WFD Reporting - Lessons Learned

Client: EC - DG Environment Report Ref: UC9498 v3.0

Report Date: April 2013 Contract No: 15995-3

Author: France, Sarah, Nixon Steve

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© WRc plc 2013

WRc Ref: UC9498 v3.0/15995-3

April 2013

WFD Reporting - Lessons Learned

1.  Introduction

The Water Framework Directive (2000/60/EC) (WFD) requires Member States (MS) to provide information to the Commission (COM) to enable it to:

·  Check compliance with the requirements of specific articles of the WFD;

·  Carry out preliminary assessment of the situation in the MS;

·  Carry out further detailed analysis (where additional data may be required);

·  Compile statistics for its own needs and to inform the European Parliament; and

·  Create a European-wide picture to inform the public.

MS have now delivered against several reporting obligations:

·  Article 3 (administrative arrangements) in 2004;

·  Article 5 (characteristics of the RBD, review of the environmental impact of human activity and economic analysis of water use) in 2005;

·  Article 8 (monitoring programmes) in 2008;

·  Article 15(1) (RBMPs) in 2010; and

·  Article 15(3) (Progress with the implementation of the planned programme of measures) in 2012.

Subsequently the Commission has prepared three implementation reports in 2007 (based on an assessment of the Article 3 and Article 5 reporting), in 2009 (based on an assessment of the Article 8 reporting) and, most recently, in 2012 (based on assessment of the reporting on the RBMPs).

The process for agreeing what information will be reported, how it will be reported, and the actual mechanisms for reporting have developed significantly since the first discussions were held in 2001. The reporting requirements are documented and agreed between the COM and MSs in Working Group D, and a guidance document prepared for agreement with the SCG and Water Directors. The agreement is then translated into an electronic schema and tools developed to support MS in generating information in the required (XML) format. The information is reported electronically by the MS to the EEA’s ReportNet system. A number of validation checks are carried out, and once the data is deemed to be compliant, it is transferred to the Water Information System for Europe (WISE) and is available to the Commission for assessment.

The required reporting has, in practice, been extensive, complex and time consuming, both on the part of the MS in collecting and providing the information and on the part of the Commission in assessing and analysing the information. There is willingness on both sides for the simplification of the reporting requirements and to capitalise on synergies with other Directives and reporting (e.g.Floods, Nitrates, MSFD, UWWTD and SoE).

The purpose of this document is to summarise the lessons learned from the completed reporting exercises and to form the basis for reviewing, and if necessary revising the reporting guidance and schemas. It will draw upon the findings of similar documents prepared after the publication of the first two Commission implementation reports, and will present feedback gathered from all interested stakeholders on the last completed reporting exercise (on RBMPs). In addition, a comparison has been made between the information requested in the schemas, and the information used in the assessments to identify areas for improvement in reporting, and where information is not needed and could be removed. It will also look to identify synergies with other reporting streams to identify opportunities for future streamlining.

2.  Conclusions and Recommendations

1.  As with previous reporting exercises, not all MS provided all the information required. Incomplete reporting by MS makes it difficult and time consuming to carry out the assessments required at a European level, and jeopardises the quality of the assessments. These problems are magnified when the information uploaded to WISE is inconsistent either with published documents or other reporting streams, as was the case for a number of MS. This can lead to information being misinterpreted and an incorrect assessment being made. MS should therefore make every effort to ensure that information uploaded to WISE is a) timely and b) accurate and that there is consistency between what is uploaded to WISE, the RBMPs and any supporting documents. Furthermore, in some cases where hyperlinks to further reference documents were provided, these did not work, or were links to general governmental web sites and not the specific document. MS should ensure that hyperlinks provided will remain valid for the period of the assessment, or if this cannot be guaranteed, provide an electronic copy of the supporting documents.

2.  The detailed assessment questions that the COM needed to answer from the information provided evolved in the period (some 6 years) between the start of the development of the reporting guidance and the information being analysed. This meant that for some areas the information that had been requested was not always ideal for the analysis that was attempted. The reporting requirements clearly place an administrative burden on MS and COM, and all support their simplification. However, the work carried out for this report has shown that the COM needs to complete a detailed assessment across the entire range of issues relating to the WFD and to do this effectively a large amount of accurate, consistent information is required. The reporting guidance and schemas should be reviewed and refined, based on the experience of the first analysis, to enable MS to more accurately provide the information that the COM needs to carry out the assessment to WISE. In order to do this the COM should also clearly define the output that is required, and redundant information should be removed from the schema.

If the Schema are to be amended a balance will need to be struck. Some MS would like to see a large-scale simplification of the schema, whilst others have called for changes to be limited as their information systems are based on the current structure. A compromise will need to be reached.

3.  The COM will continue to have a need to carry out in-depth assessment on new and emerging issues in the water field, and to identify how these are affecting the water environment and are being addressed by MS policies. Some of these will be on-off information collection exercises, whilst others may need to be incorporated into routine reporting. WFD reporting could provide a valuable source of information to support these assessments, but the Reporting Guidance and schemas will need to be adapted to include them. A balance will need to be achieved between agreeing the reporting requirements in sufficient time for the MS to collect and collate the information, whilst allowing the Commission sufficient time to identify what the emerging issues are. This will require some flexibility from both sides.

4.  It has proved to be impossible to carry out a DPSIR-type analysis for the WFD due to the inconsistency in the level of aggregation of reporting of Pressures, Status, Impacts and Measures. An appropriate, consistent, level of aggregation for reporting should be agreed. To allow detailed assessment the provision of information at a water body level might be considered but will need to be balanced against the work required to collate the data, the complexity of collation and analysis, and the uncertainties that may be generated. Further development of the Guidance in certain areas (e.g. what is meant by water bodies at risk, significant pressures) would also result in better reporting in this area.

5.  Information on methodologies was generally under reported and has had to be obtained by reference to specific documents as the textual summaries provided by MS were not of sufficient detail to enable an assessment to be carried out. It is recommended that clearer guidance be provided on the issues that should be covered in the textual summaries. Where possible, tick lists of approaches could be provided, or more specific questions be asked for certain issues. This will require amendment of the schema.

6.  The analysis of the Atkins Helpdesk log shows that, in general, the use of schemas and ReportNet for the submission of information is working well with only small refinements required. The need that has been identified for the COM to have access to some disaggregated data (see recommendation 4) illustrates the need to move to a decentralised reporting system. However, given that most MS are not yet able to extract XML files from their national systems, agreeing a common format to enable this to take place could take a considerable time. As an interim solution, a mechanism should be found to enable MS to provide a limited amount of disaggregated data for key areas of analysis.

7.  Extracting the data from the CDR in a usable form proved complex for those who aren’t familiar with the system. Consideration should be given to the development of an easier to use “analysts front end” for the CDR that enables information to be more easily extracted. The COM has now started bi-lateral discussions with a number of MS and it has become clear that they are interested in benchmarking their performance with others. Providing on-line access for MS to information to enable this to be done easily, and in advance of the publication of the Commission report, may encourage the provision of better quality information “win-win”.

8.  It is clear that full use was not made of information reporting by MS for other Directives that can contribute to the implementation of the WFD (e.g. EPRTR, Habitats Directive). Work on ensuring synergies between reporting streams are fully exploited should be continued, and if possible, accelerated, particularly with those reporting streams that are not directly associated with water, to fully implement the “report once, use many” principle.

9.  It is clear that many MS will review and revise the delineation of water bodies in the next planning cycle. In order to ensure comparability is important that links can be made between the existing water bodies and the new water bodies and MS should ensure that they have systems in place to enable these linkages to be made. Guidance needs to be developed on how this information should be reported. In future reporting information should also be requested on the expected status of water bodies in 2021 and 2027.

10.  There are a number of specific technical areas where it is clear that there has been a difference in understanding of the requirements between COM and MS and between MS and RBDs which has contributed to the incomparability of the information provided. The Guidance (Reporting, CIS, GIS, schema etc.) needs to be reviewed and refined in a number of areas (see Section 4.2) in order to improve the understanding, and hence the quality, of the information required. It is clear that within MS, those who are making the submissions to WISE do not always have a clear understanding of what is needed and that they have not contributed to the preparatory stages of the development of the reporting guidance, nor of the reporting tools. It is recommended that MS ensure that those who will be responsible for providing the information to the COM are kept fully aware of the discussions and agreements that are being held at an EU level.

3.  Synergies with other reporting streams

There are synergies between the WFD and a number of other Directives and European reporting obligations which need to be fully exploited in order to implement the principle of “report once, use many” that was established in the Concept Paper for WISE. However, it is clear that, currently, it is not easy to compare data that are collected under different reporting requirements, for example, SoE and WFD monitoring stations. For some reporting streams that are water related, and report via WISE, there is a simple technical solution in using the water body code and RBD/sub-unit as the common reference for all reporting. However, this may require the adaptation of the reporting requirements for other Directives which will require the agreement of the MS. This approach will also present difficulties for those Directives that are based on administrative areas (e.g. UWWTD and Nitrates). The existing close co-operation of the two “water” related COM units, and the EEA, will facilitate this process. The Floods Directive requires co-ordination with the WFD in the development and reporting of flood management plans, so the reporting in 2016 could be used as an example of how such co-ordination can work. Some MS experts have suggested synchronising frequencies of reporting between Directives. However, this would require a legal amendment to the text and is not something that COM envisages attempting in the near future.

During the interviews it was suggested that a further step that could facilitate the inter-operability of water-related reporting streams would be the development of a common dictionary of European terms (or ontologies). An example of how this might work for typologies, with broad European terms being defined against which MS assign their own types is given below.

In the Reporting Guidance it was made clear that MS should not report information that has already been reported for other reporting streams. In some cases (e.g. Protected Areas) MS were asked to give the code of the protected area under that reporting stream. This led to difficulties in interpretation of the information as, in some MS, the same code is used for a number of different protected areas. In other cases (e.g. point source data reported under E-PRTR) it is not clear whether the information was available for the assessment of the pressures and measures, if it was available, whether it was used, or whether it could not be used because of the information collected for the purposes of E-PRTR was not sufficient for the purposes of the WFD assessment. Resolving this issue may require adaptation of the E-PRTR data flow which may take some time to achieve, and therefore it may be necessary in the short term to request more detailed information from MS on point sources.

4.  Technical issues

4.1  IT issues

An interview was carried out with the Consultants who provided support to the Commission on the IT aspects of reporting. As their main role was to provide support to the MS in providing the data their comments have been included here. It is clear that only a few MS currently have the capability to export XML files from their national systems, and, as a result most MS are using the Access database tool to generate their XML. A number of MS had difficulties when uploading their Access generated XML files to ReportNet, as it was difficult for them to understand the error messages that were generated in the validation. Where possible the documentation was updated to provide information on the common errors that occurred, but due to the complexity of the schema this was not possible in all cases.