Bergen op Zoom, 9 juni 2005
Aan Parlementsleden
Geachte Parlementsleden,
Ondergetekende is bestuurlijk betrokken bij vier waterschappen (Zeeuwse Eilanden, Brabantse Delta, Rivierenland en Rijn en IJssel).
Op dit moment staat de Kaderrichtlijn Water bestuurlijk in de belangstelling.
Nederland maakt deel uit van vier grote Europese stroomgebieden (Schelde, Maas, Rijn en Eems). Tot op heden heb ik de Karakteriseringen van de Nederlandse stroomgebieden van Schelde en Maas gelezen en een poging gedaan me te verdiepen in de stukken en informatie over de betrokken stroomgebieden en België en Duitsland. Daar wordt je niet vrolijk van!
Door de verschillende systematieken, methoden en normen is vergelijken/afstemmen lastig. Toch is het Nederlandse belang in deze erg groot.
Middels citaten en verwijzingen naar teksten uit de Karakterisering van het Nederlandse Maasstroomgebied zal ik één en ander trachten te verduidelijken c.q. het belang van vergaande afstemming c.q. gelijkschakeling aan te tonen.
Omgang met verontreinigende stoffen
Op pagina 28 van de samenvatting laat figuur 18 zien dat bij de acht probleemstoffen in onze wateren veruit het grootste deel afkomstig is uit het buitenland:
zink ca. 80 %
fosfor ca. 70 %
stikstof ca. 70 %
koper meer dan 80 %
nikkel ca. 70 %
cadmium meer dan 90 %
benzo(k)fluorantheen ca. 95 %
PCB’s nagenoeg 100 %
Pagina 28 – samenvatting:
“Vanwege de benedenstroomse ligging is het bereiken van een goede ecologische toestand in de Nederlandse Maaswateren mede afhankelijk van de inspanningen die de bovenstrooms gelegen landen leveren om lozingen te verminderen en de waterkwaliteit te verbeteren.
Inzicht in die effectiviteit van maatregelen in Nederland en in de bovenstroomse landen is een nadrukkelijk punt van aandacht”.
Pagina 51 – hoofdrapport
“Uit de brede screenings blijkt ook dat het aantal meetlocaties waar diuron de MTR overschreed, in 2003 met ongeveer 60 % afgenomen was ten opzichte van 2000. Sinds 1999 is er in Nederland een verbod op het gebruik van dit middel. In enkele gebieden is het goed mogelijk dat het middel uit België afkomstig is, waar gebruik toegestaan is.”
Pagina 87 – hoofdrapport
“Diuron is veel gebruikt op verharde terreinen, maar is in Nederland inmiddels verboden.”
Verschillende methoden/normen
Pagina 67 – hoofdrapport
“De begrenzing (grondwaterlichamen) is in Duitsland en België anders aangepakt dan in Nederland. Hierover wordt bilateraal overleg gevoerd.”
“In Duitsland is een andere begrenzingsmethodiek gehanteerd.”
Pagina 69 – hoofdrapport
“Ook over de begrenzing van grondwaterlichamen ten westen van Maastricht (daar is de aansluiting tussen Nederlandse, drie Vlaamse en een Waals grondwaterlichaam onduidelijk) is afstemming noodzakelijk.”
Pagina 137 – hoofdrapport
“Nederland en België gaan verschillend te werk bij het opnemen van grondwaterlichamen voor menselijke consumptie in het register. In Nederland zijn alle grondwaterbeschermingsgebieden (per definitie) opgenomen in het register. In België is slechts een deel van de gebieden die in het nationale beleid beschermd worden, in het register opgenomen. Dit geeft verschillen aan de grens.”
De feitelijke verschillen (o.a. pag. 174 – hoofdrapport)
| Nederland | Vlaanderen | Nordrhein-Westfalen | |
| Waterlichamen | 55 typen | 9 typen | 23 typen |
| Grondwater-lichamen | grotere, geen onderscheid in lagenkleinere, alleen voor onttrekkingen menselijke consumptie | kleiner dan Nederland, groter dan Nordrhein-Westfalen, deels verticaal | kleine lichamenonderscheid |
| prioritairestoffen | toetsen aan EC-voorstellen Fraunhofer Instituut | toetsen aan nationale normen en Fraunhofer normen als vastgesteld | toetsen aan nationale normen |
Verder zijn er verschillen op: politieke aandachtspunten, het implementatieproces, het ambitieniveau, de risicoanalyse en de publieke participatie.
Wat gebeurt er of is er gebeurd
Pagina 13 – samenvatting
“Duitsland en België hebben grondwaterlichamen op een andere manier ingedeeld. In België is het grondwaterlichaam Zand in de verticaal onderverdeeld. In Duitsland zijn veel kleinere grondwaterlichamen onderscheiden. In een procedure van wederzijdse afstemming met de buurlanden is aan de Duitse grens een aantal (kleine) grensoverschrijdende grondwaterlichamen aangewezen, terwijl aan de Belgische grens rekening is gehouden met de verticale verdeling.”
Het is in de ogen van de tekstschrijvers geen groot probleem. Maar in de ogen van de ambtenaren en bestuurders die ik sprak, is er in ieder geval wel een probleem met de typologie-indelingen.
Nederland is voor de realisering van de doelen in 2015 en/of later, gezien de herkomst van het grootste deel van de vervuiling, grotendeels afhankelijk van de aanpak van de problemen bovenstrooms.
Op pagina 20 van de samenvatting en op pagina 113 van het hoofdrapport is te lezen dat één de uitgangspunten van de risicoanalyse is: “voor een realistische inschatting is aangenomen dat de belasting vanuit het buitenland niet merkbaar zal verminderen in de periode tot 2015.”
Het gebruik van andere typologieën, methoden en normen kan er toe leiden dat men ideale excuses en vertragingstactieken kan ontwikkelen om vooral niet of niet volledig te komen tot een effectieve aanpak van de problemen. Wij (Nederland) blijven dan als afvoerputje mooi zitten met de vuiligheid in onze wateren!
Pagina 9 – hoofdrapport
“De internationale coördinatie van een rapportage door de Internationale Maas Commissie richt zich op de grotere onderwerpen die relevant zijn voor het gehele internationale stroomgebied. Daarom is er aanvullend de noodzaak van bilaterale afstemming met direkt aangrenzende buurlanden. Het maasstroomgebied grenst aan de zuidkant aan Vlaanderen, in het uiterste zuidoosten aan Wallonië en in het oosten aan Nordrhein-Westfalen. Met uitzondering van Wallonië, heeft met deze partijen bilateraal overleg plaatsgevonden over de gehanteerde methoden.”
Pagina 67 – hoofdrapport
“De begrenzing van het diepgelegen grondwaterlichaam voor menselijke consumptie is al aangepast aan de Belgische indeling.”
Constateringen – conclusies
Pagina 41 – hoofdrapport
“Het wordt niet als een groot probleem ervaren dat er verschillen in de typologie zijn.”
VERZOEK
Ondergetekende verzoekt U parlementsleden alles te doen wat in Uw vermogen ligt om te komen tot een Europese invulling van de Kaderrichtlijn Water, zodat typologieën, normen en methoden afgestemd worden c.q. gelijk zijn.
Dan ontstaat de situatie dat dit kostbare, maar noodzakelijke proces om te komen tot gezonder water voor mens, dier en plant tot een succesvol einde wordt gebracht.
Maar wat bijna nog belangrijker is: het proces wordt transparant en afrekenbaar.
Als bestuurder en als burger zou ik dit graag zien.
Uw handelen afwachtend,
hoogachtend,
L.H. van der Kallen
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