Measurement & monitoring implications of the Water Framework Directive
By Michael Scott, Secretary & Director SWIG
A SWIG Workshop in London this February concluded that the Water Framework Directive will have a big impact on the water industry and its suppliers but that there is a great deal of work to be done before we can deal with the monitoring and measurement challenges.
The WFD is based on ecology, which is a new approach that presents new challenges.
Planning The Water Companies will have to take action in time period of AMP 5 which is currently in the planning and approval phases. However they have little hard policy to guide their planning for WFD and this discontinuity will have a material affect on the UK in meeting its obligations under the Directive.
Some of the vital bits of information are not yet available; for example the Agency is awaiting the results of the negotiations on chemical status for the Groundwater Daughter Directive. The EU is currently generating Guidance documents which are then being turned into UK relevant documents.
The Agency has identified some 13000 catchments or aquifers which will require status reports and there is debate on how pollution in one part of such a body will be treated. The WFD emphasis is on water quality, so will a small incident in one corner mean that the whole body is considered to be polluted or over abstracted? The EU requires only a good status/bad status report so it might mean “one out all out”.
Diffuse pollution There will be a need to show that the monitoring and resultant practices are reducing pollution. It might take decades to get back to acceptable levels in some areas since diffuse pollution is going to be a major challenge since it is known that 30 years of nitrate application will take a long time to leach into nearby water courses. On top of this it is difficult to get ecologists to define a “wetland” or other area of special ecological interest and to show the dynamics so that natural changes can be de-convoluted from changes caused by pollution.
Monitoring Self monitoring is now being accepted as admissible evidence. To meet the requirements there is a need for better, more efficient monitoring and pro-active innovation is needed on the methodologies - starting now. EU law might be breached if it can be shown that appropriate monitoring is not available; before the data has been provided to interested parties! Further, when the Aarhus agreement is ratified the data must be made available to the public and presented in a form which is understandable to the public. The courts will now take into account the pre-amble when considering a case and this is a new approach which imposes new burdens on understanding the quality of data.
Article 9 – Monitoring says:
- The Agency must give effect to the provisions of the Directive;
- Monitoring programmes to be established by Dec 2006.
So the bottom line is that DEFRA carry the can and the Agency must deliver There are some difficulties since, under article 21, a committee is to be set up to establish standard methods for monitoring; but it is not yet known when the committee will start work.
It has been suggested that using a risk based approach might reduce the costs but some think that the many stakeholders will insist on the precautionary principle.
The cause of pollution is not always obvious; for example Sterol fingerprinting in the Blackwater Estuary showed that the Brent Geese did it! Some people consider that management of all parts of the “pollution” industry will need to Balance levels of resource and this will require a much more holistic approach to monitoring the environment. There will almost certainly be a need for more co-operation on data sharing but this will require the setting up a co-operation structure. The questions are by whom and at whose cost?
Without a holistic approach there are potential risks that point sources may be over controlled in order to compensate for the lack of effective diffuse pollution regulation. Therefore the WFD should be viewed as a land and water management directive since agriculture is by far the major cause of diffuse pollution.
For groundwater monitoring there is a need to establish a network of sampling points to enable representative samples to identify long and short term trends. The problem is what is the benchmark – historic data? Each groundwater catchment has to be linked with the river basin management plans but these are only now being developed and there are clear problems in merging disparate adjoining interests.
- the nature of the temporal and spatial variability of the target determinand affects the required sampling strategy;
- it is critical to know what a chosen monitoring method monitors in relation to the ecological requirement;
- data/monitoring is expensive and purpose needs to be defined in order to optimise a strategy;
- high frequency monitoring (sensors) is not necessarily the ultimate answer.
The WFD requires the monitoring of the ecological health of systems and the Agency currently monitors stressors on the system and tries to correlate it with the health. The Agency is looking for sophisticated monitoring techniques using biological sensor technologies that can be telemetered. This together with modelling might be a contribution to dealing with the significant increase in monitoring required by the WFD.
The Agency has stated that it is assembling a list, which will publicly available, of determinands and performance requirements; including limit of detection. The sampling programmes (i.e. temporal and spatial considerations) can only be addressed when the Agency has identified the bodies/stretches relevant to the WFD regulation and this may take longer.
The impact of the WFD monitoring and measurement requirements will be increased:
- Capital Cost;
- Operational Cost;
- Operational Complexity;
- Higher levels of resource (people, IT, communications, consumables.