Water Framework Directive Implementation Research Articles

The goby fish Sicydium spp. as valuable sentinel species towards the chemical stress in freshwater bodies of West Indies

Implementation of the European Water Framework Directive in tropical areas such as the French West Indies (FWI) requires to select relevant aquatic sentinel species for investigating the ecological status of surface waters. The present work aimed to study the biological response of the widespread fish Sicydium spp. towards river chemical quality in Guadeloupe island through a set of proper biomarkers. During a 2-year survey, the hepatic EROD activity, the micronucleus formation and the level of primary DNA strand breaks in erythrocytes were measured respectively as an enzymatic biomarker of exposure and genotoxicity endpoints in fish living upstream and downstream of two chemically-contrasted rivers. Hepatic EROD activity was shown to be variable along the time but always significantly higher in fish from the most contaminated river (Rivière aux Herbes) compared to the low contaminated one (Grande Rivière de Vieux-Habitants). Fish size did not influence EROD activity. Female fish exhibited a lower EROD activity compared to males depending on the catching period. We observed significant temporal variation in micronucleus frequency and primary DNA damage level measured in fish erythrocytes that did not depend on the fish size. Micronucleus frequency and to a lesser extent DNA damage were significantly higher in fish from the Rivière aux Herbes compared to the Grande Rivière de Vieux-Habitants. Our results argue for the interest of using Sicydium spp. as sentinel species to assess river quality and chemical pressures in FWI.

Synergistic Use of Earth Observation Driven Techniques to Support the Implementation of Water Framework Directive in Europe: A Review

The development of a sustainable water quality monitoring system at national scale remains a big challenge until today, acting as a hindrance for the efficient implementation of the Water Framework Directive (WFD). This work provides valuable insights into the current state-of-the-art Earth Observation (EO) tools and services, proposing a synergistic use of innovative remote sensing technologies, in situ sensors, and databases, with the ultimate goal to support the European Member States in effective WFD implementation. The proposed approach is based on a recent research and scientific analysis for a six-year period (2017–2022) after reviewing 71 peer-reviewed articles in international journals coupled with the scientific results of 11 European-founded research projects related to EO and WFD. Special focus is placed on the EO data sources (spaceborne, in situ, etc.), the sensors in use, the observed water Quality Elements as well as on the computer science techniques (machine/deep learning, artificial intelligence, etc.). The combination of the different technologies can offer, among other things, low-cost monitoring, an increase in the monitored Quality Elements per water body, and a minimization of the percentage of water bodies with unknown ecological status.

Water governance diversity across Europe: Does legacy generate sticking points in implementing multi-level governance?

The Water Framework Directive (WFD) aims to protect and improve water quality across Europe through an integrative and multi-level water governance approach. The goal is to ensure that water quality in Europe meets good ecological status by 2027. Whilst the WFD has been hailed as a cornerstone for governance innovation in water management, most EU member states (MS) still struggle to achieve good ecological status of their waters. The realignment to a multi-level governance structure under the WFD is discretionary, and has generated diversity in WFD multi-level governance implementation approaches and final governance arrangements across MS. This diversity may contribute to low goal achievement and weak compliance. This paper investigates how visual impressions of legislative structure across nine MS can illustrate and contribute to understanding the differences in multi-level implementation of WFD and associated water protection directives. We explore, in-depth, the drivers of visual differences in Portugal, Germany (Lower Saxony) and France. We hypothesise that many of the challenges of WFD implementation, and resulting governance arrangements can be explained in terms of the legacy effects of previous water governance choices. With this conceptual framework of investigating the history and legacy, we found the three in depth studies have had different starting points, paths, and end points in their water governance, with sticking points influencing the decision-making processes and compliance required by the WFD. Sticking points include the complexity of existing water governance structures, lobbying by different sectors, and the mandatory WFD timeline for implementation. Portugal had to resolve its focus on water infrastructure and engineering to enable a re-focus on water quality. France and Portugal experienced 'top down' governance at different points in time, slowing the shift to a multi-level governance system. Lower Saxony, representing just one of 16 federal state systems in Germany, highlighted the complex historic governance structures which cannot easily be restructured, generating a layering effect where new governance systems are fitted to old governance systems. We conclude that there is a need to implement a hybrid approach to water governance and WFD implementation including decentralisation (discretionary) to ensure collaboration and engagement of stakeholders at the local level. This hybrid governance system should run in parallel with a centralised (mandatory) governance and regulatory system to enable national environmental standards to be set and enforced. Such systems may provide the best of both worlds (bottom-up involvement of stakeholders meeting top-down goal achievements) and is worthy of further research.

Ecosystem services’ capacity and flow in the Venice Lagoon and the relationship with ecological status

Ecosystem services (ES) are theoretically linked to healthy ecological conditions, but this relationship seems to be rather challenging to demonstrate in the real world. Therefore, shedding light on these aspects can be crucial for implementing effective ecosystem management strategies, for instance within the context of the EU Water Framework Directive (WFD) implementation. This work aims to present a spatially-explicit assessment of the ecological potential (capacity) and actual use (flow) of 12 ES in the Venice lagoon and to explore the relationships with the ecological status. Quantitative indicators of capacity and flow for each ES have been assessed and mapped and the results summarised with a set of aggregated indicators. The outcomes reveal a positive relationship between the overall capacity and flow of ES, suggesting that where the first is degraded, an overall loss of ES delivery occurs. A complex picture emerges when exploring the links with the ecological conditions, as the relationship changes with the ES and ecological status indicators considered. Structural indicators of ecological status, such as the Biological Quality Elements adopted by the WFD (assessed by MAQI and M-AMBI metrics), seem to be weakly linked with ES, while functional indicators (Kempton Q-90 diversity and secondary production) showed stronger links, especially when aggregated ES indicators are considered. Concerning different ES, it appears that the flow of the ES that are mediated by human uses (provisioning and cultural ES) is negatively related with some of the ecological status indicators. Finally, our results suggest possible limitations of the zonation adopted under the WFD, when it comes to the analysis of ES. We argue that ES could play a role in the management of the Lagoon ecosystem, as their analysis could be used to preserve the ecological functioning by managing the ‘uses’ we make of the ecosystem.

MODEL OF REGIONAL MANAGEMENT OF ECOLOGICAL AND ECONOMIC SYSTEMS OF FRESHWATER RESOURCES IN THE CONDITIONS OF SUSTAINABLE DEVELOPMENT

In this paper, the object of research is an innovative model of regional management of freshwater resources in the context of achieving environmental goals. The study found that the most problematic issues are the lack of clear criteria and methodological mechanisms in the formation of the basic innovative principles of freshwater resource management in the context of sustainable development. When solving the problems posed in the work, the methods of analysis and synthesis, comparative comparison and logical generalization were used. On their basis, the analysis of the main principles of adaptation of the world experience of regional management of freshwater resources in the context of the implementation of the European Union Water Framework Directive was carried out and the conceptual foundations for the formation of an innovative model for the management of freshwater resources of territories in the context of sustainable development were developed. A cluster model of a regional innovation-information portal of freshwater resources is proposed, which allows uniting the efforts of public authorities, the population, the public, scientific institutions and business in solving problematic issues related to the ecosystem based on smart technologies in the context of sustainable development. It is determined that for the functioning of the cluster model it is necessary to develop institutional, legislative, regulatory, scientific and innovative, investment support. It is substantiated that the functioning of the cluster model of the regional innovation-information portal of freshwater resources will solve the following problems:–creation of a unified data bank for monitoring the quality of water resources, the results ofscientific and technical activities, business planning and design for the conservation, restoration and purification of water;–information services in the field of innovation;–attraction of business representatives to co-financing of innovative projects.Thanks to the results of the conducted studies, it is possible to more objectively and balanced assess the possible schemes and tools for managing the territory’s freshwater resources. The conceptual approach presented in the paper is a rather flexible tool with a free choice of elements of analysis depending on the goals and objects of management.

Pesticides and their metabolites in European groundwater: Comparing regulations and approaches to monitoring in France, Denmark, England and Switzerland

Pesticides, i.e. plant protection products (PPP), biocides and their metabolites, pose a serious threat to groundwater quality and groundwater dependent ecosystems. Across large parts of Europe these compounds are monitored in groundwater to ensure compliance with the European Water Framework Directive (WFD), the Groundwater Directive (GWD) and Drinking water Directive (DWD). European regulation concerning the placing of PPP on the market includes groundwater monitoring as a higher tier of the regulatory procedure. Nevertheless, the lists of compounds to be monitored vary from one directive to another and between countries. The implementation of monitoring strategies for these directives and other national drivers, differs across Europe. This is illustrated using case studies from France, Denmark (EU member states), England (part of the EU up to January 2020) and Switzerland (associated country). The collection of data (e.g. monitoring design and analytical approaches) and dissemination at national and European level and the scale of data reporting to EU is country-specific. Data generated by the implementation of WFD and DWD can be used for retrospective purposes in the context of PPP registration whereas the post-registration monitoring data generated by the product applicants are generally only directly available to the regulators. This lack of consistency and strategic coordination between thematic regulations is partly compensated by national regulations. This paper illustrates the benefits of a common framework for regulation in Europe but shows that divergent national approaches to monitoring and reporting on pesticides in groundwater makes the task of assessment across Europe challenging.

Coordination across the policy cycle: Uncovering the political economy of river basin management in Spain

Coordination in the public sector among interdependent policies is considered crucial for their effectiveness. However, while coordination has been studied for decades, conceptual approaches to understand the functional and temporal dimensions of policy coordination are lacking. This paper attempts to address these gaps by integrating governance functions and action situations into the analysis of the policy cycle, thereby introducing the notion of holistic coordination. We argue that this approach is useful to get a more differentiated understanding of where and why coordination across the policy cycle breaks down, and to capture the political economy of policy-making. Empirically, we undertake an illustrative case study of the European Union (EU) Water Framework Directive (WFD) implementation in the Guadalquivir river basin, Spain, focusing on measures to reduce agricultural water consumption. We find that the failure to reach agreed policy objectives of reduction of water consumption can be traced back to the way governance functions were addressed and coordinated within action situations and across the overall policy cycle. Furthermore, the analysis shows that the lack of holistic coordination can be seen as an outcome of deliberate decisions by public actors involved in the policy, taken already at the beginning of the policy cycle. Thereby, expected benefits that agricultural water users associated with the policy have been deliberately increased, while their related expected costs have been decreased. Ultimately, this made the policy objective to reduce agricultural water consumption less credible and the policy more acceptable to water users and a powerful agricultural lobby.

Development of innovative model of regional management of freshwater resources in conditions of sustainable development

In this paper, the object of research is an innovative model of regional management of freshwater resources in the context of achieving environmental goals. The study found that the most problematic issues are the lack of clear criteria and methodological mechanisms in the formation of the basic innovative principles of freshwater resource management in the context of sustainable development. When solving the problems posed in the work, the methods of analysis and synthesis, comparative comparison and logical generalization were used. On their basis, the analysis of the main principles of adaptation of the world experience of regional management of freshwater resources in the context of the implementation of the European Union Water Framework Directive was carried out and the conceptual foundations for the formation of an innovative model for the management of freshwater resources of territories in the context of sustainable development were developed. A cluster model of a regional innovation-information portal of freshwater resources is proposed, which allows uniting the efforts of public authorities, the population, the public, scientific institutions and business in solving problematic issues related to the ecosystem based on smart technologies in the context of sustainable development. It is determined that for the functioning of the cluster model it is necessary to develop institutional, legislative, regulatory, scientific and innovative, investment support. It is substantiated that the functioning of the cluster model of the regional innovation-information portal of freshwater resources will solve the following problems: – creation of a unified data bank for monitoring the quality of water resources, the results of scientific and technical activities, business planning and design for the conservation, restoration and purification of water; – information services in the field of innovation; – attraction of business representatives to co-financing of innovative projects. Thanks to the results of the conducted studies, it is possible to more objectively and balanced assess the possible schemes and tools for managing the territory's freshwater resources. The conceptual approach presented in the paper is a rather flexible tool with a free choice of elements of analysis depending on the goals and objects of management.

Ecosystem Service Assessments within the EU Water Framework Directive: Marine Mussel Cultivation as a Controversial Measure

To combat the persistent eutrophication in coastal waters, sustainable sea-based measures are recommended. Yet, they are the subject of controversial stakeholder discussion, which hampers the implementation and planning process. The aim of this study is to evaluate if a participatory mapping (PM) approach and ecosystem service assessments (ESA) can be suitable tools within Water Framework Directive (WFD) implementation to support the communication with different target groups to improve and accelerate the planning and realization of new sea-based mitigation measures. We conducted three stakeholder-based PMs to visualize the perception of sea-based mitigation measures in coastal waters and seven different ESAs to investigate the perceptions of different mussel cultivation scenarios as mitigation measures. The PMs showed that ecological measures were preferred. The ESA approach showed that, while experts rated mussel cultivation scenarios positively overall, non-expert stakeholders still seemed skeptical and preferred alternative measures like floating wetlands. The methodological results indicate that PM can be a cost-effective tool to visualize stakeholders’ perceptions, but it needs to be applied with an ESA to be beneficial for the WFD implementation process. A web-based ESA improves the discussion with stakeholders and can reveal potential misperceptions and concerns faster and lead to a more focused discussion.

Sharing of EDF's experiences on the implementation of the European Water Framework Directive

Sharing of EDF's experiences on the implementation of the European Water Framework Directive

European work to support the implementation of the European Water Framework Directive and the Floods Directive

European work to support the implementation of the European Water Framework Directive and the Floods Directive

The implementation of the European Water Framework Directive - What were the challenges?

The implementation of the European Water Framework Directive - What were the challenges?

Do investments in water quality and habitat restoration programs pay off? An analysis of the chemical and biological water quality of a lowland stream in the Zwalm River basin (Belgium)

Early nineties of previous century aquatic biodiversity was low in many West-European countries as a consequence of pollution, hydromorphological degradation and a lack of sound environmental legislation. Since the early 2000s and the implementation of the European Water Framework Directive a big step forward has been made to achieve a good ecological status of surface waters in Europe. However, to date little is known about the response of biological life in small lowland streams on improving conditions for both water quality and habitat diversity. In this study, we assessed possible relationships between chemical water quality and aquatic biodiversity of the Zwalm River basin (Belgium) using a dataset of long-term measurements of the chemical and biological water quality. Specifically, we wanted to know 1) the evolution in chemical and biological water quality over the last three decades and 2) if an improvement in chemical water quality was reflected in the macroinvertebrate and fish diversity. We found that there was indeed a significant improvement in the chemical water quality thanks to the installation of wastewater treatment plants and river basin management plans. Shortly after this improvement in chemical water quality, an increase in the number and abundance of pollution sensitive macroinvertebrate taxa was observed, which was consequently also seen in the biotic index score, based on macroinvertebrates. Despite a limited change in community composition observed for fish, no significant increase in diversity, or in the biotic index score of fish could be found. Currently, a stagnation of the improving water quality is observed. Hydromorphological restoration and free fish migration remain important key factors to improve diversity of macroinvertebrates and fish species. Based on the results of this study, we provide guidelines (for example restoration of spawning beds, decrease diffuse pollution from agriculture) to optimize the investments made in river restoration and to achieve the good ecological status by 2027 as defined by the European Water Framework Directive.

The achievement of Water Framework Directive goals through the restoration of vegetation in agricultural canals

Decreasing nitrate concentrations is one of the most relevant Water Framework Directive (WFD) goals, which today is still unreached in several European countries. Vegetated canals have been recognized as effective filters to mitigate nitrate pollution, although rarely included in restoration programs aimed at improving water quality in agricultural watersheds.The Po di Volano basin (713 km2, Northern Italy) is a deltaic territory crossed by an extensive network of agricultural canals (~1300 km). The effectiveness in buffering nitrate loads via denitrification was assessed for different levels of in-stream emergent vegetation maintenance by employing an upscale model based on extensive datasets of field measurements. The scenarios differed for the canal network length (5%, 20%, 40%, and 60%) where conservative management practices were adopted by postponing the mowing operations from the middle of summer, as nowadays, to the early autumn, i.e., the vegetative season end.The scenario simulations demonstrated that the capacity to mitigate diffuse nitrate pollution would increase up to four times, compared to the current condition (5% scenario), by postponing the vegetation mowing to the end of the vegetative season in 60% of the canal network length. By preserving the in-stream vegetation in 20% of the canal network, its denitrification capacity would equal the nitrate load reduction target required for achieving, from May to September, the good ecological status according to the WFD in waters delivered to the coastal areas. Changing the timing of vegetation mowing may create a large potential for permanent nitrate removal via denitrification in agricultural landscapes, thus protecting the coastal areas when the eutrophication risk is higher. Conservative management practices of in-stream vegetation might be promoted as an effective low-cost tool to be included in the WFD implementation strategies.

Adapting participatory processes in temporary rivers management

The European Water Framework Directive (WFD) mandates to incorporate the participation of stakeholders and the general public in the development and updating of the river basin management plans. So far, the WFD implementation has been mainly focused on perennial rivers without considering temporary rivers properly, neither in biomonitoring programs nor participatory processes. This paper aims at adapting participatory processes in river basin management to enhance the inclusion of ecosystems with poor or no social recognition such as temporary rivers. To do so, we examined previous experiences of participatory processes conducted in the WFD and adapted them to propose and implement an approach for promoting stakeholders’ engagement in temporary rivers. The approach is based on a collaborative leadership, includes multiple participatory engagement mechanisms, uses future global change scenarios and the concept of ecosystem services at different stages of the process, and aims at involving stakeholders not only in the proposal of measures stage but in the diagnosis of the ecological status. It also includes an evaluation of participants’ satisfaction on the process. We tested our approach in temporary rivers from the Mediterranean region. We found that the combination of environmental education and citizen science activities, together with the inclusion of the ecosystem services concept, was the most useful way to raise awareness on the biodiversity and ecological value of temporary rivers and to promote stakeholders’ engagement. Workshops conducted during the diagnosis stage played an important role in both including stakeholders’ suggestions and increasing their knowledge on temporary rivers. Further, envisaging climate-related future scenarios allowed participants to incorporate measures that could tackle new and emerging pressures on these ecosystems. As future environmental changes will increase the proportion of rivers with temporary flow regimes, our approach can contribute to adapt current participatory processes to future needs.

Groundwater quality trend and trend reversal assessment in the European Water Framework Directive context: an example with nitrates in Italy

Groundwater resources are of utmost importance in sustaining water related ecosystems, including humans. The long-lasting impacts from anthropogenic activities require early actions, owing to the natural time lag in groundwater formation and renewal. The European Union (EU) policy, within the implementation of the Water Framework Directive (WFD), requires Member States to identify and reverse any significant and sustained upward trend in the concentration of pollutants, defining specific protection measures to be included in the River Basin Management Plans (RBMP). In Italy, official guidelines for trend and trend reversal assessment have been published recently. Statistical methods, such as the Mann-Kendall test for trend analysis and the Sen’s method for estimating concentration scenarios, should be applied at the fixed terms stated by the WFD implementation cycles to identify upward trends, while the Pettitt test is proposed for the identification of trend reversal. In this paper, we present an application of a slightly modified version of the Italian Guidelines to a groundwater body in Northern Italy featuring nitrate pollution and discuss its advantages and limitations. In addition to Pettitt test, for the trend reversal analysis, we apply the Mann-Kendall test in two sections and compare the results. We conclude that this method seems more reliable than Pettitt test to identify a reversal point in quality time series. The overall procedure can be easily applied to any groundwater body defined at risk across Europe, for the assessment of the upward trends of pollutants and their reversal, even with little chemical monitoring data. Although focused on the EU legislative framework, this procedure may be relevant for a wider context, allowing to individuate upward trend as early warning for contamination processes in an integrated water resources management context.

Water Values: Participatory Water Ecosystem Services Assessment in the Arno River Basin, Italy

Water-related Ecosystem Services (WES), namely the multiple benefits that humans can obtain from water or water-related functions of an ecosystem, constitute a useful perspective to look at the overlap between biosphere and anthroposphere and to explore their sustainable coupling. On one hand, society acts as a driver of landscapes transformation, influencing the ecohydrological processes that underpin a large set of potential WES. On the other hand, society is the recipient of the WES provided by ecosystems, determining the actual production of services. Aiming at exploring the ecosystem-water-society nexus, this study develops a 4-tiered methodology for the participatory evaluation of WES as a basis to facilitate a shared watershed planning process in the Arno river basin (Central Italy), carried out within the framework of the Tuscany Regional Law for participation. Starting from the biophysical assessment of the study area and the analysis of the population, multiple focus groups were organized to allow the participatory evaluation of WES, mainly targeting low impact stakeholders. The proposed approach allowed the WES mapping and the identification of valuable WES characterised by a critical status. These results served as the basis for the analysis of multiple scenarios and the co-definition of a shared management strategy, jointly with decision makers. The analysis highlights the potential of WES concept as a suitable common language for developing participatory processes that support integrated water resources management. The proposed participatory WES assessment approach can sustain the active involvement of all interested parties in Water Framework Directive implementation (Art.14) and foster a wider policy objective of sustainability through the management plans.

Including sediment in European River Basin Management Plans: twenty years of work by SedNet

PurposeThis paper describes the efforts made by SedNet—the European Sediment Network—to generate attention for the inclusion of sediment in River Basin Management Plans (RBMPs) under the European Water Framework Directive (WFD).Materials and methodsThe SedNet response to key WFD implementation events is described using the “three-streams and windows-of-opportunities model” published by John Kingdon in 1995.Results and discussionSedNet was initially a response to the realization that the WFD—which came into force in 2000—largely neglected sediment. For SedNet, it was clear from the beginning that the WFD objectives can be achieved only if sediment is included in RBMPs. The SedNet efforts inspired the establishment of a sediment management concept for the Elbe river basin. That concept was used as a basis for the full inclusion of sediment in the second Elbe RBMP (2015–2021). SedNet experts are currently involved in the drafting of the WFD Common Implementation Strategy (CIS) sediment document which will be completed in 2021 and that will provide guidance about how to include sediment in RBMPs.ConclusionsSince 2000, SedNet has persistently drawn attention to the need to include sediment in RBMPs. However, it was not until 2015 that the Elbe became the first European river basin to include sediment management fully in their RBMP. The 2021 WFD CIS sediment document and the focus on sediment in the Water Fitness Check in 2019 make it significantly more likely that the sediment will be included in the updates of WFD RBMPs in the near future.

The Design of Pricing Policies for the Management of Water Resources in Agriculture Under Adverse Selection

Water pricing policy for irrigated agriculture is considered as a key issue in the Water Framework Directive (WFD) implementation. The main obstacle is that a large part of the water used in agriculture is unmetered. The objective of this study is to assess the Water Authorities (WA)’s choices between different options of incentive pricing policies (IPP) and to evaluate their economic performance compared with flat rate (FR) solutions. The applied method relies on a principal-agent model under adverse selection, in which WAs are less informed than farmers about the water use costs and profits. In this respect, the paper provides a theoretical interpretation of how different information conditions, profit and cost structures contribute to affecting WAs’ pricing strategies and their ability to deal with some of the WFD principles. The study shows that, in the absence of water metering, WAs can still set up incentive pricing strategies by formulating menus of contracts that are more efficient than flat rate payments. Also, we show that, at least for cases in which there is only a small differentiation in water costs among farmers or no transaction costs, the first-best solution (the solution that yields the highest return from the use of the resource) can also be optimal under asymmetric information. The main policy recommendation is that, in the absence of water metering, a wider set of incentive pricing options should be considered, the performance of which, however, should be evaluated based on the specificities of each irrigated region.

A Fuzzified Multicriteria Outranking Method for Water Framework Directive Implementation in a Heavily Modified Urban Lake (Pamvotis, Greece)

Freshwater ecosystems deliver various ecosystem services providing essential goods and services, on which humans depend. These include vital provision of water for domestic, agricultural and industrial use. Lake Pamvotis, a heavily modified urban lake is providing multiple services but at the same time is under multiple pressures. Setting as target the achievement of the Water Framework Directive (WFD) “Good Ecological Status or Potential” goal and acknowledging the revised River Basin Management Plan’s Program of Measures, a set of six alternatives is suggested. For the preferable alternatives’ selection, six criteria were adopted whose relations are given through a Driving Forces – Pressure - State-Impact - Responses (DPSIR) conceptual model. Qualitative judgments based on expert opinion are selected to describe the scores of the criteria which are finally evaluated as fuzzy numbers. A hybrid method which incorporates the outranking relation and the right of veto of the ELECTRE III method, and finally the net flow of the PROMETHEE method is developed. The proposed method is based on fuzzy sets and logic in order, firstly to interpret both the monocriterion comparison and the aggregation among the criteria and secondly to enable the evaluation of the criteria with fuzzy scores. The results prioritized the increase of the water quality for the improvement of water related ecosystem services among the other alternatives in all tests. The proposed method is suitable for environmental problems where the evaluation of the scores is not crisp and furthermore, commensurate alternatives are demanded.