Miljø- og Fødevareudvalget 2017-18
MOF Alm.del Bilag 35
Offentligt
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The Panel’s respons to the stakeholders’ comments and questions to the Scientific Documentation Report
Organization
Stakeholder
Bæredygtigt Landbrug
Ch/ sect
Comments
Question
Does the reviewing group agree that "N
limitation" means that the ecosystem receives too
much P (from wastewater, run off and sediment) -
not that nitrogen must be controlled?
Overall Consideration of the N:P ratio, cf.
Comments/questions from the
organization
N:P interactions, cf. Comments/questions
from the organization
N and P in marine environment
Response to question and comments
The panel discusses possibilities of controlling N and P
jointly in Chapter 5. In particular, it recommends
studying innovative ways of reducing agricultural P
input
N:P ratios are important to watch. The panel has
commented on this in Chapter 5. Current N:P ratio of
loads is not very different from historic values (it was
much more deviant in the 1980s). The panel discusses
possibilities to act on N and P simultaneously, and
recommends further study on this
See above
See above
Efforts to reduce P have already had significant results
during the implementation of the UWWT directive and
phosphate free detergents (EEA, 2015
https://www.eea.europa.eu/data-and-
maps/indicators/nutrients-in-freshwater/nutrients-in-
freshwater-assessment-published-6). See also Conley,
D.J., Paerl, H.W., Howarth, R.W., Boesch, D.F.,
Seitzinger, S.P., Havens, K.E., Lancelot, C. and Likens,
G.E., 2009. Controlling eutrophication: nitrogen and
phosphorus. Science, 323(5917), pp.1014-1015.
Large reductions of P input from urban sources have
already been implemented. In general the data do
support the thesis that further reduction of
eutrophication can be reached by reducing diffuse
loads, in particular of Nitrogen. See also Ch. 5
Efforts in Denmark with respect to WFD do not lag
behind the efforts in other countries
General
Bæredygtigt Landbrug
General
How is the comment taken into account?
Bæredygtigt Landbrug
Bæredygtigt Landbrug
General
General
How is the comment taken into account?
How is the comment taken into account?
Bæredygtigt Landbrug
General
Phosphorus in waste water creates
problems, cf. Comments/questions from
the organization
How is the comment taken into account?
Bæredygtigt Landbrug
General
Conclusion on general comments, cf.
Comments/questions from the
organization
The work with the models started late in
the process. The WFD was signed in 2000.
This first Danish plan covered the period
from 2010-2015
How is the comment taken into account?
Dansk
Sportsfiskerforbund
General
How is the comment taken into account?
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Dansk
Sportsfiskerforbund
General
Do you find that the Danish surveillance is
sufficient and is this data good enough to support
the models?
The panel comments on monitoring in several chapters
Dansk
Sportsfiskerforbund
Dansk
Sportsfiskerforbund
General
Do you find that there had been the necessary
finance and time for the development of the
models?
Is there the necessary continuity in the model
work?
The EU Water Framework Directive (WFD)
prescribes all water bodies to attain “good
ecological status”. In Denmark, River Basin
Management Plans (RBMP) are developed How is the comment taken into account?
to ensure that this goal is achieved., cf.
comments/questions from the
organization
General
The panel has no full overview of time and resources,
and is only given the final output as a basis for the
evaluation. Consequently, the panel will not comment
on this question
The panel has not seen reasons to question the
continuity in the model work
Landbrug & Fødevarer
General
See Chapter 2.1
Landbrug & Fødevarer
General
Landbrug & Fødevarer
General
All calculations of uncertainty are based
on the final results concerning required
nitrogen load reductions. It is shown that
the available data are insufficient for
determination of the maximum
confidence interval, cf.
comments/questions from the
organization
The Scientific Documentation Report clearly builds on
the scientific literature. Methods used are also based
Should eco-system models supporting RBMP build
on published literature. The current review, both by
on scientific documentation, i.e. peer-reviewed
stakeholders and by the review panel, is a more
articles?
thorough peer review than the usual procedure used by
journals.
The panel is strongly encouraged to request
additional information regarding peer-reviewed
See above
articles describing the modeling approach from
both DHI and AU.
Landbrug & Fødevarer
General
How is the comment taken into account?
The panel recommends on this in Chapters 6 and 8
Landbrug & Fødevarer
General
No attempt is made to quantify the uncertainties The panel recommends on this in Chapters 6 and 8. We
arising from model input and through modeling
note that a full formal uncertainty analysis is not
procedures, using both mechanistic and statistical possible for the very complicated calculations needed
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approaches.
Does the panel agree that a solid assessment of
uncertainties of the models is missing?
to estimate MAI. Researchers, stakeholders and
authorities will have to accept the existence of
uncertainty, and continue to properly monitor the
systems' response to measures with the aim of
adjusting the measures where and when needed.
The panel are not legal experts so cannot respond
adequately to this question
The panel members do not speak or read Danish
therefore are not qualified to comment on alleged
mistranslation.
This question has legal implications and the panel are
not legal experts so cannot respond adequately to this
question
Bæredygtigt Landbrug
2
Bæredygtigt Landbrug
2
Legal comments on the International
Nitrogen Assesment, cf.
Comments/questions from the
organization
Water Services contra the Danish
translation "forsyningsforpligtelser", cf.
Comments/questions from the
organization
Proportionality, cf. Comments/questions
from the organization
We notice, that the development of the
marine model tools was largely founded
on the recommendations of the ‘Eelgrass
Working Group II’.
How is the comment taken into account?
How is the comment taken into account?
Bæredygtigt Landbrug
2
How is the comment taken into account?
Danmarks
Naturfredningsforening
Danmarks
Naturfredningsforening
Danmarks
Naturfredningsforening
Dansk
Sportsfiskerforbund
Dansk
Sportsfiskerforbund
2
How is the comment taken into account?
Do you find that the marine model tools founded
on the recommendations of ‘Eelgrass Working
Group II’ are sufficient?
Can you recommend, that the marine model tools
founded on the recommendation of the ‘Eelgrass
Working Group II’ is further qualified?
The panel has no full overview of the ways in which the
work originated or was based on previous efforts, and
prefers to comment on the end product instead
See Chapter 10, for the overall assessment of the
sufficiency of the models and primarily Chapters 6-8 for
details
see recommendations in Chapter 11, and further details
about model tools Chapters 6-8
See Chapter 10, for the overall assessment of the
sufficiency of the models and primarily Chapters 6-8 for
details
See Chapter 10, for the overall assessment of the
sufficiency of the models and primarily Chapters 6-8 for
details
The Duarte et al (2009) paper is an excellent and very
interesting article, particularly since it includes a Danish
example. Nevertheless, it cannot be invoked as a basis
to abandon the Danish implementation of the WFD.
Note that, in general, the literature on regime shifts and
alternative stable states indicates that stronger nutrient
2
2
The development of the marine model
tools was founded on recommendations
of the ‘Eelgrass Working Group II’.
2
How is the comment taken into account?
2
The text in section 2.1 does not touch the
central issue in the WFD – returning to
good ecological status. Already in 2009,
Duarte et al. (2009) described (...), cf.
comments/questions from the
organization
Are these tools qualified? Are they sufficient?
Landbrug & Fødevarer
2.1
How is the comment taken into account?
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reduction is needed than would be estimated from a
linear model, in order to revert to the original state of
the system.
Landbrug & Fødevarer
2.1
It is clearly demonstrated that returning
to good ecological status is not merely a
question of reducing nitrogen loads to
previous levels.
How is the comment taken into account?
See above
Coastal systems are subject to a range of pressures. This
is the reason that a number of directives (UWWT,
Nitrates, WFD, MSFD) address water quality as part of
environmental and ecological status. Nutrients are one
of the most important pressures and this was why the
EU chose eutrophication for the intercalibration
excercise. It is also an important issue for Helcom and
Ospar. The Panel stress that in Danish waters
decreasing the nutrient pressure is a necessary, but
possibly insufficient condition for restauration of GES.
However, the Panel recommends that more effort can
be put into investigating further whether combined
nitrogen and phosphorus reduction could optimise the
efficiency of action (Ch. 5)
The panel is fully aware of the importance of feedback
mechanisms. There is a real possibility that the
proposed measures will be insufficient if they are not
able to push the system back to the original state.
Monitoring and follow-up of the effects of the proposed
measures will indicate if more effort is needed. The
panel estimates that it is highly unlikely that less effort
in nutrient reduction will be sufficient to obtain GES.
Landbrug & Fødevarer
2.1
Does the panel agree that several stress factors
must be taken into account?
Landbrug & Fødevarer
2.1
Does the panel agree that understanding
feedback mechanisms is important in order to
implement the right measures for achieving good
ecological status?
Bæredygtigt Landbrug
2.2
Bæredygtigt Landbrug
Danmarks
Naturfredningsforening
2.2
2.2
Uncertain nitrogen assessment
methodology behind the River Basin
Management Plans, cf.
Comments/questions from the
organization
Neglect of the WFD requirements, cf.
Comments/questions from the
organization
With a reference to section 2.1 (…) The
essence of The Water Framework
Directive (WFD) is, that all surface waters
How is the comment taken into account?
See Chapter 2
How is the comment taken into account?
See Chapter 2
How is the comment taken into account?
See Chapter 2.1
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shall achieve at least good ecological and
chemical status., cf. Comments/questions
from the organization
Danmarks
Naturfredningsforening
2.2
Do you find that the ecological status in the
Danish plan period 2015-21 can be classified
according to the three indicators mentioned in
section 2.2.1 (page 9 – 10)?
Do you find, that the ecological status in the
Danish plan period 2015-21 could have been
classified according to more or other indicators,
than the three indicators mentioned I section
2.2.1 (page 9 – 10)? If so, do you think, that it
would have had influence of the result for the
maximum allowable nutrient input (MAI) due to
the models for calculation?
Per 1: The eel grass tool ”However,
though the best availably tool at that
time, it…” Ell grass tool was not the best
How is the comment taken into account?
tool at that time. There were models (DHI)
which were much better developed.”
In Denmark the required reduction of
nutrients inputs is political defined. And
the reduction have been changed in the
period – and prosponed.
How is the comment taken into account?
We find that The Water Framework
Directive (WFD), demands that all surface
waters shall achieve at least good
ecological and chemical status.
It is possible to classiefi the ecological status in
the Danish plan period 2015-21, according to the
three indicators mentioned?
See Chapter 2.2 and chapter 4
Danmarks
Naturfredningsforening
2.2
See Chapter 2.2 and chapter 4
Dansk Akvakultur
2.2
Not dealt with by the Panel
Dansk
Sportsfiskerforbund
2.2
The panel agree that the Water Framework Directive
(WFD) requires that all surface waters shall achieve at
least good ecological and chemical status. We are not
qualified to comment on the political process in
Denmark.
Dansk
Sportsfiskerforbund
2.2
The indicators capture the essence of water quality. See
chapter 4, chapter 11 and next response
More indicators could, at least in principle, be included
to make the assessment more robust, see
recommendations in Chapter 11. Note however, that
the inclusion of an additional indicator requires that (1)
a credible reference state can be defined and (2) the
response of the indicator on proposed measures can be
quantified. Unless this can be achieved, additional
indicators will add more expert judgment and
discussion to the process. Therefore the panel
Dansk
Sportsfiskerforbund
2.2
Could the plan have been classified according to
other indicators?
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recommends more study into additional indicators
before they are operationally used.
Dansk
Sportsfiskerforbund
Dansk
Sportsfiskerforbund
2.2
Is the three indicators representative?
See Chapter 2.2 and chapter 4
2.2
Landbrug & Fødevarer
2.2
Figure 2,3 p. 10 (status of clorophyll a), cf.
comments/questions from the
organization
Landbrug & Fødevarer
2.2
Transitional water, cf.
comments/questions from the
organization
Could that have had influence of the result for the
maximum
See Chapter 9 about Maximum Allowable Input
allowable nutrient input due to the models for
calculation?
This issue is recognised by the Panel and typology and
reference conditions are discussed extensively in the
Abrupt changes in ecological status between
evaluation. Note, however, that when gradients in a
neighboring water bodies frequently occur, as
system are summarized into a few discrete classes,
demonstrated in the comments. Does the panel
‘abrupt’ transitions will always appear in maps even
agree that biologically it does not make sense to
though underlying gradients are small. It is comparable
see such changes?
to a student passing with 5.1/10, and failing with
4.9/10.
Do the abrupt changes indicate problems for
See chapter 3 Typology
instance with the typologization being too coarse?
How is the comment taken into account?
Has hydromorphology for Danish coastal waters
been sufficiently described?
Why have no Danish water bodies been
designated “transitional water”, given the
description in the WFD?
Would it be relevant to re-consider the
designation of certain water bodies – in particular
the inner, coastal fjords, as suggested by the EU
commission?
This was a decision by the Danish Competent Authority.
Other countries (e.g. Germany) have also adopted this
strategy.
The typology is discussed by the Panel extensively in Ch.
3
See chapter 3 Typology. This was a decision by the
Danish Competent Authority. Other countries (e.g.
Germany) have also adopted this strategy.
It is a possibility and we note a suggestion that such a
project is planned in the answers of the researchers to
our questions. However, we recommend that the
Danish modelling could go to specific water bodies.
See chapter 3 Typology
Landbrug & Fødevarer
3.1
Landbrug & Fødevarer
Landbrug & Fødevarer
3.1
3.1
Landbrug & Fødevarer
3.1
Landbrug & Fødevarer
3.2
Landbrug & Fødevarer
3.2
The typology is central for the
classification of reference conditions and
How is the comment taken into account?
ecological status., cf. comments/questions
from the organization
The European Commission has requested that
Denmark further develops water typologies. Is it
acceptable to simplify typologization to a degree
where highly different water bodies must live up
to similar environmental threshold values?
See chapter 3 Typology. As long as type specific
reference conditions are established for the water
bodies, this is not a problem in the context of WFD
implementation. See also previous answers
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Landbrug & Fødevarer
3.2
Landbrug & Fødevarer
3.2
Physical modifications, such as dams and bridges,
are not taken into account in the typologization.
There is the possibility to classify as
modified
water
Does the panel agree that dams and, to some
body.
extent, bridges may impact the exchange of
water?
Only in two cases are fjords with a sluice
designated the “sluice fjord” typology.
Does the panel agree that as a basic premise, the
presence of a sluice should require an individual
See chapter 3 Typology
assessment of the impact of the modification, and
if necessary specific threshold values for the given
fjord?
In the chapter it is mentioned, that
originally The Danish National Aquatic
Monitoring and Assessment Programme
(DNAMAP) probably was the most
comprehensive programmes in the world
(page 19).
Danmarks
Naturfredningsforening
4
How is the comment taken into account?
See chapter 3 Typology
Danmarks
Naturfredningsforening
Danmarks
Naturfredningsforening
Danmarks
Naturfredningsforening
4
4
4
Danmarks
Naturfredningsforening
4
Dansk
Sportsfiskerforbund
4
Do you find, that The Danish National Aquatic
Monitoring and Assessment Programme
(DNAMAP) probably no longer is the most
comprehensive programmes in the world?
Do you overall find, that the DNAMAP is sufficient
according to numbers of stations and monitoring
land-based loadings of N and of P in Denmark?
Do you overall find that the data from DNAMAP
can be used to develop the marina modeling tools
as done in the project?
Do you overall find that if the land-based loadings
of N and P in Denmark had been monitored
further in DNAMAP in the period used, it would
have result in a greater strength of linear
relationship between modeled and observed
data, than shown in the project? If so, how much
more should there have been monitored in order
to get a greater strength of linear relationship
between modelled and
observed data, than shown in the project?
In the chapter it is mentioned, that originally The
Danish National Aquatic Monitoring and
See chapter 3 Typology
See chapter 3 Typology
See chapter 3 Typology
Annex V, 1.3 of WFD specifies the minimum
requirements for monitoring of ecological status and
chemical status for surface waters
See chapter 3 Typology
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Dansk
Sportsfiskerforbund
Dansk
Sportsfiskerforbund
4
4
Assessment Programme (DNAMAP) in the start
was the best programme. Do you agree?
The Danish National Aquatic Monitoring and
Assessment Programme (DNAMAP) probably no
longer is the best programme in the world? Do
you agree?
Is the numbers of stations and monitoring land-
based loadings of N and of P in Denmark
sufficient?
See chapter 3 Typology
See chapter 3 Typology
Landbrug & Fødevarer
4
Landbrug & Fødevarer
4.1
Landbrug & Fødevarer
4.1
Landbrug & Fødevarer
4.1
Dansk Akvakultur
4.2
The monitoring program has been
decreased at the same time as the
government introduced different
reduction targets for each water body,
How is the comment taken into account?
See chapter 3 Typology
Water bodies with specific nitrogen
reduction targets, cf. comments/questions
from the organization
The monitoring carried out in Danish
marine waters does not cover all water
bodies with specific nitrogen reduction
targets. Only very
How is the comment taken into account?
See chapter 3 Typology
few typologies are applied to the 119
Danish marine water bodies (see section
3.2)., cf. comments/questions from the
organization
Considering the extensive use of models, does the
See chapter 3 Typology
panel find the ongoing monitoring program
See chapter 3 Typology
sufficient?
Modelling and monitoring are complementary
Meta models are used when modeling data is
activities. Adequate monitoring and data is necessary to
insufficient. As meta models are developed in
calibrate and test the models. Annex V, 1.3 of WFD
different water bodies than where applied, they
specifies the minimum requirements for monitoring of
often produce result of high uncertainty. Should
ecological status and chemical status for surface waters.
the monitoring program be extended in order to
The application of Meta models is also discussed
reduce the use of meta models?
extensively in Chapter 8.
The panel cannot make a statement on the specific
An aquaculture plant in Smålandshavet is
case. However in general, depending on the sort of
mentioned as increasing the load here.
aquaculture, there can be inputs, e.g. caged salmon.
The discharge of nutrients is very low
How is the comment taken into account?
Some organisms can act as biofilters and others (e.g.
compared to other sources. Therefore it is
algae) can remove nutrients. So the type of aquaculture
incorrect and misleading and should be
is important.
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Dansk Akvakultur
4.2
Landbrug & Fødevarer
Landbrug & Fødevarer
Danmarks
Naturfredningsforening
4.2
4.2
removed. There hasn’t been any new
aquaculture farm here in many years.
Sentence: ” Despite the efforts to reduce
the diffuse loads, Danish agriculture
remains the major source of both N (80%)
and P (50%) in Danish streams, lakes and
coastal waters (Kronvang et al. 2005).”is
not correct for coastal waters, as external
sources are far more important here.
Nitrogen loading, on an annual basis, is
the target of action in the Danish RBMP.
How is the comment taken into account?
The Panel is well aware that there are influences from
offshore on coastal waters to a varying degree and
although the Panel have suggestions for refined
typology, the effects are accounted for adequately in
the models described in the Scientific Documentation
Report
The Panel address the issue of seasonality in Chapter 5
See questions regarding this point in section 9.1
How is the comment taken into account?
5.1
Danmarks
Naturfredningsforening
5.1
Danmarks
Naturfredningsforening
5.1
Danmarks
Naturfredningsforening
5.1
Are those models and methods – or similar
We notice the recommendation given by
models and methods -used to support the
the Eelgrass Working Group II about which
establishment of Danish River Basin Management
models, there should be in focus (page
Plans – been develop and used in other
24).
countries/water bodies?
We notice, that both the budget and the
time schedule was taking into account
Are the models and methods used to support the
when it was adopted an approach
establishment of Danish River Basin Management
involving development of four
Plans generally scientifically accepted?
mechanistic biogeochemical models and
statistical models (page 24).
Should there have been developed more than
four mechanistic biogeochemical models and
statistical models (if the budget and the time had
not to be taking into account) calculating nutrient
reduction requirement and corresponding MAI to
obtain GES?
Considering the Danish water bodies do you
assess, that the four mechanistic biogeochemical
models and statistical models developed
sufficient covers the Danish water bodies?
Development of four mechanistic
biogeochemical models and statistical
models had a budget and time schedule,
that set the frame.
The Panel address the issue in Chapter 9
The Panel gives an overall assessment in chapter 10,
details are found in remaining chapters.
Yes, the Panel recommends that mechanistic models
are applied in more water bodies
The question is extensively discussed in Chapter 8
The Panel have noticed that the researchers behind the
Scientific Documentation Report refer to limited
resources and time as reason for not exploring certain
lines of research. However, the Panel has not the
overview over time-frame and budget to make an
assessment on whether reasonable resources have
been spent.
Dansk
Sportsfiskerforbund
5.1
How is the comment taken into account?
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Dansk
Sportsfiskerforbund
5.1
Dansk
Sportsfiskerforbund
5.1
Dansk
Sportsfiskerforbund
5.1
Dansk
Sportsfiskerforbund
5.1
Do you find that the necessary money and time
was given to the
development of the models?
Are the models and methods used to support the
establishment of
Danish River Basin Management Plans generally
scientifically
accepted?
Do you find that the Danish water bodies is
sufficient covered, with
the used of the mechanistic biogeochemical
models and statistical
models?
Should there have been developed more models
calculating
nutrient reduction requirement and
corresponding MAI to obtain
GES?
It is explained that meta models are used
for “too small” water bodies and when
data availability is limited, cf.
comments/questions from the
organization
See response to the comment above, however, we give
recommendations on how the work could be extended
and refined.
See the overall assessment in Chapter 10
The question is extensively discussed in Chapter 8
The question is extensively discussed in Chapter 8 and
consider the recommendations in Chapter 10
Landbrug & Fødevarer
5.1
How is the comment taken into account?
Meta modeling is discussed extensively in Chapter 8
and the typology in Chapter 3
Landbrug & Fødevarer
5.1
Have scientific criteria for identification of ‘too
small’ water bodies been established / provided?
We notice, that it is mentioned, that for
the Danish plan period 2015-21, ecological
status is classified to three indicators
(chlorophyll-a, eelgrass depth limit and a
How is the comment taken into account?
fauna index (DKI). We furthermore notice,
that not all of these indicators can be
linked to the model toolbox (page 25).
See chapter 3 and chapter 8
Danmarks
Naturfredningsforening
5.2
The Panel discuss indicators in general in Chapter 2 in
terms of the WFD, but also specifically in several of the
other Chapters the consequences of indicator choices
are discussed.
Danmarks
Naturfredningsforening
5.2
Danmarks
Naturfredningsforening
5.2
The Panel agrees with the researchers that the link
Do you agree that it was necessary to make the
between nutrient inputs and the benthic fauna
adjustments as described in section 5.2 (page 25 –
biodiversity is not understood well enough to make use
26)?
of that indicator in the present context
Here the Panel assume that the question relates to the
What is your assessment of the adjustment
estimation of Chl-a targets using the models. This is
described in section 5.2 (page 25 – 26)? Could the
discussed in several of the chapters, concerning various
adjustment have influence on the result of linear
aspects on that issue
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relationship between modeled and observed
data?
Dansk Akvakultur
5.2
p. 26 par 2: Is it a lack that biodiversity
not is included.
In the Danish plan period 2015-21,
ecological status is classified to three
indicators.
How is the comment taken into account?
The Panel agrees with the researchers that the link
between nutrient inputs and the benthic fauna
biodiversity is not understood well enough to make use
of that indicator in the present context.
See Chapter 2 and Chapter 4 on indicators
The Panel agrees with the researchers that the link
between nutrient inputs and the benthic fauna
biodiversity is not understood well enough to make use
of that indicator in the present context
Here the Panel assume that the question relates to the
estimation of Chl-a targets using the models. This is
discussed in several of the chapters, concerning various
aspects on that issue
Dansk
Sportsfiskerforbund
Dansk
Sportsfiskerforbund
5.2
How is the comment taken into account?
Do you find it was necessary to make the
adjustments as described? What is your
assessment of the adjustment described?
Will you comment the influence on the result of
linear relationship between model and observed
data with these adjustments?
5.2
Dansk
Sportsfiskerforbund
5.2
The WFD operates with three “biological
quality elements”, of which angiosperm
distribution is one. cf.
comments/questions from the
organization
Landbrug & Fødevarer
5.2
How is the comment taken into account?
See Chapter 2 on indicators
Landbrug & Fødevarer
5.2
Landbrug & Fødevarer
5.2
Is it acceptable to disregard species of
angiosperms other than eelgrass, e.g. spiral
tasselweed, even though specific areas have
abundant populations of these?
Is it reasonable to assign poor ecological status,
concerning “other aquatic flora”, to areas with a
widespread eelgrass population, but where
eelgrass is not found at the bottom of e.g. an
artificial channel in the fjord?
Kd is a physico-chemical quality element;
basically the transparency of the water,
cf. comments/questions from the
organization
Numerous factors influence the eelgrass depth
limit. Is it reasonable to focus exclusively on Kd as
a proxy?
Is it possible, maybe even likely, that eelgrass will
not, even after a time lag, spread to the required
depth limit if only one stress factor is addressed?
The distribution of
Ruppia
(Spiral tassle weed) will also
be affected by Kd
If the channel is dredged to be kept open "artificially"
this will also destroy the eelgrass
Landbrug & Fødevarer
5.2
Kd was the chosen indicator, but maybe insufficient.
See discussion in Ch. 4
This is discussed in Ch.4. It is indeed possible that other
measures would be necessary. However, the panel also
discusses the possibility that Kd is affected by nutrient
loading but lags behind in its response due to stocks of
(coloured) organic matter or other factors
Landbrug & Fødevarer
5.2
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Landbrug & Fødevarer
6
Danmarks
Naturfredningsforening
6.1
The panel is kindly requested to reflect and
comment on the evaluation report differing from
the original, Danish reports, which form the basis
for RBMP. What is the value of an international
evaluation, if the background reports have been
altered at critical points?
Do you agree, that the PLS regression models are
an appropriate tool taking the argument for the
chose mentioned in section 6.1 in to
consideration (page 27)?
Do you in overall find, that it would have been
inadvisable, if PLS regression models had not
been chosen as a tool?
p.27 par 1: Statistical linear models with
multiple predictors (MLR, mixed models,
PLS etc.) have previously been applied in
several studies of marine eutrophication
published in international peerreviewed
journals (Conley et al. 2007;….” These
models are as far as we know not pre-
reviewed but only used in reports. There
should be a clear discussion of the
advantages, as well as the disadvantages
of using the statistical models.
Is it right that these models are not
prereviewed?
We are unable to ascertain this as we cannot read
Danish. The panel only evaluates the English report. We
urge the different parties to build a relationship on trust
and respect to resolve the complex issue of ecological
quality, which will ultimately benefit all Danish people.
Yes
We do not understand the question with its double
negation very well. The panel does not see problems
with PLS as a statistical tool. However, it recommends
changes to the statistical approach based on other
considerations in Ch. 6
Danmarks
Naturfredningsforening
6.1
Dansk Akvakultur
6.1
How is the comment taken into account?
Basic computational methods have been published
elsewhere and the methods are well established. It is
possible that no publications describe application to
Danish marine systems, but that does not render the
models suspicious or bad. Note that the present review
should be considered a 'heavy' peer review
Dansk Akvakultur
6.1
Is it right that these models are not prereviewed?
The models should be pre-reviewed if they are
used, and it should be clear that the models are
not pre-rewired.
See previous response
The reports that form the basis of the typology and the
modelling are not based on peer reviewed articles and
this is pointed out as a weakness by the stakeholders.
However, the nature and purpose of scientific reports is
different to that of scientific, peer reviewed articles.
Articles are usually too short for a full and detailed
explanation. Nevertheless, this DRBMP report has now
been subjected to a very thorough peer review lasing
several weeks and involving 5 international experts on
the panel. Additionally, it has been peer reviewed by
Landbrug & Fødevarer
6.1
The cited ”earlier work on MLR”
(Markager et al. 2006, 2008) are non-peer
reviewed reports. Thus, both previous
work and the present reports have not
passed a scientific peerreview, cf.
comments/questions from the
organization
How is the comment taken into account?
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highly qualified consultants acting for the stakeholders.
This level of scrutiny should contribute to an improved
report and more robust results.
According to this section, PLS models
were developed “with the main purpose
of quantifying the relationship between
nutrient loadings and the selected
response variables”, cf.
comments/questions from the
organization
We notice, that the predictors was
selected due to their known ability to act
as forcing factors on the indicators (see
table 6.2 at page 30).
Does the panel agree that selecting input
variables in advance is a problematic approach,
which is unnecessary given the many advantages
of PLS regression?
Landbrug & Fødevarer
6.2
yes. See comments in Chapter 6
Danmarks
Naturfredningsforening
6.3
How is the comment taken into account?
Please comment figure 6.1 according to the
numbers of official stations compared to the
Danish water bodies and their individual
characteristics (page 29).
Do you find it correct, that only monitoring
stations within the zone of WRD and data series
with at least 15 years of data during the period
1990 to 2012 with a minimum of one bimonthly
observation, has been used (page 29)?
Do you assess, that the selected predictors are
the right predictors in order to developed
statistical models in the project?
Could there have been chosen fewer predictors
without influencing the project statistical models
and the project result of linear relationship
between modeled and observed data?
To what extent can it have influenced on the
statistical models, that all data series have not
been analyzed for outliers individually (page 32)?
Do you agree, that in order to balance the two
aspect of the predictor variables described (page
33) it is correct to specify, that the predictors
variables should not start earlier than the year
For this and the following comments and questions, the
panel refers to Ch. 6
Danmarks
Naturfredningsforening
6.3
Question is unclear to the panel
It is advisable to use all available data that has been
quality controlled. Annex V section 1.3 of the WFD
sets out the requirements for monitoring of ecological
status and chemical status for surface waters. In
practice decisions on what is 'sufficient' must be taken
by all researchers. The panel thinks the applied criteria
are reasonable and does not see reason to criticize
them
Collinear predictors could have included given
estimated covariances to add the most important
predictors for the management.
No
Danmarks
Naturfredningsforening
6.3
Danmarks
Naturfredningsforening
Danmarks
Naturfredningsforening
Danmarks
Naturfredningsforening
Danmarks
Naturfredningsforening
6.3
6.3
6.3
Data series should be quality checked. Outliers may be
important but if erroneous they can distort results.
6.3
Time lags seem ok given short retention times
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Danmarks
Naturfredningsforening
6.3
before the responding variable? And do you find,
that the rules for predictor variables are sufficient
(se also figure 6.3 at page 34)?
Do you agree that the additional analyses used to
identify the most likely variable in those cases,
Analysis gives additional information necessary. In this
where different sets of predictor variables
case, it is hard to get better information.
described the selected responding variable almost
equally, is sufficient (see also page 38)?
We notice, that the predictors was
selected due to their known ability to act
as forcing factors on the indicators.
How is the comment taken into account?
Please comment figure 6.1 according to the
numbers of official stations compared to the
Danish waterbodies and their individual
characteristics.
Do you find it correct, that only monitoring
stations within the zone of WRD and data series
with at least 15 years of data during the period
1990 to 2012 with a minimum of one bimonthly
observation, has been used?
Do you assess, that the selected predictors are
the right predictors in order to developed
statistical models in the project?
Could there have been chosen fewer predictors
without influencing the project statistical models
and the project result of linear relationship
between modelled and observed data?
To what extent can it have influenced on the
statistical models, that all data series have not
been analyzed for outliers individually?
Do you agree, that in order to balance the two
aspect of the predictor variables described (p. 33)
it is correct to specify, that the predictors
variables should not start earlier than the year
before the responding variable? And do you find,
that the rules for predictor variables are sufficient
(se also figure 6.3)?
For this and the following comments and questions, the
panel refers to Ch. 6
Dansk
Sportsfiskerforbund
Dansk
Sportsfiskerforbund
6.3
6.3
Question is unclear to the panel
It is advisable to use all available data that has been
quality controlled. Annex V section 1.3 of the WFD
sets out the requirements for monitoring of ecological
status and chemical status for surface waters. In
practice decisions on what is 'sufficient' must be taken
by all researchers. The panel thinks the applied criteria
are reasonable and does not see reason to criticize
them
Collinear predictors could have included given
estimated covariances to add the most important
predictors for the management.
No
Dansk
Sportsfiskerforbund
6.3
Dansk
Sportsfiskerforbund
Dansk
Sportsfiskerforbund
Dansk
Sportsfiskerforbund
6.3
6.3
6.3
Data series should be quality checked. Outliers maybe
important but if erroneous they can distort results.
Dansk
Sportsfiskerforbund
6.3
Time lags seem ok given short retention times
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Dansk
Sportsfiskerforbund
6.3
Do you agree that the additional analyses used to
identify the most likely variable in those cases,
Analysis gives additional information necessary. In this
where different sets of predictor variables
case, it is hard to get better information.
described the selected responding variable almost
equally, is sufficient?
Four responding variables (…) were
chosen as environmental indicators due to
Is choosing responding variables based on which
their welldocumented response to
factors they respond to an acceptable method in
nutrient enrichment”, cf.
accordance with scientific standards?
comments/questions from the
organization
Landbrug & Fødevarer
6.3
Variable selection is in accordance with scientific
standards, but see comments in Ch. 6
Landbrug & Fødevarer
6.3
Should non-Danish contributions to the total
nutrient load in Danish marine waters be taken
into account when developing regression models
describing the
ecosystems in these waters?
Landbrug & Fødevarer
6.3
Should the trend in climate change be included in
the model work?
Landbrug & Fødevarer
6.3
How is the comment taken into account?
According to equation 6.2, detrending was
used for preprocessing data. The exact
Should the trend in climate change be included in
settings for the detrending are not stated
the model work?
in the paper, why the strength of the
detrending is unknown to the reader, cf.
They should, but the question is not easy to solve.
When regressing a response variable on land-based N
load only, as was done in the statistical modelling, one
accounts for other influences as random influences. If
however external loading has a decreasing trend, e.g. as
a consequence of Baltic actions, this could deviate from
the random assumption. In principle, the effect could
be built into the statistical model. We suspect,
however, that it will have little influence in practice
since it applies to very open waters where required
nutrient load reductions are small
The panel discusses this in Ch.9. Climate change could
have effects but these are not very clear at the
moment. Climate change should not be invoked as a
reason not to act today. Elliot et al 2015, discuss this
with respect to Good Environmental Status (MSFD) and
biodiversity, however, most of the arguments are also
valid for GES and the WFD. See Elliott, M et al. 2015.
Force majeure: Will climate change affect our ability to
attain Good Environmental Status for marine
biodiversity?. Marine pollution bulletin, 95(1), pp.7-27.
The Panel asked the researchers about the importance
of this detrending. It appears to have minimal effect on
the overall analysis
Landbrug & Fødevarer
6.3
See Chapter 9 MAI and other answers on the topic
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comments/questions from the
organization
As commented in Appendix 2, it is unusual
to use MLR for variable selection,
How is the comment taken into account?
followed by PLS for the actual modeling.
Variable selection in general is statistically well justified.
However, the Panel also questions whether it is needed
here, given the well-established theory on the influence
of nutrients on phytoplankton. See chapter 6 for full
discussion
Variable selection in general is statistically well justified.
However, the Panel also questions whether it is needed
here, given the well-established theory on the influence
of nutrients on phytoplankton. See chapter 6 for full
discussion
See chapter 6 on statistical modelling
Landbrug & Fødevarer
6.3
Landbrug & Fødevarer
6.3
Has variable selection been carried out in a
satisfactory way?
Could important information potentially be lost
through the applied procedures, specifically the
use of MLR for variable selection before PLS
modeling?
Specific comment to page 36: “we
experienced that the parameters (PLS
coefficients) were still sensitive to small
variations in the data set when highly
intercorrelated predictors (r > 0.9) were
How is the comment taken into account?
used, making use of highly correlated data
sets problematic even in PLS regressions”,
cf. comments/questions from the
organization
Does the panel agree that omitting
intercorrelated variables, which are very well
handled by PLS regression, might mean that
important information is lost?
Landbrug & Fødevarer
6.3
Landbrug & Fødevarer
6.3
It's likely and justified. The Panel proposes an
alternative approach that reduces this problem
Landbrug & Fødevarer
6.3
This is likely and therefore, we recommend to model
the correlation between the variables and to make
resulting uncertainty MAI transparent
Bæredygtigt Landbrug
6.4
This is based on the assumption that water bodies
behave in the same way. If the evidence from water
In more than 40% of the cases, no relation was
body specific model & data is not strong enough then
found between N load and Kd. How is it then
this assumption is valid. The panel comments on
possible to assume that the relation is still valid by
specific problems with Kd in chapter 4, and proposes
using the so called meta model?
cross-systems statistical analysis in Ch. 6 to better treat
this problem
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Danmarks
Naturfredningsforening
6.4
We notice, that it is referred, that a closer
autocorrelation analysis revealed, that the
historical signal for TN have different
How is the comment taken into account?
effect to different water bodies, but due
to the relative short time series available.
Do you access, that there could have been done
quantification of autocorrelation in order to
improve the models based on time series
available?
Please comment the two last sections at page 43.
Do you agree in the arguments and the
assessments in these two sections?
We notice, that it is referred, that a closer
autocorrelation analysis revealed, that the
historical signal for TN have different
How is the comment taken into account?
effect to different water bodies, but due
to the relative short time series available.
Do you access, that there could have been done
quantification of autocorrelation in order to
improve the models based on time series
available?
It is noted that the Kd models do not
describe data very well. This is explained
by influence of light absorption by
dissolved organic matter
How is the comment taken into account?
and detritus as well as scattering of light
by particles, cf. comments/questions
from the organization
Time series may be too short but reveal the differences
in effects.
Danmarks
Naturfredningsforening
Danmarks
Naturfredningsforening
6.4
That would have been informative addition.
6.4
The panel has commented on this in Ch. 6
Dansk
Sportsfiskerforbund
6.4
Time series may be too short but reveal the differences
in effects.
Dansk
Sportsfiskerforbund
6.4
That would have been informative addition.
Landbrug & Fødevarer
6.4
See Chapter 4. Kd may not be sufficient as an indicator
for eelgrass. Kd was the chosen indicator, but maybe
insufficient,
Landbrug & Fødevarer
6.4
Landbrug & Fødevarer
6.4
Closer analysis of the correlation between Kd and Chl-a,
When the ecological status of Kd is determined by both at the present and in 1900, suggests that both are
several factors in addition to N loading, is it then
influenced by nutrient loading but with different
scientifically correct to investigate and address
response times. Seagrass is known to be very sensitive
only N loading?
to nutrient loading, although low nutrient loading alone
may not be sufficient to restore seagrass meadows.
Is good ecological status obtainable when other
The panel recommends pursuing closer studies into this
variables of significance are not addressed?
problem (Ch. 4 and general recommendations)
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Landbrug & Fødevarer
6.4
We notice, that the aim of the project is to
provide a model-based management tools
for estimation Maximum allowable
loadings (MAI) for each of the 119 marine
water bodies covered by the WFD in
Denmark (page 46).
The aim is to provide a model-based
management tools for estimation
Maximum allowable loadings (MAI) for
each of the 119 marine water bodies
covered by the WFD in Denmark.
Is it problematic to extrapolate a correlation far
out of its defined range, as is done in the
statistical model approach?
Do you agree that there is overwhelming
evidence in the scientific literature, that nutrient
loadings do have an impact on selected response
variables (page 46)?
Uncertainty has been acknowledged correctly in the
report.
Danmarks
Naturfredningsforening
6.5
Yes
Dansk
Sportsfiskerforbund
Dansk
Sportsfiskerforbund
6.5
How is the comment taken into account?
See Chapter 9 MAI.
6.5
Is there evidence, that nutrient loadings do have
an impact on selected response variables?
It is unfortunately necessary to inform the
panel that the described approach of
modeling seems to have changed from
the original reports, in Danish, to the
How is the comment taken into account?
English report forming the basis for the
present evaluation. A phrasing such as
(…), cf. comments/questions from the
organization
Different aspects of the various water
bodies’ ecosystems could have been
investigated by using the models, cf.
comments/questions from the
organization
Why are only scenarios of nitrogen and
phosphorus load reductions included in the
modeling work?
yes
We are unable to ascertain this as we cannot read
Danish. There will always be differences in
interpretation in a translation. We urge the different
parties to build a relationship on trust and respect to
resolve the complex issue of ecological quality, which
will ultimately benefit all Danish people.
N and P loads are 2 of the most important pressures
(Andersen et al 2017). Other pressures such as non-
indigenous species and noise are covered in the MSFD
descriptors. Local measures such as sluice operations
etc. could become part of a local management plan. See
also Ch. 2.5
N and P loads are 2 of the most important pressures
(Andersen et al 2017). Other pressures such as non-
indigenous species and noise are covered in the MSFD
descriptors. Local measures such as sluice operations
etc. could become part of a local management plan. See
also Ch. 2.5
We are afraid we do not understand the comment and
the question. The physical modelling described on p.62
is assessed as excellent by the panel
Landbrug & Fødevarer
6.5
Landbrug & Fødevarer
7
Landbrug & Fødevarer
7
Alternative scenarios, focusing on different stress
factors, would support the work towards finding
the most promising solutions.
We notice, that the modelling work,
where the focus was on the inner Danish
waters did not experience any systematic
errors and therefore it could be concluded
Referring to, that the project found, that the
specific acceptance criteria were lower for the
coastal areas and enclosed water bodies as
specific bathymetric details and local conditions
Danmarks
Naturfredningsforening
7.3
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Dansk Akvakultur
7.3
that the official data on loadings were
valid for the purpose of the modeling
page 59).
Following sentence is very important: “As
can be seen, there is a strong correlation
between especially the Danish and the
German N loads, but also a rather strong
correlation between the Danish and the
Swedish loads.” It verifies that models
only calculating Danish loads are
misleading.
become increasingly important, do you find, that
there are scientific evidence for this (page 62)?
How is the comment taken into account?
The suggestion that the models used in the report are
invalid because of this reason, is not endorsed by the
Panel. The researchers have very carefully taken into
account nutrient fluxes from outside Denmark.
Landbrug & Fødevarer
7.4
It does not seem that the mechanistic models are
The calibration and validation of
used for studying all relevant aspects of the
mechanistic models, like that of statistical,
ecosystem. Would it have been relevant to use
is crucial, cf. comments/questions from
mechanistic models for analyzing other scenarios
the organization
than reducing nitrogen and phosphorus?
Bæredygtigt Landbrug
8
Exploitation of the Water Frame Directive,
cf. Comments/questions from the
How is the comment taken into account?
organization
Bæredygtigt Landbrug
8
Non-compliance with the Water
Framework Directive, cf.
Comments/questions from the
organization
How is the comment taken into account?
Danmarks
Naturfredningsforening
8
General comment
Can the decisions of how to use the historical
observation together with the handling of the
The mechanistic models are very comprehensive and
could run diverse scenarios. However, the panel does
not see obvious other pressures that could be of similar
importance for the ecological status as nutrient loading,
especially at national level
See Chapter 2.1 Annex II of the WFD (section 1.3)
specifies the procedure for the “Establishment of type-
specific reference conditions for surface water body
types”. Type-specific reference conditions (RC) may be
either spatially based or based on modelling, or may be
derived using a combination of these methods. Where
it is not possible to use these methods, Member States
may use expert judgement to establish such conditions.
The Danish approach relies on modelling and a 1900
baseline, since there are no pristine systems that can be
used as a reference, which is appropriate and WFD
compliant.
See further Ch. 3 on typology
See Chapter 2.4 Based on the ‘one out all out’ principle,
the indicators should be considered individually. If one
is classified as below the G/M boundary, then
management measures must be applied. This was not
applied in the DRBMP as confirmed by the researchers
in their answers to the panel questions. The outcome of
using the 'one out all out' principle would make the
measures more stringent. The panel comments on this
point in chapter 4
See Chapter 9 about Maximum Allowable Input. If the
historical data exists it could be used as the reference
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model uncertainty and sensitivity result in an
underestimated nutrient reductions requirement
in one or more of the 119 Danish WFD water
bodies to fulfill GES according to the WFD?
condition. However, see Chpt 2.1 Annex II of the WFD
(section 1.3) specifies the procedure for the
“Establishment of type-specific reference conditions for
surface water body types”. Type-specific reference
conditions (RC) may be either spatially based or based
on modelling, or may be derived using a combination of
these methods. Where it is not possible to use these
methods, Member States may use expert judgement to
establish such conditions. The Danish approach relies
on modelling and a 1900 baseline, since there are no
pristine systems that can be used as a reference, which
is appropriate and WFD compliant.
Dansk
Sportsfiskerforbund
8
Dansk
Sportsfiskerforbund
8
Do you agree, that the use of the
historical data together with the handling
of the model uncertainty, result in
underestimating the requirement of
nutrient reductions in more of the 119
Danish WFD water bodies, just to fulfill
GES according to the WFD?
The year 1900 is chosen as the historical
reference conditions in Denmark founded on
historical observations documenting eelgrass
depth distribution and light
penetration at that time. The historical
observation is not used directly, even
though Denmark have the data. It was decided to See Chapter 9 about Maximum Allowable Input
use the 90 pct percentil of the historical
observations. The reference for GES was defined
as 25-30 pct. deviation
from the reference. Thus you have the data it was
decided to assumed that GES for Danish
waterbodies can be estimated at a lower level.
See Chapter 9 about Maximum Allowable Input. If the
historical data exists it could be used as the reference
condition. However, see Chpt 2.1 Annex II of the WFD
(section 1.3) specifies the procedure for the
“Establishment of type-specific reference conditions for
surface water body types”. Type-specific reference
conditions (RC) may be either spatially based or based
on modelling, or may be derived using a combination of
these methods. Where it is not possible to use these
methods, Member States may use expert judgement to
establish such conditions. The Danish approach relies
on modelling and a 1900 baseline, since there are no
pristine systems that can be used as a reference, which
is appropriate and WFD compliant.
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Bæredygtigt Landbrug
8.1
No data – only uncertain model
calculations, cf. Comments/questions
from the organization
Dansk Akvakultur
8.1
p.73. 8.1.4: Important to discuss the
reasonableness of using 1900 as
historical reference year in relation to
data and natural changeability and
fluctuation.
Landbrug & Fødevarer
8.1
The chlorophyll a reference value is
central in the modeling work. Finding a
value for that can be approached in
several ways, cf. comments/questions
from the organization
Landbrug & Fødevarer
8.1
Landbrug & Fødevarer
8.1
1900 nutrient load estimates were not part of this
project. Proper reference to the data sources has been
How is the comment taken into account?
given. There is more knowledge on nutrient budgets in
that period than suggested here
See Chapter 9 about Maximum Allowable Input. If the
historical data exists it could be used as the reference
condition. However, see Chpt 2.1. Annex II of the WFD
(section 1.3) specifies the procedure for the
“Establishment of type-specific reference conditions for
surface water body types”. Type-specific reference
Is it optimal to choose 1900 as historical reference conditions (RC) may be either spatially based or based
on modelling, or may be derived using a combination of
your, or was it better to use an other periode?
these methods. Where it is not possible to use these
methods, Member States may use expert judgement to
establish such conditions. The Danish approach relies
on modelling and a 1900 baseline, since there are no
pristine systems that can be used as a reference, which
is appropriate and WFD compliant.
see Chpt 2.1. Annex II of the WFD (section 1.3) specifies
the procedure for the “Establishment of type-specific
reference conditions for surface water body types”.
Type-specific reference conditions (RC) may be either
spatially based or based on modelling, or may be
derived using a combination of these methods. Where
How is the comment taken into account?
it is not possible to use these methods, Member States
may use expert judgement to establish such conditions.
The Danish approach relies on modelling and a 1900
baseline, since there are no pristine systems that can be
used as a reference, which is appropriate and WFD
compliant.
Does the panel agree that the almost flat
This is not necessarily the case. A response can have a
response curves describing the correlation
small slope but still be estimated with reasonably low
between nitrogen load and chlorophyll a result in
error. Also note that low slopes imply that current
large uncertainties on the estimated nitrogen load
status and reference value will be close together
reductions?
See Chapter 9 about Maximum Allowable Input. see
Does the panel find that the certainty of the
Chpt 2.1. Annex II of the WFD (section 1.3) specifies the
reference load in 1900 has been satisfactorily
procedure for the “Establishment of type-specific
accounted for?
reference conditions for surface water body types”.
Type-specific reference conditions (RC) may be either
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Landbrug & Fødevarer
Bæredygtigt Landbrug
8.1
8.3
And does the panel find that it falls within an
acceptable range?
Is it the opinion of the reviewing group that lack
of funds and time is an acceptable reason for
ignoring the phosphorous effect in the model?
spatially based or based on modelling, or may be
derived using a combination of these methods. Where
it is not possible to use these methods, Member States
may use expert judgement to establish such conditions.
The Danish approach relies on modelling and a 1900
baseline, since there are no pristine systems that can be
used as a reference, which is appropriate and WFD
compliant.
See Chapter 9 where comparisons with neighbouring
countries are given
The panel was not asked to evaluate funds and time. It
comments on N and P measures in Ch. 5
See Chapter 2.4 Based on the ‘one out all out’ principle,
the indicators should be considered individually. If one
is classified as below the G/M boundary, then
management measures must be applied. This was not
applied in the DRBMP as confirmed by the researchers
in their answers to the panel questions. The outcome of
using the 'one out all out' principle would make the
measures more stringent. The panel comments on this
point in chapter 4
Danmarks
Naturfredningsforening
8.3
We notice, that there is referred to the
principle ‘one-out-all-out’ in the WFD and
the project considers one pressure factor
(nutrient loadings) (page 91).
How is the comment taken into account?
Danmarks
Naturfredningsforening
8.3
Danmarks
Naturfredningsforening
8.3
Danmarks
Naturfredningsforening
8.3
While nutrient loadings are a major pressure
factor do you agree that the set up of the project
using several indicators to describe the effect of
this pressure factor is reasonable and correct?
And do you agree that though not taken the
principle ‘one out all out’ into consideration MAI
estimated in project is sturdy?
Do you agree in the assumption, that a weighted
average approach provides a more correct
estimate of the maximum allowable load and
making it less susceptible to random variation in
the data parameters (page 91)?
Do you agree in the use of each of six indicators
and arguments for the modifications and values
of the constant involved (an overview is given in
table 8.7 at page 100 – 101))?
According to the WFD each BQE should have at least
one indicator. See Chapt 2. Also see discussion in
chapter 4
It is not guaranteed, but often likely. The panel
comments on averaging in Ch. 8
The panel has extensively commented on this in
chapter 4
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Danmarks
Naturfredningsforening
8.3
Danmarks
Naturfredningsforening
8.3
Do you agree in the approach to handle the
described off-sets and thus the assumption, that
it is a valid approach as the overall calibration
seems strong (page 103)?
Do you find that the percentage chosen for
‘Categorized in case of time Lag’ are correct in
order to the estimated GES (see table 8.7 at page
100 – 101)?
It is well documented that hypoxia or
anoxia in the bottom water will accelerate
the negative effects of eutrophication,
such as loss of macro vegetation, release
How is the comment taken into account?
of both nitrogen and phosphorus from the
sediment, fish kills and, ultimately, direct
release of hydrogen sulphide to the
atmosphere.
Do you agree, that if the low oxygen
concentrations are restricted to a deep hole in an
estuary, it may not have a significant impact on
the estuary as a whole, whereas comprehensive
hypoxia covering a large-sized area will most likely
result in notable
derived negative effects.
Quoting the report page 90: “…this implies
Can the two model approaches be compared
a restriction to indicators for which a
directly, given that the statistical modeling
reference condition and an EQR value for
approach requires the inclusion of four supporting
good-moderate status have been
indicators, whereas the mechanistic approach
established.”, cf. comments/questions
does not?
from the organization
The one-out all-out principle means that
the ecological status of a water body is
governed by the biological quality
element of lowest status, cf.
comments/questions from the
organization
This decision seems well justified. The panel has
checked the overall validation and found it in general
very good
See comments in chapter 4
Dansk
Sportsfiskerforbund
8.3
Oxygenation condition could be included in the
modelling as an indicator, provided good reference
conditions can be estimated and clear dose-effect
relations with causal factors can be established. The
panel recommends research in this direction in Ch. 4
Dansk
Sportsfiskerforbund
8.3
Even Hypoxia in a deep hole can have redox effects
such as the release of P from the sediment. Wide-
spread hypoxia is even more detrimental.
Landbrug & Fødevarer
8.3
see chapter 6 Statistical modelling and chapter 4 on
indicators
Landbrug & Fødevarer
8.3
How is the comment taken into account?
See Chapter 2.4 Based on the ‘one out all out’ principle,
the indicators should be considered individually. If one
is classified as below the G/M boundary, then
management measures must be applied. This was not
applied in the DRBMP as confirmed by the researchers
in their answers to the panel questions. The outcome of
using the 'one out all out' principle would make the
measures more stringent. The panel comments on this
point in chapter 4
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Landbrug & Fødevarer
8.3
The indicator “chlorophyll a-
concentration” It is reported that 17 out
of 28 chlorophyll a models have a
significant nitrogen coefficient, cf.
comments/questions from the
organization
See discussion in chapter 4 on Kd and Chl-a. The panel
Does the panel find that using a weighted average
has reasons to find this weighted averaging approach
is in acceptable compliance with the WFD?
acceptable
When only 67 % of the developed models have
The panel discusses this issue in chapter 5. Also in
nitrogen as a predictor variable, is it reasonable to
Chapter 6 comments are given on the variable selection
focus exclusively on nitrogen regulation? Or
procedures and its consequences
should other factors be taken into account?
Percent load reductions above 100 % frequently
occur for models on the chlorophyll a indicator.
Not only in open waters, also indeed in closed
fjords. Numbers as high as 135 % (Haderslev
Fjord) are included in the weighted average to
give the final PLR.
Is including unrealistic model results in further
calculations acceptable, scientific practice? Or
should it be considered that maybe the model is
not optimal if yielding unrealistic results?
The indicator “light attenuation” The
problem with eelgrass being the only
angiosperm included in the Danish RBMP
has been elaborated in section 5.2, but it
is likewise relevant when discussing the
indicator “light attenuation”, cf.
comments/questions from the
organization
Landbrug & Fødevarer
8.3
Landbrug & Fødevarer
8.3
See Chapter 3 on typology, Chapter 8 on calculation
schemes, and chapters 9 and 10 on recommendations
to avoid this type of situations.
Landbrug & Fødevarer
8.3
How is the comment taken into account?
See Chapter 2.2 Kd maybe insufficient as an indicator
for eelgrass and is not independent from Chlorophyll a.
Kd was the chosen indicator, but maybe insufficient
because other factors also affect seagrasses. See
chapter 4 for discussion on Kd
Landbrug & Fødevarer
8.3
Is it reasonable to link nitrogen load and
angiosperm distribution directly, without
considering other stress factors?
Is it acceptable scientific practice to replace
clearly erroneous results with values that are
chosen, based on no scientific evidence or
calculations?
Occurrence of Hypoxia / Ecological Signs
of Hypoxia Occurrence of low oxygen
conditions, or ecological signs of the
same, is directly translated into a demand
of 25 % reduction of total nitrogen (TN),
See chapter 4 for discussion of Kd and problems of
seagrass.
The answer to the general question is obviously 'No'.
However, the question seems to imply that in the
section referred to there are clear errors, and that is
not endorsed by the Panel. The panel has discussed the
problem of 'look-up' tables in Chapter 4
Hypoxia is a serious and well documented consequence
of nutrient pressures, especially nitrogen. Howarth, R.,
Chan, F., Conley, D.J., Garnier, J., Doney, S.C., Marino, R.
and Billen, G., 2011. Coupled biogeochemical cycles:
eutrophication and hypoxia in temperate estuaries and
Landbrug & Fødevarer
8.3
Landbrug & Fødevarer
8.3
How is the comment taken into account?
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cf. comments/questions from the
organization
Landbrug & Fødevarer
8.3
Is it common, scientific practice to simply choose
a nitrogen reduction demand?
coastal marine ecosystems. Frontiers in Ecology and the
Environment, 9(1), pp.18-26. See however comments of
the panel on the lack of clear dose-effect relationships
and why that makes the indicator less suitable.
Expert judgment is an allowable and generally
respected way of solving problems for which there is
not enough other information available. However,
when it can be replaced by hard information the latter
is preferable. The Panel does not endorse the look-up
tables (Ch. 4) but would also not call the expert
judgment 'simply choose'
Landbrug & Fødevarer
Landbrug & Fødevarer
8.3
8.3
Nitrogen limitation of phytoplankton
growth Again, please be advised that this
indicator is not used in the calculations
using mechanistic models.
As for Kd models, the calculated values
are changed according Table 8.7, though
the change is less dramatic than for Kd.
Weights – as noted in Table 8.7 According
to the table, chlorophyll and Kd model
results are each given the weight 2,
“occurrence of hypoxia” and “N
limitation” are each given the weight 1,
and the two “ecological signs of hypoxia”-
indicators each have the weight 0.5, cf.
comments/questions from the
organization
Is it acceptable to base regulation on numbers
chosen without any scientific basis, calculations or See previous response
references?
Could the TN reduction demand just as well have
See previous response
been 20 %? 30 %? Or 15 %?
Landbrug & Fødevarer
8.3
How is the comment taken into account?
The panel had fully understood this, thank you
Landbrug & Fødevarer
8.3
How is the comment taken into account?
The panel makes recommendations on these ancillary
indicators in chapter 4
Landbrug & Fødevarer
8.3
Landbrug & Fødevarer
8.3
Is it acceptable to include supporting indicators
which, in almost all cases, lead to lower required
See previous response
reductions – in the statistical and not in the
mechanistic models?
Is it acceptable to include four supporting
indicators which, in almost all cases, lead to lower See previous response
required reductions in the designated statistical
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Danmarks
Naturfredningsforening
8.4
Danmarks
Naturfredningsforening
8.5
models - and including only one supporting
indicator in the meta models?
Do you find that the methodology described is
sturdy, and combined with the reference values
from section 8.1 can be used to estimate the part
of the individual indicator that can be regulated
from Danish land-based N loadings alone (page
102)?
Do you agree, that even though the nature of the
model types differs pronouncedly, the slopes are
very similar, and thus support both the use of
models for defining MAI and the application of
water body types (page 119)?
It is important to underline that the
statistical models (vs. mechanistic
models) overestimate the Danish
contribution to the eutrophication in the
marine waters.
See Ch. 8 for comments on the calculation
methodology. The answer to the specific question is yes
see comments in Ch. 3 on typology, and in Ch.8 on
calculation methodology
This cannot be stated in general. It is, in fact, very
difficult to exactly assess how much the statistical
model results depend on Danish land-based N loads,
but one should take into account that it are only these
loads that have been considered when calculating the
reference values
This is partly a semantic question. 'Black box' in this
case means that if Y is described as a*X+b, it cannot
directly be known (or measured in experiments) what a
and b are. This does not mean however, that there
cannot be very solid evidence and experience that
across many systems and many periods, Y always tends
to be a more or less linear function of X. In other words,
'black box' has no relation with the degree of
confidence one can have in the relation, nor in the
expectation that X will be related to Y. In chapter 6 the
panel has commented extensively on variable selection
The interpretation of the stakeholder is only partly true.
The slopes of the N-load versus Chl-a or Kd, in cases
where Nload was not selected as variable, were indeed
replaced by the average slope of the type. The panel
has commented on this in chapter 6. The
metamodelling procedure, however, contains additional
elements
See chapter 6 (statistical modelling) for comments on
this points
Dansk Akvakultur
8.5
How is the comment taken into account?
Landbrug & Fødevarer
8.5
It is noted in this section that “…statistical
models are “black-box” models with a
Is it acceptable to describe a modeling approach
direct link to observations but without any
as a “black-box” approach, when in fact input
descriptions of causal
variables to some extent are selected in advance?
links”, cf. comments/questions from the
organization
Landbrug & Fødevarer
8.6
Landbrug & Fødevarer
8.6
Meta models are used for water bodies
where no mechanistic or statistical model
has been developed, for various reasons.
However, for the
How is the comment taken into account?
statistical models, meta models are also
used, if nitrogen load was not selected as
an input variable, cf. comments/questions
from the organization
Is it acceptable scientific procedure to omit results
that differ from the expected? In this case
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meaning when nitrogen load is not selected as an
input variable.
The idea in meta models is to apply
models from different water bodies to a
water body of the same type. A great part
of the problem with meta models is, thus
(…), cf. comments/questions from the
organization
Would a more differentiated typologization
possibly improve the applicability of meta
models?
See Chapters 2.1, 3, 6 and 8. The panel is very
concerned about this point and makes
recommendations for change
The Panel does not know all details about this system
and refrains from making very specific comments about
single localities. Statistical variation and occasional
outliers due to errors in the monitoring procedure are
known to occur and always present a problem. If one
removes too many points, there is a danger of data
manipulation. If one does not remove a clear outlier,
there is a danger of reaching incorrect conclusions. The
panel hopes that close interaction with stakeholders is a
mechanism to take into account local knowledge that
can avoid occasional errors of this kind.
Data series should be quality checked. Outliers maybe
important but if erroneous they can distort results and
the calibration of models.
Landbrug & Fødevarer
8.6
Landbrug & Fødevarer
8.6
One specific example of the implications
of problematic use of meta models is
Stege Nor, a small water body with very
limited opening towards open water. A
satellite image of Stege Nor is presented
in Appendix 4, cf. comments/questions
from the organization
Is it reasonable to include a measured value so
clearly deviating from the general level?
Landbrug & Fødevarer
8.6
Should it be expected that input data for models
of this type are comprehensively screened for
outliers?
As a comment to the calculations of
model uncertainty, it is important to know
that the calculations presented here, to
the international panel, are completely
different from the original calculations
which were presented to Danish
politicians and the public, cf.
comments/questions from the
organization
The analysis of variance results in a
minimum confidence interval of ± 13.3 %-
points. Thus, for three out of the 11 water
bodies in question, no
required load reduction has been
demonstrated, as the mean reduction is
Landbrug & Fødevarer
8.8
How is the comment taken into account?
The panel has no way of verifying this and only takes
the English report as input. If the stakeholder is right
that constructive comments have been taken into
account, this reflects a commendable scientific attitude
Landbrug & Fødevarer
8.8
Given that neighboring water bodies are definitely
correlated, does the panel find that a confidence
interval of ± 13.3 %-points based on an
assumption of independence provides useful
information on the actual uncertainty? See
further questions in section 8, General
The panel has commented on uncertainty analysis, the
use of cross-system analysis, statistical models and
independence between the statistical and mechanistic
models in chapters 6 and 8
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Landbrug & Fødevarer
8.8
less than 13.3 %, cf. comments/questions
from the organization
Quantification of model uncertainty The
presented analysis of variance shows, by a
very narrow margin (P = 0.06), no
significant difference between required
nitrogen load reductions calculated by
mechanistic and statistical models, cf.
comments/questions from the
organization
The panel is kindly requested to comment on the
statistically significant differences between model
results using the mechanistic and the statistical
approaches, respectively.
The panel has commented on uncertainty analysis, the
use of cross-system analysis, statistical models and
independence between the statistical and mechanistic
models in chapters 6 and 8
Landbrug & Fødevarer
9
It is mentioned that model development
should be based on “state-of-the-art
knowledge”. The panel is, once again,
advised to pay attention to the lack of
peer-reviewed publishing of the statistical
models. A report alone cannot be
accepted as scientific documentation!
How is the comment taken into account?
The scientific basis of management should be based on
peer reviewed papers. The reports that form the basis
of the typology and the modelling are not based on
peer reviewed articles and this is pointed out as a
weekness by the stakeholders. However, the nature
and purpose of scientific reports is different to that of
scientific, peer reviewed articles. Articles are usually too
short for a full and detailed explanation. Nevertheless,
this DRBMP report has now been subjected to a very
thorough peer review lasing several weeks and
involving 5 international experts on the panel.
Additionally, it has been peer reviewed by highly
qualified consultants acting for the stakeholders. This
level of scrutiny should contribute to an improved
report and more robust results.
From the response of the researchers to the panel
questions, it appeared that this was not part of the
mission they were tasked with. However, N and P loads
are 2 of the most important pressures (Andersen et al
2017). Other pressures such as non-indigenous species
and noise are covered in the MSFD descriptors.
Landbrug & Fødevarer
9.1
The WFD requests that each member
state ensures “a review of the impact of
human activity on the status of surface
waters” (article 5 (1)). In the Danish
RBMP, no thorough review of all relevant
stress factors was performed, and N is the
only stress factor addressed, cf.
comments/questions from the
organization
How is the comment taken into account?
Landbrug & Fødevarer
9.1
The goal of the RBMP is to obtain good ecological
status, as stated in the WFD, not to reduce
nutrient loads. Should other stress factors than
nitrogen load therefore be taken into account in
the RBMP?
N and P loads are 2 of the most important pressures
(Andersen et al 2017). Other pressures such as non-
indigenous species and noise are covered in the MSFD
descriptors. See Ch. 2.5 for more discussion
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Landbrug & Fødevarer
9.1
Is it realistic that acting solely on a single stress
factor will be the best way to attain good
ecological status for all required elements?
N and P loads are 2 of the most important pressures
(Andersen et al 2017). Other pressures such as non-
indigenous species and noise are covered in the MSFD
descriptors. See Ch. 2.5 for more discussion
Landbrug & Fødevarer
9.1
Landbrug & Fødevarer
9.1
Is it possible that if acting only on a single stress
factor, the need to reduce impact from this will be
The panel comments on this in Chapter 5 and chapter 4
higher than by using a combined effort on several
stress factors?
The panel are not economic modellers. However,
Preamble 38 of the WFD states “The use of economic
instruments by Member States may be appropriate as
part of a programme of measures. The principle of
recovery of the costs of water services, including
environmental and resource costs associated with
damage or negative impact on the aquatic environment
should be taken into account in accordance with, in
particular, the polluter-pays principle”.
The WFD has a requirement of applying a cost
Preamble 28 of the WFD states that “Member States
effective approach. When leaving out clearly
may phase implementation of the programme of
relevant stress factors from the modeling, can it
measures in order to spread the costs of
be claimed that the RBMP live up to this
implementation”.
requirement?
Article 9 of the WFD addresses the Recovery of costs for
water services. Details of the economic analysis are
given in Annex III and this takes in account ‘the polluter
pays principle’. Member States can “make judgements
about the most cost-effective combination of measures
in respect of water uses to be included in the
programme of measures under Article 11 based on
estimates of the potential costs of such measures”.
Article 11 is the Programme of measures.
The impact of future climate changes is
briefly discussed, and climate changes in
the form of increased temperature and
precipitation since
1875 are mentioned. It is noted that these How is the comment taken into account?
changes have not been taken into account
in the modeling work, cf.
comments/questions from the
organization
Landbrug & Fødevarer
9.1
See Chapter 9 MAI.
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Landbrug & Fødevarer
9.1
Does the panel find that climate change can be
omitted when estimating which ecological status
can be obtained in Danish coastal waters?
See Chapter 9 MAI.
Residence time and flushing are important attributes of
the sensitivity of the water bodies and should be taken
into account. However, hysteriesis should also be taken
into account as there may be a legacy effect,
particularly in soils and sediments. The panel
recommends a cross-system approach in statistical
analysis (Ch. 6), which effectively incorporates these
aspects. See also O’Higgins, T., Tett, P., Farmer, A.,
Cooper, P., Dolch, T., Friedrich, J., Goulding, I., Hunt, A.,
Icely, J., Murciano, C., Newton, A., Psuty, I., Raux, P.,
Roth, E., 2014. Temporal constraints on ecosystem
management: Definitions and examples from Europe’s
regional seas. Ecology and Society, v. 19, n. 4, Art. 46.
DOI: dx.doi.org/10.5751/ES-06507-190446
The panel recommends on this in Chapter 5. In
principle, this may open innovative solutions, but
important potential side effects should be taken into
account: regional effects of total loading, and storage of
organic matter in the systems. In addition, agronomic
research should demonstrate what is possible in this
respect. Therefore, the panel has recommended
studying these possibilities in depth before
incorporating them into the plans
The panel does not fully understand the question, but
assumes it is about seasonal timing of the N loads. The
panel recomends on this in Chapter 5
Landbrug & Fødevarer
9.1
The hydraulic residence time in a water
body is of great significance to the
biological effect of nutrients released into
the water. This is not taken into account
in the Danish RBMP, cf.
comments/questions from the
organization
How is the comment taken into account?
Landbrug & Fødevarer
9.1
It is known that the nitrogen lost during winter
months in many water bodies with short
residence time will be gone (washed to sea)
before the onset of the algal
growing season. Based on this, should timing of
nitrogen reductions be included in the modeling
work?
Various time periods are selected for input
variables in the statistical models, but the periods
are not included in the public reports. Should this
information
be included in order to evaluate the models
better from a biological perspective?
Chlorophyll a targets It is described how
reference values are
determined according to type of water
bodies, instead of based on the individual
water bodies, cf. comments/questions
from the organization
See chapter 3 Typology
Landbrug & Fødevarer
9.1
Landbrug & Fødevarer
9.2
How is the comment taken into account?
See chapter 3 Typology
Landbrug & Fødevarer
9.2
Do more data lead to more accurately determined
See chapter 3 Typology
reference values for a specific water body, if the
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data derive from widely different water bodies
assigned to
the same type?
Chlorophyll a as indicator The discussion
mentions high grazing
pressure and high density of benthic filter
feeders as cases where chlorophyll a
levels do not increase in spite of high
nutrient loads, cf. comments/questions
from the organization
Filter feeders can act as biofilters for phytoplankton
thus resulting in 'high N, low Chorophyll waters',
however other factors also play a part. In general, filter
feeders show a trend of declining in Danish waters upon
reduction of nutrient inputs (Riemann et al., 2016). This
may imply that larger nutrient reductions may be
needed than currently estimated, but this will have to
be deduced from monitoring effects of measures.
Landbrug & Fødevarer
9.2
How is the comment taken into account?
Landbrug & Fødevarer
9.3
Landbrug & Fødevarer
9.3
The statistical model approach is again
described as built solely on monitoring
data “without including any process
descriptions or mechanisms”. The panel is
How is the comment taken into account?
kindly reminded that in all cases where
nitrogen load was not selected as an input
variable, the model has been discarded
and replaced by a meta model.
For the statistical models it is repeated
that “a suite of ecological[ly] relevant
indicators […] was introduced in order to
obtain a more
How is the comment taken into account?
holistic approach”, cf.
comments/questions from the
organization
The comparison of results from the two
modeling approaches “revealed an overall
satisfactory agreement between the two
How is the comment taken into account?
model approaches” according to the
presente, cf. comments/questions from
the organization
Regime shifts are mentioned and briefly
discussed. Such shifts are central to the
critique of extrapolating correlations
between chlorophyll a and nitrogen load
far beyond the defined range, cf.
The panel is aware of this and has commented on this
at various places in the report
The panel comments on this in Chapter 4 and Chapter 8
Landbrug & Fødevarer
9.3
Landbrug & Fødevarer
9.4
How is the comment taken into account?
Reference values actually used to calculate MAI were
averaged across models before the calculations
proceeded. The mentioned differences are therefore
not reflected in the MAIs. In fact, the panel
recommends against this averaging, in order to keep
differences and variability of model results transparent
and decide on merging both approaches only in a final
stage, based on observed differences and variability
Regime Shifts (Barange et al 2008) are complex issues,
especially for mangement. The Duarte et al (2009)
paper is an excellent and very interesting article,
particularly since it includes a Danish example.
Nevertheless, it cannot be invoked as a basis to
abandon the Danish implementation of the WFD.
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comments/questions from the
organization
Sustained monitoring should reveal to what extent
regime shifts prevent return to desired conditions and
what additional measures should be needed to reach
the goals.
Barange,
M., Beaugrand, G., Harris, R., Perry,
R.I., Scheffer, M. and Werner, F., 2008. Regime shifts in
marine ecosystems: detection, prediction and
management. Trends in Ecology & Evolution, 23(7),
pp.402-409.
Duarte,
C.M., Conley, D.J., Carstensen, J.
and Sánchez-Camacho, M., 2009. Return to Neverland:
shifting baselines affect eutrophication restoration
targets. Estuaries and Coasts, 32(1), pp.29-36.
Dansk
Sportsfiskerforbund
Conclusi
on
To obtain more certain MAI estimates, it is
important to continuously monitor the
ecosystems as they approach GES and to
evaluate, update and improve the models
and methods accordingly based on new
knowledge.
Thus, themodel tools and methods
developed in this project should be
regarded as part of an ongoing process
towards better understanding and
improved predictability of the behaviour
of marine ecosystems in a changing world.
Do you find that the Danish surveillance is
sufficient and is this data good enough to support
the models? Do you find that there had been the
necessary finance and time
for the development of the models? Is there the
necessary continuity in the model work?
The panel makes recommendations on monitoring in
several chapters and in the final recommendations
Danmarks
Referenc
Naturfredningsforening
es
Danmarks
Referenc
Naturfredningsforening
es
Do you find the references used in the project are
sufficient (page 144 – 163)?
Do you find the references support the tool
development and application, the specific use for
setting chlorophyll-a targets and calculating the
load reduction requirements from Danish
catchments in the project?
yes
yes