Technical Support for the Impact Assessment of the Review of Priority Substances under Directive 2000/60/EC

Updated Project Method for WG/E Brussels 22/10/10

Presentation

Project

– Reminder: Aim and scope

– Reminder: Tasks

Method

– Evolution and development of methodology

– Summary of key issues (WGE comments on August methodology paper)

– Summary of COM comments on 5th Interim

– Updated methodology

Questions/discussion

Reminder of project aim and scope

Assess the impact, in terms of costs and benefits, of the options for the review of priority substances.

The review considers:

– addition (or removal) of substances from priority list – revision of EQS for existing priority substances – establishment of water, sediment and/or biota EQS for proposed

new substances– addition of sediment or biota EQS for existing priority substances– possible additional EU-level control measures for existing and

newly identified substances

The study covers:– All current EU Member States and Candidate Countries;– All existing and proposed priority substances (Annex II of the

EQSD and new substances identified through the prioritisation process); At this stage we are now focussing on 16 proposed substances, 3

'grey list' proposed substances, and up to 12 existing substances– The impacts of potential new control measures.

Reminder of Project Tasks

Develop a methodology to assess the impacts – Task 1

Identify, review and collect all relevant data – Task 2

Assessment of impacts – Task 3

Provide support to the Impact Assessment Board process– Task 4

Aim of Methodology

Develop a methodology to assess impacts – How to assess the costs and benefits of each aspect

('option') of the review

– Substance-by-substance approach

– However requires recognition of overlaps/common impacts between substances

Evolution and Development of Methodology

Initial methodology discussions with WGE in June 2010

Methods paper circulated to WGE Aug 2010

Comments requested by 10/09/10

Responses in 5th Interim report

Further comments from COM 15/10/10

Responses in 6th Interim report

Summary of key issues identified (WGE)

For PHS, clarify difference between reaching EQS and phase out of emissions- make sure both are adequately considered

Selecting case studies where PECs>EQS may skew results

Concerns with extrapolation process (e.g. volumes, GDP and lack of data in some MS)

Ensure that all benefits captured Is one case study enough (e.g. differences in use

and production across MS)? Measures to phase-out should be covered at EU

level Costs of developing analytical monitoring

techniques

Summary of Comments on 5th Interim report (COM)

More that one case study per substance is needed, unless it can be clearly demonstrated that one case study will provide robust information about how impacts vary across MS.

Case study selection and MS representation Criteria for deciding on whether extrapolation

can be undertaken Assessment of benefits Accuracy of extrapolation of costs and benefits Need to develop a methodology for the

assessment of possible EU level measures Calculation of non-financial costs (e.g.

environmental costs) Robustness of benefits assessment Assessment of non-use benefits

Updated Methodology

Case-study based approach

Initial EU information available, e.g. Ineris database– Used to identify initial case study (based on failures in

Ineris database)

More data collation, including during case study and questionnaire responses– Informs development of further case study (or studies)– Case studies to cover range of impacts between MS

Consider potential for applying at EU level

Step 1: Identification of options

Potential Outcomes of the Priority Substances Review

Existing substances New substances

No change

Change in status from PS to PHS Classification of a substance as a PS or PHS

Change in the EQS for water Establishing an EQS for water, sediment and/or biota

Establishing additional types of EQS (i.e. a standard for biota or sediment)

Introduction of new control measures Introduction of new control measures

Method distinguishes between:• Review outcomes resulting in a change in concentration of a substance• Outcomes that establish EQS for sediment and/or biota for existing substances, where there is no change in the water EQS

Step 2: Identify the EU Baseline

To determine a basic level of understanding of the variability in use, environmental concentrations and control between MS to:– 1. Identify appropriate case studies– 2.Determine the appropriate number of case studies – 3. provide the basis for extrapolation of impacts in

case studies to other MS Further clarification of baseline through initial

case study

Step 3: Initial Case Study (or Studies)

Step 3a. Selection of case study (or studies)– initial case study (or in some cases two) on MS basis– primary selection criteria for initial case study is

monitoring data (EQS failure)– where multiple options, also consider production and

use patterns, WGE contacts and questionnaire returns– careful not to be over-representative of certain MS, as

far as data availability allows Step 3b. Refinement of baseline

– Case study baseline further developed using additional MS-specific information for the specific substance

– More recent and localised monitoring data, distributed information on production, use and emissions, consideration of policy measures at MS and EU level

Step 3: Initial Case Study (or Studies)

Step 3c: Identification of Possible Measures– where environmental concentrations need to be

reduced, practical measures will be required on the ground (which in some cases may be a result of EU policy measures)

– Database of potentially feasible measures used. MS and industry body representatives on WGE contacted to discuss range of potential applicable measures.

Step 3d: Implementation Rate of Measures– to determine how widely the measure needs to be

applied based on:effectiveness of the measurethe level of failure of EQS under current (or projected)

baseline

Step 3: Initial Case Study (or Studies)

Step 3e: Assessment of costs– Costs to Industry

Based on the measures identified in Step 3d– Costs to public bodies

Monitoring costs incurred by regulatory authorities estimated using information from questionnaires

– Environmental and social costs

Vary between substance. e.g. calculation of carbon costs and electricity use, based on standard methods

Step 3: Initial Case Study (or Studies)

Step 3f: Assessment of benefits– Focus on aquatic ecosystems and human health (via

environmental exposure)

– Initial qualitative description of all possible benefits

– Environmental benefitsnon-use likely to be significantunlikely to be quantifiable benefit transfer will be explored

– Human health benefitsqualitative assessment if available academic studies not readily

transferable

– Financial benefitse.g. avoided treatment costs, commercial fisheries, sewage

sludge disposal

– Recreationalbenefits to tourism and water related recreation

Step 4: Additional case studies

Need for additional case studies identified as a response to WG E comments and COM comments on Methodology paper

Not completely sequential- timing of case studies will overlap

Additional studies undertaken to ensure:– Range of measures covered– Range of environmental concentrations covered– Validation phase between case studies and EU-level

Requires second stage of consultation

Step 5: EU-level impacts

Step 5a: Completion of EU level baseline– calculator to extrapolate to EU MS– hierarchical approach depending on data availability– consideration of uncertainty

Step 5b: Scaling up the case study results to EU level– Assumes measure considered appropriate in one MS

can be applied to others. Use more than one case study to validate this assumption

– qualitative assessment of EU impacts where not appropriate

Step 6: Combined assessment between substances

Approach thus far has been substance-specific

Recognise there may be overlaps, e.g. due to limited number of measures, with one measure addressing more than one substance

– Develop matrix of substances and measures to identify areas of overlap

– Use to scale back total costs appropriately

In theory could also have compounding impacts, e.g. if one substance would have been a substitute for another. Recognise as appropriate

Thank you.

Questions?

Note: please contact Heather Musgrave (musgh@entecuk.co.uk in future rather than Oliver Warwick