DISPROPORTIONATE COSTS IN PRACTICE

DISPROPORTIONATE COSTS DISPROPORTIONATE COSTS IN PRACTICEIN PRACTICE

Case study considering a potential derogation

Inspired froma real case study in the Rhin-Meuse district (F)

Some elements were picked from "Economic assessment of groundwater protection. Groundwater restoration in the potash mining fields of Alsace,

France",BRGM 2003

http://agire.brgm.fr/eco_EU.htm

Derogation

Need to assess the disproportion of costs of required

measures

Formal definitions in the directiveart. 4.4: deadline extension for two 6 years periods

art. 4.5: less stringent objective to be reviewed every 6 years

Derogation may apply only in limited caseswhen it is impossible to achieve GES by 2015 for justified technical, environmental or economic reasons

and provided that no further deterioration occurs

and when the derogation is justified on a transparent basis

WHAT DEROGATIONS UNDER WFD?

2/10

Derogation

FLOW CHART OF THE PROCEDURE FOR THE JUSTIFICATION OF

DEROGATIONIdentification of key pressures

causing the potential gap in 2015 and design of potential

supplementary measures

Cost-benefit analysis of potential supplementary

measures

Is the cost of the supplementary measures

disproportionate?

no

Reach the goal in 2015

yes

Does it remain disproportionate if

the implementation of

measures is phased out?

The goal can be reached in 2021 or

2027

The goal can't be reached by 2027

no

yes

A lower objective may be defined according to art. 4.5Redefine the programme of

measures

Main steps

Economic analysisGoal

3/10

Derogation

DEROGATION IN PRACTICE

Sourc

e:

Min

istr

y o

f th

e e

nvir

onm

ent,

Québ

ec,

Canad

a

4/10

Derogation

DESCRIPTION OF THE SITUATION

10-15% of the salt

withdrawn every

yearProspectivemodel shows that the impact of the

measures is not sufficient to reach the goal by 2015 (after 2027)

supplementary measures are needed

salt <250mg/l

in all the

aquifer

5/10

polluted zone

salt tips

limit of the aquifer

Description of the site aquifer intensely polluted by mining

activity: huge waste deposits of salt efficient measures already implemented:

geo-membrane on some dumps, artificial dissolution of waste with high concentration of salt ...

Aquifer

Source: BRGM & Agence de l'eau Rhin-Meuse

Derogation

SUPPLEMENTARY MEASURES AND THEIR EFFECTIVENESS

Measure 1 Measure 2 Measure 3

Complete removal ofsalt tips

Construction of lines ofpumping wellsdownstream the highlypolluted areas

Construction of lines ofpumping wellsi-downstream the

highly polluted areasii-in the centre of the

pollution plume

Effectiveness

?

Restoredsurface

(ha)

Surfaceremaining torestore (ha)

Effectiveness(% )

Businessas usual

2 600 2 200 54

Measure 1 2 800 2 000 58

Measure 2 4 520 280 94

Measure 3 4 779 21 99,5

in

2015

Ineffectiv

e

Maybe

further

investigated

if necessary

6/10

Derogation

COST-BENEFIT ANALYSIS

Define scale of assessment

Who will be affected? To what extent? Directly or not?...

Identify types of costs and benefits

Quantitative, qualitative or monetary? Present and/or future? Which appear significant?...

Choose methodologyIs it necessary to apply different methods? What resources are available for original research?...

Collect data Do we need first hand data? Can we rely on other resources?...

Assess costs and benefits

Are impacts important and properly weighted? How can different types of impacts can be presented in a way that facilitates decision-making?...

7/10

Derogation

COST-BENEFIT ANALYSISIDENTIFICATION OF COSTS AND

BENEFITS Types of costs

Agriculture - corrosion damages to irrigation equipment- potential impact on quality of soil investments, operating and maintenance costs damages

Public watersupply

- mitigation of water salinity: dilution, treatments, alternative resources… investments, operating and maintenance costs

Agriculture - avoided damages. E.g. renewal of corroded pipes and pumps- more valuable crops possible. E.g. tobacco potential future benefit

Public watersupply

- no need for more mitigation measures- pure water potentially available in the future potential future benefit

Industry - pure water available for specific activity (electronics…) potential future benefit

Types of benefits

TD OD

8/10

Derogation

COST BENEFIT ANALYSISEstimated costs (M€)

Construction of the wells 9

Operation of the wells 8,9

Connection of wells (11km) 2,5

Doubling of the canal for salmons 3

Damages to wetlands not assessed

Total estimated costs (M€) 23,4

Estimated benefits (M€)

For direct users

Agriculture : avoided damages to equipment, soiland crops due to salinisation

3,1

Public water supply : no further treatment needed,no need to investigate for alternative resources

13,9

For potential future uses

The aquifer is free of nitrates and pesticides: it maygenerate benefits in the future once desalinated

6,6

Total estimated benefits (M€) 23,6

NET COST (M€) -0,2Estimated

potential benefits

equal costs

A9/10

Derogation

TARGET:

reach the goal

in 2015

COST BENEFIT ANALYSIS

Estimated costs (M€) Measure 3

Construction of the wells 16,8




Damages to wetlands not assessed



For direct users

Agriculture : avoided damages to equipment,soil and crops due to salinisation

3,1

Public water supply : no further treatment, nomore investigation for alternative resources

13,9


Aquifer free of nitrates and pesticides: it maygenerate future benefits once desalinated

6,6


NET COST (M€) 11,8

B9/12

Derogation

Simulation for

2021


Estimated costs (M€) Measure 2 Measure 3

Construction of the wells 8,4 16,8

Operation of the wells 9,2 15,1

Connection of wells (11km) 2,5 2,5

Doubling of the canal for salmons 3 3

Damages to wetlands not assessed not assessed

Total estimated costs (M€) 23,1 37,4


For direct users

Agriculture : avoided damages to equipment,soil and crops due to salinisation

1,5 1,5


7 7



3,3 3,3

Total estimated benefits (M€) 11,8 11,8

NET COST (M€) 11,3 25,6

B11/12

Derogation

TARGET

reach the goal

in 2015


Estimated costs (M€) Measure 3

Construction of the wells 16,8




Damages to wetlands 1,1



For direct users

Agriculture : avoided damages to equipment, soiland crops due to salinisation

3,1

Public water supply : no further treatment needed,no need to investigate for alternative resources

13,9


The aquifer is free of nitrates and pesticides: it maygenerate benefits in the future once desalinated

6,6


NET COST (M€) 13,9

C9/12

Derogation

Simulation

s

2021-2027


Measure 2 Measure 3Estimated costs (M€)

2021 2027 2021 2027

Construction of the wells 11,4 11,4 16,8 16,8

Operation of the wells 9,6 12 15,1 18,9

Connection of wells (11km) 3,5 3,5 3,5 3,5

Doubling of the canal for salmons 4 4 4 4

Damages to wetlands 1,1 1,1 1,1 1,1

Total estimated costs (M€) 29,6 32 40,5 44,3


For direct users

Agriculture : avoided damages toequipment, soil and crops due to salinisation

1,5 0,9 1,5 0,9


7 5,4 7 5,4



3,3 3,3 3,3 3,3

Total estimated benefits (M€) 11,8 9,6 11,8 9,6

NET COST (M€) 17,8 22,4 28,7 34,7

C11/12

Derogation

GO FURTHER

Article 4.4 - Time derogation Article 4.5 - Less stringent objective Effectiveness of the potential alternative

measures aimed at reducing aquifer pollution

Derogation

Derogation

DEROGATIONS IN WFDEXTENSION OF DEADLINE - Art. 4.4

The deadlines (…) may be extended for the purposes of phased achievement of the objectives for bodies of water, provided that no further deterioration occurs in the status of the affected body of water when all of the following conditions are met:

(a)Member States determine that all necessary improvements in the status of bodies of water cannot reasonably be achieved within the timescales (…) for at least one of the following reasons:

(i) the scale of improvements required can only be achieved in phases exceeding the timescale, for reasons of technical feasibility;

(ii) completing the improvements within the timescale would be disproportionately expensive;

(iii) natural conditions do not allow timely improvement in the status of the body of water.

(b)Extension of the deadline, and the reasons for it, are specifically set out and explained in the river basin management plan (…).

(c)Extensions shall be limited to a maximum of two further updates of the river basin management plan except in cases where the natural conditions are such that the objectives cannot be achieved within this period.

(d)A summary of the measures (…) which are envisaged as necessary to bring the bodies of water progressively to the required status by the extended deadline, the reasons for any significant delay in making these measures operational, and the expected timetable for their implementation are set out in the river basin management plan. A review of the implementation of these measures and a summary of any additional measures shall be included in updates of the river basin management plan.

Derogation

Derogation

DEROGATIONS IN WFDLESS STRINGENT OBJECTIVE - Art. 4.5

Member States may aim to achieve less stringent environmental objectives than those required (…) for specific bodies of water when they are so affected by human activity, as determined in accordance with Article 5(1), or their natural condition is such that the achievement of these objectives would be infeasible or disproportionately expensive, and all the following conditions are met:

(a)the environmental and socio-economic needs served by such human activity cannot be achieved by other means, which are a significantly better environmental option not entailing disproportionate costs;

(b)Member States ensure, - for surface water, the highest ecological and chemical status

possible is achieved, given impacts that could not reasonably have been avoided due to the nature of the human activity or pollution,

- for groundwater, the least possible changes to good groundwater status, given impacts that could not reasonably have been avoided due to the nature of the human activity or pollution;

(c)no further deterioration occurs in the status of the affected body of water;

(d)the establishment of less stringent environmental objectives, and the reasons for it, are specifically mentioned in the river basin management plan (…) and those objectives are reviewed every six years.Derogatio

n

Derogation

EFFECTIVENESS OF THE MEASURES

0

5

10

15

20

25

2015 2021 2027

Quantity of salt remainingvs. initial stock (%)

0

5

10

15

20

25

2015 2021 2027

Surface with more than 250mg/l salt (km²)

Measure 1Measure 2Measure 3

17/10

Derogation

Source: BRGM & Agence de l'eau Rhin-Meuse

DISPROPORTIONATE COSTS IN PRACTICE

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