All feedback sent to the European Commission will be summarized and presented to the European Parliament and Council, with the aim of feeding into the legislative debate.
The coordination of water, agriculture and energy policies has so far been very weakly implemented at European and national level, thus preventing a return to a good ecological status of water bodies, while aggravating conflicts of use. This failure of policies coordination is attributable to the predominant influence of business lobbies within European and national institutions.
After the Blueprint to safeguard Europe’s water resources, the fitness check of the WFD and associated directives will look at the «effectiveness, efficiency, coherence» of these directives, especially regarding policies coordination, as part of the WFD review. This is the right step but what does the European Commission intend to do to prevent business lobbies sabotaging the whole process to their unique advantage as they have always done so far? We have examples of this when transposing these directives in almost all Member States. We are particularly concerned when we see that a «quantitative assessment of actual costs and benefits including impacts on business» with a «regulatory simplification and burden reduction» is put forward. Business lobbies are in favor of a regulatory simplification because they hope that it will allow them to more easily circumvent a certain number of constraints including environmental ones.
The debate about water at European level has completely changed in the recent years as a result of the European Citizen’s Initiative on the right to water and massive movilisations all around the continent to stand for public water management. European citizens have shown that they have a lot to say about water. Therefore, public participation for the fitness check of the directives needs to go beyond the usual Brussels-based stakeholder meetings.
The evaluation roadmap should be more inclusive and accessible. The following aspects should be taken into account:
1/ «Online public consultation» should be better publicised than usual, given the importance of the topic, and ensure the visibility of the call for contributions to a broad spectrum of actors. In the same line, questions should include a broad range of aspects, including political and implementation oriented issues, while up to now questions were very technical and oriented at a specialised target audience. In order to allow new actors to get involved, relevant documentation needs to be available in a suitable format to be properly understood and analysed before the consultation.
2/ «European Water Conference» should include specific sessions/workshops for NGOs and citizens to present concrete case studies and field experience on WFD implementation.
3/ The roadmap needs to ensure throughout transparency and a full detailed list of «specific stakeholder meetings» (held + foreseen) is imperative for sound participation. it is crucial for all citizens to fully access all information and to evaluate the possibility to participate directly. The roadmap brief invites stakeholders to request the organization of specific meetings; the conditions and opportunities should be stated clearly. Moreover, the huge amount of information to be analysed for this evaluation makes virtually impossible the process of selection and prioritization of issues at stake. A way forward in this sense would be to actively engage EU citizens in the evaluation, including by a broad data compilation effort from citizens directly. This would allow to overcome barriers related to monitoring and control by Member States, therefore allowing citizens to complement the official evaluation process with crucial information.
4/ Given each country specific conditions, such as the transposition of the directives, it would be important to have country-specific fora where WFD implementation can be assessed and the evaluation process improved and complemented with citizens direct experience. This would reduce the lack of data on the implementation process, its effectivity and water governance praxis.
Feedback submitted on November 14, 2017.