Bergen op Zoom, 1 augustus 2005
Aan het Dagelijks Bestuur van
Waterschap Rivierenland
per e-mail: [email protected]
Geacht Dagelijks Bestuur,
Recent is verschenen de karakterisering deelstroomgebied Rijn-West. Dit stuk leidt voor ondergetekende tot een aantal vragen/bemerkingen, te weten:
pagina 23
“De afstemming inzake afbakening van grensoverschrijdende grondwaterlichamen is nog niet afgerond. Ook de karakterisering van deze grondwaterlichamen is een kennishiaat. De richting en grootte van de grensoverschrijdende grondwaterstroming dient te worden vastgesteld, bij voorkeur in samenspraak met de buurlanden”.
VRAAG
1. Wie is hierbij de initiatiefnemer?
pagina 55
Uit tabel 3.4b blijkt dat in het rivierengebied relatief weinig (4) virtuele waterlichamen met toetsingswaarden zijn vastgesteld.
VRAAG
2. Zijn in het rivierengebied dezelfde criteria gehanteerd als elders in het stroomgebied bij de bepaling van de aard, omvang of het aantal van de virtuele waterlichamen?
pagina 57
“De wijze van bepaling van de 100-jaarszone is door elke betrokken provincie op een iets andere wijze uitgevoerd”.
Hier zou harmonisatie van methoden, regelgeving en werkwijzen op z’n plaats zijn!
pagina 91
“Daarnaast wordt geen nieuw gecreosoteerd hout meer toegepast”.
VRAAG
3. Deze tekst is niet geheel juist. Uit enkele begraafplaatsreglementen blijkt dat men voor de verankering van grafmonumenten nog steeds verduurzaamd/gecreosoteerd hout voorschrijft. Ligt hier een taak voor het waterschap om richting begraafplaatsen op dit punt stappen te ondernemen?
pagina 91
“Diuron is sinds 2000 voor elke toepassing verboden in Nederland. Regionaal zal de stof geen probleem meer vormen in 2015. Mogelijk zou door belasting vanuit het buitenland de stof nog wel in rijkswateren een probleem kunnen geven.
VRAAG
4. Deze tekst lijkt in strijd met de tekst op pagina 77 (“Diuron (herbicide) is voor gebruik in de landbouw in 1999 in Nederland verboden, maar wordt nog beperkt toegepast als anti-foulingsmiddel”). Welke tekst: pagina 91 of pagina 77 is juist?
pagina 91
“Omdat het in het buitenland nog wordt gebruikt, komt Endosulgan via atmosferische depositie en de grote rivieren nog in de Nederlandse wateren terecht”.
De regelgeving ten aanzien van verboden stoffen, zoals Diuron en Endosulfan dienen op Europese schaal geharmoniseerd te worden!
pagina 112
“De in Nederland onderscheiden waterdiensten betreffen drinkwaterverzorging, riolering, afvalwaterzuivering, grondwaterbeheer en het regionale watersysteem”.
Hier ontbreekt de scheepvaart c.q. het bevaarbaar houden als waterdienst. Deze omissie is des te meer van belang, omdat de KRW uitgaat van de vervuiler betaalt en van het kostenterug-winningsprincipe.
Onderstaand enkele citaten uit de karakterisering deelstroomgebied Rijn-West, die de belasting door de scheepvaart onderschrijven:
– pagina 76 t.a.v. fluorantheen: “Tenslotte is een belangrijke bron de coating van de binnenvaartschepen (17 %)”
– t.a.v. benzo(k)fluorantheen: “Een andere bron die wordt geschat is de emissie uit de onderwateruitlaten van recreatievaartuigen (23 %)”
– t.a.v. benzo(a)pyreen: “de belangrijkste bron is de coating van de binnenvaartschepen (51 %)
– pagina 77: “verontreinigde waterbodems (samen met opwoeling door recreatie- en beroepsvaart) zijn in Rijn-West belangrijke overige belastingen”
– zie tevens het eerdere citaat inzake Diuron als anti-foulingsmiddel.
VRAAG
5. Is het DB met ondergetekende van mening dat scheepvaartdiensten ook voor kostenterugwinning in aanmerking zouden moeten komen?
Op 13 juli stelde ondergetekende een aantal vragen inzake de karakterisering van het Nederlandse Maastroomgebied. Gezien een zekere samenhang stel ik gezamenlijke beantwoording met deze brief op prijs.
Met vriendelijke groet,
L.H. van der Kallen
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