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The Water Framework Directive and Groundwater in the UK

This Groundwater Forum meeting was held in Solihull, Birmingham on 21 March 2002. Over 100 people attended the meeting, drawn from the regulators, the water industry, consultancies and academia. The presentations were given by some of those who have been involved in the development and implementation of the Water Framework Directive in the UK, giving attendees the chance to hear directly about the current state of the Directive and plans for its future implementation. A lively discussion of a wide variety of issues took place following the presentations. The information on this page is intended to summarise what took place at the meeting.

The meeting programme is given below, with a summary of each of the presentations (plus the presenter's slides in some cases nb. you will need to have PowerPoint to see the slides) followed by a bulleted summary of the general discussion at the end of the presentation sessions.

The Water Framework Directive and Groundwater - Peter Pollard, Scottish Environment Protection Agency
Terminology and concepts: groundwater bodies and river basins - Steve Fletcher, Environment Agency
Definition and characterisation of groundwater bodies - Dave Allen, British Geological Survey
Groundwater Quality and the Groundwater Daughter Directive - work in progress - Tony Marsland, Environment Agency
Monitoring requirements for groundwater under the Water Framework Directive - Rob Ward, Environment Agency
Scientific challenges for the implementation of the Water Framework Directive (with a bit on training) - John Tellam, University of Birmingham
The Water Framework Directive and Groundwater – the water industry perspective - Jacob Tompkins, Water UK
Discussion following presentation sessions
Summary

The Water Framework Directive and Groundwater

Peter Pollard, SEPA

Peter Pollard provided an overview of the Water Framework Directive as it pertains to groundwater. The slides from the presentation can be seen or downloaded from here (454Kb). Peter started off by stating that, although complex, the Directive is based on straightforward principles, and introduced the following points:

the important dates by which the Directive will be implemented
the concepts involved in River Basin Management Plans
the concepts involved in groundwater bodies
groundwater status objectives: quantitative and qualitative (including the Groundwater Daughter Directive)
Surface receptors and chemical status: surface water objectives (including ecological status classes); significant diminuation in chemical or ecological quality, or significant damage to terrestrial ecosystems); intrusions
objective setting: protected area objectives, trend reversal objectives and prevent or limit inputs objectives.

Terminology and concepts: groundwater bodies and river basin

Steve Fletcher, Environment Agency

Steve Fletcher presented a view of the nature of the parts of the Directive dealing with groundwater bodies and river basins, starting off with the statement that we should ‘work out what’s in the spirit of the Directive and what we are trying to achieve’. The slides from the presentation can be seen or downloaded from here (3,293Kb). Steve covered the following points:

the different treatment of definitions of water quantity/resources from water quality under the Directive
definitions of groundwater, surface water and drinking water bodies, and how they are important under the Directive
how to define groundwater bodies: conceptual modelling, setting boundaries and sub-dividing
requirements for initial and further characterisation

Definition and characterisation of groundwater bodies

Dave Allen, British Geological Survey

Dave Allen described some of the work of an ongoing project by the Environment Agency and the British Geological Survey that aims to develop procedures for characterising groundwater bodies. The slides from the presentation can be seen or downloaded from here (298 Kb). Dave covered the following points:

groundwater bodies form the principal management units under the Directive. They should be hydraulically continuous entities, and must be defined on the basis of flow or abstraction, and are inextricably linked to surface water bodies. Only rock units from which there is very low or no abstraction and which affect no surface water bodies will be exempt
a methodology for characterising groundwater bodies is being developed, designed to fit with other parts of the Directive, which will be trialled in real catchments. This is an iterative process, based on developing conceptual models of groundwater bodies using existing data only during initial characterisation and refining them if necessary during further characterisation
based on this groundwater body status and an analysis of pressures from anthropogenic activities, ‘At Risk’ assessments will be made of those groundwater bodies which may fail to achieve good status

Groundwater Quality and the Groundwater Daughter Directive – work in progress

Tony Marsland – Environment Agency

Tony Marsland presented a view of the current standing of the Groundwater Daughter Directive, which covers specific measures to prevent and control groundwater pollution, and will eventually replace the existing Groundwater Directive, although the scope of the Daughter Directive is greater. Tony covered the following points:

the groundwater objectives: e.g. prevent or limit pollutant input to groundwater and prevent deterioration of status of all groundwater bodies; protect, enhance and restore groundwater bodies
definitions of good status: e.g. no saline or other intrusions; concentrations not exceeding quality standards in other relevant legislation and not so high as to cause failure of surface water, terrestrial and abstraction objectives
background to the Expert Advisory Forum and Technical Discussion groups working at EC level to complete the Daughter Directive by autumn 2002, so that it can be put in place by December 2002
key issues include:

the integration of surface water and groundwater objectives
a potential new ‘high chemical status’ to protect pristine groundwaters
what exactly is a pollutant?
benchmarks for good status
three types of standards: for status definition; for remediation; and for prevent or limit (release of pollutants to groundwater)
the role(s) of monitoring data

There is a wide spectrum of approaches to groundwater standards that is currently being narrowed down. Hopefully the Daughter Directive will allow flexibility in implementation: the current efforts in providing technical support to DEFRA are having a major influence

Monitoring requirements for groundwater under the Water Framework Directive

Rob Ward, Environment Agency

Rob Ward introduced the overarching objectives of monitoring to meet the requirements of the Water Framework Directive. The slides from the presentation can be seen or downloaded from here (259Kb). Rob covered the following points:

groundwater monitoring programmes must be in place by December 2006 to provide a reliable assessment of groundwater quantitative and chemical status and assess any pollutant trends in all groundwater bodies
a risk-based approach will be taken, and monitoring must be consistent with other statutory and environmental needs
quantitative status: groundwater level is the key parameter. Need sufficient density of monitoring points in each groundwater body to fully assess groundwater levels, and additionally in each ‘At Risk’ groundwater body to assess risk. Need sufficient frequency to assess status in all groundwater bodies, and additionally in ‘At Risk’ bodies to assess impacts
chemical status: needed at 2 levels: surveillance (to supplement groundwater body characterisation), operational (in ‘At Risk’ bodies to assess long-term anthropogenically-induced trends. Need data representative of the whole of each groundwater body/group of bodies. Chemical status will be interpreted by aggregating mean values for each groundwater body as a whole
CAMS is providing the framework for monitoring under the Directive
Supporting initiatives are being carried out at Europe level (the Common Implementation Strategy) and by the EA (the Groundwater Monitoring Strategy)
the determinands to be monitored during surveillance and operational monitoring have not been finalised
a partnership approach is needed to deliver effective monitoring and the required outputs

Scientific challenges for the implementation of the Water Framework Directive (with a bit on training)

John Tellam, University of Birmingham

The slides from John Tellam’s presentation can be seen or downloaded from here (936Kb). John started off by stating a view shared by BGS that the Directive doesn’t throw up any new knowledge requirements, but does highlight existing knowledge gaps and related problems and opportunities, including:

we currently know ‘something about everything’ in hydrogeology, but in some areas we know very little
without a basic understanding of issues such as heterogeneity and scales of heterogeneity; 4 dimensional flow, velocity and chemical processes; and ecosystem/groundwater flow/chemical relationships, a proper understanding of groundwater and groundwater bodies is impossible
too much of current research is geared towards short-term results, funded by the regulators and industry, while long-term basic research on the main issues is largely untargeted, largely because it brings limited immediate benefits
each aquifer/groundwater body is unique and it is difficult to transfer research results from one to another there seems to be a growing shortage of suitably qualified and experienced groundwater professionals, coupled with an increasing workload

The Water Framework Directive and Groundwater – the water industry perspective

Jacob Tompkins, Water UK

Jacob Tompkins summarised the outlook and concerns of the water industry, including the following points:

although the UK is less reliant on groundwater than some other EU Member States, there is still a high reliance on groundwater and it is correspondingly of fundamental importance to the water industry
all stakeholders should be involved in the Directive’s implementation, including farmers, local councils and planners (e.g. in housing development) as well as the water suppliers and regulators. ‘Joined up thinking’ is needed for effective water management
all groundwater must be protected, not just drinking water, although water companies currently have no statutory duty relating to raw water quality
the water industry may play a large part in meeting the objectives of the Directive, but has specific concerns, e.g.:

1. need to know baseline quality for effective restoration
2. the lack of groundwater data may lead to overuse of the precautionary principle, impacting on abstraction
3. a national groundwater database is needed
4. licence requirements, including for monitoring, are not coordinated
5. use of data from water companies and other abstractors is difficult because of confidentiality
6.water industry monitoring does not currently include routine measurement of standard parameters, and current sampling frequencies may not meet Directive requirements
7. there are cost, operational, health and safety and quality control implications to sampling

protocols for cooperation in monitoring and sharing data are being developed. Most water companies are interesting in sharing data with the regulators, but need to deal with the concerns listed above
in conclusion, the water industry perspective is that:

1. qualitative and quantitative aspects must be considered together
2.need definition of responsibilities in order to meet objectives
3. need to move away from end-of-pipe solutions
4. may need changes in government policy to allow for a changing water industry role

Discussion following presentation sessions

The issues raised by the speakers generated much discussion among the participants. The main areas of discussion are summarised below.

What does the Water Framework Directive say about surface waters affecting groundwater status, e.g. poor quality losing streams or sewage discharges recharging groundwater?

The Water Framework Directive does not currently define groundwater as a receptor but in terms of its impact on surface water and terrestrial ecosystems. If groundwater quality doesn’t impact on these, groundwater status is not affected.
Poor groundwater quality caused by surface water intrusion may affect Drinking Water regulations but these are not linked to groundwater status?
There is some pressure to define groundwater a receptor as well.

Regarding the precautionary approach to characterising groundwater bodies: could measures will be implemented to constrain groundwater abstraction because a lack of data means groundwater bodies can be characterised as ‘At Risk’ when they may not be? Could there be another category, e.g. ‘Not Proven’?

In cases where lack of data restricts characterisation, these groundwater bodies will be subject to further characterisation, which requires data collection.
The ‘At Risk’ category is mandatory under the Water Framework Directive, but there are compensations in that improvement efforts are focused on bodies defined as ‘At Risk’.
In practice there is enough data for basic characterisation in most areas, even in parts of Wales and Scotland where groundwater is not a major supply.
Ensuring there is enough data is therefore a management priority.

It seems that we need the right type of data as well as the right amount – requirements seem to be for detailed data.

There needs to be a tiered approach: during initial characterisation, hydrogeologists can make use of ‘educated guesses’/expert assessments. If these are felt to be insufficient in certain areas, those areas should be subject to further characterisation.
Rigorous numerical groundwater modelling can be used to test conceptual models where there is enough data.

What does the Water Framework Directive say about totally confined aquifers from the surface water aspect?

Most confined aquifers have an outcrop area and the related groundwater body would probably extend from the outcrop area to the furthest extent of the aquifer. Surface water bodies may be related where they run across outcrop or discharge points of the confined aquifer.
If there is no outcrop area (e.g. London Basin?), no abstraction or plans for abstraction and it doesn’t affect surface water, a confined aquifer may not be covered by the Water Framework Directive. In this case does the aquifer need to be managed?
There is no requirement to delineate a groundwater body if groundwater is not used and does not affect surface water, unless there is a pressure on the groundwater (e.g. ASR). Assessments must be done on a sound hydraulic basis & must also be renewed every 6 years, allowing new pressures to be identified.

What about ASR? Does it count as injecting ‘pollution’ (water of different quality) to a confined aquifer?

Any aquifer used for ASR would have to be classified as a groundwater body.
The ‘prevent or limit’ measures expressly forbid the injection of pollution to a confined aquifer. The position of ASR may remain unclear?

The current Groundwater Directive doesn’t define what ‘prevent’ means. Will the Groundwater Daughter Directive define it?

For priority hazard substances, ‘prevent’ is defined as eliminating discharge at eh surface; for other priority substances it is defined as reducing discharge to ‘very small values’. There is some flexibility so that very small discharges need not be dealt with if they are judged not to have a negative impact.

How does the UK compare to other EU states in terms of implementation measures? – are we taking a ‘Rolls Royce’ approach?

Not in terms of groundwater quality: e.g. one approach is to apply 75 % of Drinking Water standards across the boards, which is not being advocated in the UK. Efforts are being made to ensure local flexibility and if possible, fit in with existing measures – e.g. ‘prevent and limit’ measures generally fit with existing Groundwater Directive.
Not clear how measures for groundwater quantity compare with other EU member states.
There is a common implementation policy with working groups spanning member states trying to ensure consistency, e.g. in defining groundwater bodies.

How might the Water Framework Directive allow increased opportunities to get necessary things done?

The explicit relationship between surface water and groundwater is a step forward and should be taken advantage of.
There are concerns over what exactly the Water Framework Directive is trying to do: e.g. it doesn’t allow for protection of specific wetlands, but for preventing overall chronic fall in groundwater levels. There is a perception that the Water Framework Directive has a greater scope than it actually does, particularly on the quantity side. It actually needs careful interpretation to achieve the necessary aims.

What about the possible definition of a ‘High Chemical Status’ category: is the aim of this to improve all groundwater bodies to high status (e.g. in Germany & Austria)?

High status isn’t intended to become a restoration target, even by those pushing for its existence.
The name is a misnomer as it is really about protecting existing pristine groundwaters, which currently exceed Drinking Water standards, by creating protected areas. A ‘high status’ category will need to be qualified by lots of exemptions.
Perhaps it should be termed a ‘standard’ not ‘status’.
Taken in conjunction with ‘prevent and limit’ measures, high status should provide a vehicle to prevent all defined groundwater bodies deteriorating to their lowest possible quality limits.

Regarding quality monitoring, the basic chemical parameters specified by the Water Framework Directive are too few even for surveillance monitoring.

Monitoring needs are going to have to be driven by working requirements and not by the minimum requirements of the Directive.

Where new data are required, will the Environment Agency look to drill new boreholes for monitoring or look to water companies?

There will need to be cooperation to ensure more effective monitoring and good data transfer, driven by needs on all sides.

Regarding the direction of research, this should be driven by actual needs, which are largely defined by legislative agendas.

This can address immediate needs but there is a danger that long term needs are missed out – i.e. we should be addressing the ‘spirit’ rather than the letter of legislation.
‘Short term’ research can address basic needs too but need to be better disseminated, e.g. commercial-scale projects on contaminated sites, which largely go unreported in the literature.
There also needs to be more overlap between hydrogeology, hydrology and ecology, which may only be addressed by ‘longer term’, strategic research – e.g. LOCAR, which is trying to achieve more interdisciplinary research.

Private abstractors represent c. 80 % of total licences (not volume of abstraction) – shouldn’t they be included in monitoring; e.g. a requirement to collect data?

The EA are considering other data sources, although currently any agreements are voluntary. There may be problems in terms of who has responsibility for monitoring.

Are groundwater bodies going to be very large? If they are subdivided, there are difficulties in using groundwater divides and flowlines to do this.

The original premise is to be able to do a water balance across the whole groundwater body. If it is too large to be manageable, it must be divided somehow. Flowlines have drawbacks but also advantages, and are accurate enough for purpose in most cases. The Water Framework Directive only asks for an average water balance: anything more than this would have to be done as and when required by the competent body for its own management purposes or interest.
There is an on-going debate between chemical and quantitative criteria and the size of groundwater bodies. The desired result of groundwater bodies is that they allow proper groundwater management: i.e. present a realistic picture of groundwater resources in the UK.
From the quality POV, the sensible approach is to start with as large a groundwater body as possible and only subdivide if required by practical factors.
Groundwater bodies aren’t fixed permanently – they can be changed if required, e.g. if they’re not sensible management units.
In Ireland there are likely to be 300-400 groundwater bodies, but as work starts in the next year the actual number required should become more obvious.

Is there an overemphasis on monitoring at the expense of managing groundwater? There has been little emphasis at European level on characterising groundwater bodies, risk based assessment, etc, than on monitoring strategies. Characterisation should continue past 2004 if needed, not just monitoring.

Up to now European meetings on characterisation have looked just at surface water but there will be a sub-group for groundwater. The EC will be issuing guidance on delineating groundwater bodies.
Monitoring is in the Water Framework Directive to support its implementation but it shouldn’t drive the Directive. It provides a good opportunity to get new data, but care should be taken to ensure this is good data.

If rock units providing even very small abstractions (a single supply point of >= 10 m3/day or a total supply of >= 100 m3/day) must be classified as groundwater bodies, does the Oxford Clay, etc, count?

Yes, but most attention can be focussed on the most important aquifers.
This will probably raise lots of local environmental and other issues by providing a base to address ‘nimby’-type issues, and could therefore divert resources away from more important things.

Who is coordinating all Water Framework Directive river basin areas, for surface water, groundwater, flooding, etc?

There is a hierarchy of groups and subgroups stemming from government that span the UK and the issues. The existing planning systems (CAMS, Shoreline action plans, etc) all have to be integrated too in order to make the Water Framework Directive effective, while maintaining their strengths and functionality.

Are environmental objectives being set based on ‘natural’ or engineered environments?

The thrust of the Water Framework Directive is to reduce anthropogenic effects, so in principle natural environments should form the basis for objectives.
It’s often difficult to tell the difference between natural and engineered environments except in obvious cases of pollution.
CAMS developed a methodology to decide how much river flow is needed to maintain ecological requirements, to naturalise river flows by taking out abstraction, and to determine how over-abstracted the river is. This fits with the Water Framework Directive and is part of the sustainability framework.
We also need to recognise natural ranges in flow regimes.
Surface water classifications are based on a range of conditions starting from (semi) natural reference states. Current projects are looking at reference states/conditions in fresh waters and estuaries and coming up with criteria.

The Water Framework Directive specifically allows for heavily modified surface water bodies: what about modified groundwater bodies, especially where they have no ecological impact? We need to be practical about getting rid of waste.

Eureau have a working group on this issue especially looking at implications for recharge and ASR and how the Water Framework Directive will impact on these. It should be possible to inject water of an equal or better quality than resident groundwater. Currently, EU member states have very different interpretations of terminology e.g. relating to abstraction under cities or injection of brines from reverse osmosis.
There are clauses in the Directive allowing ASR with conditions. Need to ensure that these conditions are flexible.

Summary

The Water Framework Directive exists in the context of the planning framework that empowers regulators to achieve environmental objectives in a context of published plans, open discussion and set timetables.
There is still a lot of detail to come out in the process of interpreting the Water Framework Directive and finalising implementation measures. The exact responsibilities of different agencies are still to be worked out.
It is clear in the context of past UK and other European experiences that there must be flexibility in standards and implementation measures so that they are locally relevant.
The current process is not a one-off: the Water Framework Directive will be implemented over a long time scale and is an iterative process, so there will be ongoing refinement.
Implementation of the Directive should mean greater focus on outcomes, better data and improved cooperation between regulators and abstractors. Related benefits include the fact that a new institutional framework in Scotland and other EU member states is being built around Water Framework Directive drivers, so that planning officials are becoming more aware of groundwater-environmental interactions.

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