Comment on "Rainfall erosivity in Europe" by Panagos et al. (Sci. Total Environ., 511, 801-814, 2015).

Recently a rainfall erosivity map has been published. We show that the values of this map contain considerable bias because (i) the temporal resolution of the rain data was insufficient, which likely underestimates rain erosivity by about 20%, (ii) no attempt had been included to account for the different time periods that were used for different countries, which can modify rain erosivity by more than 50%, (iii) and likely precipitation data had been used instead of rain data and thus rain erosivity is overestimated in areas with significant snowfall. Furthermore, the seasonal distribution of rain erosivity is not provided, which does not allow using the erosivity map for erosion prediction in many cases. Although a rain erosivity map for Europe would be highly desirable, we recommend using the national erosivity maps until these problems have been solved. Such maps are available for many European countries.