Improving Water Framework Directive compliance assessments
Ashley Carton, from Black & Veatch, discusses how practitioners can enhance Water Framework Directive compliance assessments (WDFCAs)
WFDCA are now a mandatory requirement for all new modifications to water bodies in the EU and have quickly become an integral part of environmental assessments of the aquatic environment, however, much can be done to refine the execution of these assessments.
In 2011, interviews were carried out with environment practitioners responsible for carrying out WFDCA on some of the UK’s foremost water management construction schemes, as well as with the then head of the Environment Agency’s National Environmental Assessment Service (NEAS).
The interviews covered key issues encountered in WFDCA, including how easy they were to complete, their place in the environmental assessment regime and their contribution to sustainable development.
WFDCA were deemed as highly successful in emphasising ecological and hydromorphological concerns, and in providing the legal backing needed to maintain this focus.
However, a number of concerns were raised about the completion of assessments, including the lack of accessible and high-quality water body information; an overreliance on expert judgement; and the high level of certainty that is required, but not easily achieved.
Based on these results a list of recommendations has been drawn up to suggest improvements to the WFDCA procedure that would ensure their effective, efficient and consistent completion. These include:
Improved quality and availability of baseline data
Pragmatism is essential; the best use must be made of available data since its collection is expensive. However, it is clear that data issues rank highly among the challenges faced by consultants completing assessments. There is consensus that the baseline data contained in river basin management plans (RBMPs) need to be improved as a matter of urgency both in terms of quality and availability. The availability of more specific guidance on where water-quality class boundaries and “tripping” thresholds fall would also be useful, as well as material indicating when a scheme might be at risk of either failing to be WFD compliant or of causing deterioration.
Increased professional consultation
Expert judgement is a crucial part of WFDCA; it is used to identify and screen possible options and to assess relevant effects and mitigation measures. However, it was felt by those interviewed that the exercise of expert judgement in decision-making must be complemented by extensive collaboration. When reviewing assessments the Environment Agency looks for evidence that decisions are supported by more than one practitioner and that opinions have been sought from specialists within the agency. Owing to the relative novelty of WFDCAs regular discussions are to be encouraged between consultants from different organisations, perhaps in an online forum, to discuss problems as they arise.
Increased involvement of NGOs in RBMP
Close working relationships between stakeholders are necessary for the effective implementation of WFDCA. The output of the interviews suggested that more contact was required with local agencies with a working knowledge of water bodies in RBMPs, to corroborate the science in the plans. Contributions should also be sought from the River Trust, the River Restoration Centre, fisheries, landowners and farmers. Strong links ought to be fostered between the Environment Agency and other organisations that monitor water bodies in order to establish common databases.
Monitoring is crucial to the management of complex ecosystems and in reporting on their status and any improvements to the rest of the EU. Monitoring would help to ensure that the measures proposed in WFDCA are incorporated into the operation of schemes; it would also prove vital to informing future projects.
Early consideration of WFD objectives
It is essential that WFD issues are considered from the beginning of a scheme to help identify the best possible option for the environment. The appropriate implementation of WFDCA at strategic environmental assessment level is very important to the effective delivery of the WFD. This can be problematic, however, as the scoping stage of WFDCA demands much more detail than the scoping stage of a traditional environmental impact assessment. The overlap between the assessment levels can also create problems of duplication in ecological and water-quality data.
Evolving guidance documents
It is imperative that the Environment Agency continues to provide up-to-date, clear and concise guidance material on effective implementation of WFDCA. These should cover emergent issues, such as the effectiveness of different mitigation measures, and any recent revisions to them, while also addressing the issues causing most confusion for practitioners. Suggestions from the interviews included potentially incorporating a more mechanistic template into parts of WFDCA documentation, and increased guidance on linking ecology and hydromorphology in assessments.
The implementation and execution of WFDCA in the UK is of the utmost importance, and the engineering design and construction industry have a key role to play in its integration into the sustainable development of the water environment. By addressing the above recommendations it will be possible to strengthen the knowledge base on which decisions in the WFDCA process are made.
This article was written as a contribution to the EIA Quality Mark’s commitment to improving EIA practice.
Ashley Carton is a graduate environmental scientist at Black & Veatch
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