EUROPEAN COMMISSION Brussels, 26.2.2019 SWD(2019) 39 final COMMISSION STAFF WORKING DOCUMENT Second River Basin Management Plans - Member State: Bulgaria 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

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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 second cycle 1.2 Main changes in implementation and compliance since 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 second cycle 2.2 Main changes in implementation and compliance since 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 second RBMPs 3.2. Main changes in implementation and compliance since first cycle 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 second cycle 4.2. Main changes in implementation and compliance since 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 second cycle Topic 6 Monitoring, assessment and classification of chemical status of groundwater bodies 6.1 Assessment of implementation and compliance with WFD requirements in second cycle 6.2. Main changes in implementation and compliance since 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 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 second cycle 8.2. Main changes in implementation and compliance since first cycle 8.3. Progress with Commission recommendations Topic 9 Programme of measures 9.1 Assessment of implementation and compliance with WFD requirements in second cycle

9.2 Main changes in implementation and compliance since 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 second cycle 10.2. Main changes in implementation and compliance since first cycle 10.3. Progress with Commission recommendations Topic11 Measures related to pollution from agriculture 11.1. Assessment of implementation and compliance with WFD requirements in second cycle 11.2. Main changes in implementation and compliance since first cycle Topic 12 Measures related to pollution from sectors other than agriculture 12.1. Assessment of implementation and compliance with WFD requirements in second cycle 12.2. Main changes in implementation and compliance since 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 second cycle 13.2. Main changes in implementation and compliance since 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 second cycle and main changes in implementation and compliance since 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 second cycle 15.2. Main changes in implementation and compliance since 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 second cycle 16.2. Main changes in implementation and compliance since 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 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 information on areas of the national river basin districts including sharing countries is provided in the following table: Table A: Overview of Bulgaria‘s River Basin Districts RBD Name Size (km2) Countries sharing borders BG1000 Danube 47235 Serbia, Romania BG2000 Black Sea 18043 (terrestrial) / 6358 (marine) Romania, Turkey BG3000 East Aegean 35236 Greece, Turkey BG4000 West Aegean 11947 Greece, Serbia, Former Yugoslav Republic of Macedonia Source: River Basin Management Plans reported to WISE A number of catchments are shared with other Member States (Romania and Greece) and with third countries (Turkey, Serbia, Former Yugoslav Republic of Macedonia) and there is a varying degree of co-operation with them. Table B: Transboundary river basins by category and % share in Bulgaria Name international river basin National RBD Countries sharing borders Co-ordination category 1 3 km² % km² % Danube BG1000 Serbia, Romania 47235 5.8 Rezovska / Mutludere BG2000 Turkey 184 24.9 Veleka BG2000 Turkey 792 80 Mesta-Nestos BG4000 Greece 2785 49.6 Struma-Strymonas BG4000 Greece, Serbia, Former Yugoslav Republic of Macedonia 8545 47.2 Maritsa-Evros_Meric BG3000 Greece, Turkey 35230 66.0 Source: WISE electronic reports Note: Bulgaria’s reports to WISE did not include any category of international cooperation for the Black Sea RBD. It was category 3 in the first RBMP. 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 four RBMPs of Bulgaria (Danube, Black Sea, East Aegean and West Aegean) were published on 30 December 2016. 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 Bulgaria are as follows: ·Governance and public consultation Bulgaria has improved coordination with Greece, including exchange of information regarding methodologies and the implementation of joint Interreg projects. A wide range of stakeholders were actively engaged in the preparation of Bulgaria’s RBMPs. Bulgaria carried out joint consultation of its RBMP and Flood Risk Management Plans; and in the Black Sea RBD, also with the Marine Strategy Framework Directive. Bulgaria did not adopt and publish the RBMP in accordance with the timetable in the Water Framework Directive. ·Characterisation of the RBD Type specific reference conditions have not been established for all quality elements. This may lead to some weaknesses in the classification of status/potential according to these quality elements. Further characterisation work has been undertaken since the first RBMPs with the inclusion of the assessment of linkages with surface water bodies and terrestrial ecosystems. For surface and groundwater bodies (except in the Black Sea RBD) significance of pressures is reported to be defined in terms of thresholds and linked to the potential failure of objectives according to the established national approaches. Not all pressure types were assessed and RBMPs do not provide information as to why some pressures have been excluded from the risk assessment. The approach used for defining pressures on surface water bodies in the first RBMPs was refined to determine the relations 'driving force-pressure-status-impact', expand the analysis of pressures (for example by considering more sources of pressures) and implement results from models, projects and research. However the approaches still differed among RBDs and some national methodologies are missing, for example for diffuse pressures. For surface water pressure assessment, there is still a high dependence on expert judgement, which raises questions about the comparability of assessments. Bulgaria reported that between four and six of the 41 Priority Substances were included in the inventories in each RBD. A combination of Tier 1 (point source information) and Tier 2 (riverine load) was implemented, in accordance with the Guidance Document n°28. The data quality was assessed as uncertain. ·Monitoring, assessment and classification of ecological status Although there were errors in reporting, it is clear that the number of monitoring sites increased significantly since the first RBMP. This is particularly the case for surveillance monitoring in rivers and for surveillance and operational monitoring in coastal waters. Both surveillance and operational monitoring sites have been reported in transitional waters, contrary to what happened for the first RBMP. However, there was a large decrease of the number of monitoring sites in lakes. This was mainly the case with surveillance monitoring, but also affected operational monitoring. In particular, operational monitoring in lakes was only done in the West Aegean RBD, even though significant pressures were reported for lakes in the other RBDs.

There is an improvement in the monitoring of quality elements compared to the first RBMP, although there are still some significant gaps. There is very little monitoring of hydromorphological quality elements, which was not done in lakes and transitional water bodies and only for some of them in two river water bodies. All coastal water bodies included in surveillance monitoring were monitored for all required biological, hydromorphological and physicochemical quality elements. However, none of the lake and transitional water bodies and only some of the river water bodies included in surveillance monitoring were monitored for all required biological quality elements. The minimum recommended frequency for monitoring biological quality elements was only met at a small proportion of the sites monitored in all water categories. Assessment methods were reported for all relevant biological quality elements in rivers. However there are significant gaps for the assessment methods in the other water categories. In addition to the very limited monitoring of hydromorphological quality elements, the classification boundaries for those quality elements are not related to the class boundaries for the sensitive biological quality elements. The hydromorphological quality elements were only used in the classification of rivers in terms of hydrological regime and morphological conditions. All the relevant supporting general physicochemical quality elements were assessed in terms of ecological status/potential in all water categories. However, the classification boundaries for some of them are not related to the class boundaries for the sensitive biological quality elements. All the standards for coastal and transitional waters are consistent with the good-moderate status boundary of the relevant sensitive biological quality elements, but this is not the case for rivers and lakes. 63 chemicals that are not Priority Substances and are, therefore, assumed to be River Basin Specific Pollutants are monitored, in water only. Not all of them are monitored at least at the minimum recommended frequency at all of the sites where they are monitored for surveillance and operational purposes. Environmental Quality Standards were reported for 42 substances, relevant to both rivers and lakes. 36 of these substances also had Standards relevant to transitional and coastal waters. The classification of all quality elements in lakes, coastal and transitional waters was based solely on monitoring results, in rivers it was based on a combination of monitoring results, expert judgment and grouping. The use of expert judgment for fish, benthic invertebrates, phytobenthos and macrophytes for some river water bodies may indicate some weaknesses in the assessment methods for biological quality elements in rivers. Very few river water bodies were classified according to hydromorphological quality elements, even when they were monitored. ·Monitoring, assessment and classification of chemical status in surface water bodies Chemical status was monitored and assessed in all water categories except for territorial waters. Between the two RBMPs, there was a large decrease in the proportion of water bodies in good status and a large increase in the proportion in unknown status across all water categories. Overall, 23 % of surface water bodies in Bulgaria were classified for chemical status with high confidence 44 % with medium confidence and 33 % with low confidence. Since the first RBMP, there has been an increase in the number of sites and water bodies monitored, and the adoption of new common national methodologies for the assessment of chemical status. More than 60 % of sites and water bodies in transitional and coastal water are monitored however the proportion was lower for surface fresh waters (14 % and 28 % of lake and river water bodies respectively). Grouping seemed to be used to some extent to classify non monitored water bodies, however the proportion of unknown status remains high. The operational monitoring programme covered all surface water bodies failing to achieve good status in the Black Sea, East Aegean and West Aegean RBDs, and 67 % of surface water bodies failing to achieve good status in the Danube RBD. All Priority Substances listed in inventories and discharged (between four and six Priority Substances depending on the RBD) were monitored in all four RBDs in Bulgaria. The monitoring frequency for status assessment met the recommended minimum frequency for operational and surveillance monitoring at some sites not at others. The RBMPs and background documents provided no specific justification for the reduced frequency of monitoring. Six substances were not monitored in any RBDs, and they were not considered in the inventories, so it is unclear whether they are discharged. Hexachlorobenzene, mercury and hexabutadiene are not monitored in biota for status assessment in Bulgaria.

For trend assessment, there is no monitoring of sediments and/or biota in any RBD. ·Monitoring, assessment and classification of quantitative status of groundwater bodies About 29 % of groundwater bodies are not monitored for quantitative status, but in these cases self-monitoring data was used or the balance method was applied. National methodologies and guidance documents have now been adopted. It remains unclear though how status was assessed without monitoring data. The environmental objectives related to groundwater dependent terrestrial ecosystems and groundwater associated surface waters have partially been considered in the second cycle although they do not cause risk in all river basin districts. ·Monitoring, assessment and classification of chemical status of groundwater bodies The coverage of groundwater bodies by monitoring is not fully complete. However, Bulgaria clarified that the total number of monitoring points for chemical status of groundwater bodies in Bulgaria has increased. Not all substances causing risk are yet subject to monitoring. The chemical status situation has worsened: The total groundwater area failing good chemical status increased from 42 % to 45 %. Bulgaria subsequently clarified that this is due to changes in the delineation of groundwater bodies, a new assessment methodology and the additional monitoring data. Groundwater dependent terrestrial ecosystems have been considered in status assessment in all river basin districts where they exist and are related to risk. Groundwater associated surface waters have been considered in status assessment in all river basin districts where they exist and are related to risk. They have not been considered in threshold value establishment in the West Aegean RBD although there is related risk in seven groundwater bodies. Bulgaria subsequently clarified that there was a reporting error and groundwater associated aquatic and groundwater dependent terrestrial ecosystems are not causing a risk of not achieving good chemical status for groundwater bodies. ·Designation of Heavily Modified and Artificial Water Bodies and definition of Good Ecological Potential The national methodology for designation of heavily modified water bodies and artificial water bodies provides a detailed step-by-step approach for designating heavily modified water bodies and artificial water bodies, including consideration of the significant adverse effects of restoration measures and achievement of the benefits by other means. A national method for determining the ecological potential of rivers, lakes and coastal waters has been developed since the first reporting cycle. However, good ecological potential is reported as defined, including reporting of mitigation measures, only in two out the four RBDs (the Danube RBD and the Black Sea RBD). ·Environmental objectives and exemptions Environmental objectives for ecological and chemical status of surface water bodies were reported in all RBDs as well as for chemical and quantitative status of groundwater bodies. Information is also provided on when it is expected that the objectives will be achieved. Pressures and pollutants leading to exemptions are reported. Drivers behind pressures and impacts leading to exemptions are not reported. Justification of exemptions regarding natural conditions might be an issue of insufficient implementation of WFD requirements, as relevant information is lacking in the RBMPs and reported background documents, or is not fully in line with the WFD requirements. The application of Article 4(7) might be an issue of insufficient implementation of WFD requirements in some basins as not enough information is reported and a generic approach is followed which is not site and project specific.

·Programme of Measures Uncertainties in the status of water bodies means that the gap to good status and the progress required from the implementation of the measures cannot be quantified. The annual operation and maintenance costs of the measures have generally not been quantified, so it is not clear how the financing of these measures can have been agreed. KTMs have been reported to be in place to address the failure of objectives caused by the substances in groundwater identified in three RBDs - no information has been provided for the East Aegean RBD. In general KTMs have been reported for all significant pressure types in both surface water and groundwater. For surface water, some pressure types are not addressed by KTMs in the Black Sea RBD. The number of River Basin Specific Pollutants reported as causing failure is very small. No relevant KTMs have been reported for the East Aegean. No data is reported in any RBD on the number of surface water bodies failing objectives as a result of River Basin Specific Pollutants, although KTMs have been reported in some RBDs. Information is reported for a small number of substances. Not all Priority Substances reported as causing failures are covered by KTMs. The number of Priority Substances reported is very small. Due to the significant number of water bodies assessed in “unknown” ecological and/or chemical status, Bulgaria has not been able to assess the level of significance of the different pressure types and to evaluate the extent of the pressure or chemical substance that is to be reduced to achieve the Environmental Objectives. The RBMPs and Flood Risk Management Plans have not been integrated. Although the plans have not been integrated, all aspects have been co-ordinated, and a financial commitment has been made. Article 9(4) has only been applied in the East Aegean RBD. ·Measures related to abstractions and water scarcity Water quantity data have been reported to support the European State of the Environment Report. Water abstraction pressure is not reported as relevant for Bulgaria; however all river basin districts face water quantity-related problems. The Water Exploitation Index + is not calculated Measures promoting efficient and sustainable water use were implemented in the previous cycle in all river basin districts except in West Aegean, and new measures and/or significant changes are planned for the second cycle. No information is reported by when the existing gaps will be closed. Bulgaria reports that it is not possible to quantify the pressures to reduce and measures that are still needed for achieving the environmental objectives. The RBMPs do not include a water resource allocation and management plan. ·Measures related to pollution from agriculture There is a clear link between agricultural pressures and agricultural measures. No gap assessment for nutrients has been undertaken in any RBDs. Safeguard zones have been established for abstractions for drinking water but also for other purposes (e.g. economically valuable fish species and protected areas). Implementation of basic measures for the control of diffuse pollution from agriculture at source as per Article 11(3)(h) is applied only in Nitrate Vulnerable Zones, except in the West Aegean RBD where the same rules apply across the whole RBD. Supplementary measures for reducing pollution from agriculture are reported.

Financing of measures related to agricultural pressures is secured in all basins and estimations of the potential financial contributions of different sectors (domestic, agriculture, industry and services) in the period 2016-2021 for the financing of the Programme of Measures are provided. Information whether the measures are mandatory or voluntary is not available either in WISE or in the RBMPs. The level of ambition is unclear, as the area covered by measures to achieve environmental objectives is not reported. ·Measures related to pollution from sectors other than agriculture ·Bulgaria has identified a wide range of KTMs relevant to non-agricultural sources of pressures causing failure of WFD objectives, and at least some relevant KTMs have been reported for each RBD ·Measures to tackle urban point sources are reported in all four RBDs, and several actions have been identified corresponding to KTM1. ·However, the RBMP does not make clear whether the funding to tackle urban point sources has already been ‘secured’ for each of the coming years. Nor is it clear whether the measures will be sufficient to fulfil the legal obligations, and whether measures for agglomerations above 2000 population equivalent. have been prioritised in the process. ·Most of the measures presented in the Programmes of Measures do not refer to specific Priority Substances or River Basin Specific Pollutants but only address such pollution in general. KTM15 measures (“Measures for the phasing-out of emissions, discharges and losses of Priority Hazardous Substances or for the reduction of emissions, discharges and losses of Priority Substances”) have not been identified in the East or West Aegean RBDs. ·Measures related to hydromorphology Significant hydromorphological pressures and operational KTMs to deal with these pressures are reported in all RBDs. However, it is not possible to draw specific conclusions on the level of ambition because indicators on the gap to be filled for significant pressures and KTM value indicators are not reported. Ecological flows have been derived and implemented partly, i.e. for some relevant water bodies, and only in one RBD (Danube) but the work is still on-going. In the other three RBDs (Black Sea, East Aegean and West Aegean), no ecological flows have been derived but there are plans to do it during the second cycle. The Programmes of Measures for the Black Sea, East Aegean and West Aegean RBDs indicate that relevant measures will start in 2017-2018. At the same time, no specific information was found that ecological flows will be applied through a review of permits. Natural Water Retention Measures are planned to tackle significant hydromorphological pressures in three RBDs (Danube, Black Sea and East Aegean), although these measures are not described in detail in any of the RBMPs. ·Economic analysis and water pricing policies Concerning cost recovery calculations, it is unclear how environmental and resource costs have exactly been included. No detailed information on the application of the Polluter Pays Principle was found in the RBMPs. ·Considerations specific to Protected Areas (identification, monitoring, objectives and measures) In terms of the numbers of Protected Areas designated, only the number of Drinking Water Protected Areas has changed since the first RBMP. This has decreased by around a third in the second cycle.

The numbers of surface water monitoring sites for Habitat and Urban Waste Water Treatment Protected Areas have decreased significantly in the second cycle compared to the first. ·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. The West Aegean RBD also addressed climate change when monitoring change at reference sites. KTM24 (climate change adaptation measures) address significant pressures in two of the river basin districts.

Recommendations The preparation of the next RBMP should be carried out in accordance with the WFD timetable, to ensure the timely adoption of the third RBMP. Bulgaria should continue to improve international cooperation, including coordinated assessments of the technical aspects of the Water Framework Directive 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. Bulgaria needs to continue its work in order to harmonise the assessment of pressures among RBMPs and to make further progress on the assessment of agricultural pressures on water bodies. Bulgaria needs to eliminate inconsistencies between significant pressures and the measures planned to mitigate their effect. Bulgaria should continue to strengthen monitoring, in order to increase the confidence in the assessment of water body status. In particular, operational monitoring needs to include all lake water bodies which are subject to significant pressures. Monitoring should also cover all relevant quality elements. An increased level of monitoring should lead to a lower dependence on expert judgment for the classification of ecological status/potential. Bulgaria should have a clear and transparent method for the selection of River Basin Specific Pollutants. Bulgaria should strengthen its assessment method for biological, general physicochemical and hydromorphological quality elements by completing the development of assessment methods which are sensitive to all significant pressures and by progressing in the transfer of the results of intercalibration into national types. Bulgaria needs to reduce the number of unknowns. Monitoring should be performed in the relevant matrix, in a way that ensures sufficient spatial coverage and temporal resolution to reach sufficient confidence in the assessment, if necessary in combination with robust grouping/extrapolation methods. Develop the missing analytical methods. Perform trend monitoring in all RBDs, for all relevant substances, in a way that provide sufficient temporal resolution and spatial coverage. The definition of good ecological potential needs to be completed for all RBDs, specifically for the East Aegean RBD and the West Aegean RBD. Progress in the justification of exemptions should be continued. The specific drivers and impacts which may lead to the application of Article 4(4) and 4(5) exemptions should be assessed and clearly outlined in all RBMPs. The justification should be elaborated in more detail at water body level. In case there is clear evidence that natural background levels are the cause for elevated concentrations, the appropriate adaptation of the reference conditions should be considered instead of applying exemptions. Furthermore, the potential use of 'natural conditions' as an exemption type under Article 4(5) should be revised because exemption types Article 4(5) refers to are either that the achievement of good status would be 'infeasible' or 'disproportionately expensive', whereas 'natural conditions' as such is not considered as an exemption type under Article 4(5). With regard to the application of Article 4(7), the types of modifications and justifications should be clearly outlined and made more transparent in all RBDs, including an ex-ante assessment whether planned new modifications may lead to deterioration / non-achievement of good status/potential at quality element level. Quantification of indicators of gaps should be quantified for any pressures in any RBD.

A cost-effectiveness analysis should be carried out and specific prioritisation of measures based on cost-effectiveness analysis should be provided. Bulgaria should make sure that all relevant KTMs are reported to control Priority Substances in the East and West Aegean RBDs. Bulgaria should ensure that KTMs are in place to address the failure of objectives caused by substances in groundwater in the East Aegean RBD. Bulgaria 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. These measures should be specific, have a clear legal basis, and include appropriate advice, monitoring and inspection regimes to ensure their effective implementation. In the third RBMPs, it should be stated clearly to what extent, in terms of area covered and pollution risk mitigated, basic measures (minimum requirements to be complied with) or supplementary measures (designed to be implemented in addition to basic measures) will contribute to achieving the WFD objectives. Sources of funding should be identified (e.g. CAP Pillar 1, Rural Development Programme), as appropriate, to facilitate successful implementation of these measures. Bulgaria should continue to encourage coordination between water and agriculture departments in the review and development of the strategy for the delivery of WFD objectives, in cooperation with the farming community to ensure the third RBMP is technically feasible and aligned with all relevant policies and instruments (e.g. Rural Development Programme, CAP Pillar 1, ND etc.). The measures in the strategy should be specific, have a clear legal basis, and include appropriate advice, monitoring and inspection regimes to ensure their effective implementation. Irrigation investments made in the Rural Development Programmemust be carried out to ensure water saved goes back to restore depleted aquifers. KTM and specific measures have been identified to tackle the significant pressures from waste disposal sites, contaminated sites or abandoned industrial sites. No gap analysis is provided so it is not clear whether the measures planned will be sufficient to reach good status by the deadline, and to avoid further deterioration. Bulgaria should perform a gap analysis to assess whether the measures planned are sufficient to reach good status and avoid further deterioration, and if necessary to identify additional measures. KTM have been reported to tackle diffuse and point source pollution. However it is not clear that all relevant diffuse and point sources have been properly identified. Bulgaria should complete the inventories of emissions, by considering all Priority Substances and other substances from part A of annex I of the EQS Directive. It is strongly recommended to use the methodology from guidance document n°28 for all these substances, and point sources as well as diffuse sources should be considered where relevant. Bulgaria should make sure all individual substances causing failures are addressed by appropriate KTMs and measures, and a gap analysis should be provided to ensure that the measures planned will be sufficient to reach the objective. Bulgaria should make sure that the planned measures will ensure compliance with Article 5 of the Urban Waste Water Treatment Directive as regards more stringent treatment, especially in big cities. Bulgaria should make sure funding is secured for the planned actions, and make sure measures are sufficient to tackle the significant pressures from UWWTP, by performing a gap analysis, prioritising where necessary agglomerations above 2000 population equivalent. Bulgaria should ensure the full application of ecological flows, which are now planned in all RBMPs, and that these are applied at the appropriate level and implemented through the revision of permits as necessary. The revision and, if necessary, the amendment of all existing permits should be continued, in order to ensure that these permits are compatible with the achievement of the WFD objectives. Bulgaria should continue prioritising the use of green infrastructure and/or natural water retention measures that provide a range of environmental (improvements in water quality, flood protection, habitat conservation, etc.), social and economic benefits which can be in many cases more cost-effective than grey infrastructure. Bulgaria should continue to apply cost recovery for water use activities having a significant impact on water bodies or justify any exemptions using Article 9(4). It should continue to transparently present how financial, environmental and resource costs have been calculated and how the adequate contribution of the different users is ensured. Bulgaria should also continue to transparently present the water-pricing policy and provide a transparent overview of estimated investments and investment needs. Bulgaria should continue its work on groundwater Protected Areas designated under the Birds and Habitats Directives. These Protected Areas should be identified and reported. It also needs to set more stringent objectives for drinking water safeguard zones and include them in the PoMs as mentioned in previous recommendation. Bulgaria should ensure that a clear distinction is made between water scarcity and drought in water policy and that a Drought Management Plan or a Water resource allocation and management plan is adopted, particularly in light of the fact that abstraction is identified as one of the significant pressures for surface water and groundwater bodies in the country.



Topic 1Governance and public participation 1.1Assessment of implementation and compliance with WFD requirements in second cycle 1.1.1 Administrative arrangements – river basin districts Bulgaria has reported four river basin districts: Danube, Black Sea, East Aegean and West Aegean. All four RBDs are part of international RBDs.

1.1.2 Administrative arrangements – competent authorities Bulgaria reports a large number of competent authorities. Key among these are the four River Basin Directorates, whose main roles are: the monitoring and assessment of groundwater and surface water, co-ordination of implementation, economic analysis, enforcement of regulations, implementation of measures, preparation of the RBMPs and Programme of Measures, public participation, and reporting to the European Commission. The Ministry of Environment and Water has the following main roles: co-ordination of implementation, economic analysis, enforcement of regulations, implementation of measures, reporting to the European Commission, and monitoring of groundwater and surface water. The Ministry has a supporting role on public participation. Several other Ministries have main roles for the implementation of measures: Energy; Economy; Regional Development and Public Works; Transport, Information Technology and Communications; and Agriculture and Food. Moreover, all these ministries have supporting roles for the enforcement of regulations, while the Ministry of Health also has supporting roles for the monitoring and assessment of status of surface water. Several national agencies are also identified. The Executive Agency for Exploration and Maintenance of the Danube River undertakes monitoring of surface water , as does the Institute of Oceanography . The Executive Environment Agency undertakes monitoring of groundwater and surface water, and so does the National Institute of Meteorology and Hydrology. The National Statistical Office carries out economic analysis. The Association ViK is also involved in the implementation of measures; so are municipalities in the RBDs (265 authorities). 1.1.3 River Basin Management plans – structure and Strategic Environmental Assessment No sub-plans are reported for Bulgaria's RBMPs; Bulgaria informed that national programmes for the application of the RBMPs were developed by the economic sector. 1.1.4 Public consultation For all four RBMPs, the public and interested parties were informed via Internet, invitations, local authorities, media (papers, TV and/or radio), meetings and printed material. In addition, direct mailing was used in the Danube RBD, and written consultation in both the Danube and East Aegean RBDs. For all four RBDs, documents were made available by direct mailing (post) and were downloadable. Documents were available for the required six months. In the Danube, Black Sea and East Aegean RBDs, documents were also made available by direct mailing (e-mail). In the West Aegean RBD, documents were distributed at exhibitions. The following stakeholder groups were actively involved in all Bulgaria's RBMPs: agriculture/farmers, fisheries/aquaculture, industry, local/regional authorities, NGOs/nature protection and water supply and sanitation. Consumer groups were actively involved in the Danube and East Aegean RBDs. Energy/hydropower was actively involved in the Danube, East Aegean, and West Aegean RBDs. Navigation/ports were actively involved in the Danube and Black Sea RBDs. In the West Aegean RBD, universities and scientific institutes were involved. In all four RBDs, active involvement included regular exhibitions; in the Danube, Black Sea and East Aegean RBDs - involvement in drafting; in the East Aegean RBD, advisory groups; and in the West Aegean RBD, opinions and proposals. For all four RBMPs, consultation led to: addition of new information, changes to selection of measures, commitment to action in the next RBMP and commitment to further research. Adjustment to specific measures was a result for the Danube and East Aegean RBDs, and changes to the methodology used for the East Aegean RBD. For the Danube only, there was international co-ordination on public participation. Further information on international cooperation with respect to measures is provided in Chapter 9 of this report. 1.1.5 Integration with the Floods Directive and the Marine Strategy Framework Directive Bulgaria did not integrate its RBMPs and Flood Risk Management Plans (under the Floods Directive ) in joint plans but did undertake joint consultation of its RBMPs and Flood Risk Management Plans. For the Black Sea RBD, joint consultation with the Marine Strategy Framework Directive was organised. 1.1.6 International coordination and co-operation For the Danube RBD, Bulgaria reported that an international agreement, permanent co-operation body and an international RBMP in place (designated as category 1 cooperation): indeed, Bulgaria is a member of the International Commission for the Protection of Danube River. Explicit links were made with national RBMPs within the international RBMP. In this RBD, there was international co-ordination of public participation. For the East Aegean RBD, shared with Greece and Turkey and the West Aegean RBD, shared with Greece, Former Yugoslav Republic of Macedonia and Serbia), Bulgaria reports that an international agreement and permanent co-operation body was in place (designated as category 2). It is not clear, however, the extent to which co-operation covers all Member States and third countries. Bulgaria and Greece signed a Joint Declaration at ministerial level for cooperation on the implementation of European Union water legislation: an important element has been the coordination and exchange of information on methodologies. Bulgaria’s RBMPs for East Aegean and West Aegean also mention that cooperation with Greece took place through international projects funded primarily by Interreg programmes. No information was found on cooperation activities with the Former Yugoslav Republic of Macedonia and Serbia in these international RBDs. Bulgaria's Black Sea RBD is shared with Romania and Turkey. Bulgaria and Romania have signed a Bilateral Agreement on Water Management that covers coordination of shared RBDs, both Danube and the Black Sea. The two Member States have shared information on methodologies and on the development of their RBMPs. Information was not found on the extent of Bulgaria’s cooperation with Turkey. Both countries (as well as Romania) are among the parties to the Convention on the Protection of the Black Sea Against Pollution, but information was not found on cooperation under this framework related to the development of RBMPs. 1.2Main changes in implementation and compliance since first cycle

Bulgaria's Administrative Arrangements appear to be more complex compared to the first cycle: the 2012 Commission Staff Working Document listed the Ministry of Environment and Water and the four RBD Directorates, while the WISE reporting indicates several other national ministries, several national agencies and 265 local authorities. These bodies are mentioned in the Member State fact sheet on administrative arrangements for Bulgaria prepared under the Pressures & Measures study : consequently, it is not clear if this represents a change in governance or simply more detailed reporting in the second cycle. In the first cycle, Bulgaria prepared sub-plans for economic sectors; although no sub-plans were reported for the second cycle, Bulgaria informed that national programmes for the application of the RBMP were developed by the economic sector: consequently, no major change was seen. International co-operation appears to have strengthened for the East Aegean and the West Aegean RBDs as both are indicated in the WISE reporting as RBD with co-operation agreement and body in place (Category 2), implying that steps were taken to improve co-operation with neighbouring countries in these international RBMPs. For the East Aegean RBD, shared with Greece and Turkey, the 2012 Commission Staff Working Document listed one river basin as having an international agreement in place (Category 3). For the West Aegean RBD, the 2012 Commission Staff Working Document listed one RBD as having an international agreement in place (shared with Greece) and a RBD without co-operation formalised (Category 4) which is shared with Greece, Former Yugoslav Republic of Macedonia and Serbia. Information gathered indicates the co-operation with Greece was strengthened; it is not clear if this was also the case for Former Yugoslav Republic of Macedonia and Serbia. The level of co-operation for the Black Sea RBD was reported as "Null. 1.3Progress with Commission recommendations The Commission recommendations based on the first RBMPs and Programme of Measures requested action on the following: ·Recommendation: There are insufficient international cooperation/coordination mechanisms established with neighbouring countries like Greece and Turkey in international river basins. This cooperation needs to improve significantly. The river basins shared with Turkey should be correctly designated as international RBDs. ·Include in the second RBMPs results of the international cooperation with neighbouring countries. Assessment: It appears that international co-ordination has improved for the East Aegean RBD and the West Aegean RBD. In particular, it appears that cooperation with Greece improved, including via a joint declaration at ministerial level as well as the development of Interreg projects. It is not clear, however, if cooperation with non-member countries – Former Yugoslav Republic of Macedonia, Serbia and Turkey – has also improved for the second cycle. These recommendations are partially fulfilled. ·Recommendation: Ensure the necessary coordination of approaches and methodologies among its four RBDs in the second RBMPs. Co-ordination during the RBMP development between the basin and state level as well as among RBDs should be improved in the next RBMP cycle. Elaboration of common methodologies would be necessary. Assessment: A review of the different WFD topics suggests that considerable progress has been achieved since the first RBMPs in developing and applying common national methodologies that are used in all four RBDs. This was achieved in part via projects carried about by the Ministry of Environment and Water, and in part by work at international and at RBD levels (e.g. the methodology used for determining confidence levels of water bodies status assessments was original developed for the international Danube RBD, adopted by the Bulgarian Danube RBD and then adopted as a national methodology). The four RBMPs used the common methodologies (when available) and either include copies of these documents in their annexes or contain links to the online documents on the Ministry of Environment and Water’s website. It can also be noted that the four RBMPs follow the same structure, with the same number and titles of chapters and very similar content provided in these chapters. There are differences in the number and format of annexes provided to each chapter across the RBDs, but overall they contain similar annexes. Key annexes such as overview of status of water bodies or Programme of Measures follow the same templates. This recommendation is fulfilled. Topic 2Characterisation of the River Basin District 2.1Assessment of implementation and compliance with WFD requirements in second cycle 2.1.1Delineation of water bodies and designation of heavily modified and artificial water bodies Overall there is a significant change in the number of water bodies delineated between the first cycle and the second cycle ( Table 2.1 ). For river water bodies there was a 27 % increase overall, including a 63 % increase in the Danube RBD. For lake water bodies, there was a decrease of 35 % in the East Aegean RBD and 46 % in the Danube RBD, whilst there were increases of 33 % in the Black Sea RBD and 50 % in the West Aegean RBD. In the Black Sea RBD, there was an 87 % increase in transitional water bodies and a 31 % increase in coastal water bodies. In the second cycle, 95 % of identified surface water bodies were natural with 4 % being designated as heavily modified and 1 % as artificial water bodies. It was a fairly similar situation in the first cycle but there was a very slight increase in the proportion of natural water bodies between the first cycle and the second cycle ( Figure 2 .1). The water uses and physical alterations have been reported for each heavily modified water body category. The RBMPs reported that a national approach for designation of heavily modified water bodies was developed and first applied in the second RBMPs (for details see Topic 7). The RBMPs reported that the delineation of the surface water bodies was updated as a result of the updated typology, updated objectives and pressures information, new data gathered through monitoring and update of the protected areas, as well as to address some technical errors from the first RBMPs and recommendations received from the European Commission on the first RBMPs. The revised typology resulted in both merging and splitting of water bodies. Transitional waters (only relevant for the Black Sea RBD) were re-delineated as a result of a study on the typology and classification of surface water bodies carried out in the first cycle ("Update of the typology and classification system for assessment of surface water bodies of categories 'river', 'lake' and 'transitional waters' in the period of the first RBMP"). There is no information about re-delineation of the coastal waters. The consequences of the re-delineation of surface water bodies mentioned in the RBMPs were: firstly, that there was a need to apply the 'grouping' approach, especially for small water bodies, and update the programmes of monitoring; secondly, direct comparison of the status of water bodies between the first and second RBMPs is not possible due to the changes.

Table 2.1 Number and area/length of delineated surface water bodies in Bulgaria for the second and first cycles Year RBD Lakes Rivers Transitional Coastal Number of water bodies Total area (km2) of water bodies Number of water bodies Total length of water body (km) Number of water bodies Total area (km2) of water bodies Number of water bodies Total area (km2) of water bodies 2016 BG1000 7 14 249 27 084 0 0 0 0 2016 BG2000 4 3 156 2 957 28 816 17 1 464 2016 BG3000 11 38 300 10 543 0 0 0 0 2016 BG4000 15 61 168 2 837 0 0 0 0 2016 Total 37 116 873 43 421 28 816 17 1 464 2010 BG1000 13 21 153 6 690 0 0 0 0 2010 BG2000 3 4 124 6 009 15 109 13 1 428 2010 BG3000 17 42 291 10 551 0 0 0 0 2010 BG4000 10 9 122 2 319 0 0 0 0 2010 Total 43 75 688 25 568 15 109 13 1 428 Source: WISE electronic reports Figure 2.1 Proportion of surface water bodies in Bulgaria designated as artificial, heavily modified and natural for the second and first cycles. Note that the numbers in parenthesis are the numbers of water bodies in each water category Source: WISE electronic reports. Table 2 .2 shows the differences in size distribution of surface water bodies in Bulgaria between the first and second and cycles. The minimum length of river water bodies has decreased in the Danube RBD and the minimum size of coastal water bodies decreased in the Black Sea RBD. The minimum size criteria reported were a 10 km2 catchment area for rivers and a 0.5 km2 surface area for lakes. Table 2.2 Size distribution of surface water bodies in Bulgaria in the second and first cycles Year RBD Lake area (km2) River length (km) Transitional (km2) Coastal (km2) Mini-mum Maxi-mum Average Mini-mum Maxi-mum Average Mini-mum Maximum Average Mini-mum Maxi-mum Average 2016 BG1000 0.79 6.27 1.93 0.17 27.18 3.56 2016 BG2000 0.26 1.87 0.87 0.5 17.54 4.27 0.04 32.93 7.14 14.82 401.91 86.13 2016 BG3000 0.13 20.97 3.46 0.02 26.35 3.9 2016 BG4000 0.4 19.64 4.04 2010 BG1000 0.5 4.43 1.62 0.55 30 4.16 2010 BG2000 0.58 2.25 1.22 0.5 18.7 4.77 0.04 32.6 7.26 7.01 453.55 109.85 2010 BG3000 0.03 20.97 2.44 0.02 26.35 3.36 2010 BG4000 0.09 2 0.85 0.8 22 5.83 Source: WISE electronic reports. For groundwater bodies there was a slight decrease overall of 5 % in the number of water bodies between the first cycle and the second cycle ( Table 2.3 ). The RBMPs explained that the delineation of the groundwater bodies was updated to address some technical errors and reduce fragmentation, to address recommendations from the Commission from the first RBMPs and to use updated data from geological research. The re-delineation was based on geological information, maps and new/targeted research used for the water abstraction permits. The RBMPs do not mention the consequences of these changes to groundwater bodies. Transboundary river water bodies have been designated for three RBDs: Danube, East Aegean and West Aegean. The same three RBDs also identified transboundary groundwater bodies. Table 2.3 Number and area of delineated groundwater bodies in Bulgaria for the second and first cycles Year RBD Number Area (km2) Minimum Maximum Average 2016 BG1000 50 27.71 13,158.04 1,480.44 2016 BG2000 40 3.21 3,474.01 737.29 2016 BG3000 41 20.19 6,596.79 963.68 2016 BG4000 38 7.24 3,080.28 409.93 2016 Total 169 2010 BG1000 50 19 13,034.00 1,471.28 2010 BG2000 40 3 3,466.00 729.9 2010 BG3000 48 20.18 5,094.83 816.25 2010 BG4000 39 8.01 2,409.11 379.91 2010 Total 177 Source: WISE electronic reports. Table 2.4 summarises the information provided by Bulgaria on how water bodies have evolved between the two cycles. The water bodies with the most significant changes were river and lake water bodies with some deletions and in addition there was a significant amount of splitting of river water bodies (n = 348).

Table 2.4 Type of change in delineation of groundwater and surface water bodies in Bulgaria between the second and first cycles Type of water body change for second cycle Groundwater Rivers Lake Transitional Coastal Aggregation 19 Splitting 348 12 3 Aggregation and splitting 46 5 11 Change 4 1 3 Extended area 9 1 Creation 7 2 Deletion 26 20 Change in code 5 14 No change 435 14 16 Total water bodies before deletion 899 57 28 17 Delineated for second cycle (after deletion from first cycle) 873 37 28 17 Source: WISE electronic reports. Access to Groundwater data was restricted. 2.1.2Delineation of small water bodies Small water bodies are not explicitly discussed in the RBMPs. However, the national methodological document 'Method for determining/updating the borders of surface water bodies during the update of RBMP' contains some information about small water bodies. According to this methodology small water bodies can either be designated as water bodies based on some significance criteria (e.g. category, type, status, pressures), or managed as part of the larger water bodies. The methodology states that small water bodies can be designated as separate water bodies in the following cases: ·the water body is a drinking water safeguard zone (protected area) or another type of protected area under national legislation (the Water Law); ·its designation as a water body is the most effective way for achieving the environmental objectives. 2.1.3Typology of surface water bodies The number of surface water body types appears to have decreased overall by about 20 % between the first cycle and the second cycle. The national methodology for typology of surface water bodies has been developed since the first RBMP based on the projects 'Determining the reference conditions and maximum ecological potential for certain types of surface water bodies (rivers and lakes) on the territory of Bulgaria' and 'Development of a classification system and assessment of ecological status and ecological potential for certain types of surface water bodies (rivers and lakes) on the territory of Bulgaria (based on the typology system B)' in 2009-2012. The projects resulted in the designation of common national types for surface water bodies - 16 types for rivers and 17 types for lakes. These types and other findings from the projects were integrated in the national legislation with the 'Ordnance N4 on the characterisation of surface water bodies' from 14 September 2012 and applied in the second RBMPs. Member States were asked to report ‘Not applicable’ if there is no corresponding intercalibration type for national types. Many national types (heavily modified, artificial and natural) have been intercalibrated. Several of the national types for Bulgaria in all of the RBDs do not appear to have corresponding intercalibration types for all river water body types and 10 lake types . In the Black Sea RBD there are also no equivalent intercalibration types for five transitional water bodies and six coastal water body types . The coordination of typology is not discussed at length in the RBMPs. The chapters on transboundary cooperation focus on presenting the framework for cooperation with each neighbouring country, listing the meetings that took place and providing summaries of the main issues discussed at each meeting. The methodology for designating the types and the typology of water bodies was discussed at bilateral meetings with Romania (Danube, Black Sea RBDs), Greece (East Aegean, West Aegean RBDs) and Turkey (Black Sea, East Aegean RBDs) . Table 2.5 Number of surface water body types at RBD level in Bulgaria for the first and second cycles RBD Rivers Lakes Transitional Coastal 2010 2016 2010 2016 2010 2016 2010 2016 BG1000 22 13 6 3 0 0 0 0 BG2000 9 8 3 4 5 5 6 9 BG3000 10 10 5 4 0 0 0 0 BG4000 17 6 4 5 0 0 0 0 TOTAL 55 20 (15) 18 10 (6) 5 5 6 9 Source: WISE electronic reports. Note that the total is not the sum of the types in each RBD as some types are shared by RBDs. Values in brackets were subsequently reported by Bulgaria but do not match the data reported to WISE. 2.1.4Establishment of reference conditions for surface water bodies Table 2.6 shows the percentage of surface water body types in Bulgaria with reference conditions established for the first and second cycles . Type specific reference conditions have been established for all relevant biological quality elements for 44 % of lakes , 64 % of rivers and 20 % of transitional waters but only for some biological elements in coastal waters. Type specific reference conditions have not been established for hydromorphological quality elements in transitional or coastal waters. Physicochemical quality elements have been established for 78 % of elements in lakes, 56 % in rivers and 40 % transitional but none in coastal waters. Reference conditions have been coordinated with some but not all Member States for biological quality elements, physico-chemical quality elements and hydromorphological quality elements. Reference conditions were only mentioned in the East Aegean and West Aegean RBMPs in relation to issues discussed at bilateral meetings with Greece. However, it is not specified which elements these reference conditions refer to. The other RBMPs do not mention if reference conditions were discussed at transboundary coordination meetings. Table 2.6 Percentage of surface water body types in Bulgaria with reference conditions established for all, some and none of the biological, hydromorphological and physicochemical quality elements Waterbody category Waterbody types Biological quality elements Hydromorphological quality elements Physicochemical quality elements Rivers All 64% 48% 56% Some 12% 16% None 24% 52% 28% Lakes All 44% 78% 78% Some 44% None 17% 22% 22% Transitional All 20% 40% Some 60% None 20% 100% 60% Coastal All Some 100% None 100% 100% Source: WISE electronic reports

2.1.5Characteristics of groundwater bodies The geological formation of the aquifer types where there are groundwater bodies, along with details of whether groundwater bodies are layered or not, are reported. Further characterisation work has been reported since the first cycle with the inclusion of the assessment of linkages to surface water bodies and terrestrial ecosystems. The methodology used in the first RBMPs was refined and a common national methodology entitled 'Methodology for characterisation of groundwater bodies' was developed and applied in the second RBMPs. 2.1.6Significant pressures on water bodies In the second cycle, “no significant pressure” was reported most often (39 % of water bodies) and the most significant pressures on surface waters were reported to be anthropogenic pressure – unknown (23 %), point - urban waste water (22 %) and diffuse – agricultural (19 %) ( Figure 2.2 . In the first cycle, Bulgaria only reported pressures at an aggregated level making it difficult to compare reporting of the first and second cycle pressures. There has been an apparent increase in the reporting of hydromorphological pressures ( Figure 2.3 ) and unknown anthropogenic pressures (or other pressures). Diffuse pressures appear to have decreased in the East Aegean and West Aegean RBDs. For groundwater bodies, diffuse – agricultural (50 %) and diffuse - discharges not connected to sewerage network (49 %) were reported to be the most significant pressures ( Figure 2.2 ). “No significant pressure” however, was also reported for 41 % of water bodies. For the second cycle, it was reported which significant pressures were not assessed for surface waters, which were different in each RBD. For surface water bodies the pressures and activities covered are: ·point sources: urban wastewater, industrial wastewater; animal farms and aquaculture (only in the East Aegean RBD); ·diffuse sources: urban areas without sewage systems, waste landfills, agriculture, aquaculture, erosion, land use, atmospheric and transport pollution; mining activities (only in the Danube and West Aegean RBDs); tourism, past activities (only in the West Aegean RBD); ·physical/ hydromorphological alterations: water abstraction, morphological alterations, water flow regulation; ·pressures from invasive species; ·pressures from climate change; ·pressures from fisheries, dredging and ports (only the Black Sea RBD); ·pressures from navigation (only Danubian and Black Sea RBDs). Overall, the same types of pressures and related activities are covered in each RBMP, for groundwater bodies the pressures and activities covered are: ·point sources: urban WWTPs, industrial installations; farms and storage facilities for pesticides and fertilisers, waste landfills, mines and quarries, past activities; ·diffuse sources: agriculture, landfills, mines, past activities, urban areas without sewage systems; ·pressures from water abstraction; ·pressures from climate change. There were 14 pressures in the Danube RBD not assessed, 13 in the Black Sea RBD, five in the East Aegean RBD and 12 in the West Aegean RBD. The RBMPs do not provide any information as to why some pressures have been excluded from the risk assessment. The RBDs did not report any significant pressures that were not assessed for groundwater. Figure2.2 The most significant pressures on surface water bodies and groundwater bodies in Bulgaria for the second cycle

Source: WISE electronic reports. Figure 2.3 Comparison of pressures on surface water bodies in Bulgaria in the first and second cycles. Pressures presented at the aggregated level. Note there were 955 identified surface water bodies for the second cycle and 759 for the first cycle Source: WISE electronic reports. 2.1.7Definition and assessment of significant pressures on surface and groundwater For surface waters the tools used to define significant pressures varied depending on the pressure. A combination of both expert judgement and numerical tools were used for defining diffuse and point pressures in all RBDs . For surface water bodies the significance of pressures is reported to be defined in terms of thresholds and linked to the potential failure of objectives for all RBDs except the Black Sea RBD. For groundwaters a combination of expert judgement and numerical tools were used for defining diffuse and point source pressures and abstractions in the Danube RBD. Numerical tools were used in the Black Sea and West Aegean RBDs. For the East Aegean RBD a combination of both were used for defining diffuse and point pressures and numerical tools only for abstractions pressures . For groundwater, the significance of pressures is reported to be defined in terms of thresholds and linked to the potential failure of objectives for all RBDs . The use of common national methodologies for analysing the pressures from point and diffuse pollution sources, water abstraction and climate change was reported. The approach used for defining pressures on surface water bodies in the first RBMPs was refined to determine the 'driving force-pressure-status-impact' relationships, expand the analysis of pressures (e.g. by considering more sources of pressures) and to implement results from models, projects and research (e.g. MONERIS, WATER, PegOpera). These changes are only explicitly summarised in the Danube RBMP. The RBMPs do not explicitly discuss the tools or methodologies for assessment of each type of pressure; they only briefly present the general approach and then the results for each type of pressure for each type of water body. However, the RBMPs contain tables with the potential impacts of different types of pressure and the indicators for their reporting.. The main text of all RBMPs list the data sources of the information used to analyse the pressures. The website of the Ministry of Environment and Water (MOEW) suggests the following national methodologies exist: ·'Pressures and impact on the quantitative status of groundwater bodies and Methodology for assessment of the risk that groundwater bodies do not reach good quantitative status'; ·'Methodology for assessment of the pressure and impact on surface water bodies and groundwater bodies of climate change and assessment of the availability of water for economic sectors'; ·'Methodology for analysis of the pressure and impact of anthropogenic activities related to water abstraction from surface waters'. The Danube and East Aegean RBMPs provide brief overviews of the remaining gaps in relation to pressure analysis that could be the reasons for the different approaches reported for different RBDs. Examples of gaps mentioned in these two RBMPs are: ·no common methods or methodologies for some pressure assessments i.e. diffuse sources, and quantitative source apportionment ·insufficient monitoring data or data of insufficient quality (credibility, coverage, format) for some pressures assessments; ·no models to assess the impacts of different pressures, including their cumulative impacts. 2.1.8Significant impacts on water bodies

In the second cycle, the most significant impact on surface water bodies was nutrient pollution (40 %) and organic pollution (25 %), with 36 % classified as having “no significant impact”. For groundwaters over 50 % were classified as “no significant impact”. The most significant impacts were classified as nutrient pollution (27 %) and chemical pollution (11 %). Bulgaria did not report on impacts in the first cycle. Figure 2.4 Significant impacts on surface water and groundwater bodies in Bulgaria for the second cycle. Percentages of numbers of water bodies Source: WISE electronic reports 2.1.9Quantification of the gap and apportionment of pressures There are some inconsistencies in significant pressures reported at the water body level and the pressures for which measures are planned. For example, in the Danube RBD, diffuse - contaminated sites or abandoned industrial sites has been reported at the groundwater body level but this pressure has not been reported as being tackled in the Programme of Measures. Similarly, in the Black Sea RBD, abstraction or flow diversion - public water supply is reported at a surface water body level but not in the Programme of Measures . Priority Substances and other substances causing the failure of good chemical status have been reported. The measures to tackle these substances to achieve good status by 2027 or the indicator gap have not been reported and were listed in Annex 0 by Bulgaria. 2.1.10Groundwater bodies at risk of not meeting good status In each RBD groundwater bodies were reported to be at risk of failing to meet good chemical status, ranging from 24 to 72 % of water bodies. The pollutants putting groundwater bodies at risk of failing good chemical status have been reported. In each RBD groundwater bodies were reported to be at risk of failing to meet good quantitative status, ranging from 15 to 26 % of water bodies. 2.1.11Inventories of emissions, discharges and losses of chemical substances Article 5 of the Environmental Quality Standards Directive 2008/105/EC (EQS Directive) requires Member States to establish an inventory of emissions, discharges and losses of all Priority Substances and the eight other pollutants listed in Part A of Annex I of the EQS Directive for each RBD, or part thereof, lying within their territory. This inventory should allow Member States to further target measures to tackle pollution from priority substances. It should also inform the review of the monitoring networks, and allow the assessment of progress made in reducing (respectively suppressing) emissions, discharges and losses for priority substances (respectively priority hazardous substances). Bulgaria reported an inventory of emissions for each of the RBDs, however these inventories included only between four and six of the 41 Priority Substances. These inventories were based on Common Implementation Strategy Technical Guidance Document No. 28 and on additional guidance documents developed at national level such as 'Methodological guidance for determining the mass weight of pollutants in waste waters from point sources when compiling the first inventory of emissions, discharges and losses of Priority Substances and some other pollutants' and 'Instructions for implementing the first inventory of emissions, discharges and losses of Priority Substances and some other pollutants'. The two step approach from the Common Implementation Strategy Guidance Document no 28 has been followed for the substances considered in the inventories. For these substances a combination of Tier 1 (point source information) and Tier 2 (riverine load) was implemented (the Guidance Document recommends using at least Tier 1+2 for the substances relevant at RBD level). The data quality was assessed as uncertain. The RBMP specifies that between 2017 and 2018 an action plan for improving the implementation of inventory of Priority Substances will be carried out where the main aim will be to refine the tools and methods for the inventory. 2.2Main changes in implementation and compliance since first cycle Overall there was a significant change in the number of water bodies delineated between the first cycle and the second cycle. For example, for river water bodies there was a 27 % increase overall with the increase as high as 63 % in the Danube RBD and for the Black Sea RBD there was an 87 % increase in transitional water bodies and a 31 % increase in coastal water bodies. For groundwater bodies there was a slight decrease overall of 5 %. The number of surface water body types appears to have decreased overall by about 20 % between the first cycle and the second cycle. There has been an apparent increase in the reporting of hydromorphological pressures and unknown anthropogenic pressures (or other pressures) for surface waters between the first cycle and the second cycle. Diffuse pressures appear to have decreased in the East Aegean and West Aegean RBDs. This is likely a result of changes in methodologies as discussed in the previous section.

2.3Progress with Commission recommendations The Commission recommendations based on the first RBMPs and Programme of Measures requested action on the following: ·Recommendation: The existing pressures are not being sufficiently detected, particularly where complex pressure factors exist, e.g. combined pollution from diffuse and point sources, or combined pressures from pollution and hydromorphological alterations. Pressures should be sufficiently detected. Assessment: For the second cycle, it was reported which significant pressures were not assessed for surface waters. The pressures listed were different in each RBD. There were 14 pressures not assessed in the Danube, 13 in the Black Sea, 5 in the East Aegean RBD and 12 the West Aegean RBD. However, pressures from aquaculture were addressed in all RBDs as were diffuse atmospheric deposition, with the exception of the Black Sea RBD. No explanation for why certain pressures were not assessed was found in the RBMPs. The approach used for defining pressures on surface water bodies in the first RBMPs was refined to determine the 'driving force-pressure-status-impact' relationships, expand the analysis of pressures (for example by considering more sources of pressures) and to implement results from models, projects and research. Therefore, this recommendation has partially been fulfilled. ·Recommendation: Set out in the second RBMPs a clear assessment of the pressure agriculture is exerting on the status of water bodies. Assessment: In terms of characterisation, diffuse – agricultural has been identified as a significant pressure in each RBD and accounts for 8 % of the pressures overall. The review of the RBMPs revealed that there are no common methods or methodologies for some pressure assessments i.e. diffuse sources and their source apportionment. Further progress is therefore required to meet this recommendation. ·Recommendation: Where there are currently high uncertainties in the characterisation of the RBDs, identification of pressures, and in the assessment of status, these need to be addressed in the current cycle, to ensure that adequate measures can be put in place before the next cycle. Assessment: In terms of characterisation, the following conclusions on the progress to this recommendation are made below: The minimum size criterion for delineating river water bodies was reported to be a 10 km2 catchment size for each RBD which is the same as the European Union average. When comparing the minimum reported catchment areas of rivers between the first cycle and the second cycle, it was observed that for the Danube RBD there was a decrease in minimum size from 0.55km2 to 0.17km2, there was no change for the Black Sea and East Aegean RBDs, and the West Aegean RBD did not report the minimum size in the second cycle. The two main criteria for designating small water bodies according to the national methodology was if the water body is a drinking water safeguard zone (protected area) or another type of protected area under national legislation (the Water Law) or if its designation as a water body is the most effective way for achieving the environmental objectives. There are gaps in the development of type specific reference conditions, for example, type specific reference conditions have only been established for all relevant biological quality elements for 33 % of lakes, 57 % of rivers and 20 % of transitional waters but only for some biological elements in coastal waters. Overall, this recommendation has been partially fulfilled. ·Recommendation: Review the pressures and impacts analysis and status assessment in a consistent manner across all RBDs in the second RBMP and ensure that the measures are based on the updated pressures and impacts analysis and status assessment of water bodies. Assessment: There have been significant changes in the delineation of water bodies between the first and second cycle. For example, for river water bodies there was a 27 % increase overall with the increase as high as 63 % in the Danube RBD. The tools used to define significant pressures varied depending on the pressure and the approaches also sometimes differed between RBDs. For groundwater either a combination of expert judgement and numerical tools or just numerical tools were used for all pressure types. Expert judgement was used for defining water flow pressures in all RBDs except the Black Sea, and expert judgement was also used for abstraction pressures in the Danube RBD. The significance of pressures from navigation appears to have been addressed only in the Black Sea RBD and Danube RBD. There appears to be some progress made in implementing this recommendation but there is still some inconsistency between RBDs. Therefore this recommendation has been partially fulfilled. Topic 3 Monitoring, assessment and classification of ecological status in surface water bodies 3.1.Assessment of implementation and compliance with WFD requirements in second RBMPs 3.1.1Monitoring of ecological status/potential Monitoring programmes Article 8.1 of the WFD requires Member States to establish monitoring programmes for the assessment of the status of surface water and of groundwater in order to provide a coherent and comprehensive overview of water status within each RBD. Bulgaria reported 54 different monitoring programmes for the second cycle covering groundwater, coastal waters, transitional waters, lakes and rivers. Generally the programmes are specific for each RBD, for each water category in the RBD and for surveillance and operational purposes. Bathing water and Nitrates Directive programmes are reported for surface waters. Monitoring sites

Table 3.1 compares the number of monitoring sites used for surveillance and operational purposes between the cycles, and Table 3.2 gives the number of sites used for different purposes for the second cycle. Table 3.1 Number of sites used for surveillance and operational monitoring in Bulgaria for the second and first RBMPs. Note that for reasons of comparability with data reported in the first cycle, the second cycle data does not take into account whether sites are used for ecological and/or chemical monitoring Rivers Lakes Transitional Coastal Surv. Op Surv. Op Surv. Op Surv. Op second RBMP BG_1000 131 (288) 0 (58) 1 (6) 0 BG_2000 307 (307) 20 (23) 2 (2) 0 28 (28) 15 (18) 14 (14) 6 (6) BG_3000 34 (34) 147 (149) 1 (1) 0 (1) BG_4000 20 (32) 118 (257) 1 (5) 14 (15) Total by type of site 492 (661) 285 (487) 5 (14) 14 (16) 28 (28) 15 (18) 14 (14) 6 (6) Total number of monitoring sites used for surveillance and/or operational monitoring 756 (1107) 19 (30) 35 (35) 20 (20) first RBMP BG_1000 97 59 40 0 BG_2000 10 18 9 14 7 3 BG_3000 12 74 8 4 BG_4000 27 67 5 4 Total by type of site 146 218 62 22 0 0 7 3 Total number of monitoring sites used for surveillance and/or operational monitoring 364 84 0 10 Sources: Member States electronic reports to WISE. The Bulgaria Authorities subsequently stated that there had been some errors in reporting the purpose of monitoring information at site level. The values in brackets in the Table above for the second RBMP are the values from the reported information at the monitoring programme level and their associated monitoring sites. Table 3.2 Number of monitoring sites in relevant water categories used for different purposes in Bulgaria Monitoring Purpose Lakes Rivers Transitional Coastal BWD - Recreational or bathing water - WFD Annex IV.1.iii 4 90 CHE - Chemical status 7 302 26 17 DWD - Drinking water - WFD Annex IV.1.i 8 319 ECO - Ecological status 35 1562 35 20 HAB - Protection of habitats or species depending on water - WFD Annex IV.1.v 1 112 17 10 NID - Nutrient sensitive area under the Nitrates Directive - WFD Annex IV.1.iv 10 266 5 6 OPE - Operational monitoring 14 285 15 6 REF - Reference network monitoring site 7 58 6 4 RIV - International network of a river convention (including bilateral agreements) 12 SHE - Shellfish designated waters - WFD Annex IV.1.ii 7 SOE - EIONET State of Environment monitoring 6 171 8 SUR - Surveillance monitoring 5 492 28 14 UWW - Nutrient sensitive area under the Urban Waste Water Treatment Directive - WFD Annex IV.1.iv 2 326 35 20 Total sites irrespective of purpose 40 1790 35 110 Source: WISE electronic reports. Bulgaria subsequently stated that there has been a technical error in reporting and the number of sites reported for operational and surveillance monitoring may not be correct. There were no monitoring sites in transitional waters for the first RBMPs, but there were sites for surveillance and operational purposes reported in the second RBMPs. There were operational sites in lakes in three RBDs reported for the first RBMPs but only in two for the second. Because of reporting errors in WISE for the second RBMPs it is not possible to make quantitative comparisons of the numbers of monitoring sites between the two RBMPs. However, it can be concluded that there have been increases in the number of surveillance and operational sites in rivers, transitional and coastal waters, and decreases in the numbers of surveillance and operational sites in lakes from the first to the second RBMPs. Monitored quality elements (excluding River Basin Specific Pollutants) Table 3.3 illustrates the quality elements used for the monitoring of surface waters for the second RBMP: no differentiation is made between purposes of monitoring. Table 3.3 Quality elements monitored for the second RBMP in Bulgaria (excluding River Basin Specific Pollutants). Note: quality element may be used for surveillance and/or operational monitoring Biological quality elements Phytoplankton Macrophytes Phytobenthos Benthic invertebrates Fish Angiosperms Macroalgae Other aquatic flora Other species Lakes Yes Yes Yes Yes No Rivers Yes Yes Yes Yes Yes No Transitional Yes Yes Yes Yes Yes No No No Coastal Yes No No Yes Yes Yes No



Hydromorphological quality elements Hydrological or tidal regime Continuity conditions Morphological conditions Lakes No No Rivers Yes Yes Yes Transitional No No Coastal Yes Yes General physicochemical quality elements Transparency conditions Thermal conditions Oxygenation conditions Salinity conditions Acidification status Nitrogen conditions Phosphorus Conditions Silicate Other determinand for nutrient conditions Lakes Yes Yes Yes Yes Yes Yes Yes No No Rivers Yes Yes Yes Yes Yes Yes Yes No No Transitional Yes Yes Yes Yes Yes Yes Yes No No Coastal Yes Yes Yes Yes No Yes Yes No No Source: WISE electronic reports There was no monitoring of transitional waters reported for the first RBMPs. All expected biological quality elements were reported to be monitored in coastal waters and rivers for the first RBMPs and in lakes all biological quality elements except phytobenthos were monitored. All expected hydromorphological and physicochemical quality elements were reported to be monitored in coastal waters, rivers and lakes for the first RBMP.

There are some significant gaps in the quality elements monitored in Bulgaria for the second RBMPs. The monitoring of macroalgae and angiosperms is missing in transitional waters, though macrophytes and phytobenthos are used, which are generally required for freshwaters . Macrophytes and benthic invertebrates are not monitored in lakes in one RBD, and fish are not monitored in lakes in two RBDs . The monitoring of phytobenthos in lakes is missing . Hydromorphological quality elements are not monitored in lakes and transitional waters, and only monitored in coastal waters and, in one of the four RBDs, in rivers . Annex V of the WFD provides guidance on the frequency of monitoring of the different quality elements. Surveillance monitoring should be carried out for each monitoring site for a period of one year during the period covered by a RBMP i.e. six years. For phytoplankton, this should be done twice during the monitoring year and for the other biological quality elements once during the year. As a guideline, operational monitoring should take place at intervals not exceeding once every six months for phytoplankton and once every three years during the six year cycle for the other biological quality elements. Greater intervals may be justified on the basis of technical knowledge and expert judgement. For the surveillance monitoring of phytoplankton, all sites in coastal waters were monitored at least at the minimum frequency; this was not the case in the other three water categories . All sites used for the surveillance monitoring of the other biological quality elements in all water categories were monitored at least at the minimum frequency. In terms of operational monitoring, phytoplankton was monitored at least at the minimum frequency in all sites where they were monitored in coastal waters, lakes and rivers; none of the sites were in transitional waters. Six of the 12 biological quality elements used for the operational monitoring of surface waters were monitored at all sites where they were monitored at least at the minimum sampling frequency. Two biological quality elements, fish and macrophytes, were not sampled at the minimum sampling frequency in any of the sites at which they were monitored in transitional waters. Monitoring of River Basin Specific Pollutants River Basin Specific Pollutants are reported to be monitored (at the generic level) in all of the water categories relevant to each RBD, except for lakes in the Black Sea RBD. 63 different River Basin Specific Pollutants (reported at the chemical substance level) are monitored in Bulgaria: one in coastal waters, 22 in lakes, 62 in rivers, none in transitional waters (even though they were reported at a generic level). All are only monitored in water. The highest number of sites were for the monitoring of iron (464 sites), followed by manganese (463 sites) and copper (315 sites). Annex V of the WFD provides guidance on the frequency of monitoring of the different quality elements: once every three months is recommended for “other pollutants” which are taken here to equate to river basin specific pollutants. Surveillance monitoring should be carried out for each monitoring site for a period of one year during the period covered by a river basin management plan i.e. six years. For river basin specific pollutants this should be done four times in the surveillance year, and for operational monitoring four times a year for each year of the cycle. Of the 47 River Basin Specific Pollutants included in surveillance monitoring of surface waters in Bulgaria, seven were monitored at least at the minimum frequency at all of the sites where they were monitored, and 24 pollutants at none of the sites . Of the 36 River Basin Specific Pollutants included in operational monitoring of surface waters in Bulgaria, 23 were monitored at least at the minimum frequency at all of the sites where they were monitored, and four pollutants at none of the sites. Table 3.4 shows the number of sites used to monitor River Basin Specific Pollutants in Bulgaria in the first and second RBMPs. Table 3.4 Number of sites used to monitor River Basin Specific Pollutants reported in the second RBMP and non-priority specific pollutants and/or other national pollutants reported in the first RBMP in Bulgaria. Note the data from both cycles may not be fully comparable as different definitions were used and also not all Member State reported information at the site level meaning that there were no equivalent data for the first cycle RBMP Lakes Rivers Transitional Coastal first Sites used to monitor non-priority specific pollutants and/or other national pollutants 66 283 0 10 second Sites used to monitor River Basin Specific Pollutants 11 599 25 20 Sources: WISE electronic reports Surveillance monitoring of surface water bodies All nine coastal water bodies included in surveillance monitoring were monitored for all required biological, hydromorphological and physicochemical quality elements. None of the lake and transitional water bodies included in surveillance monitoring was monitored for all required biological quality elements, whereas a proportion of river water bodies in surveillance monitoring in three of the four RBDs were monitored for all required biological quality elements: the minimum was 11 % in the West Aegean RBD and maximum 61 % in the Black Sea RBD. Lakes and transitional water bodies were not monitored for any hydromorphological quality elements. Only two river water bodies included in surveillance monitoring were monitored for hydromorphological quality elements but neither was monitored for all the required ones. Lakes in three of the four RBDs were monitored for all required physicochemical quality elements in surveillance monitoring; in the other RBD none were. Nearly all river water bodies in surveillance monitoring in three of the four RBDs were monitored for all required physicochemical quality elements; in the other RBD, 70 % were. 63 % of transitional water bodies in surveillance monitoring were monitored for all required physicochemical quality elements. At the national level around a quarter of water bodies in each category were included in operational monitoring. There were greater differences in the proportion of water bodies included in the surveillance monitoring of each category than for operational monitoring: 86 % of transitional water bodies, 53 % of coastal water bodies, 30 % of river water bodies and 14 % of lake water bodies were included in surveillance monitoring. It should be noted that there were significant increases in the number of delineated coastal, river and transitional water bodies for the two cycles. For example, 688 river water bodies were delineated for the first RBMP compared to 873 for the second. For lakes there was a decrease from 43 for the first to 37 for the second RBMP. Figure 3.1 shows the proportion of water bodies subject to surveillance and operational monitoring.

Figure 3.1 Percentage of water bodies included in surveillance and operational monitoring in Bulgaria for the first cycle (2010) and second cycle (2016). Note no differentiation is made between water bodies included in ecological and/or chemical monitoring Source: WISE electronic reports Similar proportions of coastal water bodies were included in operational and surveillance monitoring for both cycles. A significant difference was that transitional water bodies were not operationally monitored for the first RBMPs but 29 % were for the second RBMPs. The comparison between the two cycles should be treated with caution as there are uncertainties in the data reported for Bulgaria in the first RBMPs. In particular some river and lake water body codes were reported as part of the WISE reporting on monitoring sites but were not included in the reporting of surface water bodies itself. Figure 3.2 shows the proportion of water bodies subject to surveillance monitoring. Figure 3.2 Proportion of water bodies in each ecological status/potential class that are included in surveillance monitoring in Bulgaria Source: WISE electronic reports Operational monitoring of surface water bodies Lakes are only operationally monitored in the West Aegean RBD even though significant pressures were reported for lakes in the other RBDs. The nine lakes included in operational monitoring are all monitored for phytoplankton and benthic invertebrates, and four of them for macrophytes. Rivers in the Danube RBD are not included in operational monitoring, while those in the other three RBDs are. The most used biological quality element for rivers is benthic invertebrates (85 % of river water bodies in operational monitoring), followed by phytobenthos (33 %), macrophytes (16 %) and fish (9 %). All four coastal water bodies in operational monitoring are monitored for all of the relevant biological quality elements. Transitional water bodies in operational monitoring are monitored for four biological quality elements, though macrophytes are reported to be monitored rather than the expected angiosperms and macroalgae . In the three RBDs (the Danube RBD, the Black Sea RBD and the East Aegean RBD) where lakes are not operationally monitored and one RBD (the Danube RBD) where rivers are not operationally monitored, there is a number of water bodies reported to be at less than good ecological status/potential: it would be expected that at least some of these would be operationally monitored. Furthermore, 19 significant pressures types were reported on river water bodies in the Danube RBD and a number of significant pressures on lakes in the Danube, Black Sea and East Aegean RBDs. Transboundary surface water body monitoring Bulgaria reported transboundary river and groundwater bodies in three of the four RBDs. 12 river monitoring sites in the Danube RBD were reported to be part of an international network of a river convention. Ecological Status/potential of surface water The most recently assessed ecological status/potential of surface water bodies in Bulgaria for the second RBMP is illustrated in Map 3.1 . The proportion of surface water at good or better status/potential increased from 43 % in the first RBMPs to 46 % in the second. In terms of less than good status/potential, the proportions were 57 % for the first RBMPs and 45 % for the second. However, there was a large increase of unknown status surface water bodies from 0.1 % in the first RBMPs to 9 % in the second: this may confound any comparison between the first and second cycles in terms of classified water bodies. Figure 3.3 compares the ecological status of surface water bodies in Bulgaria in the first RBMPs with that in the second RBMPs and that expected by 2015.

Map 3.1 Ecological status or potential of surface water bodies in Bulgaria based on the most recently assessed status/potential of the surface water bodies

Note: Standard colours based on WFD Annex V, Article 1.4.2(i). Source: WISE, Eurostat (country borders) High Good Moderate Poor Bad Unknown River Basin Districts Countries outside the European Union

Figure 3.3 Ecological status or potential of surface water bodies in Bulgaria for the second RBMP, for the first RBMP and expected in 2015. The number in 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 the first RBMP is not known Source: WISE electronic reports Member States were asked to report the expected date for the achievement of good ecological status/potential. The information for Bulgaria is shown in 3.4. For coastal and transitional waters in the Black Sea RBD, good ecological status/potential is expected to be achieved by 2027. For rivers and lakes, there remain some uncertainties on when this objective will be met, with a proportion with reported dates as unknown or beyond 2027. For the several water bodies with unknown ecological status/potential (especially in the East Aegean RBD), this is perhaps understandable but needs to be resolved. Figure 3.4 Expected date of achievement of good ecological status/potential of surface water bodies in Bulgaria. The number in the parenthesis is the number of water bodies in each category Source: WISE electronic reports Confidence in the classification of ecological status/potential Figure 3.5 shows the confidence in the classification of ecological status/potential. The number of surface water bodies increased from 759 for the first RBMPs to 955 for the second. This makes comparison between the cycles difficult. However, it is clear that the confidence in the classification of ecological status/potential has improved significantly for the second cycle. In particular, no water body was classified with high confidence in the first RBMPs, while 19 % were in the second. In addition, the proportion of water bodies classified with low confidence decreased from 87 % to 16 %.

Figure 3.5 Confidence in the classification of ecological status or potential of surface water bodies in Bulgaria based on the most recently assessed status/potential Source: WISE electronic reports Classification of ecological status at the quality element level Figure 3.6 shows the percentage of water bodies in terms of the biological quality elements used for classification. Benthic invertebrates are the most commonly used biological quality element in the classification of ecological status across each of the water categories, with phytoplankton also widely used. This perhaps reflects the traditional use of these elements in the assessment of ecological status. The coverage in terms of the proportion of surface water bodies covered by each biological quality element is not complete, especially in rivers and lakes, suggesting that some further progress is required in the monitoring of biological quality elements and their use in classification. Figure 3.6 Ecological status/potential of the biological quality elements used in the classification of lakes and rivers in Bulgaria. Note that water bodies with unknown status/potential, and those that are monitored but not classified or reported as not applicable, are not presented Source: WISE electronic reports Figure 3.7 compares the classification of biological quality elements in terms of ecological status/potential for the two cycles. It should be