EUROPEAN COMMISSION Brussels,17.7.2018 SWD(2015) 54 final/2 CORRIGENDUM

This document corrects document SWD(2015) 54 final of 09.03.2015.

[Document updated with River Basin Districts GR13 and GR14 in Greece].



The text should read as follows: COMMISSION STAFF WORKING DOCUMENT Report on the implementation of the Water Framework Directive River Basin Management Plans

Member State: GREECE Accompanying the document COMMUNICATION FROM THE EUROPEAN COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL The Water Framework Directive and the Floods Directive: Actions towards the 'good status' of EU water and to reduce flood risks {COM(2015) 120 final}



{SWD(2015) 50 final}



{SWD(2015) 51 final}



{SWD(2015) 52 final}



{SWD(2015) 53 final}



{SWD(2015) 55 final}



{SWD(2015) 56 final}



TABLE OF CONTENTS 1. General information 2. Status of River Basin Management Plan reporting and compliance 3. Governance 3.1 Timeline of implementation 3.2 Administrative arrangements - river basin districts and competent authorities 3.3 RBMPs - Structure, completeness, legal status 3.4 Consultation of the public, engagement of interested parties 3.5 Cooperation and coordination with third countries 3.6 Integration with other sectors 4. Characterisation of river basin districts 4.1 Water categories in the RBD 4.2 Typology of surface waters 4.3 Delineation of surface water bodies 4.4 Identification of significant pressures and impacts 4.5 Protected areas 5. Monitoring 5.1 General description of the monitoring network 5.2 Monitoring of surface waters

5.3 Monitoring of groundwater 5.4 Monitoring of protected areas 6. Overview of status (ecological, chemical, groundwater) 7. Assessment of ecological status of surface waters 7.1 Ecological status assessment methods 7.2 Application of methods and ecological status results 8. Designation of heavily modified water bodies (hmwb) and assessment of good ecological potential 8.1 Designation of HMWBs 8.2 Methodology for setting good ecological potential (GEP) 8.3 Results of ecological potential assessment in HMWB and AWB 9. Assessment of chemical status of surface waters 9.1 Methodological approach to the assessment 10. Assessment of groundwater status 10.1 Quantitative status 10.2 Groundwater chemical status 10.3 Protected areas 11. Environmental objectives and exemptions 11.1 Additional objectives in protected areas 11.2 Exemptions according to Article 4(4) and 4(5) 11.3 Exemptions according to Article 4(6)

11.4 Exemptions according to Article 4(7) 11.5 Exemptions to Groundwater Directive 12. Programmes of measures 12.1 Programme of measures – general 12.2 Measures related to agriculture 12.3 Measures related to hydromorphology 12.4 Measures related to groundwater 12.5 Measures related to chemical pollution 12.6 Measures related to Article 9 (water pricing policies) 12.7 Additional measures in protected areas 13. Climate change adaptation, water scarcity and droughts, flood risk management and other emerging and linked issues as part of the rbmp 13.1 Water Scarcity and Droughts 13.2 Flood Risk Management 13.3 Adaptation to Climate Change 14. RECOMMENDATIONS



General information Figure 1.1: Map of River Basin Districts International River Basin Districts (within EU) International River Basin Districts (outside EU) National River Basin Districts (within EU) Countries (outside EU) Coastal Waters

Source: WISE, Eurostat (country borders) Greece has a population of 11 million with a high concentration in the Athens metropolitan area, and a total surface area of 131,957 square km. It is located in the southern extremity of the Balkan peninsula in south-east Europe. Its territory includes more than 2,000 islands in the Aegean and Ionian seas. Mount Olympus is the highest point in the country. Greece has 14 River Basin Districts (RBDs) (see Table 1.1. below). The two largest ones are the Western Macedonia RBD (GR09) covering 13,585 km2 and the Thessalia (GR08) covering 13,153 km2. Two of the RBDs, namely Aegean Islands (GR14) and Crete (GR13) cover islands, while 6 more (Northern Peloponese-GR02, Western Sterea Ellada-GR04, Epirus-GR05, Attica-GR06, Eastern Sterea Ellada-GR07 and Thrace-GR12) cover both mainland and island areas. The following overview is provided regarding the shared transboundary catchment with MS/third countries (see Table 1.2 below): §With Albania: Lake Prespa Basin (Part of Drin/Drim sub-basin) (GR09), Aoos/Vjosa River Basin (GR05); §With Bulgaria: Mesta-Nestos River Basin (GR12), Struma-Strymonas River Basin (GR11), Maritsa-Evros-Meric River Basin (GR12), Axios/Vardar River Basin (GR10); §With the former Yugoslav Republic of Macedonia: Lake Prespa Basin (Part of Drin/Drim sub-basin) (GR09), Axios/Vardar River Basin including the Doirani Lake Basin (GR10), Struma-Strymonas River Basin (GR11); and, §With Turkey: Maritsa-Evros-Meric River Basin (GR12). RBD Name Size* (km2) Countries sharing borders GR01 Western Peloponnese 7,235 - GR02 Northern Peloponnese 7,418 - GR03 Eastern Peloponnese 8,442 - GR04 Western Sterea Ellada 10,432 - GR05 Epirus 10,007 AL GR06 Attica 3,139 - GR07 Eastern Sterea Ellada 12,268 - GR08 Thessalia 13,153 - GR09 Western Macedonia 15,218 AL, FYROM GR10 Central Macedonia 14,264 BG, FYROM GR11 Eastern Macedonia 7,320 BG, FYROM GR12 Thrace 11,242 BG, TR GR13 Crete 8,301 - GR14 Aegean Islands 9,118 - Table 1.1: Overview of Greece’s River Basin Districts * Area in Greek territory Source: River Basin Management Plans reported to WISE : http://cdr.eionet.europa.eu/be/eu/wfdart13



Name international river basin National RBD Countries sharing borders Co-ordination category 2 3 4 km² % km² % km² % Lake Prespa (Part of Drin/Drim Sub-basin) GR09 AL, MK 347 25.1 Aoos/Vjosa GR05 AL 2,154 33.0 Mesta-Nestos GR12 BG 2,429 42.3% Struma-Strymonas GR11 BG, FYROM 6,295 36.5% Maritsa-Evros_Meric GR12 BG, TR 3,345 6.3% Axios/Vardar GR09 FYROM, BG 863 3.9 Axios/Vardar GR10 FYROM, BG 1,636 7.3 Table 1.2: Transboundary river basins by category (see CSWD section 8.1) and % share in Greece . Category 1: Co-operation agreement, co-operation body, RBMP in place. Category 2: Co-operation agreement, co-operation body in place.

Category 3: Co-operation agreement in place. Category 4: No co-operation formalised. Source: EC Comparative study of pressures and measures in the major river basin management plans in the EU. Note: the area figures (km2) refer to the actual hydrological catchment of the respective river (i.e. not the RBD area, nor the respective WFD river basin area which both contain additional small catchments grouped with the actual river catchment)



Status of River Basin Management Plan reporting and compliance By late 2014 , Greece had adopted 12 RBMPs (GR01, 02, 03, 04, 05, 06, 07, 08, 09, 10, 11, 12), which have also been fully reported in WISE (along with the accompanying Annexes) (see Table 2.1 below). In late 2014, in the context of a bilateral meeting between Commission Services and Greek authorities, some additions and corrections to specific tables of this report were provided, which have been incorporated. In 2015, 2 additional RBMPs have been adopted (GR13 and 14) which have been reported in WISE in March 2016 (yet without the full accompanying Annexes as it was done for the other 12 RBMPs). The drafting of the 12 RBMPs (GR01, 02, 03, 04, 05, 06, 07, 08, 09, 10,11, 12) was commissioned to different consultants and coordinated by the Ministry of Environment, Energy and Climate Change – Special Secretariat for Water (EGY) assisted by a “coordinator consultant”. In contrary the drafting of the RBMPs for GR13 and GR14 has been undertaken by the EGY in close collaboration with the Water Directorates of the Decentralised Administration (of Crete and North & South Aegean respectively). A general national approach has been followed, yet it is evident that the RBMPs’ implemented approaches and structures present commonalities within the plans assigned to the same consultant, and differences across the background documents (Annexes) of the plans assigned to different consultants. Thus, the following groups can be observed: GR01/02/03, GR04/05/08, GR06/07, GR09/10, GR11/12, GR13/14 The role of the “coordinator consultant” was to support the EGY and provide expertise and guidelines (also in the form of guidance documents, which were nevertheless not officially published) for the streamlining and harmonisation of the process. One of the main shortcomings of the Greek RBMPs is that they have been delayed due to a number of factors which relate to technical issues, as well as legislative and administrative barriers and socio-economic constraints. Consequently, time to implement the suggested Programme of Measures (PoMs) by 2015 and revise the plans for the second WFD cycle (considering and embedding the effects of the measures) is very tight (even impossible for GR13/14 which were adopted in 2015). Nevertheless EL has specified that implementation of a great number of measures included in the PoMs had started before the approval of the RBMPs (detailed information on this aspect is reported by EL to be available in the PoM-Implementation Progress Report – national level, due in December 2012 but submitted to the COM in late 2014, and uploaded on WISE on 22.01.2015; the contents of that Progress Report has not been assessed yet and therefore is not taken into account in this report). Another significant problem with the RBMPs was the lack of WFD-compliant data. The information used for the various assessments was based on the old monitoring network which was obsolete (with regard to the WFD required data) and the time-series fragmented and incomplete. Thus, the embedded uncertainty in the characterisation is judged significant, and in some cases it is not transparent how water bodies have been classified as “good” status (given the lack of complete information), as opposed to “unknown” status, since the characterisation is based on limited data and assumptions. The new National Monitoring Programme (NMP), according to the WFD requirements, has been established late in the process (in 2012) and it is mentioned that it will furnish the necessary data for the revision and update of the RBMPs in the second cycle. Yet, the RBMPs have proposed some modifications with regard to the sites and parameters of the NMP based on their current findings, which essentially resulted from the new typology using system B (as opposed to the original typology using system A back in 2011 when the NMP was designed, see section 5.1 below). These suggestions have not been taken up yet by the Special Secretariat for Water, and would in some cases require additional financial resources (i.e. when supplementary sites are proposed). It is stated by EL that the NMP will be updated for the planning period 2016-2021, taking into account all available data and information from the RBMPs and of course the proposed modifications in each RBD. After the adoption of the RBMPs for all of the country’s RBDs and a cost-effectiveness analysis in relation to the financial resources already allocated for the planning period 2016-2021, the Special Secretariat for Water will propose a new updated National Monitoring Network to be consulted on with all involved national and regional authorities, within 2015. The new updated National Monitoring Network will be defined in an amendment of the JMD 140384/9-9-2011. With regard to harmonisation and common approaches across the RBMPs, a national coordination programme was in place, yet it is not clearly reflected that all RBMPs implemented exactly the same approaches (e.g. on issues with small water bodies, definition of “significance” of pressures, assessment of groundwater quantitative status) when reading the WISE summary reporting and the Annexes. The Annexes themselves are very different in structure and content (for the same topics) which confuses the reader. A common structure and content across the RBMPs’ Annexes would have increased transparency and understanding, while all the Annexes for GR13/14 have not been reported in WISE. Finally, a common approach to ensure adequate incentives for efficient use and an adequate contribution from different users was not in place (Art. 9). Moreover, economic analysis varied across the RBMPs, partly due to missing information. It is planned that the methodologies for the economic analysis will be increasingly harmonised in the second and future cycles of review of the RBMPs. An important strength for the Greek RBMPs is that all underwent strategic environmental assessment (SEA). Another added value is the parallel development of a Drought & Water Scarcity Management Plan (DMP) for each RBD (except for GR13/14). In most cases the specific sub-units or specific river basins are looked at separately. Quantity issues are discussed in the RBMPs and some measures related to quantity management (incl. efficient use of water resources) have been identified in the PoMs. The links between the RBMPs and the DMPs should be further strengthened and the DMPs should be further developed into fully operational plans complementing the RBMPs. DMPs for GR13/14 are planned to be developed, in fact these are mentioned in the PoMs as a basic measure. RBD RBMP Date of Adoption RBMP Date of Reporting* GR01 08/04/2013 13/09/2013 GR02 08/04/2013 13/09/2013 GR03 08/04/2013 13/09/2013 GR04 18/09/2014 05/12/2014 GR05 04/09/2013 28/01/2014 GR06 08/04/2013 05/09/2013 GR07 08/04/2013 05/09/2013 GR08 18/09/2014 05/12/2014 GR09 30/01/2014 25/09/2014 GR10 30/01/2014 25/09/2014 GR11 04/09/2013 19/03/2014 GR12 04/09/2013 12/02/2014 GR13 27/02/2015 16 /03/2016 GR14 17/09/2015 11/03/2016 Table 2.1: Adoption and reporting to the Commission of Greece’s RBMPs. Source: RBMPs and CDR. *Latest date of WISE reporting including all annexes and background documents.



Governance Timeline of implementation

The dates of publication of RBMP preparatory documents are provided in Table 3.1.1 below; these are behind the due dates set in Art. 14 of the WFD. RBD Timetable Work programme Statement on consultation Significant water management issues Draft RBMP Final RBMP Due dates 22/06/2006 22/06/2006 22/06/2006 22/12/2007 22/12/2008 22/12/2009 GR01 05/04/2013 05/04/2013 05/04/2013 05/04/2013 05/04/2013 08/04/2013 GR02 05/04/2013 05/04/2013 05/04/2013 05/04/2013 05/04/2013 08/04/2013 GR03 05/04/2013 05/04/2013 05/04/2013 05/04/2013 05/04/2013 08/04/2013 GR04 01/11/2011 01/02/2012 05/04/2013 04/09/2013 30/10/2013 18/09/2014 GR05 01/11/2011 01/02/2012 05/04/2013 04/09/2013 04/09/2013 04/09/2013 GR06 30/08/2010 13/04/2011 03/05/2012 13/01/2012 03/05/2012 08/04/2013 GR07 30/08/2010 13/04/2011 03/05/2012 13/01/2012 03/05/2012 08/04/2013 GR08 01/11/2011 01/02/2012 05/04/2013 04/09/2013 30/10/2013 18/09/2014 GR09 15/06/2011 27/04/2012 30/07/2012 30/07/2012 01/02/2013 30/01/2014 GR10 15/06/2011 27/04/2012 30/07/2012 30/07/2012 01/02/2013 30/01/2014 GR11 30/08/2010 09/08/2010 15/10/2011 18/11/2011 07/05/2012 04/09/2013 GR12 30/08/2010 09/08/2010 15/10/2011 18/11/2011 07/05/2012 04/09/2013 GR13 1126/04/2013 1126/04/2013 11/07/2013 2711/07/2013 -04/032014 2731/03/2015 GR14 30/05/2014 30/05/2014 -30/05/2014 1730/05/2014 3007/10/2014 17/09/2015 Table 3.1.1: Timeline of the different steps of the implementation process Source: WISE (for all columns except “Final RBMP”) and DG Environment web page: http://ec.europa.eu/environment/water/participation/map_mc/countries/greece_en.htm (for “Final RBMP” column). Administrative arrangements - river basin districts and competent authorities At a decentralised level, Greece is managed by 7 Decentralised Administrations, 13 self-governed Regions, and 325 Municipalities. This restructuring of the decentralised state structure in Greece (called “Kallikratis”) was implemented in 2010 and has created some confusion regarding the roles and functioning of various state institutions and difficulties on various topics including water management. With regard to the development of the RBMPs, the national competent authority is the "Special Secretariat for Water" (under the Ministry of Environment, Energy and Climate Change), based on the Presidential Decree 24/2010 OJ A 56/15.04.2010 and Law 3199/2003, which has the following responsibilities: coordination of water management issues; implementation of the WFD; monitoring of water quality and quantity; management and reuse of wastewater; floods management. Furthermore, the main competencies of the Secretariat are described in WISE 1.1. The decentralised administrations (Regional Water Directorates) are responsible for the river basin districts. However, for the first round of the RBMPs they signed off their responsibility for the drafting of the plans to the EGY, but they were involved and contributed to the final formulation of the PoMs at the regional level; they are the ones responsible for implementing the plans. The RBMPs specifically state that “the RBMPs of Greece are developed under the responsibility of the competent authorities for each RBD. Based on a request by their Secretaries, the Special Secretariat for Water took over the development of the RBMPs, which then were commissioned to consultants”. Other authorities including regional, municipal, and local authorities from other sectors have contributed under topics of their expertise and interest. Nevertheless, this has not been the case for GR13/14: they were not commissioned to consultants, but they were in fact drafted by the EGY with the direct contributions of the Regional Water Directorates of Crete, and North and South Aegean respectively. Finally, in the relevant Annexes on those “responsible for specific aspects of water management”, long lists of additional authorities are presented showing how complex the overall setup is. With regard to the main next steps and difficulties, the RBMPs mention that many of the “responsible authorities” at the regional level are not sufficiently staffed, so they are in danger of not fully covering their responsibilities. Additionally, the fact that the RBMPs were commissioned to consultants may have limited the Regional Water Directorates’ opportunities to gain further insight into WFD issues and experience (except for GR13/14). Capacity building has nevertheless been undertaken through seminars organised by the EGY. As mentioned above, the drafting of the RBMPs was commissioned to different consultants and coordinated by the EGY (except for GR13/14). A general national approach has been followed. There are some differences in terms of the methodologies and available data that were used among the different groups of the consultants e.g. the GR01/02/03 plans were compiled by one team, the GR04/05/08 plans by another, GR06/07 plans by a third team, GR09/10 plans by a fourth, GR11/12 plans by a fifth, while GR13/14 by the EGY and the Regional Water Directorates (also assisted by the local universities of Crete and Aegean), as well as by other involved regional and local authorities).. However, as the Special Secretariat for Water coordinated all the teams there are several common specifications. There were no main changes announced or implemented after the submission of the RBMPs (corrections dealt with clarifications or typos). RBMPs - Structure, completeness, legal status In general the structure of the RBMPs follows the specifications of the WFD. In terms of clarity there are certain issues regarding the implementation of the methodology that is described in the relevant chapters of the RBMPs. In some cases it is not very clear whether and how a specific methodology, e.g. for assessing the water bodies, is applied. The different RBMPs have the same structure and content, but are accompanied by numerous Annexes, and harmonisation of structure and content is missing across them, thus confusing the assessment. In terms of completeness, it is explicitly mentioned on several occasions that there was insufficiency of available data and supporting studies/surveys for the assessment of water bodies. It is mentioned that in cases where no data were available, the assessment was done through expert judgment and/or through grouping of water bodies with similar types and levels of pressures, and thus the level of uncertainty was characterised as large. An improvement of the data quality and the water bodies’ assessment can only be addressed through the implementation of the National Monitoring Program that was defined with the Common Ministerial Decree 140384/9-9-2011. It was originally foreseen that the new network programme would provide the first monitoring results at the end of 2013. This new data would be used to improve the knowledge of the water bodies’ status and thus the completeness of the RBMPs in the next cycle. No links to any international plans are referenced within the RBMPs. 8 of them have been approved and embedded into the National Law by September of 2013 (GR01/02/03/05/06/07/11/12), another 4 by September 2014 (GR04/08/09/10), while the remaining 2 by September 2015 (GR13/14). The relevant Strategic Environmental Assessments/Environmental Impact Assessments (SEA/EIAs) have been approved as well and are publicly available. The 12 RBMPs officially approved by late 2014 should implement the Programmes of Measures in the following very short period as the second round of revised Plans should be submitted by 2015, according to the WFD, taking into account the implementation of the first RBMPs, while it is questionnable if this is even feasible for the 2 RBMPs which have been approved in late 2015 (GR13/14) . Consultation of the public, engagement of interested parties Regarding the RBMPs of GR01/02/03/09/10 there was a critical assessment expressed in a rather “positive” way about most consultation activities (in WISE 1.3.6), mentioning that: “Unprecedented for the Greek situation was the less than expected participation of the public”. A “results of the participation” document was submitted along with the relevant RBMPs. Regarding the consultation procedures, in the RBMPs of GR04/05/06/07/08/11/12, the consultation document does not refer to the activities that took place, but is a “planning document” for the activities that should/would take place. According to WISE 1.3.6, the main activities include: (a) publication and commenting of the public participation plan, involved stakeholders, Significant Water Management Issues report; (b) publication and commenting of the RBMP; (c) publication and commenting of the SEA/EIA; (d) informational meetings and (e) 39 stakeholder conferences/workshops (attended by 3,500 participants in total as stated by the EGY). Moreover the EGY has set up an interactive internet site http://wfd.ypeka.gr where the full content of the RBMPs is available and which facilitated the submission of comments by interested stakeholders. The consultation can be assessed as adequate but “improvable” in terms of stakeholders’ participation (almost 450 written comments/interventions were received through questionnaires and the consultation website) and input. Regarding the RBMPs of GR13/14, there was a positive assessment on the consultation activities, and a statement that the collaboration with the stakeholders was continuous and very active. It is difficult to describe the impact of the consultation on the final plans, since the document “results of the participation” was not submitted (however it is reported by EL as available in the EGY). A “general list of comments was received” during the consultation workshops but it cannot be inferred from the RBMP itself whether these comments were actually taken under consideration and were incorporated in the newer RBMPs version. It is stated by the EGY that they have been considered and incorporated. Most of the comments originated either from the scientific community or from other institutions, organisations, etc. There was no active continuous involvement of stakeholders and the general public but rather limited participation in certain consultation workshops. In general the consultation across all RBMPs can be assessed as not very successful in terms of stakeholder participation and input. Cooperation and coordination with third countries For GR05 there has not been international coordination on public participation and active involvement of interested parties. In practice, in Albania (where the Aoos River Basin extends), the decisions of the National Water Council (NWC) and the respective local authorities have not been implemented; thus the competent national and local authorities do not fully operate. Both in WISE and in the RBMP there is no specific reference to existing or planned coordination on public participation . For GR09, one part of the Prespa Basin and a sub-basin of Axios River extend geographically in the neighboring countries of FYROM and Albania; thus these basins are transboundary. However, there are no International RBMPs, as these countries are not EU MS; and thus not obligated to submit these Plans. Regarding the Axios River Basin, there is no border co-operation established for the integrated water resources management. Regarding the Prespa Basin there has been an international agreement between the three countries (Greece, Albania & FYROM) on the protection and sustainable development of the Prespa National Park. Additionally, a Coordination Commission was formed for the protection of the Park on 27/11/2009 and an International Agreement was signed on 02/02/2010 among the Ministers of Environment of the three countries and the EC Commissioner for the Environment. Furthermore, there has been recent mobility in international cooperation regarding the integrated water resources management in cross-border areas on 25/01/2012, followed by further meetings in June 2012 and May 2013 (both for Prespa and Axios Basin). Several actions and programmes have been implemented in the sub-basin of Prespa with the cooperation of Albania and FYROM. Also a working group has been established from 2006 for the monitoring and protection of the Prespa Basin. This group has organised four (4) meetings so far. For GR10, one part of the Strimonas River Basin extends geographically in the neighboring country of Bulgaria, thus this basin is a transboundary one. However, there has not been an International RBMP, as Bulgaria had already submitted its RBMP to the EC before Greece. Thus, for the first round of the Plans, these are separate for the two countries. However, since 27th July 2010, there has been a common Announcement of the two responsible Ministries (i.e. the Hellenic Ministry of Environment, Energy and Climate Change and the Bulgarian Ministry of Environment and Water Resources). The Announcement confirmed the intention of the two countries to cooperate in the water resources management issues in the transboundary basins. For this purpose, the Joint Expert Working Group was established. The Group initially met in Drama on 16th May 2011, in Sofia on 12th October 2011 and in Thessaloniki on 23rd April 2013. Recently there has been a Joint Declaration of the competent Ministers of Greece and Bulgaria regarding the intention of cooperation between the two countries on issues of transboundary basin management.

For GR11 and GR12 there has been no international coordination on public participation and active involvement of interested parties, as Bulgaria submitted its RBMP to the EC before Greece, while Turkey is not a MS and thus not obligated to submit Plans. For GR05/11/12 there have not been any international RBDs designated and no international RBMPs adopted. For GR11, in spite of the fact that there has not been full international coordination between Greece and Bulgaria, from 27th July 2010, there has been a Joint Declaration between the Hellenic Ministry of Environment, Energy and Climate Change and the Bulgarian Ministry of Environment and Water Resources regarding the use of water resources in the territories of shared river basins. The Joint Declaration confirmed the intention of the two countries to cooperate in the water resources management issues in the transboundary basins. For this purpose, the Joint Expert Working Group was established; the Group initially met in Drama on 16th May 2011, then in Sofia on 12th October 2011, in Thessaloniki on 23rd April 2013 and in Athens on 8th May 2014. As regards the public participation there has been no international coordination between the two countries. For GR12, in spite of the fact that there has not been full international coordination between Greece, Bulgaria and Turkey, regarding the cooperation with Bulgaria, there has been a series of negotiations that started in 1965 and resulted in an Agreement between Greece and Bulgaria that was signed in 1995, certified with the Greek Law 2402/96, Government Gazette (GG/A/98) and has 8 Articles. As with GR11, the cooperation of the two countries was enhanced on 27th July 2010 with the Joint Declaration of the two responsible Ministries (see further details above). Additionally, regarding the cooperation with Turkey, an Ad Hoc Joint Committee has been established in November 2010 in respect to cooperation issues for the Evros River Basin. The Committee initially met on 30th May 2011. In this framework, the Joint Expert Working Group was established in order to exchange data and information for the Evros River and the relevant sub-basins in Greece and Turkey. The Joint Expert Working Group has met twice, in Adrianoupolis on 24th June 2011 and in Alexandroupolis on 8th September 2011. It should also be mentioned that both the Greek and the Turkish sides give a great deal of emphasis on a common management response to the flood issues of Evros, a subject of Greek terms associated with the implementation of the corresponding Directive 2007/60/EC on flood risk management in the EU. As regards the public participation there has been no international coordination between the interested countries. Integration with other sectors The links with 10 national sectoral plans were analysed in the SEAs which accompanied the RBMPs (e.g. National Plan for Rural Development 2007-2013). The Directorate for Spatial Planning and the Ministry of Rural Development were among the stakeholders that have sent written comments on RBMPs and the respective SEAs. There are some cases, such as the regional development plans, which are in the process of compilation and might have been linked or used information from the approved RBMPs but this is not currently established, as these plans are not fully completed yet. No links with agricultural plans are apparent in the RBMPs.



Characterisation of river basin districts Water categories in the RBD The RBDs reviewed in the current report include all water systems and their classification into four categories according to the requirements of the WFD (rivers, lakes, transitional and coastal waters, groundwater). According to Annex II of the WFD, categorisation of surface water bodies apart from the four above categories include the identification of Heavily Modified Water Bodies (HMWB) as well as artificial water bodies (AWB). Typology of surface waters The Presidential Decree 51/2007 “Establishment of measures and procedures for integrated protection and management of water in compliance with the provisions of the Water Framework Directive 2000/60/EC” defines in Annex II that both systems A and B could be used in the characterisation of surface water bodies. In the Greek RBMPs, system B has been mostly applied for all the water categories, with the exception of GR13 where system A was used for river and lake water bodies. More specifically, system A was selected because the information required for its implementation was readily available for GR13, but also because it contains the essential factors that differentiate the rivers and streams of this RBD, i.e. distinguishing different geological types and different types of altitude. For lakes, system A was also selected for GR14 as the information was also readily available and could efficiently identify the environmental variations between the lakes. It is to be noticed that previously, in 2009, in response to the obligations of Art. 8 of the WFD, system A was used for all the RBDs. In the current RBMPs there was a switch to system B for the 13 out of 14 RBDs (all obligatory descriptors for system B have been used), which resulted in the modification of the number, boundaries and characteristics of the surface water bodies. Overall the surface water typology has been validated with biological data. For river water bodies it was based solely on benthic macroinvertebrates, for lakes on phytoplankton and for coastal and transitional water bodies on macroinvertebrates, phytoplankton and macroalgae. In general, reference conditions have been established for each of the surface water types with the exception of the transitional waters where the work on reference conditions is at an early stage and the information provided so far is indicative until intercalibration is finalised. The methodology used was based both on spatially based methods, as well as on expert judgement. It is unclear from the RBMPs and Annexes (provided as background documents) how much expert judgement was used. In terms of a national Guidance Document, guidelines were formulated by the coordinator consultant and the General Secretariat for Water to guide and harmonise the work and methodological approach of all other consultants who were commissioned with the drafting of the RBMPs, but these were not organised into a detailed guidance document. The number of surface water types that have been defined in different water categories is summarised in Table 4.2.1. RBD Rivers Lakes Transitional Coastal GR01 6 1 2 1 GR02 6 4 2 1 GR03 5 1 2 1 GR04 8* 3* 2* 1* GR05 8 3 2 1 GR06 1 1 0 1 GR07 5 1 1 1 GR08 8* 2* 0* 1* GR09 10 4 2 1 GR10 7 4 2 1 GR11 6 2 1 1 GR12 7 2 2 1 GR13 6** 2** 2** 3** GR14 No data reported in WISE1 1** 1 0 5 Table 4.2.1: Surface water body types at RBD level

Source: WISE; * corrections/additions provided by EL late 2014; ** no data reported in WISE-the information is extracted from the RBMP Delineation of surface water bodies The river delineation process excluded from the first step ephemeral streams, where 95% of the time there is no presence of water in them and neither is any aquatic environment present. After this exclusion the initial water bodies selection was performed on the basis of the Strahler stream classification index. Only streams of the 4th order and above are initially included in the set. This initial set is considered by definition to be comprised of “important and discrete” elements of surface water, but not including all such elements. Additional water bodies (which were initially excluded due to their ephemeral flow) were then added to this initial set if deemed important elements in terms of aquatic ecosystem and fish population. This assessment of importance of these small water bodies was made almost exclusively based on expert judgment of scientists from the Hellenic Centre for Marine Research (HCMR) taking into account biological data (fish and benthic invertebrates) where available. In the RBMPs it is mentioned that an investigation was undertaken into whether small water bodies can be aggregated with adjacent water bodies (aggregation was performed where feasible and essential). However, a different approach was followed in the case of GR13 using the factors that were defined through the intercalibration exercise for the delination, and mainly associated with the periodicity of the streamflow. More specifically, three categories have been distinguished in Crete: the 1st category includes river water bodies where streamflow occurs for 8 to 9 months during the wet period. In the 2nd category streamflow occurs for 6 to 8 months,while in the 3rd category it occurs for a very limited period (about 3 months) . It has been identified that in GR13 the dominant type of rivers is small and ephemeral. A special attention has been given on this aspect, and GR13 further introduced 2 new river types (RM-1a, RM-5a) expanding on the results of theIntercalibration exercise in the Mediterranean GIG.Finally, some further additions were made during the consultation process where some additional streams to be included were indicated by local officials and scientists. For example, in the RBMP of GR11 it is stated that during the public consultation, objections were raised with regards to the inclusion of some small water bodies with ephemeral flow in the sub-catchment of the Aggitis River, and thus the necessary adjustments were then performed to exclude them. The above clarifications were provided by EL since it does not clearly appear from the RBMPs’ Annexes how the inclusion/exclusion of small water bodies has actually been implemented (i.e. the specific criteria for defining what is termed as an “important” element of water/ aquatic ecosystem are not clear in the RBMPs; the information on which small water bodies have been joined with adjacent ones, or not joined, and/or not considered is not obvious). In the case of lakes, all lakes with a size greater than 0.5 km2 have been considered as surface water bodies. RBD Surface Water Groundwater Rivers Lakes Transitional Coastal Number Average Length (km) Number Average Area (sq km) Number Average Area (sq km) Number Average Area (sq km) Number Average Area (sq km) GR01 110 8 2 2 5 1 11 95 26 262 GR02 63 11 6 5 9 2 19 127 26 284 GR03 80 7 1 1 6 1 13 206 27 299* GR04 102* 10* 5* 26* 4* 68* 8* 273* 25* 410* GR05 85 13 1 19 7 59 13 81 26 349 GR06 14 9 1 3 0 - 14 288 24 129 GR07 81 13 3 12 1 18 19 339 46 268 GR08 74* 19* 1* 35* 0* 0* 7* 134* 32* 392* GR09 150 10 14 39 2 20 2 564 62 275 GR10 104 11 6 28 3 23 11 350 39 348 GR11 91 9 2 24 1 7 4 183 15 456 GR12 188 10 6 4 5 56 12 61 18 578 GR13 -118 -6 -5 -1 -4 -0 -25 -89 -91 -92 GR14 -75 -4 -8 -0 -0 -0 -87 -70 -113 -79 Total 1335 10 4861 17 4347 2324 133245 225204 366570 338262 Table 4.3.1: Surface water bodies, groundwater bodies and their dimensions Source: WISE; * corrections/additions provided by EL late 2014. Identification of significant pressures and impacts

Even though in certain RBDs limited information on methods for defining significant pressures is available, the WISE summary report shows that determination of significant pressures has been made for all of the RBDs. Table 4.4.1 gives an overall picture of the significance of the different pressures within the country. These data indicate that diffuse pollution is assessed as the most significant pressure in Greece, affecting 48% of surface water bodies (808 SWBs) followed by point source pollution which affects 33% (549 SWBs). “Other pressures” affect 14% (229 SWBs), and surface water abstraction affects 4% (74 SWBs) of surface water bodies. Additionally, pressures such as water flow regulations and morphological alterations, other morphological alterations,river management and transitional and coastal water management are allocated smaller percentages, i.e. 3% (43 SWBs), 0.3% (4 SWBs), 1% (14 SWBs) and 1% (9 SWBs) respectively. It needs to be pointed out that GR13 and GR14 have reported very small percentages of water bodies affected by diffuse and point source pressures (only about 10%), which lowers the overall country average (the country average is decreased by about 12-15%). An explicit identification of the criteria used to determine the significance of pressures is not apparent in all the RBMPs, yet EL clarified that criteria (and the related thresholds) for individual pressures (point and diffuse pollution, and water abstraction) were identified from the limits contained in other relevant Directives, studies and research results found in literature, and expert judgement as being likely to impact on water status. Regarding point source pollution, some RBMPs (such as GR11/12) refer to the use of both numerical tools and expert judgement in pressure analysis; however, they do not provide details on the specific methods or criteria used. On the other hand, GR01/02/03/05/06/07/09/10/13/14 identify specific thresholds that define significant pressures from point source pollution (e.g. in GR05 the significance of pressure from industrial units was based on the criterion of the type, size and number of units that relate to discharges of priority substances and were classified as follows: N≥5 (high), 1≤N<5 (medium), N=0 (low)). Regarding diffuse source pollution most RBDs (e.g. GR01/02/03/04/05/06/07/08/09/10/13/14) give a summary table of criteria (related to type, size and pollution load) for all pressures, defining specific levels of N, P and BOD concentrations as thresholds connected to diffuse pollution (e.g. when BOD>10 mg/l, N>10mg/l and P >1mg/l the pressure is defined as significant). Regarding abstraction pressures, generally in all RBDs a description of the pressures considered and the methodology followed is mentioned (a mixture of actual numbers and expert judgement). Criteria for assessing the significance of the pressure are available in GR01, GR02, GR03, GR04, GR06 (only relevant for groundwater abstractions), GR07, GR08 GR09 and GR10. These criteria relate to the assessment of water exploitation, abstraction volumes as percentage the natural annual and summer runoff volumes. Regarding water flow regulation and hydromorphological alterations, overall all RBMPs describe these pressures and a relevant analysis (a mixture of actual numbers and expert judgement), but specific criteria to judge significance were not found in the background documents. The most common hydromorphological pressures mentioned and analysed among RBDs are: flood defence structures/dams, water reservoirs, modifications and diversions, water transfers. Further information provided by Greek authorities indicate that the criteria used are far from comprehensive because, to a large extent, only main dams (higher than 15 m and considering also the abstractions and the regulating capacity in relation to the river flow) have been considered as significant hydromorphological pressure. It appears also that the main impact that has been assessed is downstream of the dam, not necessarily considering the water bodies where the dams are located and the upstream effects. This approach potentially overlooks many smaller but significant hydromorphological pressures. This is likely the reason for the very low percentages of water bodies reported as affected by hydromorphological pressures. As regards pollution loads, the main conclusions for each RBD are summarised below: ·GR01: the greatest individual point source pollution load comes from industrial units. Important pollution is also produced from urban waste water, and notable BOD load is produced by aquaculture. ·GR02/03: the greatest point source pollution burden comes from industrial units. Regarding diffuse pressures, livestock produces the largest amount of pollutants. ·GR04: it is evident from the available data collected for point source pollution that the increased pressure on water bodies comes from the Acheloos basin (GR15). Significant point source pollution loads are mainly generated by the industrial units and the stabled livestock. The greatest effect from non-point source pollution seems to be related to the intense livestock activity in the region, as the organic load, the nitrogen and phosphorus load is estimated to contribute over 90%, 80% and 50% respectively, of the total load. ·GR05: Significant point source pollution loads are mainly generated by industrial units and stabled livestock. One of the major sources of non-point source pollution in the area relates to livestock and agriculture. In particular, the greatest effect is associated with intense livestock activity in the region, as the organic load, the nitrogen and phosphorus load is estimated to contribute more than 90%, 80% and 60% of the total load respectively. ·GR06: it was concluded that the main pollution load is generated by the intense industrial activity. Moreover, from the evaluation of quantitative estimates of diffuse sources of pollution it was concluded that surface runoff from cropland and livestock contribute significantly to pollution loads. The organic load due to untreated urban sewage contributes more than 60% of the total organic load (BOD t/year), while the effect of nitrogen and phosphorus load due to agricultural activity is greater (75% and 90% respectively). ·GR07: the main pressures on surface water bodies come from the sectors of agriculture, industry and livestock. From the assessment of quantitative estimates of diffuse sources of pollution it can be concluded that surface runoff from agriculture and livestock contributes significantly to pollution loads. The organic load due to livestock contributes more than 78% of the total organic load, while the effect of nitrogen and phosphorus load due to agricultural activity is greater (84% and 95% respectively). ·GR08: the increased pressure on the water bodies comes mainly from the river basin of Pinios from various activities (urban waste water treatment plants, livestock activity, industry, mining activities and uncontrolled dumpsites). Regarding the pollution load from diffuse sources (mainly from agriculture and stable livestock activity), the organic load and the nitrogen load resulting from livestock is over 90% and 60% respectively, while greater is the influence of phosphorus load due to agricultural activity (about 70%). ·GR09/GR10: industrial activity together with livestock and agriculture are the greater pressures within the water district. Quantitative estimates of diffuse sources show that the surface runoff from cropland and livestock contribute significantly to pollutant loads. The effect of nitrogen and phosphorus load due to agricultural activity is significant. It is worth mentioning that the concentration of organic load is generated mostly due to livestock activities, while nitrogen and phosphorus arise in farming and agriculture. The mining activity that relates to water pollution is located mainly in the region of Jerrissou, in the southeast of the water districts. ·GR11/12: most of the pollution loads come from agriculture, livestock and urban waste. ·GR13/14: most of the pollution loads comes from agriculture, livestock, oil mills, atmospheric deposition and sewage from urban settlements that are not served by Urban Waste Water Treatment Plants (UWWTP).

RBD No pressures Point source Diffuse source Water abstraction Water flow regulations and morphological alterations River management Transitional and coastal water management Other morphological alterations Other pressures No. % No. % No. % No. % No % No. % No. % No. % No. % GR01 - 0 88 69 128 100 10 8 0 0 0 0 0 0 0 0 32 25 GR02 - 0 48 49 97 100 18 19 0 0 0 0 0 0 0 0 39 40 GR03 2 2 63 63 98 98 4 4 0 0 0 0 0 0 0 0 37 37 GR04 53* 44* 54* 45* 41* 34* 11* 9* 17* 14* 5* 4* 4* 3* 0* 0 53 44 GR05 44 42 46* 42 44* 41 11* 9 8 8 0 0 5* 5* 0* 0* 44* 42* GR06 5 17 23 79 19 66 0 0 0 0 0 0 0 0 0 0 0 0 GR07 20 19 67 64 74 71 5 5 0 0 0 0 0 0 4 4 0 0 GR08 13* 16* 55* 67* 62* 76* 2* 2* 2* 2* 7* 9* 0* 0* 0* 0* 13* 16* GR09 115 68 28 17 25 15 0 0 0 0 0 0 0 0 0 0 0 0 GR10 51 41 26 21 67 54 1 1 0 0 0 0 0 0 0 0 0 0 GR11 40 41 17 17 52 53 10 10 6 6 0 0 0 0 0 0 0 0 GR12 114 54 5 2 95 45 2 1 9 4.27 2 1 0 0 0 0 10 5 GR13 124 82 22 14 5 3 -0 -0 0 -0 -0 -0 -0 -0 -0 -0 1 1 GR14 -161 95 7 4 1 1 -0 -0 1 1 -0 -0 -0 -0 -0 -0 0 -0 Total 742 44% 549 33% 808 48% 74 4% 43 3% 14 1% 9 1% 4 0,3 229 14% Table 4.4.1: Number and percentage of surface water bodies affected by significant pressures Source: WISE; * corrections/additions provided by EL late 2014. Figure 4.4.1: Graph of percentage of surface water bodies affected by significant pressures 1 = No pressures 2 = Point source 3 = Diffuse source 4 = Water abstraction 5 = Water flow regulations and morphological alterations 6 = River management 7 = Transitional and coastal water management 8 = Other morphological alterations 9 = Other pressures Source: WISE Protected areas In Greece 2,614 protected areas have been designated, according to information provided to WISE (see Table 4.5.1). Just over half of these areas (56%) are for bathing water (mostly from GR14), while 7% are for drinking water abstraction under Art. 7 of the WFD. Another 18% are for habitats, birds and fish altogether, 4% are for UWWTPs and 12% for local protected areas (mostly from GR14) With regard to the protected areas under Art. 7 abstraction for drinking water, out of the total 178 protected areas 131 are for groundwater (i.e. 74%) and the remaining 26% are for surface water. RBD Number of PAs Article 7 Abstraction for drinking water Bathing Birds European Other Fish Habitats Local National Nitrates Shellfish UWWT GR01 5 50 2 4 8 8 GR02 9 114 4 6 15 5 1 GR03 3 88 3 4 7 8 1 GR04 21* 60* 15* 22* 9* 25* 2* 12* GR05 10 87 21 23 33 23 2 6 GR06 4 125 4 5 3 4 GR07 16 170 14 16 4 11 GR08 7* 67* 16* 13* 5* 1* 2* GR09 17 11 11 6 22 2 2 23 GR10 4 84 9 15 1 4 6 GR11 15 23* 5 2 7 1 4 14 GR12 20 36 14 5 12 3 7 27 GR13 -47 -143 - - - -53 -57 - -2 - - GR14 -0 -405 - - - -89 -203 - - - - Total 131178 9151463 118 0 27 165307 42302 74 2123 17 105

Table 4.5.1: Number of protected areas of all types in each RBD and for the whole country, for surface and groundwater Source: WISE; * corrections/additions provided by EL late 2014. Monitoring General description of the monitoring network The monitoring programme for Greece has been defined in the Common Ministerial Decree ΚΥΑ 140384/9-9-2011 while the standards and minimum performance criteria of the analytical methods for the chemical analysis and monitoring have been defined in the Common Ministerial Decree 38317/1621/Ε103/2011. According to the Ministerial Decree 140384/9-9-2011, the EGY is responsible for: i) the submission of the annual budget for the operation of the NMP to the Ministry, ii) the monitoring at national level of the quantity and quality of surface and groundwaters in cooperation with the Regional Water Directorates of the Decentralised Administrations, iii) the development and operation of the national network/ grid. At the time that the RBMPs were being drafted, the new WFD monitoring programme was not operational. Thus, the monitoring data used for the characterisation of the water bodies in the RBMPs were based on the old fragmented monitoring network which had significant data gaps with regard to the WFD-required assessment parameters. The new National Monitoring Programme - NMP (established with the above mentioned Ministerial Decree in 2011 and currently implemented from 2012 onwards) follows a common national approach in terms of objectives, standards, definition of monitoring points, responsible authorities, etc. The number, type and location of monitoring stations per water body and the number, type and frequency of the sampling parameters are listed in the Ministerial Decree. All these were originally defined in 2009 in response to the obligations of Article 8 of the WFD, considering the state-of-the-art knowledge at that time and the results of a relevant study commissioned by the General Secretariat for Water (which also defined the water bodies, pressures and impacts) and were updated and finalised in 2010 in the framework of the national project “Development and application of methods and software for the assessment of the water quality related data of the Greek water bodies”. A total of 616 monitoring stations for surface water bodies are defined in the new programme for the whole territory, and 1,387 for groundwater bodies. It is foreseen that the new network programme will be updated periodically in order to better meet the systems’ needs based on the first monitoring results (originally expected at the end of 2013) and the findings of the current RBMPs. In the 13 out of 14 RBMPs the typology used for the characterisation of the water bodies changed with regard to the system that was used back in 2008-2009 (shifting from system A to system B). This resulted in the modification of the number, boundaries and characteristics of the water bodies, and the subsequent need to perform a new matching between the established monitoring points of the Ministerial Decree and the latest defined water bodies (in the RBMPs). The matching has been performed, but also additional information from the neighbouring RBDs, the water bodies’ grouping and the identified pressures and impacts has been integrated and led to suggestions on modification of the new monitoring programme to better serve its purpose. These suggestions are presented in all the RBMPs and are basically grouped under three main categories: (i) reallocation of the monitoring stations to neighbouring sites (e.g. upstream or downstream in rivers); (ii) switching of monitoring stations from the surveillance to the operational programme and vice-versa; (iii) inclusion/exclusion of the sampling elements and/or changes in the frequency of sampling. It is acknowledged in some RBMPs that these modifications (especially category ii - additional sites) may be difficult to implement since they would require additional funding, but categories i and iii are deemed feasible. Figure 5.1: Maps of surface water (left) and groundwater (right) monitoring stations • River monitoring stations • Lake monitoring stations • Transitional water monitoring stations • Coastal water monitoring stations • Unclassified surface water monitoring stations • Groundwater monitoring stations River Basin Districts Countries outside EU Source: WISE, Eurostat (country borders) Monitoring of surface waters As explained above, the data used in the RBMPs originated from the old monitoring network, which was not compliant with WFD requirements. The available data were fragmented, with many gaps in parameters and time-series which restricted the corresponding assessments in the RBMPs. The data of the old monitoring network were provided by different agencies, mainly the Ministry for the Environment, Energy and Climate Change, the Ministry of Rural Development and Food and the General Chemical State Laboratory. Data from regional authorities and sample monitoring from various existing surveys were also available in some cases. As a result, based on quality assurance, completeness, accuracy, etc. the following quality elements of the old monitoring system have been considered overall for the classification of surface water bodies (yet not in all cases, and not with continuous long time-series) in the current RBMPs: ·BQEs: benthic macroinvertebrates (for rivers); phytoplankton (lakes); macroinvertebrates, phytoplankton and macroalgae (coastal and transitional) –more details in section 7. ·Physico-chemical elements: transparency, thermal conditions, oxygen conditions, salinity, acidification conditions and nutrient conditions –more details in section 7. ·Hydromorphological elements: not clear if they have been considered –more details in section 7. ·Priority substances and other specific pollutants: Ni, Pb, Hg, Cd, Brominated diphenylether, Di(2-ethylhexyl)phthalate (DEHP), Endosulfan, Hexachlorocyclohexane, Chlorfenvinphos, Anthracene, Hexachlorobenzene, considered on a case-by-case basis –more details in section 9. In assessing the river water bodies (in the current RBMPs), grouping was performed when there was no monitoring station within a certain river water body (of the old network). Groups have been formulated so that each group contains at least one river water body which is being monitored. The grouping was based on the hydromorphological characteristics of the rivers (biogeographical regions, annual discharge, slope, altitude) as reflected in the water bodies’ typology, as well as on the type and intensity of pressures that are identified in the sub-catchment of the water body. The heavily modified and artificial water bodies have been excluded from grouping and are considered individually even when monitoring stations are not present in them. With regard to the New Monitoring Programme (established by the Ministerial Decree in 2011) it includes both surveillance and operational monitoring programmes including all relevant quality elements. A total of 616 monitoring stations for surface water bodies are defined in the NMP for the whole territory, of which 377 are for surveillance and 239 for operational monitoring. Biological, physico-chemical and hydromorphological QEs are defined to be monitored in all of them, priority substances in 326, specific pollutants in 282 and other substances in 29 of them. The relevant elements that are monitored per RBD are shown in Table 5.1 below as reported in the WISE Summary Reports 4.1.7 and 4.1.8, and further corrected by EL in late 2014 (except for the GR13/14 where corrections by EL are not made and it is not clear in WISE whether some elements are included or not).

Few of the monitoring stations are part of the International Network Barcelona Convention/Mediterranean Action Plan (MEDPOL). A detailed view of the programmes (surveillance & operational), station locations, elements and frequencies foreseen to be monitored at each water body is provided in the Annexes of the Ministerial Decree, and also on WISE - CDR under the Art. 8 reporting (submitted 26.08.2009), and have been defined in the document “Updated Report of Article 8 of the WFD including the catalogue of elements and parameters to be monitored in each station of the NMP”. The sampling and frequency methodologies are also mentioned there. With regard to the methodologies for selecting the BQEs of the operational programme, the priority substances and other pollutants, it is mentioned that these are developed within the guidance documents of the research project “Development of network and monitoring of the internal, transitional and coastal water bodies of the country – Assessment/Classification of their ecological status” undertaken by the HCMR-EKBY, 2008 (Hellenic Centre for the Marine Research – Greek Biotope/Wetland Centre). As mentioned above, upon the establishment of the RBMPs and their findings additional suggestions were made in the RBMPs regarding modifications to the NMP (inclusion/exclusion of monitoring stations and/or elements) to better accommodate the identified needs. Monitoring of groundwater As explained above, the data used in the RBMPs originated from the old monitoring network, which was not compliant with the WFD requirements. The available data was fragmented, with gaps in parameters and time-series which restricted the corresponding assessments in the RBMPs. The data of the old monitoring network were provided by different agencies, mainly the Institute of Geology and Mineral Exploration, the Ministry for the Environment, Energy and Climate Change, the Ministry of Development. Data from regional authorities and sample monitoring from various existing surveys were also available in some cases. As a result, based on quality assurance, completeness, accuracy, etc. the following elements and parameters of the old monitoring programme have been considered overall for the assessment of groundwater bodies (yet not in all cases, and not with continuous long time-series) in the current RBMPs: ·Quantitative status: abstraction per sector (mostly estimated from water demands); water balance (comparison between available groundwater resource by the long-term annual average rate of abstraction), groundwater levels, spring discharges –more details in section 10. ·Chemical status: pH, conductivity, chloride, nitrates, nitrogen dioxide, ammonium, sulphate. Pb, Cr, Ni, Al, Fe, Mg, Mn, B were assessed in a subset of the groundwater bodies. The data series of heavy metals (Pb, Cd, As, Hg) were not systematic – more details in section 10. ·No data were available for trichloroethylene and tetrachloroethylene. Thus, these parameters have not been considered in the assessments – more details in section 10. Quantitative, surveillance and operational monitoring programmes are included in the new monitoring network (established with the Ministerial Decree in 2011). It includes monitoring of quantitative status and the all chemical elements considered relevant by the Greek authorities. A total of 1,387 monitoring stations for groundwater bodies are defined in the NMP for the whole territory, of which 294 are for surveillance and 1093 for operational monitoring. Quantity and physico-chemical parameters are defined to be monitored in all stations, nitrates in 867, heavy metals in 844, pesticides in 502, and composite compounds in 284 of them. A detailed view of the programmes (quantitative, surveillance & operational), station locations, elements and frequencies foreseen to be monitored at each groundwater body are provided in the Annexes of the Ministerial Decree, and have been defined in the document “Updated Report of Article 8 of the WFD including the catalogue of elements and parameters to be monitored in each station of the NMP”. The sampling and frequency methodologies are also mentioned there. With regard to the criteria for defining the monitoring stations of the operational programme the following are listed: (I)Availability of existing monitoring stations (of the old networks) for which representative samples can be retrieved; (II)Possibility to support different programmes and requirements of the Water Framework, Groundwater and Nitrates Directives (e.g. monitoring of both quantitative and chemical elements, monitoring of nitrates pollution, monitoring of drinking water areas); (III)Accessibility and capacity to achieve/support the measurement of parameters on a long-term basis. With regard to the methodologies for selecting the parameters or elements of the operational programme, it is mentioned that these are developed within the guidance documents of the research project “Development of network and monitoring of the internal, transitional and coastal water bodies of the country – Assessment/Classification of their ecological status” undertaken by the HCMR-EKBY, 2008 (Hellenic Centre for Marine Research – Greek Biotope/Wetland Centre). As mentioned above, upon the establishment of the RBMPs and their findings, additional suggestions were made in the RBMPs regarding modifications to the NMP (inclusion/exclusion of monitoring stations and/or elements) to better accommodate the identified need. BD Rivers Lakes QE1.1 Phytoplankton QE1.2 Other aquatic flora QE1.2.3 Macrophytes QE1.2.4 Phytobenthos QE1.3 Benthic invertebrates QE1.4 Fish QE1.5 Other species QE2 Hydromorphological QEs QE3.1 General Parameters QE3.3 Non priority specific pollutants QE3.4 Other national pollutants QE1.1 Phytoplankton QE1.2 Other aquatic flora QE1.2.3 Macrophytes QE1.2.4 Phytobenthos QE1.3 Benthic invertebrates QE1.4 Fish QE1.5 Other species QE2 Hydromorphological QEs QE3.1 General Parameters QE3.3 Non priority specific pollutants QE3.4 Other national pollutants GR01 GR02 GR03 GR04 GR05 GR06 GR07 GR08 GR09 GR10 GR11 GR12 GR13 - - - - - - - - - - - - - - - - - - - - - - GR14 - - - - - - - - - - - - - - - - - - - - - -







RBD Transitional Coastal QE1.1 Phytoplankton QE1.2 Other aquatic flora QE1.2.1 Microalgae QE1.2.2 Angiosperms QE1.3 Benthic invertebrates QE1.4 Fish QE1.5 Other species QE2 Hydromorphological QEs QE3.1 General Parameters QE3.3 Non priority specific pollutants QE3.4 Other national pollutants QE1.1 Phytoplankton QE1.2 Other aquatic flora QE1.2.1 Microalgae QE1.2.2 Angiosperms QE1.3 Benthic invertebrates QE1.4 Fish QE1.5 Other species QE2 Hydromorphological QEs QE3.1 General Parameters QE3.3 Non priority specific pollutants QE3.4 Other national pollutants GR01 GR02 GR03 GR04 GR05 GR06 - - - - - - - - - - - GR07 GR08 - - - - - - - - - - - GR09 GR10 GR11 GR12 GR13 - - - - - - - - - - - - - - - - - - - - - - GR14 - - - - - - - - - - - - - - - - - - - - - - Table 5.1: Quality elements monitored



QE Monitored QE Not monitored - Not Relevant

Source: WISE Summary Reports: 4.1.7 and 4.1.8. Note: EL provided an alternative formulation of this Table, but the output from the Annexes and WISE have been used here. D Rivers Lakes Transitional Coastal Groundwater Surv Op Surv Op Surv Op Surv Op Surv Op Quant GR01 17 19 1 0 0 2 4 0 27* 59* 86* GR02 25 11 2 1 0 4 4 5 10 95* 105* GR03 12 10 0* 0* 0* 0* 3 2 13 113* 126* GR04 15* 26* 10* 2* 0* 5* 1* 1* 23* 42* 65* GR05 32 5* 3 1* 0* 6 2 5* 19* 71* 90* GR06 4 4 0 1 0* 0* 3 6 6 74 80 GR07 37 6 2 1 0 1 3 6 11 154* 165* GR08 24* 33* 2* 0* 0* 0* 4* 1* 33* 61* 94* GR09 19 11 2 10 0 2 1 0 45* 44 89* GR10 22 4 1 4 0 2 3 2 5 108 113 GR11 26 10 1 1 0 1 1 0 16 35 51 GR12 36 4 2 3 0 8 3 1 26 53 79 GR13 21* 5* 1* 2* 0* 0* 5* 1* 36* 76* 112* GR14 10* 0* 0* 0* 0* 4* 13* 0* 24* 108* 132* Total by type of site 300 148 27 26 0 35 50 30 294 1093 1387 Total number of monitoring sites 448* 53* 35* 80* 1387* Table 5.2: Number of monitoring sites by water category, in accordance with JMD 140384/09-09-2011 Surv = Surveillance, Op = Operational, Quant = Quantitative Source: WISE *corrections/additions provided by EL in late 2014. Some discrepancies between this information and the RBMPs/their Annexes are observed. Monitoring of protected areas Figure 5.2: Map of monitoring stations for protected areas

Source: WISE In the NMP there are monitoring stations located within protected areas and drinking water protected areas (of the Birds, Habitats and Drinking Water Directives). Upon the establishment of the RBMPs and their findings, suggestions were made to place additional stations in more protected areas which are explicitly mentioned. There is no detailed information in the RBMPs on specific monitoring programmes (e.g. drinking water, bathing water) for the protected areas (i.e. name and code of protected area, number and location of monitoring sites, specific monitored parameters, etc.).



RBD Surface waters Ground-water drinking water Surface drinking water abstraction Quality of drinking water Bathing water Birds sites Fish Habitats sites Nitrates Shell- Fish UWWT GR01 1* 0 6* 1* 4* 13* 0 0 0 9* GR02 3* 0 5* 10* 4* 13* 0 0 0 12* GR03 0 0 4* 4* 3* 6* 0 0 0 17* GR04 7* 0* 3* 28* 6* 25* 0* 0* 61* 4* GR05 0 0 0 0 0 0 0 0 0 20 GR06 1 0 8 3 0 6 0 0 2 13* GR07 3 0 8 23 0 34 15 0 5 69* GR08 0* 0* 5* 35* 0* 12* 58* 0* 64* 12* GR09 1* 1* 0 14 2* 15* 16* 0 5* 9* GR10 0 0 0 16* 0 11* 27* 4 4* 3* GR11 0 0 1* 4* 1* 6* 26* 1 6* 51* GR12 1* 0 3* 26* 1* 17* 21* 3 12* 79* GR13 -0 0 0 0 0 0 -1 0 1 0 GR14 0 0 0 0 0 0 0 0 0 0 Total 17 1 43 164 21 158 164 8 160 298 Table 5.3.1: Number of monitoring stations in protected areas . Source: WISE *corrections/additions provided by EL in late 2014



Overview of status (ecological, chemical, groundwater) The ecological status of natural surface water bodies presented in the RBMPs shows that 49 % are in high or good status (8% and 41% respectively). Another 16% are in moderate status, 9% in poor and bad status (8% and 1% respectively) while 27% remain unknown. GR04 presents the lowest percentage of surface water bodies with unknown status (2%) while GR13 the highest (55%). Variations are observed across the RBDs (see Table 6.1): GR04 and GR05 have the highest percentage of water bodies in high and good status (84% of their surface water bodies), while GR08 and GR09 has the highest percentage of water bodies in poor and bad status (40% and 25% respectively). With regard to the ecological potential of artificial and heavily modified water bodies (see Table 6.2), 6% across the RBDs are in good status, 22% in moderate, 22% in poor, 2% in bad and 48% in unknown status. In GR01/02/03/10/13/14 more than 60% are in unknown status (in GR14 it reaches 92%). It should be taken into consideration that in these classifications, not all relevant quality elements have necessarily been evaluated or considered, and that the available data were limited in many cases. As such the confidence in the classification is not high. RBD Total High Good Moderate Poor Bad Unknown No. (%) No. (%) No. (%) No. (%) No. (%) No. (%) GR01 109 9 8% 51 47% 10 9% 4 4% 0 0% 35 32% GR02 88 13 15% 27 31% 8 9% 5 6% 0 0% 35 40% GR03 89 10 11% 20 22% 23 26% 6 7% 0 0% 30 34% GR04 101* 3* 3%* 82* 81%* 13* 13%* 1* 1%* 0* 0%* 2* 2%* GR05 90 10 11% 66* 73%* 10 11% 0 0% 0 0% 4* 5%* GR06 25 2 8% 6 24% 7 28% 4 16% 1 4% 5 20% GR07 96 12 13% 38 40% 17 18% 7 7% 3 3% 19 20% GR08 70* 5* 7%* 11* 16%* 19* 27%* 28* 40%* 0* 0%* 7* 10%* GR09 128* 3 2% 47 37%* 20 16% 27* 21%* 5 4% 26 20%* GR10 108 7 6% 38 35% 7 6% 20 19% 1 1% 35 32% GR11 66 0 0% 13 20% 31 47% 3 5% 0 0% 19 29% GR12 166 4 2% 81 49% 45 27% 11 7% 0 0% 25 15% GR13 130 20 15% 26 20% 15 12% 2 2% 0 0% 71 55% GR14 158 14 9% 74 47% 2 1% 0 0% 0 0% 68 43% Total 1424 112 8% 580 41% 227 16% 118 8% 10 1% 381 27%

Table 6.1: Ecological status of natural surface water bodies. Source: WISE; *corrections/additions provided by EL in late 2014



RBD Total High Good Moderate Poor Bad Unknown No. (%) No. (%) No. (%) No. (%) No. (%) No. (%) GR01 19 0 0% 1 5% 3 16% 3 16% 0 0% 12 63% GR02 9 0 0% 0 0% 2 22% 0 0% 0 0% 7 78% GR03 11 0 0% 0 0% 4 36% 0 0% 0 0% 7 64% GR04 19* 0* 0%* 7* 37%* 2* 11%* 0* 0%* 0* 0%* 10* 52%* GR05 16 0 0% 3 19% 4 25% 1 6% 0 0% 8 50% GR06 4 0 0% 0 0% 1 25% 2 50% 0 0% 1 25% GR07 8 0 0% 0 0% 4 50% 2 25% 2 25% 0 0% GR08 12* 0* 0%* 2* 17%* 2* 17%* 3* 25%* 0* 0%* 5* 41%* GR09 40* 0 0% 0 0% 1 2% 13* 33%* 3 7% 23 52% GR10 16 0 0% 0 0% 1 6% 4 25% 0 0% 11 69% GR11 32 0 0% 0 0% 12 38% 12 38% 0 0% 8 25% GR12 45 0 0% 1 2% 19 42% 18 40% 0 0% 7 16% GR13 18 0 0% 2 11% 2 11% 0 0% 0 0% 14 78% GR14 12 0 0% 0 0% 1 8% 0 0% 0 0% 11 92% Total 261 0 0% 16 6% 58 22% 58 22% 5 2% 124 48% Table 6.2: Ecological potential of artificial and heavily modified water bodies. Source: WISE; *corrections/additions provided by EL in late 2014 The chemical status of natural surface water bodies presented in the RBMPs shows that 23% are good status, 6% in poor status, while 71% remain unknown. GR04 presents the lowest percentage of water bodies with unknown status (yet it reached 29%) while GR13/14 the highest (99%). Variations are observed across the RBDs (see Table 6.3): among the classified surface water bodies GR04 has the highest percentage of water bodies in good status (71% of its surface water bodies). With regard to the chemical status of artificial and heavily modified water bodies (see Table 6.4), 11% across the RBDs are in good status, 24% in poor, and 65% in unknown status. It should be taken into consideration that in these classifications not all relevant quality elements have necessarily been evaluated or considered (refer to section 9), and that the available data were limited in many cases.



RBD Total Good Poor Unknown No. % No. % No. % GR01 109 10 9% 5 5% 94 86% GR02 88 5 6% 3 3% 80 91% GR03 89 6 7% 18 20% 65 73% GR04 101* 72* 71%* 0* 0%* 29* 29%* GR05 90 54 60% 0 0% 36 40% GR06 25 6 24% 0 0% 19 76% GR07 96 34 35% 2 2% 60 63% GR08 70* 25* 36%* 5* 7%* 40* 57%* GR09 128* 50* 39%* 9 7% 69* 54%* GR10 108 43 40% 12 11% 53 49% GR11 66 8 12% 9 14% 49 74% GR12 166 4 2% 22 13% 140 84% GR13 134 3 2% 0 0% 131 98% GR14 158 2 1% 0 0% 156 99% Total 1428 322 23% 85 6% 1021 71% Table 6.3: Chemical status of natural surface water bodies. Source: WISE *corrections/additions provided by EL in late 2014 RBD Total Good Poor Unknown No. % No. % No. % GR01 19 5 26% 2 11% 12 63% GR02 9 1 11% 0 0% 8 89% GR03 11 0 0% 4 36% 7 64% GR04 19* 9* 47%* 4* 21%* 6* 32%* GR05 16 8 50% 1 6% 7 44% GR06 4 1 25% 0 0% 3 75% GR07 8 1 13% 1 13% 6 75% GR08 12* 3* 25%* 2* 17%* 7* 58%* GR09 40* 0* 0%* 12 30%* 28* 70% GR10 16 0 0% 4 25% 12 75% GR11 32 2 6% 12 38% 18 56% GR12 45 0 0% 20 44% 25 56% GR13 18 0 0% 0 0% 18 100% GR14 12 0 0% 0 0% 12 100% Total 261 30 11% 62 24% 169 65% Table 6.4: Chemical status of artificial and heavily modified surface water bodies. Source: WISE, *corrections/additions provided by EL in late 2014 The chemical status of groundwater bodies presented in the RBMPs shows that 83 % are in good status, 17% in poor, while none remain unknown. Variations are observed across the RBDs (see Table 6.5): GR05 has the highest percentage of water bodies in good status (96.2% of its groundwater bodies), while GR06 has the highest percentage of water bodies in poor status (45.8% of its groundwater bodies). With regard to the quantitative status of the groundwater bodies, 82 % are in good status, 18% in poor, while none remain unknown. Variations are observed across the RBDs (see Table 6.6): GR12 has the highest percentage of water bodies in good status (100% of its groundwater bodies), while GR06 has the highest percentage of water bodies in poor status (37.5% of its groundwater bodies). It should be taken into consideration that in these classifications the available data were limited in many cases. RBD Good Poor Unknown No. % No. % No. % GR01 24 92.3% 2 7.7% 0 0% GR02 22 84.6% 4 15.4% 0 0% GR03 17* 63%* 10* 37%* 0 0% GR04 24* 96%* 1* 4%* 0** 0% GR05 25 96.2% 1 3.8% 0 0% GR06 13 54.2% 11 45.8% 0 0% GR07 40 87% 6 13% 0 0% GR08 28* 87,5%* 4* 12,5%* 0* 0%* GR09 58 93.5% 4 6.5% 0 0% GR10 31 79.5% 8 20.5% 0 0% GR11 14 93.3% 1 6.7% 0 0% GR12 14 77.8% 4 22.2% 0 0% GR13 82 90.1 9 9.9 0 0 GR14 81 71.7 32 28.3 0 0 Total 473 83% 97 17% 0

Table 6.5: Chemical status of groundwater bodies. Source: WISE *corrections/additions provided by EL in late 2014 RBD Good Poor Unknown No. % No. % No. % GR01 24 92.3% 2 7.7% 0 0% GR02 24 92.3% 2 7.7% 0 0% GR03 22 81.5% 5 18.5% 0 0% GR04 23* 92%* 2* 8%* 0* 0%* GR05 25 96.2% 1 3.8% 0 0% GR06 15 62.5% 9 37.5% 0 0% GR07 41 89.1% 5 10.9% 0 0% GR08 22* 68.8%* 10* 31.2%* 0* 0%* GR09 48 77.4% 14 22.6% 0 0% GR10 28 71.8% 11 28.2% 0 0% GR11 14 93.3% 1 6.7% 0 0% GR12 18 100% 0 0 0 0% GR13 81 89 10 11 0 0 GR14 80 70.8 33 29.2 0 0 Total 465 82% 105 18% 0 0 Table 6.6: Quantitative status of groundwater bodies. Source: WISE *corrections/additions provided by EL in late 2014 A total of 333 surface water bodies (i.e. 19.2%) are expected to achieve good or better global status by 2015. The most significant increase is observed in GR03 (25% increase between 2009 and 2015). 25% of the surface water bodies are applying exemptions according to Article 4.4. No exemptions according to Art. 4.5 are applied, based on the information provided by EL in late 2014. RBD Total Global status (ecological and chemical) Good Global status 2021 Good Global status 2027 Global exemptions 2009 (% of all SWBs) Good or better 2009 Good or better 2015 Increase 2009 -2015 Art 4.4 Art 4.5 Art 4.6 Art 4.7 No. % No. % % No. % No. % % % % % GR01 128 4 3.1 20 15.6 12.5 128 100 128 100 4* 0 0* 0* GR02 97 2 2.1 5 5.2 3.1 95 98 96 99 4* 0 0* 0* GR03 100 2 2 27 27 25 100 100 100 100 33* 0 0* 0* GR04 120* 71* 59* 71* 59* 0* 88* 73* 116* 97* 15* 0* 0* 4* GR05 106 52 49.1 52 49.1 0 67* 63* 105* 99* 14* 0* 0* 0.9* GR06 29 2 6.9 3 10.3 3.4 10* 34* 17* 58* 48 0 GR07 104 27 26 27 26 0 48* 46* 62* 59* 33 0 GR08 82* 5* 6* 5* 6* 0* 56* 68* 80* 98* 62* 0* 0* 2* GR09 168 45 26.8 50 29.8 3 14 0 2* GR10 124 36 29 58* 47* 18* 10 0 GR11 98 5 5.1 8* 8.2* 0 - - 52* 0 1 GR12 211 4 1.9 4 1.9 0 - - 40* 0 4.3* GR13 152 -1 -0.7 -1 -0.7 0 -13 -0 0 3.3 GR14 170 -2 -1.2 -2 -1.2 -0 -1.8 -0 0 0.6 Total 13671689 255258 19%15.3 330333 24%19.7 5%4.4 Table 6.7: Surface water bodies: overview of status in 2009 and expected status in 2015, 2021and 2027; Waterbodies with good status in 2009 fall into the following category: 1. Ecological status is high or good and the chemical status is good, exemptions are not considered Waterbodies expected to achieve good status in 2015 fall into the following categories: 1. Ecological status is high or good and the chemical status is good, exemptions are not considered 2. Chemical status is good, and the ecological status is moderate or below but no ecological exemptions 3. Ecological status is high or good, and the chemical status is failing to achieve good but there are no chemical exemptions 4. Ecological status is moderate or below, and chemical status is failing to achieve good but there are no ecological nor chemical exemptions

Note: Waterbodies with unknown/unclassified/Not applicable in either ecological or chemical status are not considered Source: WISE, corrections provided by EL in late 2014. For this and the following tables of this chapter, there are some discrepancies between this information and the RBMPs/their Annexes. *corrections/additions provided by EL in late 2014



RBD Total Ecological status Good ecological status 2021 Good ecological status 2027 Ecological exemptions (% of all SWBs) Good or better 2009 Good or better 2015 Increase 2009 -2015 Art 4.4 Art 4.5 Art 4.6 Art 4.7 No. % No. % % No. % No. % % % % % GR01 109 60 55% 74 68% 13% 109* 100%* 109* 100%* 0%* 0%* 0%* 0%* GR02 88 40 45% 53 60% 15% 88* 100%* 88* 100%* 2%* 0%* 0%* 0%* GR03 89 30 34% 59 66% 32% 89* 100%* 89* 100%* 17%* 0%* 0%* 0% * GR04 101* 85* 84%* 85* 84%* 0%* 92* 91%* 96* 95%* 7%* 5% * GR05 90 76* 84%* 76* 84%* 0% 86* 96%* 89* 99%* 11% 1%* GR06 25 8 32% 8 32% 0% 48% GR07 96 50 52% 50* 52%* 0%* 28%* GR08 70* 16* 23%* 16* 23%* 0%* 61* 87%* 69* 99%* 64%* 1%* GR09 128* 50 39%* 92* 72%* 33%* 6%* 2% GR10 108 45 42% 65* 60%* 18%* 10% 0.02%* GR11 66 13 20% 19* 29%* 9%* 41%* 2% GR12 166 85 51% 90* 54%* 3%* 27%* 4%* GR13 -134 -46 -34.3% -45 -33.6% --0.7% 13% -3.3% GR14 -158 -88 -56% -88 -56% -0 -1.8% -0.6% Total 11361428 558692 49%48% 687820 60%57% 11%9% Table 6.8: Natural surface water bodies: ecological status in 2009 and expected status in 2015, 2021 and 2027 Source: WISE *corrections/additions provided by EL in late 2014



RBD Total Chemical status Good chemical status 2021 Good chemical status 2027 Chemical exemptions (% of all SWBs) Good or better 2009 Good or better 2015 Increase 2009 -2015 Art 4.4 Art 4.5 Art 4.6 Art 4.7 No. % No. % % No. % No. % % % % % GR01 109 10 9% 15 14% 5% 109* 100%* 109* 100%* 0%* 0%* 0%* 0%* GR02 88 5 6% 8 9% 3% 88* 100%* 88* 100%* 2%* 0%* 0%* 0%* GR03 89 6 7% 24 27% 20% 89* 100%* 89* 100%* 17%* 0%* 0%* 0% * GR04 101* 72* 71%* 72* 71%* 0%* 79* 78%* 97* 96%* 5%* 4% * GR05 90 54 60% 54 60% 0% 54* 60%* 89* 99% * 0%* 1%* GR06 25 6 24% 6 24% 0% GR07 96 34 35% 34 35% 0% 2% GR08 70* 25* 36%* 25* 36%* 0%* 30* 43%* 68* 97%* 7%* 3% * GR09 128* 50* 40% 51* 40% 0% 5%* GR10 108 43 40% 48 44% 4% 9%* GR11 66 8 12% 8 12% 0% 14% GR12 166 4 2% 4 2% 0% 13% GR13 -134 -3 -2% -3 -2% -0% -0 0 0 0 GR14 -158 -2 -1% -2 -1% -0% -0 0 0 0 Total 11361428 317322 28%23% 349354 31%25% 3%2% Table 6.9: Natural surface water bodies: chemical status in 2009 and expected status in 2015, 2012 and 2027 Source: WISE *corrections/additions provided by EL in late 2014



RBD Total GW chemical status Good chemical status 2021 Good chemical status 2027 GW chemical exemptions (% of all GWBs) Good or better 2009 Good or better 2015 Increase 2009 -2015 Art 4.4 Art 4.5 Art 4.6 Art 4.7 No. % No. % % No. % No. % % % % % GR01 26 24 92.3 24 92.3 0 24* 92.3* 26 100% 7.7%* 0%* GR02 26 22 84.6 22 84.6 0 22* 84.6* 26 100% 15.4%* 0%* GR03 27 17* 63* 17* 63* 0 17* 63* 27 100% 37%* 0%* GR04 25* 24* 96* 24* 96* 0* 24* 96* 4%* 0%* 0%* 0%* GR05 26 25 96.2 26 100 3.8 25 96 4% 0% 0%* 0%* GR06 24 13 54.2 13 54.2 0 24 100% 46% 0% GR07 46 40 87 40 87 0 46 100% 13% 0% GR08 32* 28* 87.5* 28* 87.5* 0* 28* 87.5* 28* 87.5* 12.5* - 0%* 0% * GR09 62 58 93.5 58 93.5 0 6% 0% GR10 39 31 79.5 31 79.5 0 18% 0% 3% GR11 15 14 93.3 14 93.3 0 14 93 15 100 7% 0% GR12 18 14 77.8 14 77.8 0 14 78 17 94 28% 0% GR13 -91 -82 -90 -82 -90 - -10% -0 GR14 -113 -81 -72 -81 -72 - -28% -0 Total 366570 310473 85%83% 311474 85%83% 0.3%0.2% Table 6.10: Groundwater bodies: chemical status in 2009 and expected status in 2015, 2012 and 2027 Source: WISE *corrections/additions provided by EL in late 2014





RBD Total Groundwater quantitative status Good quantitative status 2021 Good quantitative status 2027 GW quantitative exemptions (% of all GWBs) Good or better 2009 Good or better 2015 Increase 2009 -2015 Art 4.4 Art 4.5 Art 4.6 Art 4.7 No. % No. % % No. % No. % % % % % GR01 26 24 92.3 24 92.3 0 24* 92.3* 26 100% 7.7%* 0% GR02 26 24 92.3 24 92.3 0 24* 92.3* 26 100% 11.5%* 0%* GR03 27 22 81.5 22 81.5 0 22* 81.5* 27 100% 33.3%* 0% GR04 25* 23* 92* 23* 92* 0* 25* 100%* 8%* 0%* 0%* 0%* GR05 26 25 96.2 25 96.2 0 25 26* 100%* 4% 0% 0%* 0%* GR06 24 15 62.5 15 62.5 0 19* 79* 24 100% 38% 0% GR07 46 41 89.1 41 89.1 0 46 100% 11% 0% GR08 32* 22* 68.87* 22* 68.87* 0* 32* 100%* 31%* 0%* 0%* 0%* GR09 62 48 77.4 48 77.4 0 23% 0% GR10 39 28 71.8 28 71.8 0 28% 0% 5% GR11 15 14 93.3 14 93.3 0 14 93 15 100 7% 0% GR12 18 18 100 18 100 0 0% 0% GR13 -91 -81 -89 -81 -89 -0 - - - - -11% -0 GR14 -113 -80 -71 -80 -71 -0 - - - - -29% -0 Total 366570 304465 83.182 304465 83.182 0 Table 6.11: Groundwater bodies: quantitative status in 2009 and expected status in 2015, 2012 and 2027 Source: WISE *corrections/additions provided by EL in late 2014



RBD Total HMWB and AWB Ecological potential Good ecological potential 2021 Good ecological potential 2027 Ecological exemptions (% of all HMWB/AWB) Good or better 2009 Good or better 2015 Increase 2009 -2015 Art 4.4 Art 4.5 Art 4.6 Art 4.7 No. % No. % % No. % No. % % % % % GR01 19 1 5% 7 37% 32% 19* 100%* 19* 100%* 16%* 0%* 0% * 0% * GR02 9 0 0% 2 22% 22% 7* 78%* 8* 89%* 22%* 0%* 0% * 0% * GR03 11 0 0% 4 36% 36% 11* 100%* 11* 100%* 55%* 0%* 0% * 0% * GR04 19* 7* 37%* 7* 37%* 0%* 9* 47%* 19* 100%* 10%* - - GR05 16 3 19% 3 19% 0% 8* 50%* 16* 100%* 31%* GR06 4 0 0% 1 25% 25% 50% GR07 8 0 0% 0 0% 0% 100% GR08 12* 2* 17%* 2* 17%* 0%* 7* 58%* 12* 100* 42%* - - GR09 40* 0* 0%* 5* 12%* 12%* 30%* GR10 16 0 0% 0 0% 0% 31%* GR11 32 0 0% 0 0% 0% 75% GR12 45 1 2% 1 2% 0% 80% 2% GR13 -18 -2 -11% -1 -5.6% --5.6% - - - GR14 -12 -0 -0 -0 -0 -0 - - - Total 231261 1416 6% 3233 14%13% 8%7% Table 6.12: Heavily modified and artificial water bodies: ecological potential in 2009 and expected ecological potential in 2015, 2021 and 2027 Source: WISE *corrections/additions provided by EL in late 2014



RBD Total HMWB and AWB Chemical status Good chemical status 2021 Good chemical status 2027 Chemical exemptions (% of all HMWB/AWB) Good or better 2009 Good or better 2015 Increase 2009 -2015 Art 4.4 Art 4.5 Art 4.6 Art 4.7 No. % No. % % No. % No. % % % % % GR01 19 5 26% 7 37% 11% 19* 100%* 19* 100%* 16%* 0%* 0%* 0%* GR02 9 1 11% 1 11% 0% 7* 78%* 8* 89%* 22%* 0%* 0%* 0%* GR03 11 0% 4 36% 36% 11* 100%* 11* 100%* 55%* 0%* 0%* 0%* GR04 19* 9* 47%* 9* 47%* 0%* 21%* 0%* 0%* 0%* GR05 16 8 50% 8 50% 0% 6% 0%* 0%* 0%* GR06 4 1 25% 1 25% 0% GR07 8 1 13% 1 13% 0% 13% GR08 12* 3* 25%* 3* 25%* 0%* 17%* 0%* 0%* 0%* GR09 40* 0* 0%* 1* 3%* 3%* 27%* GR10 16 0% 0 0% 0% 25% GR11 32 2 6% 2 6% 0% 38% GR12 45 0% 0 0% 0% 44% GR13 -18 -0 -0 -0 -0 -0 -0 0 0 0 GR14 12 -0 -0 -0 -0 -0 0 0 0 0 Total 261 30 11% 37 14% 3% Table 6.13: Heavily modified and artificial water bodies: chemical status in 2009 and expected status in 2015, 2021 and 2027 Source: WISE *corrections/additions provided by EL in late 2014 Figure 6.1: Map of ecological status of natural surface water bodies 2009 Figure 6.2: Map of ecological status of natural surface water bodies 2015 Good or better Less than good Unknown River Basin Districts Countries outside EU

Source: WISE, Eurostat and corrections/additions provided by EL in late 2014 Figure 6.3: Map of ecological potential of artificial and heavily modified water bodies 2009 Figure 6.4: Map of ecological potential of artificial and heavily modified water bodies 2015 Good or better Less than good Unknown River Basin Districts Countries outside EU Source: WISE, Eurostat and corrections/additions provided by EL in late 2014



Figure 6.5: Map of chemical status of natural surface water bodies 2009 Figure 6.6: Map of chemical status of natural surface water bodies 2015 Good Failing to achieve good Unknown River Basin Districts Countries outside EU Note: Standard colours based on WFD Annex V, Article 1.4.3. Source: WISE, Eurostat and corrections/additions provided by EL in late 2014 Figure 6.7: Map of chemical status of artificial and heavily modified water bodies 2009

Figure 6.8: Map of chemical status of artificial and heavily modified water bodies 2015 Good Failing to achieve good Unknown River Basin Districts Countries outside EU Note: Standard colours based on WFD Annex V, Article 1.4.3. Source: WISE, Eurostat (country borders) and corrections/additions provided by EL in late 2014 Figure 6.9: Map of chemical status of groundwater bodies 2009 Figure 6.10: Map of chemical status of groundwater bodies 2015 Good Poor Unknown River Basin Districts Countries outside EU Note: Standard colours based on WFD Annex V, Article 2.4.5. Source: WISE, Eurostat (country borders) and corrections/additions provided by EL in late 2014 Figure 6.11: Map of quantitative status of groundwater bodies 2009 Figure 6.12: Map of quantitative status of groundwater bodies 2015 Good Poor Unknown River Basin Districts Countries outside EU Note: Standard colours based on WFD Annex V, Article 2.2.4. Source: WISE, Eurostat (country borders) and corrections/additions provided by EL in late 2014





Assessment of ecological status of surface waters It seems that the different projects commissioned for the development of the different RBMPs were centrally coordinated by the Special Secretarial for Water; thus, generally a national approach is followed. At the same time, for GR01/02/03 the actual classification was done (partly) based on a specific sampling study. For the different RBMPs the information is provided in a very different way, so it remains unclear if a national approach is transparently used for all RBDs (it is also unclear due to the lack of national published guidance on different issues, although EL has stated that internal guidelines have been provided to the different consultants). Out of the 14 RBMPs that should have been approved by 2009, 12 RBMPs were approved by late 2014 and 2 RBMPs by late 2015. The 12 RBMPs (that become official in 2014) should implement the Programmes of Measures in the following very short period as the second round of revised Plans should be submitted by 2015, according to the WFD, taking into account the implementation of the first RBMPs, while this is even more challenging (even not feasible) for the other 2. A PoM-Implementation Progress Report (national level) has been submitted by EL to the Commission as a reply to an EU enquiry in December 2014, and was uploaded on WISE on 22.01.2015. Ecological status assessment methods The assessment methods for the classification of ecological status are only partly developed for some BQEs and are explicitly described in the Annexes A/6, Annex I (Reference conditions of SWBs) and in the RBMPs For rivers only the benthic fauna was used; it is stated that "in agreement with the managing authority, for the classification of rivers in the current RBMPs cycle it was decided to rely only on the biological quality element (BQE) of benthic macroinvertebrates”. Accordingly, phytoplankton is the only BQE that is able to produce reliable assessment methods of the ecological status in lakes. For most of the BQEs specified in the WFD, national methods for assessing ecological status have not been developed. This is due to the insufficiency of available data to describe reference conditions, due to the lack of development of indicators for the parameters estimation for each BQE, or due to inadequate experience and knowledge on the biology of specific BQEs to link the status of the habitats with the condition of the water bodies. There are therefore important gaps in the assessment system. The overall approach of classification according to the WFD is described, and was principally based on the One-Out-All-Out principle. It is clearly mentioned that “for water bodies where there are measurements of priority substances, the One-Out-All-Out principle was followed among the qualitative data, regardless of the number of parameters for which data have been available; that is, if a priority substance exceeded the boundaries set, the water body was classified in a lower than good status”. Similarly, in cases where, based on the available data, the BQEs resulted a good status but physicochemical parameters failed, the ecological status has been classified as moderate. In cases where correlation in the monitoring data was not evident, at the time and the position of the sampling for physicochemical parameters, and the BQEs exhibited discrepancies, the physicochemical data were not used for the classification of the water bodies (mainly in the RBDs GR06/GR07/GR13/GR14). At the same time, and based on the way the classification was done, it is not possible to say if this principle was followed in practice. It is highly questionable whether the classification system is responsive to all pressures as relevant information is insufficient. In some RBMPs there is a brief mention of the different pressures addressed by the classification system (e.g. the phytoplankton increases eutrophication in a lake system), but not sufficient information on which BQEs are detecting which pressures. For GR09 the same applies for the information from the Prespa plan as well. In the case of GR11/12, it is explicitly mentioned that at this stage the system is not using calibrated measurements of the BQE to determine whether there is a correlation between the abstraction levels from rivers and their ecological status assessed by the measurements of the BQE. In the case of river water bodies for which no data are available from monitoring programmes, a process of grouping of the water bodies was followed for GR04/05/08/09/10/13/14 in relation to the different pressures. The main idea of grouping is that water bodies of the same type which are subject to similar levels of anthropogenic pressures are likely to have the same ecological quality. The purpose was to minimise the number of water bodies that would be characterised as of unknown ecological status. As this approach is indirect, this type of assessment has a low level of confidence. In general, it is mentioned that the classification of water bodies in terms of physico-chemical QEs was supplementary to the assessment of the BQEs (respecting the One-Out-All-Out (OOAO) principle); that is these QEs are used to assist in determining the ecological status of surface water bodies. The elements that are assessed include the transparency, thermal conditions, oxygen conditions, salinity, acidification conditions and nutrient conditions. For the RBMPs of GR01/02/03, regarding the classification, there was very limited monitoring information available. One specification regarding the way the physico-chemical QEs were dealt with in practice is the sampling study used for some water bodies. The study collected samples and measurements concerning the biodiversity and carrying capacity of rivers such as for macroinvertebrates. In this case, the physico-chemical parameters were determined in situ with a portable multi-parameter instrument. For the RBMPs of GR06/07/GR13/GR14 it is clearly stated that physico-chemcial QEs were not used for the classification of the ecological status for surface water bodies. For the RBMPs of GR04/05/08/09/10/11/12, the assessment is conducted through measured data (limited years) of the General Chemical State Laboratory, the Ministry of Rural Development and Food, Universities, and the Decentralised Administrations, Water Directorates. These are then compared to the relevant environmental quality standards (EQS) for each water body category. When the value of the parameters complies with standards, the water body is classified as in good status; in the opposite case the water body is classified as in a less than good status. The values refer to the boundary between good and moderate status, which according to the general classification scheme, determines the possibility of relegation measured by the BQEs of ecological status of a water body from good to moderate. Theoretically, EQSs have been established. The relevant Ministerial Decision (51354/2641/Ε103/2010) establishes Environmental Quality Standards for 101 chemical compounds or groups of compounds, of which 41 are priority substances and other pollutants, which have been agreed within the European Union (Directive 2008/105/EC) and 60 relating to specific pollutants, which either have been detected in water bodies of the country or identified in previous legislation. Note that the priority substances characterise the chemical status of water, as defined in the WFD and the specific pollutants are used to assist in determining ecological status. In the Annexes it is mentioned that “the specific pollutants are supporting parameters which are also considered for the classification of ecological status; the classification of a water body is not good if a specific pollutant does not meet the specified environmental quality standards”. Consequently, it seems that all pollutants referred to in the WFD-Annexes VIII and X are covered by the Ministerial Decision. No reference is provided on how the EQSs were established. Additionally, it is noted that only very limited monitoring information is available regarding these pollutants in the RBDs. The overall approach of classification according to the WFD is described, including the One-Out-All-Out principle. It is implied on several occasions that the total ecological status of the water system is determined by the results of the biological, physico-chemical and hydromorphological quality elements taking into account the worst category (i.e. the part of the quality most affected by human activity); that is the One-Out-All-Out principle. The hydromorphological data were taken into account only to rank the “high” status. At the same time, and based on the way the classification was done, it is not possible to say if this principle was followed in practice. Based on the very limited information available for the classification of the surface water bodies and the common use of expert judgement, etc., the uncertainty is classified in three categories as follows: §Large Uncertainty: concerns water bodies in which there was no monitoring station; §Medium Uncertainty : where there is one monitoring station (either from the sampling study, or from the existing monitoring network); §Small Uncertainty: where there is more than one monitoring station. If in a water body several monitoring results exist and the assessments do not agree, then the uncertainty is characterised as medium. §Not defined uncertainty: where the situation remains unknown. Specifically, in the GR04/05/08/11/12, regardless of the parameter for which the analysis was conducted the level of uncertainty was considered: §Limited Uncertainty for the types with more than 7 samples; §Medium Uncertainty for the types that did not comply with the above condition; §High Uncertainty for the types with less than 4 samples or 4 stations; §Large Uncertainty in cases where no data were available and the determination of the values was done through the expert judgment.

There is no classification in terms of uncertainty for GR13/14. It has to be noted that regarding the main data gaps and uncertainties relating to surface waters there are delays in determining the physico-chemical and hydromorphological standards so it is not possible to set reference conditions and class boundaries between high, good condition, etc. All water body types are covered by a classification system. For most of the BQEs specified in the WFD, national methods for assessing ecological status for the case of Greece have not been developed. This is due to the insufficiency of available data to describe reference conditions, due to the lack of development of indicators for the parameters estimation for each BQE, or due to inadequate experience and knowledge on the biology of specific BQEs to link the status of the habitats with the condition of the water bodies. For GR05/09/10/11/12 the transitional waters are assessed based on the criteria that are used for the coastal waters and for the coastal waters there is only one water body type for the whole country in order to avoid increased fragmentation. This is not the case for GR13/14 as it is clear from the RBMPs that three types of coastal waters (different in each RBD) have been identified as well as with different methodological approaches. The intercalibration work is mentioned only in general. The class boundaries are in almost all cases not used for the actual classification of water bodies due to the lack of data. No data is available to cross-check the intercalibration decision with what is mentioned in the relevant Annexes. The boundaries used for the case of Greece for the respective types (R-M1, R-M2 and RM-4), referred only to the biological quality element of benthic macroinvertebrates; the purpose was to evaluate which is the common Intercalibration Common Metrics index (ICMi), as a national assessment method for the ecological status to be involved in the exercise was not fully developed. Additionally, Greece’s involvement in the intercalibration exercise of the countries of the Mediterranean eco-region was fragmented. As a result any national methods that were developed in the context of individual pilot projects implementing the WFD cannot be matched with the methods developed by other countries. Consequently, there is a lack of commonly accepted values ​​of reference conditions and class boundaries of the ecological status classification including national methods that have been used at times in other Mediterranean countries. The background documents that have been reported as Annexes to the RBMPs are Annexes A/6 (Reference conditions for SWBs) and A/9 (Classification of SWBs) (with the exception of GR14 where these Annexes have not been reported) In terms of a national Guidance Document, guidelines were formulated by the coordinator consultant and the General Secretariat for Water to guide/harmonise the work and methodological approach of all other consultants who were commissioned with the drafting of the RBMPs, but these were not organised into a detailed guidance document. RBD Rivers Lakes Transitional Coastal Phytoplankton Macrophytes Phytobenthos Benthic invertebrates Fish Physico-Chemical Hydromorphological Phytoplankton Macrophytes Phytobenthos Benthic invertebrates Fish Physico-Chemical Hydromorphological Phytoplankton Macroalgae Angiosperms Benthic invertebrates Fish Physico-Chemical Hydromorphological Phytoplankton Macroalgae Angiosperms Benthic invertebrates Physico-Chemical Hydromorphological GR01 GR02 GR03 GR04 GR05 GR06 GR07 GR08 - - - - - - - GR09 GR10 GR11 GR12 GR13 GR14 - - - - - - - Table 7.1.1: Availability of biological assessment methods as reflected in the RBMPs. Some of the methods marked in red may be under development but the information available is unclear. Assessment methods fully developed Assessment methods partially developed or under development Assessment methods not developed for BQEs, no information provided on the assessment methods or unclear information provided - Water category not relevant Source: RBMPs (Annex A/6 Reference Conditions of SWBs). Note: EL provided alternative formulation of this Table, reflecting on-going development of methods). Application of methods and ecological status results The national monitoring network (defined by the Common Ministerial Decree 140384/2011) was not operational by the time of data collection for the purposes of the RBMPs in order to assess the current status of SWR. Thus, the data for the compilation of the RBMPs were collected by the Ministry of Environment, Energy and Climate Change, the Ministry of Rural Development and Food, the Water Directorates of the Regions, etc. as well as