EUROPEAN COMMISSION Brussels, 26.2.2019 SWD(2019) 46 final COMMISSION STAFF WORKING DOCUMENT Second River Basins Management Plans - Member State: Finland 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 the Floods Directive (2007/60/EC)

Second River Basin Management Plans

First Flood Risk Management Plans {COM(2019) 95 final} - {SWD(2019) 30 final} - {SWD(2019) 31 final} - {SWD(2019) 32 final} - {SWD(2019) 33 final} - {SWD(2019) 34 final} - {SWD(2019) 35 final} - {SWD(2019) 36 final} - {SWD(2019) 37 final} - {SWD(2019) 38 final} - {SWD(2019) 39 final} - {SWD(2019) 40 final} - {SWD(2019) 41 final} - {SWD(2019) 42 final} - {SWD(2019) 43 final} - {SWD(2019) 44 final} - {SWD(2019) 45 final} - {SWD(2019) 47 final} - {SWD(2019) 48 final} - {SWD(2019) 49 final} - {SWD(2019) 50 final} - {SWD(2019) 51 final} - {SWD(2019) 52 final} - {SWD(2019) 53 final} - {SWD(2019) 54 final} - {SWD(2019) 55 final} - {SWD(2019) 56 final} - {SWD(2019) 57 final} - {SWD(2019) 58 final} - {SWD(2019) 59 final} - {SWD(2019) 60 final} - {SWD(2019) 61 final} - {SWD(2019) 62 final} - {SWD(2019) 63 final} - {SWD(2019) 64 final} - {SWD(2019) 65 final} - {SWD(2019) 66 final} - {SWD(2019) 67 final} - {SWD(2019) 68 final} - {SWD(2019) 69 final} - {SWD(2019) 70 final} - {SWD(2019) 71 final} - {SWD(2019) 72 final} - {SWD(2019) 73 final} - {SWD(2019) 74 final} - {SWD(2019) 75 final} - {SWD(2019) 76 final} - {SWD(2019) 77 final} - {SWD(2019) 78 final} - {SWD(2019) 79 final} - {SWD(2019) 80 final} - {SWD(2019) 81 final} - {SWD(2019) 82 final} - {SWD(2019) 83 final} - {SWD(2019) 84 final}



Table of contents Acronyms and definitions 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 RBMPs 3.2 Main changes in implementation and compliance since the first RBMPs 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 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 8.2 Main changes in implementation and compliance since the first cycle 8.3 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 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 since the first cycle 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 Water Information System for Europe Annex 0 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 population of Finland is 5.38 m (ref. Eurostat 2011) and the total surface area is 370 807 km2, including coastal waters. Tornionjoki RBD is the Finnish part of the Torne river, shared with Sweden, which forms part of the border between the countries, and to a smaller extent with Norway. The Teno, Näätämöjoki, and Paatsjoki RBD has river basins shared both with the Russian Federation and Norway. The other eastern RBDs Kemijoki and Vuoksi share river basins with the Russian Federation. The Åland is an autonomous region of the Finnish republic with its own legislation related to water. There are also some differences between water management on the Mainland of Finland and Åland. Information on areas of the national RBDs including sharing countries is provided in Table A and Finland’s share of the international RBDs is shown in Table B. Table A Overview of Finland‘s River Basin Districts RBD Name Size* (km2) Countries sharing RBD FIVHA1 Vuoksi 58 158 RU FIVHA2 Kymijoki-Gulf of Finland 57 074 - FIVHA3 Kokemäenjoki-Archipelago Sea-Bothnian Sea 83 357 - FIVHA4 Oulujoki-Iijoki 68 084 RU FIVHA5 Kemijoki 54 850 RU FIVHA6 Tornionjoki (Finnish part) 14 587 NO, SE FIVHA7 Teno-, Näätämöjoki- and Paatsjoki (Finnish part) 25 566 NO, RU FIWDA Åland 9 379 - Source: RBMP reported to WISE. Finland subsequently clarified that there are no RBDs shared with Russia Table B Transboundary river basins by category and % share in Finland Name international river basin National RBD Countries sharing borders Co-ordination category 2 km² % Munkelelva/Uutanjoki FIVHA7 NO, RU 174 73.4 Kem (Viena) FIVHA4 RU 1 297 4.7 Kemijoki FIVHA5 RU 49 467 96.8 Naatamo FIVHA7 NO, RU 2 354 81.0 Oulujoki FIVHA4 RU 22 509 98.5 Pasvik/Paatsjoki FIVHA7 NO, RU 14 492 99.9 Teno/Tana FIVHA7 NO, RU 5 133 31.3 Torneälven/ Tornionjoki FIVHA6 NO, SE 14 587 36.2 Tuloma/Tuulomajoki FIVHA7 NO, RU 3 241 12.6 Vuoksi FIVHA1 RU 58 158 76.9 Source: WISE electronic reporting





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 A total of eight RBMPs for Finland (Vuoksi, Kymijoki-Gulf of Finland, Kokemäenjoki-Archipelago Sea-Bothnian Sea, Oulujoki-Iijoki, Kemijoki, Tornionjoki (Finnish part), Teno-, Näätämö- and Paatsjoki (Finnish part), Åland) were published between 8 October 2015 and 3 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(s) The main strengths and shortcomings of the second RBMP of Finland are as follows: ·Governance and public consultation ·A broad range of stakeholders was actively involved in the preparation of Finland’s RBMPs, including via advisory groups. ·Finland has strengthened cooperation with Sweden and Norway, including via the preparation of common “roof reports” for their shared iRBDs. Finland also strengthened cooperation with the Russian Federation. ·Characterisation of the RBD Many new water bodies have been delineated, particularly if they were relevant for water management or for other reasons such as nature conservation or water use. The typology of rivers and lakes in mainland Finland is based on geographical, geological, chemical and physical characteristics and therefore it is unclear if they have been made biologically relevant. There are several river, lake and coastal water body types that were reported not to have a corresponding intercalibration type, approximately 60 % in total. Type specific reference conditions were reported not to have been established for any water body for relevant hydromorphological quality elements. This may lead to weaknesses in the classification of status/potential according to the hydromorphological quality elements. For groundwater bodies, further characterisation work has been undertaken since the first RBMPs, by describing the geological formation and whether or not they are layered. Finland have also made an assessment of linkages with surface water bodies and terrestrial ecosystems. For surface waters and groundwaters, significance of pressures was linked to failure of objectives. However, it is unclear how numerical tools have been used and expert judgement was extensively used. This is likely to give a qualitative rather than a quantitative assessment of the significance on this pressure. In addition thresholds were reported not to be used to assess the significance of pressures in surface water. 36 substances were included in an inventory for each of the RBDs, out of the 41 Priority Substances. Tier 1 of the methodology was implemented for most of the substances in the inventories, including for some of the substances deemed relevant at

RBD level. Higher tiers of the methodology were also implemented but only for some substances. The data quality was not reported.

·Monitoring, assessment and classification of ecological status The number of monitoring sites in Finland have more than doubled since the first RBMPs, with increased numbers for both surveillance and operational sites in the three relevant water categories. However, the proportion of water bodies with surveillance monitoring for some biological quality elements decreased since the first RBMPs. ·A high proportion of sites were sampled at least at the minimum recommended frequencies for all biological quality elements used for surveillance and operational purposes in all relevant water categories. ·River Basin Specific Pollutants were not monitored for surveillance purposes in coastal waters and in a very few cases in lakes and rivers. Furthermore, none of the substances was monitored at the minimum recommended frequency at any of sites at which they were monitored. ·Only in 6 % of water bodies included in surveillance monitoring were all the required biological quality elements monitored. ·Only 69 % of water bodies included in operational monitoring included at least one biological quality element, while 98 % of river water bodies were monitored for at least one physicochemical quality element. ·In all water categories, the ecological status/potential classification is often based on more quality elements than had been used for the first RBMPs. However, for many water bodies in lakes and coastal waters, the assessment is still based on phytoplankton and nutrients only. ·The overall ecological status/potential in Finland has not improved significantly since the first RBMPs, but there has been a significant improvement in the level of confidence of the classification. ·There are now methods developed for all relevant biological quality elements in all water categories, and these were reported to be sensitive to most reported significant impacts, although none of them seems to be sensitive to chemical pollution and acidification in coastal waters. ·All the relevant hydromorphological quality elements were reported to be assessed in terms of ecological status/potential. However, the classification boundaries are not related to the class boundaries for the sensitive biological quality elements. ·Only a limited number of physicochemical quality elements were used in the assessment of ecological status/potential of surface water bodies and significant gaps remain. ·Environmental Quality Standards were reported for 13 River Basin Specific Pollutants in water and one in sediment, but these did not include any metals. There is no information available on how the River Basin Specific Pollutants have been identified in the second RBMPs. Finland subsequently indicated that there were no changes in the list of River Basin Specific Pollutants since the first RBMPs. ·Environmental Quality Standards have not been derived in accordance with the Technical Guidance n° 27. The analytical methods used are in line with Articles 4(1) or 4(2) of Directive 2009/90/EC for the strictest standard applied. However, both these have been reported in the first cycle. ·River Basin Specific Pollutants are classified mainly using expert judgement, with only a few using monitoring results. ·Finland reported that the one-out-all-out principle has been used in all RBDs, which had not been the case for the first RBMPs. ·Monitoring, assessment and classification of chemical status in surface water bodies ·Comparing the number of sites and water bodies monitored for operational and surveillance purposes between the first and second RBMPs, there appears to be a net increase in monitoring sites and surface water bodies monitored. However, there remains a significant proportion of surface water bodies that is not monitored for chemical status. Territorial waters are not monitored or assessed for chemical status in Finland. While the increase in the number of sites and water bodies monitored from the first cycle represents some progress, the proportion of surface water bodies monitored for operational and surveillance purposes is low. ·Finland reported that 36 of the 41 groups of Priority Substances were included in an inventory for each of the RBDs. However, across the eight RBDs in Finland only between three and eight of the groups of Priority Substances in an inventory were reported as being discharged. For seven of the eight RBDs, with the exception of DEHP in the Oulujoki-Iijoki RBD, all of the substances discharged were reported to be monitored. ·For status assessment, where monitoring for chemical status does occur, the number of groups of Priority Substances monitored varies widely: in coastal waters up to five, in lakes only one and in rivers up to 10 groups of Priority Substances were monitored. Finland clarified that mercury, hexachlorobenzene and hexachlorobutadiene were monitored in biota for status assessment (hexachlorobenzene and hexachlorobutadiene being also monitored in water). Finland also clarified that water is supposed to be monitored every month, but in practice, water monitoring may sometimes happen less than 12 times per year. No explanation was provided for the reduced frequency. The monitoring frequency in biota was once per year and every three years in the monitoring cycle for each monitoring site, which is lower than the minimum recommended frequency in the Directive. No explanation was found for the reduced frequency. ·There is no monitoring reported in Finland for long-term trend analysis in sediment and/or biota.

·Overall between the two cycles there was a decrease in proportion of surface water bodies with good chemical status from 64 % down to 49 %, similar decreases occurred across all water body types (artificial, heavily modified and natural). The proportion of surface water bodies failing to achieve good status dramatically increased between the two cycles, from 0.44 % to 49 %. While 36 % of surface water bodies were reported with unknown status in the first RBMP, all water bodies were classified in the second RBMP which represents an improvement from the first cycle. ·40 out of the 41 groups of Priority Substances in the classification of chemical status were monitored in all the RBDs however in different proportions (i.e. from 0 in one RBD to 40). This would explain that the overall 93 % of surface water bodies in Finland classification for chemical status is with low confidence, 6 % with medium confidence and only 1 % with high confidence regardless of class. ·Monitoring, assessment and classification of quantitative status of groundwater bodies There is very limited monitoring for quantitative status, which has even decreased since the first RBMPs. How quantitative status was assessed without monitoring data is not fully clear. Yet, 98 % of groundwater bodies are in good quantitative status. Groundwater dependent terrestrial ecosystems and groundwater associated surface waters were considered in status assessment of all river basin districts where such ecosystems exist. Also, their needs have been considered in all river basin districts ·Monitoring, assessment and classification of chemical status of groundwater bodies The coverage of monitoring for chemical status in groundwater is still very low. A number of groundwater bodies is still reported with unknown chemical status. The total number of groundwater bodies failing good chemical status has increased. Monitoring of WFD core substances and of substances causing risk of deterioration in chemical status is very limited. Groundwater dependent terrestrial ecosystems and groundwater associated surface waters were considered in status assessment in all river basin districts where such ecosystems exist. ·Designation of Heavily Modified and Artificial Water Bodies and definition of Good Ecological Potential There is no exact description of the changes made to the methodology for designating heavily modified water bodies, but the criteria seem to be defined in a more detailed form than in the first RBMPs. Furthermore, the basis of evaluation of hydrological and morphological status is described in more detail. Information is also provided on the methodology used to assess significant adverse effects, however, no information was found on the assessment of other means to achieve the beneficial objectives served by the modifications of the heavily modified water body. Specific information on the outcome of the assessment of significant adverse effects and better environmental options is not given on a water body level. Good ecological potential is defined with the Prague approach on the basis of mitigation measures. Mitigation measures for defining good ecological potential have been reported and the ecological changes expected due to the mitigation measures are described in a qualitative way. However, good ecological potential has not been defined fully in biological terms yet (using all relevant biological quality elements). ·Environmental objectives and exemptions ·Environmental objectives for ecological and chemical status of surface water bodies have been reported in all RBDs as well as for chemical and quantitative status of groundwater. Information is also provided on when the objectives will be achieved. ·Justifications of technical feasibility for the application of Article 4(4) exemptions are provided, however, further elaboration and clarification may be needed. ·Further information and assessments are needed in order to ensure that the procedures under Article 4(7) are in line with the requirements of the WFD. The fact that expected deterioration from high to good status seems not to trigger an Article 4(7) assessment might be an issue of insufficient and/or non-compliant implementation of WFD requirements. ·Programme of Measures ·Finance was reported to have been secured in all RBDs. Costs were reported in each RBMP. However, no information on the costs of the measures for either Programme of Measures was provided in WISE. ·All RBDs in Finland have reported that new legislation or regulations are required and are in progress.

·The KTMs addressing some, but not all significant pressures in both surface water and groundwater have been identified. ·National basic and supplementary measures have been mapped against KTMs. ·14 national basic measures have been mapped against only four pre-defined KTMs. Not all measures apply in all RBDs. ·No information has been provided on the River Basin Specific Pollutants causing surface water bodies to fail to reach good status. Some individual substances were reported as causing groundwater bodies to fail to be of good status, however no KTMs to control these substances were reported. ·Information on the Priority Substances causing surface water bodies to fail to be of good status has not been reported for three RBDs. For those RBDs where failures were reported they cover only three substances. KTMs were reported for two of these substances. ·Indicators of the gap to the achievement of environmental objectives have been provided but only for 2015. ·The objectives of the Floods Directive have been considered in the RBMPs. Win-win measures and Natural Water Retention Measures have been included. The design of new and existing structural measures has been adapted for the WFD. Article 9(4) has been applied. ·The RBMPs and Flood Risk Management Plans have not been integrated. The flood protection was reported as “not applicable” to the financing of measures. ·Measures related to abstractions and water scarcity Water abstraction and scarcity have not been reported to be relevant for Finland. All water uses are subject to permitting procedures under Article 11(3)(e), with the exception of small abstractions. Under Article 11(3)(c), measures promoting efficient and sustainable water use (e.g. water metering and allocations) were implemented in the previous cycle. ·Measures related to pollution from agriculture There is a clear link between agricultural pressures and agricultural measures. No gap assessment in terms of reduction needed has been performed, though the area on which each measure is implemented is provided. For pesticides, the number of water bodies failing EQS are reported for all basins except Aland RBD. Safeguard zones for drinking water have been established for abstractions. Implementation of basic measures Article 11(3)(h) for the control of diffuse pollution from agriculture at source is ensured in all RBDs, with the same rules applying across the whole RBD. Supplementary measures for reducing pollution from agriculture were reported. Financing of measures is secured. The Programme of Measures heavily relies on voluntary measures. ·Measures related to pollution from sectors other than agriculture

Measures to tackle non-agricultural sources of pressures include the construction and upgrade of urban waste water treatment plants, but it is not clear how effective this will be at reducing the emission of nutrients in low-temperature environments. Where measures were reported for Priority Substances causing non-compliance, no indication was given of their effectiveness at achieving the objectives. ·Measures related to hydromorphology ·Operational KTMs to address all or part of the significant hydromorphological pressures were reported for all RBDs. However, indicators on the gap to be filled for significant hydromorphological pressures are only reported for 2015 but not for 2021 or 2027, which does not allow any conclusions on the level of ambition in closing the gap. ·In the seven mainland RBDs, ecological flows have been derived for some relevant water bodies but the work is still on-going. The ecological flows which have been derived have not been implemented yet but there are plans to do so during next cycle. At the same time, no clear measure is yet included in the RBMPs to review all existing hydropower permits to ensure the achievement of WFD objectives, in particular in relation to ecological flow, fish passes and other mitigation measures. ·Natural Water Retention Measures are applied in four of eight RBDs to address hydromorphological pressures related to agriculture and flood protection. Examples of Natural Water Retention Measures included are restoration of flood meadows and flood forests as well as constructed wetlands in agricultural areas. ·Economic analysis and water pricing policies Cost recovery calculations remain limited – environmental and resource costs have not been included. No information has been provided on ‘adequate incentives’ of pricing policies. No detailed information has been provided on the application of the polluter pays principle. A narrow definition of water services has been used. There is no consideration of (cross-) subsidies in the calculated and reported cost recovery rates for the two water services identified. ·Considerations specific to Protected Areas (identification, monitoring, objectives and measures) The reported monitoring activities for each Protected Area type were similar to that in the first cycle with the exception of that for Protected Areas related to Birds and economically significant species where no monitoring was reported in the second cycle. The RBMPs indicate that two additional measures are to be implemented for the protection of drinking water Protected Areas. However, these are poorly defined. ·Adaptation to drought and climate change Climate change was considered in various ways in all river basin districts and it is stated that the Common Implementation Strategy guidance document on how to adapt to climate change was used. All Finnish river basin districts recognise the existence of local or sub-basin drought spells as one of the effects of climate change. However, none of the river basin districts has developed a drought management plan.



Recommendations ·Clear information should be included in national RBMPs on international coordination efforts in order to increase transparency.

·Finland should continue to improve international cooperation, including coordinated assessments of the technical aspects of the WFD such as ensuring a harmonized approach for status assessment and a coordinated Programme of Measures in order to ensure the timely achievement of the WFD objectives. ·Finland should describe clearly the methodology used to identify significant pressures on both surface waters and groundwater. ·Finland should further improve monitoring of surface waters, as there are still important gaps. Monitoring should be extended to cover all water bodies for all relevant quality elements, including hydromorphological quality elements and River Basin Specific Pollutants in coastal waters. For the latter, the coverage for lakes and rivers should increase. ·Finland should have a clear and transparent method for the selection of River Basin Specific Pollutants, and provide clear information on how the status of River Basin Specific Pollutants has been determined, in particular for non-monitored substances. Finland 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, following the requirements of the WFD and the Directive on environmental quality standards. ·An increased level of monitoring should lead to a lower dependence on expert judgement for the classification of ecological status/potential, especially for hydromorphological quality elements and for River Basin Specific Pollutants. ·Finland should strengthen its assessment methods. In particular, the classification boundaries of hydromorphological quality elements should be related to the classification boundaries for the sensitive biological quality elements, and all the relevant physicochemical quality elements should be used in the assessment of ecological status/potential. ·Finland should continue improving the monitoring for status assessment to reach sufficient confidence, spatial coverage and temporal resolution for all the Priority Substances (including territorial waters whose status should be also assessed). If a different matrix or reduced frequencies are used, the corresponding explanations should be provided, as required by the Directives. ·Finland should ensure that the trend monitoring is up and running so that all the relevant substances specified in Directive 2008/105/EC are monitored in order to provide sufficient data for long-term trend analysis ·Groundwater monitoring should continue to be enhanced in Finland, especially for substances posing risk. ·The improvement of the methodology and subsequent application for the designation of heavily modified water bodies needs to be continued. The assessment of other means to achieve the beneficial objectives served by the modifications of the heavily modified water bodies and the outcome of the assessment of significant adverse effects on the use or the wider environment at water body level need to be made transparent. ·The definition of good ecological potential needs to be continued for all relevant biological quality elements. ·Progress in the application of Article 4(4) exemptions should be continued. The justifications for technical feasibility and disproportionate cost should be elaborated in more detail and further clarified. ·The issue that expected deterioration from high to good status may not trigger an Article 4(7) assessment is an issue of concern. Finland needs to ensure a thorough assessment of proposed new modifications in line with the requirements of the WFD and as further specified by the Judgment of the European Court of Justice in case C-461/13. ·Finland should ensure that KTMs addressing all the significant pressures are identified. ·Indicators of the gap to the achievement of the environmental objectives should be provided. ·KTMs to tackle River Basin Specific Pollutants should be presented, in order to control these reported substances, and assess the likely effectiveness of measures planned to tackle them and Priority Substances causing failure, taking account of the low-temperature conditions. ·Finland should continue improving the linkage of the analysis of pressures and impacts with the identification of measures in the RBMPs in relation to chemical pollution. ·A clear financial commitment for all the RBDs should be ensured. However, FI stated that information on the costs of the measures is provided, but not reported in WISE. ·Finland 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 RBMPs (as per WFD Article 11(3)(h)), to facilitate the achievement of WFD objectives. ·In the third RBMPs, Finland should make more effective use of the cross compliance regime to support WFD objectives, make the links between the WFD and Nitrates Directive more explicit and ensure that an expert and effective advisory service is available to farmers to aid successful implementation of measures. Finland should also ensure that RDP funds are made available to support the successful implementation of the RBMPs’ agricultural measures.

·Finland should continue the work on defining ecological flow, and make sure that this is implemented in all RBDs. The revision of all existing hydropower permits should be done to ensure the achievement of WFD objectives, in particular in relation to ecological flow, fish passes and other mitigation measures. ·Finland should apply cost recovery for water use activities having a significant impact on water bodies or justify any exemptions using Article 9(4). It should transparently present how financial, environmental and resource costs have been calculated and how the adequate contribution of the different users is ensured. Further, it should transparently present the water-pricing policy and provide a transparent overview of estimated investments and investment needs. ·Finland should improve the information in the RBMPs regarding the exemptions and measures put in place for Drinking Waters. Finland has only informed that safeguard zones are in place, but there are no plans to change the regulations. ·Based on the prevalence of local or sub-basin drought spells as one of the effects of climate change, Finland should re-consider preparing drought management plans where appropriate. Topic 1Governance and public participation 1.1Assessment of implementation and compliance with WFD requirements in the second cycle 1.1.1Administrative arrangements – river basin districts Finland has designated eight RBDs, seven in mainland Finland and one for Åland. Five of these RBDs are part of international RBDs, shared with Norway, Russia and Sweden. 1.1.2Administrative arrangements – competent authorities Finland lists 14 authorities at sub-national level: 13 Centres for Economic Development, Transport and the Environment; and the Government of Åland. These authorities all have roles for the preparation and implementation of the RBMPs, except coordination and reporting to the European Commission. The two national ministries are listed: the Ministry of Agriculture and the Ministry of Environment. Both ministries are responsible for the coordination of implementation of the WFD, and the Ministry of Environment is also responsible for reporting to the European Commission. 1.1.3RBMP – structure and Strategic Environmental Assessment Finland reported that no sub-plans to the RBMPs were prepared. A Strategic Environmental Assessment was prepared for seven of Finland's eight RBMPs. For Åland, a Strategic Environmental Assessment was not reported to WISE; however, Finland informed that a Strategic Environmental Assessment had been carried out for this RBMP. 1.1.4Public consultation RBMP documents were available for public consultation for the required six months in all of Finland's RBDs. The public and interested parties were informed by a broad range of means, including: internet, invitations to stakeholders, media (newspaper, TV and radio), meetings and social networking. For all RBDs, copies of the draft documents were available for download and paper copies were available in municipal buildings, and consultation was carried out via direct involvement in drafting the RBMP (see active involvement, below), via Internet and via social networking. For all RBDs except Åland, an online questionnaire was also used. According to information reported to WISE, in the Vuoksi, Kymijoki-Gulf of Finland and Oulujoki-Iijoki RBDs, announcements were made in newspapers and in each municipality of the RBDs; Finland subsequently informed, however, that newspaper announcements were made in all RBDs. In all of Finland's RBDs, stakeholders were actively involved via the establishment of stakeholder groups as well as involvement in drafting the RBMPs. The stakeholder groups actively involved were: agriculture/farmers, energy/hydropower, fisheries/aquaculture, industry, local/regional authorities, navigation/ports, NGOs/nature protection, water supply and sanitation, land owners’ associations, forestry associations, water owners’ associations, research institutes. (All these groups participated in each RBD except for energy/hydropower - not listed for Åland - and navigation/ports, not listed for the Vuoksi RBD). In all Finland's RBDs, public consultation had the following impacts on each of the RBMPs: addition of new information, adjustment to specific measures, changes to the selection of measures and commitment to further research. 1.1.5Integration with the Floods Directive and the Marine Strategy Framework Directive

Finland reported RBMPs and Floods Directive Flood Risk Management Plans in separate plans for the RBDs. In six of Finland's eight RBDs, there was joint consultation of RBMPs and Flood Risk Management Plans (the exceptions being the Vuoksi and Åland RBDs, where no flood risk areas were identified and thus FRMPs were not prepared). Further information on integration with respect to the implementation of measures is provided in Chapter 8 of this report. Seven of Finland's eight RBDs organised joint consultation on the RBMPs and on the Marine Strategy Framework Directive (the exception being the Åland RBD). 1.1.6International coordination Finland reports on international co-ordination in two RBDs. Finland reports agreement on international RBMPs for the Tornionjoki RBD, shared with Sweden, and for the Teno, Näätämöjoki and Paatsjoki RBD, shared with Norway. Finland’s reporting to WISE indicates that joint RBMPs were prepared for these two RBDs shared with Sweden and Norway. For the catchments shared between Finland and Norway (which are part of Finland’s Teno, Näätämökjoki and Paatsjoki RBD, FIVHA7) cooperation has included monitoring, the preparation of a common “roof report” that includes descriptions of co-operation, characteristics of the international river basin district, impact of human activity, state of the waters, monitoring network, environmental objectives and measurements. This document is available in Finnish, Norwegian, Sami and English. Finland’s Tornionjoki RBD (FIVHA6) is shared with Sweden and Norway. Sweden and Finland have prepared a common “roof report” which includes descriptions of co-operation, characteristics of the international river basin district, impact of human activity, state of the waters, monitoring networks, environmental objectives and measurements. This report has been published in four languages; Finnish, Swedish, Sami and Tornedalian Finnish, Meänkieli. For each international RBD, the common roof report plus the national RBMPs are together considered as the international RBMP (for further information see the reports on international coordination on the Water Framework Directive). Finland has bilateral agreements with Sweden and Norway: under each, there is a commission for coordination on shared surface water bodies that has addressed water management. Four of Finland's RBDs are part of international RBDs shared with Russia: Vuoksi, Oulujoki-Iijoki, Kemijoki and Teno, Näätämöjoki and Paatsjoki. Under the Finnish-Russian Cross-Border Commission , there are working groups on water resources and water protection, plus a sub-group on fisheries. Cooperation has covered monitoring activities and research projects. The Finnish-Russian Cross-Border Commission established a cooperation which aims to reach good water status. Recent cooperation milestones included, for example, an updated monitoring programme in 2015, a revised map of transboundary catchment areas in 2014 and a decision to start preparing a joint risk management programme in 2013 . Russia has an observer status in the Finnish-Norwegian Transboundary Water Commission's meetings . Murmansk regional environment authorities work in cooperation with matters related to the international River Paatsjoki catchment (shared also with Norway). 1.2Main changes in implementation and compliance since the first cycle The main change has been the strengthening of cooperation with Sweden and Norway, including the development of common International RBD “roof reports” that bring together the respective national RBMPs. 1.3Progress with Commission recommendations The Commission recommendations based on the first RBMPs and Programme of Measures requested action on the following: ·Recommendation: International co-ordination with Sweden and Norway as well as the Russian Federation need to be extended. Assessment: Finland has deepened its coordination with Sweden and Norway in shared RBDs, including via the preparation of common “roof reports” that bring together the respective national RBMPs. Finland’s ongoing cooperation activities with the Russian Federation have also strengthened, including activities such as monitoring and mapping. Consequently, Finland has implemented this recommendation.

Topic 2Characterisation of the River Basin District 2.1Assessment of implementation and compliance with WFD requirements in the second cycle

Figure 3.3 Confidence in the classification of ecological status or potential of surface water bodies in Finland based on the most recently assessed status/potential Source: WISE electronic reporting Figure 3.4 compares the ecological status of surface water bodies in Finland for the first plan with that for the second plan (based on the most recent assessment of status/potential) and that expected by 2015). Overall ecological status has been reported for all delineated water bodies, which was not done for the first RBMPs, when only 50 % were classified. The confidence has improved compared to the first RBMPs, especially for rivers and lakes. The overall ecological status has not improved significantly since the first RBMPs, and the status changes at the quality element level is not reported, due to lack of available data for the first RBMPs (Annex 0). This lack of data is hard to understand, as Finland has compiled a substantial amount of data for several biological quality elements during that first RBMPs in order to develop and intercalibrate the assessment methods. In the Åland RBD, the ecological status/potential in coastal waters and lakes is much worse than reported for the first RBMP, but this is probably due to changes in monitoring and assessment methods.



Figure 3.4 Ecological status or potential of surface water bodies in Finland for the second RBMPs, for the first RBMPs and expected in 2015. The number in the parenthesis is the number of surface water bodies for both cycles. Note the period of the assessment of status for the second RBMPs was 2006 to 2013. The year of the assessment of status for the first RBMPs is not known Source: WISE electronic reporting According to the Kymijoki-Gulf of Finland RBMP the ecological status of surface water bodies has generally remained the same in comparison to the previous classification. In most of the cases, changes in class are caused by methodological changes, new monitoring data and changes in the typology. In the Åland RBD, the ecological status of coastal water bodies (measured by chlorophyll a) has improved in three areas and deteriorated in five areas. The changes are considered to be mainly caused by the general state of the Baltic Sea. The chlorophyll levels increased in all reported lakes. Changes cannot be assessed using more parameters since the data from the first RBMPs is missing. Member States were asked to report the expected date for the achievement of good ecological status/potential. The information for Finland is shown in Figure 3.5.



Figure 3.5 Expected date of achievement of good ecological status/potential of surface water bodies in Finland. The number in the 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 Figure 3.6 shows the ecological status/potential of water bodies for each biological quality elements used in the classification of surface water bodies.



Figure 3.6 Ecological status/potential of the biological quality elements used in the classification of surface waters in Finland Note that water bodies with unknown status/potential have been excluded from the presentation

Source: WISE electronic reporting. A differentiated presentation of this data between ecological status and potential and including all types of quality element can be viewed here Figure 3.7 compares the classification of biological quality elements in terms of ecological status/potential for the two cycles. It should be noted that this comparison should be treated with some caution as there are differences between the numbers of surface water bodies classified for individual elements from the first to the second RBMPs.



Figure 3.7 Comparison of ecological status/potential in Finland according to classified biological quality elements in rivers and lakes from the first to the second RBMPs. Note the number in brackets is the number of surface water bodies with status Source: Surface water bodies: Quality element status Figure 3.8 and Figure 3.9 illustrate the basis of the classification of ecological status/potential of rivers and lakes in Finland for the second RBMP. The classification is more often based on several quality elements in all water categories and on more than had been used for the first RBMPs, although for many water bodies in lakes and coastal waters, the assessment is still based on phytoplankton and nutrients only. The nutrient quality elements are reported as not being monitored, or assessed in coastal waters in the Åland RBD. Finland subsequently clarified that there is monitoring in more than 100 sites in coastal waters of the Åland RBD. The results of monitoring are used for classification. This information is contrary to the information reported electronically to WISE for this RBD.

Figure 3.8 The classification of the ecological status or potential of surface waters in Finland 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 The percentage of surface water bodies in Finland where no biological quality element or no hydromorphological (HYMO) or no general physicochemical (PHYSCHEM) or no River Basin Specific Pollutant (RBSP) has been used in the classification of ecological status or potential Source: WISE electronic reporting The basis of the classification of the individual quality elements is illustrated in Figure 3.10 Figure 3.10 Basis of the classification of ecological status/potential in Finland. The percentages are in terms of all waterbodies in each category. Source: WISE electronic reporting There is very little change in ecological status since the first RBMPs, and quality element level change is not reported due to lack of comparable data for the first RBMPs (Annex 0 justification). The ecological status in coastal waters is still less than good for all water bodies in the Kymijoki-Gulf of Finland RBD and for 93 % of water bodies in the Åland RBD, which is a deterioration compared to the first RBMPs as 68 % were less than good. For rivers in the Kymijoki-Gulf of Finland RBD, the proportion less than good is 53 %, which is almost the same as for the first RBMPs. (No rivers are delineated in the Åland RBD). For lakes, the proportion less than good is now 26 % in the Kymijoki-Gulf of Finland RBD, which is a slight improvement from 31 % less than good for the first RBMP, while in the Åland RBD the proportion less than good is higher for the second RBMP (57 %) than for the first, when all the lakes were reported to be in high or good ecological status. The reason for the negative changes is probably a change of methods from expert judgement for the first RBMPs to monitoring for the second. Use of monitoring results for classification

The majority of water bodies was reported to be classified based on monitoring at quality element level. Of the hydromorphological quality elements, hydrological regime is the only element monitored in rivers and lakes: all elements are used in classification only on the basis of expert judgement. Finland reported that the grouping of water bodies has been used in extrapolating the assessment and classification of ecological status from monitored water bodies to those water bodies with no monitoring sites. However, this is not consistent with the information reported on the means of classification of quality elements where grouping was reported not to be used. For the first and the second RBMPs, no water bodies were reported as being directly monitored for morphological quality elements, and close to zero monitoring of River Basin Specific Pollutants were reported. However, all those quality elements have been classified for all water bodies in all water categories (based on expert judgement), and all water bodies were classified in good status for the River Basin Specific Pollutants. River continuity is reported as being classified for rivers, coastal waters and for lakes. Hydromorphological quality elements are used for classification, but no reference conditions have been established and they are not linked to the biological quality elements. The basis for classification of both hydromorphological quality elements and River Basin Specific Pollutants seems to be unreliable. For general physicochemical quality elements, the classification is based only on expert judgement in the Åland RBD for total nitrogen and total phosphorus. No general physicochemical standards have been reported for this RBD. In the Kymijoki-Gulf of Finland RBD, many parameters were monitored, but not used for classification (oxygen in all water categories, transparency in lakes, acidification parameters in lakes, thermal conditions and salinity conditions). It is not clear whether the data will be used for development of assessment methods or for other purposes. Assessment methods and classification of biological quality elements There are now assessment methods developed for all relevant biological quality elements, including angiosperms in coastal waters, macrophytes in rivers and phytobenthos in lakes, which were missing for the first RBMPs. However, the method for macrophytes in rivers is not reported in the electronic report to WISE, probably due to very recent completion and intercalibration of the method. The assessment methods were reported to be sensitive to most reported significant impacts, the exception being for chemical pollution and acidification in coastal waters. Intercalibration of biological assessment methods and national classification systems Many Finnish water body types are linked to the common intercalibration types, but it is not clear which biological quality element methods have been intercalibrated, and how the class boundaries have been set for national types not linked to the common intercalibration types. For example, none of the three national types for coastal waters in the Åland RBD are linked to any common intercalibration type, although the methods used are the same that were intercalibrated for Sweden and Finland. Assessment methods for hydromorphological quality elements All the relevant hydromorphological quality elements were reported to be assessed in terms of ecological status/potential in rivers, lakes and coastal waters but the classification boundaries are not related to the class boundaries for the sensitive biological quality elements. There are no reference conditions reported for hydromorphological quality elements in any water category. Hydromorphological quality elements are nevertheless used for assessment of ecological status based on expert judgement: the basis for this expert judgement is not clear. The second RBMPs were examined for information on the major changes between the first and second RBMPs in the assessment methodologies for the hydromorphological quality elements. For rivers and lakes the approach is the same, but more care is taken that a detailed assessment is carried out for all water bodies where hydromorphological aspects are identified as a significant factor deteriorating the quality of the water body. For coastal waters, also similar approach is used as during the first RBMPs but more care is taken to include expert views and the views of different stakeholders when the significance of the effects is assessed. The methodology is the same in all RBMPs. Assessment methods for general physicochemical quality elements Only a limited number of general physicochemical quality elements were used in the assessment of ecological status/potential of surface water bodies: nutrient conditions in all three water categories, transparency in coastal waters and acidification status in rivers. There are therefore significant gaps in the elements required to be assessed in all categories. Type-specific standards were reported for nutrients in all water categories in many types of water bodies, acidification parameters in rivers and secchi depth in coastal waters, and all are reported as being compatible with the good-moderate status/potential boundaries for sensitive biological quality elements. Standards are not developed for oxygen in any water category, or for secchi depth in lakes, but these quality elements were monitored. Selection of River Basin Specific Pollutants and use of Environmental Quality Standards There is no information on how the River Basin Specific Pollutants have been identified in the second RBMPs . No metal has been identified as River Basin Specific Pollutants. Finland reported nine different River Basin Specific Pollutants that are monitored and 13 different River Basin Specific Pollutants for which Environmental Quality Standards have been set. Environmental Quality Standards have been set for all substances monitored. It is not clear whether and how the substances not monitored were taken into account in the assessment of status. 13 Environmental Quality Standards apply to coastal waters though none was reported to be monitored in coastal waters. There were Environmental Quality Standards for 12 substances in rivers and for 13 substances in lakes.

12 Environmental Quality Standards were reported in water, one in sediment (for 3, 5-dimethyl-phenol, although this substance is not reported as monitored). The standards have not been derived in accordance with the 2011 Technical Guidance Document No 27 . The analytical methods used for the substances meet the minimum performance criteria laid down in Article 4(1) of Directive 2009/90/EC for the strictest standard applied in river and lakes. However, for four substances in coastal water the analytical method does not meet the minimum performance criteria laid down in Article 4(1), but does comply with the requirements laid down in Article 4(2) for the strictest standard applied. River Basin Specific Pollutants are classified mainly using expert judgement, only a few water bodies are classified based on monitoring results. It is not clear on what information this expert judgment was based. All water bodies were reported to be in good status for River Basin Specific Pollutants. However it should be highlighted that the spatial coverage of monitoring is low, and environmental quality standards were not set according to the Technical Guidance Document, which reduces the reliability of the assessment. Overall classification of ecological status (one-out, all-out principle) The one-out, all-out principle has been used in all RBDs. It is not clear how the change in combination rules from the weight-of-evidence approach used for the first RBMPs to the one-out-all-out approach for the second RBMPs affects the comparability of ecological status assessment. There is no information available on how the no-deterioration principle has been applied, nor on how they deal with spatial variability within water bodies. 3.2Main changes in implementation and compliance since the first RBMPs Overall there has been a 2.3 fold increase in the number of monitoring sites in Finland since the first RBMPs. Proportionally the largest increase was in coastal waters (2.8 fold), followed by rivers (2.4 fold) and lakes (2.1 fold): Finland did not identify any transitional water bodies. Generally there were increased numbers of sites in most RBDs though there were small decrease in lakes sites in three RBDs, and in coastal waters and rivers in one RBD. For Finland as a whole, for the second RBMPs around 20 % of water bodies in coastal waters, lakes and rivers were included in surveillance monitoring. This was an increase from the first RBMPs where 11 % to 15 % of water bodies were included in surveillance monitoring. The biological quality element predominantly used for surveillance monitoring for the first RBMPs in each water category was the same as those used for the second. The other biological quality elements used were also the same but the proportion of water bodies monitored for some biological quality elements decreased for the second RBMPs compared to the first. For example, benthic invertebrates were monitored in 94 % of coastal water bodies included in surveillance monitoring for the first RBMPs compared to 15 % for the second: there were similar reductions in lakes and rivers. In addition, there was a reduction in the proportion of water bodies in surveillance monitoring where fish were monitored in lakes (-10 %) and rivers (-13 %). Ecological status has deteriorated for lakes and coastal waters in the Åland RBD, probably due to improved monitoring and assessment methods. Lakes in the Åland RBD are assessed with more biological quality elements / quality elements for the second RBMP than for the first. The proportion of surface water bodies of unknown status/potential has decreased from 50 % to 2 %. The confidence the classification has also improved. The classification is based on more comprehensive methods that consider more of the relevant biological quality elements, all hydromorphological quality elements (although not all are relevant) and some physicochemical quality elements (mainly nutrients). The gaps in the biological quality element methods highlighted from the assessment of the first RBMPs have now been covered, although some very recently, so not reported electronically to WISE. Physicochemical standards have been reported for nutrients for specific types and are related to the good-moderate status/potential boundaries for the sensitive biological quality elements. Hydromorphological quality elements are used for classification, but are reported not to be monitored. The one-out, all-out principle has been used for the second RBMPs, in contrast to the first. 3.3Progress with Commission recommendations The Commission recommendations based on the first RBMPs and first Programme of Measures requested action on the following: ·Recommendation 8: There is a large proportion of surface water bodies in Finland for which the status is unknown. Some RBDs have a high proportion of water bodies for which status is unknown. Finland therefore needs to increase its efforts in this first cycle to decrease this lack of knowledge and uncertainty. Some recommendations below are crucial to ensure this improvement. Finland needs to improve the surface water monitoring and the quality of the reporting of monitoring networks, methodologies and results, and to extend the monitoring programmes to cover all water bodies (including smaller water bodies) and all required quality elements. Assessment: A large percentage of surface water bodies have been reported as having unknown status/potential in the first RBMP (52.8 % of 6153 surface water bodies). For the second RBMPs this was reduced to 1.4 % of the 6806 surface water bodies. Significant progress has therefore been made. Some required quality elements were not monitored (e.g. morphological conditions, macrophytes in rivers etc.). Considering hydromorphology only in operational monitoring programmes (as was in 2013) and not in surveillance ones is not consistent with the WFD. Macrophytes in rivers are only monitored in around 1 % of river water bodies. Morphological conditions are not included in surveillance monitoring. There has been very limited progress on this aspect.

The number of small water bodies (less than 0.5 km²) monitored in the second RBMPs has increased since the first RBMPs. For coastal water bodies, 1 of the 5 water bodies which are smaller than 0.5 km² is monitored in the second RBMPs, compared to none in the first. For lakes, the proportion of small water bodies monitored increased from 4 % of the total number of monitored lakes to 6 %. For rivers, the number of small water bodies monitored increased from 2 to 17 Therefore, regarding the number of small water bodies monitored, there has been progress from the first to the second RBMPs. A significant proportion of surface water bodies included in surveillance monitoring were not monitored for all required biological quality elements. There is still a predominant focus on the monitoring of phytoplankton in coastal waters and lakes, and on the physicochemical quality elements in all water categories. There has been some progress on this aspect but there are still important gaps on this issue. Some of the biological quality element methods missing for the first RBMPs have now been developed. The following new biological quality element methods have been developed: rivers macrophytes, lakes phytobenthos and coastal waters angiosperms. The sensitivity to impacts has been reported for each biological quality element though there are gaps for two impact types in coastal waters. In conclusion, the recommendation has been partially fulfilled. ·Recommendation 9: Finland needs to base its classification on such extended monitoring results. The ecological status assessments are based primarily on expert judgement but not on WFD compliant methods, and there is a significant shortcoming in the availability of data for classification. Assessment: The results of monitoring have been overwhelmingly used for the classification of biological and physicochemical quality element with expert judgment only being used in a very few cases. However, the hydromorphological quality elements have been exclusively classified by expert judgment. Hydrological regime is monitored in rivers and lakes, but morphological quality elements and river continuity are not monitored in any water category. The recommendation has been partially fulfilled because of the lack of monitoring of, and the use of expert judgement for the classification of, hydromorphological quality elements. ·Recommendation 10: The identification of River Basin Specific Pollutants needs to be more transparent, with clear information of how pollutants were selected, how and where they were monitored, and where there are exceedances and how such exceedances have been taken into account in the assessment of ecological status. Assessment: It is not clear how River Basin Specific Pollutants have been identified. (However Finland reported that the CIS Guidance Document n°27 was not used to derive the Environmental Quality Standards). Finland has provided detailed information on how and where the substances are monitored. It is important to note that River Basin Specific Pollutants were not monitored in coastal waters, and the spatial coverage of monitoring for lakes and rivers is low. Overall nine River Basin Specific were reported to be monitored (only in water) while standards were reported for 13 substances: it is not clear whether and how the substances not monitored were taken into account in the assessment of status. Information reported on monitoring frequencies is inconsistent, but Finland subsequently clarified that the monitoring frequencies in rivers are higher than the minimum recommended frequency. No reliable information is available on monitoring frequencies in lakes. No failures of good ecological status/potential were reported for River Basin Specific Pollutants. The one-out-all-out has been applied to assess ecological status. In most cases, the status of river basin specific Pollutants has been determined based on expert judgment, and no information is available on the basis for this expert judgment. In conclusion, the recommendation has been partially fulfilled. ·Recommendation 11: Provide more information about the threshold values/standards that have been set to support good status, not only for surface waters, but also for groundwater, including coastal waters. Assessment: The Commission advised Finland to set out the calculations they have made of the nitrate and phosphate loading from agriculture that needs to be reduced in order to allow for nutrient conditions in water bodies that would be consistent with the achievement of good status. Finland reported standards for total nitrogen and total phosphorus in rivers, lakes and coastal waters, and are related to the good-moderate boundary of the sensitive biological quality element i.e. support good status. Finland did not report the loads of phosphorus and nitrogen that need to be reduced to achieve WFD objectives. On this basis the recommendation has been partially 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 4.1.1.Monitoring 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 Finland for the second RBMP. Figure 4.1 summarises the proportion of sites used for the monitoring of chemical status in rivers, lakes and coastal waters for the second RBMP (territorial waters are not monitored and their chemical status is not assessed). 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 all sites are used for the monitoring of chemical and ecological status. However, Finland provided additional information stating that there has been a reporting error and in fact not all monitoring sites are used for monitoring of chemical status. Finland also stated that data is rarely available compared with the large number of waterbodies. For the second RBMP, for surface water bodies across all RBDs in Finland, there are a similar proportion of sites monitored for Priority Substances under surveillance monitoring and operational monitoring (11 % and 10 % respectively). Figure 4.1 Proportion of sites used for monitoring of chemical status and, for comparison, ecological status, in Finland. The number in parenthesis next to the category is the total number of monitoring sites irrespective of their purpose Source: WISE electronic reporting - Finland subsequently clarified that there has been a reporting error and that not all monitoring sites are used for monitoring of chemical status. Figure 4.2 summarises the proportion of water bodies monitored for chemical status in lakes and rivers for the second RBMP. In this figure, no distinction is made between water bodies monitored for surveillance and/or operational purposes. Also given is the proportion of water bodies monitored for any purpose and, for comparative purpose, those for ecological status. In Finland overall, 48 % of river water bodies, 35 % of lake water bodies and 74 % of coastal water bodies were monitored for chemical status. In most RBDs in Finland, there is a small number of surface water bodies failing to achieve good chemical status being monitored as part of the operational monitoring programme for chemical status i.e. on average 4.5 % . However, a higher percentage of water bodies failing to achieve good chemical status are monitored in the following RBDs: Kemijoki (100 %), Kokemäenjoki-Archipelago Sea-Bothnian Sea (50 % of coastal waters and 13 % of rivers), Kymijoki-Gulf of Finland (33 % of coastal waters). All of the surface water bodies in the Tornionjoki, Teno, Näätämöjoki and Paatsjoki and Åland RBDs were reported to be at good status. Figure 4.2 Proportion of total water bodies in each category which are monitored, monitored for chemical status and monitored for ecological status, in Finland. The number in parenthesis next to the category is the total number of water bodies in that category Source: WISE electronic reporting 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 According to WISE, a large number of coastal waters in Finland were not monitored for any Priority Substances: 100 % in the Tornionjoki and Åland RBDs, 92 % for the Kokemäenjoki-Archipelago Sea-Bothnian Sea RBD and between 78 % and 80 % for the Kymijoki-Gulf of Finland, Oulujoki-Iijoki and Kemijoki RBDs. The remaining coastal water bodies in these RBDs were monitored for between one and five Priority Substances. The Åland RBD however subsequently clarified that priority substances are monitored in coastal waters, in water, sediment and biota. There are also large numbers of lake waters with no monitoring for Priority Substances across all the RBDs. The monitoring sites for lake water bodies are predominantly monitored for only one Priority Substance. Similarly, for river water bodies across seven RBDs, between 90 and 99 % are not monitored for Priority Substances. 2 % of river waters in Kokemäenjoki-Archipelago Sea-Bothnian Sea were monitored for more than 10 Priority Substances. The remaining river waters were monitored for between 1 and 10 Priority Substances. In WISE, only mercury is reported to be monitored in biota for status assessment with hexachlorobenzene and hexachlorobutadiene being monitored in water. There is no information available to confirm whether the water environmental quality standard is at least as protective as the biota standard. However, Finland subsequently clarified that mercury, hexachlorobenzene and hexachlorobutadiene were monitored in biota for status assessment (hexachlorobenzene and hexachlorobutadiene being also monitored in water according to WISE reporting).

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 in water were reported in WISE for 26 Priority Substances at the site level in the Kymijoki-Gulf of Finland RBD and for 22, 21, 12 and four substances in the Kokemäenjoki-Archipelago Sea-Bothnian Sea, Oulujoki-Iijoki, Vuoksi and Tornionjoki RBDs respectively. The monitoring frequency in both water and biota was once per year and every three years in the monitoring cycle for each monitoring site within each of the seven RBDs. These reported frequencies do not meet the guidelines for operational or surveillance monitoring in water or biota for status assessment in the Directive. The RBMPs provide no specific information on frequencies. No explanation was provided for the reduced frequency. 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. Spatial coverage and frequencies There is no monitoring reported in Finland for long-term trend analysis in sediment and/or biota. Finland has provided additional information stating that they will be monitoring ubiquitous persistent, bioaccumulative and toxic substances in fish (although it is not totally clear whether this will be part of a trend assessment), and that they are also considering monitoring sediment in undisturbed lakes. 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. Finland reported that 36 substances were included in an inventory for each of the RBDs. (See section 2.1.11 of this report for further information). However, not all the substances were reported to be discharged. Across the eight RBDs in Finland only between three and eight of the Priority Substances in an inventory were reported as being discharged. For seven of the eight RBDs, with the exception of DEHP in the Oulujoki-Iijoki RBD, all of the substances discharged were reported to be monitored. In the Åland RBD 3 substances were reported as being discharged but none were monitored (although a reporting error with regard to monitoring is suspected ). Performance of analytical methods used According to WISE for 25 groups of Priority Substances the analytical methods used meet the minimum performance criteria laid down in Article 4(1) of Directive 2009/90/EC for the strictest standard applied. For the remaining 16 reported, Finland reported that the analytical methods complied with the requirements laid down in Article 4(2) of Directive 2009/90/EC for the strictest standard applied. The method of dealing with measurements of Priority Substances lower than the limit of quantification was as specified in Article 5 of Directive 2009/90/EC. 4.1.2.Chemical Status of surface water bodies Member States are required to report the year on which the assessment of chemical status was based. This may be the year 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. For Finland, the assessment of chemical status was undertaken between 2010 and 2014. The chemical status of surface water bodies in Finland for the second RBMP is illustrated on the map below. This is based on the most recent assessment of status. The chemical status of surface waters in Finland for the first and second RBMPs is given in Table 4.1. More information on the chemical status in each RBD and water category can be found on the website of the European Environment Agency . Map 4.1 Chemical status of surface water bodies in Finland based on the most recently assessed status of the surface water bodies

Note: Standard colours based on WFD Annex V, Article 1.4.3. Source: WISE, Eurostat (country borders) Overall between the first and second RBMPs, there was a decrease in the proportion of surface water bodies with good chemical status from 64 % down to 49 %, similar decreases occurred across all water body types (artificial, heavily modified and natural) . The proportion of surface water bodies that fail to achieve good chemical status dramatically increased between the two cycles, from 0.44 % to 49 %. In the first cycle there were surface water bodies listed as having an unknown status which were not observed in the second cycle. The increase in the number of surface water bodies failing to achieve good status may result from the classification of water bodies that were in unknown status in the first RBMPs. The considerable reduction in surface water bodies at unknown status in the second RBMP represents a significant improvement compared to the first RBMP. Table 4.1Chemical status of surface water bodies in Finland 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 EQS Directive 2008/105/EC (version in force on 13 January 2009). Some Member States did not implement the Directive in the first RBMPs as the transposition deadline was in July 2010, after the adoption of the first RBMPs Category Good Failing to achieve good Unknown Number % Number % Number % Second RBMP Lakes (4617) 1 778 39 % 2 839 61 % Rivers (1913) 1 322 69 % 591 31 % Coastal (276) 266 96 % 10 4 % Total (6806) 3366 50 % 3440 50 % First RBMP Lakes (4275) 2 639 62 % 3 0.07 % 1 633 38.20 % Rivers (1602) 1 026 64 % 24 1.50 % 552 34 % Coastal (276) 273 99 % 3 1 % Total (6153) 3938 64 % 27 0.4 % 2188 35.6 % Source: WISE electronic reporting Figure 4.3 shows the confidence in the classification of chemical status for the second RBMP. Overall 93 % of surface water bodies in Finland were classified for chemical status with low confidence, 6 % with medium confidence and only 1 % with high confidence regardless of class. For surface water bodies, most of the classifications of good status and those that fail to achieve good status are given a low or medium level of confidence. The RBMPs indicated that confidence was assigned according to a national methodology comprising four classes: (1) no classification; (2) expert opinion based on use, emission and transport data; (3) chemical analyses, some data; (4) chemical analyses, good data . Confidence in the classification of chemical status for the first RBMPs was not reported. Figure 4.3 Confidence in the classification of chemical status of surface water bodies in Finland based on the most recently assessed status/potential Source: WISE electronic reporting On average, for seven out of eight RBDs, approximately 90 % of surface water bodies have been classified via expert judgement. The Åland RBD only includes lakes and coastal waters; 100 % of coastal waters were classified through expert judgement, 71.4 % of lakes were classified through monitoring, with the remaining 28.6 % being classified through expert judgement. The extensive use of expert judgement is reflected in the reported low confidence in the classification. In contrast to the information reported to WISE and summarised above (which states that water bodies are classified through either monitoring or expert judgement), the RBMPs include descriptions of the use of grouping and modelling in the assessment of chemical status. In the Vuoksi RBMP, grouping is especially used for the assessment of lakes in relation to mercury and according to the national methodology document; grouping is combined with expert opinion both in the case of mercury and other chemical substances. It is therefore not clear which techniques have been used in the absence of monitoring data. Finland also stated that all available measured data was used for the classification and that expert assessment was used, when no measured data existed. The classification was carried first by carrying out a specific generic expert assessment to all water bodies, and this was subsequently replaced by measured data when available. The expert assessment is reported to have involved the following: •No environmental quality standard exceedances were expected for substances, which were not detected or detected only in trace level in Finnish surface water (many of those chemicals had either never or were no longer used in Finland);

•For mercury, which was the most important substance in chemical classification in Finland, a simple grouping model was developed and used ; •In addition to mercury, only a few other substances were expected to exceed their EQS values occasionally or in specific areas. Regional authorities undertook the assessment according case specific potential loading routes; •For tributyltin, measurements were available only from expected ‘risky’ locations (such as harbours); Cadmium and Nickel presented a risk in certain areas (rivers on the central western coast in acid sulphate soil areas) and downstream from some mining areas, scattered in different parts of Finland. Figure 4.4 compares the chemical status of surface water bodies in Finland for the first RBMP with that for the second RBMP (based on the most recent assessment of status) and that expected by 2015. This illustrates the reduction in the proportion of surface water bodies in good status from the first to the second cycles which was anticipated in the expected status in 2015. The assessment of chemical status for the second RBMP was expected to be based on the standards laid down in the EQS Directive (version in force on 13 January 2009 ). Some Member States did not fully implement the Directive in the first RBMPs as the transposition deadline was in July 2010, after the adoption of the first RBMPs. Good chemical status should be reached by 2021 in relation to the revised environmental quality standards, unless Member States apply exemptions under WFD Article 4(4) and/or less stringent objectives under WFD Article 4(5). Member States were asked to report the expected date for the achievement of good chemical status. The information for Finland is shown in Figure 4.5. Good chemical status of surface water bodies is expected to be achieved by the end of the third planning cycle in five of the eight RBDs. In the remaining three RBDs (Tornionjoki, Teno, Näätämöjoki and Paatsjoki and Åland) surface waters were reported to already be at good status. The expected or actual improvement in the chemical status of surface water bodies at the end of the first cycle was reported to be as described in the RBMP. Figure 4.4 Chemical status of surface water bodies in Finland for the second RBMP, for the first RBMP and expected in 2015. The number in the parenthesis is the number of surface water bodies for both cycles. Note the period of the assessment of status for the second RBMP was 2010 to 2014. The year of the assessment of status for first RBMP is not known Source: WISE electronic reporting Figure 4.5 Expected date of achievement of good chemical of surface water bodies in Finland. The number in the parenthesis is the number of water bodies in each category Source: WISE electronic reporting Priority Substances causing the failure of good chemical status Three Priority Substances were reported to be causing failure to achieve good chemical status in surface water bodies in Finland. The most common priority substances causing failure to achieve good chemical status are shown in Figure 4.6. The substances causing the greatest proportion to fail good chemical status in the second RBMP were mercury (50 %), cadmium (0.71 %) and nickel (0.35 %). Figure 4.6The most common Priority Substances causing failure to achieve good chemical status in surface water bodies in Finland Source: WISE electronic reporting. Overall for surface water bodies in Finland, the largest proportion of exceedances was for the Annual Average-Environmental Quality Standard for mercury (98 %). In terms of exceedance of both types of standard at the same time (noting that separate exceedances for the maximum allowable concentration and not the annual average were not observed and/or reported), the largest proportion was for cadmium (0.31 %).

In terms of Priority Substances resulting in an improvement in the chemical status of a water body, nickel showed an improvement in 3.2 % of the river water bodies and cadmium an improvement of 1 % in the Kokemäenjoki-Gulf of Finland RBD. No improvements occurred in the other RBDs. Directive 2013/39/EU amended the EQS Directive. In particular, it sets more stringent environmental quality standards for seven substances . Member States were required to indicate if the new standards caused the status of the surface water body to appear to deteriorate. The new standards were not reported by Finland to cause surface water bodies to deteriorate. Ubiquitous persistent, bioaccumulative and toxic Priority Substances According to Article 8(a) of the EQS Directive , eight priority substances and groups of priority substances are behaving like ubiquitous, persistent, bioaccumulative and toxic (uPBT) substances . These substances are generally expected to cause widespread exceedances, and their emissions can be challenging to tackle (e.g. due to long-range atmospheric transport and deposition). In order to show the progress made in tackling other priority substances, Member States have the possibility to present the information related to chemical status separately for these substances. The assessment of uPBT substances for Finland has been based on the 2008 EQSs. In Finland overall, there were 3440 water bodies reported to be failing to achieve good status in the second RBMP. Of these 3419 (over 99 %) are reported to have at least one uPBT that is failing its environmental quality standards; however, for approximately half of these the uPBT substance was determining the status alone. This is illustrated in the 2018 State of Water report of the European Environment Agency . The influence of uPBT substances on the cause of the failure to achieve good chemical status in Finland is therefore significant; in the vast majority of cases this is due to mercury with a few coastal water bodies affected by tributyltin. Priority Substances used in the assessment of chemical status compared to those monitored For the seven mainland RBDs, chloroalkanes was the only Priority Substance reported as not being used in the assessment and not monitored. The remaining 40 out of the 41 Priority Substances reported for these RBDs were used in the assessment of status. However, not all of these substances were reported as being monitored across these seven RBDs: between 4 and 30 out of 40 Priority Substances were monitored in the mainland RBDs. For the Åland RBD, the following 6 out of 41 Priority Substances were reported as not being used in the assessment: carbon tetrachloride; trichloroethylene; 4-nonylphenol; di(2-ethylhexyl)phthalate (DEHP); tetrachloroethylene, and; octylphenol (4-(1,1',3,3'-tetramethylbutyl)-phenol). According to WISE, no Priority Substances were reported to be monitored in this RBD, however the Åland RBD subsequently clarified that monitoring of priority substances is performed as described in the RBMP. The fact that more Priority Substances were used in the classification of chemical status than in monitoring would explain the widespread use of expert judgement in the assessment of chemical status. Application of alternative environmental quality standards for water, biota and sediment According to the EQS Directive, Member States may opt to apply environmental quality standards for another matrix than the one specified in the Directive for a given substance. If they do so, they have to ensure the environmental quality standard they set in the other matrix (or matrices) offers at least the same level of protection as the standard established in the Directive. Finland reported that all of the Environmental Quality Standards laid down in Part A of Annex I of the Directive 2008/105/EC (in force in 2009) had been applied and no alternative and/or additional standards had been applied. Use of mixing zones Article 4 of the EQS Directive provides Member States with the option of designating mixing zones adjacent to points of discharge in surface waters. Concentrations of priority substances may exceed the relevant environmental quality standard within such mixing zones if they do not affect the compliance of the rest of the surface water body with those standards. Member States that designate mixing zones are required to include within their RBMPs a description of the approaches and methodologies applied to define such zones, and a description of the measures taken to reduce the extent of the mixing zones in the future. For three of the eight RBDs in Finland (Vuoksi, Kokemäenjoki-Archipelago Sea-Bothnian Sea and Oulujoki-Iijoki), mixing zones have been designated under Article 4 of the EQS Directive. For the remaining five RBDs, mixing zones have not been designated. Mixing zones have been designated following the tiered approach as laid down in the ‘Technical Background Document on Identification of Mixing Zones’ . Measures reported to be taken to reduce the extent of mixing zones in the future include a review of the permits referred to in Directive 2008/1/EC (the IPPC Directive). Finland provided additional information stating that in Kemijoki RBD in addition to those identified above, one mixing zone has been designated. Background Concentrations and Bioavailability The EQS Directive stipulates that Member States have the possibility, when assessing the monitoring results against the environmental quality standard, to take into account: (a) natural background concentrations for metals and their compounds, if they prevent compliance with the environmental quality standard, and; (b) hardness, pH or other water quality parameters that affect the bioavailability of metals. No information has been reported for any of the eight RBDs in Finland, as to whether natural background concentrations for metals and their compounds are taken into consideration where such concentrations prevent compliance with the relevant Environmental Quality Standards.

Finland subsequently clarified that the typical background level for metals has been established in the Government Degree 1040/2006 on the harmful and hazardous substances in the surface waters (in the Annex C2). Measured concentrations are reported to be compared to the sum of the background level and the given EQS-value. Finland states that in all of its RBDs, in assessing monitoring results against EQSs, the application of water quality parameters that affect the bioavailability of metals have been taken into account. 4.2.Main changes in implementation and compliance since the first cycle Comparing the number of sites and water bodies monitored for operational and surveillance purposes between the first and second cycles, there appears to be a net increase in monitoring sites and surface water bodies monitored for operational purposes (an increase of 876 sites and 843 water bodies noting that these numbers are for a range of parameters, not just Priority Substances) both due to relatively large increases in both river and lake monitoring. For surveillance monitoring, the number of sites has increased by 802 and the number of water bodies has increased by 799 since the first cycle. However, there remains a significant proportion of surface water bodies not monitored for chemical status (48 % of coastal water bodies, 35 % of lake water bodies and 74 % of river water bodies were monitored for chemical status). Where monitoring for chemical status does occur, the number of Priority Substances monitored varies widely: in coastal waters up to 5, in lakes one and in rivers up to 10 Priority Substances were monitored. Only 1 of the 14 Priority Substances for which the EQS Directive requires the monitoring of the long-term trends in biota and/or sediment in coastal, lake and river water bodies in all RBDs. Finland has reported that that all of the Environmental Quality Standards laid down in Part A of Annex I of the Directive 2008/105/EC for assessment of the chemical status of bodies of surface water had been applied and that alternative and/or additional standards for particular Priority Substances had not been applied. This represented progress from the first cycle when these Environmental Quality Standards were not used. Overall between the two cycles there was a decrease in the proportion of surface water bodies with good chemical status from 64 % down to 49 %, similar decreases occurred across all water body types (artificial, heavily modified and natural). The first cycle also listed some unknown water body types, these were not present in the second cycle so no comparison can be made. The proportion of surface water bodies that fail to achieve good chemical status dramatically increased between the two cycles, from 0.44 % to 49 %. In the first cycle, there were surface water bodies listed as having an unknown status, these were not observed in the second cycle; the increase in the number of surface water bodies failing to achieve good status may result from the classification of water bodies that were in unknown status in the first RBMPs. In terms of Priority Substances causing an improvement in chemical status between the two RBMPs, nickel showed an improvement in 3.2 % of the river water bodies and cadmium an improvement of 1 % in the Kokemäenjoki-Gulf of Finland RBD. No improvements occurred in the other RBDs. Where available, classification of chemical status is based on the results of monitoring. However, on average, for seven out of eight RBDs, approximately 90 % of surface water bodies have been classified via expert judgement and the remaining 10 % by monitoring. Consequently, the majority of the classifications of good and those that fail to achieve good status are made with either low or medium confidence. 4.3.Progress with Commission recommendations The Commission recommendations based on the first RBMPs and first Programme of Measures requested action on the following: ·Recommendation: There is a large proportion of surface water bodies in Finland for which the status is unknown. Some RBDs have a high proportion of water bodies for which status is unknown. Finland therefore needs to increase its efforts in this first cycle to decrease this lack of knowledge and uncertainty. ·Assessment: Progress has been made in addressing this recommendation. The proportion of surface water bodies that fail to achieve good chemical status increased between the two cycles, from 0.44 % to 49 %. In the first cycle, there were surface water bodies listed as having an unknown status, but it was not the case in the second cycle. Therefore the increase in the number of surface water bodies failing to achieve good status may result from the classification of water bodies that were in unknown status in the first RBMPs. It is worth noting in this regard that expert judgement has been widely used in the assessment of chemical status in the second cycle and that the resulting classifications are made with a low degree of confidence. All assessments across Finland were carried out between 2010 and 2014. This recommendation has therefore been partially fulfilled. ·Recommendation: Finland needs to improve the surface water monitoring and the quality of the reporting of monitoring networks, methodologies and results, and to extend the monitoring programmes to cover all water bodies (including smaller water bodies) and all required quality elements). Finland needs to base its classification on such extended monitoring results. Assessment: Limited progress has been made with this recommendation. Comparing the number of sites and water bodies monitored for operational and surveillance purposes between the f