EUROPEAN COMMISSION Brussels, 26.2.2019 SWD(2019) 38 final COMMISSION STAFF WORKING DOCUMENT Second River Basin Management Plans - Member State: Denmark Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC)

Second River Basin Management Plans

First Flood Risk Management Plans

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

Topic 4 Monitoring, assessment and classification of chemical status in surface water bodies 4.1. Assessment of implementation and compliance with WFD requirements in second cycle 4.2. Main changes in implementation and compliance since first cycle 4.3. Progress with Commission recommendations Topic 5 Monitoring, assessment and classification of quantitative status of groundwater bodies 5.1. Assessment of implementation and compliance with the WFD requirements in the second cycle 5.2. Main changes in implementation and compliance since the first cycle 5.3. Progress with Commission recommendations Topic 6 Monitoring, assessment and classification of chemical status of groundwater bodies 6.1. Assessment of implementation and compliance with the WFD requirements in the second cycle 6.2. Main changes in implementation and compliance since the first cycle 6.3. Progress with Commission recommendations Topic7 Designation of Heavily Modified and Artificial Water Bodies and definition of Good ecological potential 7.1. Assessment of implementation and compliance with the WFD requirements in the second cycle for designation 7.2. Main changes in implementation and compliance since the first cycle 7.3. Progress with Commission recommendations Topic 8 Environmental objectives and exemptions 8.1. Assessment of implementation and compliance with WFD requirements in second cycle 8.2. Main changes in implementation and compliance since first cycle 8.3. Progress with Commission recommendations

Topic 9 Programme of measures 9.1. Assessment of implementation and compliance with WFD requirements in second cycle 9.2. Main changes in implementation and compliance since first cycle 9.3. Progress with Commission recommendations Topic 10 Measures related to abstractions and water scarcity 10.1. Assessment of implementation and compliance with the WFD requirements in the second cycle and main changes in implementation and compliance since the first cycle 10.2. Progress with Commission recommendations Topic 11 Measures related to pollution from agriculture 11.1. Assessment of implementation and compliance with the WFD requirements in the second cycle and main changes in implementation and compliance since the first cycle 11.2. Main changes in implementation and compliance since first cycle 11.3. Progress with Commission recommendations Topic 12 Measures related to pollution from sectors other than agriculture 12.1. Assessment of implementation and compliance with WFD requirements in second cycle 12.2. Main changes in implementation and compliance since first cycle 12.3. Progress with Commission recommendations Topic 13 Measures related to hydromorphology 13.1. Assessment of implementation and compliance with WFD requirements in second cycle 13.2. Main changes in implementation and compliance since first cycle 13.3. Progress with Commission recommendations Topic 14 Economic analysis and water pricing policies

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



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





General Information The Danish population is 5.6 million (the exact number on 1 January 2012 was 5 560 628) . Denmark has a total area of 43 321 km2. Denmark’s RBDs are shown in Map A. Map A Map of RBDs Source: WISE, Eurostat (country borders) International RBDs (within European Union) International RBDs (outside European Union) National RBDs (within European Union) Countries (outside European Union) Coastal Waters Denmark has one international RBD (Vidå-Kruså) shared with Germany. The international RBD shared with Germany is not jointly designated. There is more than one transboundary river basin in the RBDs. The areas of the national RBDs including sharing countries is provided in Table A and Denmark’s share of the international RBD is shown in Table B. Table A Overview of Denmark’s RBDs RBD Name Size (km2) (Area including coastal waters shown in brackets) Countries sharing RBD DK1 Jutland and Funen 32 040 (44 898) - DK2 Zealand 9 280 (16 364) - DK3 Bornholm 602 (825) - DK4 International (Vidå-Kruså) 1 100 (1 305) DE Source: RBMPs reported to WISE Table B Transboundary RBDs by category and % share in Denmark Name international RBD National RBD Countries sharing borders Co-ordination category 3 km² % Krusaa/Krusau DK4 DE 15 71.4 Vidaa/Wiedau (Rudboel Soe/Ruttebüller See) DK4 DE 1081 80.5 Source: WISE electronic reports Category 1: International agreement, permanent co-operation body and international RBMP in place. Category 2: International agreement and permanent co-operation body in place. Category 3: International agreement in place. Category 4: No co-operation formalised.



Status of second river basin management plan reporting A total of four RBMPs of Denmark (Jutland and Funen, Zealand, Bornholm, International Vidå-Kruså) were published on 27 June 2016. Documents are available from the European Environment Agency (EEA) EIONET Central Data Repository https://cdr.eionet.europa.eu/ .

Key strengths, improvements and weaknesses of the second River Basin Management Plan(s) The main strengths and shortcomings of the second RBMP of Denmark are as follows: ·Governance and public consultation ·A broad range of stakeholder groups were actively involved in the preparation of Denmark’s RBMPs, including via advisory groups. ·Denmark and Germany have agreed to strengthen coordination in the iRBD. ·Denmark did not adopt and publish the RBMPs in accordance with the timetable in the Water Framework Directive. ·Characterisation of the RBD ·Significant changes in the delineation of small water bodies and heavily modified and artificial water bodies may lead to issues with the comparability of pressures and status between cycles. ·Several of the national types for Denmark in all of the RBDs do not appear to have corresponding intercalibration types. ·Type specific reference conditions have been established for some of the relevant biological quality elements in most water body types, and for all relevant biological quality elements in the others. Type specific reference conditions have not been established for physicochemical quality elements or hydromorphological quality elements. ·There have been some improvements in the assessment of significant pressures since the first RBMPs, with the development of new models. For both surface and groundwater, the significance of pressures was reported to be defined in terms of thresholds and linked to the potential failure of objectives. ·For the second RBMPs, there is no data reported on which significant pressures were not assessed for surface waters or groundwater. “Anthropogenic pressure - Unknown” was identified for 25 % of groundwater bodies, which may indicate some inadequacies in the methodologies used to assess pressures and impacts. Some of the tools for assessing certain pressures could be improved (e.g. hydromorphological pressures and quantitative pressures on groundwater). ·Denmark reported inventories for all RBDs, each one including 19 of the 41 Priority Substances. According to the RBMPs, the substances not included in the inventories are not used in Denmark or screening has shown that they do not occur in significant quantities. The CIS Guidance Document recommends providing basic estimation of emissions, including for these substances of minor importance, which has not been done. Tier 1 (point source information) was implemented for substances not relevant at RBD level, and Tier 2 (riverine load) was used for other substances, while the Guidance Document recommends using at least Tier 1+2 for the relevant substances. The data quality was not reported. ·Monitoring, assessment and classification of ecological status ·The number of monitoring sites increased significantly since the first RBMPs, mostly due to a large increase in the number of operational monitoring sites in rivers. ·There are gaps in the monitored biological quality elements: phytobenthos are not monitored in rivers and benthic invertebrates are not monitored in lakes. None of the water bodies included in surveillance monitoring were monitored for all the required biological, hydromorphological and physicochemical quality elements.

·15 River Basin Specific Pollutants were monitored in all relevant water categories (three in coastal waters, three in lakes and 13 in rivers), but the percentage of water bodies monitored is low. Monitoring in coastal waters was in biota only, while in surface freshwaters it was done in the water column and biota. River Basin Specific Pollutants were monitored at the minimum recommended frequency at some sites for surveillance monitoring but at no sites for operational monitoring. ·New assessment methods have been developed since the first RBMPs for macrophytes and fish in rivers and lakes. The remaining gaps are phytobenthos in rivers, benthic invertebrates and phytobenthos in lakes, and macroalgae in coastal waters. ·There is no biological quality element method which is sensitive to nutrients in rivers. ·Morphological conditions of rivers were assessed in terms of ecological status/potential and their classification boundaries are related to the class boundaries for the sensitive biological quality elements. ·Hydrological/tidal regime and river continuity were not assessed . No hydromorphological quality elements are used in the classification of status/potential. ·Standards for assessment of general physicochemical elements are reported in supporting documents accompanying the RMBPs, even if they were not reported to WISE. ·Environmental Quality Standards values were reported for water for all 15 River Basin Specific Pollutants: 12 in rivers, three in lakes, as well as two in biota in coastal waters. The standards have been derived in accordance with Technical Guidance n. 27 and the analytical methods used meet the minimum performance criteria laid down in Article 4(1) of the QA/QC Directive (2009/90/EC) for the strictest standard applied. ·River Basin Specific Pollutants are used for the classification of ecological status where they are monitored in surface waters. ·The reported values show an increase in the total number of water bodies in less than good ecological status since the first RBMPs. Denmark’s analyse in the RBMPs states in general minor improvements in ecological status for coastal waters and lakes and no changes for watercourses. Comparison between the two cycles should however be analysed with care, considering changes in delineation of water bodies and in methodologies. ·The number of natural water bodies with unknown ecological status has significantly decreased since the first RBMP, which is an improvement. However, there is still a significant number of water bodies reported with unknown ecological status (20% for lakes, 23 % for rivers ), with the exception of coastal waters, which were always classified for ecological status, while 54% of coastal water bodies had unknown status in the first RBMPs. ·The confidence in classification is high for all coastal water bodies and for the large majority of rivers and lakes where the overall ecological status/potential is classified. There are no water bodies classified with low confidence. This is a major improvement compared to the first RBMPs, in which there was no information on confidence for more than 95 % of the river and lake water bodies. ·The one-out, all-out principle is reported as having been used in all RBDs, but has not included the supporting quality elements (except nutrient in lakes). ·Monitoring, assessment and classification of chemical status in surface water bodies ·Between the two RBMPs, the proportion of unknown, good and failing to achieve good chemical status remained fairly stable, with in particular a very high percentage of unknown (almost 99 % of water bodies). There was a change in the delineation of water bodies, as well as a reported change in the methods for status assessment. ·Chemical status assessment is based on monitoring only, with no use of grouping or expert judgement. Classifications have been assigned medium confidence. ·Priority substances were not monitored in water in coastal and territorial waters in any of the four RBDs, and no monitoring in water was performed in lakes and rivers in the Bornholm and International (Vidå-Kruså) RBDs. In the other two RBDs, only four priority substances are reported to be monitored in water for status assessment in lakes, and 13 in rivers. About 95 % of lake water bodies were not monitored for any priority substances. Less than 3 % river water bodies were monitored for six or more Priority Substances. Monitoring frequencies were in line with the recommended minimum frequencies for surveillance monitoring but not operational monitoring, which Denmark said was justified on the basis of expert judgment and technical knowledge, but no further detail was provided. ·According to WISE, not all discharged substances are monitored. Denmark subsequently clarified that all substances discharged were actually monitored, however it was not clear whether they were monitored in a matrix for which a standard exist, and therefore whether the monitoring could be used for status assessment. ·Denmark mentioned that several priority substances were monitored for example in biota or sediment, but that the corresponding standard was not derived, despite the requirement of the Directive, and there the monitoring cannot be used in the assessment of status. ·Mercury was monitored in biota for status assessment in coastal and surface freshwaters, and hexachlorobenzene in coastal waters only. Denmark highlighted that hexachlorobutadiene was not monitored because it was not discharged. The monitoring frequencies were lower than the recommended minimum frequencies, which according to Denmark was justified on the basis of expert judgment and technical knowledge, but no further detail was provided. ·Trend monitoring was reported in biota for four substances, all of which were monitored in coastal waters, but only one in lakes and rivers. Monitoring for trends was also reported in water. The frequencies were not always in line with the recommended minimum frequency.

·Monitoring, assessment and classification of quantitative status of groundwater bodies ·The number of monitoring sites has increased significantly by 35 % from the first cycle. ·The total number/total area of groundwater bodies failing good status has significantly decreased from the first cycle. ·Groundwater dependent terrestrial ecosystems are not considered in the status assessment. ·Groundwater associated surface waters are considered in the status assessment. ·Monitoring, assessment and classification of chemical status of groundwater bodies ·The coverage of groundwater bodies by monitoring is not complete, neither for surveillance monitoring nor for operational monitoring, but grouping of groundwater bodies has been applied in all river basin districts. Denmark informed that all core substances are being monitored and that only those parameters and substances that were included in the status assessment and calculation of trends have been reported. ·The status situation improved significantly with a decrease of the groundwater body area failing good chemical status from 52.7 % to 19.6 % of the total groundwater body area from the first to the second cycle. ·30% of the groundwater bodies have no clear status and the confidence in status results is low or unknown for more than the half of the groundwater bodies. ·Designation of Heavily Modified and Artificial Water Bodies and definition of Good ecological potential ·A new guidelines document for the designation of heavily modified water bodies has been developed since the first RBMPs. The reduction in the number of designated heavily modified and artificial water bodies is partly due to the new guidelines and partly due to the re-delineation of water bodies. Further changes to the extent of designations may take place until the end of 2019. An information gap is related to the water uses for which water bodies are designated, namely most heavily modified river water bodies are designated due to unknown uses. ·The method for defining Good ecological potential is more clearly explained than in the first cycle. The approach used is the Common Implementation Strategy Guidance approach and not the Prague approach which was reported in the first RBMPs. Furthermore, improvements have been made since the first cycle, mainly related to the inclusion of more quality elements in the assessment. The mitigation measures for two out of four RBDs (Jutland and Funen and Zealand) have been defined, whereas in the first RBMPs, mitigation measures were not defined in any RBD. For the International (Vidå-Kruså) and Bornholm RBD, no mitigation measures have been used for water bodies which have been defined as being at good ecological potential in the districts. For the Bornholm RBD, good ecological potential is not defined. Work to designate heavily modified water bodies and set environmental goals is still on going in all four RBDs, and will continue during 2019, as part of the Food and Agriculture Package (2015). ·Environmental objectives and exemptions ·Environmental objectives for ecological status of surface water bodies have been reported in all RBDs, whereas for some water bodies the date for the achievement of the objectives is unknown. ·Drivers and pressures leading to exemptions were not reported. ·Article 4(4) is used more widely in surface water and groundwater in the second cycle than in the first. ·Article 4(5) was not applied in the first cycle but is now used in the second cycle for surface waters. The information provided is not sufficient to assess whether the application is compliant. ·Programme of Measures ·There is a shortage of meaningful information so it is not possible to judge whether any progress has been made, other than the indication that “some measures have been completed”. ·A clear financial commitment has been secured in all four RBDs for the relevant sectors.

·All except one significant pressure has been covered by operational KTMs in surface water and groundwater in all four RBDs. One significant pressure (Anthropogenic – unknown) is not covered by an operational KTM in one RBD. ·A total of 18 national supplementary measures have been mapped against eight predefined KTMs and one KTM defined by Denmark. No national basic measures have been mapped. ·The information on measures on River Basin Specific Pollutants and Priority Substances is unclear (but seems to be covered under general significant pressures). Denmark has clarified that Priority Substances are covered by the Programmes of Measures, and newly identified Priority Substances will be covered by preliminary Programmes of Measures plan running from 2018-2021. ·The objectives and requirements of the Floods Directive have not been considered in the second RBMP and Programme of Measures. However, there has been some co-ordination between RBMPs and FRMPs in all four RBDs. ·Measures related to abstractions and water scarcity ·A low proportion of groundwater bodies face water quantity-related problems for achieving good quantitative status and water abstraction pressures significantly affect only a few surface water bodies. ·Water abstraction pressures were reported as relevant for Denmark. However, the Water Exploitation Index + is not calculated, but water quantity data have been reported to support the European State of the Environment Report in relation to Water Quantity. ·The RBMPs include a water resource allocation and management plan in all RBDs. Measures on Article 11(3)(c) for efficient and sustainable water use have not been implemented in the previous cycle. ·There is a concession, authorisation and/or permitting regime to control surface and groundwater abstractions and water impoundment; and a register of impoundments exists in all RBDs. ·Measures related to pollution from agriculture ·There is a clear link between agricultural pressures and agricultural measures for surface and groundwater. ·An assessment of the gaps to the achievement of WFD environmental objectives for nutrients has partly been undertaken in all RBDs. In the RBMPs gap analyses are made for coastal waters (nitrogen) and lakes (phosphorus). ·Safeguard zones have been established for abstractions. ·The implementation of basic measures according to Article 11(3)(h) for the control of diffuse pollution from agriculture at source is ensured in all RBDs where the same rules apply across the whole RBD. ·Financing of measures is secured in all RBDs.

·Measures related to pollution from sectors other than agriculture ·Denmark is implementing measures regarding wastewater (small wastewater treatment plants, stormwater overflow and wastewater from scattered settlements) in order to improve water quality in rivers and lakes. ·Measures in relation to Priority Substances and River Basin Specific Pollutants were described only in a broad manner; i.e. not specific to each substance, and it is not clear whether all relevant substances have been identified, nor whether the non-specific measures will be sufficient to achieve the objectives.

·Measures related to hydromorphology ·Overall, the second RBMPs reflect a significant improvement in measures to tackle hydromorphological pressures. It is expected that efforts will improve the condition of up to 3 575km of rivers/streams (which amounts to approximately half of the river kilometres which are not in good status due to poor physical conditions). ·Whilst KTMs relevant to hydromorphological pressures have been mapped against national hydromorphological measures, information is not available in WISE on the links of these KTMs to specific significant pressures. However, Denmark subsequently clarified that information is included in the RBMPs. In addition, there is no information available on the indicator gap to be filled for significant hydromorphological pressures by 2021 or 2027. Nevertheless, based on information from the published RBMPs, it is evident that hydromorphological measures (both supplementary and basic) are planned for the second cycle. ·Ecological flows have been derived only partly and not implemented yet in any RBD. The work to make operational the new methodology on ecological flow is still on going. ·Economic analysis and water pricing policies ·Environmental and resource costs have only partly been included. ·A narrow definition of water services has been used.



·Considerations specific to Protected Areas (identification, monitoring, objectives and measures) ·Protected Areas for all relevant types have been reported. Compared to the first cycle, comparable numbers of Article 7 (groundwater) and shellfish production areas, and many more Birds and Habitats areas were reported in the second cycle. ·Additional objectives have been set for shellfish production areas; some of which have been met, which reflects significant progress since the first cycle. ·The majority of Habitats Directive Protected Areas are also protected under the Birds Directive so monitoring of these areas covers both directives. The extent of the reported monitoring programmes is reduced in the second cycle compared to the first cycle. ·Monitoring programmes for specific Protected Area types have not been reported for all types. Monitoring of Habitats areas does not cover all water categories and the number of monitoring sites is low. ·Adaptation to drought and climate change ·A climate check of the Programme of Measures has been carried out in the second cycle.

Recommendations ·The preparation of the next RBMPs should be carried out in accordance with the WFD timetable, so that the third RBMPs are adopted on time. ·Denmark should continue to improve cooperation in iRBD and ensure transparency regarding coordination of the technical aspects of the WFD such as ensuring a harmonized approach and a coordinated Programme of Measures in order to ensure the timely achievement of the WFD objectives.

·Denmark needs to continue its work on the apportionment of significant pressures among different sectors, in order to further improve the identification of the appropriate mitigation measures. ·Denmark should further strengthen monitoring of surface waters by covering all relevant biological, physico-chemical and hydromorphological quality elements in all water categories. The proportion of water bodies covered by monitoring for River Basin Specific Pollutants should increase. ·Denmark should complete the development of assessment methods for all biological quality elements in all water categories, including methods that are sensitive to nutrients in rivers. Hydromorphological quality elements should be included in the classification of ecological status. ·The use of grouping for the classification of ecological status and the methodology used for grouping needs to be clearly described. ·Denmark should make significant efforts to reduce the number of surface water bodies in unknown chemical status. Monitoring should be performed in the relevant matrix in a way that ensures sufficient spatial coverage and temporal resolution to reach sufficient confidence in the assessment for all water bodies, if necessary in combination with robust grouping/extrapolation methods. If a different matrix is used, the corresponding standards need to be derived to provide at least the same level of protection, and the corresponding explanations should be provided, as required by the Directives. Explanations should also be provided if reduced frequencies are used. All priority substances discharged should be monitored so that monitoring can be used for status assessment. ·Denmark should further improve trend monitoring for all relevant substances, in a way that provides sufficient temporal resolution and spatial coverage. ·Monitoring should improve as well as confidence status to address the number of groundwater bodies with unknown chemical status, and grouping methodologies should be further clarified. ·Groundwater monitoring and methodologies for chemical should all in line with the WFD obligations. Measures to ensure good chemical status of groundwater should be established considering all WFD aspects. Trend reversals should be carried out. ·Denmark should continue progressing on the designation of HMWBs and definition of good ecological potential, and complete the required assessments for all RBDs. ·Meaningful information regarding the timing of the measures should be included in the Programmes of Measures. ·Denmark should provide clear information on the links of KTMs to specific significant pressures. ·All Priority Substances and River Specific Pollutants identified as causing failure should be individually associated with KTMs. ·Denmark should ensure that its Programme of Measures as regards chemical pollutants from non-agricultural sources is based on reliable assessment of the pressures, so that all relevant pollutants are addressed. It should also assess whether the measures proposed will be sufficient to meet the objectives. ·Denmark needs to continue its efforts to ensure that appropriate measures are applied in all water bodies subject to hydromorphological pressures. Even if the ecological flows have been derived, the necessary steps to make it operational in all RBDs need still to be taken. ·Cost recovery should be applied for water services. Any exemption should be justified using Article 9(4). Denmark should also present in a transparent manner how financial, environmental and resource costs have been calculated and how the adequate contribution of the different users is ensured. The water-pricing policy should be set out in a transparent fashion and a clear overview of estimated investments and investment needs should be provided. Denmark needs to establish objectives for its relevant Protected Areas for surface and groundwater.



Topic 1Governance and public participation 1.1Assessment of implementation and compliance with WFD requirements in second cycle 1.1.1Administrative arrangements – RBDs

Denmark has fourRBDs: Jutland and Funen, Zealand, Bornholm and International (Vidå-Kruså). One RBD, International (Vidå-Kruså), is part of an international RBD shared with Germany. 1.1.2Administrative arrangements – competent authorities Denmark has reported one Competent Authority for the second cycle, the Danish Environmental Protection Agency (EPA), responsible for all the main roles for the RBMPs: monitoring and assessment of status of groundwater and surface water, enforcement of regulations, pressure and impact analysis, economic analysis, preparation of the RBMPs and Programme of Measures, public participation, implementation of measures, coordination of implementation and reporting to the European Commission. Denmark subsequently informed that for the second cycle, the Danish Minister for Environment and Food delegated administrative powers to the Danish EPA. For the first RBMPs, the administrative powers of the Competent Authority, at the time the Minister for the Environment, were delegated to, the Danish Nature Agency, which was indicated as the main Competent Authority for the first RBMPs. 1.1.3RBMPs – structure and Strategic Environmental Assessment Denmark did not report any sub-plans for its RBMPs. In the first cycle, Denmark prepared individual sub-plans for the 23 main catchments that make up the four River Basin Districts. Denmark carried out Strategic Environmental Assessments for all 4 RBMPs. 1.1.4Public consultation For all four RBMPs, the public and interested parties were informed by: Internet, invitations to stakeholders, local authorities, media (papers, TV and radio), and meetings. Documents were available for download for the requisite six months. Public consultation was not coordinated at international level (i.e. with Germany) in the International (Vidå-Kruså) RBD. The following stakeholder groups were actively involved in the development of all four RBMPs: agriculture/farmers, fisheries/aquaculture, local/regional authorities, navigation/ports, NGOs/nature protection and water supply and sanitation. The mechanisms for active involvement were the establishment of advisory groups and involvement in drafting. For all four RBMPs, public consultation had the following impacts: addition of new information, adjustment to specific measures, changes to the selection of measures, changes to the methodology used and commitment to further research. 1.1.5Integration with the Floods Directive and the Marine Strategy Framework Directive Denmark carried out a joint consultation of its RBMPs and the Floods Directive Flood Risk Management Plans. Denmark did not carry out joint consultation with the Marine Strategy Framework Directive . 1.1.6International coordination One of Denmark's four RBMPs is part of an international RBMP (Vidå-Kruså), which is shared with Germany. There is an international agreement on water management in place but without a coordination body nor an international RBMP (designated as Category 3 cooperation). According to the RBMP for International (Vidå-Kruså), Denmark and Germany exchanged information on the assessment of border river catchments. Nonetheless, there were some differences in the classification in waters and the two Member States do not fully follow the same surveillance monitoring programme. Denmark and Germany have agreed to coordinate with regard to a number of issues: transboundary river basins, in particular analysis and reviews, monitoring programmes, programmes of measures, river basin management plans, timetables and work programmes, interim overviews of significant water management issues, measures for consulting and informing the public and reporting to the European Commission. Denmark subsequently informed that the Competent Authority on the German side was consulted in parallel with relevant Danish authorities. Further information on international co-operation with respect to measures is provided in Chapter 9 of this report. 1.2Main changes in implementation and compliance since first cycle For the first cycle, Denmark prepared a sub-plan for each of the 23 main catchments that make up the four RBDs. RBD-wide RBMPs were also prepared for the Bornholm RBD and the International (Vidå-Kruså) RBDs. No RBD-wide RBMPs were prepared for the Jutland and Funen RBD or the Zealand RBD.

In the second cycle Denmark reports the preparation of four RBMPs, one for each RBD covering all main catchments within the RBD, and no sub-plans. For the first RBMPs the administrative powers of the Competent Authority, at the time the Danish Minister for the Environment, were delegated to the Danish Nature Agency, which was indicated as the main competent authority (with the Minister of Environment as overall water authority); for the second cycle the administrative powers of the Competent Authority, now the Danish Minister for Environment and Food, were delegated to the Danish Environmental Protection Agency. 1.3Progress with Commission recommendations The Commission recommendations based on the first RBMPs and Programme of Measures requested action on the following: ·Recommendation: Given the late adoption of the sub-district RBMPs, Denmark needs to take special care to ensure that the preparation of the next cycle of RBMPs is carried out in accordance with the WFD timetable, to ensure the second RBMPs are adopted no later than December 2015. Assessment: According to the information reported by Denmark the second RBMPs were published on 27 June 2016 and thus were 6 months late. Consequently, Denmark did not meet the deadline set in the recommendation (nor the timetable set and in the WFD). This recommendation has not been fulfilled.



Topic 2 Characterisation of the River Basin District 2.1.Assessment of implementation and compliance with the WFD requirements in the second cycle 2.1.1.Delineation of water bodies and designation of heavily modified and artificial water bodies Overall there was a significant decrease in the number of river water bodies delineated between the first and second RBMPs of 49 % ( Table 2.1 ). The same was true for coastal water bodies with a decrease of 28 % . Territorial waters were only reported in the second cycle . For lake water bodies, however there was an increase of 23 % overall, with the largest increase in the International (Vidå-Kruså) RBD (83 %). In the second RBMP, 91 % of identified surface water bodies were natural with 5 % being designated as heavily modified and 4 % as artificial water bodies. In the first RBMP, the situation was quite different with 72 % natural, 16 % heavily modified and 11 % artificial ( Figure 2.1 ). Table 2.2 shows the differences in size distribution of surface water bodies in Denmark between the second and first RBMPs. Table 2.1 Number and area/length of delineated surface water bodies in Denmark for the second and first cycles Cycle RBD Rivers Lakes Coastal Number of water bodies Total length of water body (km) Number of water bodies Total area (km2) of water bodies Number of water bodies Total area (km2) of water bodies second DK1 6 206 15 246 (15 248) 598 306 83 12 803 second DK2 1 276 2 765 214 162 33 7 085 second DK3 184 369 11 1 2 233 second DK4 110 518 33 8 1 205 second Total 7 776 18 898 (18 900) 856 477 119 20 325 first DK1 11 513 (11 516) 15 191 (15 197) 477 272 (273) 106 27 754 first DK2 2 919 (2 922) 2 763 190 157 (159) 56 11 656 first DK3 431 370 11 1 3 4 071 first DK4 264 518 18 7 0 0 first Total 15 127 (15 133) 18 842 696 437 (440) 165 43 481 Source: WISE electronic reports. Numbers in brackets were provided subsequently by Denmark Figure 2.1 Proportion of surface water bodies in Denmark designated as artificial, heavily modified and natural for the second and first cycles. NB - the numbers in parenthesis are the numbers of water bodies in each water category Source: WISE electronic reports.

Table 2.2 Size distribution of surface water bodies in Denmark in the second and first cycles Cycle RBD River length (km) Lake area (km2) Coastal (km2) Territorial (km2) Mini-mum Maxi-mum Aver-age Mini-mum Maxi-mum Aver-age Mini-mum Maxi-mum Average Mini-mum Maxi-mum Average second DK1 0.01 37.11 (37.08) 2.46 0.01 16.55 (17.13) 0.51 0.08 1 807.01 154.25 60.08 4 225.79 1 883.59 second DK2 0.01 20.61 2.17 0.01 39.54 (35.35) 0.76 5.19 1 131.35 214.7 179.2 1 863.58 899.34 second DK3 0.03 10.19 (10.21) 2.01 0.04 0.13 0.07 18.95 213.69 116.32 3 827.22 3 827.22 3 827.22 second DK4 0.04 16.87 (16.85) 4.71 0.01 2.02 0.23 204.99 204.99 204.99 first DK1 0 21.24 1.32 0.01 16.54 (17,13) 0.57 0.08 2 495.79 261.83 first DK2 0 9.17 0.95 0.02 39.54 (87) 0.83 3.41 1 166.84 208.13 first DK3 0 8.08 0.86 0.04 0.13 0.07 19 3 837.96 1 357.08 first DK4 0.04 10.44 1.96 0.03 2.02 0.39 Source: WISE electronic reports. Numbers in brackets were provided subsequently by Denmark Transitional waters were not delineated in the first or the second cycle. The RBMP reports that there are no large river outlets to Danish coastal waters, but only gradual changes in salinity from the near-shore areas to the open sea. Therefore, the Danish fjords have been defined as separate types of coastal waters. It was reported in the RBMP that many river water bodies were aggregated where they were considered to have similar typology and status and were generally homogenous in character. Small water bodies for example that were less than 500 metres in length were also aggregated. The aggregation of water bodies, has resulted in an increase of the average length of rivers from 1.25 km to 2.43 km ( Table 2.2 ). No changes in the criteria for delineation of lakes or coastal waters were reported, yet more lakes were included in the second RBMP, mainly lakes between one and five hectares. Table 2.3 Number and area of delineated groundwater bodies in Denmark for the second and first cycles Year RBD Number Area (km2) Minimum Maximum Average second DK1 241 0.48 6 175.01 219.44 second DK2 136 0.92 1 315.18 109.75 second DK3 19 0.35 368.62 30.5 second DK4 6 0.49 730.42 218.36 second Total 402 0.35 6 175.01 173.39 first DK1 271 first DK2 101 first DK3 6 first DK4 7 first Total 385 Source: WISE electronic reporting For groundwater bodies, there was an overall increase of 4 %, however within the Jutland and Funen RBD there was a significant decrease ( Table 2.3 ). The boundaries of groundwater bodies have been updated based on the proximity and/ or connection to dependant surface water bodies. Table 2.4 summarises the information provided by Denmark on how water bodies have evolved between the two cycles. The changes to the river water bodies and groundwater bodies have been reported as “creation” and “deletion” of new water bodies. Table 2.4 Type of change in delineation of groundwater and surface water bodies in Denmark between the second and first cycles Type of water body change for second cycle (wiseEvolutionType) Groundwater Rivers Lakes Coastal Territorial Aggregation Splitting Aggregation and splitting Creation 402 7 776 162 18 814 Deletion 385 15 127 2 2858 Change in code ExtendedArea change 694 36 6 Delineated for second cycle (after deletion from first cycle) 402 7 776 856 119 14 Source: WISE electronic reports 2.1.2.Identification of transboundary water bodies No transboundary surface or groundwater bodies have been identified by Denmark. However, the International (Vidå-Kruså) RBD borders with Germany and is an international RBD. It was identified that there are differences in delineation of transboundary water bodies between Denmark and Germany, indicating that the delineation may not have been coordinated, and that joint approaches and methods are not in place. 2.1.3.Typology of surface water bodies The number of water body types per RBD and water body categories remained largely the same between the first and second RBMPs ( Table 2.5 ). However, there was a decrease in the number of lake water body types reported overall, from 17 to 12 types . Member States were asked to report ‘Not applicable’ if there is no corresponding intercalibration type for national types. Many national types (heavily modified, artificial and natural) have been intercalibrated. Several of the national types for Denmark in all of the RBDs do not appear to have corresponding intercalibration types. It is the case for two types of river water bodies, nine types of lake water bodies, and 11 types of coastal water bodies . For the national types that have been linked to common intercalibration types, the Danish classification system has been successfully intercalibrated for all the biological quality elements. This indicates that the Danish typology is biologically relevant for those national types. For the other national types that are not linked to any common type, there is no information available as to whether those types are biologically relevant.

Table 2.5 Number of surface water body types at RBD level in Denmark for the first and second cycles RBD Rivers Lakes Coastal first second first second first second DK1 6 5 17 (11) 12 (11) 15 17 DK2 6 5 17 (8) 10 (9) 8 9 DK3 6 2 17 (2) 4 1 1 DK4 6 5 17 (6) 8 (7) 1 1 TOTAL 6 5 17 (11) 12 (11) 17 19 Source: WISE electronic reports. Numbers in brackets were provided subsequently by Denmark. Note that the total is not the sum of the types in each RBD as some types are shared by RBDs 2.1.4.Establishment of reference conditions for surface water bodies Table 2.6 shows the percentage of surface water body types in Denmark with reference conditions established for the first and second cycles. Type specific reference conditions have been established for some or all relevant biological quality elements. Type specific reference conditions have not been established for physicochemical quality elements or hydromorphological quality elements. Table 2.6 Percentage of surface water body types in Denmark with reference conditions established for all, some and none of the biological, hydromorphological and physicochemical quality elements. Numbers in parenthesis in the column “water category” are the number of types in each category Water category Water types Biological quality elements Hydromorphological quality elements Physicochemical quality elements Rivers (6) All Some 100% None 100% 100% Lakes (12 (11)) All 17% (18%) Some 83% (82%) None 100% 100% Coastal (20(19)) All 95% (100%) Some None 5% (0%) 100% 100% Source: WISE electronic reports. Numbers in brackets were provided subsequently by Denmark Type-specific reference conditions have been intercalibrated with other relevant Member States and is part of the European Commission Decisions on Intercalibration. 2.1.5.Characteristics of groundwater bodies The geological formation of the aquifer types in which groundwater bodies reside along with details of whether groundwater bodies are layered or not were reported. Further characterisation work has been reported since the first cycle with the inclusion of the assessment of linkages to surface water bodies and terrestrial ecosystems. 2.1.6.Significant pressures on water bodies In the second RBMP the significant pressures reported on surface water bodies overall were ‘Diffuse - Discharges not connected to sewerage network’ (49 %), followed by ‘Dams, barriers and locks – Other’ (26 %), which was mainly applicable to river water bodies ( Figure 2.2 ). Diffuse pollution from agriculture is not reported as a significant pressure overall for surface water bodies (4 %). However, when it comes to coastal water bodies 98 % have diffuse pollution from agriculture and 30 % of lake water bodies but it is not a significant pressure for river water bodies (<1 %). ‘No significant pressure’ was reported for 22 % of surface water bodies overall. Figure 2.3 shows the comparison of pressures at an aggregated level between the first and second cycle in Demark, which shows an increase in the number of surface water bodies with associated diffuse pressures. It appears that this increase relates to ‘discharges not connected to the sewerage network.’ However due to important changes in the delineation of water bodies between the first and the second RBMPs, changes of pressures between the two RBMPs have to be analysed with caution. For groundwater bodies “No significant pressure” was reported 75 % of the time and the most significant pressures were ‘Anthropogenic pressure – Unknown’ (25 %) and ‘pressures due to abstractions’ ( Figure 2.2 ). For the second RBMP, there is no data reported on which significant pressures were not assessed for surface waters or groundwater, and it does not appear that all pressures have been apportioned. For example, the main pressure on groundwater is ‘Anthropogenic pressure – Unknown.’ However, the changes in the significant pressures between the first and the second cycle were reported. For rivers since the first RBMP, phosphorus emissions from scattered dwellings, have been included whilst acidifying substances and pathogens were removed. For coastal waters since the first RBMP, nutrients from scattered dwellings have been added, whilst pathogens were removed. For coastal waters, atmospheric deposition of nutrients and nutrients coming from other countries was added since the first RBMP. It is unclear whether the changes relate to exclusion of pressures from the assessment or to changes in the methodologies. Figure 2.2 The most significant pressures on surface water bodies and groundwater bodies in Denmark for the second cycle Source: WISE electronic reports.

Figure 2.3 Comparison of pressures on surface water bodies in Denmark in the first and second cycles. Pressures are presented at the aggregated level. NB - there were 8 765 identified surface water bodies for the second cycle and 15 988 for the first cycle. Source: WISE electronic reports. 2.1.7.Definition and assessment of significant pressures on surface and groundwater For surface waters, a combination of both expert judgement and numerical tools were used for defining point source pressures and pressures from water flow. Numerical tools were used for assessing diffuse source pressures. The tools used to assess significant pressures are Geographical Information System analyses, models, and threshold values linking the pressure to the good/moderate status boundary for the sensitive biota. The tools for hydromorphological pressures are not well developed and pressures are considered significant if the physical index exceeds a certain threshold. The RBMPs reported that there have been significant changes in the methodology for assessing significant pressures from diffuse and point source pollution by nutrients and organic matter since the first RBMP. New models have been developed to estimate nitrogen loads to coastal waters, which include the future prediction of nutrient loads. An equivalent methodology has been developed for updated calculations of nutrient and organic loads from point sources and scattered dwellings. For groundwater, the tools used for defining significant pressures were reported as “Not Assessed” for point and diffuse pollution, and numerical tools were used for abstraction pressures. For groundwater, significance of pressures was reported to be defined in terms of thresholds and linked to the potential failure of objectives. Water abstraction for irrigation is estimated with hydrogeological models. The significance of this pressure has been linked to the high probability of deterioration to less than good status of the dependent surface waters (river, benthic invertebrate ecological quality ratio values), as well as to a screening criterion of the maximum acceptable exploitation of groundwater. The hydrogeological models are also reported to be improved since the first cycle. 2.1.8.Significant impacts on water bodies In the second RBMP, the most significant impact on surface water bodies overall was classified as ‘Organic pollution’ (49 %), followed by ‘Altered habitats due to morphological changes’ (33 %) which relates mainly to impacts on rivers ( Figure 2.4 ). For coastal water bodies the main impact was reported to be nutrient pollution affecting 98 % of water bodies and for lakes water bodies it was 62 %. For groundwater, 74 % of water bodies were classified as ‘no significant impact’ and the most significant impact was ‘Chemical pollution’ (25 %). Denmark did not report on impacts in the first RBMP. Figure 2.4 Significant impacts on surface water and groundwater bodies in Denmark for the second cycle. Percentages of numbers of water bodies Source: WISE electronic reports 2.1.9.Groundwater bodies at risk of not meeting good status Groundwater bodies were reported to be at risk of failing to meet good chemical status in three RBDs, ranging from 17 to 27 % in the Jutland and Funen, Zealand and International (Vidå-Kruså) RBDs. For the Bornholm RBD, no groundwater bodies were reported to be at risk. The pollutants putting groundwater bodies at risk of failing good chemical status have been reported. In the Zealand RBD groundwater bodies were reported to be at risk of failing to meet good quantitative status (2 % of water bodies) and none were reported to be at risk for the remaining water bodies. Further information on the chemical status of groundwater bodies can be found in Chapter 6 of this report. 2.1.10.Quantification of the gap and apportionment of pressures There was one inconsistency in the pressures for which measures are planned and the significant pressures reported at the water body level. In the International (Vidå-Kruså) RBD, ‘Anthropogenic pressure – Unknown’ has been reported at the groundwater body level but this pressure has not been reported as being tackled in the Programme of Measures. Further information on the Programme of Measures can be found in Chapter 9 of this report.

Denmark has also stated that projects are also being launched to obtain further knowledge on pollutants in the aquatic environment, and substances added to the EU list of priority substances in 2013 are covered by a preliminary program of measures from the end of 2018 to the end of 2021. Further information on measures related to pollution from sectors other than agriculture can be found in Chapter 12 of this report. 2.1.11.Inventories of emissions, discharges and losses of chemical substances Article 5 of the Environmental Quality Standards Directive (EQS Directive) requires Member States to establish an inventory of emissions, discharges and losses of all Priority Substances and the eight other pollutants listed in Part A of Annex I EQS Directive for each RBD, or part thereof, lying within their territory. This inventory should allow Member States to further target measures to tackle pollution from priority substances. It should also inform the review of the monitoring networks, and allow the assessment of progress made in reducing (respectively suppressing) emissions, discharges and losses for priority substances (respectively priority hazardous substances). Denmark reported inventories for each RBD. However each of them included only 19 of the 41 Priority Substances. The RBMP reported that the Priority Substances not included on the inventories are not used in Denmark or that screening has shown that they do not occur in significant quantities. This does not seem to be entirely in line with the Common Implementation Strategy Guidance Document n°28, which recommends that “For the substances discarded (i.e. for substances of minor relevance) Member States should try to provide a basic estimation of emissions, discharges and losses from available data. This is especially important for PHS [priority hazardous substances – for which emissions must be phased out]”. The two-step approach from the Common Implementation Strategy Guidance Document n°28 has been followed for the substances considered in the inventories. Tier 1 (point source information) was implemented for substances not relevant at RBD level, and Tier 2 (riverine load) was used for other substances, while the Guidance Document recommends using at least Tier 1+2 for the relevant substances. The data quality was not reported. 2.2.Main changes in implementation and compliance since the first cycle Overall there was a significant decrease of 49 % in the number of river water bodies delineated between the first and second RBMPs. The same was true for coastal water bodies with a decrease of 28 % . For lake water bodies, however there was an increase of 23% overall, with the largest increase in the International (Vidå-Kruså) RBD (83%). For groundwater bodies, there was an overall increase of 4 %. In the second RBMPs, 91 % of identified surface water bodies were natural, 5% were designated as heavily modified and 4 % were artificial water bodies. In the first RBMPs, the situation was somewhat different with 72 % natural, 16 % heavily modified and 11 % artificial. The number of water body types per RBD and water body categories remained largely the same between the first and second RBMPs. There are increases in the number of surface water bodies with diffuse pressures between the first and the second cycle. It appears that this increase relates to discharges not connected to the sewerage network. 2.3.Progress with Commission recommendations The Commission recommendations based on the first RBMPs and Programme of Measures requested action on the following: ·Recommendation: Transitional waters are not designated, and no justification is given as to why this water category has not been used. Denmark should review its designation of at least some coastal waters, notably those referred to as inner coastal fjords water, and consider transitional water designation, considering physical and chemical factors that determine the characteristics of transitional waters and hence the biological population structure and composition. Assessment: Transitional waters are not delineated in the first or the second cycle. The RBMP reports that there are no large river outlets to Danish coastal waters, but only gradual changes in salinity from the near-shore areas to the open sea. Therefore, the Danish fjords have been defined as separate types of coastal waters. This justification is adequate and therefore the recommendation has been fulfilled. ·Recommendation: There are no criteria or thresholds given on how to define significant pressures from point and diffuse sources. Where there are currently high uncertainties in the characterisation of the RBDs, identification of pressures, and assessment of status, these need to be addressed in the current cycle, to ensure that adequate measures can be put in place before the next cycle. [Action: Improved and clear descriptions of how all pressures and impacts were quantified, in particular on how significance was defined] Assessment: For surface waters, a combination of both expert judgement and numerical tools were used for defining point source pressures and pressures from water flow. Numerical tools only were used for assessing diffuse source pressures. For groundwater, the tools used for defining significant pressures were reported as “Not Assessed” for point and diffuse pollution, and numerical tools were used for abstraction pressures. For both surface water bodies and groundwater, significance of pressures was reported to be defined in terms of thresholds and linked to the potential failure of objectives for all RBDs. The criteria and thresholds are described in the RBMPs and changes from the first cycle are highlighted. Therefore this recommendation has been mostly fulfilled. ·Recommendation: There is no information on tools to assess significant hydromorphological pressures. Denmark needs to improve the identification of significant pressures, describe the methodologies, thresholds and tools better in the plans and report more detailed data by water body. This applies also to hydromorphological pressures and chemical pollution. Assessment: The RBMP does not provide information on what pressures were excluded from the assessment, but the changes in the significant pressures between the first and the second cycle were reported. There is information in the RBMPs regarding the tools used to assess the significance of pressures including hydromorphological pressures. The tools for hydromorphological pressures are not well developed and pressures are considered significant if the physical index exceeds a certain threshold. Therefore this recommendation has been partially fulfilled. ·Recommendation: The basis for assessing quantitative status in groundwater bodies is weak and needs to be improved. [Action: Water abstraction for irrigation is a major source of this pressure]. Assessment: In terms of characterisation, abstractions are only reported to be a significant pressure for 2 % of water bodies and impacts were identified where abstraction exceeds available groundwater resource (lowering water table). It was reported that the assessment of abstraction pressures has been improved since the first cycle with the use of a new hydrogeological model. All pressures including water abstraction for irrigation have been considered for the assessment of the quantitative status. However, only those pressures that have led to poor quantitative status have been specified to be significant. Therefore this recommendation has been partially fulfilled.





Topic 3 Monitoring, assessment and classification of ecological status in surface water bodies 3.1.Assessment of implementation and compliance with WFD requirements in second RBMPs 3.1.1.Monitoring of ecological status/potential Monitoring programmes Article 8.1 of the WFD requires Member States to establish monitoring programmes for the assessment of the status of surface water and of groundwater in order to provide a coherent and comprehensive overview of water status within each RBD. A number of different monitoring sub-programmes were reported by Denmark and are common across the four RBDs. Even though coastal waters were reported for all four RBDs, only three of the RBDs have indicated that there is a programme covering coastal waters: the Bornholm RBD did not have coastal monitoring, except one monitoring site for macroalgae. Denmark subsequently clarified that the sub-programme for coastal waters that was the basis of the second RBMPs did not distinguish between surveillance and operational monitoring. Each monitoring site in that programme was used for both surveillance and operational monitoring. Monitoring sites and monitored water bodies used for surveillance and operational monitoring The first RBMPs for Denmark were adopted on 21 December 2011 and reported to the Commission on 22 December 2012. Electronic reporting to WISE was submitted in the spring of 2012. However, for legal reasons the first plans were declared invalid by the Danish Authorities in the spring of 2013. The RBMPs were resubmitted to a consultation process and the revised RBMPs for the first planning period were adopted in October 2014. Data were also resubmitted to WISE, the latest in March 2015. This assessment is largely based on the data submitted to WISE in 2012, supplemented by information subsequently provided by Denmark. There was a five fold increase in the number of operational sites in rivers in Denmark between the first RBMP (2 475) and the second (12 464). There was a smaller increase in the number of operational sites in coastal waters (434 to 625) and a decrease in sites in lakes (351 to 262). There is no summary of the changes in the RBMPs or referenced background documents. The monitoring programme used for the second RBMPs (NOVANA 2011-2015) does not include any information on the changes made since the first RBMPs. Due to the short time between the final adoption of the first and second RBMPs, the changes in the monitoring programme are likely to be minor. There are no differences in main monitoring approach between RBDs as the monitoring programmes are national. Table 3.1 compares the number of monitoring sites used for surveillance and operational purposes between the two RBMPs, and Table 3.2 gives the number of sites used for different purposes for the second RBMPs. There is a significant increase in the total number of monitoring sites in lakes from 351 for the first RBMPs to 1080 for the second RBMPs. For the first RBMPs, no surveillance sites were reported for lakes; whereas for the second RBMPs, 818 sites were reported. However Denmark subsequently clarified that there were 351 surveillance sites in lakes for the first RBMPs. Conversely, no surveillance sites were reported for coastal waters for the second RBMP and 243 were reported for the first RBMPs. However, Denmark subsequently clarified that the total number of monitoring sites for coastal waters has increased from 636 for the first RBMPs to 781 for the second, and that no distinction was made between surveillance and operational sites for the second RBMPs. Overall, there were only small changes in the numbers of surveillance sites in rivers between the two RBMPs. There was a five-fold increase in the number of operational sites in rivers in Denmark between the first RBMP (2 475) and the second (12 464). There was a smaller increase in the number of operational sites in coastal waters (434 to 625 ) and a decrease in sites in lakes (351 to 262). There is no summary of the changes in the RBMPs or referenced background documents. The monitoring programme used for the second RBMPs (NOVANA 2011-2015) does not include any information on the changes made since the first RBMPs. Due to the short time between the final adoption of the first and second RBMPs, the changes in the monitoring programme are likely to be minor. There are no differences in main monitoring approach between RBDs as the monitoring programmes are national. Table 3.1 Number of sites used for surveillance and operational monitoring in Denmark for the second and first RBMPs. Note that for reasons of comparability with data reported for the first RBMPs, the second RBMPs’ data does not take into account whether sites are used for ecological and/or chemical monitoring Rivers Lakes Coastal Surv. Op Surv. Op Surv. Op second RBMP DK_1 613 10 269 553 194 (519) 420 (519) DK_2 140 1766 230 56 (257) 202 (257) DK_3 23 203 13 3 (1) (1) DK_4 14 226 22 9 (4) 3 (4) Total by type of site 790 12464 818 262 0 (781) 625 (781) Total number of monitoring sites 13 116(13140) 1080 625 (781) first RBMP DK_1 607 1 971 0 (250) 250 162 312 DK_2 140 393 (89) 0 89 77 119 DK_3 15 27 (3) 0 3 4 3 DK_4 14 84 (9) 0 9 Total by type of site 776 2 475 (351) 0 351 243 434 Total number of monitoring sites 3 251 351(552) 636 Sources: WISE electronic reports. Numbers in brackets were provided subsequently by Denmark. Table 3.2 Number of monitoring sites in relevant water categories used for different purposes in Denmark

Monitoring Purpose Rivers Lakes Coastal CHE - Chemical status 24 37 156 ECO - Ecological status 20 (13 136) 1080 (625) HAB - Protection of habitats or species depending on water 410 21 OPE - Operational monitoring 12 464 262 625 (781) SOE - EIONET State of Environment monitoring 31 17 SUR - Surveillance monitoring 790 818 (781) Total sites irrespective of purpose 13 140 1 080 783 Source: WISE electronic reports. Numbers in brackets were provided subsequently by Denmark. Quality elements monitored (excluding River Basin Specific Pollutants) Table 3.3 illustrates the quality elements used for the monitoring of surface waters for the second RBMPs that have been reported in WISE: no differentiation is made between purposes of monitoring. There are also gaps in the monitored biological quality elements: macroalgae are not reported in WISE to be monitored in coastal waters, although the biological quality element is included in the NOVANA programme for 2011-2015 with 46 sites, phytobenthos are not monitored in rivers , and benthic invertebrates are not monitored in lakes. Phytobenthos is not reported as being monitored in lakes, but Denmark subsequently clarified that it is monitored but not used in the assessment. Table 3.3 Quality elements monitored for the second RBMPs in Denmark (excluding River Basin Specific Pollutants). Note: quality element may be used for surveillance and/or operational monitoring. Note that some Member States reported “other aquatic flora” rather than the component sub-quality elements, macrophytes, phytobenthos, angiosperms and macroalgae. Biological quality elements Hydromorphological quality elements Phytoplankton Macrophytes Phytobenthos Benthic invertebrates Fish Angiosperms Macroalgae Other aquatic flora Other species Hydrological or tidal regime Continuity conditions Morphological conditions Rivers Yes No Yes Yes No No No No Lakes Yes Yes No No Yes No No No Coastal Yes Yes Yes No No No No General physicochemical quality elements Transparency conditions Thermal conditions Oxygenation conditions Salinity conditions Acidification status Nitrogen conditions Phosphorus Conditions Silicate Other determinant for nutrient conditions Rivers No No No No No No No No Lakes No No No No No No No No No Coastal No No No No No No No No No Source: WISE electronic reports. Denmark subsequently clarified that due to reporting error, more elements are monitored than what was reported. In particular, all general physicochemical quality elements are monitored in coastal waters (except transparency and acidification), lakes (except silicate and other determinant for nutrient conditions) and rivers (except transparency, silicate and other determinant for nutrient conditions). All hydromorphological quality elements are monitored in rivers and lakes, while in coastal water freshwater flow and composition of sediments are monitored. Phytobenthos in rivers and lakes was not monitored for the first RBMPs, it has been monitored in lakes but not in rivers for the second RBMPs. All biological quality elements were said to be monitored in coastal waters for the first RBMPs, but macroalgae were not included in the WISE reporting for the second RBMPs (although it was included in the NOVANA programme, see above). It appears that for the first RBMP some physicochemical and hydromorphological quality elements were monitored in some water categories, but for the second RBMPs none were reported to be monitored. However, Denmark has subsequently clarified that this is a reporting error. All hydromorphological quality elements are monitored in rivers and lakes, while in coastal water freshwater flow and composition of sediments are monitored. All general physicochemical quality elements are monitored in coastal waters (except transparency and acidification), lakes (except silicate and other determinant for nutrient conditions) and rivers (except transparency, silicate and other determinant for nutrient conditions). [Note: Denmark also reported that reference conditions had not been established for any type for any hydromorphological or physicochemical quality element.] Annex V of the WFD gives a recommended minimum frequency for the sampling of biological quality elements unless greater intervals would be justified on the basis of technical knowledge and expert judgement. For phytoplankton, the minimum recommended frequency is once every six months in all water categories, and once every three years for the other biological quality elements. The highest rate of alignment with these frequencies was for coastal sites where benthic invertebrates, angiosperms and phytoplankton were sampled at the minimum recommended or higher frequency at 89 %, 88 % and 43 % of sites. The rate of alignment with the recommended frequencies was much lower in the other two water categories in Denmark. For lakes only 4 %, 1 % and 1 % of sites were sampled at least at the minimum recommended frequency for macrophytes, phytoplankton and fish, respectively. None of the 3631 sites sampled for fish in rivers were sampled in line with the recommended frequencies. 22 % and 12 % of river sites were sampled with at least at the minimum recommended frequency for benthic invertebrates and macrophytes. Monitored River Basin Specific Pollutants 15 different River Basin Specific Pollutants were reported to be monitored in Denmark. The substance monitored at the most sites (60) was “dioxin-like polychlorinated biphenyls”. Three River Basin Specific Pollutants were monitored in coastal waters, three in lakes and 13 in rivers. The substances in coastal water were only monitored in biota and those in lakes and rivers only in water. River Basin Specific Pollutants were not monitored at the recommended frequency at any of the sites. The analytical methods used meet the minimum performance criteria laid down in Article 4(1) of the QA/QC Directive (2009/90/EC) for the strictest standard applied. Table 3.4 shows the number of sites used to monitor River Basin Specific Pollutants in Denmark for the first and second RBMPs. Table 3.4 Number of sites used to monitor River Basin Specific Pollutants for the second RBMPs and non-priority specific pollutants and/or other national pollutants for the first RBMPs in Denmark. Note the data from both cycles may not be fully comparable as different definitions were used and also not all Member State reported information at the site level meaning that there were no equivalent data for the first RBMPs RBMP Rivers Lakes Coastal second RBMP Sites used to monitor River Basin Specific Pollutants 21 4 61 first RBMP Sites used to monitor non-priority specific pollutants and/or other national pollutants NR NR NR Source: WISE electronic reports

NR = Not reported to WISE Surveillance monitoring of surface water bodies None of the water bodies included in surveillance monitoring of rivers, lakes and coastal waters were monitored for all the required biological, hydromorphological and physicochemical quality elements, which indicates non-compliance with the WFD. Figure 3.1 shows the proportion of water bodies object of surveillance and operational monitoring in each cycle: operational monitoring generally covers a greater proportion of water bodies (except for lakes) in the second RBMPs. Surveillance monitoring was reported in WISE as occurring for the first time in lakes and not occurring at all in coastal waters in the second RBMPs. As explained above, for lakes in the first RBMPs and for coastal waters in the second, Denmark used the same monitoring programmes and the same monitoring sites for both surveillance and operational monitoring. Figure 3.2 shows the proportion of water bodies object of surveillance monitoring. Surveillance monitoring sites are distributed throughout the status classes, in water categories where it is reported, including good and high status classes as required. None of the water bodies included in surveillance monitoring of rivers, lakes and coastal waters were monitored for all the required biological, hydromorphological and physicochemical quality elements, which may indicate non-compliance with the WFD. Figure 3.1 Percentage of water bodies included in surveillance and operational monitoring in Denmark for the first RBMPs and second RBMPs. Note no differentiation is made between water bodies included in ecological and/or chemical monitoring Source: WISE electronic reports. Denmark subsequently noted that for the first RBMPs all lake monitoring sites served the purposes of both surveillance monitoring and operational monitoring. The same approach was taken for all coastal monitoring sites also for the second RBMPs. See Table 3.1 for numbers of surveillance and operational monitoring sites in lakes and coastal waters provided by Denmark. Figure 3.2 Proportion of water bodies included in surveillance monitoring in Denmark shown for each ecological status/potential class. Source: WISE electronic reports. Note: Denmark subsequently noted that for the first RBMPs all lake monitoring sites served the purposes of both surveillance monitoring and operational monitoring. The same approach was taken for all coastal monitoring sites also for the second RBMPs. See Table 3.1 for numbers of surveillance and operational monitoring sites in lakes and coastal waters provided by Denmark. There were significant changes in the delineation of surface water bodies in Denmark from the first to the second RBMPs with a decrease of 49% and 28% in the number of river water bodies and coastal water bodies respectively. For lake water bodies, there was an increase of 23% overall. For the second RBMPs, coastal water bodies were identified in all 4 RBDs. According to the WISE reporting, 91 % were included in operational monitoring, but none of these were in the Bornholm RBD. For the second RBMPs, 9 % of river water bodies were included in surveillance monitoring and 70 % in operational monitoring. 58 % of lake water bodies were in surveillance monitoring and 22 % in operational monitoring. Bearing in mind the significant decreases in the numbers of water bodies delineated from the first to the second RBMPs 5 % of river water bodies were in surveillance monitoring for the first RBMPs compared to 9 % for the second. Overall there was a significant increase in the proportion of river water bodies included in operational monitoring (14 % for the first RBMPs, 70 % for the second), an increase in coastal water bodies (72 % for the first, 91 % for the second) and a decrease in lake water bodies (37 % for the first RBMPs, 22 % for the second). Operational monitoring of surface water bodies The biological quality element predominantly used in Denmark for the operational monitoring of coastal waters was phytoplankton (82 % of water bodies included in operational monitoring) followed by angiosperms (74 %) and benthic invertebrates (49 %). Phytoplankton was also the predominant biological quality element used in the operational monitoring of lakes (98 %), where macrophytes (38 %) and fish (0.5 %) were also used. In the operational monitoring of rivers, benthic invertebrates were used in 96 % of water bodies included in operational monitoring, fish in 36 % and macrophytes in 2 %. In coastal water and rivers, a large proportion of water bodies at less than good ecological status/potential are included in operational monitoring, 91 % and 94 %, respectively. For lakes this was only 27 %. Transboundary surface water body monitoring Denmark did not report any transboundary surface or groundwater bodies nor any monitoring sites that are part of international monitoring networks.

3.1.2.Ecological Status/potential of surface water The ecological status/potential of surface water bodies in Denmark for the second RBMPs is illustrated in Map 3.1 . Figure 3.3 compares the ecological status of surface water bodies in Denmark for the first RBMPs with that for the second RBMPs and that expected by 2015. It indicates an overall deterioration in ecological status from the first to the second RBMPs. Denmark has since suggested that this deterioration may be a result of the changes in delineation of waterbodies and the use of more quality elements in the classification of status in the second RBMPs. Therefore, any comparison between the two RBMPs needs to be taken with care. Member States were asked to report the expected date for the achievement of good ecological status/potential. The information for Denmark is shown in Figure 3.4 . Map 3.1 Ecological status or potential of surface water bodies in Denmark based on the most recently assessed status/potential of the surface water bodies Note: Standard colours based on WFD Annex V, Article 1(4)(2)(i) Source: WISE, Eurostat (country borders) High Good Moderate Poor Bad Unknown RBDs Countries outside the European Union Figure 3.3 Ecological status or potential of surface water bodies in Denmark for the second RBMPs, for the first RBMPs and expected in 2015. The number in the parenthesis is the number of surface water bodies in each cycle. Note the period of the assessment of status for the second RBMPs was 1993 to 2014. The year of the assessment of status for first RBMPs is not known Source: WISE electronic reports



Figure 3.4 Expected date of achievement of good ecological status/potential of surface water bodies in Denmark. The number in the parenthesis is the number of water bodies in each category Source: WISE electronic reports The large majority of water bodies in all water categories are in less than good status/potential, and quite a high proportion are in poor or even bad status/potential. There are also still several water bodies with unknown ecological status/potential, in particular for artificial and heavily modified rivers. It should be noted, however, that the big differences in delineation of water bodies and the changes in number of quality elements used in the classification make any quantitative comparison very difficult. The overall picture indicates a deterioration in status/potential since the revised first RBMPs ( Figure 3.3 ) with 5-20 % more water bodies in less than good status/potential in the second RBMPs, except coastal waters in the Zealand RBD, which has a slight improvement, while rivers in the Zealand RBD and coastal waters in the Jutland and Funen RBD and the International (Vidaa-Krusaa) RBD show no change. A more detailed analysis included in the RBMPs estimates that there is a general improvement for lakes and coastal waters, and no change for rivers.

In the first RBMPs, 19 % of surface water bodies in Denmark were reported to have unknown ecological status/potential and this increased to 24 % in the second. Many heavily modified and artificial water bodies (30-60 %) were reported with unknown ecological status in most RBDs. For natural water bodies, relatively few water bodies were reported with unknown ecological status (15-25%); this is an improvement since the revised first RBMPs, when the proportion of natural water bodies with unknown ecological status was much higher. The ecological status changes from the first to the second RBMPs have been described in the second RBMPs. Water bodies that have been re-delineated and those that had unknown status in the first RBMPs have not been compared. Results for biological quality elements that have only been classified in the second RBMPs could also not be included in the comparisons. The comparisons show that the large majority (60-80 %) of all classified water bodies have the same status in the first and second RBMPs, which is explained by the short time between the publication of the first RBMP and the second RBMP. The changes from the first to the second RBMPs for rivers are quite different in the different RBDs: for the Jutland and Funen RBD, the same proportion of water bodies (16 %) has improved or deteriorated; for the Zealand RBD, only 10 % have improved, while 20 % have deteriorated; while for the Vidaa-Krusaa RBD, 27 % have improved and 13 % have deteriorated. The changes for lakes are quite similar in the different RBDs with more water bodies improved than deteriorated: for the Jutland and Funen RBD, 21 % have improved, while 10 % have deteriorated; for the Zealand RBD, 24 % have improved, while 9 % have deteriorated; while for the Vidaa-Krusaa RBD, 23 % has improved and 15 % has deteriorated. The changes for coastal waters show improvements in all the RBDs: 16 % in the Jutland and Funen RBD, 33 % in the Zealand RBD, except in the Vidaa-Krusaa RBD, where there were no changes, and in the Jutland and Funen RBD, where 3 % have deteriorated. As stated above, any comparison between the two cycles needs to be taken with care, due to the significant re-delineation of surface water bodies that took place and to the use of a larger number of biological quality elements in the second RBMPs. The supporting quality elements are not classified in any water bodies in the two cycles. Confidence in ecological status assessment Figure 3.5 shows the confidence in the classification of ecological status/potential in the second RBMPs. Overall the confidence in the classification of surface water bodies increased from the first to the second RBMPs: 2 % were classified with high confidence in the first RBMPs and 68 % in the second. The confidence in classification is high for all coastal water bodies and for the large majority of rivers and lakes where the overall ecological status/potential is classified. There are no water bodies classified with low confidence. This is a major improvement compared to the first RBMPs, in which there was no information on confidence for more than 95 % of the river and lake water bodies. Figure 3.5 Confidence in the classification of ecological status or potential of surface water bodies in Denmark based on the most recently assessed status/potential Source: WISE electronic reports Classification of ecological status at the quality element level Figure 3.6 shows the percentage of water bodies in terms of the biological quality elements used for classification. Figure 3.7 compares the classification of biological quality elements in terms of ecological status/potential for the two cycles. It should be noted that this comparison should be treated with caution, as there are differences between the numbers of surface water bodies classified for individual elements from the first to the second RBMPs. Figure 3.8 illustrates the basis of the classification of ecological status/potential of rivers and lakes in Denmark for the second RBMPs. Figure 3.6 Ecological status/potential of the biological quality elements used in the classification of surface water bodies in Denmark. Note that water bodies with unknown status/potential, and those that are monitored but not classified or not applicable, are not presented.

Source: WISE electronic reports Figure 3.7 Comparison of ecological status/potential in Denmark according to classified biological quality elements in surface water bodies from the first to the second RBMPs. The number in brackets provides the number of surface water bodies with status Source: WISE electronic reports. . Figure 3.8 The classification of the ecological status or potential of rivers, lakes and coastal waters in Denmark using one, two, three or four types of quality element Note: The four types are: biological; hydromorphological, general physicochemical and River Basin Specific Pollutants Source: WISE electronic reports Supporting physicochemical quality elements are not classified ( Figure 3.8 ) and classification of status relies on biological quality elements ( Figure 3.6 and Figure 3.7 ). This is in particular the case for the nutrients (phosphorus and nitrogen) in rivers. Diffuse pollution from agriculture and nutrient pollution (which includes both phosphorus and nitrogen) were not reported as a significant pressure or impact in rivers . The change in status/potential from the first to the second RBMPs at the quality element level was reported to be unknown for the large majority of water bodies, but was reported for approximately one third of lakes water bodies in all the RBDs for phytoplankton and for a few coastal water bodies in the Jutland and Funen RBD and the Zealand RBD for phytoplankton and angiosperms. Two thirds show improvement and one third show deterioration. All these changes were reported to be real and not due to changes in delineation or in methodologies. Assessment methods and classification of biological quality elements Reference conditions and class boundaries are developed for most biological quality elements in all national types. New assessment methods have been developed since the first RBMPs, for macrophytes and fish in rivers and lakes. The remaining gaps are phytobenthos in rivers , benthic invertebrates and phytobenthos in lakes The sensitivity to impacts of the various existing methods is consistent for all the relevant impacts in Denmark (nutrients, organic, acidification, hydromorphological) for the various biological quality elements, except for nutrients (including phosphorus) in rivers, for which there is no sensitive biological quality element method developed . Transitional waters have not been delineated in Denmark, so there are no biological quality element methods for that water category. Denmark has provided the Commission in 2009 with the technical explanation for not designating transitional waters. Examination of the RBMPs showed that reference conditions are missing for the following biological quality elements in river types: benthic algae in all river types, benthic invertebrates and macrophytes for the soft-bottom river type, macrophytes in small rivers. There are projects to develop a new index for benthic algae in all river types and macrophytes in small rivers. There is no explanation on the reason why benthic algae are missing. For macrophytes, the current index is considered not applicable in small rivers and for benthic invertebrates the current index is not applicable in soft-bottom rivers, according to experts from Aarhus University. There is a plan to develop a new index for benthic invertebrates and macrophytes in soft-bottom rivers. Reference conditions are missing for benthic algae and benthic invertebrates in all lake types. A classification system for these biological quality elements in lakes was under development, but it has not been used for classification of ecological status in lakes for the second RBMPs. Phytoplankton class boundaries are missing for humic lake types . No justifications are found in the plans nor in relevant background documents to explain these gaps . For coastal waters, reference conditions are missing for macroalgae, for which no justification was found . Intercalibration of biological quality element methods A minority of national types are linked to common intercalibration types in all RBDs. Some national types overlap several intercalibration types, and it is unclear which class boundaries are used. This is particularly difficult for river types, as the Danish river typology does not include geology as a typology factor. Some national types do not match any common intercalibration type, so information on class boundaries has not been reported. Phytoplankton, macrophytes and fish biological quality elements in lakes are intercalibrated through two types that are linked to the common intercalibration types L-CB1 and L-CB2. The other nine national types have not been intercalibrated.

Some biological quality elements in rivers (with the exception of benthic algae) have been intercalibrated in all the three national types that are linked to the common intercalibration types in the Central Baltic Geographic Intercalibration Group. However, these three national types overlap two of these common intercalibration types, which have highly different geology and it is not clear which of the intercalibrated class boundaries are used for classification of rivers. Two national types with soft-bottom (small and medium sized rivers, type 1 and 2) have not been intercalibrated. Biological quality elements (with the exception of macroalgae) in coastal waters are intercalibrated for the six national types that are linked to the common intercalibration types in North East Atlantic Geographic Intercalibration Group and Baltic Geographic Intercalibration Group. The other 11 national types, mostly fjords, have not been intercalibrated for any biological quality element. No information on particular methods was found in the RBMPs. There was a general statement in the RBMPs that the results of the intercalibration must be translated so that the national types obtain the same level of protection as the intercalibrated types. This work has been done by national experts . Assessment methods for hydromorphological quality elements Morphological conditions of rivers were reported to be assessed in terms of ecological status/potential reported and their classification boundaries are related to the class boundaries for the sensitive biological quality elements. Hydrological/tidal regime in all 3 categories and river continuity are not assessed in terms of ecological status/potential. It should be noted that no hydromorphological quality elements were reported to be monitored and none were used in the classification of status/potential in Denmark . However Denmark subsequently clarified that all hydromorphological quality elements are monitored in rivers. There was no description in the RBMPs of any changes in the assessment of hydromorphological quality elements from the first to the second RBMPs. The only assessment method for the hydromorphological quality elements is a physical index for rivers, which was also available in the first RBMPs. This index seems to be used both as a typology factor, and as a quality element for classification with a good-moderate status threshold of 0.5. For rivers, it is unclear whether the physical index includes all the hydromorphological quality elements required in the WFD, and whether this is consistent with the high-good status and good-moderate status thresholds for benthic fauna or other biological quality elements. For lakes and coastal waters, there are no assessment methods developed for any of the hydromorphological quality elements . Classification methods for general physicochemical quality elements Three physicochemical quality elements (transparency, oxygenation conditions and nutrient conditions) were assessed in terms of the ecological status/potential of coastal waters; one (nutrient conditions) was used in lakes and one (salinity conditions) also in rivers. The classification boundaries for the assessed quality elements were reported to be related to the class boundaries for the sensitive biological quality elements. No standards were reported to WISE for any physicochemical quality element, although they are included in a background document. Information was found in the RBMPs on the good-moderate status boundaries for only one physicochemical quality element in rivers which is ochre (ferrous iron), where the good-moderate status boundary of 0.7 mg/l is said to be correlated with the benthic fauna at good status class. This quality element would only be used for classification in the absence of biological data on benthic fauna. For lakes, there are good-moderate status boundaries for total phosphorus and total nitrogen for shallow and deep lakes. For phosphorus, the good-moderate status boundary for shallow lakes is 0.080 milligrams per litre and for deep lakes 0.042 milligrams per litre (summer mean values). For nitrogen, the good-moderate status boundaries are 0.95 milligrams per litre for shallow lakes and 0.90 milligrams per litre for deep lakes (summer mean values). These boundaries are based on dose-response curves with phytoplankton, using the upper 25th percentile of lakes that are in good status in terms of chlorophyll a to set the good-moderate status boundary value for the nutrients. This approach provides quite relaxed boundaries. For coastal waters, three physicochemical quality elements have recently been developed with good-moderate status boundaries that intend to support the biological quality elements. These are light conditions (transparency) supporting angiosperms, oxygen conditions in deep waters supporting benthic fauna and inorganic nitrogen supporting phytoplankton in nitrogen-limited waters. The boundaries appear to be appropriate to support good status, at least for oxygen and nitrogen. The transparency conditions quality element is difficult to judge, due to a special model used to set the boundaries. However, none of these have been used for classification in any of the coastal waters in the second RBMPs , according to the information reported to WISE. Large gaps remain for rivers, in particular for nutrients (phosphorus and nitrogen), turbidity, temperature and oxygen. For lakes, the most serious gaps are for transparency and oxygen in deep waters of deep lakes. Acidification parameters are less relevant in most Danish rivers and lakes, as they have moderate or high alkalinity and are not vulnerable to acidification. Selection of River Basin Specific Pollutants and use of Environmental Quality Standards The selection of River Basin Specific Pollutants is based on monitoring results, screening of pollutants in the aquatic environment, and information on the use of substances. Environmental Quality Standard values were reported for water for 10 River Basin Specific Pollutants in Denmark as a whole: nine in rivers and three in lakes; as well as two in biota in coastal waters . The standards have been derived in accordance with the 2011 Technical Guidance Document No 27. Use of monitoring results for classification The basis for the classification of the individual quality elements is illustrated in Figure 3.9 . Overwhelmingly the results from monitoring have been used in the classification of ecological status/potential of quality elements. Expert judgment was used for phytoplankton for some coastal water bodies in particular in the Bornholm RBD where the one water body had not been directly monitored. Benthic invertebrates and phytobenthos were not used in the classification of lakes, phytobenthos was not used in rivers , and macroalgae were not used in coastal waters. Hydromorphological and physicochemical quality elements were not used in the classification of any surface water body . River Basin Specific Pollutants were used but only in a few river and lake water bodies (<0.5% in each). Denmark reported that grouping of water bodies has been used for the classification of water bodies with no monitoring sites. However, this is inconsistent with other reported information, which indicated that there were no water bodies classified based on grouping.

Figure 3.9 Basis of the classification of ecological status/potential in Denmark Source: WISE electronic reports. Denmark subsequently clarified that coastal waters that were classified based on grouping were reported in WISE as based on expert judgement. For rivers, it is reported that some water bodies are classified based on grouping, and therefore the number of classified water bodies for biological quality elements is higher than the number of water bodies monitored. But Denmark has indicated in Annex 0 that it is not possible to report the surface water bodies which have been monitored and used in grouping due to aggregation of river water bodies from first to second RBMPs. River water bodies grouped cannot be individually identified, including those that have been monitored. The RBMPs indicate that only monitored water bodies are classified for rivers and lakes. Both recent (2008-2013) and older monitoring data are used if they are considered by the national WFD Authority (D