Three reasons why the Water Framework Directive (WFD) fails to identify pesticide risks

The Water Framework Directive (WFD) demands that good status is to be achieved for all European water bodies. While governmental monitoring under the WFD mostly concludes a good status with regard to pesticide pollution, numerous scientific studies have demonstrated widespread negative ecological impacts of pesticide exposure in surface waters. To identify reasons for this discrepancy, we analysed pesticide concentrations measured in a monitoring campaign of 91 agricultural streams in 2018 and 2019 using methodologies that exceed the requirements of the WFD. This included a sampling strategy that takes into account the periodic occurrence of pesticides and a different analyte spectrum designed to reflect current pesticide use. We found that regulatory acceptable concentrations (RACs) were exceeded for 39 different pesticides at 81% of monitoring sites. In comparison, WFD-compliant monitoring of the same sites would have detected only eleven pesticides as exceeding the WFD-based environmental quality standards (EQS) at 35% of monitoring sites. We suggest three reasons for this underestimation of pesticide risk under the WFD-compliant monitoring: (1) The sampling approach - the timing and site selection are unable to adequately capture the periodic occurrence of pesticides and investigate surface waters particularly susceptible to pesticide risks; (2) the measuring method - a too narrow analyte spectrum (6% of pesticides currently approved in Germany) and insufficient analytical capacities result in risk drivers being overlooked; (3) the assessment method for measured concentrations - the protectivity and availability of regulatory thresholds are not sufficient to ensure a good ecological status. We therefore propose practical and legal refinements to improve the WFD's monitoring and assessment strategy in order to gain a more realistic picture of pesticide surface water pollution. This will enable more rapid identification of risk drivers and suitable risk management measures to ultimately improve the status of European surface waters.