EUROPEAN COMMISSION Brussels, 26.2.2019 SWD(2019) 44 final COMMISSION STAFF WORKING DOCUMENT Second River Basin Management Plans - Member State: Luxembourg Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of the Water Framework Directive (2000/60/EC) and Floods Directive (2007/60/EC)

Second River Basin Management Plans

First Flood Risk Management Plans

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Table of contents Acronyms Foreword General Information Status of second river basin management plan reporting Key strengths, improvements and weaknesses of the second River Basin Management Plan(s) Recommendations Topic 1 Governance and public participation 1.1 Assessment of implementation and compliance with WFD requirements in the second cycle 1.2 Main changes in implementation and compliance since the first cycle 1.3 Progress with Commission recommendations Topic 2 Characterisation of the River Basin District 2.1 Assessment of implementation and compliance with WFD requirements in the second cycle 2.2 Main changes in implementation and compliance since the first cycle 2.3 Progress with Commission recommendations Topic 3 Monitoring, assessment and classification of ecological status in surface water bodies 3.1 Assessment of implementation and compliance with WFD requirements in the second RBMP 3.2 Main changes in implementation and compliance since the first RBMP 3.3 Progress with Commission recommendations

Topic 4 Monitoring, assessment and classification of chemical status in surface water bodies 4.1 Assessment of implementation and compliance with WFD requirements in the second cycle 4.2 Main changes in implementation and compliance since the first cycle 4.3 Progress with Commission recommendations Topic 5 Monitoring, assessment and classification of quantitative status of groundwater bodies 5.1 Assessment of implementation and compliance with WFD requirements in the second cycle 5.2 Main changes in implementation and compliance since the first cycle 5.3 Progress with Commission recommendations Topic 6 Monitoring, assessment and classification of chemical status of groundwater bodies 6.1 Assessment of implementation and compliance with WFD requirements in the second cycle 6.2 Main changes in implementation and compliance since the first cycle 6.3 Progress with Commission recommendations Topic 7 Designation of Heavily Modified and Artificial Water Bodies and definition of Good Ecological Potential 7.1 Assessment of implementation and compliance with WFD requirements in the second cycle for designation 7.2 Main changes in implementation and compliance since the first cycle 7.3 Progress with Commission recommendations Topic 8 Environmental objectives and exemptions 8.1 Assessment of implementation and compliance with WFD requirements in the second cycle and main changes in implementation and compliance since the first cycle 8.2 Progress with Commission recommendations Topic 9 Programme of measures

9.1 Assessment of implementation and compliance with WFD requirements in the second cycle 9.2 Main changes in implementation and compliance since the first cycle 9.3 Progress with Commission recommendations Topic 10 Measures related to abstractions and water scarcity 10.1 Assessment of implementation and compliance with WFD requirements in the second cycle 10.2 Main changes in implementation and compliance since the first cycle 10.3 Progress with Commission recommendations Topic 11 Measures related to pollution from agriculture 11.1 Assessment of implementation and compliance with WFD requirements in the second cycle 11.2 Main changes in implementation and compliance since the first cycle 11.3 Progress with Commission recommendations Topic 12 Measures related to pollution from sectors other than agriculture 12.1 Assessment of implementation and compliance with WFD requirements in the second cycle 12.2 Main changes in implementation and compliance since the first cycle 12.3 Progress with Commission recommendations Topic 13 Measures related to hydromorphology 13.1 Assessment of implementation and compliance with WFD requirements in the second cycle 13.2 Main changes in implementation and compliance since the first cycle 13.3 Progress with Commission recommendations Topic 14 Economic analysis and water pricing policies

14.1 Assessment of implementation and compliance with WFD requirements in the second cycle and main changes in implementation and compliance 14.2 Progress with Commission recommendations Topic 15 Considerations specific to Protected Areas (identification, monitoring, objectives and measures) 15.1 Assessment of implementation and compliance with WFD requirements in the second cycle 15.2 Main changes in implementation and compliance since the first cycle 15.3 Progress with Commission recommendations Topic 16 Adaptation to drought and climate change 16.1 Assessment of implementation and compliance with WFD requirements in the second cycle 16.2 Main changes in implementation and compliance since the first cycle 16.3 Progress with Commission recommendations Acronyms and definitions EQS Directive Environmental Quality Standards Directive FD Floods Directive Km Kilometre km2 Kilometre squared KTM Key Type of Measure PoM Programme of Measures QA/QC Directive Quality Assurance / Quality Control Directive RBD River Basin District RBMP River Basin Management Plan WFD Water Framework Directive WISE Annex 0 Water Information System for Europe Member States reported the structured information on the second RBMPs to WISE ( Water Information System for Europe ). Due to the late availability of the reporting guidance, Member States could include in the reporting an Annex 0, consisting of a short explanatory note identifying what information they were unable to report and the reasons why. This Annex was produced using a template included in the reporting guidance. If Member States reported all the required information, this explanatory note was not necessary.



Foreword The Water Framework Directive (WFD) (2000/60/EC) requires in its Article 18 that each Member State (MS) reports its River Basin Management Plan(s) (RBMPs) to the European Commission. The second RBMPs were due to be adopted by the Member States in December 2015 and reported to the European Commission in March 2016. This Member State Assessment report was drafted on the basis of information that was reported by Member States through the Water Information System for Europe (WISE) electronic reporting. The Member State Reports reflect the situation as reported by each Member State to the European Commission in 2016 or 2017 and with reference to River Basin Management Plans (RBMP) prepared earlier. The situation in the Member States may have changed since then.





General Information Map A Map of River Basin Districts Source: WISE, Eurostat (country borders) International River Basin Districts (within European Union) International River Basin Districts (outside European Union) National River Basin Districts (within European Union) Countries (outside European Union) Coastal Waters The Grand Duchy of Luxembourg is surrounded by Belgium, France and Germany. The total population is 0.5 m and the total surface area is 2.597 km2. Most of Luxembourg (97.3 %2) belongs to the international Rhine RBD, or Moselle-Saare sub-basin of the Rhine RBD. The remaining 2.7 % (73 km2) are part of the international Meuse RBD. There are seven sub-basins (so-called ‘study areas’), six of these belonging to the Rhine RBD. There is one national RBMP covering both the Rhine and Meuse RBD. There are no sub-basin or other sectoral plans. The information on areas of the national RBDs including sharing countries is provided in the following table: Table A Overview of Luxembourg’s River Basin Districts RBD Name Size (km2) Countries sharing RBD LU000 (also LU 000) Rhine 2525 (AT), BE, CH, DE, FR, (IT), (LI), NL LU001 (also LU 001) Meuse 73 BE, DE, FR, NL Source: RBMPs reported to WISE. Luxembourg subsequently noted that the countries in brackets share the LU000 RBD. The share of Luxembourg in the respective international RBDs is 1 % (Rhine), and 0.2 % (Meuse). Table B: Transboundary RBDs by category and % share in Luxembourg RBD Name National RBD Countries sharing RBD Co-ordination category 1 km² % Rhine LU RB_000 (AT), BE, CH, DE, FR, (IT), (LI), NL 2525 1.0 Meuse LU RB_001 BE, DE, FR, NL 73 0.2 Source: WISE electronic reporting. Luxembourg subsequently noted that the countries in brackets share the LU000 RBD.

Category 1: International agreement, permanent co-operation body and international RBMP in place. Category 2: International agreement and permanent co-operation body in place. Category 3: International agreement in place. Category 4: No co-operation formalised.



Status of second river basin management plan reporting One RBMP for Luxembourg (Rhine, Meuse) was published on 22 December 2015. Documents are available from the European Environment Agency EIONET Central Data Repository https://cdr.eionet.europa.eu/

Key strengths, improvements and weaknesses of the second River Basin Management Plan The main strengths and shortcomings of the second RBMP of Luxembourg are as follows: ·Governance and public consultation Luxembourg involved stakeholders through the establishment of advisory groups. Luxembourg has cooperated closely with neighboring Member States and others in the international RBDs it shares via the international commissions for water management as well as bilateral agreements. ·Characterisation of the RBD All the national types for Luxembourg appear to have corresponding intercalibration types. Type specific reference conditions were established for all biological and physicochemical quality elements. Type specific reference conditions were not reported for hydromorphological quality elements, but Luxembourg reported that it applied a German methodology and related all the national river types to a LAWA-type of the German typology. Therefore each Luxembourgish river type has its correspondent reference conditions defined by the German LAWA type. For surface water and groundwater bodies, significance of pressures is linked to the potential failure of objectives and defined in terms of thresholds. For the second RBMP, a relatively high number of pressures were not reported (39 for surface waters, and 53 for groundwater) as Luxembourg did not use the same level of detail used in WISE reporting and information could not be provided at this more detailed level. The significance of pressures affecting some surface water bodies (point sources, diffuse, abstraction and other significant pressures) has been determined mainly by expert judgment and no quantitative tools were used. The same was true for diffuse and point source pressures in groundwater, where only expert judgement was used. This may indicate potential shortcomings in the assessment of these pressure types. The reduction in pressures required to achieve environmental objectives has not been adequately assessed and the measures to tackle Priority Substances causing failure to achieve good status have not been reported. Luxembourg reported that all Priority Substances were included in the inventories for each RBD. They carried out a simple assessment (tier 1 point source information) for substances not relevant at RBD level, and a much more thorough assessment (all 4 tiers) for substances relevant at RBD level, as recommended by the CIS Guidance Document n°28. The quality of the input data is assessed as medium in all cases. ·Monitoring, assessment and classification of ecological status The number of operational monitoring sites increased significantly since the first RBMP in the Rhine RBD, while the number of surveillance sites decreased slightly. There were no changes in numbers in the Meuse RBD.

According to the data reported to WISE, there would still be one gap in the elements monitored: fish in rivers in Meuse RBD. Of the five biological quality elements used for the surveillance monitoring of rivers, four were sampled with at least the minimum recommended frequency. However, this was the case for only one of the five biological quality elements used in the operational monitoring of rivers. Information on how the River Basin Specific Pollutants were selected was provided, and they were monitored at least at the minimum recommended frequency at all surveillance monitoring sites, but they were not monitored at the minimum recommended frequency in all of the operational monitoring sites. Environmental Quality Standards have been set for 54 River Basin Specific Pollutants in water for rivers, but none of them was derived in accordance with the Technical Guidance Document No 27. For all substances, the analytical methods are in line with Article 4(1) or Article 4(2) of the Quality Assurance/Quality Control Directive (QA/QC Directive) (2009/90/EC) for the strictest standard applied. The water bodies used for surveillance monitoring in the Rhine RBD were monitored for all required biological quality elements and physicochemical quality elements. None of the water bodies included in surveillance monitoring was reported as having been monitored for all required hydromorphological quality elements. ·Monitoring, assessment and classification of chemical status in surface water bodies Luxembourg monitors all 41 Priority Substances in water and monitoring frequencies are reported for each of these at the site level in both Luxembourgish RBDs. These frequencies meet the frequency requirements according to the WFD for surveillance monitoring in both RBDs but not for operational monitoring in the Rhine RBD. A very small proportion of the total number of monitoring sites (3 %) are reported to be used for monitoring chemical status corresponding to a total of 13 out of 110 river water bodies in the two RBDs in Luxembourg (12 in the Rhine RBD and one in the Meuse RBD). Only 12 % of water bodies at poor chemical status were reported to be monitored in Luxembourg as a whole as part of the operational monitoring programme. Luxembourg subsequently clarified that it only reported to WISE the sites where all priority substances have been monitored. Monitoring has been carried out also at other sites, either only for some of the priority substances, or at a frequency not in line with the provisions of the WFD. These other sites haven’t been reported to WISE, although the monitoring results were used to assess chemical status. Monitoring of sediment and biota for status and trend assessment is not reported in the second RBMP. However, Luxembourg uses alternative standards for mercury, hexachlorobenzene and hexachlorobutadiene in water for the assessment of status. Luxembourg also monitors suspended sediment at one strategic location as part of an international monitoring programme for trend assessment. According to the Luxembourgish authorities, monitoring of biota and sediment has started and will be reported in the next RBMP. All river water bodies fail to achieve good chemical status in the second RBMP due to the widespread occurrence of polycyclic aromatic hydrocarbons. The classification of chemical status is underpinned by monitoring for 11 % and 33 % of river water bodies in the Rhine and Meuse RBDs, respectively, with the remainder classified by expert judgement. This is reflected in the confidence assigned to the classification: Overall 12 % of surface water bodies in Luxembourg were classified for chemical status with high confidence and 88 % of surface water bodies were classified with low confidence. Overall in Luxembourg between the two cycles, there was a large decrease in the proportion of surface water bodies with good chemical status from 70 to 0 % and a significant increase in the proportion failing to achieve good status from 30 to 100 %. The change is largely accounted for by an improvement in the monitoring programmes and the extrapolation of those results to all river water bodies. ·Environmental objectives and exemptions Environmental objectives for ecological and chemical status of surface water bodies have been reported for both RBDs and for chemical and quantitative status of groundwater in the Rhine RBD. The number of Article 4(4) exemptions has increased. Although this can inter alia be explained by the re-classification of all surface waters being in poor chemical status, the number remains significant, particularly also with regard to ecological status of surface water bodies. ·Monitoring, assessment and classification of quantitative status of groundwater bodies There is still a gap in monitoring since one out of the six groundwater bodies has no monitoring. Luxembourg clarified however, that a monitoring site is already operational and will be integrated in the monitoring network by 2019. ·Monitoring, assessment and classification of chemical status of groundwater bodies Due to an error in the electronic reporting, there is an indication that there is no operational monitoring even though four out of six groundwater bodies are at risk of failing good chemical status and not all WFD core parameters are monitored. Luxembourg subsequently clarified that in fact the number of surveillance monitoring sites remained at 31 for the first and second RBMP and also operational monitoring is performed at these sites. It was also clarified that from the WFD core parameters only dissolved oxygen is not systematically monitored due to concerns of the representativity for measures, especially in springs.

·Designation of Heavily Modified and Artificial Water Bodies and definition of Good Ecological Potential The methodology for the designation of heavily modified water bodies has not been modified since the first cycle, but the designations have been reviewed based on the availability of better hydromorphological structural quality mapping of all surface (river) waters, measures in progress, and results of new investigations concerning feasibilities of re-naturalisation actions. In addition, descriptions of the assessment of significant adverse effects of restoration measures and of other means to deliver the benefits of the modifications are provided for each heavily modified water body, although they remain general and do not use any quantified criteria as a basis. For the second cycle, a method has been developed to define good ecological potential. Efforts have also been made do this in biological terms (for fish and benthic invertebrates), and mitigation measures are included in the detailed Programme of Measures. However, no information could be found on the ecological changes that the mitigation measures are designed to achieve in either qualitative or quantitative terms. According to information subsequently provided by Luxembourg, the definition of ecological potential and the mitigation measures permitting to achieve good ecological potential are under development and will be available for the third RBMP. ·Programme of Measures From WISE reporting it is not clear if Key Types of Measures (KTMs) are operational for all identified significant pressures. National basic and supplementary measures have been mapped against a wide range of KTMs. However, no information was provided on the KTMs to address significant pressures and therefore a comparison could not be made. There is no information in WISE, on KTMs used to tackle individual Priority Substances causing failure of objectives. There are no gap indicators or gap analyses for any of the reporting cycles. Therefore, it is not possible to measure progress in achieving WFD objectives. The objectives and requirements of the Floods Directive have been considered in the second RBMP and Programme of Measures: The design of new and existing structural measures has been adapted to take account of WFD environmental objectives, and clear financial commitments have been secured for the implementation of Programme of Measures in the flood protection sector. Although Luxembourg indicated that natural water retention measures have been included in the Programme of Measures, there is no evidence that such measures have been made operational. WFD Article 9(4) has not been applied to impoundments for flood protection. ·Measures related to abstractions and water scarcity Water abstraction pressures are not reported as relevant for Luxembourg, and the Water Exploitation Index + is not calculated. There is a concession, authorisation and/or permitting regime to control water abstractions and impoundments but no register of impoundments; and small abstractions are not exempted from these controls. Measures promoting efficient and sustainable water use (Basic Measure Article 11(3)(c)) were implemented in the previous cycle, and new measures and/or significant changes are planned for the 2016-2021 period. ·Measures related to pollution from agriculture There is a clear link between pressures from agriculture and measures taken. A gap assessment for nutrients and pesticides has not been undertaken in all RBDs. So far, five drinking water protection zones have been designated near groundwater bodies and further safeguard zones will be established. Luxembourg reported that financing of agricultural measures has been secured.



·Measures related to pollution from sectors other than agriculture

KTMs have been reported for the River Basin Specific Pollutants identified as causing failure. Information is missing from the RBMP on the number of basic and supplementary measures used to tackle pollution from non-agricultural sources, and links between the measures and pressures causing failure are not always presented. Information on the progress expected in implementing KTMs between 2015 and 2027 is also missing from the RBMP, and there is no evidence that a gap analysis has been undertaken for non-agricultural pollutant pressures. ·Measures related to hydromorphology The level of detail provided in the second RBMP on measures is far higher than in the first cycle. A catalogue of hydromorphological measures is used, which includes a semi-quantitative effectiveness assessment for each measure type on the different quality elements, as well as an indication of the relevance to the Floods Directive. The catalogue also includes the cost of the measures. However, for the largest share of water bodies affected by significant hydromorphological pressures, the specific sector linked to these pressures is either unknown or obsolete. Indicators on the gap to be filled for significant hydromorphological pressures and KTM value indicators are not reported, as the respective data was not available at the time of the WISE reporting. Ecological flows have not been derived for the relevant water bodies but there are plans to do it during the second cycle. A new supplementary measure is planned, namely to revise the Water Law to set minimum ecological flows. The implementation of measures on minimum flow is scheduled to take place by 2021. ·Economic analysis and water pricing policies No detailed information on the application of the polluter pays principle was reported. Information on the incentive function of water pricing is rather limited. ·A national approach for the calculation of cost recovery rates is used via a harmonised calculation method ·Considerations specific to Protected Areas (identification, monitoring, objectives and measures) A significant reduction in monitoring of water bodies associated with protected areas is reported for the second cycle compared to the first cycle, although this was related to an error in the information reported to WISE. The information in WISE did not include data on monitoring under the Birds, Habitats and UWWTD, which was reported under the obligations of those Directives. ·Adaptation to drought and climate change A climate check of the Programme of Measures has been made in the second cycle, while such a check was missing in the first cycle. No national Climate Change Strategy had been developed by the time the river basin management plan was published



Recommendations ·Luxembourg should focus on international cooperation, including coordinated assessments of the technical aspects of the Water Framework Directive. ·Luxembourg still needs to continue work on apportionment of pressures among sources, so that measures can be adequately targeted.

·Luxembourg should reduce the dependence on expert judgment for assessing the significance of pressures. ·The development of assessment methods should be completed for all quality elements and use them for the assessment of ecological status/potential for next RBMP. ·Luxembourg also should ensure that Environmental Quality Standards meet the minimum requirements for the protection of freshwater and marine ecosystems from possible adverse effects, as well as of human health. Luxembourg should complete the ongoing work on the establishment of nutrient thresholds that are sufficiently protective for good ecological status. Luxembourg should continue improving the confidence in the assessment of surface water chemical status. Luxembourg should also continue improving the operational monitoring for status assessment to reach sufficient spatial coverage and temporal resolution for all the relevant Priority Substances. If reduced frequencies are used, Luxembourg should provide the corresponding explanations, as required by the Directive. ·Luxembourg should ensure that the trend monitoring is up and running to ensure that all the relevant substances specified in Directive 2008/105/EC are monitored in order to provide sufficient data for long-term trend analysis. ·The designation of heavily modified water bodies needs to be further improved by Luxembourg by developing and applying clear criteria for significant adverse effects of restoration measures on the use or the wider environment and the lack of significantly better environmental options. This will improve the transparency of the designation process. Furthermore, a further refined methodology for the definition of ecological potential needs to be applied for the 3rd RBMP. ·A significant number of Article 4(4) exemptions remains to be applied in the second cycle. Although the WFD allows for exemptions, a thorough review of the assessment of technical feasibility and disproportionate costs is required. Efforts should be continued to ensure the implementation of an ambitious program of measures in order to ensure the timely achievement of the WFD objectives. ·It remains unclear whether there are any new physical modifications planned in Luxembourg. For the potential application of Article 4(7), Luxembourg needs to ensure a thorough assessment of possible new modifications in line with the requirements of the WFD and as further specified by the Judgment of the Court in case C-461/13. ·KTMs should be operational and cover all the pressures causing failure to objectives. In addition, all individual Priority Substances identified as causing failure should be associated with KTMs. ·Luxembourg should ensure that the RBMP clearly identifies the gap to good status, and that the Programme of Measures are designed and implemented to close that gap with transparent and meaningful information regarding the timing and the funding of the measures. ·Luxembourg should complete a comprehensive gap assessment for diffuse pollutant loads from agriculture (nutrients, agri-chemicals, sediment, organic matter) across all waters in all RBDs and link it directly to mitigation measures in the third RBMP (as per WFD Article 11(3)(h)), to facilitate the achievement of WFD objectives. ·Luxembourg should continue to review and develop a coherent strategy encompassing WFD with all relevant policies and instruments (e.g. RDP, CAP Pillar 1, Nitrates Directive, etc.) to achieve the WFD objectives, and enhance the technical feasibility of its next RBMPS, in cooperation with the farming community and Luxembourg CAP delivery authorities. ·A robust methodology should be implemented to identify River Basin Specific Pollutants and information on this methodology should be provided. It is strongly recommended to use the Technical Guidance for deriving EQSs. ·A gap analysis should be carried out as regards pollutants from non-agricultural sources, and the impact of the planned measures, such as improved urban waste water treatment, should be assessed, so that adequate supplementary measures can be identified and implemented where necessary. ·Luxembourg should ensure the implementation of ecological flows and all relevant hydromorphological measures during this second cycle. ·Luxembourg should apply cost recovery for water use activities having a significant impact on water bodies or justify any exemptions using Article 9(4). Luxembourg should continue to transparently present how financial, environmental and resource costs have been calculated and how the adequate contribution of the different users is ensured. It should also continue to transparently present the water-pricing policy and provide a transparent overview of estimated investments and investment needs. ·Luxembourg should continue the establishment of safeguard zones to protect drinking water sources in designated groundwater bodies until complete coverage of these zones is achieved.



Topic 1Governance and public participation 1.1Assessment of implementation and compliance with WFD requirements in the second cycle

1.1.1Administrative arrangements – RBDs Luxembourg belongs to two international RBDs, the Rhine and the Meuse. The Luxembourgish part of the international RBD Rhine is also called Moselle RDB and the Luxembourgish part of the international RBD Meuse is also called Chiers RBD. 1.1.2Administrative arrangements – competent authorities Luxembourg has reported two competent authorities. The Department of the Environment, Ministry for Sustainable Development and Infrastructure, is responsible for the enforcement of regulations and the coordination of implementation. The Water Management Agency is responsible for the monitoring and assessment of status of groundwater and surface water, economic analysis, pressure and impact analysis, preparation of the RBMP and Programme of Measures, public participation, implementation of measures and reporting to the European Commission. 1.1.3River Basin Management Plans – structure and Strategic Environmental Assessment. Luxembourg did not prepare sub-plans for its RBMP. The RBMP underwent a Strategic Environmental Assessment procedure. 1.1.4Public participation and active involvement of stakeholders The public and interested parties were informed by direct mailing, over the internet, invitations to stakeholders, media (papers, television and radio) and through meetings. Documents were available for the requisite six months and were available for download and also in paper copies at the Water Management Agency. The mechanisms for the active involvement of stakeholders were the establishment of advisory groups, and the formation of alliances. The stakeholder groups actively involved were: agriculture/farmers; local/regional authorities; NGOs/nature protection; water supply and sanitation; and municipal associations and river partnerships. The public consultation had the following impacts: addition of new information, adjustment to specific measures, changes to the selection of measures, and commitment to action in the next RBMP cycle. 1.1.5Integration with other European Union legislation: Floods Directive and Marine Strategy Framework Directive Luxembourg did not carry out joint consultation of its RBMP and Flood Risk Management Plan. 1.1.6International Coordination Luxembourg's two RBDs are both part of international RBDs: the Rhine and the Meuse. For both, an international agreement was in place and a permanent co-operation body; an international RBMP had been produced for the second cycle; and explicit links had been made with national RBMP within the international RBMP (designated as category 1 cooperation). However, Luxembourg reported that there was no international co-ordination on public participation. Luxembourg’s RBMP indicates that international co-operation related to the Rhine RBD takes place via the International Commission for the Protection of the Rhine (ICPR) and the International Commissions for the Protection of the Moselle and Saar (ICPMS), which covers a major sub-basin of the Rhine IRBD. The latter Commission is particularly important as it brings together Luxembourg and its three neighbouring Member States, France, Germany and Belgium (Wallonia). In1984, moreover, Germany and Luxembourg signed a new agreement for joint water management, including for the rivers Our, Sauer and Moselle, which form the border between the two Member States for a length of about 128 km. A first agreement has already been signed in 1816. In the Meuse international RBD co-operation took place under the international Meuse Commission (IMC). For further information see the reports on international coordination on the Water Framework Directive.

1.2Main changes in implementation and compliance since the first cycle The information reported to WISE does not indicate any major changes concerning Governance topics. 1.3Progress with Commission recommendations The Commission recommendations based on the first RBMP and Programme of Measures requested action on the following:

·Recommendation: Improve the reporting into the WISE to reflect the information in the RBMPs. Assessment: In comparison with the first cycle, when reporting to WISE was incomplete and often duplicated information for the two RBDs, Luxembourg’s reporting to WISE for the second cycle appears to be complete: the following chapters have not identified gaps in reporting to WISE. Moreover, Luxembourg has reported separately for its two RBDs. Luxembourg has fulfilled this recommendation. ·Recommendation: The RBMPs should be clearly structured and accessible to the public and relevant stakeholders. It would also be advisable to clearly distinguish the information and the measures that are relevant for the Rhine RBD, for the Meuse or for both. This transparency within a clear governance structure will encourage public participation in both the development and delivery of necessary measures to deliver sustainable water management. Assessment: The RBMP is clearly structured. The information relevant to the Rhine and Meuse RBDs is clearly distinguished in many cases where there are differences between the two RBDs. Although the PoM (Section 9 of the RBMP) focuses mainly on the national level in the RBD, tables list measures against surface water body codes, so it is possible to work out whether they belong to the Rhine or Meuse RBDs; moreover, Annex 20 of the RBMP provides details of measures separately for the Rhine and Meuse RBDs. Luxembourg has fulfilled this recommendation.



Topic 2Characterisation of the River Basin District 2.1Assessment of implementation and compliance with WFD requirements in the second cycle 2.1.1Delineation of water bodies and designation of heavily modified and artificial water bodies Overall the number of river water bodies ( Table 2.1 ) and groundwater bodies ( Table 2.2 ) remained largely constant between the first and second cycles. There was only one extra groundwater body and an 8 % increase in river water bodies in the Rhine RBD. Updates to the delineation involved: changes in the length and size of the catchment for some river water bodies; some divisions and some joining of river water bodies; two new surface water bodies; and the division of one groundwater body into two (Table 2.3). Table 2.1 shows the differences in size distribution of surface water bodies in Luxembourg between the second and first cycles. However, the lengths of rivers were not reported for the first cycle. The minimum size criteria reported was 0.5 km2 surface area for lakes but no minimum size was reported for river catchments. The reasons for delineation of surface water bodies provided in the RBMP were: comments from the European Commission, correcting errors in geographical boundaries, revision of surface water typology, and the revision of heavily modified water body designations. Table 2.1 Number, length and size distribution of delineated surface water bodies in Luxembourg for the second and first cycles Year RBD Number of river water bodies River length (km) Total length Minimum Maximum Average 2016 LU000 107 1 191 (1.197) 2.6 43.4 (43.26) 11.13 (11.18) 2016 LU001 3 23 (22) 4.2 (3.9) 14.44 (12.85) 7.77 (7.177) 2016 Total 110 1,214 2010 LU000 99 2010 LU001 3 2010 Total 102 Source: WISE electronic reporting. The numbers in brackets were subsequently provided by Luxemburg.

Table 2.2 Number and area of delineated groundwater bodies in Luxembourg for the second and first cycles Year RBD Number Area (km2) Minimum Maximum Average 2016 LU000 6 20.59 912.02 482.62 2016 LU001 0 0 0 0 2016 Total 6 20.59 912.02 482.62 2010 LU000 5 19 831 517.2 2010 LU001 0 0 0 0 2010 Total 5 19 831 517.2

Source: WISE electronic reporting Table 2.3 Type of change in delineation of groundwater and surface water bodies in Luxembourg between the second and first cycles Type of water body change for second RBMP Groundwater Body River Water Body Aggregation 8 Splitting 2 41 Aggregation and splitting 5 Extended area Creation Deletion Change in code No change 4 53 Total water bodies before deletion 6 110 Delineated for second cycle (after deletion from first cycle) 6 110 Source: WISE electronic reporting. In the second cycle, 93 % of identified surface water bodies were natural, while 7 % were designated as “heavily modified”; there were no artificial water bodies. Overall, there was a 4 % increase in natural water bodies, and a 4 % decrease in heavily modified water bodies between the first and second cycles ( Figure 2.1 ). The RBMP described that this re-delineation was in the light of new information, including water structure maps, which indicated that three heavily modified water bodies could achieve good ecological status.





Figure 2.1 Proportion of surface water bodies in Luxembourg designated as artificial, heavily modified and natural for the second and first cycles. Note that the numbers in parenthesis are the numbers of water bodies in each water category Source: WISE electronic reporting One of the groundwater bodies was divided into two groundwater bodies in the Rhine RBD, changing the total number from five to six, on the basis of spatial and hydrological considerations, as well as geological and land use considerations, and including horizontal stratification in line with Common Implementation Strategy guidance. 2.1.2Identification of transboundary water bodies Transboundary river water bodies have been designated for the Moselle-Saar sub-unit. No transboundary groundwater bodies have been identified. Delineation was coordinated with other Member States. 2.1.3Typology of surface water bodies The number of surface water body types remained the same between the first and second cycles ( Table 2.4 ). The RBMP, however, described that the surface water typology was changed from using four different methods developed and applied in the first RBMP to focusing on one methodology adapted for Luxembourg for the second cycle. The reason provided in the RBMP was that the method allowed for the validation of the typology, to make it biologically relevant for aquatic fauna and flora. All the national types for Luxembourg appear to have corresponding intercalibration types. The Moselle was assigned type VI, which also coincided with the German designation. In general, there is good permanent cooperation within the relevant International Commissions for the Protection of the Moselle-Saar, Rhine and Meuse. Table 2.4 Number of surface water body types at RBD level in Luxembourg for the first and second cycles RBD Rivers 2010 2016 LU000 6 6 LU001 1 1 TOTAL 6 6

Source: WISE electronic reporting Note that the total is not the sum of the types in each RBD as some types are shared by RBDs. 2.1.4Establishment of reference conditions for surface water bodies Table 2.5 shows the percentage of surface water body types in Luxembourg with reference conditions established for the second cycle. Type specific reference conditions have been established for all relevant biological quality elements, and all physicochemical quality elements. Type specific reference conditions were not reported for hydromorphological quality elements . The reference conditions were revised and clarified following the first cycle in fact sheets, which describe the ideal conditions for good ecological status (the fact sheets are in Annex 2 of the RBMP).



Table 2.5 Percentage of surface water body types in Luxembourg with reference conditions established for all, some and none of the biological, hydromorphological and physicochemical quality elements. Numbers in parenthesis are the number of types in each category Water category Water types Biological quality elements Hydromorphological quality elements Physicochemical quality elements Rivers (6) All 100 % 100 % 100 % Some None Source: WISE electronic reporting 2.1.5Significant pressures and impacts on water bodies In the second cycle, “diffuse - atmospheric deposition”, “physical alteration of channel/bed/riparian area/shore” and “anthropogenic pressure” were the most dominant significant pressures affecting about 100 % of river water bodies ( Figure 2.2 ). For groundwater bodies, the most significant pressure was “diffuse – agricultural” (83 %), followed by “point - contaminated sites” or “abandoned industrial sites” (50 %) ( Figure 2.2 ). No data was available for significant pressures on water bodies in Luxembourg in the first cycle. For the second cycle, it was reported that 39 pressures were not assessed for surface waters. For groundwater it was reported that 53 significant pressures were not assessed . Many of which were related to surface water specific pressures such as dams and hydrological changes. However, there were some pressures that could impact groundwater which were not assessed such as “groundwater - alteration of water level or volume”. No explanation for this was found in the RBMP . The RBMP did report that additional pressures have been considered since the first RBMP, the relationship between pressures and drivers was clarified. In the second cycle, the most significant impact on surface water bodies was “organic and chemical pollution” and “altered habitats due to morphological changes”, each affecting 100 % of river water bodies, followed by nutrient pollution (90 %) ( Figure 2.4 ). For groundwater, the most significant impacts were organic and nutrient pollution (100 %), followed by chemical pollution (83 %) ( Figure 2.4 ). Luxembourg did not report on impacts in the first cycle. Figure 2.2 The most significant pressures on surface water bodies and groundwater bodies in Luxembourg for the second cycle Source: WISE electronic reporting Figure 2.3 Significant impacts on surface water and groundwater bodies in Luxembourg for the second cycle. Percentages of numbers of water bodies Source: WISE electronic reporting

2.1.6Definition and assessment of significant pressures on surface and groundwater For surface waters, expert judgement was used for defining significant pressures from point sources, diffuse sources, abstraction and other significant pressures. Expert judgement and numerical tools were used for defining water flow pressures. For surface water bodies, significance of pressures is reported as being linked to the potential failure of objectives and is defined in terms of thresholds. For groundwater, a combination of expert judgement and numerical tools were used for defining significant pressures from abstractions. For diffuse and point source pressures expert judgement was used. Artificial recharge pressures do not appear to have been assessed. The criteria used to set threshold values for significant pressures for surface water and groundwater bodies were reviewed following the first RBMP, and some thresholds were made more stringent. Threshold values were set for all significant pressures and the relationship between drivers and pressures was clarified. The threshold values were used along with the status assessment, monitoring programme results to define significant pressures. 2.1.7Quantification of the gap and apportionment of pressures There are some inconsistencies in the pressures for which measures are planned and the significant pressures reported at the water body level. Luxembourg has characterised the drivers for the significant pressures and linked them to activities/sectors. The drivers at a national level were urban, agriculture and forestry, navigation, hydroelectricity, flood protection, and atmospheric deposition. For groundwater bodies, the main drivers were agriculture and forestry, linked to the nitrate and pesticides pressures. The Priority Substances causing the failure of good chemical status have been reported, but the measures to tackle these substances to achieve good status have not been reported, which is a significant gap. The RBMP reported that the reason measures are not yet in place was that further investigations of the sources are planned. This included polycyclic aromatic hydrocarbons, which are possibly from old/disused industrial or waste sites, diuron (possibly from inappropriate disposal), and isoproturon, which is expected to be reduced to some extent as a result of bans on usage in water protection zones (already in place). 2.1.8Groundwater bodies at risk of not meeting good status In the Rhine RBD, 67 % of groundwater bodies were reported to be at risk of failing to meet good chemical status. The pollutants putting groundwater bodies at risk of failing good chemical status have been reported. It was reported that no groundwater bodies were at risk of failing to meet good quantitative status. 2.1.9Inventories of emissions, discharges and losses of chemical substances Article 5 of the Environmental Quality Standards Directive (EQS Directive) requires Member States to establish an inventory of emissions, discharges, and losses of all Priority Substances and the eight other pollutants listed in Part A of Annex I EQS Directive for each RBD, or part thereof, lying within their territory. This inventory should allow Member States to further target measures to tackle pollution from priority substances. It should also inform the review of the monitoring networks, and allow the assessment of progress made in reducing (resp. suppressing) emissions, discharges and losses for priority substances (resp. priority hazardous substances). Luxembourg reported that all Priority Substances were included in the inventories for each RBD. The two step approach from the Common Implementation Strategy Guidance Document n°28 has been followed for all substances considered in the inventories. They carried out a simple assessment (tier 1 point source information) for substances not relevant at RBD level as recommended by the guidance document, and a much more thorough assessment (all 4 tiers) for substances relevant at RBD level. The quality of the input data is assessed as medium in all cases. 2.2Main changes in implementation and compliance since the first cycle Overall, the number of groundwater bodies and river water bodies remained largely the same between the first and second cycles. There was one extra groundwater body and an 8 % increase in river water bodies in the Rhine RBD. In the second cycle, 93 % of identified surface water bodies were natural with 7 % being designated as heavily modified and no artificial water bodies. The number of surface water body types remained the same between the first and second cycles, but the typology was applied using an updated methodology moving from using four different methods developed and applied in the first RBMP to focusing on one methodology. Overall, there was a 4 % increase in natural water bodies and a 4 % decrease in heavily modified water bodies between the first and second cycles because it was realised that some of them could achieve good ecological status. The criteria used to set threshold values for significant pressures for surface water bodies and groundwater bodies were reviewed since the first RBMP and some thresholds were made more stringent. 2.3Progress with Commission recommendations The Commission recommendations based on the first cycle and Programme of Measures requested action on the following: ·Recommendation: Complete the inventory of chemical emissions with detailed information on pressures from priority and priority hazardous substances including small emitters and diffuse sources. This improved inventory is expected to support the design of relevant and more detailed measures for the reduction / phasing out of emissions of these substances as appropriate.

Assessment: Luxembourg reported that all of Priority Substances were included in the inventories for each RBD. The two step approach from the Common Implementation Strategy Guidance Document n°28 has been followed for all substances considered in the inventories. They carried out a simple assessment (tier 1 point source information) for substances not relevant at RBD level as recommended by the guidance document, and a much more thorough assessment (all 4 tiers) for substances relevant at RBD level. The quality of the input data is assessed as medium in all cases. Therefore, this recommendation has been fulfilled. ·Recommendation: Where there are currently high uncertainties in the characterisation of the RBDs, identification of pressures, and assessment of status, these need to be addressed in the current cycle, to ensure that adequate measures can be put in place before the next cycle. and ·Recommendation: Ensure that the RBMPs clearly identify the gap to good status, and that the Programme of Measures is designed and implemented to close that gap with transparent and meaningful information regarding the scope, the timing and the funding of the measures. and ·Recommendation: Improve knowledge about the link between pressures and impacts in designing and making operational the measures for the second RBMPs cycle in order to: Refine the significance of the pressures by quantifying those which are likely to prevent the achievement of environmental objectives. Apportion pressures by their source and identify the responsible sectors/areas. Assess the reduction in pressures required to achieve environmental objectives. Assessment: For the second cycle, it was reported that 39 pressures were not assessed for surface waters, and 53 for groundwater, which was not explained in the RBMP. The criteria used to set threshold values for significant pressures for surface water bodies and groundwater bodies were reviewed following the first RBMP and some thresholds were made more stringent. Threshold values were set for all significant pressures and the relationship between drivers and pressures was clarified. The threshold values were used, along with the status assessment and monitoring programme results, to define significant pressures. This shows some progress towards fulfilling the part of the recommendations, relating to defining significance in relation to the environmental objectives. Pressures have been apportioned by their source, and responsible sectors/areas have been identified. However, expert judgement is still largely used for defining significant pressures from point sources, diffuse sources, abstraction, and other significant pressures for surface waters, which means that this may be less robust compared to using a combination of quantitative tools and expert judgement. The Priority Substances causing the failure of good chemical status have been reported, but the measures to tackle these substances to achieve good status have not been reported. Overall, there appears to be some progress in implementing these recommendations; however they have been partially fulfilled. Topic 3Monitoring, assessment and classification of ecological status in surface water bodies 3.1Assessment of implementation and compliance with WFD requirements in the second RBMP 3.1.1Monitoring of ecological status/potential Monitoring programmes Article 8.1 of the WFD requires Member States to establish monitoring programmes for the assessment of the status of surface water and of groundwater in order to provide a coherent and comprehensive overview of water status within each RBD. Separate surveillance and operational monitoring programmes were reported for rivers (the only surface water category delineated) in both RBDs. There were also other separate monitoring programmes in both RBDs, for example, for eutrophication and river gauging. Monitoring sites Table 3.1 compares the number of monitoring sites used for surveillance and operational purposes between the first and second RBMPs.

Table 3.1Number of sites used for surveillance and operational monitoring in Luxembourg for the second and first RBMPs. Note that for reasons of comparability with data reported in the first RBMP, the data for the second RBMP does not take into account whether sites are used for ecological and/or chemical monitoring Rivers Surv. Op. 2nd RBMP LU_000 3 215 LU_001 2 3 Total by type of site 5 218 Total number of monitoring sites 223 1st RBMP LU_000 4 99 LU_001 2 3 Total by type of site 6 102 Total number of monitoring sites 108 Source: WISE electronic reporting

There are differences in the numbers of monitoring sites reported to WISE and that obtained from the published first RBMP. Using the most recent data for the first RBMP, it seems that there has been a large increase in the number of operational sites in the Rhine RBD, from 99 in the first RBMP to 215 in the second. The number of operational sites (3) for the other RBD (Meuse) was the same for both RBMPs. In terms of surveillance sites, the only difference from the first to the second RBMPs was a decrease in the Rhine RBD, from four for the first RBMP to three for the second. Table 3.2 gives the number of sites used for different monitoring purposes for the second RBMP. In addition to operational and surveillance monitoring, a number of other monitoring purposes was reported in relation to some types of Protected Areas and international monitoring obligations, and in particular a large number of sites used for investigative monitoring.



Table 3.2Number of monitoring sites in relevant water categories used for different purposes in Luxembourg Monitoring Purpose Number of sites BWD - Recreational or bathing water - WFD Annex IV.1.iii 11 CHE - Chemical status 13 ECO - Ecological status 222 INT - International network of other international convention 2 INV - Investigative monitoring 405 NID - Nutrient sensitive area under the Nitrates Directive - WFD Annex IV.1.iv 16 OPE - Operational monitoring 218 RIV - International network of a river convention (including bilateral agreements) 3 SUR - Surveillance monitoring 5 Total sites irrespective of purpose 514 Source: WISE electronic reporting Quality elements monitored (excluding River Basin Specific Pollutants) Table 3.3 illustrates the quality elements used for the monitoring of rivers for the second RBMP: no differentiation is made between purposes of monitoring. The same biological quality elements monitored for the first RBMP were reported to be monitored for the second RBMP. This means there is still one gap in the elements monitored: fish in rivers in the Meuse RBD. Hydromorphological quality elements and general physicochemical quality elements were only reported at an aggregated level for the first RBMP. For the second RBMP, river continuity and morphological conditions were reported not to be monitored. All required general physicochemical quality elements were monitored in rivers in Luxembourg for the second RBMP. Table 3.3Quality elements monitored for the second RBMP in Luxembourg (excluding River Basin Specific Pollutants). Note; quality element may be used for surveillance and/or operational monitoring Biological quality elements Hydromorphological quality elements7 Phytoplankton Macrophytes Phytobenthos Benthic invertebrates Fish Angiosperms Macroalgae Other aquatic flora Other species Hydrological or tidal regime Continuity conditions Morphological conditions Rivers Yes Yes Yes Yes Yes No Yes No No General physicochemical quality elements Transparency conditions Thermal conditions Oxygenation conditions Salinity conditions Acidification status Nitrogen conditions Phosphorus Conditions Silicate Other determinand for nutrient conditions Rivers Yes Yes Yes Yes Yes Yes Yes No No Source: WISE electronic reporting Annex V of the WFD provides guidance on the frequency of monitoring of the different quality elements. Surveillance monitoring should be carried out for each monitoring site for a period of one year during the 6-year period covered by a RBMP. For phytoplankton, this should be done twice during the monitoring year and for the other biological quality elements once during the year. Operational monitoring should take place at intervals not exceeding once every six months for phytoplankton and once every three years during the 6-year cycle for the other biological quality elements. Greater intervals may be justified on the basis of technical knowledge and expert judgement. In Luxembourg as a whole, four of the five biological quality elements used for the surveillance monitoring of rivers were sampled at least at the minimum recommended frequency at all of the sites where they were monitored. The exception was macrophytes, for which 75 % of the sites met this frequency. In contrast, only one of the five biological quality elements used in the operational monitoring of rivers was sampled at least at the minimum frequency. For fish only 17 % of sites were sampled at this frequency. The RBMP specifically mention the following changes from the first to the second RBMP: (i) the quality element phytoplankton was added to the monitoring programme in all relevant water bodies and the results included in the assessment of ecological status/potential; (ii) other aquatic flora has only been monitored since 2007 and has therefore been fully included only in the assessment for the second RBMP; (iii) the second intercalibration phase set new limit values and reference values (2013/480/EU), and therefore the reference and limit values for benthic invertebrates, macrophytes and diatoms were adjusted accordingly; (iv) the benthic invertebrates have been evaluated using the French “Indice Biologique Global Normalisé” (IBGN) since 2007, therefore the calculation continued to be as an “IBGN-equivalent” value to allow comparison with earlier results. River Basin Specific Pollutants and matrices monitored Member States were not asked to report to WISE on which River Basin Specific Pollutants have been identified or which ones are specifically monitored. However, information was reported on the individual chemical substances monitored in surface and groundwater. Information on monitored River Basin Specific Pollutants in surface waters was derived by removing Priority Substances from the list of monitored chemical substances in surface waters.

On this basis, 54 River Basin Specific Pollutants are monitored in Luxembourg, all in water. All were monitored at 14 sites. Member States were also asked to report River Basin Specific Pollutants at the generic quality element level for the second RBMP. Luxembourg reported (at the generic level) that 400 sites were used for the monitoring of River Basin Specific Pollutants for investigative purposes. 173 sites were reported to be used for surveillance and/or operational monitoring. Information in the first RBMP was also reported at a generic quality element level. From the reported information it appears that there has been a significant increase in the number of sites from the first RBMP ( Table 3.4 ).



Table 3.4 Number of sites used to monitor River Basin Specific Pollutants reported in the second RBMP and non-priority specific pollutants and/or other national pollutants reported in the first RBMP in Luxembourg. Note the data from both cycles may not be fully comparable as different definitions were used and also not all Member States reported information at a site level, meaning that there were no equivalent data for the first RBMP RBMP Number of stations

(River water bodies) 1st Sites used to monitor non-priority specific pollutants and/or other national pollutants – reported at the quality element level 136 2nd Sites used to monitor River Basin Specific Pollutants – reported at the quality element level 173 Sources: WISE electronic reporting. Data does not take into account whether sites are used for ecological and/or chemical monitoring Annex V of the WFD provides guidance on the frequency of monitoring of the different quality elements: once every three months is recommended for “other pollutants”, which are taken here to equate to river basin specific pollutants. Surveillance monitoring should be carried out for each monitoring site for a period of one year during the 6-year period covered by a river basin management plan. For river basin specific pollutants this should be done four times for the surveillance year, and for operational monitoring four times a year for each year of the cycle. For all sites and all River Basin Specific Pollutants monitored for surveillance purposes, these were sampled at least at the minimum recommended frequency. In terms of operational monitoring none of the sites for all River Basin Specific Pollutants was sampled at least at the minimum recommended frequency. However, reported as being sampled at least at the minimum recommended frequency. However Luxembourg subsequently informed the Commission that there were errors in the reporting and that some of the sites were monitored at the minimum recommended frequency. Surveillance monitoring of surface water bodies All three river water bodies in the Rhine RBD used for surveillance monitoring were monitored for all required biological quality elements and general physicochemical quality elements. All required general physicochemical quality elements were monitored in the one river water body in the Meuse RBD used for surveillance but this was not the case for the biological quality elements. None of the water bodies included in surveillance monitoring in both RBDs was reported as having been monitored for all required hydromorphological quality elements. Overall in Luxembourg, the number of delineated river water bodies increased from 102 in the first RBMP to 110 in the second. The total number and proportion of river water bodies included in surveillance monitoring decreased from five (5 %) for the first RBMP to four (4 %) for the second. In contrast the proportion of river water bodies included in operation monitoring increased from 74 % in the first RBMP to 85 % in the second. Overall, 86 % of river water bodies were reported to be included in surveillance and/or operational monitoring ( Figure 3.1 ). Luxembourg subsequently informed the Commission that due to errors in the reporting the number of water bodies monitored might differ from what was reported. The proportion of surface water bodies in different status classes in which there was surveillance monitoring ( Figure 3.2 ) indicates that no surface water bodies in good status are included, and therefore not as required by the WFD. Figure 3.1Percentage of water bodies included in surveillance and operational monitoring in Luxembourg for the first RBMP and second RBMP. Note no differentiation is made between water bodies included in ecological and/or chemical monitoring Source: WISE electronic reporting, Luxembourg subsequently noted that wrong water body codes have been reported for some monitoring stations.



Figure 3.2Proportion of water bodies in each ecological status/potential class which are included in surveillance monitoring in Luxembourg Source: WISE electronic reporting Operational monitoring of surface water bodies

The biological quality elements predominantly used for operational monitoring were macrophytes, phytobenthos and benthic invertebrates (in 94 % of water bodies included in operational monitoring). 84 % of water bodies in less than good status/potential were included in operational monitoring: the only three water bodies in good or high status/potential were included in operational monitoring but not in surveillance monitoring. Transboundary surface water body monitoring Six transboundary river water bodies were reported by Luxembourg. Five river monitoring sites were reported to be part of an international network and/or a river convention network. Use of monitoring results for classification Grouping has not been used for the classification of ecological status/potential at the quality element level. Around 10 % of water bodies were classified by expert judgment for general physicochemical quality elements and River Basin Specific Pollutants. The biological quality elements were overwhelmingly classified using monitoring results. There are often discrepancies between the number of water bodies directly monitored for biological quality elements in the Rhine RBD and those classified using monitoring results. For example, benthic invertebrates were monitored in 87 river water bodies and 103 were reported as having been classified using monitoring results: grouping was reported not to have been used. Luxembourg subsequently informed the Commission that due to errors in the reporting the number of water bodies monitored might differ from what was reported. A more significant discrepancy is in terms of hydromorphological quality elements where hydrological regime was directly monitored but was not used in the classification of ecological status/potential. Conversely river continuity and morphological conditions were reported to be classified using monitoring results even though no water body was reported to be monitored. However, Luxembourg subsequently clarified that river continuity and morphological conditions were monitored, but it was not reported in WISE. 3.1.2Ecological Status/potential of surface water The ecological status/potential of surface water bodies in Luxembourg in the second RBMP is illustrated in Map 3.1 . The total number of river water bodies increased from 102 in the first RBMP to 110 in the second. The proportion of river water bodies in good status/potential decreased from 7 % in the first RBMP to 3 % in the second. Correspondingly, the proportion of less than good increased from 93 % to 97 %. There has been an improvement in the confidence of the classification from the first to the second RBMP: 61 % were classified with high confidence in the first RBMP and 100 % in the second ( Figure 3.3 ). The proportion of river water bodies in poor status was reduced from about 10 % in the first RBMP to 8 % in the second, and river water bodies in bad status from about 30 % in the first RBMP to 23 % in the second. There were increases in the proportion of moderate status, with about 53 % in the first plan and 66 % in the second (none were classified as high status) ( Figure 3.4 ). Map 3.1Ecological status or potential of surface water bodies in Luxembourg based on the most recently assessed status/potential of the surface water bodies Note: Standard colours based on WFD Annex V, Article (1)(4)(2)(i). Source: WISE, Eurostat (country borders) High Good Moderate Poor Bad Unknown River Basin Districts Countries outside the European Union Figure 3.3 Confidence in the classification of ecological status or potential of surface water bodies in Luxembourg based on the most recently assessed status/potential Source: WISE electronic reporting A similar picture emerged for ecological potential, where the proportion of heavily modified water bodies in good ecological potential was reduced from 9 % to zero from the first to the second RBMP, whilst the proportion with moderate ecological potential remained about the same, and the proportion in the class of bad potential were significantly reduced, from 45 % to 25 %, whilst the proportion in the class of poor potential increased from about 18 % to 50 %.

The RBMP indicates that the changes are due in part to changes in the designation of water bodies (91 natural water bodies in the first RBMP and 102 in the second , 11 heavily modified water bodies in the first RBMP and eight in the second), but most importantly due to a more complete dataset and more stringent assessment, in particular more biological quality elements and a higher number of water bodies monitored, and assessment of the ecological status on the basis of the worst case results in terms of biological and general physicochemical quality elements. Luxembourg reports that the majority of their river water bodies will reach good status/potential for the third RBMP ( Figure 3.5 ).



Figure 3.4 Ecological status or potential of surface water bodies in Luxembourg for the second RBMP, for the first RBMP and expected in 2015. The number in parenthesis is the number of surface water bodies for each cycle. Note the period of the assessment of status for the second RBMP was 2008 to 2015. The year of the assessment of status for first RBMP is not known Source: WISE electronic reporting Figure 3.5 Expected date of achievement of good ecological status/potential of surface water bodies in Luxembourg. The number in parenthesis is the number of water bodies in each category Source: WISE electronic reporting Classification of ecological status in terms of each classified quality element Over 95 % of river water bodies were classified for benthic invertebrates, phytobenthos and macrophytes but for only 41 % for fish ( Figure 3.6 ). Phytoplankton is monitored in the one reported reservoir and four other river water bodies. Figure 3.7 compares the classification of biological quality elements in terms of ecological status/potential for the second RBMP. It should be noted that this comparison should be treated with caution as there are differences between the numbers of surface water bodies classified for individual elements between the first and second plans. The same biological quality elements were used for the first and second plans. Other aquatic flora was reported but Luxembourg subsequently confirmed that this was a reporting error, and that theyreported “other aquatic flora” in place of the two sub-BQEs diatoms and macrophytes. Even fewer water bodies have been classified using the supporting quality element hydrological regime in the second RBMP than in the first ( Figure 3.9 ). All river water bodies were classified according to River Basin Specific Pollutants, 97 (88 %) using monitoring results, the remainder by expert judgment. 100 water bodies were reported to be directly monitored ( Figure 3.9 ). Figure 3.6 Ecological status/potential of the biological quality elements used in the classification of surface waters in Luxembourg. Note that water bodies with unknown status/potential, and those that are monitored but not classified or not applicable, are not presented. Source: WISE electronic reporting. Luxembourg subsequently noted that there was no monitoring for “other aquatic flora” and this was reported by mistake. Figure 3.7 Comparison of ecological status/potential in Luxembourg according to classified biological quality elements in rivers between the first and second RBMP

Source: WISE electronic reporting. Luxembourg subsequently noted that there was no monitoring for “other aquatic flora” and this was reported by mistake. Figure 3.8 and Figure 3.9 illustrate the basis of the classification of ecological status/potential of rivers in Luxembourg for the second RBMP. Overall in Luxembourg, the ecological status of rivers has been assessed using all four groups of quality elements ( Figure 3.8 ). Figure 3.8 The classification of the ecological status or potential of rivers in Luxembourg using 1, 2, 3 or 4 types of quality element. Note: The 4 types are: biological; hydromorphological, general physicochemical and River Basin Specific Pollutants. Source: WISE electronic reporting Figure 3.9 Basis of the classification of ecological status/potential in Luxembourg. The percentages are in terms of the total number of waterbodies in each category. Source: WISE electronic reporting. Luxembourg subsequently noted that there was no monitoring for “other aquatic flora” and this was reported by mistake, “Transparency conditions” and “Hydrological regime” were monitored but not used, Assessment methods and classification of biological quality elements Reference conditions were reported not to have been established for any river type in Luxembourg for hydromorphological quality elements. Reference conditions have been established for all general physicochemical quality elements for all river types. In terms of biological quality elements, there are reference conditions for all elements in all six river types, and for some elements for one type that has not been given a national code. There is also double reporting of one type (VI): a common intercalibration type has been reported but also "not applicable". According to the reporting in WISE, there is still one gap in the biological quality elements monitored: fish in rivers in the Meuse RBD. However Luxembourg subsequently clarified that this was a reporting error and that fish are monitored and assessed in two of the three water bodies of the Meuse RBD. None of the water bodies included in surveillance monitoring in both RBDs was reported to be monitored for all required hydromorphological quality elements. Luxembourg subsequently clarified that this was also a reporting error and that all water bodies included in surveillance monitoring had been monitored for the required hydromorphological quality elements. One reported assessment method is relevant for phytoplankton in lakes. This is related to the one river water body that is a reservoir and is therefore monitored and assessed as a lake. Methods for the assessment of all relevant biological quality elements have been reported for rivers and are reported to be sensitive to all possible impacts. Intercalibration of biological assessment methods Only 3 % of river water bodies did not have an equivalent common intercalibration type. The river types were intercalibrated against four common intercalibration types. Assessment methods for hydromorphological quality elements Only two of the three required hydromorphological quality elements were assessed in terms of ecological status and potential, hydrological regime was not. The assessment of river continuity was reported to be related to the class boundaries for the sensitive biological quality elements whereas for morphological conditions it was not.

The supporting quality elements of morphology and continuity were classified for all water bodies on the basis of a German assessment method (LAWA-guideline). The hydrology has not been classified, as the assessment method did not cover this aspect. The evaluation of the hydromorphological status was based on a detailed structural quality survey of all water bodies, which was not available for the first RBMP; a comparison with the first RBMP is therefore not possible. Assessment methods for general physicochemical quality elements Luxembourg reported that all the relevant supportive general physicochemical quality elements in rivers have been assessed in terms of ecological status/potential and the classification boundaries are related to the class boundaries for the sensitive biological quality elements. Standards have been set for all relevant general physicochemical quality elements in rivers and are reported to be consistent with the good-moderate status boundary of the relevant sensitive biological quality elements. The RBMP indicates that Environmental Quality Standards for the general physicochemical parameters were used to adjust the specific reference conditions for the second RBMP, and the worst case classification for these quality elements was used in combination with the biological quality elements to determine ecological status/potential. Selection of River Basin Specific Pollutants and use of Environmental Quality Standards The RBMP indicates that River Basin Specific Pollutants were selected from the list of substances listed in Appendix I of the Grand-Ducal Regulation of 28 February 2003, depending on their relevance. The environmental quality standards have been set based on an analysis of the Directives in force. In case of divergence between the regulatory provisions, it is the most stringent quality objectives that have been retained. Environmental Quality Standards have been set for 54 River Basin Specific Pollutants in water for rivers: none was derived in accordance with the Technical Guidance Document No 27 . For 35 substances the analytical method used meets the minimum performance criteria laid down in Article 4.1 of the QA/QC Directive (2009/90/EC) for the strictest standard applied. For the remaining 19 substances the analytical method complies with the requirements laid down in Article 4.2 of the same Directive for the strictest standard applied. Overall classification of ecological status (one-out, all-out principle) Luxembourg reported that the ‘one‐out, all‐out’ principle has been applied in deriving the overall classification of the ecological status/potential of a water body in both RBDs. 3.2Main changes in implementation and compliance since the first RBMP There are differences in the numbers of monitoring sites reported to WISE and that obtained from the published first RBMP. Using the most recent data for the first RBMP, it seems that there has been a large increase in the number of operational sites in the Rhine RBD, from 99 in the first RBMP to 215 in the second. The number of operational sites (3) for the other RBD (Meuse) was the same for both RBMP. In terms of surveillance sites, the only difference from the first to the second RBMP was a decrease in the Rhine RBD, from four for the first RBMP to three for the second. Overall the assessment is based on more complete data sets, i.e. more complete sets of quality elements and results for a larger number of water bodies. For example, assessments for phytobenthos and macrophytes were available for 98 % of surface water bodies for the second RBMP, whereas for the first RBMP 47 % of surface water bodies were assessed on the basis of macrophytes alone and 49 % on the basis of diatoms; fish were reported to be assessed in 41 % of surface water bodies for the second RBMP, compared with 14 % for the first RBMP. 3.3Progress with Commission recommendations The Commission recommendations based on the first RBMP and Programme of Measures requested action on the following: ·Recommendation: The assessment methods for ecological and chemical status need to be further developed, in particular for the hydromorphological quality elements. Some biological quality elements still need to be adapted to the Decision on Intercalibration. Assessment: The biological quality element “fish” and the supporting quality element 'hydrological regime' were not classified for the majority of water bodies. A biological assessment method for fish is in place; therefore it is unclear why Luxembourg did not classify more water bodies using this biological quality element. An assessment method for the hydrological regime was not available. No information is available on the status of intercalibrated biological quality elements for Luxembourg. Based on this information it is considered that this recommendation has been partially fulfilled.

·Recommendation: The identification of River Basin Specific Pollutants needs to be more transparent, with clear information on how pollutants were selected, how and where they were monitored, where there are exceedances and how such exceedances have been taken into account in the assessment of ecological status. It is important that there is an ambitious approach to combatting chemical pollution and that adequate measures are put in place. Assessment: The RBMP provide information on how River Basin Specific Pollutants have been selected. Environmental Quality Standards have been derived for 54 River Basin Specific Pollutants in water (only) for the second RBMP, but none of the standards was derived in accordance with the Technical Guidance Document No 27. For 35 substances the analytical method used meets the minimum performance criteria laid down in Article 4.1 of the QA/QC Directive (2009/90/EC) for the strictest standard applied and for the remaining 19 substances it complies with the requirements laid down in Article 4.2. Detailed information has been reported on the River Basin Specific Pollutants monitored in water with their respective sampling frequencies. However, whereas all pollutants were monitored at least at the minimum recommended frequency for surveillance monitoring at all sites where they are monitored, for operational monitoring none of the sites for all pollutants were reported to be sampled at least at the minimum frequency. However Luxembourg subsequently informed the Commission that there were errors in the reporting and that some of the sites were monitored at the minimum recommended frequency. In addition, there is conflicting information on the number of sites monitoring River Basin Specific Pollutants with far fewer being reported at the specific substance level than at the generic quality element level: Luxembourg subsequently clarified that this is a reporting error. Zinc and copper were reported to be causing the failure to achieve good ecological status/potential in 11 and six river water bodies, respectively. The one-out, all-out principle has been applied in the classification based on River Basin Specific Pollutants. Based on this information it is considered that this recommendation has been partially fulfilled. ·Recommendation: Close the remaining gaps in monitoring networks and assessment methodologies as regards ecological status or surface water, chemical status of surface and groundwaters and quantitative status of groundwaters. Assessment: In terms of biological quality elements, the same elements monitored for the first RBMP were reported to be monitored for the second RBMP. Fish in rivers was still reported as not being monitored in the Meuse RBD, but Luxembourg subsequently clarified that this was a reporting error and two water bodies had been monitored for fish in the Meuse. For the second RBMP, river continuity and morphological conditions were reported not to be monitored but Luxembourg subsequently clarified that morphological conditions and river continuity were monitored and evaluated for every water body, while hydrological regime was not evaluated in the second RBMP. In conclusion, there has been progress in this aspect and the recommendation has been partially fulfilled. ·Recommendation (partial): Enhance measures to tackle pollution by nutrients (nitrogen and phosphorus) considering their impact on ecological status. Full consideration of the basin-wide impact is needed in this respect (local and downstream up to transitional and coastal waters). To this extent Luxembourg should check that their nutrient standards are consistent with biological requirements for the achievement of good status and provide a more coherent strategy encompassing WFD with the Nitrates Directive and Common Agricultural Policy in agriculture. Assessment: The nutrient threshold defined for nitrate (25 mg/l) may be considered as too relaxed to support the achievement of good ecological status/potential. However, it would require additional analysis to confirm this supposition. Luxembourg subsequently stated that a study from 2015 relating nitrate, phosphorous and biological parameters found the threshold to be accurate for good ecological status, but that a more substantial study taking into consideration other parameters will be launched in 2018. In conclusion, there are still questions concerning the adequateness of the threshold used by Luxembourg and at this stage it cannot be concluded whether or not the recommendation has been fulfilled.

Topic 4Monitoring, assessment and classification of chemical status in surface water bodies 4.1Assessment of implementation and compliance with WFD requirements in the second cycle 4.1.1Monitoring of chemical status in surface waters Monitoring sites and monitored water bodies used for monitoring of chemical status Member States have to implement surveillance and operational monitoring programmes in accordance with the requirements of the WFD and of the EQS Directive for the assessment of ecological status/potential and chemical status. Surveillance monitoring programmes should allow Member States to supplement and validate the impact assessment procedure, to efficiently and effectively review the design of their monitoring programmes, and to assess the long-term changes in natural conditions and those resulting from widespread anthropogenic activity. For operational purposes, monitoring is required to establish the status of waterbodies identified as being at risk of failing to meet their environmental objectives, and to assess any changes in the status of such waterbodies resulting from the programme of measures. Section 3.1.1 of this report summarises the characteristics of the surveillance and operational monitoring programmes in Luxembourg for the second RBMP.

Figure 4.1 summarises the proportion of sites used for the monitoring of chemical status in rivers for the second RBMP. In this figure, no distinction is made between sites used for surveillance and/or operational purposes. More detailed information can be found on the website of the European Environment Agency. Figure 4.1 shows that only a very small proportion of the total number of monitoring sites (3 %) are used for monitoring chemical status whereas 43 % of all monitoring sites are used for monitoring ecological status. Luxembourg subsequently clarified that they only reported to WISE the sites where all priority substances have been monitored. Monitoring has been carried out also at other sites, either only for some of the priority substances, or at a frequency not in line with the provisions of the WFD. These other sites haven’t been reported to WISE, although the monitoring results were used to assess chemical status. Figure 4.1 Proportion of sites used for monitoring of chemical status and, for comparison, ecological status, in Luxembourg. The number in parenthesis next to the category is the total number of monitoring sites irrespective of their purpose Source: WISE electronic reporting A total of 13 out of 110 river water bodies are reported to be monitored for chemical status across the two RDBs in Luxembourg (12 in the Rhine RBD and one in the Meuse RBD). Figure 4.2 summarises the proportion of water bodies monitored for chemical status rivers for the second RBMP. For the purposes of this figure, no distinction is made between sites used for surveillance and/or operational purposes. The graph shows also the proportion of water bodies monitored for any purpose and those for ecological status. Figure 4.2 Proportion of water bodies used for monitoring of chemical status and, for comparison, ecological status, in Luxembourg. The number in parenthesis next to the category is the total number of water bodies irrespective of their purpose Source: WISE electronic reporting 12 % of water bodies failing to achieve good chemical status were reported to be monitored in Luxembourg as a whole. More explicit, the percentage of water bodies failing to achieve good chemical status being monitored are 11 % in the Rhine RBD and 33 % in the Meuse RBD respectively. Long-term trend monitoring and monitoring of Priority substances in water, sediment and biota for status assessment Monitoring for status assessment Requirements Article 8.1 of the WFD requires Member States to establish monitoring programmes in order to provide inter alia a coherent and comprehensive overview of water status within each RBD. The amount of monitoring undertaken in terms of priority substances, frequency and numbers of sites should be sufficient to obtain a reliable and robust assessment of status. According to the EQS Directive (version in force in 2009), mercury, hexachlorobenzene and hexachlorobutadiene have to be monitored in biota for status assessment, unless Member States derived a standard for another matrix, which is at least as protective as the biota standard. Spatial Coverage All 41 Priority Substances that are used in the classification of chemical status are all reported to be monitored. According to the data reported, 89 % and 67 % of water bodies (all rivers) in Luxembourg (the Rhine and Meuse RBDs respectively), were not monitored for the whole list of Priority Substances but the remainder were monitored for all of the Priority Substances. Luxembourg subsequently clarified that metals and PAH were monitored in the 89 % of waterbodies identified above, but the information was not reported because the monitoring frequencies were not in line with the frequencies in the WFD. The initial assessment shows that no information was reported to WISE on the monitoring of sediments or biota. The RBMP confirms that monitoring has only been carried out in water samples (except at one monitoring station where suspended solids are also analysed). The RBMP indicates that Luxembourg has derived alternative standards for mercury, hexachlorobenzene and hexachlorobutadiene in water for use in the assessment of chemical status and monitors for these substances in water. A new analytical method has been applied to mercury from 2014 (for water samples) with a much lower limit of detection and therefore only a small number of mercury results are considered to be reliable to use in the assessment of chemical status. Luxembourg subsequently clarified that analysis of biota and sediments started in 2016 and the results will be presented in the next RBMP. In terms of transnational monitoring, Priority Substances are monitored at least at one site in each international RBD in collaboration with the relevant international body.

Frequencies The WFD indicates that, for the surveillance and operational monitoring of Priority Substances in water, the frequency of monitoring should be at least monthly for one year during the RBMP cycle and at least monthly every year, respectively. Monitoring in biota for status assessment should take place at least once every year according to the EQS Directive. In all cases greater intervals can be applied by Member States if justified on the basis of technical knowledge and expert judgement. Monitoring frequencies are reported for 41 Priority Substances at the site level in both Luxembourg RBDs. All substances were monitored 13 times per year in both RBDs for a period of at least one year which fulfils the minimum requirements for surveillance monitoring. For operational monitoring, the frequencies of monitoring in the Rhine RBD do not meet the minimum recommended frequency as described in the WFD. For the Meuse RBD, the frequency of operational monitoring is in accordance with the minimum recommended frequency of the WFD. Monitoring for long-term trend assessment Requirements Article 3.3 of the EQS Directive (version in force in 2009) requires Member States to monitor 14 priority substances that tend to accumulate in sediment and/or biota, for the purpose of long-term trend assessment. Monitoring should take place at least once every three years, unless technical knowledge and expert judgment justify another interval. No information was provided via WISE for either RBD on the arrangements for the long-term trend analysis of concentrations of those Priority Substances listed in Part A of Annex I of the EQS Directive that tend to accumulate in sediment and/or biota (Article 3(3) EQS Directive). Some information can however be found in the RBMP: the RBMP indicates that the monitoring of suspended sediment at one location (Wasserbillig / Sûre) at the downstream extent of the river network in Luxembourg is used for trend assessment. Monitoring at this station is part of a coordinated international programme as part of the International Commissions for the Protection of Moselle and Saar and the data contributes a long-term data series. Luxembourg subsequently clarified that monitoring of sediments commenced in 2016 at all four surveillance monitoring sites (used for the assessment of the chemical status) and additionally 13 operational monitoring sites and will be reported in the next RBMP. Frequency Monitoring of Priority Substances that are discharged in each RBD Annex V of the WFD states, in Section 1.3.1 (Design of surveillance monitoring), that “Surveillance monitoring shall be carried out for each monitoring site for a period of one year during the period covered by a river basin management plan for [inter alia]: priority list pollutants which are discharged into the river basin or sub-basin.” Section 1.3.2 (Design of operational monitoring) of the Directive states that “In order to assess the magnitude of the pressure to which bodies of surface water are subject Member States shall monitor for those quality elements which are indicative of the pressures to which the body or bodies are subject. In order to assess the impact of these pressures, Member States shall monitor as relevant [inter alia]: all priority substances discharged, and other pollutants discharged in significant quantities.” Member States are therefore required to monitor all Priority Substances which are discharged into the river basin or sub-basin. In Luxembourg, 41 Priority substances and groups of priority substances are reported to be included in the inventories of emissions in both RBDs and all are reported to be monitored. Performance of analytical methods used For 29 Priority Substances, Luxembourg reported that the analytical methods used meet the minimum performance criteria laid down in Article 4(1) of the Technical specifications for chemical analysis and monitoring of water status , the strictest standard are applied. For the remaining 12 Priority Substances reported, the analytical methods complied with the requirements laid down in Article 4(2) of the Technical specifications for chemical analysis and monitoring of water status for the strictest standard applied. The RBMP indicates that some issues remain with the analytical methods for mercury, hexachlorobenzene and hexachlorobutadiene in terms of achieving a suitable limit of quantification in relation to the alternative environmental quality standards in water used for status assessment. The method of dealing with measurements of Priority Substances lower than the limit of quantification is as specified in Article 5 of the Technical specifications for chemical analysis and monitoring of water status. 4.1.2Chemical Status of surface water bodies

Member States are required to report the year on which the assessment of chemical status is based. This may be the year that the surface water body was monitored. In case of grouping this may be the year in which monitoring took place in the surface water bodies within a group that are used to extrapolate results to non-monitored surface water bodies within the same group. In Luxembourg, the chemical assessments were carried out in specified years in the period from 2011 to 2014 in the Meuse RBD. However, in the Rhine RBD, 41 % and 6 % of chemical assessments were carried out in 2014 and 2013, respectively with the remainder being carried between 2011 and 2014. The one-out-all-out principle has been applied. The chemical status of surface water bodies in Luxembourg for the second RBMP is illustrated in Map 4.1 . This is based on the most recent assessment of status. All water bodies are classified as “failing to achieve good status”. Map 4.1Chemical status of surface water bodies in Luxembourg based on the most recently assessed status of the surface water bodies The chemical status of rivers in Luxembourg for the first and second RBMP is given in Table 4.1 . Overall in Luxembourg between the two cycles, there was a large decrease in the proportion of surface water bodies with good chemical status from 70 to 0 % and a significant increase in the proportion failing to achieve good status from 30 to 100 %. With regards to the basis of the classification of chemical status, monitoring underpinned the classifications of 11 and 33 % of river water bodies in the Rhine and Meuse RBDs, respectively, with the remainder classified by expert judgement. Table 4.1 Chemical status of surface water bodies in Luxembourg for the second and first RBMP. Note: the number in parenthesis next to the water category is the number of water bodies. Note: Chemical status assessment is based on the standards laid down in the EQS Directive. All water bodies are assessed as failing to achieve good chemical status in the second RBMP, whether the 2008 or the 2013 environmental quality standards are used. Some Member States did not implement the Directive in the first RBMP as the transposition deadline was in July 2010, after the adoption of the first RBMP Category Good Failing to achieve good Unknown Number % Number % Number % 2nd RBMP Rivers (110) 0 0 110 100 % 0 0 1st RBMP Rivers (102) 71 70 % 31 30 % 0 0 Figure 4.3 shows the confidence in the classification of chemical status for the second RBMP. Overall 12 % of surface water bodies in Luxembourg were classified for chemical status with high confidence and 88 % of surface water bodies were classified with low confidence. Luxembourg subsequently clarified that high confidence was assigned where monitoring for all Priority Substances was undertaken and low confidence where this was not the case. Confidence in the classification of chemical status for the first RBMP was not reported. Figure 4.4 compares the chemical status of surface water bodies in Luxembourg for the first cycle with that for the second RBMP (based on the most recent assessment of status) and that expected by 2015. As stated above, a 70 % increase in the proportion of water bodies failing to achieve good status was observed, and all water bodies were expected to be classified as such in 2015. Luxembourg based the assessment of chemical status for t