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Published Results: FCMonitoringReportin...

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2.1 Who are you?([ID2.1])
2.2. Please give your country of residence/establishment([ID2.2])
Other, please specify below([ID2.21])
2.3. Please indicate your preference for the publication of your response on the Commission’s website:([ID2.3])
2.4. Please give your name if replying as an individual/private person, otherwise give the name of your organisation([ID2.4])
2.5. Please provide your email address if you would like to be informed of the outcome of this consultation([ID2.5])
3.1 Overall impression On the whole, are you satisfied, fairly satisfied, not very satisfied or not at all satisfied with environmental Monitoring and Reporting requirements?([ID3.1])
If you are not satisfied, could you give the reason(s)?([ID3.15])
3.2 Overall perception Please choose the environmental policy area(s) for which you are familiar with the Monitoring and Reporting requirements.([ID3.2])
We are interested in getting more information about your perceptions as regards the policy area(s) you are familiar with. See below the two questions related to section 4. Current perceptions of environmental reporting (after these questions, please continue with question 3.3). 4.1 Effectiveness You declared you are familiar with the following policy area: AIR QUALITY AND POLLUTION. Which of these statements do you consider as appropriate about the amount of information that is collected?([ID4.1AQ])
Do you have specific comments, concrete examples or specific evidence that could underpin your response?([ID4.15AQ] )
4.2. Efficiency You declared you are familiar with the following policy area: AIR QUALITY AND POLLUTION. Which of the following statements do you consider appropriate when assessing the cost and administrative burden of the reporting process?([ID4.2AQ] )
Do you have specific comments, concrete examples or specific suggestions?([ID4.25AQ])
Are you able to provide any quantitative evidence or references relating to the costs of monitoring and reporting for authorities, regulators, sectors or businesses?([ID4.26AQ])
We are interested in getting more information about your perceptions as regards the policy area(s) you are familiar with. See below the two questions related to section 4. Current perceptions of environmental reporting (after these questions, please continue with question 3.3). 4.1 Effectiveness You declared you are familiar with the following policy area:BIODIVERSITY AND NATURE. Which of these statements do you consider as appropriate about the amount of information that is collected?([ID4.1BIO])
Do you have specific comments, concrete examples or specific evidence that could underpin your response?([ID4.15BIO])
4.2. Efficiency You declared you are familiar with the following policy area: BIODIVERSITY AND NATURE. Which of the following statements do you consider appropriate when assessing the cost and administrative burden of the reporting process?([ID4.2BIO])
Do you have specific comments, concrete examples or specific suggestions?([ID4.25BIO])
Are you able to provide any quantitative evidence or references relating to the costs of monitoring and reporting for authorities, regulators, sectors or businesses?([ID4.26BIO])
We are interested in getting more information about your perceptions as regards the policy area(s) you are familiar with. See below the two questions related to section 4. Current perceptions of environmental reporting (after these questions, please continue with question 3.3). 4.1 Effectiveness You declared you are familiar with the following policy area: CHEMICALS. Which of these statements do you consider as appropriate about the amount of information that is collected?([ID4.1CHE])
Do you have specific comments, concrete examples or specific evidence that could underpin your response?([ID4.15CHE])
4.2. Efficiency You declared you are familiar with the following policy area: CHEMICALS. Which of the following statements do you consider appropriate when assessing the cost and administrative burden of the reporting process?([ID4.2CHE])
Do you have specific comments, concrete examples or specific suggestions?([ID4.25CHE])
Are you able to provide any quantitative evidence or references relating to the costs of monitoring and reporting for authorities, regulators, sectors or businesses?([ID4.26CHE])
We are interested in getting more information about your perceptions as regards the policy area(s) you are familiar with. See below the two questions related to section 4. Current perceptions of environmental reporting (after these questions, please continue with question 3.3). 4.1 Effectiveness You declared you are familiar with the following policy area: NATURAL RESOURCES. Which of these statements do you consider as appropriate about the amount of information that is collected?([ID4.1NR])
Do you have specific comments, concrete examples or specific evidence that could underpin your response?([ID4.15NR])
4.2. Efficiency You declared you are familiar with the following policy area: NATURAL RESOURCES. Which of the following statements do you consider appropriate when assessing the cost and administrative burden of the reporting process?([ID4.2NR])
Do you have specific comments, concrete examples or specific suggestions?([ID4.25NR])
Are you able to provide any quantitative evidence or references relating to the costs of monitoring and reporting for authorities, regulators, sectors or businesses?([ID4.26NR])
We are interested in getting more information about your perceptions as regards the policy area(s) you are familiar with. See below the two questions related to section 4. Current perceptions of environmental reporting (after these questions, please continue with question 3.3). 4.1 Effectiveness You declared you are familiar with the following policy area: NOISE. Which of these statements do you consider as appropriate about the amount of information that is collected?([ID4.1NO])
Do you have specific comments, concrete examples or specific evidence that could underpin your response?([ID4.15NO])
4.2. Efficiency You declared you are familiar with the following policy area: NOISE. Which of the following statements do you consider appropriate when assessing the cost and administrative burden of the reporting process?([ID4.2NO])
Do you have specific comments, concrete examples or specific suggestions?([ID4.25NO])
Are you able to provide any quantitative evidence or references relating to the costs of monitoring and reporting for authorities, regulators, sectors or businesses?([ID4.26NO])
We are interested in getting more information about your perceptions as regards the policy area(s) you are familiar with. See below the two questions related to section 4. Current perceptions of environmental reporting (after these questions, please continue with question 3.3). 4.1 Effectiveness You declared you are familiar with the following policy area: SOIL. Which of these statements do you consider as appropriate about the amount of information that is collected?([ID4.1SO])
Do you have specific comments, concrete examples or specific evidence that could underpin your response?([ID4.15SO])
4.2. Efficiency You declared you are familiar with the following policy area: SOIL. Which of the following statements do you consider appropriate when assessing the cost and administrative burden of the reporting process?([ID4.2SO])
Do you have specific comments, concrete examples or specific suggestions?([ID4.25SO])
Are you able to provide any quantitative evidence or references relating to the costs of monitoring and reporting for authorities, regulators, sectors or businesses?([ID4.26SO])
We are interested in getting more information about your perceptions as regards the policy area(s) you are familiar with. See below the two questions related to section 4. Current perceptions of environmental reporting (after these questions, please continue with question 3.3). 4.1 Effectiveness You declared you are familiar with the following policy area: WASTE. Which of these statements do you consider as appropriate about the amount of information that is collected?([ID4.1WAS])
Do you have specific comments, concrete examples or specific evidence that could underpin your response?([ID4.15WAS])
4.2. Efficiency You declared you are familiar with the following policy area: WASTE. Which of the following statements do you consider appropriate when assessing the cost and administrative burden of the reporting process?([ID4.2WAS])
Do you have specific comments, concrete examples or specific suggestions?([ID4.25WAS])
Are you able to provide any quantitative evidence or references relating to the costs of monitoring and reporting for authorities, regulators, sectors or businesses?([ID4.26WAS])
We are interested in getting more information about your perceptions as regards the policy area(s) you are familiar with. See below the two questions related to section 4. Current perceptions of environmental reporting (after these questions, please continue with question 3.3). 4.1 Effectiveness You declared you are familiar with the following policy area: WATER. Which of these statements do you consider as appropriate about the amount of information that is collected?([ID4.1WAT])
Do you have specific comments, concrete examples or specific evidence that could underpin your response?([ID4.15WAT])
4.2. Efficiency You declared you are familiar with the following policy area: WATER. Which of the following statements do you consider appropriate when assessing the cost and administrative burden of the reporting process?([ID4.2WAT])
Do you have specific comments, concrete examples or specific suggestions?([ID4.25WAT])
Are you able to provide any quantitative evidence or references relating to the costs of monitoring and reporting for authorities, regulators, sectors or businesses?([ID4.26WAT])
3.3. Objectives How important do you rate these different objectives (which relate to relevance and coherence) for setting environmental Monitoring and Reporting requirements? : Monitoring and reporting should allow for an assessment of whether EU legal obligations are being met ([ID3.31])
3.3. Objectives How important do you rate these different objectives (which relate to relevance and coherence) for setting environmental Monitoring and Reporting requirements? : Monitoring and reporting should allow stakeholders to understand the state of the environment and the actions taken to maintain and improve it ([ID3.32])
3.3. Objectives How important do you rate these different objectives (which relate to relevance and coherence) for setting environmental Monitoring and Reporting requirements? : Monitoring and reporting should indicate how well the legislation is working (i.e. costs and benefits) ([ID3.33])
3.3. Objectives How important do you rate these different objectives (which relate to relevance and coherence) for setting environmental Monitoring and Reporting requirements? : Monitoring and reporting should generate reliable environmental information and ensure access to environmental information for citizens so they understand what EU legislation achieves ([ID3.34])
3.3. Objectives How important do you rate these different objectives (which relate to relevance and coherence) for setting environmental Monitoring and Reporting requirements? : Monitoring and reporting should allow comparison between Member States as regards their performance when implementing EU environment law ([ID3.35])
3.4. Principles How important do you rate these different criteria for setting environmental Monitoring and Reporting requirements and delivering EU value added? : Comprehensive: Monitoring and reporting should provide a very detailed picture ([ID3.41])
3.4. Principles How important do you rate these different criteria for setting environmental Monitoring and Reporting requirements and delivering EU value added? : Efficiency: Monitoring and reporting should cover the information on the costs and benefits of the action ([ID3.42])
3.4. Principles How important do you rate these different criteria for setting environmental Monitoring and Reporting requirements and delivering EU value added? : Coherence: Information should be collected once, and shared where possible for many purposes (minimise overlap) ([ID3.43])
3.4. Principles How important do you rate these different criteria for setting environmental Monitoring and Reporting requirements and delivering EU value added? : Proportionality: A balance should be struck between asking for more information, and the cost of that provision ([ID3.44])
3.4. Principles How important do you rate these different criteria for setting environmental Monitoring and Reporting requirements and delivering EU value added? : Accessibility: Reported information should be fully available to the general public, after due consideration of the appropriate level of aggregation and subject to appropriate confidentiality constraints ([ID3.45])
3.4. Principles How important do you rate these different criteria for setting environmental Monitoring and Reporting requirements and delivering EU value added? : Timeliness: Monitoring and reporting information should be timely and up to date ([ID3.46])
4.3. Different governance levels As well as environmental reporting obligations towards DG Environment, there are a number of international obligations, for example, to European marine conventions, OECD, UN, and UNECE. Attention needs to be made to ensuring that synergies are exploited between these commitments, and that inconsistencies are avoided. What are the levels of governance where there is the biggest potential to combine or streamline reporting requirements in order to reduce costs and administrative burdens? : International (wider than Europe) ([ID4.31])
4.3. Different governance levels As well as environmental reporting obligations towards DG Environment, there are a number of international obligations, for example, to European marine conventions, OECD, UN, and UNECE. Attention needs to be made to ensuring that synergies are exploited between these commitments, and that inconsistencies are avoided. What are the levels of governance where there is the biggest potential to combine or streamline reporting requirements in order to reduce costs and administrative burdens? : European Commission ([ID4.32])
4.3. Different governance levels As well as environmental reporting obligations towards DG Environment, there are a number of international obligations, for example, to European marine conventions, OECD, UN, and UNECE. Attention needs to be made to ensuring that synergies are exploited between these commitments, and that inconsistencies are avoided. What are the levels of governance where there is the biggest potential to combine or streamline reporting requirements in order to reduce costs and administrative burdens? : Member State (including national Competent Authority) ([ID4.33])
4.3. Different governance levels As well as environmental reporting obligations towards DG Environment, there are a number of international obligations, for example, to European marine conventions, OECD, UN, and UNECE. Attention needs to be made to ensuring that synergies are exploited between these commitments, and that inconsistencies are avoided. What are the levels of governance where there is the biggest potential to combine or streamline reporting requirements in order to reduce costs and administrative burdens? : Regional and local ([ID4.34])
Do you have specific comments, concrete suggestions or specific evidence that could underpin your response?([ID4.35])
4.4 The Standardised Reporting Directive This Directive was agreed in 1991 to provide a single harmonised approach. Many specific reporting decisions in different policy areas (e.g. water, waste, etc) have been agreed. Over time, however, most reporting requirements have been included in specific pieces of legislation so that they can be better tailored to the needs of those specific pieces of legislation. The Commission is now considering the repeal of the Standardised Reporting Directive including all its specific reporting questionnaires most of them being obsolete already. However, the question in relation to the Fitness Check on monitoring and reporting is whether such a legally binding, horizontal approach should be developed again in the future. In this context, do you agree or disagree with each of the following statements? : The reporting obligations should be laid down specifically in individual pieces of legislation and coordination and streamlining should be ensured through collaboration ([ID4.41])
4.4 The Standardised Reporting Directive This Directive was agreed in 1991 to provide a single harmonised approach. Many specific reporting decisions in different policy areas (e.g. water, waste, etc) have been agreed. Over time, however, most reporting requirements have been included in specific pieces of legislation so that they can be better tailored to the needs of those specific pieces of legislation. The Commission is now considering the repeal of the Standardised Reporting Directive including all its specific reporting questionnaires most of them being obsolete already. However, the question in relation to the Fitness Check on monitoring and reporting is whether such a legally binding, horizontal approach should be developed again in the future. In this context, do you agree or disagree with each of the following statements? : Reporting requirements do not need to be laid down in legislation but should be agreed informally on a case-by-case basis between the EU Commission and the Member States ([ID4.42])
Do you have specific comments or concrete suggestions?([ID4.43])
4.5 The process for reporting As well as the content of what is reported, the process for reporting is important for ensuring that the right information is collected, processed and disseminated at lowest possible cost. IT technologies could be one of the answers. In this context, do you agree or disagree with each of the following statements? : IT technology is already adequately used and no further major improvements of the reporting process are needed ([ID4.51])
4.5 The process for reporting As well as the content of what is reported, the process for reporting is important for ensuring that the right information is collected, processed and disseminated at lowest possible cost. IT technologies could be one of the answers. In this context, do you agree or disagree with each of the following statements? : The INSPIRE directive can provide a common approach and process for reporting, reducing administrative burden and facilitating reuse of the reporting process and information across different levels of government ([ID4.52])
4.5 The process for reporting As well as the content of what is reported, the process for reporting is important for ensuring that the right information is collected, processed and disseminated at lowest possible cost. IT technologies could be one of the answers. In this context, do you agree or disagree with each of the following statements? : The business process and quality assurance procedures (outside the rules laid down by the INSPIRE Directive) in place for reporting are still causing significant administrative burden and need to be improved ([ID4.53])
4.5 The process for reporting As well as the content of what is reported, the process for reporting is important for ensuring that the right information is collected, processed and disseminated at lowest possible cost. IT technologies could be one of the answers. In this context, do you agree or disagree with each of the following statements? : More help is needed for the Member States in preparing reports including the development of common tools ([ID4.54])
We would welcome specific suggestions as to what we should look at during this Fitness Check of the environmental acquis in relation to monitoring and reporting. Please suggest any issues you wish.([ID5.1])
If you have prepared a dedicated position paper or want to share any other related material with the Commission, please use the upload function.([ID6.1])
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Not at all — please keep my contribution confidential (it will not be published, but will be used internally within the Commission). Note that in this case your contribution may still be subject to requests for ‘access to documents’ under Regulation 1049/2001[1]
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Noise
Soil
Waste
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Too much, less is needed
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Civil society organisation([ID2.1.3])
Italy([ID27])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
ITALIA NOSTRA ONLUS - SEZIONE VITERBO
viterbo@italianostra.org
Satisfied([ID3.11])
 
Air quality and pollution([ID3.21] )
Biodiversity and nature([ID3.22])
Chemicals([ID3.23])
Natural resources([ID3.24])
Noise([ID3.25])
Soil([ID3.26])
Waste([ID3.27])
Water([ID3.28])
Too little, more is needed([ID4.13AQ] )
PER QUANTO RIGUARDA L'ITALIA: 1) SI CONTINUA A PERMETTERE LA COSTRUZIONE E LA VENDITA DI MARMITTE NON ASSIMILABILI ALLE OMOLOGATE ECOLOGICHE CHE GENERANO RILEVANTE INQUINAMENTO ATMOSFERICO; 2) SI PERMETTE LA MODIFICA DI CICLOMOTORI (SCOOTER) E DI ALTRI VEICOLI MOTORIZZATI, ACQUISTATI CON ECO INCENTIVI STATALI, DI MARMITTE CHE GENERANO UN ALTO INQUINAMENTO ATMOSFERICO, DIFFICILMENTE RILEVABILE DALLE FORZE DI POLIZIA IN SERVIZIO SULLE STRADE E DALLE OFFICINE DI REVISIONE PRIVATE, AUTORIZZATE DALLA MOTORIZZAZIONE CIVILE E DALLE PROVINCE.
Reporting process is inefficient, significant improvements are needed([ID4.23AQ] )
DIVIETO ASSOLUTO DI COSTRUZIONE, DI VENDITA E DI INSTALLAZIONE DI MARMITTE NON ECOLOGICHE-OMOLOGATE.
 
About right([ID4.12BIO])
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22BIO])
 
 
About right([ID4.12CHE])
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22CHE])
 
 
About right([ID4.12NR])
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22NR])
 
 
Too little, more is needed([ID4.13NO])
 
Reporting process is inefficient, significant improvements are needed([ID4.23NO])
PER QUANTO RIGUARDA L'ITALIA: 1) SI CONTINUA A PERMETTERE LA COSTRUZIONE E LA VENDITA DI MARMITTE NON ASSIMILABILI ALLE OMOLOGATE ECOLOGICHE CHE GENERANO RILEVANTE INQUINAMENTO ACUSTICO; 2) SI PERMETTE LA MODIFICA DI CICLOMOTORI (SCOOTER) E DI ALTRI VEICOLI MOTORIZZATI, ACQUISTATI CON ECO INCENTIVI STATALI, DI MARMITTE CHE GENERANO UN ALTO INQUINAMENTO ACUSTICO, DIFFICILMENTE RILEVABILE DALLE FORZE DI POLIZIA IN SERVIZIO SULLE STRADE E DALLE OFFICINE DI REVISIONE PRIVATE, AUTORIZZATE DALLA MOTORIZZAZIONE CIVILE E DALLE PROVINCE.
 
Too little, more is needed([ID4.13SO])
DIVIETO ASSOLUTO DI COSTRUZIONE, DI VENDITA E DI INSTALLAZIONE DI MARMITTE NON ECOLOGICHE-OMOLOGATE.
Reporting process is inefficient, significant improvements are needed([ID4.23SO])
PER QUANTO RIGUARDA L'ITALIA, ABROGAZIONE/ANNULLAMENTO, ANCHE CON EFFETTO RETROATTIVO, DELLE NORME INCOSTITUZIONALI SUI CONDONI E SANATORIE EDILIZI E SUI PIANI CASA IMPATTANTI NEGATIVAMENTE SUL TERRENO, SULL'AMBIENTE E SUL PAESAGGIO, AI SENSI DELL'ART. 9 DELLA COSTITUZIONE ITALIANA, COME DA NUMEROSE SENTENZE DELLA CORTE COSTITUZIONALE ITALIANA,
 
Too little, more is needed([ID4.13WAS])
 
Reporting process is inefficient, significant improvements are needed([ID4.23WAS])
 
 
Too little, more is needed([ID4.13WAT])
PER QUANTO RIGUARDA L'ITALIA: 1) MAGGIORE TRASPARENZA CON OBBLIGO DI PUBBLICAZIONE TRAMITE APPOSITI CARTELLI IN LOCO E SUI SITI WEB ISTITUZIONALI, RIPORTANTI I DATI DELLE AUTORIZZAZIONI/NULLA OSTA RILASCIATI PER DERIVAZIONI SU CORSI D'ACQUA (PUBBLICI), SU REALIZZAZIONI EX NOVO E PER AMPLIAMENTI DI POZZI PER PRELIEVO DI ACQUE SOTTERRANEE, ETC.
Reporting process is inefficient, significant improvements are needed([ID4.23WAT])
 
 
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I totally agree
Totally disagree
 
Totally disagree
I totally agree
No opinion
I totally agree
 
 
As an individual / private person([ID2.1.1])
Germany([ID23])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
individual
 
Not very satisfied([ID3.13])
Not strict enouggh
Biodiversity and nature([ID3.22])
Waste([ID3.27])
 
 
 
 
 
Too little, more is needed([ID4.13BIO])
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22BIO])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Too little, more is needed([ID4.13WAS])
 
Reporting process is inefficient, significant improvements are needed([ID4.23WAS])
Not enough rules for standardized reporting
 
 
 
 
 
 
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No opinion
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Totally disagree
No opinion
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Tend to agree
 
 
Public authority([ID2.1.5])
Finland([ID21])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Samuli Korpinen
samuli.korpinen@ymparisto.fi
Satisfied([ID3.11])
 
Biodiversity and nature([ID3.22])
Water([ID3.28])
 
 
 
 
 
Too little, more is needed([ID4.13BIO])
There is no requirement in the Habitats Directive monitoring and assessment to coordinate with neighboring countries or within a region. This has caused specific problems with the Marine Strategy Framework Directive, where coordinated monitoring and assessment is the requirement.
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22BIO])
In case of the MS reporting to the Commission, the electronic reporting of the EU MSFD is an efficient practice. Especially the possibility to give web links to regionally coordinated actions under the regional sea conventions.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Too much, less is needed([ID4.11WAT])
There are huge differences in the amount of water bodies between MS. In Finland, the amount of rivers, lakes, or ponds is too much for a national monitoring programme and therefore a risk-based monitoring, assessment and reporting system should be enabled, where risk from polluting human activities would trigger monitoring and otherwise the state would be assessed on a selection of monitoring sites. Another comment is the common implementation strategy of the WFD which is too bureaucratic to allow dynamic changes in monitoring and development of assessment methods(e.g. after the intercalibration it will be difficult to develop and assess new indicators even though there is a separate process for that; but who would like to start the process?). Also in this latter case, more dynamic approach would be more efficient and would allow for example better integration with the development of the MSFD assessment.
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22WAT])
 
 
4
5
3
8
3
5
4
9
8
8
9
5
7
10
9
For many (marine) monitoring and reporting purposes the level of European regional sea conventions has big potential for streamlining. That was noted in the reporting of MSFD. In many cases the EU wide streamlining may be too wide to actually reduce costs and other burdens. There are different traditions in north and south which often become visible in these processes.
Tend to agree
Tend to agree
Depending on the piece of legislation (object of monitoring) there may be different burdens for MS. In such cases the legislation should only give a minimum frame and more concrete requirements could be agreed bilaterally or through a separate process. Such a case could be the monitoring of inland waters which is very different in Finland vs. some central European MS. However, the case-by-case basis could be non-transparent which shoul dbe avoided and therefore a risk-based approach might be a solution in many cases. Such an approach was being suggested in the implementation of the MSFD by a MS with large marine areas.
Totally disagree
Tend to agree
No opinion
Tend to disagree
 
 
International organisation([ID2.1.6])
Germany([ID23])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
IHK Hochrhein-Bodensee
michael.zierer@konstanz.ihk.de
Fairly satisfied([ID3.12])
Umfang und Detailierungsgrad für Daten sind zu aufwändig. Vor allem KMU können nicht immer alle Daten in entsprechender Genauigkeit und Zeitachse darstellen.
Air quality and pollution([ID3.21] )
Biodiversity and nature([ID3.22])
Chemicals([ID3.23])
Natural resources([ID3.24])
Noise([ID3.25])
Soil([ID3.26])
Waste([ID3.27])
Water([ID3.28])
Too much, less is needed([ID4.11AQ] )
 
Reporting process is inefficient, significant improvements are needed([ID4.23AQ] )
 
 
Too much, less is needed([ID4.11BIO])
 
Reporting process is inefficient, significant improvements are needed([ID4.23BIO])
 
 
Too much, less is needed([ID4.11CHE])
 
Reporting process is inefficient, significant improvements are needed([ID4.23CHE])
 
 
Too much, less is needed([ID4.11NR])
 
Reporting process is inefficient, significant improvements are needed([ID4.23NR])
 
 
Too much, less is needed([ID4.11NO])
 
Reporting process is inefficient, significant improvements are needed([ID4.23NO])
 
 
Too much, less is needed([ID4.11SO])
 
Reporting process is inefficient, significant improvements are needed([ID4.23SO])
 
 
Too much, less is needed([ID4.11WAS])
 
Reporting process is inefficient, significant improvements are needed([ID4.23WAS])
 
 
Too much, less is needed([ID4.11WAT])
 
Reporting process is inefficient, significant improvements are needed([ID4.23WAT])
 
 
5
5
7
5
10
3
3
10
10
2
3
10
10
7
5
 
No opinion
I totally agree
 
I totally agree
Tend to agree
I totally agree
I totally agree
 
 
Civil society organisation([ID2.1.3])
Ireland([ID26])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
donna mullen bat conservation ireland
donnamullen@wildlifesurveys>net
Satisfied([ID3.11])
 
Air quality and pollution([ID3.21] )
Biodiversity and nature([ID3.22])
Natural resources([ID3.24])
Water([ID3.28])
Too little, more is needed([ID4.13AQ] )
 
Reporting process is efficient (good practice example)([ID4.21AQ] )
 
air quality monitoring resulted in a smokey coal ban in Ireland< saving lives (reported in the lancet) and over %) million euro in healthcare>
Too little, more is needed([ID4.13BIO])
 
Reporting process is efficient (good practice example)([ID4.21BIO])
we now have aaction plans which will help in future developments< we know sensitive areas for wildlife
 
 
 
 
 
 
Too little, more is needed([ID4.13NR])
 
Reporting process is efficient (good practice example)([ID4.21NR])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Too little, more is needed([ID4.13WAT])
well water in Ireland is often polluted and locally people don't know about the dangers _ my own daughter spent time in temple st hospital having been poisoned from drinking well water> although the school is next door and the authorities (HSE) were notified< no actionwas taken
Reporting process is inefficient, significant improvements are needed([ID4.23WAT])
 
if monitoring was increased there wouyld be a decrease in environmental and health bills
10
10
5
10
10
10
5
7
1
9
10
10
 
10
10
there would be no wildlife (annex !V and II) monitoring in irrland if it was not for the habitats directive and case CONE EIGHT THREE_ ZERO FIVE)
Totally disagree
Totally disagree
 
Tend to disagree
No opinion
No opinion
I totally agree
 
 
As an individual / private person([ID2.1.1])
Lithuania([ID29])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Deivis Bluznevicius
deivis_bluz@yahoo.com
Fairly satisfied([ID3.12])
Our bodys feel exact noon of the place it is in. We live according to clock which shows the time of the time zone. We see this in computers, phones, cash registers, reports, working hours, TV program. We tend to sleep and wake up according to clock. This is a big stress to the body and then we tend to create more pollution in order to obscure stress. When filling the report there should be announced how much time has passed since midday of the building along with the time of the clock. There should be a map which shows how much time has passed after the astronomical noon of every building and the deviation of each building from the axis of the planet because we take the direction of the building we are in and our body feels the axis of the rotating planet.
Waste([ID3.27])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Too little, more is needed([ID4.13WAS])
Every waste stream has its source. Not every waste item is recyclable. It would be good to know before buying which waste is going to be recycled. This information should be printed beside name of the product and price at the store. Some of the packaging is dirty. It should be separated and washed. There has been developed an automated line for washing such packaging. It would be good that such lines are implemented at every municipal waste stream managing facility.
No opinion([ID4.24WAS])
 
 
 
 
 
 
 
10
10
8
10
10
10
10
8
9
10
10
8
10
10
10
Waste is collected, sorted out and recycled after production/ditribution and consumption. Recycling technologies give one name to one type of waste. Manufacturers should give the one standard name/ID in the EU used by the recycling technology to each part of their product and packaging. Then each link from resources, manufacturing, distribution, consumption, recycling and energy recovery could automate reporting process.
I totally agree
Tend to agree
 
Tend to disagree
No opinion
No opinion
I totally agree
There should be estimation how much time is needed for the each product/packaging in the EU to desintegrate, how much pollution this would create and alternatively how much resources are saved if the product/package has been recycled completely.
 
Public authority([ID2.1.5])
Belgium([ID13])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Public Service of Wallonia - DG Environment - Water Department - Groundwater Unit
DESO.DEE.DGARNE@spw.wallonie.be
Fairly satisfied([ID3.12])
 
Water([ID3.28])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Too much, less is needed([ID4.11WAT])
 
 
 
 
9
8
7
5
8
3
7
10
9
6
8
5
8
5
5
Evidence that reporting requirements are coming from the EU level
Tend to disagree
Tend to agree
Experinence of the DWD - precise templates of reporting are defined by the Expert group chaired by Commission
Tend to agree
No opinion
Tend to disagree
Tend to disagree
 
 
As an individual / private person([ID2.1.1])
Italy([ID27])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
laura petriglia
laura.petriglia@gmail.com
Not at all satisfied([ID3.14])
generally they are very time consuming and sometimes non to easy to apply
Noise([ID3.25])
Water([ID3.28])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Too much, less is needed([ID4.11NO])
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22NO])
instead of reporting in excel sheet it would be better if each competent authority could publish its own data as web service
 
 
 
 
 
 
 
 
 
 
 
No opinion([ID4.14WAT])
 
No opinion([ID4.24WAT])
directives on water are many: there is the need to uniform all the directives regarding the reporting systems
 
4
7
5
9
5
5
5
10
7
10
10
3
8
8
8
 
Tend to agree
Tend to disagree
 
Totally disagree
I totally agree
Tend to agree
Tend to agree
 
 
Public authority([ID2.1.5])
Germany([ID23])
 
Anonymously: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.2)
Environmental Protection Agency Saxony-Anhalt, Germany
 
Satisfied([ID3.11])
 
Air quality and pollution([ID3.21] )
About right([ID4.12AQ] )
 
Reporting process is efficient (good practice example)([ID4.21AQ] )
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
10
10
10
10
10
10
9
10
9
10
10
10
10
9
8
 
No opinion
No opinion
 
I totally agree
No opinion
No opinion
Tend to agree
 
 
Other([ID2.1.8])
Belgium([ID13])
Industry Association
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
European Crop Protection Association (ECPA)
gavin.whitmore@ecpa.eu
Fairly satisfied([ID3.12])
 
Biodiversity and nature([ID3.22])
Chemicals([ID3.23])
Water([ID3.28])
 
 
 
 
 
Too little, more is needed([ID4.13BIO])
Policy responses should be evidence based - an improved understanding of the state of nature and biodiversity in Europe should improve policy decision making.
No opinion([ID4.24BIO])
 
 
About right([ID4.12CHE])
 
No opinion([ID4.24CHE])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
No opinion([ID4.14WAT])
Effectiveness relates to the quality of data and not the quantity of data. Often data is not comparable between Members States and even between regions.
No opinion([ID4.24WAT])
 
 
10
10
10
10
1
3
8
10
8
8
5
1
10
5
1
 
I totally agree
Tend to disagree
 
Tend to disagree
Tend to agree
No opinion
Tend to agree
For appropriate water quality monitoring specific meta-data is required related to: Analytical sensitivity and precision, and whether the data has been generated as a result of general water quality assessment programmes or investigative monitoring to follow-up on known pollution incidents - without such information the data has greatly reduced value.
 
Public authority([ID2.1.5])
Belgium([ID13])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Flemish Environment Agency (VMM)
r.vannevel@vmm.be
Satisfied([ID3.11])
 
Chemicals([ID3.23])
Water([ID3.28])
 
 
 
 
 
 
 
 
 
 
Too little, more is needed([ID4.13CHE])
Concerning chemicals in water, the growing number of EQS-based substances leads to ever increasing M&R obligations. Reporting on a restricted number of key substances or preferably based on an effect-based monitoring should be made possible.
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22CHE])
For aquatic substances, the number of parameters monitored is high, but at a low frequency. Intensive monitoring is needed to provide reliable results, but requires substantial additional financial means. Reduction of the number of parameters and monitoring at a higher frequency could improve efficiency.
Monitoring costs can be provided.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
About right([ID4.12WAT])
Regulations cover most aspects of the water domain. Not fully covered: aquatic biodiversity, aquatic ecosystem services. In general, the provided information effectively contributes to meet the objectives of the environmental acquis. Effectiveness should compare the generated data/information (D/I) with the D/I needs that are only partially legally required. Policy and management define what kind of and how much D/I is needed. D/I needs are clearly described in the reporting guidance (WFD), the data dictionaries (WISE SoE) and the manual on water accounts (Eurostat). Effectiveness of data provision relates to the degree of legal binding: highest for WFD and lowest for Eurostat. Monitoring is designed according to EU legislation, most of the non-compulsory reporting depends on data available in the data bases. Additional monitoring practices, such as remote sensing, passive sampling, effect-based monitoring and e-DNA, should be explored and standardized.
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22WAT])
Neither efficient nor inefficient: Efficiency is about optimal use of financial and human resources. The reporting process of the water sector is considered to be in the middle of a transition process for already a few years, which requires more resources. This WFD included the repeal or streamlining of a few directives. On the other hand, the amount of new data elements increased and the harmonization process is long and difficult. Monitoring, modelling and specific IT tools contribute to more adapted reporting (in terms of timeliness, data validation, etc.) but increased complexity will not require less resources in the future to maintain the same level of efficiency.
Yes. Up to a certain level and according to a defined set of accounts, data can be provided of monitoring costs (analysis, personnel) and reporting, including the IT costs of data management.
10
10
5
5
10
5
3
10
9
10
8
6
10
8
4
Intern’l: Except of the WFD, the total burden of M&R to the international level is not that high at the national level in an absolute sense. Harmonization seems very efficient, and in particular favoring the intern’l authorities, obtaining structured data at once. This puts an additional burden on the MSs. The Eurostat/OECD JQs are a good example of data transfer ; EC and EEA could play a similar role towards marine conventions (OSPAR), UN (GEMS/Water) etc. EC: With WISE, this process is ongoing. MS: As a federal state, Belgium has a co-ordination committee to discuss thematic issues, one working group specifically dealing with env. reporting. Environment is a regional responsibility and co-ordination is limited to a general level. Regional and local: The number of water-related authorities involved in M&R in each Belgian region is rather low as they have the full regional responsibility (except of the federal marine matter and national environmental statistics).
Tend to disagree
Totally disagree
A third option is proposed: general requirements in a horizontal directive, specific requirements as part of the directive concerned and practical arrangements being informally agreed. The horizontal part could include items of responsibilities, e-governance (open access), e-reporting (data submission via WISE), codification systems, the role of questionnaires, transboundary monitoring, flow charts and balances, data exchange between international authorities, data confidentiality, … Specific requirements deal with monitoring requirements, reporting frequency, timing etc. Informal arrangements include templates, data element attributes, guidances (including practices and methods), …
Tend to agree
Tend to disagree
Tend to disagree
Tend to agree
1. Country comparison: Applying indicators inevitably results in country ranking. Monitoring strategies differ largely between countries, so only monitoring methods can be standardised. Measuring efforts (improved SoE by measures) is more important than SoE M&R. Core indicators should not be based on efficiency of M&R, but on effectiveness of measures (e.g. costs vs distance to target reduction). 2. Implementation reporting requirements: calls for reporting must be launched timely, supported by guidances, and with minimal last minute changes (at least avoiding those that affect IT programming). 3. Chemical parameters: Importance of terminological coherence across environmental themes and harmonisation of parameter lists according to the EU legislation (e.g. REACH). 4. General consideration: there is a common need to harmonise objectives between EU obligations, in particular on chemicals (air- water – soil vs emissions – SoE).
 
Public authority([ID2.1.5])
Germany([ID23])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Umweltbundesamt, Dep. Water&Soil
joerg.rechenberg@uba.de
Fairly satisfied([ID3.12])
 
Water([ID3.28])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
About right([ID4.12WAT])
This statement is depending on the directives concerned: - for Urban Waste Water and Nitrates directive the amount of information is considered appropriate - for the WFD the amount of information is too burdensome due to the low level of aggregation (waterbody level) , although much progess has been made in drafting the Guidance document - for the MSFD the amount of reporting in the first round of Art. 8,9 and 10 was way too detailed, but we feel that the situation is improving over time.
No opinion([ID4.24WAT])
efficiency and cost effectiveness of reporting depends on the subsequent use of the information provided.
no
10
7
3
7
8
1
1
5
8
10
6
1
8
5
8
The role of the COM in this context is to provide in the very beginning a clear picture of the evauluations which should be performed with the information collected and submitted. This is a prerequisite to define the information necessary and subsequently to develop effective technical means for data collection and compilation on the local, regional and national level.
I totally agree
No opinion
As reporting should serve the objective of specific pieces of legislation, the general purposes of reporting should be stated individually in each of the legislations. The detailed requirements should be agreed in an informal procedure. The evolution of WFD reporting is a good example of this approach. A horizontal legislation on reoportin is not considered helpful. The implementation diffuculties of the INSPIRE Directive clearly support this view.
Tend to disagree
Tend to disagree
I totally agree
No opinion
Means to share information on different processes, on the technolgies and on the evaluation experiences should be encouraged. As a general comment we would like to state that this questionnaire suffers from not differentiating between monitoring and reporting. These are clearly distinct areas. Monitoring is mainly based on local needs (based on the existing legislation, whereas reporting is the process of compiling and aggregation the information available to a level, which allows for the evaluation according to the objectives of the different levels involved in the implementation process.
 
Public authority([ID2.1.5])
Germany([ID23])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Ministry of Environment, Agriculture, Food, Viniculture and Forestry, Rheinland-Pfalz/Germany
Armin.mueller@mulewf.rlp.de
Not very satisfied([ID3.13])
There is a lack of coordination between the different EU Groups/Communities (Environment/INSPIRE). Lack of harmonisation and reduction of redundancies in data acquisition and reporting.
Water([ID3.28])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Too much, less is needed([ID4.11WAT])
Effective environmental reporting relies on continuous Innovation. Despite talking about streamlining the reporting for more than 5 years in the Eu-Working Groups, especially the amount of data reported under the WFD-Directive has continuosly risen. Major parts of the provided data have never been analysed.
Reporting process is inefficient, significant improvements are needed([ID4.23WAT])
Douple workflow/duplicated data - EU-Reporting Sheets/Web Services. Textual Information or target questions shoulb be collected via central form applications in WISE, otherwise 28 MS have to set up the same infrastructure to gather the same Information. Spatial data should be provide via INSPIRE mechanism, instead we have to provide shape-files with individual data models and selected INSPIRE Content. For example this circumstance generates douple work in the MS.
 
8
8
8
7
7
7
8
10
9
10
8
9
9
9
9
 
Tend to disagree
Tend to agree
 
Totally disagree
Tend to agree
I totally agree
Tend to agree
Review Content/Data models - which products are needed (COM/MS). Prioritization INSPIRE-themes (WFD-Reporting Guidance 2016, Chapter 12). Evaluate common reference datasets across directives (+ INSPIRE). Agreed Terminologies and Definitons across directives (+ INSPIRE). Networking of Information, distributed Services for FD, WFD eg. Open Data Strategy for up to date datasets.
Public authority([ID2.1.5])
Denmark([ID19])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Danish Environmental Proction Agency
andwi@mst.dk
Fairly satisfied([ID3.12])
 
Air quality and pollution([ID3.21] )
Chemicals([ID3.23])
Noise([ID3.25])
Soil([ID3.26])
Waste([ID3.27])
About right([ID4.12AQ] )
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22AQ] )
 
 
 
 
 
 
 
About right([ID4.12CHE])
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22CHE])
 
 
 
 
 
 
 
About right([ID4.12NO])
 
Reporting process is inefficient, significant improvements are needed([ID4.23NO])
Reporting of same data to EEA as to INSPIRE. EEA requirements should use the INSPIRE data in the future
 
No opinion([ID4.14SO])
 
No opinion([ID4.24SO])
 
 
About right([ID4.12WAS])
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22WAS])
 
 
 
 
 
 
 
7
7
7
9
9
8
5
10
9
8
6
7
9
9
8
 
I totally agree
Totally disagree
 
Tend to disagree
I totally agree
I totally agree
Tend to agree
 
 
Public authority([ID2.1.5])
Denmark([ID19])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Miljøstyrelsen
eikri@mst.dk
 
 
Waste([ID3.27])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
About right([ID4.12WAS])
 
No opinion([ID4.24WAS])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The EWC should be expanded, such that relevant categories from other directives / regulation can be measured. For example the coming six WEEE fractions and the fractions in the Battery-directive. Furthermore future implementation of the Hong Kong declaration should also be implemented in the EWC. In Denmark all reporting of Waste is done with the use of EWC codes, both internally and with regard to import and export.
 
Public authority([ID2.1.5])
Finland([ID21])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
SYKE/Data and Information Centre
kristiina.soini@ymparisto.fi
Not very satisfied([ID3.13])
The overall reporting ( EU and international conventions) is not properly coordinated. There are overlapping reportings. Some reporting tools are not user-friendly. In some cases the reporting guidelines are available very late and may include mistakes and typos which make timetables very challenging. In addition to these the reporting guidelines change between the reporting periods, which makes automatized routines useless. Adding new themes or details in the guidelines late makes collection of additional necessary data difficult or impossible,. Common standardized vocabularies/data dictionaries are of utmost importance and should be used in ALL reporting oblications ( for instance CAS codes of chemicals etc.)
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
9
4
9
4
7
1
5
10
10
9
7
10
10
5
3
 
Tend to agree
Tend to agree
 
Tend to disagree
Tend to agree
I totally agree
I totally agree
The reporting of protected areas via EEA (CDDA Common Database on Designated Areas) to **several** international stakeholders is working relatively smoothly. The data dictionary is there, the ACCESS tool provided is not too complicated and the (fortunately rare) changes in reporting are informed early enough to the member states. From a member state point of view similar features would be most welcome in other themes too.
 
Public authority([ID2.1.5])
Germany([ID23])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Thüringer Ministerium für Umwelt, Energie und Naturschutz
poststelle@tmuen.thueringen.de
Fairly satisfied([ID3.12])
 
Air quality and pollution([ID3.21] )
Biodiversity and nature([ID3.22])
Chemicals([ID3.23])
Noise([ID3.25])
Waste([ID3.27])
Water([ID3.28])
About right([ID4.12AQ] )
 
Reporting process is efficient (good practice example)([ID4.21AQ] )
 
 
About right([ID4.12BIO])
 
Reporting process is efficient (good practice example)([ID4.21BIO])
 
 
About right([ID4.12CHE])
 
Reporting process is efficient (good practice example)([ID4.21CHE])
 
 
 
 
 
 
 
About right([ID4.12NO])
 
Reporting process is efficient (good practice example)([ID4.21NO])
 
 
 
 
 
 
 
About right([ID4.12WAS])
 
Reporting process is efficient (good practice example)([ID4.21WAS])
 
 
Too much, less is needed([ID4.11WAT])
Insbesondere die Berichtspflichten zur EU-WRRL für WISE gehen mittlerweile deutlich über die Anforderungen der EU-WRRL hinaus und erzeugen einen erheblichen Verwaltungsaufwand, der zu Lasten der Umsetzung der WRRL geht.
Reporting process is inefficient, significant improvements are needed([ID4.23WAT])
Insbesondere die Berichtspflichten zur EU-WRRL für WISE gehen mittlerweile deutlich über die Anforderungen der EU-WRRL hinaus und erzeugen einen erheblichen Verwaltungsaufwand, der zu Lasten der Umsetzung der WRRL geht.
 
9
9
7
9
9
8
6
9
9
10
9
3
9
7
3
Nationale bzw. regionale Berichtserfordernisse basieren fast ausschließlich auf EU-Anforderungen und können daher in der Regel nur auf EU-Ebene reguliert/angepasst werden.
I totally agree
Tend to disagree
 
Tend to agree
Tend to agree
Tend to agree
Tend to agree
 
Public authority([ID2.1.5])
Germany([ID23])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
LUBW - Landesanstalt für Umwelt, Messungen und Naturschutz Baden-Wuerttemberg
Christian.Haile@lubw.bwl.de
Not very satisfied([ID3.13])
There is a lack of coordination between the different EU Groups/Communi ties (Environment/INSPIRE). Lack of harmonisation and reduction of redu ndancies in data acquisition and reporting.
Water([ID3.28])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Too much, less is needed([ID4.11WAT])
Despite talking about streamlining the reporting for more than 5 years in the EU-Working Groups, especially the amount of data reported under the WFD-Directive has continuosly risen. The dataset which have to be reported is seen as too detailed for a EU water policy. Major parts of the provided data have never been analysed.
Reporting process is inefficient, significant improvements are needed([ID4.23WAT])
Douple workflow/duplicated data - EU-Reporting Sheets/Web Services. Tex tual Information or target questions should be collected via central fo rm applications in WISE, otherwise 28 MS have to set up the same infras tructure to gather the same Information. Spatial data should be provide via INSPIRE mechanism, instead we have to provide shape-files with indi vidual data models and selected INSPIRE Content. For example this circu mstance generates douple work in the MS.
 
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Tend to disagree
Tend to agree
 
Totally disagree
Tend to agree
I totally agree
Tend to agree
Review Content/Data models - which products are really needed (COM/MS). Priorization INSPIRE-themes (WFD-Reporting Guidance 2016, Chapter 1 2). Evaluate common reference datasets across directives (+ INSPIRE). Agreed Terminologies and Definitions across directives (+ INSPIRE). Networking of Information, distributed Services for FD, WFD eg. Open Data Strategy for up to date datasets.
 
As an individual / private person([ID2.1.1])
Belgium([ID13])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Philippe Cornille
cornille@telenet.be
Not very satisfied([ID3.13])
Reporting, as imposed of EU regulation, and with a EU use, should not be organized by Member States. This extra step introduces differences in interpretation and introduces an extra manipulation step that is prone to error.
Air quality and pollution([ID3.21] )
Waste([ID3.27])
Water([ID3.28])
About right([ID4.12AQ] )
aim for direct reporting (from data generator or owner, towards EU database)
Reporting process is inefficient, significant improvements are needed([ID4.23AQ] )
the PRTR for instance comprises errors and differences in interpretation because of the extra step via Member States ; definitions and thresholds that vary from Member State to Member State, and the data manipulation to report from M.S. to the Commission, can only introduce additional errors.
the manpower required in each Member State
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
About right([ID4.12WAS])
 
Reporting process is inefficient, significant improvements are needed([ID4.23WAS])
idem as other comments
see other comments
About right([ID4.12WAT])
idem
Reporting process is inefficient, significant improvements are needed([ID4.23WAT])
idem
idem
10
9
9
7
9
6
9
10
10
9
9
5
10
5
5
 
Tend to agree
Totally disagree
EU harmonized reporting is to be directed by the Commission, with no flexibility for Member States, and no involvement if direct reporting from companies to Commission is possible.
Tend to disagree
Tend to agree
I totally agree
No opinion
 
 
Public authority([ID2.1.5])
Germany([ID23])
 
Anonymously: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.2)
Environmental Protection Agency Saxony-Anhalt, Germany
 
Satisfied([ID3.11])
 
Noise([ID3.25])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
About right([ID4.12NO])
 
Reporting process is efficient (good practice example)([ID4.21NO])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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9
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9
9
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9
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No opinion
No opinion
 
I totally agree
No opinion
No opinion
No opinion
 
 
Professional organisation([ID2.1.7])
Romania([ID35])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Prezent&Perfect SRL
Eugen.cincu@yahoo.com
Not at all satisfied([ID3.14])
Raspunsurile primite de la CE au fost de neimplicare si dezinteres, pentru problemele din Romania si din Europa
Air quality and pollution([ID3.21] )
Biodiversity and nature([ID3.22])
Chemicals([ID3.23])
Natural resources([ID3.24])
Waste([ID3.27])
Too little, more is needed([ID4.13AQ] )
Din Romania nu se colecteaza decat valorile care convin Ministerului Mediului
Reporting process is inefficient, significant improvements are needed([ID4.23AQ] )
Un control UE ar scoate la iveala problemele grave de mediu din Romania
Ministerul Mediului nu doreste depunerea la gropile de gunoi a mai putin gunoi, si de 10 ani se lupta sa mentina cota de 2-3% depunere la groapa. Aceasta deoarece, esaloanele 3 si 4 ale acestui minister, sut formate din Dir. Gen. si Dir. care fac parte din MAFIA GUNOIULUI!
Too little, more is needed([ID4.13BIO])
Arborii sunt taiati intr-un ritm de 1He/zi, si orice controale sunt inutile atata timp cat mafia lemnului este formata din firme fantoma, paznicii ocolulilor silvice, garda de mediu si angajati din minister. Animalele sunt decimate pentru sume infime de catre straini care isi bat joc de aceasta bogatie si frumusete, pe bani puti si pe spagi!
Reporting process is inefficient, significant improvements are needed([ID4.23BIO])
Suparfata de paduri disparuta in mod ilegal acopera 2000 de stadioane de fotbal
Un singur vanator italian putea sa impuste zilnic 200 de privighetori, din care folosea doar limbile, nu este aceasta o cruzime fara margini si o adevarata nebunie? Cine era mai nebun, vanatorul sau cel ce-i dadea aprobare.
No opinion([ID4.14CHE])
 
No opinion([ID4.24CHE])
 
 
No opinion([ID4.14NR])
 
No opinion([ID4.24NR])
 
 
 
 
 
 
 
 
 
 
 
 
No opinion([ID4.14WAS])
 
Reporting process is inefficient, significant improvements are needed([ID4.23WAS])
Se minte ca nu putem sa reducem cantitatea de gunoi depusa la groapa, dar se uita cu interes(interesul este al groparilor de gunoi si al celor din ministerul mediului care vor sa aduca incineratoarele, si au inceput sa dea aprobari de functionare) ca in Romania Firma Eco Solution SA are o instalatie de tratare a gunoaielor menajere 100% NO WASTE.
 
 
 
 
 
 
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Romania este pe penultimul loc in EU datorita MAFIEI DIN MINISTERUL MEDIULUI
I totally agree
I totally agree
 
Totally disagree
I totally agree
I totally agree
I totally agree
The solution comes from Europe, my splines Romania, where there are 5-year factory household waste management, industrial, agricultural and urban. It is a new concept, which relies on gasification of waste, this leading to obtaining recyclable waste, about 10%, electricity 1MW / t + Thermal 1MW / t 85%, and 5% clay neutral, used in paving streets or roads. The plant is called Eco Solution SA, and the owner, who is author of the patent filed with OSIM, called COSTIN Francu aviation engineer. We would like to make known the investment of 20,000,000.00 Euros, by a visit to Sacele, Brasov. So you will be able to see this in operation, sending a shooting along with a PDF schema of operation, hoping to interest a project that is 100% NO WASTE, installation has chimney, do not spill anything environment, water, air, soil or subsoil.
Public authority([ID2.1.5])
Finland([ID21])
 
Anonymously: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.2)
Ministry of Agriculture and Forestry
 
Not very satisfied([ID3.13])
Reporting requirements vary from very general ones to very (too) detailed ones without a clear picture why data is collected, how it is used and what are the uncertainties of it.
Water([ID3.28])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
No opinion([ID4.14WAT])
Instead of amount of information collected, the focus should be on why and how it is collected and how used.
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22WAT])
Level of detail of information collected is too high, causing administrative burden and interpretation errors because of complexity and uncertainties that exist in environmental monitoring
Taking into account for current economical situation and technological developments, we must rethink the whole monitoring in a new way (concentrate, optimise, automize, "remotise" and out/crowdsource)
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EC reporting requirements are continuesly increasing, developed separetly, both topically and time-wise, and without a proper coordination and focus it will be a big and laboroius mess
 
 
Basic principles, such us efficiency, asking just once, harmonisation/standardisation and openness, could be laid down in a general regulation, but also individual pieces are needed. These individual pieces should however be left to a minimum and preferably integrated into a sectoral pieces of legislation
Totally disagree
Tend to agree
Tend to agree
Tend to disagree
Think twice, ask just once and utilise multiple times. EC should start working into direction where monitoring and reporting would be as automatic as possible and data is [automatically] collected directly from the process where it is born. Member states and private sector should only have the responsibility of taking care of that data is available and reliable.
 
Public authority([ID2.1.5])
Denmark([ID19])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Danish Environmental Protection Agency, Commerce, Industry and Agriculture
krrst@mst.dk; tanak@mst.dk
Satisfied([ID3.11])
 
Air quality and pollution([ID3.21] )
No opinion([ID4.14AQ] )
Too much data is collected that is not needed (or is in a format and scope without contextual information which renders the data not very useful in the end, like the PRTR). The data that is actually useful, is not collected (ex in terms of BAT, applied ELV, actual performance/emissions in units proposed in BAT conclusions). The response is in relation to IED and E-PRTR reporting.
Reporting process is inefficient, significant improvements are needed([ID4.23AQ] )
Standardisation is required. Reporting formats and reporting channels (systems) should be the same.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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At least within the EU it should be possible to align and streamline the reporting requirements (formats). It is suggested that the reporting requirements is part of the directive/regulation and not put in the Working Groups to be decided at a later stage.
I totally agree
Totally disagree
Data is to be acquired from industry. Any obligation or burden posed upon industry should stem from obligation laid down in regulation. Voluntary reporting will not be effective.
Tend to disagree
I totally agree
Tend to agree
Tend to agree
Alignment of it-tools for reportering to the European Commission
 
Public authority([ID2.1.5])
Estonia([ID20])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Ministry of Environment of Estonia
keskkonnaministeerium@envir.ee
Fairly satisfied([ID3.12])
The requested monitoring data is sometimes too detailed and the resources spent to gather the data may be bigger than the value gained from the data. Very detailed data has a sometimes low value for decision making on EU level. In addition, duplication of reporting to EU and international conventions, duplication of data formats, disharmony of reporting cycles, low usage of modern IT possibilities and lack of sufficient clarity of methodologies can be a problem.
Air quality and pollution([ID3.21] )
Biodiversity and nature([ID3.22])
Chemicals([ID3.23])
Natural resources([ID3.24])
Noise([ID3.25])
Soil([ID3.26])
Waste([ID3.27])
Water([ID3.28])
About right([ID4.12AQ] )
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22AQ] )
 
The annual budget of air quality monitoring under Estonian National Environmental Monitoring Program is about 625 000 euros. Collecting monitoring data and reporting costs additionally about 200 000 euros annually.
About right([ID4.12BIO])
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22BIO])
 
The annual budget of biodiversity and nature monitoring under Estonian National Environmental Monitoring Program is about 500 000 euros.
About right([ID4.12CHE])
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22CHE])
 
Reporting is mainly done by officials. Chemicals are monitored via several monitoring programs. High cost of monitoring of chemicals is problematic (e. g. initial calculation for monitoring of priority substances in surface water is about 400 000 euros annually).
No opinion([ID4.14NR])
Mainly internal reporting.
No opinion([ID4.24NR])
Mainly internal reporting.
 
About right([ID4.12NO])
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22NO])
 
Reporting is mainly done by officials. Case-based monitoring with annual budget about 10 000 – 15 000 euros.
About right([ID4.12SO])
 
Reporting process is efficient (good practice example)([ID4.21SO])
 
The annual budget of soil monitoring at agricultural land under Estonian National Environmental Monitoring Program is about 20 000 euros. Additionally, soils at forested land are monitored under forest monitoring program and soils at agicultural land from farming sector and through the on-going evaluation of rural development programme by Estonian Agricultural Research Centre.
Too much, less is needed([ID4.11WAS])
Implementation reports every three years are not effective tool for verifying compliance and ensuring good implementation and are generating unnecessary administrative burden
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22WAS])
EDAMIS system is outdated and submission of the implementation reports should be web-based.
 
About right([ID4.12WAT])
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22WAT])
 
Reporting is mainly done by officials. The annual budget of water monitoring (groundwater, surface water, sea) under Estonian National Environmental Monitoring Program is about 1,5 million euros. Also, additional monitoring programs are carried out (e.g. bathing water surveillance and monitoring).
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Regional and local level is the executing level of governance. There is more potential to combine or streamline reporting requirements on member state and European Commission level. On International level, due to greater number of actors, finding the consensus can be more difficult.
Tend to agree
Tend to disagree
Standardised reporting is a promising approach but standardised monitoring can be problematic as environmental conditions differ. At the same time, standardisation of environmental monitoring is necessary for enabling comparability of environmental data for decision making on EU level.
Tend to disagree
Tend to disagree
Tend to agree
Tend to agree
Duplication: occurs in different sectors. Greenhouse gases – reporting data to EC and UNFCCC, various reports (PAM, Biennial Report, National Communication); water – reporting data to EC, EEA, Eurostat, etc.; air – reporting for NEC directive and for Convention on Long-range Transboundary Air Pollution, etc. Forms and Instructions: same data is submitted for different institutions on different forms. Guidance materials for reporting are published too late. Reporting cycles: not unified reporting cycles are burdensome (e.g. Nitrate directive reporting cycle does not unify with Water framework reporting cycle; PAM report on greenhouse gases does not unify with Biennial Report, etc.) Definitions and classifications: for waste sector dissimilarity of classification systems EWC-Stat (material-based) and LoW (activity-based) is a problem. Most of the problems have already been discussed at sectoral working groups – this information needs to be collected.
 
Public authority([ID2.1.5])
United Kingdom([ID40])
Scotland
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Scottish Natural Heritage
stewart.pritchard@snh.gov.uk
Fairly satisfied([ID3.12])
 
Biodiversity and nature([ID3.22])
 
 
 
 
 
Too much, less is needed([ID4.11BIO])
Comments in relation to reporting on Derogations under the Habitats and Birds Directive It is difficult to know whether more or less data is needed without understanding exactly how the data collected is used and exactly what information has the highest value. The reports that the UK submit contain lots of text compared with other Member States like those from Sweden or Germany. This begs the question of is the UK's information too detailed? We need to ensure that we provide information that has real value, and that if it does not, then it should not be required. One problem with this may be the variations between Member States as to how the Directives have been transposed into domestic legislation and subsequently providing clearer guidance on the specifics of what is required and what is not. The nuances of the different pieces of domestic legislation compared to the Directives can interfere with how we interpret reporting requirements so further guidance would be welcome.
Reporting process is inefficient, significant improvements are needed([ID4.23BIO])
Comment in relation to the process of reporting on derogations under the Habitats and Birds Directive For these reports there already exists a common reporting tool, 'Habides'. However it is extremely cumbersome to use and inflexible and as a result has a considerable cost in terms of staff time associated with its completion each year. New versions of Habides have developed over time but, despite the UK contributing the vast majority of data into this report, as far as we are aware we have never been approached as users to help inform developments and as a result we have a very user-unfriendly system. This has been discussed with all relevant agencies within the UK and is a significant problem for all of them every year.
Comments specific to Article 9 and 12 reporting (derogations) as above: Reporting on derogations probably costs Scottish Natural Heritage c. £3.5-4k per annum. Almost all of this cost is associated with the reformatting of data that we already have in order to make it fit with the common reporting tool.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Our experience on derogation reporting is that there are massive inconsistencies in reporting across Member States and it is unclear as to why those inconsistencies exist. However the most likely reason that we can find is a lack of common interpretation of the terms used in the respective Directives. These inconsistencies mean that we may be expending considerable resources reporting on issues that are not needed or alternatively that member states are under-reporting on requirements. In order to ensure that reporting requirements are appropriate (i.e. that they gather data that has real value) there needs to be a much better common understanding of requirements. In order to do this there may need to be much greater transparency as to what the data is used for.
Tend to agree
Tend to agree
I would suggest that any reporting requirements laid down in legislation should only cover the basic principles for which reporting is required (i.e. those pursuant to the overall aims of the particular Directive). They should avoid being overly prescriptive in order to ensure that actual reporting requirements can be adaptable to ensure that they meet purpose and priorities which may develop over time.
Totally disagree
No opinion
I totally agree
I totally agree
it can be useful to understand how other Member States have derogated but reporting data is hidden on the European Environment Agency website and isn't standardized making it difficult to access valuable information and share experience of derogations
 
Public authority([ID2.1.5])
Germany([ID23])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Lower Saxony Water Management, Coastal Defence and Nature Conservation Agency, Riverbasindistrict Management (H34)
dirk.weber@nlwkn-hi.niedersachsen.de
Not very satisfied([ID3.13])
There is more need for coordination between some EU Groups. There are lots of redundancies in data acquisition and reporting.
Water([ID3.28])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Too much, less is needed([ID4.11WAT])
In WFD-Directive have the amount of data reported continously risen. INSPIRE brings no help to manage the Reporting for WFD.
Reporting process is inefficient, significant improvements are needed([ID4.23WAT])
There are two ways and duplicated data for EU-Reporting. When we give our spatial data physicially to WISE, then EU should manage the INSPIRE-Services. Otherwise when member states have to provide INSPIRE-Services, why should they Report it once again to WISE? The lack of coordination leads to double work.
 
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Totally disagree
Tend to agree
 
Totally disagree
Tend to agree
I totally agree
Tend to agree
Agreed Terminologies across directives (INSPIRE, WFD, FD). INSPIRE-themes should get a Prioritization of reference datasets across directives. Using INSPIRE-mechanism for data managment for the other directives (CIS-WG should communicate and structure the needed Data and Reportings for implementation into the INSPIRE-Process)
 
Public authority([ID2.1.5])
Germany([ID23])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
INSPIRE-working group of the steering committee on geospatial data infrastructure
markus.meinert@bmub.bund.de
Not very satisfied([ID3.13])
"not verysatisfied" as marked aboved refers to the process of reporting of geospatial data, not to the content. Member states are obliged by directive 2007/2/EG (INSPIRE) to set up national geospatial data infrastructures, provide data services and harmonise data, metadata and service structures by using common standards. Finally this is supposed to aim in interoperability of data and services across geographical and administrative borders. This development leads to a resource of data available not only to national authorities and the public but to european authorities, too. Although there are successfull operating examples of implementing the directive above, which were offered to use for fullfilling european reporting obligations commission seems to hesitate to switch from delivered national data to exploring necessary data by using existing geoportals and services, which would be a relief for reporting authorities, a gain of timeliness and may mean multiple use of data
Biodiversity and nature([ID3.22])
Water([ID3.28])
 
 
 
 
 
About right([ID4.12BIO])
Biodiversity and nature: amount of reporting data were unanimously adopted by all Member States and thus represent a necessary minimum
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22BIO])
Biodiversity and nature: e.g. the Natura 2000 directives significantly improved the overall situation of nature protection and biodiversity in Europe, thus the information provided to promote the acceptance of the NATURA 2000 network was sufficient. However, workflows and data provision could and should be optimized. Here the INSPIRE directive enters the scene.
Biodiversity and nature: There has been extensive research into the costs of the preservation of biodiversity on European level resp. connected to EU directives. However, these costs cannot easily be separated from the costs each single MS has to cover, because of legislation addressing biodiversity on national level.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Too much, less is needed([ID4.11WAT])
Water: Effective environmental reporting relies on continuous innovation.. Despite talking about streamlining the reporting for more than five years in the EU-working groups, especially the amount of data reported under the WFD-directive has continuosly risen, Major parts of the provided data have never been analysed.
Reporting process is inefficient, significant improvements are needed([ID4.23WAT])
Water: Double workflow/duplicated data - EU reporting sheets/web services. Textual information onr target questions should be collected via central form applications in WISE, otherwiese 28 member states have to set up the same infrastructure to gather the same information. Spatial data should be provide via INSPIRE mechanism, instead we have to provide shape files with individual data models and selected INSPIRE content. For example this circumstance generates double work in the MS
Water:
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The federal structure of environmental governance in Germany reflects the federal structure of the EU. The advantages of data provision via a spatial data infrastructure (SDI) could and should be rolled out within Germany down to the regional and local level to support reduce of costs and administrative burdens, too.
Tend to disagree
Tend to disagree
The content of reporting might be laid down in different pieces of legislation referring to the the special issues to monitor and report on. But there are several aspects which should be laid down in a cross cutting legislation. These aspects should cover the quality of data and the process of reporting. Quality of data in this case e.g. means timeliness, continuity, consistency, comparabilty, datamodels, level of detail for european reporting. Lots of these quality aspects - as far as geospatial data are meant - should be handled by referring to directive 2007/2/EG. The process of reporting has to be converted. Member states - no matter what issue they have to report on - should provide the data by services and online-portals so anyone including the european authorities members states have to report to are able on their own to explore these data and get an impression how european goals are met. Core aspects mentioned before should become part of directive 91/692/EWG from 23.12.1991.
Totally disagree
Tend to agree
Tend to agree
Tend to agree
For many INSPIRE themes, relevant legislation & directives triggered data specification (e.g. Protected Sites (PS)<>Natura 2000). There are representations of reporting obligations (e.g. Natura 2000 Standard Data Form) within INSPIRE data specs (e.g. Natura 2000 extension for PS), but the regular reporting still neglects these possibilities (e.g. “species distribution maps” for art. 17 reporting of the Habitats Directive (HD), represented in INSPIRE theme Species Distribution). Reporting on different issues should be checked for multiple re-use and data service reduction: e.g. reporting on PS under the HD & the WFD. Both should be fulfilled by providing only one data service via INSPIRE-PS. COM should check reporting across directives incl. INSPIRE by -Review of content/data models (which products are needed) -Evaluating common reference data sets -Working on common terminology & definitions -Prioritizing INSPIRE-themes (WFD) -Networking of information & distributed services
 
Public authority([ID2.1.5])
Belgium([ID13])
 
Anonymously: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.2)
service public de wallonie
 
Fairly satisfied([ID3.12])
 
Water([ID3.28])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
About right([ID4.12WAT])
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22WAT])
 
very important costs for monitoring water (surface & ground), espcially chemicals analysys
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I totally agree
Totally disagree
 
Tend to agree
I totally agree
I totally agree
I totally agree
 
 
Public authority([ID2.1.5])
Belgium([ID13])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Brussels Environment (BE)
 
Not very satisfied([ID3.13])
Too complex, too much/detailed information asked, too frequent (related to topic WATER and mainly the implementation of the WFD).
Water([ID3.28])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Too much, less is needed([ID4.11WAT])
The effort of reporting seems disproportionaltly high given our small territory and small human ressources. Also, given our specific urban character, harmonisation/simplification efforts applied an EU wide data potentially gives wrong interpretations (differents scales and aggretations levels).
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22WAT])
WISE is a good tool to report to Europe but not as a local tool (too complex).
 
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Tend to disagree
Tend to disagree
Some information on monitoring of pollutants (for instance PAH in air, water, soil; pesticides;..) need clearly a horizontal approach concerning the reporting of information so as to allow for a more horizontal policy on proposing relevant (source) measures for diminishing emissions to the environment.
Tend to agree
Tend to agree
Tend to agree
Tend to agree
For a digital reporting obligation within the EU or member state, the organization requesting this information should produce specifications/tools conform with the INSPIRE one's : concerning the reported spatial datasets, the work to ensure conformity with INSPIRE should not be done afterwards by MS.
Public authority([ID2.1.5])
Denmark([ID19])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Danish Nature Agency
thell@nst.dk
Fairly satisfied([ID3.12])
 
Biodiversity and nature([ID3.22])
 
 
 
 
 
About right([ID4.12BIO])
However, any discussions to increase reporting burden will mean that the category choosen should be Too much, less is needed. The information is used by the EEA for analysis and any bit not used should be omitted.
Reporting process is efficient (good practice example)([ID4.21BIO])
trends of populations or area of nature in the EU reportings are useful to follow changes and evaluate implementation.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
7
10
4
9
7
7
6
9
10
10
7
5
5
5
 
 
Tend to disagree
Tend to agree
It is important that MS and COM are in a close dialouge on specific reporting matters.
No opinion
No opinion
No opinion
Tend to disagree
Important to create user friendly software reporting systems in order to keep focus on the content and not the tools themselves.
 
Public authority([ID2.1.5])
Germany([ID23])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Ministry of Energy, Agriculture, the Environment and Rural Areas of the Land Schleswig-Holstein; Department of Water Management, Ocean and Coastal Protection
joern.froehlich@melur.landsh.de
Fairly satisfied([ID3.12])
Requirements are very complex, comprehensive and in some cases too detailed. Therefore reporting is a very time consuming task. An additional burden in a decentral structure is communication or to schedule adjustments, especially in terms of changing requirements (from reporting to reporting or during preparation of reporting data). It is sometimes not clear for which purpose COM requests information or specific level of detail. One lesson learnt during implementation of different Directives and INSPIRE process is that not every kind of MS information or data are or will be comparable at EU-level due to different initial positions and different interpretations in MS. Therefore we propose to focus on information or data to be comparable on EU-level to answer concrete questions and to produce specific maps or graphs. Strong coordination between different EU Groups/Communities (Environment/INSPIRE) is needed for harmonization and to stop redundant data acquisition and reporting.
Water([ID3.28])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Too much, less is needed([ID4.11WAT])
Environmental reporting is effective when assessments of reporting information result in meaningful products on EU-level showing implementation progress or in answers to specific questions related with the objectives of each Directive. Reporting should not request as much data as possible. Especially WFD reporting covers a broad range of river basin management aspects requesting a huge amount of very detailed data. From our experience it’s a challenging task to generate harmonized and seamless datasets even for whole MS (due to different interpretation, misinterpretation, data gaps and different quality or quantity). We assume that also in future only a limited part of reported data will be suitable to generate meaningful products on EU-level. Therefore we support the idea that data provision should be established, maintained and managed by each MS in the most appropriate way via web services in the course of implementing INSPIRE standards.
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22WAT])
Streamlining the reporting is an important issue for more efficiency and hence stressed for more than 5 years in the CIS process. In the water sector EU Commission and MS are in a learning process with continuous innovation which triggers reviews of requirements and adaptions in terms of technical solutions. But implementation of changes in both – content and technical issues – need enough time in advance before it comes to reporting (both should be fixed at least two years in advance to allow consideration in draft plans and to leave enough time for staff and/or contractors to ensure sufficient implementation - even in terms of more or less technical issues like changes in element names and related coding). We strongly recommend to make use of INSPIRE provisions or mechanisms as soon as possible to avoid double working/duplication of spatial data provisions.
 
10
10
10
10
6
6
8
10
8
10
8
8
10
10
10
Majority of needed data to fulfil reporting obligations or requirements are stored and maintained in databases on regional and local level. Past reporting data streams were organized more or less as independent data streams with generally domain specific terminology, definitions and formats in terms of data requirements. In terms of “streamlining” these differences lead often to confusion and/or additional work to identify and compass synergies or something like “multi-purpose data”. Data sets on MS-, EU- or international level base generally on data provided from regional and local level with other words reporting data could be seen as more or less different aggregation levels. The difference between EU-level and International is probably not as significant as between MS- and EU-level or MS-level and regional and local level.
Tend to agree
I totally agree
Before phrasing reporting obligations or requirements under each Directive in a first step concrete products and quality standards for data needed should be defined to identify overlaps with contents or reporting requirements of other Directives. Data sharing should be ensured by cross domain adjustments to make data fit to serve/fulfil as far as possible also the needs of related Directives. Experiences showed that as long as reporting requirements are laid down Guidance documents only it won’t be possible to draw a seamless, harmonized and meaningful picture over all countries even for important assessments on EU-level. Therefore after informally agreements in CIS process it should be checked which reporting requirements should become part of binding implementation rules (with an obligation to fill data gaps and to maintain data) because INSPIRE obliges MS not to gather data or to fill data gaps. This is a combination of a horizontal and vertical appproach based on collaboration.
Tend to disagree
Tend to disagree
I totally agree
Tend to agree
It seems to be underestimated that streamlining + increasing semantically interoperability is extensive work + therefore it takes years to adjust precise definitions + requirements in terms of data contents/quality. One experience in INSPIRE TWG’s was that it's a task to agree upon generic or common definitions + codes. INSPIRE can help in terms of setting domain + cross domain standards for interoperable data provision through web services but provision of harmonized and seamless data can’t be limited to infrastructure or technical interoperability issues or common codes only. It will be not easy for reporting community to find precise definitions which are valid + operable cross different domains or at least to document relationships between different terminologies addressing the same/similar issue. Nevertheless for an efficient data sharing there is the need to make semantically interoperable - domain specific as well as cross domain between Environm. Directive at different scales.
Professional organisation([ID2.1.7])
United Kingdom([ID40])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Valpak Limited
Hannah.woodrose@valpak.co.uk
Fairly satisfied([ID3.12])
Valpak Limited is the UK’s largest producer responsibility compliance scheme operator with member schemes for Packaging, WEEE and Waste Batteries. Valpak do not report to the Commission directly but we do report on various subjects to the UK Government. It is the UK Government which then reports back to Europe. We are therefore responding to this consultation on this basis.
Waste([ID3.27])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
About right([ID4.12WAS])
In our experience whilst the overall intention and scope of reporting seems appropriate there are a number of situations where the requirements do not appear to have been fully assessed at a European level before being implemented. This can lead to unintended consequences which, if not addressed, can cause significant complications, for example the change in EEE / WEEE categories from the current 10 to the new 6. Whilst this was intended to simplify and align reporting with current collection practise in fact the opposite is likely to be the case. The category definitions selected are likely to have a large impact on both obligated businesses and treatment facilities which will need to re-evaluate their entire reporting practices as a result of an arbitrary 50cm dimension threshold.
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22WAS])
Another example is the proposal to include preparation for re-use along with recycling in the recently issued Circular Economy proposals on waste. Again, whilst the intention of this is understandable, the practical and operational impact in relation to for example re-useable transit packaging systems appear not to have been sufficiently evaluated. Further clarification on this will be necessary before these proposals are finalised. Similarly the calculations to be applied to calculate WEEE generation target and recycling efficiency targets are requiring a lot of further detailed exploration before they are in a state to be implemented.
 
 
 
 
 
 
10
10
10
10
10
5
5
10
10
10
10
 
 
 
 
We do not understand this question so have not commented
Tend to agree
Totally disagree
 
No opinion
No opinion
No opinion
No opinion
In respect of question 3.3 we believe it is extremely important to ensure that Member States are applying calculations or methodologies for reporting and monitoring consistently. This will help to ensure a level-playing field and that comparison can be made between Member States. For example with regards to the Packaging Directive national approaches and methodologies used for monitoring and reporting purposes can have considerable differences. These can include: 1. Definitions of what is and is not packaging 2. Whether reporting covers both commercial and household packaging in a consistent method 3. How the total packaging onto the market is calculated and whether it includes only registered tonnage or the total tonnage 4. Whether national performance is based on material collected, sorted or recycled
 
Academic/research institution([ID2.1.2])
Sweeden([ID39])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
IVL Swedish Environmental Research Institute
asa.stenmarck@ivl.se
Satisfied([ID3.11])
 
Waste([ID3.27])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
About right([ID4.12WAS])
For some flows (like food) more might be needed. It should also be looked in to how we could measure also reuse and prevention (if this should be done with a waste perspective, but ince it is linked in the waste hierarchy). It might also be worth thinking of if we could measure differently to ensure resource efficiancy - for example measuring just collected tonnes of WEEE don't really give the full picture.
Reporting process is efficient (good practice example)([ID4.21WAS])
 
 
 
 
 
 
 
10
10
10
9
9
5
7
9
10
10
10
4
8
10
10
 
I totally agree
Totally disagree
 
Tend to agree
No opinion
No opinion
Tend to disagree
 
 
Public authority([ID2.1.5])
Germany([ID23])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
German Environment Agency, Department Ambient Air, Ute Dauert
ute.dauert@uba.de
Fairly satisfied([ID3.12])
 
Air quality and pollution([ID3.21] )
About right([ID4.12AQ] )
The Air Quality reporting System was revised and streamlined in 2011.
Reporting process is efficient (good practice example)([ID4.21AQ] )
During the last 5 years, the Air Quality reporting System was revised (Decision 2011/850/EG) and streamlined in a new e-reporting system. The Member states were closely involves in this process. A group of pilot countries supported the transition to the new system.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
10
10
5
8
8
8
3
10
10
10
10
5
10
6
1
Member states should be involved in the processes
I totally agree
Totally disagree
whithout legislation on EU level monitoring and reporting wouldn't work
Tend to agree
Tend to agree
Tend to disagree
Tend to agree
We recommend that the reporting not only covers reports related to regulated limit or target values (conform to current legislation). For the revision purpose of current legislation and for the further development of limit or target values primary assessment data are needed and data for pollutants, which are yet unregulated (pollutants without limit or target values in current legislation).
 
Public authority([ID2.1.5])
Belgium([ID13])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Public Service of Wallonia (SPW-DGO3-DEMNA-DNE) - http://environnement.wallonie.be/cgi/dgrne/plateforme_dgrne/visiteur/v2/frameset.cfm?page=http://environnement.wallonie.be/administration/demna.htm
francois.darchambeau@spw.wallonie.be
Fairly satisfied([ID3.12])
 
Water([ID3.28])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Too much, less is needed([ID4.11WAT])
Aggregated data instead of unaggregated data Usefulness of detailed spatial data
Reporting process is inefficient, significant improvements are needed([ID4.23WAT])
At minimum 6 water-related european directives are presentely active in MS. Distinct specific reportings are requested with different timings (every 1, 2 or 3 years) while few or many common data/indicators must be reported. An important simplification and harmonization of the reporting process must be developed and should benefit from the synergies between the Directives.
For the Walloon region, 8.5 full-time equivalents are devoted to the biological monitoring and reporting of the biological data for the WFD. The full expenses, incl. salary, functioning and outsourcing, amounted 0.85 M€ yearly for the biological monitoring and reporting.
10
10
10
10
10
6
6
10
10
10
10
5
10
7
10
A sound harmonization of the water-related European directives must be developed in a cost-effective way.
No opinion
No opinion
 
Tend to disagree
No opinion
No opinion
I totally agree
Attention should be paid to the links between the answers and the category of the respondents because the answers are provided in specific contexts. Some questions were unclear and could be understood in different ways.
 
Public authority([ID2.1.5])
Belgium([ID13])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Public Service of Wallonia (SPW-DGO3-DEMNA-DNE) http://environnement.wallonie.be/cgi/dgrne/plateforme_dgrne/visiteur/v2/frameset.cfm?page=http://environnement.wallonie.be/administration/demna.htm
jeanmarc.couvreur@spw.wallonie.be
Fairly satisfied([ID3.12])
 
Biodiversity and nature([ID3.22])
 
 
 
 
 
About right([ID4.12BIO])
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22BIO])
As example of improvement better guidelines on specific topics could be made but this process is ongoing through adhoc european working groups
As the collection of data is anyway needed for the implementation of the Birds and Habitats Directives (mapping, legal acts, management in the field) and for other biodiversity purposes it is difficult to determine the amount of work specifically dedicated to the monitoring and reporting processes. Furthermore an integrated Life (2015-2021) is aimed at a better optimization of the efficiency of the reporting data collection.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
10
10
10
10
10
6
6
10
10
10
10
5
10
7
10
 
I totally agree
No opinion
Clarification should be provided to properly answer the second statement. Is it a case-by-case between each MS and the Commission or a more global EU agreement between the Commission AND the MS?
Tend to disagree
No opinion
No opinion
I totally agree
Attention should be paid to the links between the answers and the category of the respondents because the answers are provided in specific contexts. Some questions were unclear and could be understood in different ways.
 
Public authority([ID2.1.5])
Belgium([ID13])
Service Public de Wallonie - DGO3-DEMNA-DCoD - Cellule SIG
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Service Public de Wallonie - DGO3-DEMNA-DCoD - Cellule SIG
sig.dgarne@spw.wallonie.be
Not very satisfied([ID3.13])
At a local level, the costs/benefits of the Inspire compliant reporting seem to be less favourable.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Tend to disagree
Tend to disagree
Tend to agree
I totally agree
In the field of Inspire compliant reporting, it is necessary that the semantic harmonization fits also the local and regional levels. Towards efficiency and reuse of information of different sources and levels.
 
Public authority([ID2.1.5])
Belgium([ID13])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Coordination Committee for International Environmental Policy (CCIEP ) - Working Group on PRTR
m.vandenhende@vmm.be
Satisfied([ID3.11])
 
Air quality and pollution([ID3.21] )
Waste([ID3.27])
Water([ID3.28])
About right([ID4.12AQ] )
 
Reporting process is efficient (good practice example)([ID4.21AQ] )
In Flanders the data retrieval of emissions to air and water, groundwater, waste and energy data are clustered in an integral environmental annual report (IMJV, Integraal Milieujaarverslag,http://milieujaarverslag.milieuinfo.be/), so allowing the facilities to report only once to the competent authority.
No information available
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
About right([ID4.12WAS])
Flanders : A survey that compares the amount of information asked from the companies and the amount of information reported by the authorities could possibly reveal opportunities to future improvement of the effectiveness. Asking less information from companies can bring down the administrative burden on them. Focus must be kept on national or regional reporting obligations as well. Sometimes, these local obligations demand a more detailed level of information. A degree of ineffectiveness (communication) was identified while determining the reporting requirements for IED (more specific in relation to the IPPC Directive and WID). This was an internal matter.
Reporting process is efficient (good practice example)([ID4.21WAS])
Flanders : Reporting tools were developed to make the reporting process as efficient as possible. Future reporting requirements should be compatible with existing reporting procedures
Flanders : It may be possible to produce an estimate about the time spent – directly and indirectly – and the related cost to the monitoring and reporting. Such an estimate was set up in the past in order to predict and manage the cost of digitalizing and integrate the different reporting processes (on paper) that were in place at that time.
About right([ID4.12WAT])
 
Reporting process is efficient (good practice example)([ID4.21WAT])
In Flanders the data retrieval of emissions to air and water, groundwater, waste and energy data are clustered in an integral environmental annual report (IMJV, Integraal Milieujaarverslag, http://milieujaarverslag.milieuinfo.be/), so allowing the facilities to report only once to the competent authority.
No information available.
10
10
10
10
10
4
2
10
9
10
10
 
10
7
7
 
I totally agree
Totally disagree
 
Tend to agree
Tend to agree
Tend to disagree
Tend to agree
 
 
Public authority([ID2.1.5])
Denmark([ID19])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Danish Nature Agency
angho@nst.dk
Not very satisfied([ID3.13])
We carry out reporting to no less than five international organizations (HELCOM, EU Commission., OSPAR, EEA, and OECD). The data is sent to the 5 organizations are mostly from the same data set. Coordination should be possible.
Water([ID3.28])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
About right([ID4.12WAT])
The type of information in the reporting i reasonable enough. The problem is that we are required to report the same types of data a number of times.
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22WAT])
 
I estimate that my colleagues and I spend about 30 days per year on the reporting of data from point source. Most of this time is used to understand the complex and diverse reporting formats. It should be possible to upload data once a year, after which the international organizations can download the data they need.
8
5
3
3
5
1
3
10
10
3
10
10
10
1
1
The answers above are based on my reporting obligations for point sources within the area Water Quality and Ecological Status.
Tend to disagree
Tend to agree
 
Tend to agree
Tend to agree
I totally agree
Tend to agree
 
 
Public authority([ID2.1.5])
Denmark([ID19])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
The Danish Environmental Protection Agency (Miljøstyrelsen)
 
Fairly satisfied([ID3.12])
 
Noise([ID3.25])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
About right([ID4.12NO])
 
Reporting process is efficient (good practice example)([ID4.21NO])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
4
8
8
8
6
6
8
8
8
8
8
2
6
8
4
 
Tend to agree
Tend to disagree
 
Tend to agree
Tend to disagree
Tend to disagree
Tend to disagree
 
 
Civil society organisation([ID2.1.3])
Germany([ID23])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
NABU Naturschutzbund Deutschland e.V. (NABU), German Nature and Biodiversity Conservation Union, Berlin, Germany, Identification number: 0285583802-96
Raphael.Weyland@NABU.de
Fairly satisfied([ID3.12])
 
Air quality and pollution([ID3.21] )
Biodiversity and nature([ID3.22])
Chemicals([ID3.23])
Natural resources([ID3.24])
Noise([ID3.25])
Soil([ID3.26])
Waste([ID3.27])
Water([ID3.28])
Too little, more is needed([ID4.13AQ] )
In light of the enormous impacts of air pollution, not least in terms of premature deaths and related costs, the collection of information related to air quality is crucial to inform the public and decision makers about the state of air quality and the resulting health and environmental impacts and to improve effectiveness of current EU and national air quality related policies, e.g. effectiveness of standards for road vehicles, best available techniques associated emission levels for industries and other air pollution related policies. However, information such as concentrations of small particles e.g. nano particles is missing from EU reporting obligations, despite growing evidence of their harmful impacts on human health. Also, additional information following recommendations from health experts such as the WHO would be extremely valuable in order to better understand air quality impacts on Europeans’ health and develop appropriate policies to address them.
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22AQ] )
Achieving compliance with Ambient Air Quality Directive through systematic upstream pollution prevention and control through the review of the industrial activities addressed under the BREFs of the IED are not made. The AAQD pollutants are not systematically addressed by the BAT Conclusions. However competent authorities are bound to ensure compliance with Air quality standards (media objective) and would need to set Emission Limit Values for these pollutants, which should be set to achieve the same maximum concentration values. In accordance to the pollution prevention at source principle, the reporting streams should be integrated. This would inform permit writers whether the point source ELVs need to be tightened or other corrective measures should be taken.
Costs related to monitoring for large point sources are available in the MON reference document or BREF documents but industry is silent about associated benefits. Continuous monitoring is needed for process control and optimisation reasons, also in relation to optimisation of environmental management systems. The associated benefits due to process and production optimisation or avoidance of liability issue due to permit breaches are most probably not quantified.
Too little, more is needed([ID4.13BIO])
Member States are under the Birds and Habitats Directives required to report every six years on the implementation. There are several aspects of implementation that are currently insufficiently reported on to assess implementation. For example, Member States are not required to report threats to all bird species, to report on hunting bags, and to report on screening results and outcomes of appropriate assessments under Article 6.3, while this would be important to assess the performance of the Directives. The Commission should examine the progress of Member States carefully and initiate infringements if knowledge does not improve sufficiently. The quality of the data also needs to improve, as there are many unknowns reported. There is also the scope for better guidance, such as on the methodology to identify favourable reference values.
Reporting process is efficient (good practice example)([ID4.21BIO])
Reporting under the Birds and Habitats Directive is overall very efficient. The reporting periods between the Birds and Habitats Directive have been harmonised, and the reporting requirements are revised and negotiated with the Member States and stakeholders after every reporting round to address any elements that have been found inefficient. A good practice example is the use of data collected by volunteers as an efficient way to assess the conservation status of breeding and wintering birds. Many Member States do this, and it is a very cost-effective method.
It is useless to look at the costs of monitoring and reporting in isolation from the benefits of collecting and sharing the data. Availability of the data is essential for responsible authorities to develop effective management plans and ensure that scarce resources are used as effectively as possible and spent in a targeted way on measures that will deliver. The monitoring and reporting is therefore an investment in order to ensure effective public spending. In addition, the data reported under the BHD could probably be used more effectively to gauge how well ecosystems which deliver services worth €200-300 billion/year are faring. Data on the condition of habitats can e.g. serve as a proxy for the condition and trends as regards certain ecosystem services such as carbon storage, flood control and water purification which are likely to increase as the conservation status of sites improves. (http://ec.europa.eu/environment/nature/natura2000/financing/docs/ENV-12-018_LR_Final1.pdf).
About right([ID4.12CHE])
REACH obliges the European Chemicals Agency to publish information on the substances manufactured or imported into the EU in order to enable competent authorities to regulate chemicals and citizens to be better informed on chemicals and to make informed decisions. The registration dossiers are therefore the pillar of REACH. Since the publication of ECHA’s dissemination portal, significant progress has been reached with regard to: the amount of data disseminated (information covering over 13,000 substances), the range of data disseminated, the user friendliness and the search options. The ECHA’s new dissemination portal makes information more easily accessible to the public, providing clearer, more organized and more concise information about the potential health and environmental risks caused by chemicals. However, there are issues still pending, e.g. the exposure scenarios (as part of Chemical Safety Reports) and also the tonnage bands of the registration data.
Reporting process is efficient (good practice example)([ID4.21CHE])
REACH substitution (IED relevant activities) data available isn't used in a comprehensive + effective manner to promote substitution of SVHC through the whole sector e.g. in setting Green Chemistry / substitution requirements within the BREF. Yet these “state of the art” benchmarks are explicitly aimed to promote the substitution of hazardous pollutants. Available information has to be used to improve production processes throughout the production lifecycle. Major Accidents Hazards (Seveso III) Information on how to prevent risk at source through substitution / lowering volumes of dangerous substances has to be used more effectively. Information reported through exposure scenario / CSR should be integrated in the elaboration of Chemical Safety Reports. In general, extending the reporting requirements in the E-PRTR to a priority list of product groups / pollutants to be addressed in outputs (including wastes) would be beneficial to chemical policy + resource efficiency objectives.
The study "REACH - Evaluation of the impact on the affected industries and the whole economy in Austria" found that chemical producers, especially large companies, were “rather positive” about REACH, with benefits including the preparation and standardization of safety data sheets (SDSs), better customer relations and wider knowledge of the properties and impacts of substances. ”The main scenario, which the study executive summary says used “the most reasonably estimated mean values for all benefits and costs”, shows REACH results in “a considerable economic resource gain” of around € 2.5bn. Similarly, a recent survey by Eurometaux concluded that REACH has improved metal companies’ knowledge of the hazards and risks of their substances. The study also revealed that 60% of companies recognise the benefits of REACH to help them to communicate to users the hazards and risks of the substances they manufacture, and to become more proactive on chemicals management.
Too little, more is needed([ID4.13NR])
Decision No 1386/2013/EU of the European Parliament and of the Council on the 7th EU Environmental Action Programme (EAP) to 2020 ‘Living well, within the limits of our planet’ sets as priority objective to turn the European Union into a resource-efficient, green and competitive low-carbon economy. Resource efficiency indicators and targets underpinned by robust data collection would provide the necessary guidance for public and private decision-makers in transforming the economy. Current reporting obligations are not sufficient to measure the EU’s total consumption of natural resources, including imports and exports. Additional data on Member State and industry level is needed to take account of the whole lifecycle of products and services and should be based on the footprint methodology, measuring at least environmental impacts on land, water and material use and carbon.
Reporting process is inefficient, significant improvements are needed([ID4.23NR])
Basically no specific reporting process has been defined yet that go beyond the implementation of EU waste legislation. In the context of the new EU Circular Economy (CE) Package the Commission intends to develop a monitoring framework (MF). The assessment of progress needs to address at least the following aspects in addition to the existing reporting on recycling of waste: material input into European production processes (e.g. through the BREF standards), ecodesign of products and services as well as resource-intensity of current consumption patterns. The planned MF for the CE should also reflect on global aspects, ecosystem considerations of resource consumption, risks to human health and well-being and other socio-economic issues. Information on characterisation of waste (e.g. hazard properties) is available through GHS / transport related obligations. This information should be better used for boosting circular economy objectives.
Generated information available at a “one stop shop” would promote the following objectives: - better knowledge of pollutants flows - circular economy and implementation of waste hierarchy - promote synergies with substitution of hazardous chemicals through relevant Chemical Policies (Green/ Sustainable Chemistry, SAICM, REACH substitution of Substances of Very High Concern etc) - support of other product design initiatives - consumer and workers health protection
Too little, more is needed([ID4.13NO])
Environmental noise affects a large number of Europeans in a number of physiological and psychological ways, interfering with basic activities such as sleep, rest, study and communication. Information about Europeans’ noise exposure levels is crucial to inform the public and decision makers about noise impacts and to develop adequate policies to address them. The amount of information should not be reduced but rather be updated in order to better reflect scientific evidence about health impacts. For instance, reporting thresholds should be updated to match the latest WHO Night Noise Guidelines for Europe’s recommended indicator values. Also, definitions of airports and agglomerations should be updated to better cover areas where people are exposed to noise levels which may put their health at risk.
 
 
 
Too little, more is needed([ID4.13SO])
Soil protection is one of the areas in which NO European legislation exists (despite a specific requirement in the IED limited to sites) therefore data collection in the European level has been kept to the minimum in the last decade. At the same time many soil related problems exist including soil sealing, land take, contamination, organic carbon change, nutrient imbalance, loss of biodiversity, compaction etc. Any action against these negative phenomena would need robust information on the state of European soils that should be collected though structured and harmonized monitoring and reporting.
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22SO])
The previous question cannot be answered as there is no option stating: Reporting process is nearly inexistent therefore it should be established. There is a general information gap on contaminated sites which has to be addressed. The obligation to elaborate a baseline report is set through the Industrial Emissions Directive (Art 12(1) point (e) and Art 22(2), this applies for new and existing installations. Available information should be integrated in the reporting obligations under the E-PRTR, in accordance to international obligations. Knowledge generated should be better linked with prioritization actions to be taken for upstream pollution prevention under REACH and the IED. Additionally, clear added value for the implementation of the Environmental Liability Directive.
Without knowledge on the state of European soils effectiveness of the agricultural, biodiversity, climate etc. policies cannot be assessed. The problem of the different national approaches is well-known by the European Commission: “EU Member States’ soil monitoring programmes vary because they were designed for different objectives and are often not integrated with other information sources. A more harmonised approach would increase the value of national programmes to European-wide soil information systems” (brochure: LIFE and soil protection, European Commission, 2014). Local soil contamination in 2011 was estimated at 2.5 million potentially contaminated sites in the EEA-39, of which about 45 % have been identified to date. About one third of an estimated total of 342 000 contaminated sites in the EEA-39 have already been identified and about 15 % of these 342 000 sites have been remediated. [reference: JRC 2014 report Progress in the management of contaminated sites in Europe].
Too little, more is needed([ID4.13WAS])
On waste, there are reporting obligations, but also clear gaps on food waste, preparation for reuse rate, consolidated data on industrial and commercial waste per sector and on residues of recycling treatment. A priority list of product groups / pollutants to be addressed in outputs (including wastes) could be included through a revised E-PRTR. Knowledge generated by national and regional initiatives on specific product groups should be used (e.g. Japan, Nordic PRTR group). The OECD Resource Compendium could be used as a good starting point: 1. Products that have relevant direct releases to the environment (Table 25) 2. Products with possible direct releases to the environment which are harmful (Table 26). Information on characterisation of waste (hazard properties) is available through GHS / transport related obligations. This would promote synergies within the various policy objectives.
Reporting process is inefficient, significant improvements are needed([ID4.23WAS])
It should be harmonised how MS report on waste generation and treatment. It needs to make better use of what is reported along the list of waste notably to consolidate data per economic sector. Gaps between generation and treatment for hazardous waste should be addressed: where they are actually treated when exported. Information on characterisation of waste (hazard properties/ waste codes) is available through GHS / transport related obligations and should be included in E-PRTR reporting Generated information available at a “one stop shop” would promote the following objectives: - better knowledge of pollutants flows - circular economy and implementation of waste hierarchy - promote synergies with substitution of hazardous chemicals through relevant Chemical Policies (Green/ Sustainable Chemistry, SAICM, REACH substitution of Substances of Very High Concern etc) - support of other product design initiatives - consumer and workers health protection
 
Too little, more is needed([ID4.13WAT])
Reporting under the WFD has collected significant amount of water related data in the last 2 years to WISE, but quality of data has to be checked by the EC. The focus should now be put on better interpretation of the existing data. Reporting under the MSFD is in its infancy. Therefore there is still a “2nd phase” to the MSFD to provide further data that still needs to be reported in 2018. Furthermore, the current criteria laid out in the Commission Decision of 2010 is lacking to ensure that sufficient data is collected + reported, e.g. when it comes to the pressures that species + habitats face. Under Descriptor 1, seabirds are one area that MS have to report back. Yet, under the current Commission Decision of 2010 criteria, MS do not have to report back on the level of the threats faced by seabirds. Therefore, where MS should be collecting + reporting on data such as seabird bycatch, this is not being done.
Reporting process is efficient (good practice example)([ID4.21WAT])
Reporting under WFD is a good practice example. The need for reporting and the main content are fixed in WFD but the details are agreed in a democratic process, a working group where Commission, MS and all interested stakeholders participate. This provides the necessary flexibility that allows for considering the experience of previous reporting exercises and the development in knowledge and legislation to make the necessary adjustments in between two reporting cycles. Detailed reporting specification and IT rules are worked out in the spirit of the INSPIRE-D. QA/QC of the reported data is ensured. The data is disseminated in the WISE system (the dissemination could further be improved). Better synergies of achieving the GES + GCS of WBs through effective upstream pollution prevention requirements set on PS/PHS in the BREF documents is needed. Integration of improved monitoring data on point source emitters and WW transfers with achieving the EQS in the receiving WB shall be achieved.
The monitoring and reporting are important elements of the implementation of the water related legislation, the costs and benefits of monitoring, reporting belong to the costs and benefits of implementation. Benefits have been discussed in a European Parliament study: “With better implementation of the legislation, and reaching the target of good ecological status for all European water bodies, the benefits would be at least €2.8 billion a year ... further European action in this field could provide further added value, representing a ‘cost of non-Europe’ of some 25 billion euro per year.” (EP: Potential benefits of EU water legislation, http://www.europarl.europa.eu/RegData/etudes/STUD/2015/536369/EPRS_STU(2015)536369_EN.pdf ).
10
10
3
10
10
10
4
7
2
10
10
5
2
10
10
It is the responsibility of the Member States that they track the state of the environment in their country vigorously. The real work underpinning the reporting is collecting the data, not the transmission of data to the European Commission. Please see our position for suggestion on how to improve data collection The adoption of the universal 2030 Sustainable Development Agenda can give the regions and MS a political leverage to streamlined accountability and monitoring mechanism. Regular assessments on international (HLPF), regional (UNECE/EU/OECD) and national levels need to be done in the framework of the 17 SDGs and 169 targets, with upcoming universal indicators.
No opinion
No opinion
The distinction between 'formal' and 'informal' used in the questionnaire is unclear, please see our attached position paper for our assessment of how the system of reporting currently in place for the Birds and Habitats Directives has worked. As mentioned earlier, WFD reporting is propably a good example in this respect (of how monitoring and reporting could be organized).
Tend to disagree
I totally agree
Totally disagree
I totally agree
We believe it is very important for the Commission to evaluate how existing reporting requirements have inspired scientific work and conservation action. The reporting under the Birds Directive has several publications including two key scientific papers (Donalds et al 2007 and Sanderson et al 2015), has formed the basis of the European Red List of Birds (BirdLife 2015a), the European Commission’s Mid-term Assesment of the EU Biodiversity Strategy (EC 2015) and the BirdLife Assessment of the same Strategy (BirdLife 2015b). Through reporting, the Commission was able to identify many infringements at an early stage, such as the Malta Spring Hunting (C-76/08), and Lauteracher Ried (C-209/04).
Professional organisation([ID2.1.7])
Belgium([ID13])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
CEMBUREAU, The European Cement Association
Industrial_Policy@cembureau.eu; v.maringolo@cembureau.eu
Not very satisfied([ID3.13])
E-PRTR is consensually (see EC-AMEC Workshop on E-PRTR on 3 November) not a tool for environmental performance assessment or for policy making, and the dataset has been used as such.
Air quality and pollution([ID3.21] )
Biodiversity and nature([ID3.22])
Chemicals([ID3.23])
Natural resources([ID3.24])
Waste([ID3.27])
About right([ID4.12AQ] )
The amount of information is about right, but overlaps and “nice-to-have” data should be avoided. We are also concerned of the use that is made of data (see comment above on E-PRTR).
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22AQ] )
Improvements could be made on E-PRTR. And for BREF making, avoid “nice-to-have” data and develop consistent methodology for derivation of BATAELs.
No
About right([ID4.12BIO])
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22BIO])
 
 
About right([ID4.12CHE])
 
Reporting process is efficient (good practice example)([ID4.21CHE])
 
 
About right([ID4.12NR])
The Resource Efficiency Scoreboard is very comprehensive.
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22NR])
Concern remains on what use the European Commission will do with these data in the future, as the flawed concept of the lead indicator based on volumes and targets setting from it would be detrimental to the extractive industries in general and the EU cement industry in particular.
No.
 
 
 
 
 
 
 
 
 
 
About right([ID4.12WAS])
While the amount is about right, the quality of information could be improved (see below).
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22WAS])
The data collection on waste treatment should breakdown into the various options. The way it is, the energy recovery from waste co-processed in cement kilns is added up to the energy recovery incinerated in waste-to-energy installations.
No.
 
 
 
 
 
10
5
5
5
10
4
10
10
10
6
10
7
5
5
5
 
Tend to agree
Tend to disagree
 
Totally disagree
No opinion
No opinion
I totally agree
E-PRTR, BAT-AELs, guidance to data reporters, guidance to data users.
 
Civil society organisation([ID2.1.3])
Slovenia([ID37])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Društvo Ekologi brez meja
jaka.kranjc+eumonitoringrefit@ocistimo.si
Fairly satisfied([ID3.12])
 
Waste([ID3.27])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Too little, more is needed([ID4.13WAS])
Both Circular Economy packages require extra indicators to be effectively implemented. Several key terms like municipal waste and recycling are loosely interpreted, which leads to subtly incomparable data (well documented in one of the 2013 waste consultations, likely the one on targets) between MS. Some will be solved by improved legal definition, in some cases leading to decoupling, in the end providing more information. Separately, there is the issue of incomplete reporting compliance from the industry (data gaps).
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22WAS])
The aforementioned data gaps prove that it is likely too easy to be non-compliant or too hard to be compliant (at least in Slovenia). We think the truth is somewhere in the middle of that spectre and more in the administrative than in financial sense.
 
 
 
 
 
 
10
8
8
10
10
7
8
10
9
10
10
6
9
10
3
 
Tend to agree
Totally disagree
The second statement would lead to chaos, madness and data deterioration!
Totally disagree
No opinion
Tend to agree
Tend to agree
 
 
Public authority([ID2.1.5])
Belgium([ID13])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Coordination Committee for International Environmental Policy (CCIEP) – Working Group on Emissions
m.vandenhende@vmm.be
Satisfied([ID3.11])
 
Air quality and pollution([ID3.21] )
About right([ID4.12AQ] )
 
Reporting process is efficient (good practice example)([ID4.21AQ] )
In Flanders the data retrieval of industrial emissions to air (and also water, groundwater, waste and energy data) are clustered in an integral environmental annual report (IMJV, Integraal Milieujaarverslag, http://milieujaarverslag.milieuinfo.be/), so allowing the facilities to report only once to the competent authority. The data are stored in a database and serve as a basis for all international reporting requirements (except ETS). In the Walloon region, there is also a database called REGINE for the industrial emissions (air, water, waste and energy data). The software which manages the air emissions for all sectors is common for the LRTAP/NEC inventory and the GHG inventory. All the data are consistent. In the Brussels Capital Region, all the data concerning the emissions from all the sectors (transportation, residential, tertiary sector, waste, …) are centralized in the database “BRAINS”. The reporting are based on these data.
No information available.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
10
10
10
10
10
4
2
10
9
10
10
10
10
7
7
 
I totally agree
Totally disagree
 
Tend to agree
Tend to agree
Tend to disagree
Tend to agree
The commission may have to continue to simplify the template they use for the reporting and the number of reporting.
 
Public authority([ID2.1.5])
Italy([ID27])
 
Anonymously: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.2)
ISPRA_Italian Institute for Protection and research of the Environmen
 
Fairly satisfied([ID3.12])
 
Air quality and pollution([ID3.21] )
About right([ID4.12AQ] )
 
Reporting process is efficient (good practice example)([ID4.21AQ] )
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
10
8
8
8
9
8
9
10
9
9
9
 
 
 
 
 
 
 
 
Tend to agree
 
 
 
 
 
As an individual / private person([ID2.1.1])
United Kingdom([ID40])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Philippa Goodwin
goodrobert@talktalk.net
Fairly satisfied([ID3.12])
 
Biodiversity and nature([ID3.22])
 
 
 
 
 
Too little, more is needed([ID4.13BIO])
Habitats Directive reporting: Art 17 & Birds Directive Art 12: Insufficient detail is required about use of Art 6(4) and optional field on the impact of projects should be mandatory so the effect of plans/projects on the Natura 2000 network can be ascertained. Most Member States don't complete this section. Insufficient transparency - some member states kept their reports locked until months after the deadline for submissions (eg NL, FR, DE). Habitats Directive derogation reporting Art 16 and Birds Directive derogation reporting Art 9: Several member states are don't report, are slow to report or lock the information from the public (eg AT, BG, DE, IE, ES). Habitats Directive Art 6(4) requires member states to inform the Commission of compensatory measures in relation to projects which have a significant negative impact on Natura 2000 sites. This information should be made public in a timely manner (more frequently than the 6 yearly reporting cycle) so there is proper transparency.
Reporting process is efficient (good practice example)([ID4.21BIO])
The information gathered is vital to assessing the status of the EU's biodiversity. The relatively small costs involved (particularly when so much of this work is done by volunteers) is trivial compared with the importance of having the data.
No, but I am aware that in the UK much of this work is done by volunteers hence lowering costs.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
10
10
10
10
10
8
7
8
8
10
10
7
10
7
7
In EU context, the Commission is best placed to standardise reporting formats and issue guidance to Member States.
I totally agree
Totally disagree
 
No opinion
No opinion
No opinion
Tend to agree
 
 
Private enterprise([ID2.1.4])
Belgium([ID13])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Metallo-Chimique
inge.maes@metallo.com
Not very satisfied([ID3.13])
We support the collection and reporting of the right information, at the right time and in an efficient way, in order to be able to do for example appropriate risk management. However, to ensure efficient reporting, further attention should be paid to consistency and correctness of data, and to the fact that data are recent and relevant to the scope. We believe an improved balance should be constantly searched between the incremental value for environmental protection, and the global competitiveness of the EU non-ferrous metal industry, taking into consideration that metals are globally priced. An important reference is the ECORYS final report ‘Competitiveness of the EU Non-ferrous Metals Industries’ (April 2011; e.g. Table 2.8, page 58). Environmental compliance costs results as a key issue of interest (together with energy and labour costs), especially in comparison with emerging economies, where the industry often is subjected to less regulation and does not face similar costs.
Air quality and pollution([ID3.21] )
Chemicals([ID3.23])
Soil([ID3.26])
Waste([ID3.27])
Water([ID3.28])
About right([ID4.12AQ] )
Many data are collected and available, however their use when implementing various regulatory processes is not yet straightforward. One major issue is still the efficient use of the information and data collected on air quality and pollution (e.g. on SO2) when dealing with different regulations; some improvements in the alignment between regulations and efficient use of already collected relevant data, would be beneficial. Data should be comparable all over EU, thus the monitoring methods should be standardized. The standardization of monitoring methods is very important especially when dealing with air quality monitoring; measured emission results from the metal production vary significantly depending on the measuring organization and method, with reference for example to the EN14181 standard, and lack of clarity on how to do the measurements.
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22AQ] )
The amount of information that is required and the way of reporting might be efficient, but measurements themselves are often very expensive and time consuming. Most of the time, measurements cannot be done by the company itself and require external laboratories or consultants, making the process more expensive. As an example: stack emissions measurements for “dust” (PM10) from stacks implies 4 hours of measuring, costing 1000 €/stack, in average at least every month per stack.
 
 
 
 
 
 
About right([ID4.12CHE])
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22CHE])
The preparation and updating of REACH dossiers are very demanding. The evolving rules and reporting tools, the need for updates, the level of detail required imply investments that are still difficult to bear for some companies.
 
 
 
 
 
 
 
 
 
 
 
Too much, less is needed([ID4.11SO])
Soil monitoring presents problems related to the variability and the uncertainties of soil sampling. Obtaining a representative picture of soil requires such a huge number of samples that in many cases the site remediation itself becomes economically more interesting than the sampling program itself. If soil sampling is held as a tool to measure incremental pollution, it will almost always fail since incremental soil contamination is difficult to detect, especially in the case of gradual impact. The costs and operational difficulties will always limit the number of locations which can be sampled and the resulting data will have high level of uncertainty and low level of confidence (and it is often difficult to distinguish old contamination from recent one). Thus soil sampling is not representative in terms of adequate characterisation of ground areas; repeated comparisons over long periods of time are almost always technically flawed and scientifically unsound.
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22SO])
A downside for soil monitoring is that it is expensive and needs to be done by external consultants.
 
About right([ID4.12WAS])
In the waste area there are many reporting obligations, and it is indeed difficult to evaluate the numerous monitoring and reporting requirements in place in different specific pieces of legislation in such a rather general questionnaire without having a reference list of monitoring and reporting obligations which are to be evaluated. To be more effective, it would be important to be able to rely on a list of all monitoring and reporting obligations and answer to concrete questions.
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22WAS])
 
 
Too little, more is needed([ID4.13WAT])
We still experience lack of matched data to properly perform the risk assessments in water bodies. In fact. for assessing the risk metals in water it is fundamental to evaluate their bioavailability, since the effects on aquatic organisms are dependent on the physico-chemical conditions in the water body that determine the amount of bioavailable metal the organisms are exposed to. There is a significant amount of monitoring data in both the whole water and dissolved fractions but, presently, matched physico-chemical data (e.g. pH, hardness, DOC) are often lacking. These are needed in conjunction with the dissolved metals concentrations data in order to estimate the bioavailable fraction. An important aspect is the high dependence of information on where the measurements is taken (e.g. mixing zones; old mining areas with high natural background levels), and the consequent need for clear regulatory indications.
Reporting process is inefficient, significant improvements are needed([ID4.23WAT])
We keep experiencing inefficiencies linked to the use of water monitoring data across EU legislations, in particular when looking at the Review of Priority Substances process under the Water Framework Directive (and related DIRECTIVE 2013/39/EU) that we have followed with commitment in the last 10 years. For examples, the PNEC values selected for many metals to run the ongoing prioritisation exercise correspond to the lowest EQS used among the EU Member States, with differences in some cases of 1 or even 2 orders of magnitude between the values derived and adopted in the various MS (and the reasons are not clear). The values used disregard the most updated datasets developed as well as the related scientific evidence gained under REACH. Thus the risk of a prioritisation under the WFD based on values derived from monitoring data of inappropriate quality is relevant, as well as the need for an improved efficiency when various data systems under EU legislations are in place.
 
6
8
6
8
5
5
7
9
9
7
9
8
9
6
5
Every level has its role to play, higher levels should set the overall goals, lower governance levels should have more emphasis on specific measures and make sure relevant and cost effective measures are taken. We still experience relevant differences at local levels, more stringent norms and data requirements in some contexts (e.g. on gold-plating), leading to unfair playing fields.
Tend to agree
Totally disagree
 
 
 
 
 
Our sectorial BREF – the Best Available Techniques (BAT) Reference Document for the Non-Ferrous Metals Industries under the Industrial Emissions Directive 2010/75/EU – was finalized last year, the BAT conclusions have just received positive opinion by Art.75 Committee and should be published soon. We will still experience some lack of consistency because of references made in the new BREF to the LVIC BREF that will not be reviewed soon. We keep believing that monitoring the receiving environment is also very relevant. To this respect, some very important databases are nowadays available, e.g. FOREGS Geochemical Atlas for Europe, and GEMAS Geochemical mapping of agricultural and grazing land soil, which allow to catch the relevance of regional background for metals versus point sources of emissions.
 
Public authority([ID2.1.5])
Spain([ID38])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
National Center for Geographic Information
elromero@fomento.es
Fairly satisfied([ID3.12])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
7
8
8
6
8
6
6
9
9
9
7
6
8
8
6
 
Tend to agree
Tend to disagree
 
Tend to agree
I totally agree
Tend to agree
I totally agree
 
 
Public authority([ID2.1.5])
Germany([ID23])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
Ministry of Environment, Energy and Climate Protection of Lower Saxony (Germany)
rudolf.gade@mu.niedersachsen.de
Not very satisfied([ID3.13])
The reporting requirements are much too extensive and not legally binding. The relation between reporting effort and Information benenefit is very low.
Water([ID3.28])
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Too much, less is needed([ID4.11WAT])
The requirements are too detailed. Many data demands can not be derived from the Directives, for example detailed cost information.
Reporting process is inefficient, significant improvements are needed([ID4.23WAT])
The reporting requirements are increasing year by year. This reduces our resources for the implementation of mitigation measures on the water bodies.
The Monitoring of water bodies by the competent authorities only in Lower Saxony costs about 7 Mill. € per year. Considered are abot 1600 water Surface water bodies and 120 groundwater bodies. Permanently 3,5 staff positions are required only for reporting (WFD, MSFD)
9
5
4
3
7
2
2
8
10
 
7
4
8
7
4
no
Tend to agree
Tend to disagree
 
Tend to agree
Tend to disagree
Tend to agree
Totally disagree
 
 
Civil society organisation([ID2.1.3])
Belgium([ID13])
 
Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication([ID2.3.1])
European Environmental Citizens' Organisation for Standardisation (ECOS)
info@ecostandard.org
Not very satisfied([ID3.13])
Some actors from the industry sector continue to perceive environmental Reporting & Monitoring requirements as an unnecessary & constraining burden, arguing that these are very costly and should be made optional, less detailed and/or less frequent. This prevents transparent, complete & reliable information exchanges to take place between the EU & Member States (MS) and hinders the enforcement of EU environmental policy, e.g corrective actions in case of insufficiency/deficiencies in reporting. Commonly agreed,harmonised standards for Monitoring and Reporting requirements could be pivotal to improve interpretation, presentation & dissemination of high-quality data,notably by ensuring that all MS actors regularly collect complete, user-friendly & comparable data (in a timely & transparent manner);and by accommodating & streamlining the diverse reporting methods & databases currently used at MS/regional/local level.
Air quality and pollution([ID3.21] )
Chemicals([ID3.23])
Waste([ID3.27])
Too little, more is needed([ID4.13AQ] )
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22AQ] )
Considering the scale and negative impacts of air pollution, collection of relevant data should be made optimal. More use should be made of existing & future mandated standards in the field of EU air quality related policies, such as those related to measurement/test methods for dioxins, particulate matter (PM 10 & PM 2,5) and mercury emissions. In this regard, more links should be drawn between standardisation efforts in the field of air quality, which aim at improving the quality & scope of the data collected (e.g automated measurement methods, quality of models used), and the development of best available techniques related to emission limit values for industries under the Ambient Air Quality and Industrial Emissions Directives. Compliance with air quality standards under the two latter Directives should be improved.
 
 
 
 
 
 
About right([ID4.12CHE])
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22CHE])
In general terms,reporting under EU Chemical legislation could be simplified and better explained to relevant actors.Relevant information relating to environmental characteristics/properties of chemicals should be complete,understandable,legible, consistent and easily accessible to the general public,especially at registration phase. This data collection process should follow the REACH principle of 'no data, nor market' and make use of e.g product passports.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Too little, more is needed([ID4.13WAS])
 
Reporting process is neither efficient nor inefficient, some specific improvements could be made([ID4.22WAS])
MS’ reporting on waste generation and treatment should be harmonised, data collected in this regard should be better used and consolidated; and transparent information should be available as regards the treatment of WEEE, e.g to what extent is WEEE de-polluted.The standard series currently under development at CENELEC (CLC/TC 111x) relating to WEEE recycling & specifics for depollution (EN 50625 series), and preparation for re-use (EN 50614) should be uniformly implemented and complied with once available.
 
 
 
 
 
 
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9
7
10
9
9
7
7
7
10
10
8
8
5
5
Potential synergies and linkages between reporting obligations & monitoring requirements under EU environmental policy and international environmental conventions could be better explored to ensure transparency & consistency in the collected data; and thus avoid scattered, opaque & costly data collection processes at MS/regional level. For instance, in the case of enforcing Ecodesign & energy labelling Regulations, adequate resources must be made available uniformly at MS level (staff, expertise, availability of laboratories & certified professionals to analyse data) to allow for legal action to be pursued by MS in case of non-compliance.
Tend to agree
Totally disagree
Reporting obligations should be clearly laid down in relevant EU environmental legislation from the outset (and regularly re-assessed once established), so as to enable the collection,monitoring & use of reliable,consistent & comparable data of high quality (e.g to build statistics or to identify trends); to allow for regular, complete & transparent information exchange both at EU and MS level; to ensure full compliance and enforceability of environmental provisions; and to allow for corrective action to be taken in case of insufficient or non-compliance. Monitoring and reporting requirements may be agreed upon in an ad hoc collaboration process among MS & stakeholders whenever appropriate, potentially informally or on a case-by-case basis, so as to provide more flexibility & common understanding of requirements and how these should be fulfilled. This process should however be closely monitored by the Commission.
Tend to disagree
Tend to agree
No opinion
Tend to agree
There is room for improvement in terms of setting commonly agreed, harmonised standards for Monitoring and Reporting requirements in order to ensure that all actors involved in the implementation of EU & international environmental policy regularly collect relevant, complete, comparable & coherent data in the same way & in a timely, transparent manner, including with a view to using MS' individual reporting as benchmark/incentive to improve their own respective environmental performance. The level of reporting requirements should not be diminished but the use and dissemination of the collected data should improve in terms of quality, consistency & comprehensiveness. Environmental reporting should be regular, of high quality & its conditions and results should also be regularly reviewed. Information/data related to Monitoring &Reporting requirements should be readily accessible to all so as to fully respect the Aarhus Convention.
 

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2.1 Who are you?

Civil society organisation

2.2. Please give your country of residence/establishment

Italy

Other, please specify below

 

2.3. Please indicate your preference for the publication of your response on the Commission’s website:

Under the name given: I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions that prevent publication

2.4. Please give your name if replying as an individual/private person, otherwise give the name of your organisation

ITALIA NOSTRA ONLUS - SEZIONE VITERBO

2.5. Please provide your email address if you would like to be informed of the outcome of this consultation

viterbo@italianostra.org

3.1 Overall impression

On the whole, are you satisfied, fairly satisfied, not very satisfied or not at all satisfied with environmental Monitoring and Reporting requirements?

Satisfied

If you are not satisfied, could you give the reason(s)?

 

3.2 Overall perception

Please choose the environmental policy area(s) for which you are familiar with the Monitoring and Reporting requirements.

Air quality and pollution
Biodiversity and nature
Chemicals
Natural resources
Noise
Soil
Waste
Water

We are interested in getting more information about your perceptions as regards the policy area(s) you are familiar with. See below the two questions related to section 4. Current perceptions of environmental reporting (after these questions, please continue with question 3.3).

4.1 Effectiveness

You declared you are familiar with the following policy area: AIR QUALITY AND POLLUTION. Which of these statements do you consider as appropriate about the amount of information that is collected?

Too little, more is needed

Do you have specific comments, concrete examples or specific evidence that could underpin your response?

PER QUANTO RIGUARDA L'ITALIA: 1) SI CONTINUA A PERMETTERE LA COSTRUZIONE E LA VENDITA DI MARMITTE NON ASSIMILABILI ALLE OMOLOGATE ECOLOGICHE CHE GENERANO RILEVANTE INQUINAMENTO ATMOSFERICO; 2) SI PERMETTE LA MODIFICA DI CICLOMOTORI (SCOOTER) E DI ALTRI VEICOLI MOTORIZZATI, ACQUISTATI CON ECO INCENTIVI STATALI, DI MARMITTE CHE GENERANO UN ALTO INQUINAMENTO ATMOSFERICO, DIFFICILMENTE RILEVABILE DALLE FORZE DI POLIZIA IN SERVIZIO SULLE STRADE E DALLE OFFICINE DI REVISIONE PRIVATE, AUTORIZZATE DALLA MOTORIZZAZIONE CIVILE E DALLE PROVINCE.

4.2. Efficiency

You declared you are familiar with the following policy area: AIR QUALITY AND POLLUTION. Which of the following statements do you consider appropriate when assessing the cost and administrative burden of the reporting process?

Reporting process is inefficient, significant improvements are needed

Do you have specific comments, concrete examples or specific suggestions?

DIVIETO ASSOLUTO DI COSTRUZIONE, DI VENDITA E DI INSTALLAZIONE DI MARMITTE NON ECOLOGICHE-OMOLOGATE.

Are you able to provide any quantitative evidence or references relating to the costs of monitoring and reporting for authorities, regulators, sectors or businesses?

 

We are interested in getting more information about your perceptions as regards the policy area(s) you are familiar with. See below the two questions related to section 4. Current perceptions of environmental reporting (after these questions, please continue with question 3.3).

4.1 Effectiveness

You declared you are familiar with the following policy area:BIODIVERSITY AND NATURE. Which of these statements do you consider as appropriate about the amount of information that is collected?

About right

Do you have specific comments, concrete examples or specific evidence that could underpin your response?

 

4.2. Efficiency

You declared you are familiar with the following policy area: BIODIVERSITY AND NATURE. Which of the following statements do you consider appropriate when assessing the cost and administrative burden of the reporting process?

Reporting process is neither efficient nor inefficient, some specific improvements could be made

Do you have specific comments, concrete examples or specific suggestions?

 

Are you able to provide any quantitative evidence or references relating to the costs of monitoring and reporting for authorities, regulators, sectors or businesses?

 

We are interested in getting more information about your perceptions as regards the policy area(s) you are familiar with. See below the two questions related to section 4. Current perceptions of environmental reporting (after these questions, please continue with question 3.3).

4.1 Effectiveness

You declared you are familiar with the following policy area: CHEMICALS. Which of these statements do you consider as appropriate about the amount of information that is collected?

About right

Do you have specific comments, concrete examples or specific evidence that could underpin your response?

 

4.2. Efficiency

You declared you are familiar with the following policy area: CHEMICALS. Which of the following statements do you consider appropriate when assessing the cost and administrative burden of the reporting process?

Reporting process is neither efficient nor inefficient, some specific improvements could be made

Do you have specific comments, concrete examples or specific suggestions?

 

Are you able to provide any quantitative evidence or references relating to the costs of monitoring and reporting for authorities, regulators, sectors or businesses?

 

We are interested in getting more information about your perceptions as regards the policy area(s) you are familiar with. See below the two questions related to section 4. Current perceptions of environmental reporting (after these questions, please continue with question 3.3).

4.1 Effectiveness

You declared you are familiar with the following policy area: NATURAL RESOURCES. Which of these statements do you consider as appropriate about the amount of information that is collected?

About right

Do you have specific comments, concrete examples or specific evidence that could underpin your response?

 

4.2. Efficiency

You declared you are familiar with the following policy area: NATURAL RESOURCES. Which of the following statements do you consider appropriate when assessing the cost and administrative burden of the reporting process?

Reporting process is neither efficient nor inefficient, some specific improvements could be made

Do you have specific comments, concrete examples or specific suggestions?

 

Are you able to provide any quantitative evidence or references relating to the costs of monitoring and reporting for authorities, regulators, sectors or businesses?

 

We are interested in getting more information about your perceptions as regards the policy area(s) you are familiar with. See below the two questions related to section 4. Current perceptions of environmental reporting (after these questions, please continue with question 3.3).

4.1 Effectiveness

You declared you are familiar with the following policy area: NOISE. Which of these statements do you consider as appropriate about the amount of information that is collected?

Too little, more is needed

Do you have specific comments, concrete examples or specific evidence that could underpin your response?

 

4.2. Efficiency

You declared you are familiar with the following policy area: NOISE. Which of the following statements do you consider appropriate when assessing the cost and administrative burden of the reporting process?

Reporting process is inefficient, significant improvements are needed

Do you have specific comments, concrete examples or specific suggestions?

PER QUANTO RIGUARDA L'ITALIA: 1) SI CONTINUA A PERMETTERE LA COSTRUZIONE E LA VENDITA DI MARMITTE NON ASSIMILABILI ALLE OMOLOGATE ECOLOGICHE CHE GENERANO RILEVANTE INQUINAMENTO ACUSTICO; 2) SI PERMETTE LA MODIFICA DI CICLOMOTORI (SCOOTER) E DI ALTRI VEICOLI MOTORIZZATI, ACQUISTATI CON ECO INCENTIVI STATALI, DI MARMITTE CHE GENERANO UN ALTO INQUINAMENTO ACUSTICO, DIFFICILMENTE RILEVABILE DALLE FORZE DI POLIZIA IN SERVIZIO SULLE STRADE E DALLE OFFICINE DI REVISIONE PRIVATE, AUTORIZZATE DALLA MOTORIZZAZIONE CIVILE E DALLE PROVINCE.

Are you able to provide any quantitative evidence or references relating to the costs of monitoring and reporting for authorities, regulators, sectors or businesses?

 

We are interested in getting more information about your perceptions as regards the policy area(s) you are familiar with. See below the two questions related to section 4. Current perceptions of environmental reporting (after these questions, please continue with question 3.3).

4.1 Effectiveness

You declared you are familiar with the following policy area: SOIL. Which of these statements do you consider as appropriate about the amount of information that is collected?

Too little, more is needed

Do you have specific comments, concrete examples or specific evidence that could underpin your response?

DIVIETO ASSOLUTO DI COSTRUZIONE, DI VENDITA E DI INSTALLAZIONE DI MARMITTE NON ECOLOGICHE-OMOLOGATE.

4.2. Efficiency

You declared you are familiar with the following policy area: SOIL. Which of the following statements do you consider appropriate when assessing the cost and administrative burden of the reporting process?

Reporting process is inefficient, significant improvements are needed

Do you have specific comments, concrete examples or specific suggestions?

PER QUANTO RIGUARDA L'ITALIA, ABROGAZIONE/ANNULLAMENTO, ANCHE CON EFFETTO RETROATTIVO, DELLE NORME INCOSTITUZIONALI SUI CONDONI E SANATORIE EDILIZI E SUI PIANI CASA IMPATTANTI NEGATIVAMENTE SUL TERRENO, SULL'AMBIENTE E SUL PAESAGGIO, AI SENSI DELL'ART. 9 DELLA COSTITUZIONE ITALIANA, COME DA NUMEROSE SENTENZE DELLA CORTE COSTITUZIONALE ITALIANA,

Are you able to provide any quantitative evidence or references relating to the costs of monitoring and reporting for authorities, regulators, sectors or businesses?

 

We are interested in getting more information about your perceptions as regards the policy area(s) you are familiar with. See below the two questions related to section 4. Current perceptions of environmental reporting (after these questions, please continue with question 3.3).

4.1 Effectiveness

You declared you are familiar with the following policy area: WASTE. Which of these statements do you consider as appropriate about the amount of information that is collected?

Too little, more is needed

Do you have specific comments, concrete examples or specific evidence that could underpin your response?

 

4.2. Efficiency

You declared you are familiar with the following policy area: WASTE. Which of the following statements do you consider appropriate when assessing the cost and administrative burden of the reporting process?

Reporting process is inefficient, significant improvements are needed

Do you have specific comments, concrete examples or specific suggestions?

 

Are you able to provide any quantitative evidence or references relating to the costs of monitoring and reporting for authorities, regulators, sectors or businesses?

 

We are interested in getting more information about your perceptions as regards the policy area(s) you are familiar with. See below the two questions related to section 4. Current perceptions of environmental reporting (after these questions, please continue with question 3.3).

4.1 Effectiveness

You declared you are familiar with the following policy area: WATER. Which of these statements do you consider as appropriate about the amount of information that is collected?

Too little, more is needed

Do you have specific comments, concrete examples or specific evidence that could underpin your response?

PER QUANTO RIGUARDA L'ITALIA: 1) MAGGIORE TRASPARENZA CON OBBLIGO DI PUBBLICAZIONE TRAMITE APPOSITI CARTELLI IN LOCO E SUI SITI WEB ISTITUZIONALI, RIPORTANTI I DATI DELLE AUTORIZZAZIONI/NULLA OSTA RILASCIATI PER DERIVAZIONI SU CORSI D'ACQUA (PUBBLICI), SU REALIZZAZIONI EX NOVO E PER AMPLIAMENTI DI POZZI PER PRELIEVO DI ACQUE SOTTERRANEE, ETC.

4.2. Efficiency

You declared you are familiar with the following policy area: WATER. Which of the following statements do you consider appropriate when assessing the cost and administrative burden of the reporting process?

Reporting process is inefficient, significant improvements are needed

Do you have specific comments, concrete examples or specific suggestions?

 

Are you able to provide any quantitative evidence or references relating to the costs of monitoring and reporting for authorities, regulators, sectors or businesses?

 

3.3. Objectives

How important do you rate these different objectives (which relate to relevance and coherence) for setting environmental Monitoring and Reporting requirements?

Monitoring and reporting should allow for an assessment of whether EU legal obligations are being met

10

Monitoring and reporting should allow stakeholders to understand the state of the environment and the actions taken to maintain and improve it

10

Monitoring and reporting should indicate how well the legislation is working (i.e. costs and benefits)

10

Monitoring and reporting should generate reliable environmental information and ensure access to environmental information for citizens so they understand what EU legislation achieves

10

Monitoring and reporting should allow comparison between Member States as regards their performance when implementing EU environment law

10

3.4. Principles

How important do you rate these different criteria for setting environmental Monitoring and Reporting requirements and delivering EU value added?

Comprehensive:
Monitoring and reporting should provide a very detailed picture

10

Efficiency:
Monitoring and reporting should cover the information on the costs and benefits of the action

10

Coherence:
Information should be collected once, and shared where possible for many purposes (minimise overlap)

10

Proportionality:
A balance should be struck between asking for more information, and the cost of that provision

10
Accessibility:
Reported information should be fully available to the general public, after due consideration of the appropriate level of aggregation and subject to appropriate confidentiality constraints
10

Timeliness:
Monitoring and reporting information should be timely and up to date

10

4.3. Different governance levels

As well as environmental reporting obligations towards DG Environment, there are a number of international obligations, for example, to European marine conventions, OECD, UN, and UNECE. Attention needs to be made to ensuring that synergies are exploited between these commitments, and that inconsistencies are avoided.

What are the levels of governance where there is the biggest potential to combine or streamline reporting requirements in order to reduce costs and administrative burdens?

International (wider than Europe)

10

European Commission

10

Member State (including national Competent Authority)

10

Regional and local

10

Do you have specific comments, concrete suggestions or specific evidence that could underpin your response?

 

4.4 The Standardised Reporting Directive

This Directive was agreed in 1991 to provide a single harmonised approach. Many specific reporting decisions in different policy areas (e.g. water, waste, etc) have been agreed. Over time, however, most reporting requirements have been included in specific pieces of legislation so that they can be better tailored to the needs of those specific pieces of legislation. The Commission is now considering the repeal of the Standardised Reporting Directive including all its specific reporting questionnaires most of them being obsolete already. However, the question in relation to the Fitness Check on monitoring and reporting is whether such a legally binding, horizontal approach should be developed again in the future.

In this context, do you agree or disagree with each of the following statements?

The reporting obligations should be laid down specifically in individual pieces of legislation and coordination and streamlining should be ensured through collaboration

I totally agree

Reporting requirements do not need to be laid down in legislation but should be agreed informally on a case-by-case basis between the EU Commission and the Member States

Totally disagree

Do you have specific comments or concrete suggestions?

 

4.5 The process for reporting

As well as the content of what is reported, the process for reporting is important for ensuring that the right information is collected, processed and disseminated at lowest possible cost. IT technologies could be one of the answers.

In this context, do you agree or disagree with each of the following statements?

IT technology is already adequately used and no further major improvements of the reporting process are needed

Totally disagree

The INSPIRE directive can provide a common approach and process for reporting, reducing administrative burden and facilitating reuse of the reporting process and information across different levels of government

I totally agree

The business process and quality assurance procedures (outside the rules laid down by the INSPIRE Directive) in place for reporting are still causing significant administrative burden and need to be improved

No opinion

More help is needed for the Member States in preparing reports including the development of common tools

I totally agree

We would welcome specific suggestions as to what we should look at during this Fitness Check of the environmental acquis in relation to monitoring and reporting. Please suggest any issues you wish.

 

If you have prepared a dedicated position paper or want to share any other related material with the Commission, please use the upload function.

 
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