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Meetings & Events
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| The Water Framework
Directive and Groundwater in the UK
This Groundwater Forum meeting
was held in Solihull, Birmingham on 21 March 2002. Over 100
people attended the meeting, drawn from the regulators, the
water industry, consultancies and academia. The presentations
were given by some of those who have been involved in the development
and implementation of the Water Framework Directive in the UK,
giving attendees the chance to hear directly about the current
state of the Directive and plans for its future implementation.
A lively discussion of a wide variety of issues took place following
the presentations. The information on this page is intended
to summarise what took place at the meeting. The
meeting programme is given below, with a summary of each of
the presentations (plus the presenter's slides in some cases
nb. you will need to have PowerPoint to see the slides) followed
by a bulleted summary of the general discussion at the end
of the presentation sessions.
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| The
Water Framework Directive and Groundwater
Peter Pollard, SEPA
Peter Pollard provided an overview of the Water Framework
Directive as it pertains to groundwater. The slides from the
presentation can be seen or downloaded from here
(454Kb). Peter started off by stating that, although complex,
the Directive is based on straightforward principles, and
introduced the following points:
- the important dates by which the Directive will be implemented
- the concepts involved in River Basin Management Plans
- the concepts involved in groundwater bodies
- groundwater status objectives: quantitative and qualitative
(including the Groundwater Daughter Directive)
- Surface receptors and chemical status: surface water objectives
(including ecological status classes); significant diminuation
in chemical or ecological quality, or significant damage
to terrestrial ecosystems); intrusions
- objective setting: protected area objectives, trend reversal
objectives and prevent or limit inputs objectives.
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Terminology
and concepts: groundwater bodies and river basin
Steve Fletcher, Environment Agency
Steve Fletcher presented a view of the nature of the parts of
the Directive dealing with groundwater bodies and river basins,
starting off with the statement that we should ‘work out
what’s in the spirit of the Directive and what we are
trying to achieve’. The slides from the presentation can
be seen or downloaded from here
(3,293Kb). Steve covered the following points:
- the different treatment of definitions of water quantity/resources
from water quality under the Directive
- definitions of groundwater, surface water and drinking
water bodies, and how they are important under the Directive
- how to define groundwater bodies: conceptual modelling,
setting boundaries and sub-dividing
- requirements for initial and further characterisation
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Definition
and characterisation of groundwater bodies
Dave Allen, British Geological Survey
Dave Allen described some of the work of an ongoing project
by the Environment Agency and the British Geological Survey
that aims to develop procedures for characterising groundwater
bodies. The slides from the presentation can be seen or downloaded
from here (298 Kb).
Dave covered the following points:
- groundwater bodies form the principal management units
under the Directive. They should be hydraulically continuous
entities, and must be defined on the basis of flow or abstraction,
and are inextricably linked to surface water bodies. Only
rock units from which there is very low or no abstraction
and which affect no surface water bodies will be exempt
- a methodology for characterising groundwater bodies is
being developed, designed to fit with other parts of the
Directive, which will be trialled in real catchments. This
is an iterative process, based on developing conceptual
models of groundwater bodies using existing data only during
initial characterisation and refining them if necessary
during further characterisation
- based on this groundwater body status and an analysis
of pressures from anthropogenic activities, ‘At Risk’
assessments will be made of those groundwater bodies which
may fail to achieve good status
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Groundwater
Quality and the Groundwater Daughter Directive – work
in progress
Tony Marsland – Environment Agency
Tony Marsland presented a view of the current standing of the
Groundwater Daughter Directive, which covers specific measures
to prevent and control groundwater pollution, and will eventually
replace the existing Groundwater Directive, although the scope
of the Daughter Directive is greater. Tony covered the following
points:
- the groundwater objectives: e.g. prevent or limit pollutant
input to groundwater and prevent deterioration of status
of all groundwater bodies; protect, enhance and restore
groundwater bodies
- definitions of good status: e.g. no saline or other intrusions;
concentrations not exceeding quality standards in other
relevant legislation and not so high as to cause failure
of surface water, terrestrial and abstraction objectives
- background to the Expert Advisory Forum and Technical
Discussion groups working at EC level to complete the Daughter
Directive by autumn 2002, so that it can be put in place
by December 2002
- key issues include:
- the integration of surface water and groundwater objectives
- a potential new ‘high chemical status’
to protect pristine groundwaters
- what exactly is a pollutant?
- benchmarks for good status
- 3 types of standards: for status definition; for remediation;
and for prevent or limit (release of pollutants to groundwater)
- the role(s) of monitoring data
- There is a wide spectrum of approaches to groundwater
standards that is currently being narrowed down. Hopefully
the Daughter Directive will allow flexibility in implementation:
the current efforts in providing technical support to DEFRA
are having a major influence
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Monitoring
requirements for groundwater under the Water Framework Directive
Rob Ward, Environment Agency
Rob Ward introduced the overarching objectives of monitoring
to meet the requirements of the Water Framework Directive. The
slides from the presentation can be seen or downloaded from
here (259Kb). Rob covered
the following points:
- groundwater monitoring programmes must be in place by
December 2006 to provide a reliable assessment of groundwater
quantitative and chemical status and assess any pollutant
trends in all groundwater bodies
- a risk-based approach will be taken, and monitoring must
be consistent with other statutory and environmental needs
- quantitative status: groundwater level is the key parameter.
Need sufficient density of monitoring points in each groundwater
body to fully assess groundwater levels, and additionally
in each ‘At Risk’ groundwater body to assess
risk. Need sufficient frequency to assess status in all
groundwater bodies, and additionally in ‘At Risk’
bodies to assess impacts
- chemical status: needed at 2 levels: surveillance (to
supplement groundwater body characterisation), operational
(in ‘At Risk’ bodies to assess long-term anthropogenically-induced
trends. Need data representative of the whole of each groundwater
body/group of bodies. Chemical status will be interpreted
by aggregating mean values for each groundwater body as
a whole
- CAMS is providing the framework for monitoring under the
Directive
- Supporting initiatives are being carried out at Europe
level (the Common Implementation Strategy) and by the EA
(the Groundwater Monitoring Strategy)
- the determinands to be monitored during surveillance and
operational monitoring have not been finalised
- a partnership approach is needed to deliver effective
monitoring and the required outputs
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Scientific
challenges for the implementation of the Water Framework Directive
(with a bit on training)
John Tellam, University of Birmingham
The slides from John Tellam’s presentation can be seen
or downloaded from here
(936Kb). John started off by stating a view shared by BGS that
the Directive doesn’t throw up any new knowledge requirements,
but does highlight existing knowledge gaps and related problems
and opportunities, including:
- we currently know ‘something about everything’
in hydrogeology, but in some areas we know very little
- without a basic understanding of issues such as heterogeneity
and scales of heterogeneity; 4 dimensional flow, velocity
and chemical processes; and ecosystem/groundwater flow/chemical
relationships, a proper understanding of groundwater and
groundwater bodies is impossible
- too much of current research is geared towards short-term
results, funded by the regulators and industry, while long-term
basic research on the main issues is largely untargeted,
largely because it brings limited immediate benefits
- each aquifer/groundwater body is unique and it is difficult
to transfer research results from one to another there seems
to be a growing shortage of suitably qualified and experienced
groundwater professionals, coupled with an increasing workload
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The
Water Framework Directive and Groundwater – the water
industry perspective
Jacob Tompkins, Water UK
Jacob Tompkins summarised the outlook and concerns of the water
industry, including the following points:
- although the UK is less reliant on groundwater than some
other EU Member States, there is still a high reliance on
groundwater and it is correspondingly of fundamental importance
to the water industry
- all stakeholders should be involved in the Directive’s
implementation, including farmers, local councils and planners
(e.g. in housing development) as well as the water suppliers
and regulators. ‘Joined up thinking’ is needed
for effective water management
- all groundwater must be protected, not just drinking water,
although water companies currently have no statutory duty
relating to raw water quality
- the water industry may play a large part in meeting the
objectives of the Directive, but has specific concerns,
e.g.:
- need to know baseline quality for effective restoration
- the lack of groundwater data may lead to overuse of
the precautionary principle, impacting on abstraction
- a national groundwater database is needed
- licence requirements, including for monitoring, are
not coordinated
- use of data from water companies and other abstractors
is difficult because of confidentiality
- water industry monitoring does not currently include
routine measurement of standard parameters, and current
sampling frequencies may not meet Directive requirements
- there are cost, operational, health and safety and
quality control implications to sampling
- protocols for cooperation in monitoring and sharing data
are being developed. Most water companies are interesting
in sharing data with the regulators, but need to deal with
the concerns listed above
- in conclusion, the water industry perspective is that:
- qualitative and quantitative aspects must be considered
together
- need definition of responsibilities in order to meet
objectives
- need to move away from end-of-pipe solutions
- may need changes in government policy to allow for
a changing water industry role
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Discussion
following presentation sessions
The issues raised by the speakers generated much discussion
among the participants. The main areas of discussion are summarised
below.
- What does the Water Framework
Directive say about surface waters affecting groundwater
status, e.g. poor quality losing streams or sewage discharges
recharging groundwater?
- The Water Framework Directive does not currently define
groundwater as a receptor but in terms of its impact
on surface water and terrestrial ecosystems. If groundwater
quality doesn’t impact on these, groundwater status
is not affected.
- Poor groundwater quality caused by surface water intrusion
may affect Drinking Water regulations but these are
not linked to groundwater status?
- There is some pressure to define groundwater a receptor
as well.
- Regarding the precautionary approach
to characterising groundwater bodies: could measures will
be implemented to constrain groundwater abstraction because
a lack of data means groundwater bodies can be characterised
as ‘At Risk’ when they may not be? Could there
be another category, e.g. ‘Not Proven’?
- In cases where lack of data restricts characterisation,
these groundwater bodies will be subject to further
characterisation, which requires data collection.
- The ‘At Risk’ category is mandatory under
the Water Framework Directive, but there are compensations
in that improvement efforts are focused on bodies defined
as ‘At Risk’.
- In practice there is enough data for basic characterisation
in most areas, even in parts of Wales and Scotland where
groundwater is not a major supply.
- Ensuring there is enough data is therefore a management
priority.
- It seems that we need the right
type of data as well as the right amount – requirements
seem to be for detailed data.
- There needs to be a tiered approach: during initial
characterisation, hydrogeologists can make use of ‘educated
guesses’/expert assessments. If these are felt
to be insufficient in certain areas, those areas should
be subject to further characterisation.
- Rigorous numerical groundwater modelling can be used
to test conceptual models where there is enough data.
- What does the Water Framework
Directive say about totally confined aquifers from the surface
water aspect?
- Most confined aquifers have an outcrop area and the
related groundwater body would probably extend from
the outcrop area to the furthest extent of the aquifer.
Surface water bodies may be related where they run across
outcrop or discharge points of the confined aquifer.
- If there is no outcrop area (e.g. London Basin?),
no abstraction or plans for abstraction and it doesn’t
affect surface water, a confined aquifer may not be
covered by the Water Framework Directive. In this case
does the aquifer need to be managed?
- There is no requirement to delineate a groundwater
body if groundwater is not used and does not affect
surface water, unless there is a pressure on the groundwater
(e.g. ASR). Assessments must be done on a sound hydraulic
basis & must also be renewed every 6 years, allowing
new pressures to be identified.
- What about ASR? Does it count
as injecting ‘pollution’ (water of different
quality) to a confined aquifer?
- Any aquifer used for ASR would have to be classified
as a groundwater body.
- The ‘prevent or limit’ measures expressly
forbid the injection of pollution to a confined aquifer.
The position of ASR may remain unclear?
- The current Groundwater Directive
doesn’t define what ‘prevent’ means. Will
the Groundwater Daughter Directive define it?
- For priority hazard substances, ‘prevent’
is defined as eliminating discharge at eh surface; for
other priority substances it is defined as reducing
discharge to ‘very small values’. There
is some flexibility so that very small discharges need
not be dealt with if they are judged not to have a negative
impact.
- How does the UK compare to other
EU states in terms of implementation measures? – are
we taking a ‘Rolls Royce’ approach?
- Not in terms of groundwater quality: e.g. one approach
is to apply 75 % of Drinking Water standards across
the boards, which is not being advocated in the UK.
Efforts are being made to ensure local flexibility and
if possible, fit in with existing measures – e.g.
‘prevent and limit’ measures generally fit
with existing Groundwater Directive.
- Not clear how measures for groundwater quantity compare
with other EU member states.
- There is a common implementation policy with working
groups spanning member states trying to ensure consistency,
e.g. in defining groundwater bodies.
- How might the Water Framework
Directive allow increased opportunities to get necessary
things done?
- The explicit relationship between surface water and
groundwater is a step forward and should be taken advantage
of.
- There are concerns over what exactly the Water Framework
Directive is trying to do: e.g. it doesn’t allow
for protection of specific wetlands, but for preventing
overall chronic fall in groundwater levels. There is
a perception that the Water Framework Directive has
a greater scope than it actually does, particularly
on the quantity side. It actually needs careful interpretation
to achieve the necessary aims.
- What about the possible definition
of a ‘High Chemical Status’ category: is the
aim of this to improve all groundwater bodies to high status
(e.g. in Germany & Austria)?
- High status isn’t intended to become a restoration
target, even by those pushing for its existence.
- The name is a misnomer as it is really about protecting
existing pristine groundwaters, which currently exceed
Drinking Water standards, by creating protected areas.
A ‘high status’ category will need to be
qualified by lots of exemptions.
- Perhaps it should be termed a ‘standard’
not ‘status’.
- Taken in conjunction with ‘prevent and limit’
measures, high status should provide a vehicle to prevent
all defined groundwater bodies deteriorating to their
lowest possible quality limits.
- Regarding quality monitoring,
the basic chemical parameters specified by the Water Framework
Directive are too few even for surveillance monitoring.
- Monitoring needs are going to have to be driven by
working requirements and not by the minimum requirements
of the Directive.
- Where new data are required,
will the Environment Agency look to drill new boreholes
for monitoring or look to water companies?
- There will need to be cooperation to ensure more effective
monitoring and good data transfer, driven by needs on
all sides.
- Regarding the direction of research,
this should be driven by actual needs, which are largely
defined by legislative agendas.
- This can address immediate needs but there is a danger
that long term needs are missed out – i.e. we
should be addressing the ‘spirit’ rather
than the letter of legislation.
- ‘Short term’ research can address basic
needs too but need to be better disseminated, e.g. commercial-scale
projects on contaminated sites, which largely go unreported
in the literature.
- There also needs to be more overlap between hydrogeology,
hydrology and ecology, which may only be addressed by
‘longer term’, strategic research –
e.g. LOCAR, which is trying to achieve more interdisciplinary
research.
- Private abstractors represent
c. 80 % of total licences (not volume of abstraction) –
shouldn’t they be included in monitoring; e.g. a requirement
to collect data?
- The EA are considering other data sources, although
currently any agreements are voluntary. There may be
problems in terms of who has responsibility for monitoring.
- Are groundwater bodies going
to be very large? If they are subdivided, there are difficulties
in using groundwater divides and flowlines to do this.
- The original premise is to be able to do a water balance
across the whole groundwater body. If it is too large
to be manageable, it must be divided somehow. Flowlines
have drawbacks but also advantages, and are accurate
enough for purpose in most cases. The Water Framework
Directive only asks for an average water balance: anything
more than this would have to be done as and when required
by the competent body for its own management purposes
or interest.
- There is an on-going debate between chemical and quantitative
criteria and the size of groundwater bodies. The desired
result of groundwater bodies is that they allow proper
groundwater management: i.e. present a realistic picture
of groundwater resources in the UK.
- From the quality POV, the sensible approach is to
start with as large a groundwater body as possible and
only subdivide if required by practical factors.
- Groundwater bodies aren’t fixed permanently
– they can be changed if required, e.g. if they’re
not sensible management units.
- In Ireland there are likely to be 300-400 groundwater
bodies, but as work starts in the next year the actual
number required should become more obvious.
- Is there an overemphasis on monitoring
at the expense of managing groundwater? There has been little
emphasis at European level on characterising groundwater
bodies, risk based assessment, etc, than on monitoring strategies.
Characterisation should continue past 2004 if needed, not
just monitoring.
- Up to now European meetings on characterisation have
looked just at surface water but there will be a sub-group
for groundwater. The EC will be issuing guidance on
delineating groundwater bodies.
- Monitoring is in the Water Framework Directive to
support its implementation but it shouldn’t drive
the Directive. It provides a good opportunity to get
new data, but care should be taken to ensure this is
good data.
- If rock units providing even
very small abstractions (a single supply point of >=
10 m3/day or a total supply of >= 100 m3/day) must be
classified as groundwater bodies, does the Oxford Clay,
etc, count?
- Yes, but most attention can be focussed on the most
important aquifers.
- This will probably raise lots of local environmental
and other issues by providing a base to address ‘nimby’-type
issues, and could therefore divert resources away from
more important things.
- If we have to subdivide CAMS
units into groundwater bodies because of variations across
them, we could end up with 1000s of bodies.
- Also, many CAMS units are out of sync with groundwater
catchments.
- Who is coordinating all Water
Framework Directive river basin areas, for surface water,
groundwater, flooding, etc?
- There is a hierarchy of groups and subgroups stemming
from government that span the UK and the issues. The
existing planning systems (CAMS, Shoreline action plans,
etc) all have to be integrated too in order to make
the Water Framework Directive effective, while maintaining
their strengths and functionality.
- Are environmental objectives
being set based on ‘natural’ or engineered environments?
- The thrust of the Water Framework Directive is to
reduce anthropogenic effects, so in principle natural
environments should form the basis for objectives.
- It’s often difficult to tell the difference
between natural and engineered environments except in
obvious cases of pollution.
- CAMS developed a methodology to decide how much river
flow is needed to maintain ecological requirements,
to naturalise river flows by taking out abstraction,
and to determine how over-abstracted the river is. This
fits with the Water Framework Directive and is part
of the sustainability framework.
- We also need to recognise natural ranges in flow regimes.
- Surface water classifications are based on a range
of conditions starting from (semi) natural reference
states. Current projects are looking at reference states/conditions
in fresh waters and estuaries and coming up with criteria.
- The Water Framework Directive
specifically allows for heavily modified surface water bodies:
what about modified groundwater bodies, especially where
they have no ecological impact? We need to be practical
about getting rid of waste.
- Eureau have a working group on this issue especially
looking at implications for recharge and ASR and how
the Water Framework Directive will impact on these.
It should be possible to inject water of an equal or
better quality than resident groundwater. Currently,
EU member states have very different interpretations
of terminology e.g. relating to abstraction under cities
or injection of brines from reverse osmosis.
- There are clauses in the Directive allowing ASR with
conditions. Need to ensure that these conditions are
flexible.
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Summary
- The Water Framework Directive exists in the context of
the planning framework that empowers regulators to achieve
environmental objectives in a context of published plans,
open discussion and set timetables.
- There is still a lot of detail to come out in the process
of interpreting the Water Framework Directive and finalising
implementation measures. The exact responsibilities of different
agencies are still to be worked out.
- It is clear in the context of past UK and other European
experiences that there must be flexibility in standards
and implementation measures so that they are locally relevant.
- The current process is not a one-off: the Water Framework
Directive will be implemented over a long time scale and
is an iterative process, so there will be ongoing refinement.
- Implementation of the Directive should mean greater focus
on outcomes, better data and improved cooperation between
regulators and abstractors. Related benefits include the
fact that a new institutional framework in Scotland and
other EU member states is being built around Water Framework
Directive drivers, so that planning officials are becoming
more aware of groundwater-environmental interactions.
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