportingQE as the same information is provided Quality Element schema
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
- TypeSpecificReferenceConditionsforHyMoQEs – further look into it before discussing: comments 199 and 200 in Talkback_comments_ xls
Indicate whether a surface water body is a natural or a heavily modified or artificial water body: comment 203 in Talkback_comments_ xls
Delete Schema SWSupportingQE as the same information is provided Quality Element schema: comment 204 in Talkback_comments_ xls
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: comment 205 in Talkback_comments_ xls

15. 7. REPORTING AT RBD/SUB-UNIT LEVEL FOR SURFACE WATER (SCHEMA SWMET) including 7.3, 7.4, 7.6 and 7.7 (cont.)
Look at the consistency with the CIS Guidance on implementing metals EQS
The list of possible significant hydromorphological pressures should be revised to be more consistent with the WFD:
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).
Look at the consistency with the CIS Guidance on implementing metals EQS: comments 213 – 216 in Talkback_comments_ xls
The list of possible significant hydromorphological pressures should be revised, following three different groups of significant pressures: comment 218 in Talkback_comments_ xls

16. 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
- 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.: comment 235 in Talkback_comments_ xls
- 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". comment 237 in Talkback_comments_ xls
- weiNational – should be reported at national level. RBMPPoM module refers to RBD level information: comment 244 in Talkback_comments_ xls

17. 9. REPORTING AT RBD/SUB-UNIT LEVEL FOR RBMP (SCHEMA RBMPPOM) including 9.4
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.
(water abstractions) reportedUnderSoEQuantity – Required(YesNo) ought to show in WISE SoE data depository
- if the term abstraction is always to be understood as “net consumption” : comment 242 in Talkback_comments_ xls
- reportedUnderSoEQuantity – Required(YesNo) ought to show in WISE SoE data depository: comment 243 in Talkback_comments_ xls

18. 10. PROGRAMME OF MEASURES REPORTED AT RBD/SUB-UNIT LEVEL (SCHEMA RBMPPOM) including 10.2, 10.3, 10.4 and 10.5
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.
- 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: comment 247 in Talkback_comments_ xls
- 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. Comment: 250 in Talkback_comments_ xls
- IndicatorGap - comments , 260, 261 in Talkback_comments_ xls
- The provision to have environmental objectives as high needs to be provided for throughout the reporting database. : comment 262 in Talkback_comments_ xls -

19. 10. PROGRAMME OF MEASURES REPORTED AT RBD/SUB-UNIT LEVEL (SCHEMA RBMPPOM) including 10.2, 10.3, 10.4 and 10.5 (cont.)
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.
KTM enumeration list should be spread to KTMs used by countries beyond RBMP2 enumeration list.
Distinction to be made within “supplementary measures” as follows:
Supplementary measures - achievement of objectives
Supplementary measures - additional protection
- 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. : comment 267 in Talkback_comments_ xls
- KTM enumeration list should be spread to KTMs used by countries beyond RBMP2 enumeration list. : comment 269 in Talkback_comments_ xls
- Distinction to be made within “supplementary measures” comment 271 in Talkback_comments_ xls

20. 10. PROGRAMME OF MEASURES REPORTED AT RBD/SUB-UNIT LEVEL (SCHEMA RBMPPOM) including 10.2, 10.4 and 10.5 (cont.)
Suggestion to delete “waterReUse” as the answer is too simplistic as water reuse is usually a better environmental option to desalinization for example but promoting it in catchments with high exploitation index will have important negative impacts in uses downstream
Which option should be chosen by a ‘landlocked country’ if during the preparations of the RBMP and PoM the MS took into account the objectives of the Marine Strategy Framework Directive?
- Suggestion to delete “waterReUse” as the answer is too simplistic: comment 272 in Talkback_comments_ xls
- Which option should be chosen by a ‘landlocked country’ if during the preparations of the RBMP and PoM the MS took into account the objectives of the Marine Strategy Framework Directive? Comment 273 in Talkback_comments_ xls

21. 11. REPORTING AT RBD/SUB-UNIT LEVEL FOR ECONOMIC ANALYSIS AND COST RECOVERY (SCHEMA RBMPPOM) including 10.3
Separation of different types of cost

22. Thank you