Document 1Q5y8p0GYeb8zdGJbgq7qQwGm

Subject: Civil society organisations urge the Council of the European Union to strengthen EU water legislation to protect European waters and citizens from pesticide pollution Brussels, 19 March 2024 Dear Permanent Representative, With this letter, the undersigned civil society organisations express their deepest concerns about the current attempt to weaken the ambition of the European Commission's proposal amending the Water Framework Directive (WFD), the Groundwater Directive (GWD), and the Environmental Quality Standards Directive (EQSD). Setting new legislative standards to address water pollution is a critical step to protect European water resources and citizens' health and halt the biodiversity crisis. It is an opportunity we cannot afford to miss and we are calling upon you for your support in view of the upcoming discussions at the European Council. Over 20 years since the EU's main water legislation set environmental objectives - originally for 2015 - only one third of Europe's surface waters1 are in good chemical status. In 2020, levels of one or more pesticides exceeded the thresholds of concern in 22% of all surface water monitoring sites and 4-11% of groundwater2. Additionally, President Ursula von der Leyen's recent announcement to withdraw the Pesticide Reduction Law SUR and pause the Water Resilience initiative exacerbates the urgency to take action at other regulatory levels to address pesticide water pollution. One of the main pressures on aquatic environments is attributed to the use of pesticides and biocides that pose toxic effects on organisms3. A 2014 meta-analysis4 of water samples taken 1 European Environmental Agency, Report No 9/202 (2021), `Drivers and pressures arising from selected key water management challenges - A European overview'. 2 European Environmental Agency, Briefing (2023), `How pesticides impact human health and ecosystems in Europe'. 3 Helmholtz Zentrum fr Umweltforschung, UFZ (2013): Pestizide reduzieren die Artenvielfalt in Gewssern deutlich. Momentane Risikobewertung schtzt nicht ausreichend. Pressemitteilung vom 17. Juni 2013: http://www.ufz.de/index.php?de=35329 4 Malaj, E. et al. (2014). Organic chemicals jeopardize the health of freshwater ecosystems on the continental scale. Proceedings of the National Academy of Sciences of the United States of America 111(26): 9549-54. DOI:10.1073/pnas.1321082111 from 4,000 monitoring sites across Europe, showed that in 42% of the sites the water was contaminated with chemicals at levels that cause chronic toxicity to aquatic life. This pressure not only exerts harmful effects on aquatic biodiversity but also reduces the availability of water for safe drinking supply and other sustainable uses. Pesticide pollution must be addressed at the source and truly ambitious actions must be undertaken at all regulatory levels to monitor agricultural practices and address the impact of pesticides on aquatic environments. The WFD is a fundamental instrument which must not, under any circumstances, be weakened or underestimated. On the contrary, it urgently needs to be strengthened. In line with this urgency, in October 2022, the European Commission released a proposal updating the lists of priority substances for surface and groundwater along with their associated legal threshold values. The proposal adds a range of key water pollutants such as PFAS, pharmaceuticals, and additional pesticides. Civil society organisations welcomed the proposal and provided recommendations to strengthen it further. Later, in September 2023, the European Parliament adopted its position, agreeing to the newly proposed substances, while also strengthening the proposal. However, alarmingly, the draft compromise text prepared by the Spanish Presidency of the Council critically weakens the Commission's proposal, risking significantly lowering the level of protection of European waters. Specifically: 1. It suggests postponing the compliance dates for the newly added substances to 20395. 2. With regard to pesticides, it recommends: - The deletion of the newly proposed `total pesticide' (and metabolites) threshold of 0.5 g/L in surface waters6. - The replacement of the new generic thresholds for individual and total non-relevant metabolites of pesticides (nrMs) in groundwater with a list of nrMs that the Commission should develop, thus further delaying the monitoring of these potentially harmful substances and opposing the WFD approach, which enables substances to be assessed regionally in light of their regional relevance7. Given the dangerously increasing water scarcity and urgency to protect European waters against pesticide pollution, we respectfully request that you adopt a strong proposal. This should consist of an ambitious timeline for urgent action that includes strict thresholds for `total pesticides' (and metabolites) for surface waters as well as for `individual' and `total' non-relevant metabolites for groundwaters. Furthermore, we ask to increase the current level of ambition in protecting the health and the environment of EU citizens and protecting aquatic biodiversity and ecosystems. 5 See Article 4(2), a new point (d), page 31 of the draft compromise text. 6 See Annex V, row 70, page 90 of the draft compromise text. 7 See I, row 7, pages 73-75 of the draft compromise text Thank you in advance for your consideration in this important matter. Yours sincerely, On behalf of the signatories, Angeliki Lysimachou Head of Science and Policy PAN Europe On behalf of the organisations: Agroecology Europe Bond Beter Leefmilieu Bndnis fr eine enkeltaugliche Landwirtschaft e.V. Child Rights International Network (CRIN) Coordination Gegen BAYER-Gefahren Eco Hvar ECOCITY Ecologistas en Accin Friends of the Irish Environment Gnrations Futures Hogar sin Txicos IAWR - International Association of Waterworks in the Rhine Basin ISDE Italy ( International Society of Doctors for Environment) Justice Pesticides Mouvement Ecologique asbl, FoE Luxembourg Nature & Progrs Pesticide Action Network Netherlands Pestizid Aktions-Netzwerk e.V., PAN Germany Quercus - Associao Nacional de Conservao da Natureza SAFE Safe Food Advocacy Europe A.S.B.L. Sane Society Movement Via Pontica Foundation Voedsel Anders Vlaanderen Women Engage for a Common Future (WECF) ZERO - Association for the Sustainability of the Earth System