COMMISSION STAFF WORKING DOCUMENT Report on the implementation of the Water Framework Directive River Basin Management Plans Member State: GREECE Accompanying the document COMMUNICATION FROM THE EUROPEAN COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL The Water Framework Directive and the Floods Directive: Actions towards the 'good status' of EU water and to reduce flood risks
Date: 2015-03-09
Institutions: European Commission
Subjects: Greece, chemical product, environmental risk prevention, flood, groundwater, hydrology, operational programme, pollution from agricultural sources, prevention of pollution, quality of the environment, surface water, water management













EUR-Lex - 52015SC0054 - EN











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52015SC0054

COMMISSION STAFF WORKING DOCUMENT Report on the implementation of the Water Framework Directive River Basin Management Plans Member State: GREECE Accompanying the document COMMUNICATION FROM THE EUROPEAN COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL The Water Framework Directive and the Floods Directive: Actions towards the 'good status' of EU water and to reduce flood risks /* SWD/2015/0054 final */









TABLE
OF CONTENTS
1.     General information.. 4
2.     Status of River Basin Management Plan reporting and compliance. 7
3.     Governance. 9
3.1        Timeline
of implementation. 9
3.2        Administrative
arrangements - river basin districts and competent authorities. 9
3.3        RBMPs -
Structure, completeness, legal status. 10
3.4        Consultation
of the public, engagement of interested parties. 11
3.5        Cooperation
and coordination with third countries. 11
3.6        Integration
with other sectors. 13
4.     Characterisation of river basin districts. 14
4.1        Water
categories in the RBD.. 14
4.2        Typology
of surface waters. 14
4.3        Delineation
of surface water bodies. 15
4.4        Identification
of significant pressures and impacts. 16
4.5        Protected
areas. 21
5.     Monitoring.. 21
5.1        General
description of the monitoring network. 21
5.2        Monitoring
of surface waters. 23
5.3        Monitoring
of groundwater. 24
5.4        Monitoring
of protected areas. 29
6.     Overview of status (ecological, chemical, groundwater) 31
7.     Assessment of ecological status of surface waters. 49
7.1        Ecological
status assessment methods. 49
7.2        Application
of methods and ecological status results. 54
8.     Designation of heavily modified water bodies (hmwb) and assessment
of good ecological potential  56
8.1        Designation
of HMWBs. 56
8.2        Methodology
for setting good ecological potential (GEP) 60
8.3        Results
of ecological potential assessment in HMWB and AWB. 60
9.     Assessment of chemical status of surface waters. 61
9.1        Methodological
approach to the assessment. 61
10.       Assessment of groundwater status. 63
10.1     Quantitative
status. 63
10.2     Groundwater
chemical status. 64
10.3     Protected
areas. 65
11.       Environmental objectives and exemptions. 67
11.1     Additional
objectives in protected areas. 67
11.2     Exemptions
according to Article 4(4) and 4(5) 67
11.3     Exemptions
according to Article 4(6) 70
11.4     Exemptions
according to Article 4(7) 70
11.5     Exemptions
to Groundwater Directive. 72
12.       Programmes of measures. 73
12.1     Programme
of measures – general. 73
12.2     Measures
related to agriculture. 75
12.3     Measures
related to hydromorphology. 79
12.4     Measures
related to groundwater. 82
12.5     Measures
related to chemical pollution. 83
12.6     Measures
related to Article 9 (water pricing policies) 84
12.7     Additional
measures in protected areas. 85
13.       Climate change adaptation, water scarcity and droughts, flood risk
management and other emerging and linked issues as part of the rbmp. 87
13.1     Water
Scarcity and Droughts. 87
13.2     Flood Risk
Management. 87
13.3     Adaptation
to Climate Change. 88
14.       RECOMMENDATIONS. 89

1.            
 General information

 
Figure
1.1:
Map of River Basin Districts
   ||   ||   || International River Basin Districts (within EU) 
   ||   ||   || International River Basin Districts (outside EU) 
   ||   ||   || National River Basin Districts (within EU) 
   ||   ||   || Countries (outside EU) 
   ||   ||   || Coastal Waters 
Source: WISE, Eurostat
(country borders)
Greece
has a population of 11 million[1]
with a high concentration in the Athens metropolitan area, and a total surface
area of 131,957
square km.[2] It is
located in the southern extremity of the Balkan peninsula in south-east Europe.
Its territory includes more than 2,000 islands in the Aegean and Ionian seas.
Mount Olympus is the highest point in the country.
Greece has 14
River Basin Districts (RBDs) (see Table 1.1. below). The two largest ones are
the Western Macedonia RBD (GR09) covering 13,585 km2 and the
Thessalia (GR08) covering 13,153 km2. Two of the RBDs, namely Aegean
Islands (GR14) and Crete (GR13) cover islands, while 6 more (Northern
Peloponese-GR02, Western Sterea Ellada-GR04, Epirus-GR05, Attica-GR06, Eastern
Sterea Ellada-GR07 and Thrace-GR12) cover both mainland and island areas. 
The following
overview is provided regarding the shared transboundary catchment with MS/third
countries (see Table 1.2 below):
§  With Albania:
Lake Prespa Basin (Part of Drin/Drim sub-basin) (GR09), Aoos/Vjosa River Basin
(GR05);
§  With Bulgaria:
Mesta-Nestos River Basin (GR12), Struma-Strymonas River Basin (GR11),
Maritsa-Evros-Meric River Basin (GR12), Axios/Vardar River Basin (GR10);
§  With the former
Yugoslav Republic of Macedonia: Lake Prespa Basin (Part of Drin/Drim sub-basin)
(GR09), Axios/Vardar River Basin including the Doirani Lake Basin (GR10),
Struma-Strymonas River Basin (GR11); and,
§  With Turkey:
Maritsa-Evros-Meric River Basin (GR12).
 RBD || Name || Size* (km2) || Countries sharing borders 
 GR01 || Western Peloponnese || 7,235 || - 
 GR02 || Northern Peloponnese || 7,418 || - 
 GR03 || Eastern Peloponnese || 8,442 || - 
 GR04 || Western Sterea Ellada || 10,432 || - 
 GR05 || Epirus || 10,007 || AL 
 GR06 || Attica || 3,139 || - 
 GR07 || Eastern Sterea Ellada || 12,268 || - 
 GR08 || Thessalia || 13,153 || - 
 GR09 || Western Macedonia || 15,218 || AL, FYROM 
 GR10 || Central Macedonia || 14,264 || BG, FYROM 
 GR11 || Eastern Macedonia || 7,320 || BG, FYROM 
 GR12 || Thrace || 11,242 || BG, TR 
 GR13 || Crete || 8,301 || - 
 GR14 || Aegean Islands || 9,118 || - 
Table 1.1: Overview of Greece’s
River Basin Districts
* Area in Greek territory
Source:
River Basin Management Plans reported to WISE[3]:
http://cdr.eionet.europa.eu/be/eu/wfdart13
 Name international river basin || National RBD || Countries sharing borders || Co-ordination category 
 2 || 3 || 4 
 km² || % || km² || % || km² || % 
 Lake Prespa (Part of Drin/Drim Sub-basin) || GR09 || AL, MK || 347 || 25.1 ||   ||   ||   ||   
 Aoos/Vjosa || GR05 || AL || 2,154 || 33.0 ||   ||   ||   ||   
 Mesta-Nestos || GR12 || BG || 2,429 || 42.3% ||   ||   ||   ||   
 Struma-Strymonas || GR11 || BG, FYROM || 6,295 || 36.5% ||   ||   ||   ||   
 Maritsa-Evros_Meric || GR12 || BG, TR || 3,345 || 6.3% ||   ||   ||   ||   
 Axios/Vardar || GR09 || FYROM, BG ||   ||   ||   ||   || 863 || 3.9 
 Axios/Vardar || GR10 || FYROM, BG ||   ||   ||   ||   || 1,636 || 7.3 
Table 1.2: Transboundary river
basins by category (see CSWD section 8.1) and % share in Greece[4].
Category 1: Co-operation agreement, co-operation body, RBMP in
place.
Category 2: Co-operation agreement, co-operation body in place.
Category 3: Co-operation agreement in place.
Category 4: No co-operation formalised.
Source: EC Comparative study of
pressures and measures in the major river basin management plans in the EU.
Note: the area figures
(km2) refer to the actual hydrological catchment of the respective
river (i.e. not the RBD area, nor the respective WFD river basin area which
both contain additional small catchments grouped with the actual river catchment)

2.            
Status of River Basin Management Plan reporting
and compliance 

At the time of drafting the current
report, Greece had adopted 12 RBMPs  (GR01, 02, 03, 04, 05, 06, 07, 08, 09,
10,11, 12), which have also been fully reported in WISE (along with the
accompanying Annexes) and thus the current report only considers those (see
Table 2.1 below). In late 2014, in the context of a bilateral meeting between
Commission Services and Greek authorities, some additions and corrections to
specific tables of this report were provided, which have been incorporated. 
The drafting of the RBMPs was
commissioned to different consultants and coordinated by the Ministry of
Environment, Energy and Climate Change – Special Secretariat for Water (EGY)
assisted by a “coordinator consultant”. A general national approach has been
followed, yet it is evident that RBMPs’ implemented approaches and structures
present commonalities within the plans assigned to the same consultant, and
differences across the background documents (Annexes) of the plans assigned to
different consultants. Thus, the following groups can be observed: GR01/02/03,
GR04/05/08, GR06/07, GR09/10, GR11/12. The role of the “coordinator consultant”
was to support the EGY and provide expertise and guidelines (also in the form
of guidance documents, which were nevertheless not officially published) for
the streamlining and harmonisation of the process. 
One of the main shortcomings of the
Greek RBMPs is that they have been delayed due to a number of factors which relate
to technical issues, as well as legislative and administrative barriers and
socio-economic constraints. Consequently, time to implement the suggested
Programme of Measures (PoMs) by 2015 and revise the plans for the second WFD
cycle (considering and embedding the effects of the measures) is very tight.
Nevertheless EL has specified that implementation of a great number of measures
included in the PoMs had started before the approval of the RBMPs (detailed
information on this aspect is reported by EL to be available in the
PoM-Implementation Progress Report – national level, due in December 2012 but
submitted to the COM in late 2014, and uploaded on WISE on 22.01.2015; the
contents of that Progress Report has not been assessed yet and therefore is not
taken into account in this report). 
Another significant problem with the
RBMPs was the lack of WFD-compliant data. The information used for the various
assessments was based on the old monitoring network which was obsolete (with
regard to the WFD required data) and the time-series fragmented and incomplete.
Thus, the embedded uncertainty in the characterisation is judged significant,
and in some cases it is not transparent how water bodies have been classified
as “good” status (given the lack of complete information), as opposed to
“unknown” status, since the characterisation is based on limited data and
assumptions. 
The new National Monitoring Programme
(NMP), according to the WFD requirements, has been established late in the
process (in 2012) and it is mentioned that it will furnish the necessary data
for the revision and update of the RBMPs in the second cycle. Yet,
the RBMPs have proposed some modifications with regard to the sites and
parameters of the NMP based on their current findings, which essentially
resulted from the new typology using system B (as opposed to the original
typology using system A back in 2011 when the NMP was designed, see section 5.1
below). These suggestions have not been taken up yet by the Special Secretariat
for Water, and would in some cases require additional financial resources (i.e.
when supplementary sites are proposed). It is stated by EL that the NMP will
be updated for the planning period 2016-2021, taking into account all available
data and information from the RBMPs and of course the proposed modifications in
each RBD. After the adoption of the RBMPs for all of the country’s RBDs and a
cost-effectiveness analysis in relation to the financial resources already
allocated for the planning period 2016-2021, the Special Secretariat for Water
will propose a new updated National Monitoring Network to be consulted on with
all involved national and regional authorities, within 2015. The new updated
National Monitoring Network will be defined in an amendment of the JMD 140384/9-9-2011.
With regard to harmonisation and common
approaches across the RBMPs, a national coordination programme was in place,
yet it is not clearly reflected that all RBMPs implemented exactly the same
approaches (e.g. on issues with small water bodies, definition of
“significance” of pressures, assessment of groundwater quantitative status)
when reading the WISE summary reporting and the Annexes. The Annexes themselves
are very different in structure and content (for the same topics) which
confuses the reader. A common structure and content across the RBMPs’ Annexes
would have increased transparency and understanding. 
Finally, a common approach to ensure
adequate incentives for efficient use and an adequate contribution from
different users was not in place (Art. 9). Moreover, economic analysis varied
across the RBMPs, partly due to missing information. It is planned that the
methodologies for the economic analysis will be increasingly harmonised in the
second and future cycles of review of the RBMPs.
An
important strength for the Greek RBMPs is that all underwent strategic
environmental assessment (SEA). Another added value is the parallel development
of a Drought & Water Scarcity Management Plan (DMP) for each RBD. In most
cases the specific sub-units or specific river basins are looked at separately.
Quantity issues are discussed in the RBMPs and some measures related to
quantity management have been identified in the PoMs. The links between the
RBMPs and the DMPs should be further strengthened and the DMPs should be
further developed into fully operational plans complementing the RBMPs.
 RBD || RBMP Date of Adoption || RBMP Date of Reporting* 
 GR01 || 08/04/2013 || 13/09/2013 
 GR02 || 08/04/2013 || 13/09/2013 
 GR03 || 08/04/2013 || 13/09/2013 
 GR04 || 18/09/2014 || 05/12/2014 
 GR05 || 04/09/2013 || 28/01/2014 
 GR06 || 08/04/2013 || 05/09/2013 
 GR07 || 08/04/2013 || 05/09/2013 
 GR08 || 18/09/2014 || 05/12/2014 
 GR09 || 30/01/2014 || 25/09/2014 
 GR10 || 30/01/2014  || 25/09/2014 
 GR11 || 04/09/2013 || 19/03/2014 
 GR12 || 04/09/2013 || 12/02/2014 
 GR13 || Pending ||   
 GR14 || Pending ||   
Table 2.1: Adoption and reporting
to the Commission of Greece’s RBMPs.
Source:
RBMPs and CDR. *Latest date of WISE reporting including all annexes and
background documents.

3.            
 Governance
3.1        
Timeline of implementation

The dates of
publication of RBMP preparatory documents are provided in Table 3.1.1 below;
these are behind the due dates set in Art. 14 of the WFD.
 RBD || Timetable || Work programme || Statement on consultation || Significant water management issues || Draft RBMP || Final RBMP 
 Due dates || 22/06/2006 || 22/06/2006 || 22/06/2006 || 22/12/2007 || 22/12/2008 || 22/12/2009 
 GR01 || 05/04/2013 || 05/04/2013 || 05/04/2013 || 05/04/2013 || 05/04/2013 || 08/04/2013 
 GR02 || 05/04/2013 || 05/04/2013 || 05/04/2013 || 05/04/2013 || 05/04/2013 || 08/04/2013 
 GR03 || 05/04/2013 || 05/04/2013 || 05/04/2013 || 05/04/2013 || 05/04/2013 || 08/04/2013 
 GR04 || 01/11/2011 || 01/02/2012 || 05/04/2013 || 04/09/2013 || 30/10/2013 || 18/09/2014 
 GR05 || 01/11/2011 || 01/02/2012 || 05/04/2013 || 04/09/2013 || 04/09/2013 || 04/09/2013 
 GR06 || 30/08/2010 || 13/04/2011 || 03/05/2012 || 13/01/2012 || 03/05/2012 || 08/04/2013 
 GR07 || 30/08/2010 || 13/04/2011 || 03/05/2012 || 13/01/2012 || 03/05/2012 || 08/04/2013 
 GR08 || 01/11/2011 || 01/02/2012 || 05/04/2013 || 04/09/2013 || 30/10/2013 || 18/09/2014 
 GR09 || 15/06/2011 || 27/04/2012 || 30/07/2012 || 30/07/2012 || 01/02/2013 || 30/01/2014 
 GR10 || 15/06/2011 || 27/04/2012 || 30/07/2012 || 30/07/2012 || 01/02/2013 || 30/01/2014 
 GR11 || 30/08/2010 || 09/08/2010 || 15/10/2011 || 18/11/2011 || 07/05/2012 || 04/09/2013 
 GR12 || 30/08/2010 || 09/08/2010 || 15/10/2011 || 18/11/2011 || 07/05/2012 || 04/09/2013 
 GR13 || - || - || - || - || - || Pending 
 GR14 || - || - || - || - || - || Pending 
Table 3.1.1: Timeline of the
different steps of the implementation process
Source: WISE (for all columns except
“Final RBMP”) and DG Environment web page: http://ec.europa.eu/environment/water/participation/map_mc/countries/greece_en.htm
(for “Final RBMP” column).

3.2        
Administrative arrangements - river basin
districts and competent authorities

At a decentralised level, Greece is
managed by 7 Decentralised Administrations, 13 self-governed Regions, and 325
Municipalities. This restructuring of the decentralised state structure in
Greece (called “Kallikratis”) was implemented in 2010 and has created some
confusion regarding the roles and functioning of various state institutions and
difficulties on various topics including water management. 
With regard to the development of the
RBMPs, the national competent authority is the "Special Secretariat for
Water" (under the Ministry of Environment, Energy and Climate Change),
based on the Presidential Decree 24/2010 OJ A 56/15.04.2010 and Law 3199/2003, which
has the following responsibilities: coordination of water management issues;
implementation of the WFD; monitoring of water quality and quantity; management
and reuse of wastewater; floods management. Furthermore, the main competencies
of the Secretariat are described in WISE 1.1. The decentralised administrations
(Regional Water Directorates) are responsible for the river basin districts.
However, for the first round of the RBMPs they signed off their responsibility
for the drafting of the plans to the EGY, but they were involved and
contributed to the final formulation of the PoMs at the regional level; they
are the ones responsible for implementing the plans. The RBMPs specifically
state that “the RBMPs of Greece are developed under the responsibility of the
competent authorities for each RBD. Based on a request by their Secretaries,
the Special Secretariat for Water took over the development of the RBMPs, which
then were commissioned to consultants”. Nevertheless, other authorities
including regional, municipal, and local authorities from other sectors have
contributed under topics of their expertise and interest.
Finally, in the relevant Annexes on
those “responsible for specific aspects of water management”, long lists of
additional authorities are presented showing how complex the overall setup is.
With regard to the main next steps and difficulties, the RBMPs mention that
many of the “responsible authorities” at the regional level are not
sufficiently staffed, so they are in danger of not fully covering their
responsibilities. Additionally, the fact that the RBMPs were commissioned to
consultants may have limited the Regional Water Directorates’ opportunities to
gain further insight into WFD issues and experience. Capacity building has
nevertheless been undertaken through seminars organised by the EGY.
As mentioned above, the drafting of the
RBMPs was commissioned to different consultants and coordinated by the EGY. A
general national approach has been followed. There are some differences in
terms of the methodologies and available data that were used among the
different groups of the consultants e.g. the GR01/02/03 plans were compiled by
one team, the GR04/05/08 plans by another, GR06/07 plans by a third team,
GR09/10 plans by a fourth and GR11/12 plans by a fifth. However, as the Special
Secretariat for Water coordinated all the teams there are several common
specifications. There were no main changes announced or implemented after the
submission of the RBMPs (corrections dealt with clarifications or typos).

3.3        
RBMPs - Structure, completeness, legal status

In general the structure of the RBMPs
follows the specifications of the WFD. In terms of clarity there are certain
issues regarding the implementation of the methodology that is described in the
relevant chapters of the RBMPs. In some cases it is not very clear whether and
how a specific methodology, e.g. for assessing the water bodies, is applied.
The different RBMPs have the same structure and content, but are accompanied by
numerous Annexes, and harmonisation of structure and content is missing across
them, thus confusing the assessment. In terms of completeness, it is explicitly
mentioned on several occasions that there was insufficiency of available data
and supporting studies/surveys for the assessment of water bodies. It is
mentioned that in cases where no data were available, the assessment was done
through expert judgment and/or through grouping of water bodies with similar
types and levels of pressures, and thus the level of uncertainty was characterised
as large. An improvement of the data quality and the water bodies’ assessment
can only be addressed through the implementation of the National Monitoring
Program that was defined with the Common Ministerial Decree 140384/9-9-2011. It
was originally foreseen that the new network programme would provide the first
monitoring results at the end of 2013. This new data would be used to improve
the knowledge of the water bodies’ status and thus the completeness of the
RBMPs in the next cycle.  No links to any international plans are referenced
within the RBMPs.
Out of the 14 RBMPs, 12 of them have
been approved and embedded into the National Law, while the remaining 2 are in
the process of compilation and consultation. For the approved RBMPs the
relevant Strategic Environmental Assessments/Environmental Impact Assessments
(SEA/EIAs) have been approved as well and are publicly available. The 12
officially approved RBMPs should implement the Programmes of Measures in the
following very short period as the second round of revised Plans should be
submitted by 2015, according to the WFD, taking into account the implementation
of the first RBMPs.

3.4        
Consultation of the public, engagement of
interested parties

Regarding the RBMPs of GR01/02/03/09/10
there was a critical assessment expressed in a rather “positive” way about most
consultation activities (in WISE 1.3.6), mentioning that: “Unprecedented for
the Greek situation was the less than expected participation of the public”. A
“results of the participation” document was submitted along with the relevant
RBMPs. Regarding the consultation procedures, in the RBMPs of
GR04/05/06/07/08/11/12, the consultation document does not refer to the
activities that took place, but is a “planning document” for the activities that
should/would take place. According to WISE 1.3.6, the main activities include:
(a) publication and commenting of the public participation plan, involved
stakeholders, Significant Water Management Issues report; (b) publication and
commenting of the RBMP; (c) publication and commenting of the SEA/EIA; (d)
informational meetings and (e) 39 stakeholder conferences/workshops (attended
by 3,500 participants in total as stated by the EGY). Moreover the EGY has set
up an interactive internet site http://wfd.ypeka.gr
where the full content of the RBMPs is available and which facilitated the
submission of comments by interested stakeholders. The
consultation can be assessed as adequate but “improvable” in terms of
stakeholders’ participation (almost 450 written comments/interventions were
received through questionnaires and the consultation website) and input.
It is difficult to describe the impact
of the consultation on the final plans, since the document “results of the
participation” was not submitted (however it is reported by EL as available in
the EGY). A “general list of comments was received” during the consultation
workshops but it cannot be inferred from the RBMP itself whether these comments
were actually taken under consideration and were incorporated in the newer
RBMPs version. It is stated by the EGY that they have been considered and
incorporated. Most of the comments originated either from the scientific
community or from other institutions, organisations, etc. 
There was no active continuous
involvement of stakeholders and the general public but rather limited
participation in certain consultation workshops. In general the consultation
can be assessed as not very successful in terms of stakeholder participation
and input. 

3.5        
Cooperation and coordination with third
countries

For GR05 there has not been
international coordination on public participation and active involvement of
interested parties. In practice, in Albania (where the Aoos River Basin
extends), the decisions of the National Water Council (NWC) and the respective
local authorities have not been implemented; thus the competent national and
local authorities do not fully operate. Both in WISE and in the RBMP there is
no specific reference to existing or planned coordination on public
participation[5]. 
For GR09, one part of the
Prespa Basin and a sub-basin of Axios River extend geographically in the
neighboring countries of FYROM and Albania; thus these basins are
transboundary. However, there are no International RBMPs, as these countries
are not EU MS; and thus not obligated to submit these Plans. Regarding the
Axios River Basin, there is no border co-operation established for the
integrated water resources management. Regarding the Prespa Basin there has
been an international agreement between the three countries (Greece, Albania
& FYROM) on the protection and sustainable development of the Prespa
National Park. Additionally, a Coordination Commission was formed for the
protection of the Park on 27/11/2009 and an International Agreement was signed
on 02/02/2010 among the Ministers of Environment of the three countries and the
EC Commissioner for the Environment. Furthermore, there has been recent
mobility in international cooperation regarding the integrated water resources
management in cross-border areas on 25/01/2012, followed by further meetings in
June 2012 and May 2013 (both for Prespa and Axios Basin). Several actions and
programmes have been implemented in the sub-basin of Prespa with the
cooperation of Albania and FYROM. Also a working group has been established
from 2006 for the monitoring and protection of the Prespa Basin. This group has
organised four (4) meetings so far.
For GR10, one part of the Strimonas
River Basin extends geographically in the neighboring country of Bulgaria, thus
this basin is a transboundary one. However, there has not been an International
RBMP, as Bulgaria had already submitted its RBMP to the EC before Greece. Thus,
for the first round of the Plans, these are separate for the two countries.
However, since 27th July 2010, there has been a common Announcement
of the two responsible Ministries (i.e. the Hellenic Ministry of Environment,
Energy and Climate Change and the Bulgarian Ministry of Environment and Water
Resources). The Announcement confirmed the intention of the two countries to
cooperate in the water resources management issues in the transboundary basins.
For this purpose, the Joint Expert Working Group was established. The Group
initially met in Drama on 16th May 2011, in Sofia on 12th
October 2011 and in Thessaloniki on 23rd April 2013. Recently there
has been a Joint Declaration of the competent Ministers of Greece and Bulgaria
regarding the intention of cooperation between the two countries on issues of
transboundary basin management.
For GR11 and GR12 there has been no
international coordination on public participation and active involvement of
interested parties, as Bulgaria submitted its RBMP to the EC before Greece,
while Turkey is not a MS and thus not obligated to submit Plans. For GR05/11/12
there have not been any international RBDs designated and no international
RBMPs adopted. For GR11, in spite of the
fact that there has not been full international coordination between Greece and
Bulgaria, from 27th July 2010, there has been a Joint Declaration
between the Hellenic Ministry of Environment, Energy and Climate Change and the
Bulgarian Ministry of Environment and Water Resources regarding the use of
water resources in the territories of shared river basins. The Joint
Declaration confirmed the intention of the two countries to cooperate in the
water resources management issues in the transboundary basins. For this
purpose, the Joint Expert Working Group was established; the Group initially
met in Drama on 16th May 2011, then in Sofia on 12th
October 2011, in Thessaloniki on 23rd April 2013 and in Athens on 8th
May 2014. As regards the public participation there has been no international
coordination between the two countries. For
GR12, in spite of the fact that there has not been full international
coordination between Greece, Bulgaria and Turkey, regarding the cooperation
with Bulgaria, there has been a series of negotiations that started in 1965 and
resulted in an Agreement between Greece and Bulgaria that was signed in 1995,
certified with the Greek Law 2402/96, Government Gazette (GG/A/98) and has 8
Articles. As with GR11, the cooperation of the two countries was enhanced on 27th
July 2010 with the Joint Declaration of the two responsible Ministries (see
further details above). Additionally, regarding the cooperation with Turkey, an
Ad Hoc Joint Committee has been established in November 2010 in respect to
cooperation issues for the Evros River Basin. The Committee initially met on 30th
May 2011. In this framework, the Joint Expert Working Group was established in
order to exchange data and information for the Evros River and the relevant
sub-basins in Greece and Turkey. The Joint Expert Working Group has met twice,
in Adrianoupolis on 24th June 2011 and in Alexandroupolis on 8th
September 2011. It should also be mentioned that both the Greek and the Turkish
sides give a great deal of emphasis on a common management response to the
flood issues of Evros, a subject of Greek terms associated with the
implementation of the corresponding Directive 2007/60/EC on flood risk
management in the EU. As regards the public participation there has been no
international coordination between the interested countries.

3.6        
Integration with other sectors

The links with
10 national sectoral plans were analysed in the SEAs which accompanied the
RBMPs (e.g. National Plan for Rural Development 2007-2013). The Directorate for
Spatial Planning and the Ministry of Rural Development were among the
stakeholders that have sent written comments on RBMPs and the respective SEAs.
There are some cases, such as the regional development plans, which are in the
process of compilation and might have been linked or used information from the
approved RBMPs but this is not currently established, as these plans are not
fully completed yet. No links with agricultural plans are apparent in the
RBMPs. 

4.            
Characterisation of river
basin districts
4.1        
Water categories in the RBD

The RBDs reviewed in the current report
include all water systems and their classification into four categories
according to the requirements of the WFD (rivers, lakes, transitional and
coastal waters, groundwater). According to Annex II of the WFD, categorisation
of surface water bodies apart from the four above categories include the
identification of Heavily Modified Water Bodies (HMWB) as well as artificial
water bodies (AWB). 

4.2        
Typology of surface waters

The Presidential Decree 51/2007
“Establishment of measures and procedures for integrated protection and
management of water in compliance with the provisions of the Water Framework
Directive 2000/60/EC” defines in Annex II that both systems A and B could be
used in the characterisation of surface water bodies. In the Greek RBMPs,
system B has been applied for all the water categories. It is to be noticed
that previously, in 2009, in response to the obligations of Art. 8 of the WFD,
system A was used. In the current RBMPs there was a switch to system B (all
obligatory descriptors for system B have been used), which resulted in the
modification of the number, boundaries and characteristics of the surface water
bodies.
Overall the surface water typology has
been validated with biological data. For river water bodies it was based solely
on benthic macroinvertebrates, for lakes on phytoplankton and for coastal and
transitional water bodies on macroinvertebrates, phytoplankton and macroalgae.
In general, reference conditions have been established for each of the surface
water types with the exception of the transitional waters where the work on
reference conditions is at an early stage and the information provided so far
is indicative until intercalibration is finalised. The methodology used was
based both on spatially based methods, as well as on expert judgement. It is
unclear from the RBMPs and Annexes (provided as background documents) how much
expert judgement was used. In terms of a national Guidance Document, guidelines
were formulated by the coordinator consultant and the General Secretariat for
Water to guide and harmonise the work and methodological approach of all other
consultants who were commissioned with the drafting of the RBMPs, but these
were not organised into a detailed guidance document.
The
number of surface water types that have been defined in different water
categories is summarised in Table 4.2.1. 
 RBD || Rivers || Lakes || Transitional || Coastal 
 GR01 || 6 || 1 || 2 || 1 
 GR02 || 6 || 4 || 2 || 1 
 GR03 || 5 || 1 || 2 || 1 
 GR04 || 8* || 3* || 2* || 1* 
 GR05 || 8 || 3 || 2 || 1 
 GR06 || 1 || 1 || 0 || 1 
 GR07 || 5 || 1 || 1 || 1 
 GR08 || 8* || 2* || 0* || 1* 
 GR09 || 10 || 4 || 2 || 1 
 GR10 || 7 || 4 || 2 || 1 
 GR11 || 6 || 2 || 1 || 1 
 GR12 || 7 || 2 || 2 || 1 
 GR13 ||  No data reported in WISE 
 GR14 ||  No data reported in WISE 
Table 4.2.1: Surface water body types at RBD level
Source: WISE; * corrections/additions provided by EL late 2014. 

4.3        
Delineation of surface water bodies

The river delineation process excluded
from the first step ephemeral streams, where 95% of the time there is no
presence of water in them and neither is any aquatic environment present. After
this exclusion the initial water bodies selection was performed on the basis of
the Strahler stream classification index. Only streams of the 4th
order and above are initially included in the set. This initial set is
considered by definition to be comprised of “important and discrete” elements
of surface water, but not including all such elements. Additional water bodies
(which were initially excluded due to their ephemeral flow) were then added to
this initial set if deemed important elements in terms of aquatic ecosystem and
fish population. This assessment of importance of these small water bodies was
made almost exclusively based on expert judgment of scientists from the
Hellenic Centre for Marine Research (HCMR) taking into account biological data
(fish and benthic invertebrates) where available. In the RBMPs it is mentioned
that an investigation was undertaken into whether small water bodies can be
aggregated with adjacent water bodies (aggregation was performed where feasible
and essential). Finally, further additions were made during the consultation
process where some additional streams to be included were indicated by local officials
and scientists. For example, in the RBMP of GR11 it is stated that during the
public consultation, objections were raised with regards to the inclusion of
some small water bodies with ephemeral flow in the sub-catchment of the Aggitis
River, and thus the necessary adjustments were then performed to exclude them.
The above clarifications were provided
by EL since it does not clearly appear from the RBMPs’ Annexes how the
inclusion/exclusion of small water bodies has actually been implemented (i.e.
the specific criteria for defining what is termed as an “important” element of
water/ aquatic ecosystem are not clear in the RBMPs; the information on which
small water bodies have been joined with adjacent ones, or not joined, and/or
not considered is not obvious).
In the case of lakes, all lakes with a
size greater than 0.5 km2 have been considered as surface water
bodies.
 RBD || Surface Water || Groundwater 
 Rivers || Lakes || Transitional || Coastal 
 Number || Average Length (km) || Number || Average Area (sq km) || Number || Average Area (sq km) || Number || Average Area (sq km) || Number || Average Area (sq km) 
 GR01 || 110 || 8 || 2 || 2 || 5 || 1 || 11 || 95 || 26 || 262 
 GR02 || 63 || 11 || 6 || 5 || 9 || 2 || 19 || 127 || 26 || 284 
 GR03 || 80 || 7 || 1 || 1 || 6 || 1 || 13 || 206 || 27 || 299* 
 GR04 || 102* || 10* || 5* || 26* || 4* || 68* || 8* || 273* || 25* || 410* 
 GR05 || 85 || 13 || 1 || 19 || 7 || 59 || 13 || 81 || 26 || 349 
 GR06 || 14 || 9 || 1 || 3 || 0 || - || 14 || 288 || 24 || 129 
 GR07 || 81 || 13 || 3 || 12 || 1 || 18 || 19 || 339 || 46 || 268 
 GR08 || 74* || 19* || 1* || 35* || 0* || 0* || 7* || 134* || 32* || 392* 
 GR09 || 150 || 10 || 14 || 39 || 2 || 20 || 2 || 564 || 62 || 275 
 GR10 || 104 || 11 || 6 || 28 || 3 || 23 || 11 || 350 || 39 || 348 
 GR11 || 91 || 9 || 2 || 24 || 1 || 7 || 4 || 183 || 15 || 456 
 GR12 || 188 || 10 || 6 || 4 || 5 || 56 || 12 || 61 || 18 || 578 
 GR13 || - || - || - || - || - || - || - || - || - || - 
 GR14 || - || - || - || - || - || - || - || - || - || - 
 Total || 1142 || 11 || 48 || 17 || 43 || 23 || 133 || 225 || 366 || 338 
Table 4.3.1: Surface water bodies,
groundwater bodies and their dimensions 
Source: WISE; * corrections/additions
provided by EL late 2014. 

4.4        
Identification of significant pressures and
impacts 

Even though in certain RBDs limited
information on methods for defining significant pressures is available, the
WISE summary report shows that determination of significant pressures has been
made for all of the RBDs. Table 4.4.1 gives an overall picture of the
significance of the different pressures within the country. These data indicate
that diffuse pollution is assessed as the most significant pressure in Greece,
affecting 63% of surface water bodies (802 SWBs) followed by point source
pollution which affects 45% (520 SWBs). “Other pressures” affect 17% (228
SWBs), and surface water abstraction affects 6% (74 SWBs) of surface water
bodies. Additionally, pressures such as water flow regulations and
morphological alterations, other morphological alterations and river management
are allocated smaller percentages, i.e. 3% (42 SWBs), 0.3% (4 SWBs), and 1% (14
SWBs) respectively.
An explicit identification of the
criteria used to determine the significance of pressures is not apparent in all
the RBMPs, yet EL clarified that criteria (and the related thresholds) for
individual pressures (point and diffuse pollution, and water abstraction) were
identified from the limits contained in other relevant Directives, studies and
research results found in literature, and expert judgement as being likely to
impact on water status.
Regarding point source pollution, some
RBMPs (such as GR11/12) refer to the use of both numerical tools and expert
judgement in pressure analysis; however, they do not provide details on the
specific methods or criteria used. On the other hand, GR01/02/03/05/06/07/09/10
identify specific thresholds that define significant pressures from point
source pollution (e.g. in GR05 the significance of pressure from industrial units
was based on the criterion of the type, size and number of units that relate to
discharges of priority substances and were classified as follows: N≥5
(high), 1≤N<5 (medium), N=0 (low)).
Regarding diffuse source pollution most
RBDs (e.g. GR01/02/03/04/05/06/07/08/09/10) give a summary table of criteria
(related to type, size and pollution load) for all pressures, defining specific
levels of N, P and BOD concentrations as thresholds connected to diffuse
pollution (e.g. when BOD>10 mg/l, N>10mg/l and P >1mg/l the pressure
is defined as significant). 
Regarding abstraction pressures,
generally in all RBDs a description of the pressures considered and the
methodology followed is mentioned (a mixture of actual numbers and expert
judgement). Criteria for assessing the significance of the pressure are
available in GR01, GR02, GR03, GR04, GR06 (only relevant for groundwater
abstractions), GR07, GR08 GR09 and GR10. These criteria relate to the
assessment of water exploitation, abstraction volumes as percentage the natural
annual and summer runoff volumes.
Regarding water flow regulation and
hydromorphological alterations, overall all RBMPs describe these pressures and
a relevant analysis (a mixture of actual numbers and expert judgement), but
specific criteria to judge significance were not found in the background
documents. The most common hydromorphological pressures mentioned and analysed
among RBDs are: flood defence structures/dams, water reservoirs, modifications
and diversions, water transfers. 
Further information provided by Greek
authorities indicate that the criteria used are far from comprehensive because,
to a large extent, only main dams (higher than 15 m and considering also the
abstractions and the regulating capacity in relation to the river flow) have
been considered as significant hydromorphological pressure. It appears also
that the main impact that has been assessed is downstream of the dam, not
necessarily considering the water bodies where the dams are located and the
upstream effects. This approach potentially overlooks many smaller but
significant hydromorphological pressures. This is likely the reason for the
very low percentages of water bodies reported as affected by hydromorphological
pressures.  
As regards pollution loads, the main
conclusions for each RBD are summarised below:

 GR01: the greatest individual point
     source pollution load comes from industrial units. Important pollution is
     also produced from urban waste water, and notable BOD load is produced by
     aquaculture. 
 GR02/03: the greatest point source
     pollution burden comes from industrial units. Regarding diffuse pressures,
     livestock produces the largest amount of pollutants. 
 GR04: it is evident from the
     available data collected for point source pollution that the increased
     pressure on water bodies comes from the Acheloos basin (GR15). Significant
     point source pollution loads are mainly generated by the industrial units
     and the stabled livestock. The greatest effect from non-point source
     pollution seems to be related to the intense livestock activity in the
     region, as the organic load, the nitrogen and phosphorus load is estimated
     to contribute over 90%, 80% and 50% respectively, of the total load.
 GR05: Significant point source
     pollution loads are mainly generated by industrial units and stabled
     livestock. One of the major sources of non-point source pollution in the
     area relates to livestock and agriculture. In particular, the greatest
     effect is associated with intense livestock activity in the region, as the
     organic load, the nitrogen and phosphorus load is estimated to contribute
     more than 90%, 80% and 60% of the total load respectively.
 GR06: it was concluded that the
     main pollution load is generated by the intense industrial activity.
     Moreover, from the evaluation of quantitative estimates of diffuse sources
     of pollution it was concluded that surface runoff from cropland and
     livestock contribute significantly to pollution loads. The organic load
     due to untreated urban sewage contributes more than 60% of the total
     organic load (BOD t/year), while the effect of nitrogen and phosphorus
     load due to agricultural activity is greater (75% and 90% respectively). 
 GR07: the main pressures on surface
     water bodies come from the sectors of agriculture, industry and livestock.
     From the assessment of quantitative estimates of diffuse sources of
     pollution it can be concluded that surface runoff from agriculture and
     livestock contributes significantly to pollution loads. The organic load
     due to livestock contributes more than 78% of the total organic load,
     while the effect of nitrogen and phosphorus load due to agricultural
     activity is greater (84% and 95% respectively). 
 GR08: the increased pressure on the
     water bodies comes mainly from the river basin of Pinios from various
     activities (urban waste water treatment plants, livestock activity,
     industry, mining activities and uncontrolled dumpsites). Regarding the
     pollution load from diffuse sources (mainly from agriculture and stable
     livestock activity), the organic load and the nitrogen load resulting from
     livestock  is over 90% and 60% respectively, while greater is the
     influence of phosphorus load due to agricultural activity (about 70%). 
 GR09/GR10: industrial activity
     together with livestock and agriculture are the greater pressures within
     the water district. Quantitative estimates of diffuse sources show that
     the surface runoff from cropland and livestock contribute significantly to
     pollutant loads. The effect of nitrogen and phosphorus load due to
     agricultural activity is significant. It is worth mentioning that the
     concentration of organic load is generated mostly due to livestock
     activities, while nitrogen and phosphorus arise in farming and
     agriculture. The mining activity that relates to water pollution is
     located mainly in the region of Jerrissou, in the southeast of the water
     districts. 
 GR11/12: most of the pollution
     loads come from agriculture, livestock and urban waste.

 RBD || No pressures || Point source || Diffuse source || Water abstraction || Water flow regulations and morphological alterations || River management || Transitional and coastal water management || Other morphological alterations || Other pressures 
 No. || % || No. || % || No. || % || No. || % || No || % || No. || % || No. || % || No. || % || No. || % 
 GR01 || - || 0 || 88 || 69 || 128 || 100 || 10 || 8 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 32 || 25 
 GR02 || - || 0 || 48 || 49 || 97 || 100 || 18 || 19 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 39 || 40 
 GR03 || 2 || 2 || 63 || 63 || 98 || 98 || 4 || 4 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 37 || 37 
 GR04 || 53* || 44* || 54* || 45* || 41* || 34* || 11* || 9* || 17* || 14* || 5* || 4* || 4* || 3* || 0* || 0 || 53 || 44 
 GR05 || 44 || 42 || 46* || 42 || 44* || 41 || 11* || 9 || 8 || 8 || 0 || 0 || 5* || 5* || 0* || 0* || 44* || 42* 
 GR06 || 5 || 17 || 23 || 79 || 19 || 66 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 
 GR07 || 20 || 19 || 67 || 64 || 74 || 71 || 5 || 5 || 0 || 0 || 0 || 0 || 0 || 0 || 4 || 4 || 0 || 0 
 GR08 || 13* || 16* || 55* || 67* || 62* || 76* || 2* || 2* || 2* || 2* || 7* || 9* || 0* || 0* || 0* || 0* || 13* || 16* 
 GR09 || 115 || 68 || 28 || 17 || 25 || 15 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 
 GR10 || 51 || 41 || 26 || 21 || 67 || 54 || 1 || 1 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 
 GR11 || 40 || 41 || 17 || 17 || 52 || 53 || 10 || 10 || 6 || 6 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 
 GR12 || 114 || 54 || 5 || 2 || 95 || 45 || 2 || 1 || 9 || 4.27 || 2 || 1 || 0 || 0 || 0 || 0 || 10 || 5 
 GR13 || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - 
 GR14 || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - 
 Total || 457 || 29 || 520 || 45 || 802 || 63 || 74 || 6 || 42 || 3 || 14 || 1 || 9 || 1 || 4 || 0,3 || 228 || 17 
Table 4.4.1: Number and percentage of
surface water bodies affected by significant pressures
Source: WISE; * corrections/additions
provided by EL late 2014. 
Figure 4.4.1: Graph of percentage of
surface water bodies affected by significant pressures
1 = No pressures
2 = Point source
3 = Diffuse source
4 = Water abstraction
5 = Water flow
regulations and morphological alterations
6 = River management
7 = Transitional and coastal water management
8 = Other morphological alterations
9 = Other pressures
Source: WISE

4.5        
Protected areas

In Greece 1,615
protected areas have been designated, according to information provided to WISE
(see Table 4.5.1).  Just over half of these areas (57%) are for
bathing water, while 8% are for drinking water abstraction under Art. 7 of the
WFD. Another 10% are for habitats, birds and fish altogether, 6.5% are for
UWWTPs. With regard to the protected areas under Art. 7 abstraction for
drinking water, out of the total 131 protected areas 85 are for groundwater
(i.e. 65%) and the remaining 35% are for surface water.
 RBD || Number of PAs 
 Article 7 Abstraction for drinking water || Bathing || Birds || European Other || Fish || Habitats || Local || National || Nitrates || Shellfish || UWWT 
 GR01 || 5 || 50 || 2 ||   || 4 || 8 ||   || 8 ||   ||   ||   
 GR02 || 9 || 114 || 4 ||   || 6 || 15 ||   || 5 || 1 ||   ||   
 GR03 || 3 || 88 || 3 ||   || 4 || 7 ||   || 8 || 1 ||   ||   
 GR04 || 21* || 60* || 15* ||   ||   || 22* || 9* || 25* || 2* ||   || 12* 
 GR05 || 10 || 87 || 21 ||   ||   || 23 || 33 || 23 || 2 ||   || 6 
 GR06 || 4 || 125 || 4 ||   ||   || 5 ||   ||   || 3 ||   || 4 
 GR07 || 16 || 170 || 14 ||   ||   || 16 ||   ||   || 4 ||   || 11 
 GR08 || 7* || 67* || 16* ||   ||   || 13* ||   || 5* || 1* ||   || 2* 
 GR09 || 17 || 11 || 11 ||   || 6 || 22 ||   ||   || 2 || 2 || 23 
 GR10 || 4 || 84 || 9 ||   ||   || 15 ||   ||   || 1 || 4 || 6 
 GR11 || 15 ||  23* || 5 ||   || 2 || 7 ||   ||   || 1 || 4 || 14 
 GR12 || 20 || 36 || 14 ||   || 5 || 12 ||   ||   || 3 || 7 || 27 
 GR13 || - || - || - || - || - || - || - || - || - || - || - 
 GR14 || - || - || - || - || - || - || - || - || - || - || - 
 Total || 131 || 915 || 118 || 0 || 27 || 165 || 42 || 74 || 21 || 17 || 105 
Table 4.5.1: Number of protected
areas of all types in each RBD and for the whole country, for surface and
groundwater[6]
Source: WISE; * corrections/additions
provided by EL late 2014. 

5.            
Monitoring
5.1        
General description of the monitoring network

The monitoring programme for Greece has been defined
in the Common Ministerial Decree ΚΥΑ 140384/9-9-2011 while the
standards and minimum performance criteria of the analytical methods for the
chemical analysis and monitoring have been defined in the Common Ministerial
Decree 38317/1621/Ε103/2011. According to the Ministerial Decree
140384/9-9-2011, the EGY is responsible for: i) the submission of the annual
budget for the operation of the NMP to the Ministry, ii) the monitoring at
national level of the quantity and quality of surface and groundwaters in
cooperation with the Regional Water Directorates of the Decentralised
Administrations, iii) the development and operation of the national network/ grid.
At the time that the RBMPs were being drafted, the new WFD monitoring programme
was not operational. Thus, the monitoring data used for the characterisation of
the water bodies in the RBMPs were based on the old fragmented monitoring
network which had significant data gaps with regard to the WFD-required
assessment parameters. 
The new National
Monitoring Programme - NMP (established with the above mentioned Ministerial
Decree in 2011 and currently implemented from 2012 onwards) follows a common
national approach in terms of objectives, standards, definition of monitoring
points, responsible authorities, etc. The number, type and location of
monitoring stations per water body and the number, type and frequency of the
sampling parameters are listed in the Ministerial Decree. All these were
originally defined in 2009 in response to the obligations of Article 8 of the
WFD, considering the state-of-the-art knowledge at that time and the results of
a relevant study commissioned by the General Secretariat for Water (which also
defined the water bodies, pressures and impacts) and were updated and finalised
in 2010 in the framework of the national project “Development and application
of methods and software for the assessment of the water quality related data of
the Greek water bodies”.  A total of 616 monitoring stations for surface water
bodies are defined in the new programme for the whole territory, and 1,387 for
groundwater bodies. It is foreseen that the new network programme will be
updated periodically in order to better meet the systems’ needs based on the
first monitoring results (originally expected at the end of 2013) and the
findings of the current RBMPs. 
In the RBMPs the
typology used for the characterisation of the water bodies changed with regard
to the system that was used back in 2008-2009 (shifting from system A to system
B). This resulted in the modification of the number, boundaries and
characteristics of the water bodies, and the subsequent need to perform a new
matching between the established monitoring points of the Ministerial Decree
and the latest defined water bodies (in the RBMPs). The matching has been
performed, but also additional information from the neighbouring RBDs, the
water bodies’ grouping and the identified pressures and impacts has been
integrated and led to suggestions on modification of the new monitoring
programme to better serve its purpose. These suggestions are presented in all
the RBMPs and are basically grouped under three main categories: (i)
reallocation of the monitoring stations to neighbouring sites (e.g. upstream or
downstream in rivers); (ii) switching of monitoring stations from the
surveillance to the operational programme and vice-versa; (iii)
inclusion/exclusion of the sampling elements and/or changes in the frequency of
sampling. It is acknowledged in some RBMPs that these modifications (especially
category ii - additional sites) may be difficult to implement since they would
require additional funding, but categories i and iii are deemed feasible.
Figure 5.1: Maps of surface water
(left) and groundwater (right) monitoring stations
   || • ||   || River monitoring stations 
   || • ||   || Lake monitoring stations 
   || • ||   || Transitional water monitoring stations 
   || • ||   || Coastal water monitoring stations 
   || • ||   || Unclassified surface water monitoring stations 
   || • ||   || Groundwater monitoring stations 
   ||   ||   ||  River Basin Districts 
   ||   ||   ||  Countries outside EU 
Source: WISE, Eurostat
(country borders) 

5.2        
Monitoring of surface waters

As explained
above, the data used in the RBMPs originated from the old monitoring network,
which was not compliant with WFD requirements. The available data were
fragmented, with many gaps in parameters and time-series which restricted the
corresponding assessments in the RBMPs. The data of the old monitoring network
were provided by different agencies, mainly the Ministry for the Environment,
Energy and Climate Change, the Ministry of Rural Development and Food and the
General Chemical State Laboratory. Data from regional authorities and sample
monitoring from various existing surveys were also available in some cases. As
a result, based on quality assurance, completeness, accuracy, etc. the
following quality elements of the old monitoring system have been considered
overall for the classification of surface water bodies (yet not in all cases,
and not with continuous long time-series) in the current RBMPs:  
·        
BQEs:  benthic macroinvertebrates (for rivers);
phytoplankton (lakes); macroinvertebrates, phytoplankton and macroalgae
(coastal and transitional) –more details in section 7.
·        
Physico-chemical elements: transparency, thermal conditions, oxygen conditions,
salinity, acidification conditions and nutrient conditions –more
details in section 7.
·        
Hydromorphological elements: not clear if they
have been considered –more details in section 7.
·        
Priority substances and other specific
pollutants: Ni, Pb, Hg, Cd, Brominated diphenylether, Di(2-ethylhexyl)phthalate
(DEHP), Endosulfan, Hexachlorocyclohexane,
Chlorfenvinphos, Anthracene, Hexachlorobenzene, considered on a case-by-case
basis –more details in section 9.
In assessing the river
water bodies (in the current RBMPs), grouping was performed when there was no
monitoring station within a certain river water body (of the old network).
Groups have been formulated so that each group contains at least one river
water body which is being monitored. The grouping was based on the
hydromorphological characteristics of the rivers (biogeographical regions,
annual discharge, slope, altitude) as reflected in the water bodies’ typology,
as well as on the type and intensity of pressures that are identified in the
sub-catchment of the water body. The heavily modified and artificial water
bodies have been excluded from grouping and are considered individually even
when monitoring stations are not present in them.
With regard to the New
Monitoring Programme (established by the Ministerial Decree in 2011) it
includes both surveillance and operational monitoring programmes including all
relevant quality elements. A total of 616 monitoring
stations for surface water bodies are defined in the NMP for the whole
territory, of which 377 are for surveillance and 239 for operational
monitoring. Biological, physico-chemical and hydromorphological QEs are defined
to be monitored in all of them, priority substances in 326, specific pollutants
in 282 and other substances in 29 of them. The relevant
elements that are monitored per RBD are shown in Table 5.1 below as reported in
the WISE Summary Reports 4.1.7 and 4.1.8 and further corrected by EL in late
2014.
Few of the monitoring
stations are part of the International Network Barcelona
Convention/Mediterranean Action Plan (MEDPOL). A
detailed view of the programmes (surveillance & operational), station
locations, elements and frequencies foreseen to be monitored at each water body
is provided in the Annexes of the Ministerial Decree, and also on WISE - CDR
under the Art. 8 reporting (submitted 26.08.2009), and have been defined in the
document “Updated Report of Article 8 of the WFD including the catalogue of
elements and parameters to be monitored in each station of the NMP”. The
sampling and frequency methodologies are also mentioned there. With regard to
the methodologies for selecting the BQEs of the operational programme, the
priority substances and other pollutants, it is mentioned that these are
developed within the guidance documents of the research project “Development of
network and monitoring of the internal, transitional and coastal water bodies
of the country – Assessment/Classification of their ecological status” undertaken
by the HCMR-EKBY, 2008 (Hellenic Centre for the Marine Research – Greek
Biotope/Wetland Centre). As mentioned above, upon the establishment of the
RBMPs and their findings additional suggestions were made in the RBMPs
regarding modifications to the NMP (inclusion/exclusion of monitoring stations
and/or elements) to better accommodate the identified needs.

5.3        
Monitoring of groundwater

As explained
above, the data used in the RBMPs originated from the old monitoring network,
which was not compliant with the WFD requirements. The available data was
fragmented, with gaps in parameters and time-series which restricted the
corresponding assessments in the RBMPs. The data of the old monitoring network
were provided by different agencies, mainly the Institute of Geology and
Mineral Exploration, the Ministry for the Environment, Energy and Climate
Change, the Ministry of Development. Data from regional authorities and sample
monitoring from various existing surveys were also available in some cases. As
a result, based on quality assurance, completeness, accuracy, etc. the
following elements and parameters of the old monitoring programme have been
considered overall for the assessment of groundwater bodies (yet not in all
cases, and not with continuous long time-series) in the current RBMPs:
·        
Quantitative status:  abstraction per sector
(mostly estimated from water demands); water balance (comparison between
available groundwater resource by the long-term annual average rate of
abstraction), groundwater levels, spring discharges –more details in section
10.
·        
Chemical status: pH, conductivity, chloride,
nitrates, nitrogen dioxide, ammonium, sulphate. Pb, Cr, Ni, Al, Fe, Mg, Mn, B
were assessed in a subset of the groundwater bodies. The data series of heavy
metals (Pb, Cd, As, Hg) were not systematic – more details in section 10.
·        
No data were available for trichloroethylene and
tetrachloroethylene. Thus, these parameters have not been considered in the
assessments – more details in section 10.
Quantitative,
surveillance and operational monitoring programmes are included in the new
monitoring network (established with the Ministerial Decree in 2011). It
includes monitoring of quantitative status and the all chemical elements
considered relevant by the Greek authorities. A total
of 1,387 monitoring stations for groundwater bodies are defined in the NMP for
the whole territory, of which 294 are for surveillance and 1093 for operational
monitoring. Quantity and physico-chemical parameters are defined to be
monitored in all stations, nitrates in 867, heavy metals in 844, pesticides in
502, and composite compounds in 284 of them. A detailed
view of the programmes (quantitative, surveillance & operational), station
locations, elements and frequencies foreseen to be monitored at each groundwater
body are provided in the Annexes of the Ministerial Decree, and have been
defined in the document “Updated Report of Article 8 of the WFD including the
catalogue of elements and parameters to be monitored in each station of the
NMP”. The sampling and frequency methodologies are also mentioned there.
With regard to the
criteria for defining the monitoring stations of the operational programme the
following are listed:
(i)           
Availability of existing monitoring stations (of
the old networks) for which representative samples can be retrieved;
(ii)         
Possibility to support different programmes and
requirements of the Water Framework, Groundwater and Nitrates Directives (e.g.
monitoring of both quantitative and chemical elements, monitoring of nitrates
pollution, monitoring of drinking water areas);
(iii)       
Accessibility and capacity to achieve/support
the measurement of parameters on a long-term basis.
With regard to the
methodologies for selecting the parameters or elements of the operational
programme, it is mentioned that these are developed within the guidance
documents of the research project “Development of network and monitoring of the
internal, transitional and coastal water bodies of the country –
Assessment/Classification of their ecological status” undertaken by the
HCMR-EKBY, 2008 (Hellenic Centre for Marine Research – Greek Biotope/Wetland
Centre). As mentioned above, upon the establishment of the RBMPs and their
findings, additional suggestions were made in the RBMPs regarding modifications
to the NMP (inclusion/exclusion of monitoring stations and/or elements) to
better accommodate the identified need. 
 BD || Rivers || Lakes 
 QE1.1 Phytoplankton || QE1.2 Other aquatic flora || QE1.2.3 Macrophytes || QE1.2.4 Phytobenthos || QE1.3 Benthic invertebrates || QE1.4 Fish || QE1.5 Other species || QE2 Hydromorphological QEs || QE3.1 General Parameters || QE3.3  Non priority specific pollutants || QE3.4 Other national pollutants || QE1.1 Phytoplankton || QE1.2 Other aquatic flora || QE1.2.3 Macrophytes || QE1.2.4 Phytobenthos || QE1.3 Benthic invertebrates || QE1.4 Fish || QE1.5 Other species || QE2 Hydromorphological QEs || QE3.1 General Parameters || QE3.3 Non priority specific pollutants || QE3.4 Other national pollutants 
 GR01 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR02 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR03 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR04 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR05 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR06 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR07 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR08 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR09 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR10 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR11 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR12 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR13 || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - 
 GR14 || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - 
 RBD || Transitional || Coastal 
 QE1.1 Phytoplankton || QE1.2 Other aquatic flora || QE1.2.1 Microalgae || QE1.2.2 Angiosperms || QE1.3 Benthic invertebrates || QE1.4 Fish || QE1.5 Other species || QE2 Hydromorphological QEs || QE3.1 General Parameters || QE3.3 Non priority specific pollutants || QE3.4 Other national pollutants || QE1.1 Phytoplankton || QE1.2 Other aquatic flora || QE1.2.1 Microalgae || QE1.2.2 Angiosperms || QE1.3 Benthic invertebrates || QE1.4 Fish || QE1.5 Other species || QE2 Hydromorphological QEs || QE3.1 General Parameters || QE3.3 Non priority specific pollutants || QE3.4 Other national pollutants 
 GR01 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR02 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR03 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR04 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR05 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR06 || - || - || - || - || - || - || - || - || - || - || - ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR07 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR08 || - || - || - || - || - || - || - || - || - || - || - ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR09 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR10 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR11 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR12 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR13 || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - 
 GR14 || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - 
Table 5.1: Quality elements monitored[7]
   || QE Monitored 
   || QE Not monitored 
 - ||   || Not Relevant 
Source: WISE Summary Reports: 4.1.7 and
4.1.8. Note: EL provided an alternative formulation of this Table, but the
output from the Annexes and WISE have been used here.
 D || Rivers || Lakes || Transitional || Coastal || Groundwater 
 Surv || Op || Surv || Op || Surv || Op || Surv || Op || Surv || Op || Quant 
 GR01 || 17 || 19 || 1 || 0 || 0 || 2 || 4 || 0 || 27* || 59* || 86* 
 GR02 || 25 || 11 || 2 || 1 || 0 || 4 || 4 || 5 || 10 || 95* || 105* 
 GR03 || 12 || 10 || 0* || 0* || 0* || 0* || 3 || 2 || 13 || 113* || 126* 
 GR04 || 15* || 26* || 10* || 2* || 0* || 5* || 1* || 1* || 23* || 42* || 65* 
 GR05 || 32 || 5* || 3 || 1* || 0* || 6 || 2 || 5* || 19* || 71* || 90* 
 GR06 || 4 || 4 || 0 || 1 || 0* || 0* || 3 || 6 || 6 || 74 || 80 
 GR07 || 37 || 6 || 2 || 1 || 0 || 1 || 3 || 6 || 11 || 154* || 165* 
 GR08 || 24* || 33* || 2* || 0* || 0* || 0* || 4* || 1* || 33* || 61* || 94* 
 GR09 || 19 || 11 || 2 || 10 || 0 || 2 || 1 || 0 || 45* || 44 || 89* 
 GR10 || 22 || 4 || 1 || 4 || 0 || 2 || 3 || 2 || 5 || 108 || 113 
 GR11 || 26 || 10 || 1 || 1 || 0 || 1 || 1 || 0 || 16 || 35 || 51 
 GR12 || 36 || 4 || 2 || 3 || 0 || 8 || 3 || 1 || 26 || 53 || 79 
 GR13 || 21* || 5* || 1* || 2* || 0* || 0* || 5* || 1* || 36* || 76* || 112* 
 GR14 || 10* || 0* || 0* || 0* || 0* || 4* || 13* || 0* || 24* || 108* || 132* 
 Total by type of site || 300 || 148 || 27 || 26 || 0 || 35 || 50 || 30 || 294 || 1093 || 1387 
 Total number of monitoring sites || 448* || 53* || 35* || 80* || 1387* 
Table 5.2: Number of monitoring
sites by water category, in accordance with JMD 140384/09-09-2011
Surv =
Surveillance, Op = Operational, Quant = Quantitative
Source: WISE
*corrections/additions provided by EL
in late 2014. Some discrepancies between this information and the RBMPs/their
Annexes are observed.

5.4        
Monitoring of protected areas

Figure
5.2: Map of monitoring stations for protected areas
Source: WISE
In the NMP there are
monitoring stations located within protected areas and drinking water protected
areas (of the Birds, Habitats and Drinking Water Directives). Upon the
establishment of the RBMPs and their findings, suggestions were made to place
additional stations in more protected areas which are explicitly mentioned.
There is no detailed information in the RBMPs on specific monitoring programmes
(e.g. drinking water, bathing water) for the protected areas (i.e. name and
code of protected area, number and location of monitoring sites, specific
monitored parameters, etc.).
 RBD || Surface waters || Ground-water drinking water 
 Surface drinking water abstraction || Quality of drinking water || Bathing water || Birds sites || Fish || Habitats sites || Nitrates || Shell- Fish || UWWT 
 GR01 || 1* || 0 || 6* || 1* || 4* || 13* || 0 || 0 || 0 || 9* 
 GR02 || 3* || 0 || 5* || 10* || 4* || 13* || 0 || 0 || 0 || 12* 
 GR03 || 0 || 0 || 4* || 4* || 3* || 6* || 0 || 0 || 0 || 17* 
 GR04 || 7* ||  0* || 3* || 28* || 6* || 25* || 0* || 0* || 61* || 4* 
 GR05 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 20 
 GR06 || 1 || 0 || 8 || 3 || 0 || 6 || 0 || 0 || 2 || 13* 
 GR07 || 3 || 0 || 8 || 23 || 0 || 34 || 15 || 0 || 5 || 69* 
 GR08 || 0* ||  0* || 5* || 35* || 0* || 12* || 58* || 0* || 64* || 12* 
 GR09 || 1* || 1* || 0 || 14 || 2* || 15* || 16* || 0 || 5* || 9* 
 GR10 || 0 || 0 || 0 || 16* || 0 || 11* || 27* || 4 || 4* || 3* 
 GR11 || 0 || 0 || 1* || 4* || 1* || 6* || 26* || 1 || 6* || 51* 
 GR12 || 1* || 0 || 3* || 26* || 1* || 17* || 21* || 3 || 12* || 79* 
 GR13 || - || - || - || - || - || - || - || - || - || - 
 GR14 || - || - || - || - || - || - || - || - || - || - 
 Total || 17 || 1 || 43 || 164 || 21 || 158 || 163 || 8 || 159 || 298 
Table 5.3.1: Number of monitoring
stations in protected areas[8].
Source: WISE
*corrections/additions provided by EL
in late 2014

6.            
Overview of status (ecological, chemical,
groundwater)

The ecological status of natural surface water bodies presented in
the RBMPs shows that 49 % are in high or good status (7% and 42%
respectively). Another 18% are in moderate status, 11% in poor and bad status
(10% and 1% respectively) while 21% remain unknown. GR04 presents the lowest
percentage of water bodies with unknown status (2%) while GR02 the highest
(40%). Variations are observed across the RBDs (see Table 6.1): GR04 and GR05
have the highest percentage of water bodies in high and good status (84% of
their surface water bodies), while GR08 and GR09 has the highest percentage of
water bodies in poor and bad status (40% and 25% respectively). With regard to
the ecological potential of artificial and heavily modified water bodies (see
Table 6.2), 6% across the RBDs are in good status, 24% in moderate, 25% in
poor, 2% in bad and 43% in unknown status. In GR01/02/03/10 more than 60% are
in unknown status. It should be taken into consideration that in these
classifications, not all relevant quality elements have necessarily been
evaluated or considered, and that the available data were limited in many
cases. As such the confidence in the classification is
not high. 
 RBD || Total || High || Good || Moderate || Poor || Bad || Unknown 
 No. || (%) || No. || (%) || No. || (%) || No. || (%) || No. || (%) || No. || (%) 
 GR01 || 109 || 9 || 8% || 51 || 47% || 10 || 9% || 4 || 4% || 0 || 0% || 35 || 32% 
 GR02 || 88 || 13 || 15% || 27 || 31% || 8 || 9% || 5 || 6% || 0 || 0% || 35 || 40% 
 GR03 || 89 || 10 || 11% || 20 || 22% || 23 || 26% || 6 || 7% || 0 || 0% || 30 || 34% 
 GR04 || 101* || 3* || 3%* || 82* || 81%* || 13* || 13%* || 1* || 1%* || 0* || 0%* || 2* || 2%* 
 GR05 || 90 || 10 || 11% || 66* || 73%* || 10 || 11% || 0 || 0% || 0 || 0% || 4* || 5%* 
 GR06 || 25 || 2 || 8% || 6 || 24% || 7 || 28% || 4 || 16% || 1 || 4% || 5 || 20% 
 GR07 || 96 || 12 || 13% || 38 || 40% || 17 || 18% || 7 || 7% || 3 || 3% || 19 || 20% 
 GR08 || 70* || 5* || 7%* || 11* || 16%* || 19* || 27%* || 28* || 40%* || 0* || 0%* || 7* || 10%* 
 GR09 || 128* || 3 || 2% || 47 || 37%* || 20 || 16% || 27* || 21%* || 5 || 4% || 26 || 20%* 
 GR10 || 108 || 7 || 6% || 38 || 35% || 7 || 6% || 20 || 19% || 1 || 1% || 35 || 32% 
 GR11 || 66 || 0 || 0% || 13 || 20% || 31 || 47% || 3 || 5% || 0 || 0% || 19 || 29% 
 GR12 || 166 || 4 || 2% || 81 || 49% || 45 || 27% || 11 || 7% || 0 || 0% || 25 || 15% 
 GR13 || - || - || - || - || - || - || - || - || - || - || - || - || - 
 GR14 || - || - || - || - || - || - || - || - || - || - || - || - || - 
 Total || 1136 || 78 || 7% || 480 || 42% || 210 || 18% || 116 || 10% || 10 || 1% || 242 || 21% 
Table 6.1: Ecological status of
natural surface water bodies.
Source:
WISE; *corrections/additions provided by EL in late 2014
 RBD || Total || High || Good || Moderate || Poor || Bad || Unknown 
 No. || (%) || No. || (%) || No. || (%) || No. || (%) || No. || (%) || No. || (%) 
 GR01 || 19 || 0 || 0% || 1 || 5% || 3 || 16% || 3 || 16% || 0 || 0% || 12 || 63% 
 GR02 || 9 || 0 || 0% || 0 || 0% || 2 || 22% || 0 || 0% || 0 || 0% || 7 || 78% 
 GR03 || 11 || 0 || 0% || 0 || 0% || 4 || 36% || 0 || 0% || 0 || 0% || 7 || 64% 
 GR04 || 19* || 0* || 0%* || 7* || 37%* || 2* || 11%* || 0* || 0%* || 0* || 0%* || 10* || 52%* 
 GR05 || 16 || 0 || 0% || 3 || 19% || 4 || 25% || 1 || 6% || 0 || 0% || 8 || 50% 
 GR06 || 4 || 0 || 0% || 0 || 0% || 1 || 25% || 2 || 50% || 0 || 0% || 1 || 25% 
 GR07 || 8 || 0 || 0% || 0 || 0% || 4 || 50% || 2 || 25% || 2 || 25% || 0 || 0% 
 GR08 || 12* || 0* || 0%* || 2* || 17%* || 2* || 17%* || 3* || 25%* || 0* || 0%* || 5* || 41%* 
 GR09 || 40* || 0 || 0% || 0 || 0% || 1 || 2% || 13* || 33%* || 3 || 7% || 23 || 52% 
 GR10 || 16 || 0 || 0% || 0 || 0% || 1 || 6% || 4 || 25% || 0 || 0% || 11 || 69% 
 GR11 || 32 || 0 || 0% || 0 || 0% || 12 || 38% || 12 || 38% || 0 || 0% || 8 || 25% 
 GR12 || 45 || 0 || 0% || 1 || 2% || 19 || 42% || 18 || 40% || 0 || 0% || 7 || 16% 
 GR13 || - || - || - || - || - || - || - || - || - || - || - || - || - 
 GR14 || - || - || - || - || - || - || - || - || - || - || - || - || - 
 Total || 231 || 0 || 0% || 14 || 6% || 55 || 24% || 58 || 25% || 5 || 2% || 99 || 43% 
Table 6.2: Ecological potential of artificial and
heavily modified water bodies.
Source:
WISE; *corrections/additions provided by EL in late 2014
The chemical status of natural surface
water bodies presented in the RBMPs shows that 44% are good status, 6% in poor
status, while 51% remain unknown. GR04 presents the lowest percentage of water
bodies with unknown status (yet it reached 29%) while GR02 the highest (91%).
Variations are observed across the RBDs (see Table 6.3): among the classified
surface water bodies GR04 has the highest percentage of water bodies in good
status (72% of its surface water bodies). With regard to the chemical status of
artificial and heavily modified water bodies (see Table 6.4), 13% across the
RBDs are in good status, 27% in poor, and 60% in unknown status.  It should be
taken into consideration that in these classifications not all relevant quality
elements have necessarily been evaluated or considered (refer to section 9),
and that the available data were limited in many cases.
 RBD || Total || Good || Poor || Unknown 
 No. || % || No. || % || No. || % 
 GR01 || 109 || 10 || 9% || 5 || 5% || 94 || 86% 
 GR02 || 88 || 5 || 6% || 3 || 3% || 80 || 91% 
 GR03 || 89 || 6 || 7% || 18 || 20% || 65 || 73% 
 GR04 || 101* || 72* || 71%* || 0* || 0%* || 29* || 29%* 
 GR05 || 90 || 54 || 60% || 0 || 0% || 36 || 40% 
 GR06 || 25 || 6 || 24% || 0 || 0% || 19 || 76% 
 GR07 || 96 || 34 || 35% || 2 || 2% || 60 || 63% 
 GR08 || 70* || 25* || 36%* || 5* || 7%* || 40* || 57%* 
 GR09 || 128* || 50* || 39%* || 9 || 7% || 69* || 54%* 
 GR10 || 108 || 43 || 40% || 12 || 11% || 53 || 49% 
 GR11 || 66 || 8 || 12% || 9 || 14% || 49 || 74% 
 GR12 || 166 || 4 || 2% || 22 || 13% || 140 || 84% 
 GR13 || - || - || - || - || - || - || - 
 GR14 || - || - || - || - || - || - || - 
 Total || 1453 || 634 || 44% || 85 || 6% || 734 || 51% 
Table 6.3: Chemical status of
natural surface water bodies.
Source: WISE
*corrections/additions provided by EL
in late 2014
 RBD || Total || Good || Poor || Unknown 
 No. || % || No. || % || No. || % 
 GR01 || 19 || 5 || 26% || 2 || 11% || 12 || 63% 
 GR02 || 9 || 1 || 11% || 0 || 0% || 8 || 89% 
 GR03 || 11 || 0 || 0% || 4 || 36% || 7 || 64% 
 GR04 || 19* || 9* || 47%* || 4* || 21%* || 6* || 32%* 
 GR05 || 16 || 8 || 50% || 1 || 6% || 7 || 44% 
 GR06 || 4 || 1 || 25% || 0 || 0% || 3 || 75% 
 GR07 || 8 || 1 || 13% || 1 || 13% || 6 || 75% 
 GR08 || 12* || 3* || 25%* || 2* || 17%* || 7* || 58%* 
 GR09 || 40* || 0* || 0%* || 12 || 30%* || 28* || 70% 
 GR10 || 16 || 0 || 0% || 4 || 25% || 12 || 75% 
 GR11 || 32 || 2 || 6% || 12 || 38% || 18 || 56% 
 GR12 || 45 || 0 || 0% || 20 || 44% || 25 || 56% 
 GR13 ||   ||   ||   ||   ||   ||   ||   
 GR14 ||  - || - || - || - || - || -  || -  
 Total || 231 || 30 || 13% || 62 || 27% || 139 || 60% 
Table 6.4: Chemical status of
artificial and heavily modified surface water bodies.
Source: WISE, 
*corrections/additions provided by EL
in late 2014
The chemical status of groundwater
bodies presented in the RBMPs shows that 83.8 % are in good status, 16.2% in
poor, while none remain unknown. Variations are observed across the RBDs (see
Table 6.5): GR05 has the highest percentage of water bodies in good status
(96.2% of its groundwater bodies), while GR06 has the highest percentage of
water bodies in poor status (45.8% of its groundwater bodies). 
With regard to the quantitative status
of the groundwater bodies, 83.1 % are in good status, 16.9% in poor, while none
remain unknown. Variations are observed across the RBDs (see Table 6.6): GR05
has the highest percentage of water bodies in good status (96.2% of its
groundwater bodies), while GR06 has the highest percentage of water bodies in
poor status (37.5% of its groundwater bodies). It should be taken into
consideration that in these classifications the available data were limited in
many cases.
 RBD || Good || Poor || Unknown 
 No. || % || No. || % || No. || % 
 GR01 || 24 || 92.3% || 2 || 7.7% || 0 || 0% 
 GR02 || 22 || 84.6% || 4 || 15.4% || 0 || 0% 
 GR03 || 17* || 63%* || 10* || 37%* || 0 || 0% 
 GR04 || 24* || 96%* || 1* || 4%* || 0** || 0% 
 GR05 || 25 || 96.2% || 1 || 3.8% || 0 || 0% 
 GR06 || 13 || 54.2% || 11 || 45.8% || 0 || 0% 
 GR07 || 40 || 87% || 6 || 13% || 0 || 0% 
 GR08 || 28* || 87,5%* || 4* || 12,5%* || 0* || 0%* 
 GR09 || 58 || 93.5% || 4 || 6.5% || 0 || 0% 
 GR10 || 31 || 79.5% || 8 || 20.5% || 0 || 0% 
 GR11 || 14 || 93.3% || 1 || 6.7% || 0 || 0% 
 GR12 || 14 || 77.8% || 4 || 22.2% || 0 || 0% 
 GR13 || - || - || - || - || - || - 
 GR14 || - || - || - || - || - || - 
 Total || 311 || 85% || 55 || 15% || 0 || 0% 
Table 6.5: Chemical status of
groundwater bodies.
Source: WISE
*corrections/additions provided by EL in late 2014
 RBD || Good || Poor || Unknown 
 No. || % || No. || % || No. || % 
 GR01 || 24 || 92.3% || 2 || 7.7% || 0 || 0% 
 GR02 || 24 || 92.3% || 2 || 7.7% || 0 || 0% 
 GR03 || 22 || 81.5% || 5 || 18.5% || 0 || 0% 
 GR04 || 23* || 92%* || 2* || 8%* || 0* || 0%* 
 GR05 || 25 || 96.2% || 1 || 3.8% || 0 || 0% 
 GR06 || 15 || 62.5% || 9 || 37.5% || 0 || 0% 
 GR07 || 41 || 89.1% || 5 || 10.9% || 0 || 0% 
 GR08 || 22* || 68.8%* || 10* || 31.2%* || 0* || 0%* 
 GR09 || 48 || 77.4% || 14 || 22.6% || 0 || 0% 
 GR10 || 28 || 71.8% || 11 || 28.2% || 0 || 0% 
 GR11 || 14 || 93.3% || 1 || 6.7% || 0 || 0% 
 GR12 || 18 || 100% || 0 || 0 || 0 || 0% 
 GR13 || - || - || - || - || - || - 
 GR14 || - || - || - || - || - || - 
 Total || 304 || 83.1% || 62 || 16.9% ||   ||   
Table 6.6: Quantitative status of
groundwater bodies.
Source: WISE
*corrections/additions provided by EL in late 2014
A total of 330 surface water bodies
(i.e. 24%) are expected to achieve good or better global status by 2015. The
most significant increase is observed in GR03 (25% increase between 2009 and
2015). 25% of the surface water bodies are applying exemptions according to
Article 4.4. No exemptions according to Art. 4.5 are applied, based on the
information provided by EL in late 2014.
 RBD || Total || Global status (ecological and chemical) || Good Global status 2021 || Good Global status 2027 || Global exemptions 2009 (% of all SWBs) 
 Good or better 2009 || Good or better 2015 || Increase 2009 -2015 || Art 4.4 || Art 4.5 || Art 4.6 || Art 4.7 
 No. || % || No. || % || % || No. || % || No. || % || % || % || % || % 
 GR01 || 128 || 4 || 3.1 || 20 || 15.6 || 12.5 || 128 || 100  || 128 || 100  || 4* || 0 || 0* || 0* 
 GR02 || 97 || 2 || 2.1 || 5 || 5.2 || 3.1 || 95 ||  98 || 96 || 99  || 4* || 0 || 0* || 0* 
 GR03 || 100 || 2 || 2 || 27 || 27 || 25 ||  100 || 100 ||  100 || 100 || 33* || 0 || 0* || 0* 
 GR04 || 120* || 71* || 59* || 71* || 59* || 0* || 88* || 73* || 116* || 97* || 15* || 0* || 0* || 4* 
 GR05 || 106 || 52 || 49.1 || 52 || 49.1 || 0 || 67* || 63* || 105* || 99* || 14* || 0* || 0* || 0.9* 
 GR06 || 29 || 2 || 6.9 || 3 || 10.3 || 3.4 || 10* || 34* || 17* || 58* || 48 || 0 ||   ||   
 GR07 || 104 || 27 || 26 || 27 || 26 || 0 || 48* || 46* || 62* || 59* || 33 || 0 ||   ||   
 GR08 || 82* || 5* || 6* || 5* || 6* || 0* || 56* || 68* || 80* || 98* || 62* || 0* || 0* || 2* 
 GR09 || 168 || 45 || 26.8 || 50 || 29.8 || 3 ||   ||   ||   ||   || 14 || 0 ||   || 2* 
 GR10 || 124 || 36 || 29 || 58* || 47* || 18* ||   ||   ||   ||   || 10 || 0 ||   ||   
 GR11 || 98 || 5 || 5.1 ||  8* ||  8.2* || 0 ||  - ||   || -  ||   ||  52* || 0 ||   || 1 
 GR12 || 211 || 4 || 1.9 || 4 || 1.9 || 0 ||  - ||   ||  - ||   ||  40* || 0 ||   ||  4.3* 
 GR13 || - || - || - || - || - || - ||   ||   ||   ||   || - || - ||   ||   
 GR14 || - || - || - || - || - || - ||   ||   ||   ||   || - || - ||   ||   
 Total || 1367 || 255 || 19% || 330 || 24% || 5% ||   ||   ||   ||   ||   ||   ||   ||   
Table 6.7: Surface water bodies:
overview of status in 2009 and expected status in 2015, 2021and 2027; 
Waterbodies
with good status in 2009 fall into the following category:
1.
Ecological status is high or good and the chemical status is good, exemptions
are not considered
Waterbodies
expected to achieve good status in 2015 fall into the following categories:
1.
Ecological status is high or good and the chemical status is good, exemptions
are not considered
2.
Chemical status is good, and the ecological status is moderate or below but no
ecological exemptions
3.
Ecological status is high or good, and the chemical status is failing to
achieve good but there are no chemical exemptions
4.
Ecological status is moderate or below, and chemical status is failing to
achieve good but there are no ecological nor chemical exemptions
Note: Waterbodies with unknown/unclassified/Not applicable in
either ecological or chemical status are not considered
Source: WISE, corrections provided by EL in late 2014.
For this and the following tables of this chapter, there are some discrepancies
between this information and the RBMPs/their Annexes. *corrections/additions
provided by EL in late 2014
 RBD || Total || Ecological status || Good ecological status 2021 || Good ecological status 2027 || Ecological exemptions (% of all SWBs) 
 Good or better 2009 || Good or better 2015 || Increase 2009 -2015 || Art 4.4 || Art 4.5 || Art 4.6 || Art 4.7 
 No. || % || No. || % || % || No. || % || No. || % || % || % || % || % 
 GR01 || 109 || 60 || 55% || 74 || 68% || 13% || 109* || 100%* || 109* || 100%* ||  0%* || 0%* || 0%* || 0%* 
 GR02 || 88 || 40 || 45% || 53 || 60% || 15% || 88* || 100%* || 88* || 100%* ||  2%* || 0%* || 0%* || 0%* 
 GR03 || 89 || 30 || 34% || 59 || 66% || 32% || 89* || 100%* || 89* || 100%* ||  17%* || 0%* || 0%* || 0% * 
 GR04 || 101* || 85* || 84%* || 85* || 84%* || 0%* || 92* || 91%* || 96* || 95%* || 7%*  ||   ||   || 5% * 
 GR05 || 90 || 76* || 84%* || 76* || 84%* || 0% || 86* || 96%* || 89* || 99%*  || 11% ||   ||   ||  1%* 
 GR06 || 25 || 8 || 32% || 8 || 32% || 0% ||   ||   ||   ||   || 48% ||   ||   ||   
 GR07 || 96 || 50 || 52% || 50* || 52%* || 0%* ||   ||   ||   ||   || 28%* ||   ||   ||   
 GR08 || 70* || 16* || 23%* || 16* || 23%* || 0%* || 61* || 87%* || 69* ||  99%* || 64%* ||   ||   ||  1%* 
 GR09 || 128* || 50 || 39%* || 92* || 72%* || 33%* ||   ||   ||   ||   || 6%* ||   ||   || 2% 
 GR10 || 108 || 45 || 42% || 65* || 60%* || 18%* ||   ||   ||   ||   || 10% ||   ||   || 0.02%* 
 GR11 || 66 || 13 || 20% ||  19* ||  29%* ||  9%* ||   ||   ||   ||   ||  41%* ||   ||   || 2% 
 GR12 || 166 || 85 || 51% ||  90* ||  54%* ||  3%* ||   ||   ||   ||   ||  27%* ||   ||   ||  4%* 
 GR13 || - || - || - || - || - || - ||   ||   ||   ||   || - ||   ||   || - 
 GR14 || - || - || - || - || - || - ||   ||   ||   ||   || - ||   ||   || - 
 Total || 1136 || 558 || 49% || 687 || 60% || 11% ||   ||   ||   ||   ||   ||   ||   ||   
Table
6.8:
Natural surface water bodies: ecological status in 2009 and expected status in
2015, 2021 and 2027
Source: WISE
*corrections/additions provided by EL in late 2014
 RBD || Total || Chemical status || Good chemical status 2021 || Good chemical status 2027 || Chemical exemptions (% of all SWBs) 
 Good or better 2009 || Good or better 2015 || Increase 2009 -2015 || Art 4.4 || Art 4.5 || Art 4.6 || Art 4.7 
 No. || % || No. || % || % || No. || % || No. || % || % || % || % || % 
 GR01 || 109 || 10 || 9% || 15 || 14% || 5% || 109* || 100%* || 109* || 100%* ||  0%* || 0%* || 0%* || 0%* 
 GR02 || 88 || 5 || 6% || 8 || 9% || 3% || 88* || 100%* || 88* || 100%* ||  2%* || 0%* || 0%* || 0%* 
 GR03 || 89 || 6 || 7% || 24 || 27% || 20% || 89* || 100%* || 89* || 100%* ||  17%* || 0%* || 0%* || 0% * 
 GR04 || 101* || 72* || 71%* || 72* || 71%* || 0%* || 79* || 78%* || 97* || 96%* || 5%* ||   ||   || 4% * 
 GR05 || 90 || 54 || 60% || 54 || 60% || 0% || 54* || 60%* || 89* || 99% * ||  0%* ||   ||   || 1%* 
 GR06 || 25 || 6 || 24% || 6 || 24% || 0% ||   ||   ||   ||   ||   ||   ||   ||   
 GR07 || 96 || 34 || 35% || 34 || 35% || 0% ||   ||   ||   ||   || 2% ||   ||   ||   
 GR08 || 70* || 25* || 36%* || 25* || 36%* || 0%* || 30* || 43%* || 68* || 97%* ||  7%* ||   ||   || 3% * 
 GR09 || 128* || 50* || 40% || 51* || 40% || 0% ||   ||   ||   ||   || 5%* ||   ||   ||   
 GR10 || 108 || 43 || 40% || 48 || 44% || 4% ||   ||   ||   ||   || 9%* ||   ||   ||   
 GR11 || 66 || 8 || 12% || 8 || 12% || 0% ||   ||   ||   ||   || 14% ||   ||   ||   
 GR12 || 166 || 4 || 2% || 4 || 2% || 0% ||   ||   ||   ||   || 13% ||   ||   ||   
 GR13 || - || - || - || - || - || - ||   ||   ||   ||   || - ||   ||   ||   
 GR14 || - || - || - || - || - || - ||   ||   ||   ||   || - ||   ||   ||   
 Total || 1136 || 317 || 28% || 349 || 31% || 3% ||   ||   ||   ||   ||   ||   ||   ||   
Table
6.9:
Natural surface water bodies: chemical status in 2009 and expected status in
2015, 2012 and 2027
Source: WISE
*corrections/additions provided by EL in late 2014
 RBD || Total || GW chemical status || Good chemical status 2021 || Good chemical status 2027 || GW chemical exemptions (% of all GWBs) 
 Good or better 2009 || Good or better 2015 || Increase 2009 -2015 || Art 4.4 || Art 4.5 || Art 4.6 || Art 4.7 
 No. || % || No. || % || % || No. || % || No. || % || % || % || % || % 
 GR01 || 26 || 24 || 92.3 || 24 || 92.3 || 0 || 24* || 92.3* || 26 ||  100% || 7.7%* || 0%* ||   ||   
 GR02 || 26 || 22 || 84.6 || 22 || 84.6 || 0 || 22* || 84.6* || 26 ||  100% || 15.4%* || 0%* ||   ||   
 GR03 || 27 || 17* || 63* || 17* || 63* || 0 || 17* || 63* || 27 ||  100% || 37%* || 0%* ||   ||   
 GR04 || 25* || 24* || 96* || 24* || 96* || 0* || 24* ||  96* ||   ||   || 4%* || 0%* || 0%*  || 0%*  
 GR05 || 26 || 25 || 96.2 || 26 || 100 || 3.8 ||  25 ||  96 ||   ||   || 4% || 0% ||  0%* ||  0%* 
 GR06 || 24 || 13 || 54.2 || 13 || 54.2 || 0 ||   ||   || 24 || 100% || 46% || 0% ||   ||   
 GR07 || 46 || 40 || 87 || 40 || 87 || 0 ||   ||   || 46 || 100% || 13% || 0% ||   ||   
 GR08 || 32* || 28* || 87.5* || 28* || 87.5* || 0* || 28* || 87.5* || 28* || 87.5* || 12.5* || - || 0%*  || 0% * 
 GR09 || 62 || 58 || 93.5 || 58 || 93.5 || 0 ||   ||   ||   ||   || 6% || 0% ||   ||   
 GR10 || 39 || 31 || 79.5 || 31 || 79.5 || 0 ||   ||   ||   ||   || 18% || 0% ||   || 3% 
 GR11 || 15 || 14 || 93.3 || 14 || 93.3 || 0 ||  14 ||  93 || 15 ||  100 || 7% || 0% ||   ||   
 GR12 || 18 || 14 || 77.8 || 14 || 77.8 || 0 ||  14 ||  78 || 17  || 94  || 28% || 0% ||   ||   
 GR13 || - || - || - || - || - || - ||   ||   ||   ||   || - || - ||   ||   
 GR14 || - || - || - || - || - || - ||   ||   ||   ||   || - || - ||   ||   
 Total || 366 || 310 || 85% || 311 || 85% || 0.3% ||   ||   ||   ||   ||   ||   ||   ||   
Table
6.10:
Groundwater bodies: chemical status in 2009 and expected status in 2015, 2012
and 2027
Source: WISE
*corrections/additions provided by EL in late 2014
 RBD || Total || Groundwater quantitative status || Good quantitative status 2021 || Good quantitative status 2027 || GW quantitative exemptions (% of all GWBs) 
 Good or better 2009 || Good or better 2015 || Increase 2009 -2015 || Art 4.4 || Art 4.5 || Art 4.6 || Art 4.7 
 No. || % || No. || % || % || No. || % || No. || % || % || % || % || % 
 GR01 || 26 || 24 || 92.3 || 24 || 92.3 || 0 || 24* || 92.3* || 26 ||  100% || 7.7%* || 0% ||   ||   
 GR02 || 26 || 24 || 92.3 || 24 || 92.3 || 0 || 24* ||  92.3* || 26 ||  100% || 11.5%* || 0%* ||   ||   
 GR03 || 27 || 22 || 81.5 || 22 || 81.5 || 0 || 22* ||  81.5* || 27 ||  100% || 33.3%* || 0% ||   ||   
 GR04 || 25* || 23* || 92* || 23* || 92* || 0* ||   ||   || 25* || 100%* || 8%* || 0%* || 0%* || 0%* 
 GR05 || 26 || 25 || 96.2 || 25 || 96.2 || 0 ||  25 ||   || 26* || 100%* || 4% || 0% || 0%*  || 0%*  
 GR06 || 24 || 15 || 62.5 || 15 || 62.5 || 0 || 19* || 79* || 24 || 100% || 38% || 0% ||   ||   
 GR07 || 46 || 41 || 89.1 || 41 || 89.1 || 0 ||   ||   || 46 || 100% || 11% || 0% ||   ||   
 GR08 || 32* || 22* || 68.87* || 22* || 68.87* || 0* ||   ||   || 32* || 100%* || 31%* || 0%* || 0%* || 0%* 
 GR09 || 62 || 48 || 77.4 || 48 || 77.4 || 0 ||   ||   ||   ||   || 23% || 0% ||   ||   
 GR10 || 39 || 28 || 71.8 || 28 || 71.8 || 0 ||   ||   ||   ||   || 28% || 0% ||   || 5% 
 GR11 || 15 || 14 || 93.3 || 14 || 93.3 || 0 ||  14 ||  93 || 15  ||  100 || 7% || 0% ||   ||   
 GR12 || 18 || 18 || 100 || 18 || 100 || 0 ||   ||   ||   ||   || 0% || 0% ||   ||   
 GR13 || - || - || - || - || - || - || - || - || - || - || - || - ||   ||   
 GR14 || - || - || - || - || - || - || - || - || - || - || - || - ||   ||   
 Total || 366 || 304 || 83.1 || 304 || 83.1 || 0 ||   ||   ||   ||   ||   ||   ||   ||   
Table
6.11:
Groundwater bodies: quantitative status in 2009 and expected status in 2015,
2012 and 2027
Source:
WISE
*corrections/additions provided by EL in late 2014
 RBD || Total HMWB and AWB || Ecological potential || Good ecological potential 2021 || Good ecological potential 2027 || Ecological exemptions (% of all HMWB/AWB) 
 Good or better 2009 || Good or better 2015 || Increase 2009 -2015 || Art 4.4 || Art 4.5 || Art 4.6 || Art 4.7 
 No. || % || No. || % || % || No. || % || No. || % || % || % || % || % 
 GR01 || 19 || 1 || 5% || 7 || 37% || 32% || 19* || 100%* || 19* || 100%* || 16%*  || 0%* || 0% * || 0% * 
 GR02 || 9 || 0 || 0% || 2 || 22% || 22% || 7* || 78%* || 8* || 89%* || 22%* || 0%* || 0% * || 0% * 
 GR03 || 11 || 0 || 0% || 4 || 36% || 36% || 11* || 100%* || 11* || 100%* ||  55%* || 0%* || 0% * || 0% * 
 GR04 || 19* || 7* || 37%* || 7* || 37%* || 0%* || 9* || 47%* || 19* || 100%* || 10%* || - ||   || - 
 GR05 || 16 || 3 || 19% || 3 || 19% || 0% || 8* || 50%* || 16* || 100%* || 31%* ||   ||   ||   
 GR06 || 4 || 0 || 0% || 1 || 25% || 25% ||   ||   ||   ||   || 50% ||   ||   ||   
 GR07 || 8 || 0 || 0% || 0 || 0% || 0% ||   ||   ||   ||   || 100% ||   ||   ||   
 GR08 || 12* || 2* || 17%* || 2* || 17%* || 0%* || 7* || 58%* || 12* || 100* || 42%* || - ||   || - 
 GR09 || 40* || 0* || 0%* || 5* || 12%* || 12%* ||   ||   ||   ||   || 30%* ||   ||   ||   
 GR10 || 16 || 0 || 0% || 0 || 0% || 0% ||   ||   ||   ||   || 31%* ||   ||   ||   
 GR11 || 32 || 0 || 0% || 0 || 0% || 0% ||   ||   ||   ||   || 75% ||   ||   ||   
 GR12 || 45 || 1 || 2% || 1 || 2% || 0% ||   ||   ||   ||   || 80% ||   ||   || 2% 
 GR13 || - || - || - || - || - || - ||   ||   ||   ||   || - || - ||   || - 
 GR14 ||  - || - || - || - || - || - ||   ||   ||   ||   ||  - ||  - ||   ||  -  
 Total || 231 || 14 || 6% || 32 || 14% || 8% ||   ||   ||   ||   ||   ||   ||   ||   
Table 6.12: Heavily modified and
artificial water bodies: ecological potential in 2009 and expected ecological
potential in 2015, 2021 and
2027
Source: WISE
*corrections/additions provided by EL in late 2014
 RBD || Total HMWB and AWB || Chemical status || Good chemical status 2021 || Good chemical status 2027 || Chemical exemptions (% of all HMWB/AWB) 
 Good or better 2009 || Good or better 2015 || Increase 2009 -2015 || Art 4.4 || Art 4.5 || Art 4.6 || Art 4.7 
 No. || % || No. || % || % || No. || % || No. || % || % || % || % || % 
 GR01 || 19 || 5 || 26% || 7 || 37% || 11% || 19* || 100%* || 19* || 100%* || 16%*  || 0%* || 0%*  || 0%* 
 GR02 || 9 || 1 || 11% || 1 || 11% || 0% || 7* || 78%* || 8* || 89%* || 22%* || 0%* || 0%* || 0%* 
 GR03 || 11 ||   || 0% || 4 || 36% || 36% || 11* || 100%* || 11* || 100%* ||  55%* || 0%* || 0%* || 0%* 
 GR04 || 19* || 9* || 47%* || 9* || 47%* || 0%* ||   ||   ||   ||   || 21%* || 0%* || 0%* || 0%* 
 GR05 || 16 || 8 || 50% || 8 || 50% || 0% ||   ||   ||   ||   || 6% || 0%* || 0%* || 0%* 
 GR06 || 4 || 1 || 25% || 1 || 25% || 0% ||   ||   ||   ||   ||   ||   ||   ||   
 GR07 || 8 || 1 || 13% || 1 || 13% || 0% ||   ||   ||   ||   || 13% ||   ||   ||   
 GR08 || 12* || 3* || 25%* || 3* || 25%* || 0%* ||   ||   ||   ||   ||  17%* || 0%* || 0%* || 0%* 
 GR09 || 40* || 0* || 0%* || 1* || 3%* || 3%* ||   ||   ||   ||   || 27%* ||   ||   ||   
 GR10 || 16 ||   || 0% || 0 || 0% || 0% ||   ||   ||   ||   || 25% ||   ||   ||   
 GR11 || 32 || 2 || 6% || 2 || 6% || 0% ||   ||   ||   ||   || 38% ||   ||   ||   
 GR12 || 45 ||   || 0% || 0 || 0% || 0% ||   ||   ||   ||   || 44% ||   ||   ||   
 GR13 || - || - || - || - || - || - ||   ||   ||   ||   || - ||   ||   ||   
 GR14 || - || - || - || - || - || - ||   ||   ||   ||   || - ||   ||   ||   
 Total || 231 || 30 || 13% || 37 || 16% || 3% ||   ||   ||   ||   ||   ||   ||   ||   
Table
6.13:
Heavily modified and artificial water bodies: chemical status in 2009 and
expected status in 2015, 2021 and
2027
Source: WISE
*corrections/additions provided by EL in late 2014
Figure 6.1: Map of ecological
status of natural surface water bodies 2009 
Figure
6.2:
Map of ecological status of natural surface water bodies 2015
   ||   ||   || Good or better 
   ||   ||   || Less than good 
   ||   ||   || Unknown 
   ||   ||   || River Basin Districts 
   ||   ||   || Countries outside EU 
Source: WISE, Eurostat and corrections/additions
provided by EL in late 2014
Figure
6.3:
Map of ecological potential of artificial and heavily modified water bodies
2009 
Figure
6.4:
Map of ecological potential of artificial and heavily modified water bodies
2015
   ||   ||   || Good or better 
   ||   ||   || Less than good 
   ||   ||   || Unknown 
   ||   ||   || River Basin Districts 
   ||   ||   || Countries outside EU 
Source: WISE, Eurostat
and corrections/additions provided by EL in late 2014
Figure 6.5: Map of chemical
status of natural surface water bodies 2009 
Figure
6.6:
Map of chemical status of natural surface water bodies 2015
   ||   ||   || Good 
   ||   ||   || Failing to achieve good 
   ||   ||   || Unknown 
   ||   ||   || River Basin Districts 
   ||   ||   || Countries outside EU 
Note:
Standard colours based on WFD Annex V, Article 1.4.3. 
Source: WISE, Eurostat
and corrections/additions provided by EL in late 2014
Figure 6.7: Map of chemical
status of artificial and heavily modified water bodies 2009 
Figure
6.8:
Map of chemical status of artificial and heavily modified water bodies 2015
   ||   ||   || Good 
   ||   ||   || Failing to achieve good 
   ||   ||   || Unknown 
   ||   ||   || River Basin Districts 
   ||   ||   || Countries outside EU 
Note:
Standard colours based on WFD Annex V, Article 1.4.3. 
Source: WISE, Eurostat
(country borders) and corrections/additions provided by EL in late 2014
Figure 6.9: Map of chemical
status of groundwater bodies 2009 
Figure
6.10:
Map of chemical status of groundwater bodies 2015
   ||   ||   || Good 
   ||   ||   || Poor 
   ||   ||   || Unknown 
   ||   ||   || River Basin Districts 
   ||   ||   || Countries outside EU 
Note:
Standard colours based on WFD Annex V, Article 2.4.5. 
Source: WISE, Eurostat
(country borders) and corrections/additions provided by EL in late 2014
Figure 6.11: Map of quantitative
status of groundwater bodies 2009
Figure
6.12:
Map of quantitative status of groundwater bodies 2015
   ||   ||   || Good 
   ||   ||   || Poor 
   ||   ||   || Unknown 
   ||   ||   || River Basin Districts 
   ||   ||   || Countries outside EU 
Note:
Standard colours based on WFD Annex V, Article 2.2.4. 
Source: WISE, Eurostat
(country borders) and corrections/additions provided by EL in late 2014

7.            
Assessment of ecological status of surface
waters

It seems that the different projects commissioned for
the development of the different RBMPs were centrally coordinated by the
Special Secretarial for Water; thus, generally a national approach is followed.
At the same time, for GR01/02/03 the actual classification was done (partly)
based on a specific sampling study. For the different RBMPs the information is
provided in a very different way, so it remains unclear if a national approach
is transparently used for all RBDs (it is also unclear due to the lack of
national published guidance on different issues, although EL has stated that
internal guidelines have been provided to the different consultants). Out
of the 14 RBMPs that should have been approved by 2009, only 12 RBMPs have been
approved so far. The 12 RBMPs that have recently become official should
implement the Programmes of Measures in the following very short period as the
second round of revised Plans should be submitted by 2015, according to the
WFD, taking into account the implementation of the first RBMPs. A
PoM-Implementation Progress Report (national level) has been submitted by EL to
the Commission as a reply to an EU enquiry in December 2014, and was uploaded
on WISE on 22.01.2015. It has not been assessed by the Commission to date. 

7.1        
Ecological status assessment methods

The assessment methods for the
classification of ecological status are only partly
developed for some BQEs and are explicitly described in the Annexes A/6
(Reference conditions of SWBs). For rivers only the benthic fauna was used; it
is stated that "in agreement with the managing authority, for the
classification of rivers in the current RBMPs cycle it was decided to rely only
on the biological quality element (BQE) of benthic macroinvertebrates”.
Accordingly, phytoplankton is the only BQE that is able to produce reliable
assessment methods of the ecological status in lakes. For most of the BQEs
specified in the WFD, national methods for assessing ecological status have not
been developed. This is due to the insufficiency of available data to describe
reference conditions, due to the lack of development of indicators for the
parameters estimation for each BQE, or due to inadequate experience and
knowledge on the biology of specific BQEs to link the status of the habitats
with the condition of the water bodies. There are therefore important gaps in
the assessment system.
The overall approach of classification according to
the WFD is described, and was principally based on the One-Out-All-Out
principle. It is clearly mentioned that “for water bodies where there are measurements
of priority substances, the One-Out-All-Out principle was followed among the
qualitative data, regardless of the number of parameters for which data have
been available; that is, if a priority substance exceeded the boundaries set,
the water body was classified in a lower than good status”. Similarly, in cases
where, based on the available data, the BQEs resulted a good status but
physicochemical parameters failed, the ecological status has been classified as
moderate. In cases where correlation in the monitoring data was not evident, at
the time and the position of the sampling for physicochemical parameters, and
the BQEs exhibited discrepancies, the physicochemical data were not used for
the classification of the water bodies (mainly in the RBDs GR06 and GR07).  At
the same time, and based on the way the classification was done, it is not
possible to say if this principle was followed in practice.
It is highly questionable whether the classification
system is responsive to all pressures as relevant information is insufficient.
In some RBMPs there is a brief mention of the different pressures addressed by
the classification system (e.g. the phytoplankton increases eutrophication in a
lake system), but not sufficient information on which BQEs are detecting which
pressures. For GR09 the same applies for the information from the Prespa plan
as well. In the case of GR11/12, it is explicitly mentioned that at this stage
the system is not using calibrated measurements of the BQE to determine whether
there is a correlation between the abstraction levels from rivers and their
ecological status assessed by the measurements of the BQE. In the case of river
water bodies for which no data are available from monitoring programmes, a
process of grouping of the water bodies was followed for GR04/05/08/09/10 in
relation to the different pressures. The main idea of grouping is that water
bodies of the same type which are subject to similar levels of anthropogenic
pressures are likely to have the same ecological quality. The purpose was to
minimise the number of water bodies that would be characterised as of unknown
ecological status. As this approach is indirect, this type of assessment has a
low level of confidence.
In general, it is
mentioned that the classification of water bodies in terms of physico-chemical
QEs was supplementary to the assessment of the BQEs (respecting the
One-Out-All-Out (OOAO) principle); that is these QEs are used to assist in
determining the ecological status of surface water bodies. The elements that
are assessed include the transparency, thermal conditions, oxygen conditions,
salinity, acidification conditions and nutrient conditions. For the RBMPs of
GR01/02/03, regarding the classification, there was very limited monitoring
information available. One specification regarding the way the physico-chemical
QEs were dealt with in practice is the sampling study used for some water
bodies. The study collected samples and measurements concerning the
biodiversity and carrying capacity of rivers such as for macroinvertebrates. In
this case, the physico-chemical parameters were determined in situ with a
portable multi-parameter instrument. For the RBMPs of GR06/07 it is clearly
stated that physico-chemcial QEs were not used for the classification of the
ecological status for surface water bodies. For the RBMPs of
GR04/05/08/09/10/11/12, the assessment is conducted through measured data
(limited years) of the General Chemical State Laboratory, the Ministry of Rural
Development and Food, Universities, and the Decentralised Administrations,
Water Directorates. These are then compared to the relevant environmental
quality standards (EQS) for each water body category. When the value of the
parameters complies with standards, the water body is classified as in good
status; in the opposite case the water body is classified as in a less than
good status. The values refer to the boundary between good and moderate status,
which according to the general classification scheme, determines the
possibility of relegation measured by the BQEs of ecological status of a water
body from good to moderate.
Theoretically, EQSs have been established. The
relevant Ministerial Decision (51354/2641/Ε103/2010) establishes
Environmental Quality Standards for 101 chemical compounds or groups of
compounds, of which 41 are priority substances and other pollutants, which have
been agreed within the European Union (Directive 2008/105/EC) and 60 relating
to specific pollutants, which either have been detected in water bodies of the
country or identified in previous legislation. Note that the priority
substances characterise the chemical status of water, as defined in the WFD and
the specific pollutants are used to assist in determining ecological status. In
the Annexes it is mentioned that “the specific pollutants are supporting
parameters which are also considered for the classification of ecological
status; the classification of a water body is not good if a specific pollutant
does not meet the specified environmental quality standards”. Consequently, it
seems that all pollutants referred to in the WFD-Annexes VIII and X are covered
by the Ministerial Decision. No reference is provided on how the EQSs were
established. Additionally, it is noted that only very limited monitoring
information is available regarding these pollutants in the RBDs. 
The overall approach of classification according to
the WFD is described, including the One-Out-All-Out principle. It is implied on
several occasions that the total ecological status of the water system is
determined by the results of the biological, physico-chemical and hydromorphological
quality elements taking into account the worst category (i.e. the part of the
quality most affected by human activity); that is the One-Out-All-Out
principle. The hydromorphological data were taken into account only to rank the
“high” status. At the same time, and based on the way the classification was
done, it is not possible to say if this principle was followed in practice.
Based on the very
limited information available for the classification of the surface water
bodies and the common use of expert judgement, etc., the uncertainty is
classified in three categories as follows:
§ 
Large Uncertainty: concerns water bodies in which there was no
monitoring station; 
§ 
Medium Uncertainty : where there is one monitoring station (either from
the sampling study, or from the existing monitoring network);
§ 
Small Uncertainty: where there is more than one monitoring station. If
in a water body several monitoring results exist and the assessments do not
agree, then the uncertainty is characterised as medium. 
§ 
Not defined uncertainty: where the situation remains unknown. 
Specifically, in
the GR04/05/08/11/12, regardless of the parameter for which the analysis was
conducted the level of uncertainty was considered:
§ 
Limited Uncertainty for the types with more than 7 samples; 
§ 
Medium Uncertainty for the types that did not comply with the above
condition;
§ 
High Uncertainty for the types with less than 4 samples or 4 stations;
§  Large Uncertainty
in cases where no data were available and the determination of the values was
done through the expert judgment.
It has to be noted that regarding the main data gaps
and uncertainties relating to surface waters there are delays in determining
the physico-chemical and hydromorphological standards so it is not possible to
set reference conditions and class boundaries between high, good condition,
etc.
All water body types are covered by a classification
system. For most of the BQEs specified in the WFD, national methods for
assessing ecological status for the case of Greece have not been developed.
This is due to the insufficiency of available data to describe reference
conditions, due to the lack of development of indicators for the parameters
estimation for each BQE, or due to inadequate experience and knowledge on the
biology of specific BQEs to link the status of the habitats with the condition
of the water bodies. For GR05/09/10/11/12 the transitional waters are assessed
based on the criteria that are used for the coastal waters and for the coastal
waters there is only one water body type for the whole country in order to
avoid increased fragmentation.
The intercalibration work is mentioned only in
general. The class boundaries are in almost all cases not used for the actual
classification of water bodies due to the lack of data. No data is available to
cross-check the intercalibration decision with what is mentioned in the
relevant Annexes. The boundaries used for the case of Greece for the respective
types (R-M1, R-M2 and RM-4), referred only to the biological quality element of
benthic macroinvertebrates; the purpose was to evaluate which is the common
Intercalibration Common Metrics index (ICMi), as a national assessment method
for the ecological status to be involved in the exercise was not fully
developed. Additionally, Greece’s involvement in the intercalibration exercise
of the countries of the Mediterranean eco-region was fragmented. As a result
any national methods that were developed in the context of individual pilot
projects implementing the WFD cannot be matched with the methods developed by
other countries. Consequently, there is a lack of commonly accepted values
​​of reference conditions and class boundaries of the ecological
status classification including national methods that have been used at times
in other Mediterranean countries.
The background documents that have been
reported as Annexes to the RBMPs are Annexes A/6 (Reference conditions for
SWBs) and A/9 (Classification of SWBs). In terms of a national Guidance
Document, guidelines were formulated by the coordinator consultant and the
General Secretariat for Water to guide/harmonise the work and methodological
approach of all other consultants who were commissioned with the drafting of
the RBMPs, but these were not organised into a detailed guidance document.
 RBD || Rivers || Lakes || Transitional || Coastal 
 Phytoplankton || Macrophytes || Phytobenthos || Benthic invertebrates || Fish || Physico-Chemical || Hydromorphological || Phytoplankton || Macrophytes || Phytobenthos || Benthic invertebrates || Fish || Physico-Chemical || Hydromorphological || Phytoplankton || Macroalgae || Angiosperms || Benthic invertebrates || Fish || Physico-Chemical || Hydromorphological || Phytoplankton || Macroalgae || Angiosperms || Benthic invertebrates || Physico-Chemical || Hydromorphological 
 GR01 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR02 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR03 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR04 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR05 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR06 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR07 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR08 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   || - || - || - || - || - || - || - ||   ||   ||   ||   ||   ||   
 GR09 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR10 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR11 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR12 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR13 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 GR14 ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
Table
7.1.1:
Availability of biological assessment methods as reflected in the RBMPs. Some
of the methods marked in red may be under development but the information
available is unclear.
   || Assessment methods fully developed 
   || Assessment methods partially developed or under development 
   || Assessment methods not developed for BQEs, no information provided on the assessment methods or unclear information provided 
 - ||   || Water category not relevant 
Source:
RBMPs (Annex A/6 Reference Conditions of SWBs). Note: EL provided alternative
formulation of this Table, reflecting on-going development of methods).

7.2        
Application of methods and ecological status
results

The national monitoring network (defined by the Common
Ministerial Decree 140384/2011) was not operational by the time of data
collection for the purposes of the RBMPs in order to assess the current status
of SWR. Thus, the data for the compilation of the RBMPs were collected by the
Ministry of Environment, Energy and Climate Change, the Ministry of Rural
Development and Food, the Water Directorates of the Regions, etc. as well as
through relevant studies and surveys and were fragmented. The difficulty of the
issue to assess the ecological status, due to lack of data, can only be
addressed through the implementation of the national monitoring program. It is
explicitly stated that once this new monitoring programme is operational and in
the revision of the RBMPs, the Special Secretariat for Water, the competent
agencies and the scientific community will undertake further investigation of
the appropriate indicators for the next management period.
Although there is information on which specific
pollutants are responsible for failure of ecological status of the water
bodies, uncertainty does remain since data limitation has in many cases
hindered a full scale assessment of all pollutants. It is
quite unclear whether the most sensitive biological quality elements have been
selected for ecological status assessment for operational monitoring sites. The national monitoring network was not operational by the
time of data collection for the purposes of RBMPs. It is highly questionable
whether the classification system is responsive to all pressures as relevant
information is insufficient. In some RBMPs there is a brief mention of the
different pressures addressed by the classification system, but not sufficient
information on which BQEs are addressing which pressures. 
There is very limited information regarding the
confidence and precision of the different parts of the classification system
for the ecological status. For example in GR05/11/12, in the calculation of the
Bentix indicator, the level of confidence is considered low when the number of
species is 3 or less, the number of items is 6 or less, the percentage of
disregarded species is 7% or more, or the percentage of species that are not
calibrated is 20% or more. This is very fragmented information.
For GR09/10, the water bodies are
characterised with low confidence when the classification is based only on
biological elements with a parallel assessment of the nutrient. Water bodies
are also characterised of low confidence when the classification has only been
based on physico-chemical characteristics and specific pollutants. They are
characterised as of medium confidence when their classification is based on
biological characteristics, physicochemical and specific pollutants (from
systematic measurements of the General Chemical State Laboratory and the Region
of Central Macedonia. 
 RBD || CAS Number || Substance || Percentage Water Bodies Failing Status (%) 
 GR01 ||   || Zinc (3 failing out of 128 SWBs) || 2.3 
   || Molybdenum (3 failing out of 128 SWBs) || 2.3 
   || Sulfonic acid/LAS (4 failing out of 128 SWBs) || 3.1 
 GR02 ||   || Zinc (1 failing out of 97 SWBs) || 1 
   || Copper (1 failing out of 97 SWBs) || 1 
   || Sulfonic acid/LAS (2 failing out of 97 SWBs) || 2.1 
   || Cyanide (2 failing out of 97 SWBs) || 2.1 
   ||   ||   
 GR03 ||   || Zinc (2 failing out of 100 SWBs) || 2 
   || Sulfonic acid/LAS (1 failing out of 100 SWBs) || 1 
 GR04* ||   || Methamidofhos(iso) (3 WBs out of 120) Monolinuron (ISO) (3 WBs out of 120) LAS (2 WB out of 120) Zinc (1 WB out of 120) || 5 
 GR05* ||   || Molybdenum (16 WBs out of 106) Monolinuron (ISO) (1WBs out of 106) Tin (1WBs out of 106) || 15 
 GR08* ||   || Monolinuron (ISO) (6WBs out of 86) Methamidofhos(iso) (6WBs out of 86) Copper (1WBs out of 86) Zinc (1WBs out of 86) || 14 
 GR09* ||   || LAS (19 failing out of 150 SWBS) || 12,6 
 GR10* ||   || Selinum -Sn (2 failing out of 104 SWBS) || 1,9 
 GR11 ||   || Molybdenum (1 WB out of 98) || 1 
   ||   || Zinc (1 WB out of 98) || 1 
 GR12 ||   || Sn (Tin) (16 WBS out of 211) || 7.6 
   || Cu (Copper) (1 WB out of 211) || 0.5 
   || Molybdenum (9 WB out of 211) || 4.3 
   || As (Arsenic) (3 WBs out of 211) || 1.4 
Table 7.3.1: River basin specific
pollutants causing failure of status
Source: RBMPs (Template 12 (Chemical Measures), question 3)
*
corrections/additions provided by EL in late 2014

8.            
Designation of heavily modified water bodies
(hmwb) and assessment of good ecological potential

Figure
8.1:
Map of percentage Heavily Modified and Artificial waterbodies by River Basin
District
   ||   ||   || 0 – 5 % 
   ||   ||   || 5 – 20 % 
   ||   ||   || 20 – 40 % 
   ||   ||   || 40 – 60% 
   ||   ||   || 60 – 100 % 
   ||   ||   || No data reported 
   ||   ||   || River Basin Districts 
   ||   ||   || Countries outside EU 
Source: WISE, Eurostat
(country borders)

8.1        
Designation of HMWBs

Based on the
information submitted by EL in late 2014, 235 water bodies are designated as
HMWB/AWB in the 12 RBDs for which the RBMPs are available (189 HMWBs and 46
AWBs). These represent approximately 17.2% of the reported 1366 surface water
bodies. There are some differences between the information submitted by EL in
late 2014, the information reported in WISE and the numbers found in the RBMPs.
The water uses that are
linked to the water bodies designated as HMWB as well as the types of physical
modifications leading to the designation are mentioned briefly in most but not
all RBDs, with differences regarding the way relevant information is presented
in each group of RBMPs: GR1/2/3, 4/5/8, 6/7, 9/10 and 11/12.
In most cases, the
starting point for the designation is the list of water bodies “preliminarily
identified” as HMWB/AWB – mostly at the end confirming their final designation.
Exceptions are e.g. GR11/12 where a significantly different list of water
bodies is “tested” regarding the HMWB/AWB-designation as the ones provisionally
identified in the past, but also confirming that all tested water bodies are
HMWB/AWB. In GR9/10, there is no reference to the “preliminarily identified”
HMWB/AWB as a starting point for the designation.
Information on
methodologies and the approach to designate HMWB/AWB varies across RBMPs. It
seems that no national legislation or guidance exists on the issue. All plans
refer to the use of the CIS Guidance document N°4. For Greece, the practical
approach for designation is described with varying detail for each RBD, mostly
covering the steps as described in the guidance. 
The level of detail for
answering each “designation step” is different and generally can be considered
as very brief or not sufficient. In addition, the way to present the
designation process differs significantly: the step-wise approach in some cases
is followed more “strictly” and with the specific results of each step
summarised per water body; in others the required steps are not followed that
clearly and the assessment is done in a summary way (e.g. in GR4/5/8/11/12).
In more detail,
criteria (or thresholds) for defining substantial changes in character and
significant adverse effects of restoration measures on the use are not clearly
stated and expert judgment has been used extensively, with only brief
information provided on this. Similarly, the identification of “better
environmental options” is very brief and the analytical criteria for this step
are mostly not clear. There is no real consideration of e.g. water demand
measures or reduction of irrigation water demands as an alternative to
increasing water supply e.g. through a dam.
HWMB/AWBs are also
designated in relation to new construction works or dams currently being built.
Some RBMPs classify water bodies to be affected by dams currently under
construction as HMWBs, instead of applying Article 4.7 of the WFD.
Uncertainties are
mentioned in general in most RBDs concerning the HMWB/AWB designation process,
due to the lack of relevant monitoring data.
Regarding future
re-assessment of the HMWB/AWB-designation, GR1/2/3 (but not the other RBMPs
assessed) mention that “during the first revision of management plans the
designation of HMWB/AWB has to be reconsidered, taking into account additional
information and measurements which will then be available as well as
developments regarding the setting of GEP through the intercalibration
activities for the whole area of the RBD and for all types of surface water
bodies. All this will then be taken into account in the PoM that will be
proposed in the RBMP of the particular RBD.” GR4/5/8 mention more specifically
that “for water bodies below dams, further analysis is needed (based on better
monitoring results, etc.) regarding the “significance of alteration” and thus
if GES can be reached in these water bodies - giving the final answer if these
water bodies are HMWB or not.” In all RBDs, there is no specific mention of
planned improvements to the methodology applied.
 HMWB or AWB || RBD || Water category 
 Rivers || Lakes || Transitional water || Coastal water || All water bodies 
 Number || % of category || Number || % of category || Number || % of category || Number || % of category || Number || % 
 HMWB || GR01 || 15 || 14 || 2 || 100 || 0 || 0 || 0  || 0 || 17 || 13% 
 GR02 || 4 || 6 || 3 || 50 || 0 || 0 || 1 || 5 || 8 || 8% 
 GR03 || 9 || 11 || 1 || 100 || 0 || 0 ||  0 || 0 || 10 || 10% 
 GR04 || 18* || 12* || 0* || 0* || 0* || 0* || 1* || 11* || 19* || 16% 
 GR05 || 10* || 13* || 1* || 100 || 0 || 0 || 2 || 15 || 13 || 12% 
 GR06 || 1 || 7 || 1 || 100 || 0 || 0 || 2 || 14 || 4 || 14% 
 GR07 || 3 || 4 ||   || 0 || 0 || 0 ||  0 || 0 || 3 || 3% 
 GR08 || 6* || 8* || 1* || 100* || 0* || 0* || 1* || 14* || 8* || 10% 
 GR09 || 26 || 17 || 8 || 57 || 0 || 0 || 0  || 0 || 34 || 20% 
 GR10 || 2 || 2 || 1 || 17 || 0 || 0 || 1 || 9 || 4 || 3% 
 GR11 || 27 || 30 || 2 || 100 || 0 || 0 ||  0 || 0 || 29 || 30% 
 GR12 || 34 || 18 || 5 || 83 || 0 || 0 || 1 || 8 || 40 || 19% 
 GR13 || - || - || - || - || - || - || - || - || - || - 
 GR14 || - || - || - || - || - || - || - || - || - || - 
 Total || 155 || 14 || 25 || 52 || 0 || 0 || 9 || 7 || 189 || 14 
 AWB || GR01 || 2 || 2 ||  0 || 0 || 0 || 0 ||  0 || 0 || 2 || 2% 
 GR02 || 0 || 0 || 1 || 17 || 0 || 0 ||  0 || 0 || 1 || 1% 
 GR03 || 1 || 1 ||  0 || 0 || 0 || 0 ||  0 || 0 || 1 || 1% 
 GR04 || 0* || 0* || 0* || 0* || 0* || 0* || 0* || 0* || 0* || 0 
 GR05 || 3 || 3 ||  0 || 0 || 0 || 0 ||  0 || 0 || 3 || 3% 
 GR06 || 0 || 0 ||  0 || 0 || 0 || 0 ||  0 || 0 || 0 || 0% 
 GR07 || 5 || 6 ||  0 || 0 || 0 || 0 ||  0 || 0 || 5 || 5% 
 GR08 || 4* || 5* || 0* || 0* || 0* || 0* || 0* || 0* || 4* || 5 
 GR09 || 10 || 7 || 0  || 0 || 0 || 0 ||  0 || 0 || 10 || 6% 
 GR10 || 10 || 10 || 1 || 17 || 0 || 0 || 1 || 9 || 12 || 10% 
 GR11 || 3 || 3 ||  0 || 0 || 0 || 0 ||  0 || 0 || 3 || 3% 
 GR12 || 5 || 3 ||  0 || 0 || 0 || 0 ||  0 || 0 || 5 || 2% 
 GR13 || - || - || - || - || - || - || - || - || - || - 
 GR14 || - || - || - || - || - || - || - || - || - || - 
 Total || 43 || 4 || 2 || 4 || 0 || 0 || 1 || 1 || 46 || 3 
Table 8.1.1: Number and percentage of HMWBs and AWBs.
Source: WISE,
corrections/additions provided by EL in late 2014 (marked with *). Some
discrepancies between this information and the RBMPs/their Annexes. 

8.2        
Methodology for setting good ecological
potential (GEP)

While HMWBs/AWBs have
been designated, the RBMPs do not define GEP, so the relevant steps for setting
GEP have not been applied, which is not in line with the WFD requirements. 
No national guidance
exists on the issue, while no specific plans are mentioned in the RBMPs for
setting GEP. According to the Greek authorities a national guidance will be
developed in the future.
According to Greek
authorities, given the lack of methodologies, for the first RBMP GEP was
defined as equal to Good Ecological Status (GES). This statement is implausible
from the point of view of the WFD. If the water body is designated as HMWB is
because the physical modification that is necessary to enable the water use
does not allow the water body to achieve GES. The underlying problem is the
lack of assessment methods which are sensitive to hydromorphological
modifications. This lack of sensitive methods makes it impossible to
effectively derive and implement GEP and to measure the improvements achieved
to the associated mitigation measures.

8.3        
Results of ecological potential assessment in
HMWB and AWB

As stated above, no GEP
has been defined. At the same time, GR4/5/6/7/8/9/10/11/12 mention that for
this implementation cycle, the GEP is defined as the usual “good ecological
status”; at the same time, GR1/2/3 just mention GEP as the objective for
HMWB/AWB, without any further specification. 

9.            
Assessment of chemical status of surface waters
9.1        
Methodological approach to the assessment

The relevant Ministerial Decree
51354/Ε103/2010 (FΕΚ 1909Β/8-12-2010) includes the
substances listed in Annex I of the Environmental Quality Standards Directive
(EQSD). The Decree calls for the consideration of background concentrations as
well as bioavailability factors of metals, and for the monitoring of biota and
sediments. It also presents an approach for monitoring in mixing zones (Article
4). 
It is recognised that only a few
priority substances (e.g. in GR05: Cadmium, Nickel, Lead and Mercury) were measured
in most water bodies of the RBDs with an exception of certain water bodies
(e.g. in GR05, Lake Pamvotida) where additional priority substances were
measured.  It is not clear whether only specific substances have been assessed
(as opposed to all of them) because expert judgment and/or existing studies
ruled out the relevance of others for the specific surface water body. It
appears also that the substances used in the assessment were not common across
the water bodies, i.e. different substances have been used in different water
bodies. The standards used for the all substances follow Annex I of the EQSD. 
Neither the standards in biota or
sediment nor the background concentrations that are set in the relevant decree
51354/Ε103/2010 (FΕΚ 1909Β/8-12-2010) were implemented in
the assessed RBMPs. Bioavailability was also not applied. The same applies for
the issue of mixing zones (Article 4). 
Table 9.1.1 lists the substances
reported as responsible for exceedances per RBD, mentioning also the number of
water bodies per substance. According to the table, heavy metals (present in 88
water bodies across the RBDs), other pollutants (present in 40 water bodies
across the RBDs) and pesticides (present in 39 water bodies across the RBDs)
are mainly responsible for those exceedances. It can also be noted that GR12
(96 WBs), GR11 (38 WBs) and GR03 (32 WBs) are the RBDs with the highest number
of water bodies with exceedances. 
 Substance causing exceedance || Exceedances per RBD 
 GR01 || GR02 || GR03 || GR04 || GR05 || GR06 || GR07 || GR08 || GR09 || GR10 || GR11 || GR12 || GR13 || GR14 
 1 Heavy Metals - aggregated || 4 ||   || 6 ||   ||   ||   ||   ||   || 16 || 11 || 9 || 42 ||   ||   
 1.1 Cadmium ||   || 1 || 5 || 1* ||   ||   ||   || 5* ||   || 2 ||   ||   ||   ||   
 1.2 Lead ||   ||   ||   ||   ||   ||   ||   ||   ||   || 3 ||   ||   ||   ||   
 1.3 Mercury ||   ||   || 10 ||   ||   ||   || 1* ||   ||   ||   ||   ||   ||   ||   
 1.4 Nickel ||   ||   ||   ||   ||   ||   ||   ||   ||   || 2 ||   ||   ||   ||   
 2 Pesticides – aggregated ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   || 14 || 25 ||   ||   
 2.5 Diuron ||   ||   ||   || 3* || 1 ||   || 3 || 4* ||   ||   ||   ||   ||   ||   
 2.5 Isopruton ||   ||   ||   ||   ||   ||   ||   || 2* ||   ||   ||   ||   ||   ||   
 3 Industrial Pollutants - aggregated ||   ||   ||   ||   ||   ||   ||   ||   || 1 ||   || 13 || 10 ||   ||   
 3.3 Brominated Diphenylether ||   ||   ||   ||   || 1 ||   ||   || 1* ||   ||   ||   ||   ||   ||   
 3.8 Di(2-ethylhexyl)phthalate (DEHP) ||   ||   ||   ||   ||   ||   ||   ||   || 1 ||   ||   ||   ||   ||   
 4 Other pollutants - aggregated || 7 || 3 || 11 ||   ||   ||   ||   ||   || 2 ||   || 2 || 15 ||   ||   
 4.9 Hexachlorobutadiene ||   ||   ||   ||   ||   ||   || 3 ||   || 1 ||   ||   ||   ||   ||   
 4.11 Polyaromatic hydrocarbons ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   || 4 ||   ||   
 4.17 Tributyltin compounds ||   ||   ||   || 3* || 1 ||   || 3 || 4* ||   ||   ||   ||   ||   ||   
Table 9.1.1: Substances
responsible for exceedances
Source: WISE 
*corrections/additions
provided by EL in late 2014.

10.        
Assessment of groundwater status

The Common Ministerial Decree
39626/2208/ Ε130/2009 sets the measures for the protection of groundwater
against pollution and deterioration, in compliance with the provisions of the
EU Directive 2006/118/EC. 
All groundwater bodies (GWBs) (366 in
total) have been assessed for both chemical and quantitative status. There are
15% of GWBs in poor chemical status and 17% are in poor quantitative status,
while 78% are in good status for both chemical and quantitative aspects.
 Status || Poor chemical status || Poor quantitative status || Good status 
 GR01 || 2 || 2 || 24 
 GR02 || 4 || 2 || 22* 
 GR03 || 10* || 5 || 17* 
 GR04 || 1* || 3* || 23* 
 GR05 || 1 || 1 || 25 
 GR06 || 11 || 9 || 12 
 GR07 || 6 || 5 || 38 
 GR08 || 4* || 10* || 21* 
 GR09 || 4 || 14 || 48 
 GR10 || 8 || 11 || 26 
 GR11 || 1 || 1 || 14 
 GR12 || 4 || 0 || 14 
 GR13 || - || - || - 
 GR14 || - || - || - 
 Total || 56 || 63 || 284 
Table 10.1: Number and percentage
of groundwater bodies and their status.
Source: WISE
*corrections/additions provided by EL in late 2014

10.1    
Quantitative status

In the 12 RBDs
reviewed so far in this report, approximately 83% of groundwater bodies are in
good quantitative status and 17% in poor. The main reason for failure to
achieve good quantitative status was reported to be the exceedance of the
available groundwater resource by the long-term annual average rate of
abstraction, which may result in a decrease of groundwater levels and saline
intrusion. The significant diminution of the status of surface waters was
reported as an additional reason in one GWB of GR11.
For the
assessment of the GW quantitative status the following criteria are mentioned
to be considered in principle:
1) Checking the
water balance. 
2) Checking the
impact on surface water flow conditions: the influence of a GWB on SWBs is
considered significant and further investigated when the groundwater
abstractions are more than 50% of the total freshwater abstractions of the
River Basin of the respective SWB. 
3) Checking the
impact on terrestrial ecosystems. 
4) Checking
saline intrusion: definition of mean annual abstractions in combination with
the long-term annual average change of groundwater levels in order to locate
the saline water front.
The above
mentioned Water Framework and Groundwater Directives’ criteria have been
adjusted in practice to the limitations or constraints imposed by the available
data during the implementation process. Thus, in practice, the above checks are
not consistently performed in all of the GWBs due to data limitations in terms
of adequacy, continuity, frequency, and spatiotemporal coverage. The
quantitative comparison of the balance between recharge and abstraction was not
always feasible (e.g. in 39% of the GR12 GWBs), the groundwater level records
were sometimes limited to 5 year-long records (e.g. in GR01), impeding trend
detection. In these cases the assessment was based on simplified practical
criteria, supportive evidence and expert knowledge. It seems that the balance
between recharge and abstraction, the groundwater level trends, the impacts of
abstractions (considered significant if more than 50% of the total freshwater
abstractions of the River Basin with associated SWBs), and the identification
of saline intrusion were the criteria mostly considered in the assessment, and
of course to the extent that they were underpinned by available data. It has to
be noted that the data on abstraction were mostly estimates obtained from water
needs and water use data.

10.2    
Groundwater chemical status

In the 12 RBDs
assessed in this report, approximately 85% of groundwater bodies are in good
chemical status and 15% in poor. The main pollutants causing failure to achieve
good chemical status were most commonly reported to be chloride, nitrates,
conductivity and sulphate, followed by aluminium, lead, chromium, nickel and
arsenic. Ammonium was also reported in some cases. It must be noted that the
assessment of chemical status has been based on the parameters for which data
were available for at least two consecutive years. Thus, in most GWBs these
were limited to pH, conductivity, chloride, nitrates, nitrogen dioxide,
ammonium, sulphate. Lead, chromium, nickel and aluminium were assessed in a
subset of the GWBs, while dissolved oxygen, cadmium, arsenic, mercury,
trichloroethylene- tetrachloroethylene and pesticides have not been assessed
due to non-availability of data. Some GWBs have been classified as good
chemical status although threshold values (TVs) were exceeded at one or more
monitoring points, as long as these were less than 20% of the total number of
monitoring sites in the whole GWB. Additional criteria are mentioned to be
considered in this case such as the assessment of saline intrusion, the
assessment of the degradation of chemical and ecological status of the SWBs (in
case the contribution of pollutants from a GWB to SWBs is more than 50%, the
former is classified as being in poor chemical status), the assessment of the
degradation of terrestrial ecosystems, and the assessment of the impact on
drinking water resources. It seems, however, that the 20% criterion (maximum
allowed number of monitoring sites exceeding GW TVs) was the one that mostly
influenced the assessment, along with the identification of anthropogenic
pressures.
In general,
limited data were available on the groundwater chemical parameters, which often
led to the adoption of some simplifications. The diminution of surface water
chemistry and ecology and the damage to groundwater-dependent terrestrial
ecosystems due to transfer of pollutants from GWBs has been considered in the
assessment of the chemical status of GWBs in cases where possible and based on
simplified and practical criteria (e.g. in case the contribution of pollutants
from a GWB to SWB(s) is more than 50%, the former is classified as being in
poor chemical status).
There is no obvious statement that all
pollutants posing a risk of failing environmental objectives for GWBs have been
considered. There are no data available for trichloroethylene and
tetrachloroethylene. Thus, these parameters have not been considered in the
assessments and no relevant maps could be produced. The measurements of heavy
metals (Pb, Cd, As, Hg) have not been systematic. Thus, in many GWBs these data
have also not been considered in the assessment. There are nevertheless
additional parameters and indicators which have been considered in the
assessments (additional to the ones proposed by the Annex II Part B of the GWD)
such as pH, NO2, NO3 and in some cases Fe, Mn, Mg, B, and
for which there are indications if TVs are exceeded, which indirectly implies
that the actual relevant pollutants might have been considered.
The TVs used for the assessment of the
GWBs’ chemical status are based on the national values as defined by the
Ministerial Decree 1811/30-12-2011. This Ministerial Decree defines the quality
standards (QSs) and TVs at national level based on Art. 3 of the Common
Ministerial Decision 39626/2208/Ε130/2009. According to the latter, these
TVs have been defined following the Guidelines provided in Annex II Part A of
the GWD. For nitrates and active substances in pesticides the QSs are the ones
established in Annex I of the GWD. On top of the Annex II substances, Greece
has also set TVs for Ni, Cr, Al, NO2, NO3 and pH. The
national TVs for GWBs are harmonised with the relevant Drinking Water Quality
Standards due to the fact that a majority of the GWBs are used to cover
drinking water needs, but to also allow the cross-comparison across GWBs and in
relation to other EU GWBs. According to the Ministerial Decree 1811 the TVs can
be adjusted due to natural background levels on a case-by-case basis, and this
was actually applied in some GWBs where the high levels were solely due to natural
background and not any anthropogenic causes.
Upward trends have been identified in
the GWBs with available data (time-series of significant length). A significant
upward trend is defined when the rate of increase of the concentration of a
substance is higher than 10% of the respective TV. The trend of the GWB is
identified when at least 80% of the monitoring sites of the GWB demonstrate a
significant upward trend. The time-series considered were of variable lengths
across the GWBs (in some limited to 4 years, while in others 8-15 years long).
For the next cycle of the RBMPs it is suggested (as depicted in some RBMPs)
that the year 2007-2008 is used as a reference, which is the year benchmarking
the beginning of the new Monitoring Programme. All
starting points for trend reversal are defined with 75 % of the GW-QS and TVs,
but no methodology is defined yet (either because upward trends have not been
identified in the GWBs with available data, or due to lack of information).
There is no mention of the assessment of plumes in the RBMPs.

10.3    
Protected areas

The status of groundwater drinking water protected
areas is presented in Table 10.3.1 below. In total 89 groundwater drinking
water protected areas are identified for the whole territory, of which 95.5%
are classified in good status and 4.5% in unknown.
No information is available on the status of other
protected areas such as water-dependent Natura 2000 protected areas, as the
objectives have not been set (see section 11.1). 
 RBD || Good || Failing to achieve good || Unknown 
 GR01 || 4 ||   ||   
 GR02 || 5 ||   ||   
 GR03 || 3 ||   ||   
 GR04 || 4* || -  || - 
 GR05 || 8 ||   ||   
 GR06 || 3 ||   ||   
 GR07 || 10 ||   || 4 
 GR08 || 4* || -  || - 
 GR09 || 9 ||   ||   
 GR10 || 3 ||   ||   
 GR11 || 14 ||   ||   
 GR12 || 18 ||   ||   
 GR13 || - || - || - 
 GR14 || - || - || - 
 Total || 85 || 0 || 4 
Table 10.3.1: Status of groundwater
drinking water protected areas
Source: WISE
*corrections/additions provided by EL in late 2014

11.        
Environmental objectives and exemptions

Based on the
information submitted by EL in late 2014, Greece has set the objective to
achieve good or better status in 330 surface water bodies (24%) by 2015, with a
5.5 % increase compared with the 2009 figures (Table 6.7). This figure is
significantly lower than the EU average.
The numbers of water
bodies at good or better status varies significantly from RBD to RBD regarding
the increase expected (from 0 to 18%) as well as regarding the number of water
bodies in good status in 2015 (1.9% to 59%), even if the number and types of
measures taken does not differ significantly among the RBDs.
The issue of water
bodies currently in “unknown” status and when they will reach good or better
status differs between the RBDs: GR11/12 mention that all water bodies
currently in unknown status will reach good or better status by 2015. The other
RBDs mention that after more monitoring information becomes available, the
situation will have to be assessed and potentially more measures taken.
In groundwater bodies,
no increase regarding good quantitative status (Table 6.11) is expected from
2009 to 2015 (while the 2009 number of groundwater bodies in good status is
already high (83.1%)). There is a similar situation regarding chemical status
(Table 6.10), with an increase of 0.3% (from the already high percentage of
groundwater bodies in good chemical status (84.7%)).

11.1     Additional objectives in protected areas

Protected areas (for
drinking water, shellfish, bathing water and Natura 2000 sites) have been
designated in all of the RBDs.
No additional
objectives going beyond the achievement of good ecological status/potential are
set or defined. For protected areas, the main environmental objectives are the
compliance (by 2015 at the latest) with the specific standards and objectives
of Community legislation under which the individual protected areas have been
established, and achieving good status by 2015.

11.2    
Exemptions according to Article 4(4) and 4(5)

There are some discrepancies in the
reporting of the numbers of Article 4.4. and Article 4.5 exemptions applied
between the corrections provided by EL in late 2014, the WISE data and the
RBMPs/their Annexes. Based on the information provided by EL, there are a total
of 430 Article 4.4 exemptions reported, and none for Article 4.5.
Overall, no methodology for the
“disproportionality of costs” argument was developed or found. There is very
limited use of the “natural conditions” argument.
Most of the Article 4.4 exemptions (266)
are applied with the reason of “technical infeasibility” given. The general
argument behind these exemptions (even if the details of the argument differ
according to the RBD) is that there is insufficient time available for the
measures to be implemented or to “work” (long recovery time of the water
bodies, which seems to be more related to natural conditions), so that the
water bodies reach good status in time. The use of these arguments for exemptions
in the Greek RBMPs are therefore not sufficiently clear. 
Regarding Article 4.4, indications of
which impacts and which drivers are causing the application of this exemption
can be found in most RBDs (but not in GR11/12), but with varying level of detail.
In some RBDs, a summary table is given for each exemption according to Art.
4.4, in which the “potential reasons for not reaching the environmental
objectives” as well as the impacts of these drivers were indicated.
It needs to be noted that a large number
of water bodies in Greece is in “unknown” status. For these water bodies, no
exemption has been applied so far. It is unclear if – after additional
monitoring information becomes available – these water bodies will be in “good
status”, so additional exemptions might then have to be justified.
 RBD || Article 4(4) || Article 4(5) 
 R || L || T || C || GW || R || L || T || C || GW 
 GR01 || 5* || 0 || 0 || 0 || 2 || 0 || 0 || 0 || 0 || 0 
 GR02 || 3* || 0 || 0 || 1* || 4* || 0 || 0 || 0 || 0 || 0* 
 GR03 || 32* || 0 || 0 || 1 || 10 || 0 || 0 || 0 || 0 || 0* 
 GR04 || 7* || 5* || 4* || 2* || 2* || 0* || 0* || 0* || 0* || 0* 
 GR05 || 6* || 1 || 4 || 4 || 1* || 0* || 0 || 0 || 0 || 0 
 GR06 || 7 || 0 || 0 || 7 || 12 || 0 || 0 || 0 || 0 || 0 
 GR07 || 28 || 0 || 1* || 6 || 8 || 0 || 0 || 0 || 0 || 0 
 GR08 || 50* || 1* || 0* || 2* || 11* || 0* || 0* || 0* || 0* || 0* 
 GR09 || 17 || 5 || 1 || 0 || 14 || 0 || 0 || 0 || 0 || 0 
 GR10 || 9 || 2 || 1 || 1 || 12 || 0 || 0 || 0 || 0 || 0 
 GR11 || 46* || 2 || 1 || 2 || 1 || 0 || 0 || 0 || 0 || 0 
 GR12 || 74* || 4 || 5 || 2 || 4 || 0 || 0 || 0 || 0 || 0 
 GR13 || - || - || - || - || - || - || - || - || - || - 
 GR14 || - || - || - || - || - || - || - || - || - || - 
 Total || 284 || 20 || 17 || 28 || 81 || 0 || 0 || 0 || 0 || 0 
Table 11.1.1: Number of WBs with
Exemptions for Article 4(4) and 4(5)
Source:
WISE, corrections/additions provided by EL in late 2014 (marked with *). Some
discrepancies between this information and the RBMPs/their Annexes.
 RBD || Global[9] 
 Technical feasibility || Disproportionate costs || Natural conditions 
 Article 4(4) || Article 4(5) || Article 4(4) || Article 4(5) || Article 4(4) || Article 4(5) 
 GR01 || 2* || 0* || 3* || 0* || 0* || 0* 
 GR02 || 3* || 0* || 1* || 0* || 0* || 0* 
 GR03 || 21* || 0 || 12* || 0* || 0* || 0* 
 GR04 || 18* || 0 || 0 || 0 || 0 || 0 
 GR05 || 15* || 0* || 0 || 0 || 0 || 0 
 GR06 || 14 || 0 || 0 || 0 || 0 || 0 
 GR07 || 35* || 0 || 0 || 0 || 0 || 0 
 GR08 ||  53* || 0 || 0 || 0 || 0 || 0 
 GR09 || 17 || 0 || 0 || 0 || 6 || 0 
 GR10 || 5 || 0 || 8 || 0 || 0 || 0 
 GR11 || 51* || 0 || 0 || 0 || 0 || 0 
 GR12 || 85* || 0 || 0 || 0 || 0 || 0 
 GR13 || -  || -  || -  || -  || -  || -  
 GR14 || -  || -  || -  || -  || -  || -  
 Total || 266 || 0 || 24 || 0 || 6 || 0 
Table 11.2.1: Number of surface
water bodies with Article 4(4) and 4(5) exemptions
Source:
WISE, corrections/additions provided by EL in late 2014 (marked with *). Some
discrepancies between this information and the RBMPs/their Annexes.
Figure 11.2.1: Number
of WBs with Article 4(4) and 4(5) exemptions
T = Technical feasibility, D = Disproportionate costs;
N = Natural conditions

11.3    
Exemptions according to Article 4(6)

No
exemptions according to Art. 4.6 have been applied. 

11.4    
Exemptions according to Article 4(7)

Overall, the application of article 4(7)
for new modifications (in particular for dams) is unclear and incomplete in the
Greek RBMPs.
The way new modifications are presented
and grouped varies significantly (similar in each of the groups of RBMPs GR
1/2/3, GR 4/5/8, GR 6/7, GR9/10 and GR11/12). In addition, the way these
modifications are initially assessed regarding if Article 4.7 needs to be
tested, also varies among the RBDs and cannot be seen as sufficiently clear;
there are many modifications reported for which it appears that an Article 4.7
exemption should have been justified (or at least tested).
In seven RBDs (GR4/5/8/9/10/11/12), such
exemptions have been applied, while there are differences regarding the number
of water bodies exempted due to Article 4.7 (see Table 11.4.1 below). In
addition and beyond these, there are another five RBDs where an
Article 4.7 “test” was done, but in the end the exemptions were not
applied:

 GR01: 6 cases tested; 
 GR02: 7 cases tested; 
 GR03: 13 cases tested; 
 GR04: 3 additional cases tested to the
     ones where Art. 4.7 was applied; 
 GR05: 9 additional cases tested to
     the ones where Art. 4.7 was applied; 
 GR06: 6 cases tested; 
 GR07: 1 case tested (while another
     6-8 are briefly discussed in the Art. 4.7 context); 
 GR08: 11 additional cases tested to
     the ones where Art. 4.7 was applied; 
 GR09: 3 additional cases tested to
     the ones where Art. 4.7 was applied; 
 GR010: no additional
     cases tested to the ones where Art. 4.7 was applied; 
 GR012: 1 additional case tested to
     the ones where Art. 4.7 was applied. 

These tested cases mostly relate to the
construction of new dams. Given the severe impacts that dams have on water
bodies, it would be expected that article 4.7 would be applied in all cases,
not only "tested". This appears not to be the case. This may be
related to the way the hydromorphological pressures are assessed (see section
4.4). Only large dams above 15 m are considered "significant" if the
regulating capacity in relation to the river flow is beyond certain threshold.
The impacts are then considered significant downstream of the dam. This
approach overlooks the following important issues:

 smaller hydromorphological impacts
     can be severe, e.g. disruption of continuity is significant for dams
     smaller than 15 m
 the impacts on the water bodies
     where the dams will be located and the upstream stretches where the river
     is converted into a reservoir are not properly assessed; the approach
     seems to consider that if the reservoir, once built, would achieve GEP,
     article 4.7 is not needed. Quite the contrary, the achievement of GEP is
     not equivalent to GES and therefore all river water bodies which are
     modified into a reservoir should be considered under article 4(7) as the
     works will prevent the water bodies from achieving GES.  
 overlooks the obligation under
     article 4.7a to incorporate all mitigation measures into the new
     modifications, including the necessary ecological flow to ensure that
     downstream water bodies achieve good status. 

The justification for the dams according
to the conditions in article 4.7 should be included in the RBMPs, including the
strategic alternatives to the dams (e.g., other projects which may achieve the
same objective by other means).
It needs to be noted also that small
hydropower plants are treated very differently regarding the Article 4.7
“testing” (aggregated or per plant, etc.).
As an example of a RBD where no Article
4.7 exemption was identified but the issue was discussed, GR01 first excludes
small projects as well as projects that “have generally (at a higher level) a
positive impact on reaching the WFD-objectives”. It should be stressed that if
a project is liable to cause deterioration or prevent the achievement of GES in
a water body, the fact that has beneficial impact on other water bodies does
not mean that article 4.7 would not be applied. The information on impacts and
benefits should be used in the assessment under article 4.7c in a transparent
way. GR01 RBMP presents a very long list (119 projects) of all planned new
measures and modifications (at any planning phase) and states that “for
modifications that will not be completed by 2015 or additional modifications,
these have to be analysed regarding their effects on WFD-implementation and be
included in the future revisions of the RBMP”. This long list includes a column
“affects reaching the WFD-objectives”, where for projects that are already
constructed, under construction or with secured financing, a simple “yes/no”
answer is given (NB: nothing is indicated for the projects in the category with
environmental permit or in final/preliminary planning phase). For six specific
projects (the “primary list”), including two dams (one of which is under
construction), one programme regarding at least eleven new micro-dams for
hydropower (in addition to the existing four), as well as three projects for
water supply, Article 4.7 is discussed but not applied.
Regarding
the way Article 4.7 is “tested”, again significant variation can be found
between the RBDs. Overall, the plans do not provide sufficiently detailed
analysis of the application of Article 4.7 provisions. For example, the way the
environmental effects of a new modification are assessed is brief with
arguments used being e.g. “EIA performed”, no deterioration of status (even if
a big dam is planned), no water bodies affected (since smaller than 0.5 km2),
etc. A benefit of the modification that is often mentioned is reducing
abstractions from groundwater bodies. An especially significant element is the
“check” of alternatives that would be better environmental options (e.g. water
demand options) which often is very brief or non-existent. Cumulative effects
have not been taken into account for the assessment under Article 4(7). 
It
should be stressed that completion of an EIA does not substitute the assessment
under article 4.7. The objectives, requirements and assessments of the EIA and
WFD are complementary but distinct. Therefore the fact that EIA has been
performed does not exempt Member States from applying article 4.7.
 RBD || Number of Water Bodies acc. to corrections provided by EL in late 2014 || Number of Water Bodies acc. to WISE-submission || Number of Water Bodies acc. to the RBMPs/Annexes 
 GR01 || 0 || 0 || 0 
 GR02 || 0 || 0 || 0 
 GR03 || 0 || 0 || 0 
 GR04 || 5 || 0 || 11 
 GR05 || 1 || 0 || 2 
 GR06 || 0 || 0 || 0 
 GR07 || 0 || 0 || 0 
 GR08 || 2 || 0 || 4 
 GR09 || 3 || 3 || 3 
 GR10 || 4 || 1 || 4 
 GR11 || 1 || 1 || 1 
 GR12 || 9 || 5 || 9 
 GR13 || - || - || - 
 GR14 || - || - || - 
 Total || 25 || 10 || 34 
Table 11.4.1 Number of WBs with Article 4(7)
exemptions
Source: WISE,
corrections provided by EL in late 2014, RBMPs/Annexes.

11.5    
Exemptions to Groundwater Directive

Overall,
no information is included in the RBMPs on exemptions under Article 3 of the
Groundwater Directive.

12.        
Programmes of measures

According to Annex VII of the WFD, the RBMPs should contain a
summary of the programmes of measures (PoM), including the ways in which Member
States expect to achieve the objectives of Article 4 of the WFD. The programmes
should have been established by 2009, but are required to become operational
only by December 2012. Due to the delayed submission of the Greek RBMPs, this
deadline cannot be kept.
The assessment in this section is based on the PoMs as summarised
by the Member State in its RBMPs.

12.1    
Programme of measures – general

Most RBMPs report that after results of
the new monitoring network are available, the RBMP/PoMs will be revised or
updated by 2015 (with the exception of GR11/12).
There is no clear link between the
identified pressures, the status of water bodies, and thus the specific needs
for the measures to be taken. The RBMPs do not indicate that the status
assessments of surface water and groundwater bodies were used to identify their
Programmes of Measures.
All of the RBMPs include a Programme of
Measures (PoM), while no sub-basin reports regarding the RBMP or the PoM have
been prepared with the exception of the Prespa sub-basin management plan (part
of GR09). The PoMs are structured in the following way (this structure and its
specification are similar between the different RBDs, but not identical – the
same approach is taken each in GR1/2/3, GR4/5/6/7/8 and GR11/12):
§    Basic
measures and “programmed actions”: first, the existing implementation status
regarding “other Directives” is presented (mainly by indicating the legal
transposition and actions taken to implement them); while all Directives are
indicated as “implemented”, indications are given per Directive on what
additional activities are planned in order to implement the WFD. These
“programmed actions” are presented differently between PoMs and with varying
levels of detail or specification (e.g. sometimes a clear “bullet list” of
actions/summary table is given, indication of the responsible institution for
their implementation, inclusion of relevant information in WISE, which are
missing in other cases). For two RBDs (GR011/12), the “programmed actions”
called “proposals” and their specification is less clear. The number of these
“actions” varies in the different RBDs, while the number of Directives
considered and for which additional action is needed varies too, e.g. with
fewer Directives in GR04/5/8.
§    “Other
basic measures”: here, a list of measures is presented for each RBD (according
to categories as required by Article 11(3)(b-i)); these are similar across the
RBDs, but with some differences (some measures not found in some RBDs) or the
addition of “specific” measures to be taken in some RBDs.
§    Supplementary
measures: these are in support of the basic and other basic measures in order
to comply with the WFD-objectives. Some RBDs (e.g. GR1/2/3) include a specific
explanation or analysis for which water bodies supplementary measures are
needed (that is, supplementary measures taken for water bodies which - based on
the current limited knowledge - are in either moderate, poor or bad status as well as for water bodies that
are either in unknown or in good condition but there is clear evidence through
the analysis of pressures that they are at risk of not achieving the
environmental objectives; GR09/10 explain that the decision regarding for which
WBs supplementary measures are needed was an assessment on if the basic/other
basic measures are sufficient to reach good status or not). Such an explanation
is missing in other RBDs; a clear indication that supplementary measures are
taken also in water bodies of “unknown” status is only found in GR01/2/3.
Overall, it remains unclear how the need for supplementary measures is
identified in practice, since there is no methodology developed for the
assessment of the effects of basic and other basic measures. GR01/2/3/9/10 also
include a distinction of supplementary measures into horizontal (for the whole
RBD) and specific (for specific water bodies), which has not been done for the
other RBDs. Some RBDs indicate which measure is applied in which water body,
others do not. In most cases, “construction works” (new dams, etc.) are
included as supplementary measures in the PoM. There are no measures specifically
oriented towards water bodies that are in “unknown” status, although some of
the more general measures will affect them.
Regarding the timing of measures, in all
RBDs a “prioritisation” of measures has been done, which is similar but not
identical among the different plans. In principle, the short-term measures will
be implemented within this management period (i.e. by 2015); measures
implemented 2015-2021 are mid-term, while the appropriate preparation and programming
of activities takes place in the current management period; measures
implemented 2021-2027 are long-term, since these need a long preparation time
for their implementation. All RBMPs contain an indication of whether measures
are short-, mid- or long-term.
Regarding the indication of the level or
scale at which the measures have been established, this varies greatly among
the RBDs. Many measures presented in the RBMPs have a national or basin-wide
scope; at the same time, the information provided in WISE on the geographic
scope varies between the RBDs, even for the same measure (e.g. concerning the
“other basic” measures, GR1/2/3 indicate “national level” while e.g. for
GR11/12 the implementation level is indicated as national, RBD, part of RBD or
groundwater body for each measure).
The authorities responsible for the
implementation of measures are indicated in most RBDs (in some they are called:
“involved authorities”), with public authorities being responsible for almost
all measures (there is specific mention of private entities also contributing
to some specific measures in GR04/5/7/8/9/10).
Regarding the cost-effectiveness
calculation of measures, this is not referred to in any PoM or RBMP. At the
same time, in each RBD a cost-effectiveness calculation was done in a separate
document with diverging methodologies, but all of them seem not to have been
used for the actual “prioritisation” of measures.
Some information regarding costs of
individual measures is provided (mostly for supplementary measures), but is not
clearly identified for all measures.[10] The
summary information found on total costs of measures is diverging: GR6/7/11/12
indicate summary figures for each basic/other basic and supplementary measures
(with GR11/12 providing disaggregated figures for basic and other basic
measures), GR9/10 provide summary numbers only for all basic measures, while
GR1/2/3/4/5/8 indicate total costs only for the supplementary measures.
In most cases, new “construction works”
(e.g. WWTP and new dams, some of which are already under construction) are part
of the PoM and their relevant costs are included in the total costs
calculations. For some of them, financing is indicated as secured, including
EU-funds.
Information on financing is available
for only a few plans and differs between plans: some RBDs (GR1/2/3/6/7) mention
the “state of funding” when discussing the supplementary measures (showing that
for most measures, no financing is available or secured yet and has to be
found), while some (GR1/2/3) indicate the “available financial resources for
water management measures per RBD” based on an allocation of available funding
to the different RBDs. No systematic indications regarding financing are found
in GR4/5/8/910//11/12, yet fragmentary financing information for some specific
measures is indicated. GR06/07 show explicitly that for most measures, no
financing is available yet and has to be found (“the relevant authorities have
included this measure in their planning in order to find funding for them”).
For the international RBDs, there is no
reference found on coordination of the PoM with neighbouring countries so far;
only GR11/12 indicate plans to coordinate the RBMP for the next implementation
cycle with Bulgaria.

12.2    
Measures related to agriculture

All RBMPs refer to agriculture as a
significant pressure due to diffuse pollution and abstractions (while for some
RBDs the issue of abstractions is seen as relevant for only a limited number of
water bodies). The issue of pressures related to self-abstractions is not
considered in detail. Point source pollution from agriculture is not cited as a
significant pressure. Regarding hydromorphological pressures from agriculture,
these are only mentioned in a general way and as related to “big” construction
works for irrigation (e.g. dams). There is no consideration or discussion of
“smaller” hydromorphological pressures linked to agriculture, such as bank
reinforcements, land reclamation, drainage, etc., nor is there consideration of
soil erosion due to agriculture.
The extent of the sector’s involvement
in the preparation of the RBMPs is limited; there is no specific approach
regarding this sector for the public participation activities regarding the
RBMP/PoM development (see the general discussion of public participation activities).
Therefore, the extent to which the specific measures have been discussed and
agreed with the agricultural sector cannot be assessed at this point.
There is no further specific indication
given regarding the scope of measures as related to agriculture as well as
regarding to their timing (see PoM-general section above on these two issues).
Regarding the costs of measures and financing commitments, also here the
general information provided holds (see PoM-general), so the costs of measures
is unclear and in the majority of cases there is no secured funding. In some
RBDs there is fragmentary information regarding Rural Development Programme
(RDP) funds being used. There are no indications that compensation payments
according to Article 31 will be used.
No information was found on how and when
the detailed specifications on the implementation of the measures will be done. Overall, the detailed
contribution of each measure to achieving the objectives is not specified,
while no specific information on the control or inspection of the
implementation of agricultural measures is provided.
The Programmes of Measures identify a
range of measures to address pressures arising from agriculture, but these are
in most cases general measures, mainly referring to legal, licensing or
permitting changes and further information collection.
There are technical measures identified
in most RBDs dealing with fertiliser and pesticide application and changes
towards low-input farming, while at the same time remaining quite general or
limited in scope with unclear impacts on the related pollution issues.
Regarding hydromorphological measures, specific measures related to agriculture
are limited and mainly refer to specific “hot spots” (deltas, lagoons, etc.) in
some RBDs that refer indirectly to agriculture (also as part of multi-objective
measures). Erosion
is mentioned only very generally in the RBMPs and PoMs, with no specific
PoM-measures found relating to this issue (even though desertification is an
issue for Greece). At the same time and according to information provided by EL
in late 2014, the Code for good
agricultural practice that has been implemented with the 125347/568/2004
ministerial decision includes details of legal requirements for sustainable
soil management that farmers must follow to ensure soil conservation and reduce
soil erosion.
All of the PoMs include measures for
water savings or increased efficiency of water usage in agriculture,
highlighting the importance of this sector’s abstractions; at the same time,
they focus mostly on irrigation efficiency measures and improving or changing the supply
infrastructure, thus e.g. substituting groundwater abstractions with other
water sources (new dams). It is difficult to estimate if these measures are
sufficient to reduce the abstraction pressures from agriculture to a sufficient
degree, especially since no indication could be found on the expected water
savings for each measure.
Regarding economic instruments, in some
RBDs the promotion of cooperative measures is referred to, while the general
“other basic” measure regarding revision of the water pricing policy is stated
to be applied for all RBDs. At the same time, it remains unclear if this water
pricing measure is also oriented towards agricultural water pricing (see
Article 9 measures section).
A range of non-technical measures are
cited in the PoM: these mainly include measures for implementing existing
relevant EU-Directives, measures related to increased knowledge for
decision-making, measures related to environmental permitting and licencing,
and some measures regarding improved controls, institutional changes,
advice/training/awareness raising and specific projects are included.
Table 12.2.1 includes an overview of
which measures are considered in the RBMPs regarding agriculture. 
 Measures || GR01 || GR02 || GR03 || GR04 || GR05 || GR06 || GR07 || GR08 || GR09 || GR10 || GR11 || GR12 || GR13 || GR14 
 Technical measures 
 Reduction/modification of fertiliser application || P || P || P || P || P ||   ||   || P || P || P || P || P ||   ||   
 Reduction/modification of pesticide application || P || P || P || P ||   || P || P || P || P || P ||   ||   ||   ||   
 Change to low-input farming || P || P || P || P || P || P || P || P || P || P ||   ||   ||   ||   
 Hydromorphological measures ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   || P ||   ||   
 Measures against soil erosion ||   ||   ||   ||   ||   ||   ||   ||   ||||   ||   ||   ||   ||   
 Multi-objective measures ||   ||   ||   || P || P ||   ||   || P || P || P || P || P ||   ||   
 Water saving measures || P || P || P || P || P || P || P || P || P || P || P || P ||   ||   
 Economic instruments 
 Compensation for land cover ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Co-operative agreements ||   ||   ||   || P || P || P || P || P || P || P || P || P ||   ||   
 Water pricing || P || P || P || P || P || P || P || P || P || P ||   || P ||   ||   
 Nutrient trading ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Fertiliser taxation ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Non-technical measures 
 Implementation and enforcement of existing EU legislation || P || P || P || P || P || P || P || P || P || P || P || P ||   ||   
 Controls || P || P || P || P || P || P || P || P || P || P || P || P ||   ||   
 Institutional changes || P || P || P || P || P || P || P || P || P || P || P || P ||   ||   
 Codes of agricultural practice ||   ||   ||   || P ||   ||   ||   || P ||   ||   ||   ||   ||   ||   
 Advice and training || P || P || P || P || P || P || P || P || P || P || P || P ||   ||   
 Awareness raising ||   || P || P || P || P || P || P || P || P || P || P || P ||   ||   
 Measures to increase knowledge for improved decision-making || P || P || P || P || P || P || P || P || P || P || P || P ||   ||   
 Certification schemes ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Zoning ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Specific action plans/programmes ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Land use planning ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Technical standards ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Specific projects related to agriculture || P || P || P || P || P || P || P || P || P || P || P || P ||   ||   
 Environmental permitting and licensing || P || P || P || P || P || P || P || P || P || P || P || P ||   ||   
Table 12.2.1: Types of WFD measures addressing agricultural
pressures, as described in the PoM
Source:
RBMPs

12.3    
Measures related to hydromorphology

Overall, as stated in previous sections,
the pressures regarding hydromorphology are described very generally and with
significant differences between RBDs. They mostly refer to the impacts of “big”
construction works (related to dams, hydropower, water supply-storage), but not
of “smaller” modifications like dams smaller than 15 meters, dredging, river
straightening, land reclamation, drainage, bank modifications, etc. In many cases it is assumed that
the existence of the dam does not hinder reaching the WFD-objectives (linked
also to the fact that the relevant water bodies are defined as HMWB/AWB - even
if GEP is not defined yet). The issue of potential impacts of small hydropower
dams is not discussed in detail; the information presented on those (either
existing or planned) is fragmentary and refers mostly to the Environmental
Impact Assessment (EIA) studies conducted for them, not linking to reaching the
WFD-objectives in related water bodies.
Very few measures have been included
regarding hydromorphology in the Greek RBMPs. No specific measures are included
e.g. regarding river restoration, remeandering, inundation of floodplains,
removal of structures, fish ladders, etc., bank reinforcement and
channelisation for flood protection. Very limited measures are reported
regarding habitat restoration (in specific “hot spots”, see e.g. GR11/12),
while some specific actions for the protection or rehabilitation of specific
lagoons, lakes and deltas are reported that should also include improvements of
hydromorphological characteristics.
Measures for sediment and debris
management are mentioned in most cases, relating to the management of gravel
extraction. There are some additional measures proposed that are linked to the
development of specific (investigative) studies in order to better understand
the impacts of modifications (e.g. impacts of dams on fish populations), as
well as for the development of criteria for defining limits of overall abstractions
for specific water bodies.
Regarding ecological flows and
environmental water allocation, no reference could be found to national
legislation or requirements regarding such flows (or national legislation or
guidance regarding other issues related to hydromorphology) as linked to the
WFD-objectives in the RBMPs/Annexes. For some specific (big) dams the
establishment or reconsideration and/or related studies regarding environmental
flows (e-flows) are proposed, but there is no overall plan for establishment of
national legislation regarding the e-flows issue linked to the WFD-objectives.
According to information provided by EL in late 2014, ecological
flows are established for small hydropower dams according to existing
legislation (MD 196978/2011); for all other cases the definition of ecological
flow is made on an ad hoc basis though the Environmental Impact Assessment and
permitting process. Furthermore, a medium-term basic measure has been included
in the PoMs of the RBMPs for the development of national guidance on e-flows,
which is under development; Greece however has not specified when the guidance
will be ready. 
There is no overview given in any of the
plans regarding the existing current e-flows regulation for all dams in place
(only fragmentary information found, especially in the context of dams
(potentially to be) considered under Art. 4.7).
The (limited) measures regarding
hydromorphology are defined for both natural water bodies and HMWBs/AWBs. These
are summarised in Table 12.3.1.
 Measures || GR01 || GR02 || GR03 || GR04 || GR05 || GR06* || GR07 || GR08 || GR09 || GR10 || GR11 || GR12 || GR13 || GR14 
 Fish ladders ||   ||   ||   ||||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Bypass channels ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Habitat restoration, building spawning and breeding areas ||   ||   ||   ||   ||   ||   ||   ||   ||   |||| P || P ||   ||   
 Sediment/debris management || P || P || P ||   ||   ||   ||   ||   ||   |||| P || P ||   ||   
 Removal of structures: weirs, barriers, bank reinforcement ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Reconnection of meander bends or side arms ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   || P ||   ||   ||   
 Lowering of river banks ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Restoration of bank structure ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   || P || P ||   ||   
 Setting minimum ecological flow requirements || P || P || P ||   ||   ||   ||   ||   ||   ||||   ||   ||   ||   
 Operational modifications for hydropeaking ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Inundation of flood plains ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Construction of retention basins ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Reduction or modification of dredging ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   || P ||   ||   
 Restoration of degraded bed structure ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Remeandering of formerly straightened water courses ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Other: Reduction/control/ban of sand/material extractions from river beds || P || P || P || P || P ||   || P ||||   ||||   ||   ||   ||   
 Other: research/study at the basin level on the impact of dams on fish populations and determining best methods to overcome impacts || P || P || P || P ||||   ||   ||   ||   ||||   || P ||   ||   
 Other: Determination of selected areas for abstracting materials for engineering needs ||   ||   ||   || P || P ||   ||   ||   || P || P || P || P ||   ||   
 Other: development of criteria for defining the limits of overall abstractions per WB ||   ||   ||   || P || P ||   ||   ||   || P || P || P || P ||   ||   
 Other: improving the water supply to one lake through reconnection to 2 springs ||   ||   ||   ||   || P ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Other: various (investigative) studies ||   ||   ||   || P || P ||   ||   || P || P || P ||   ||   ||   ||   
 Other: Investigation of potential artificial wetlands sites. ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   || P || P ||   ||   
 Other: Studies regarding sediment transport of the Strimonas river ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   || P ||   ||   ||   
 Other: Specific actions for the protection / rehabilitation of lagoons/lakes/deltas (including studies, but also "water balance rehabilitation") ||   ||   ||   ||   ||   ||   ||   ||   || P || P ||   || P ||   ||   
Table
12.3.1:
Types of WFD measures addressing hydromorphological pressures, as described in
the PoM
Source: RBMPs 
* No specific hydromorphological measures are going to be taken in GR06.

12.4    
Measures related to groundwater

Many measures related to groundwater
target specific pressures, such as over-exploitation, and many refer to the
sectors driving these pressures: abstraction for irrigation, for example, is
frequently cited. However, detailed links between risks, impacts, pressures and
measures are not provided.
Regarding quantitative status, basic
measures mentioned in most RBDs relate to:
§    A
better information basis: e.g. reshaping the monitoring network for groundwater
bodies in accordance with their final delineation and their qualitative and
quantitative status;  creating a single register of licensed water
abstractions; installation of systems for recording groundwater abstractions;
§    Better
regulation or licencing: e.g. review of the regulatory framework for water use
licensing and execution of water resources development projects; updating the
regulation regarding the minimum and maximum limits of the necessary quantities
of irrigation water; determination of criteria for setting limits for total
abstraction by water bodies; ban on new construction of water abstraction
projects from groundwater (boreholes, wells, etc.) in certain cases;
§    Incentives:
adjusting the water pricing policy in a flexible and efficient way in order to
serve the primary target of environmental sustainability and avoid water
wastage (see Article 9 section below; it is unclear if this holds also for
irrigation water);
§    Increasing
water use efficiency or water saving: e.g. establishment of an institutional
framework and a programme of measures for private user water conservation;
restructuring and rationalisation of the institutional operational framework of
collective management bodies of irrigation networks; and,
§    Investigation
of the conditions for implementing artificial recharge of groundwater bodies.
Regarding supplementary measures (which
are considered to be needed in all RBDs), there is a greater variety of
measures proposed in the different RBDs. Some commonly found are: installation
of functional valves in artesian wells; identification of groundwater areas or
restrictions for coastal groundwater that face saltwater intrusion; promoting
voluntary agreements with big water users and especially the agricultural
sector; awareness raising and information activities.
Beyond that, there are specific
supplementary measures regarding, in most cases, specific groundwater bodies,
e.g. regarding the introduction of artificial recharge, specific studies or
monitoring regarding water availability and water needs linked to a specific
groundwater body, etc., investigation of specific water transfers, construction
of appropriate drainage works, modernisation (e.g. to drip or “micro”
irrigation) and maintenance of irrigation networks; subsidies for irrigation
systems change; use of treated effluents for supporting water supply or artificial
recharge; total groundwater withdrawals not to exceed a certain amount for a
specific groundwater body; restrictions of new boreholes in specific
groundwater bodies; and, on-site inspections for licensed abstractions (big
water consumers) at least twice per year. 
Here, it is important to note that
various “construction works” (mainly new dams, but also improvements or
expansions of irrigation networks, sometimes leading to irrigation areas to be
expanded) are proposed in order to reduce quantitative pressure on groundwater
bodies (among other objectives) by shifting abstraction to surface water
bodies. At the same time, not all of the planned new dams are mentioned as
“WFD-measures” or no criteria could be found regarding which of these
construction works would become part of the WFD-PoM and which not. According to
information provided by the Greek authorities, construction projects shifting
abstraction from groundwater to surface water have been included in the PoM
where the quantitative status of groundwater is below good or exhibits downward
trends.
Regarding measures to prevent and limit
inputs of pollution to groundwater bodies, for GR5/6/7/8 basic measures are not
considered as sufficient for point and diffuse sources. For GR1/2/4, basic
measures are considered as sufficient for both sources, while for GR3
supplementary measures are seen as needed for point sources and for GR9/10 for
diffuse sources. For GR11, basic measures are not enough regarding point
sources, but supplementary measures are taken also for diffuse sources, with
the explanation given that supplementary measures are taken to maintain good
status and to deal with localised quality issues. For GR12, supplementary
measures are taken, even though only one groundwater body faces quality issues
due to saltwater intrusion, with the same explanation given as for GR11. In all
RBDs, measures regarding chemical pollution of groundwater bodies are provided
in the PoM (see section “measures related to chemical pollution” for details).
Specific measures oriented towards
groundwater bodies with exceedances were rarely found (the exceptions are
specific studies to further investigate the occurrence of a specific substance,
e.g. in GR01/2/3/5). 
In transboundary RBDs, co-ordination
with neighbouring countries regarding measures for groundwater management is
not mentioned. 

12.5    
Measures related to chemical pollution

There is no information regarding
an inventory of sources of chemical pollution; however, all RBDs mention the
“establishment of an inventory of pollution sources (emissions, discharges and
losses)” as one of the “other basic measures” (mid-term).
Overall, there is very limited
information regarding the existence of chemical pollution, due to significant
gaps in monitoring information. 
In general, it is considered that the
Greek legislation previous to the WFD implementation (regarding e.g.
authorisation and control of point source discharges) should cover most of the
issues related to chemical pollution. At the same time, a variety of actions or
measures on the issue are planned, mostly linked to legal changes, the
development of inventories and guidelines and voluntary activities.
Some of these main measures (regarding
“programmed actions”) include : legislative actions regarding permitting or licensing
as well as the use of sludge; continued and in many cases better monitoring
information,  databases and registers; completion
of required works for the collection and processing of urban wastewater or for
facilities falling under IPPC; rational use of plant protection products
(putting the legal requirements or measures into practice); delineation of new
nitrate vulnerable areas and developing action plans for them; incentives for
improving livestock facilities.
Regarding “other basic” measures, some
found in most RBDs are: better monitoring,  information or management systems
(e.g. for pollution accidents; aquaculture; setting up an inventory of sources
of pollution); measures for improving the regulatory framework or licensing
regarding protection of protected areas for drinking water, aquaculture, sludge
management, emission limits for priority substances and other pollutants,
industrial waste water and waste and truck transportation of wastewater;
protection of surface water abstraction installations for irrigation;
investigations regarding implementing artificial recharge of groundwater
bodies; development and use of specialised tools for the Rational Use of
Fertilisers and Water; and, strengthening the synergy of the water management
plans with the emergency plans of facilities included in the IPPC and SEVESO.
Regarding the main supplementary
measures found in many RBDs, these include: information or capacity building
events for agriculture; special protection measures for groundwater bodies in areas
where geothermal or thermal waters exist; additional monitoring for e.g. areas
of existing landfills, systems with high natural background levels (chlorides,
sulphates) and lagoons; investigation of possible sources of pollution
associated with pesticides; definition of restriction zones for new wells or
water uses extensions of licenses linked to coastal groundwater bodies facing
salinisation (and defining the groundwater body areas affected); upgrading WWTP
from secondary treatment; and, rational management of waste water from
agglomerations with a population peak < 2000 pe. Beyond that, there are also
specific supplementary measures in some RBDs regarding specific chemical
pollution “hot spots” (e.g. in GR06 regarding the Asopos river and related groundwater
bodies and chemical pollution from industry)
Measures to reduce or phase-out the
emissions of specific pollutants have not been identified in the PoMs, although
in some cases there is a specific investigative study planned regarding the
occurrence or exceedance of a certain pollutant (GR1/2/3/5).

12.6    
Measures related to Article 9 (water pricing
policies)

Overall, the work done on the economic
analysis differs significantly between RBDs (with common approaches each in
GR1/2/3, GR4/5/8, GR6/7, GR9/10 and GR11/12). According to the Greek
authorities, this is due to the extensive lack of data and the different RBDs
following the approach deemed most suitable for the data available to them.
There seems to be no clear national guidance on the issue.
For all RBDs, the economic analysis
shows gaps regarding the actual information used or available (e.g. division of
costs for public water supply and sewage is not possible; lack of information
regarding assets, (operational) costs and revenues for many water supply
companies/municipalities; there is a lack of metering in agriculture, etc.) and
questionable methodologies and assumptions are used (e.g. regarding the way
financial costs are calculated (using “average values” for many important
elements of the calculation), the way (cross-) subsidies are (not) considered
(especially regarding irrigation), for the calculation of environmental costs
(e.g. taking as a basis the “status” of water bodies while many of them are in
“unknown status”, linking the existence of environmental costs to the existence
of a waste water treatment plant which does not cover non internalised
environmental and resource costs, including costs the costs related to water
abstraction, assuming in many cases that irrigation does not entail environmental
costs, etc.).
There is no consideration or discussion
of the polluter pays principle, the contribution of water users to the costs of
water services and the implementation of incentive pricing.
There is no clear definition of water
services. In general, water supply and wastewater treatment services are
treated together as one service, while also “irrigation water services, mainly
from organised irrigation” seem to be considered as a water service (GR01/2/3
explicitly also mention “self-service” for irrigation as a water service). In
other cases (e.g. GR04/5/8), additional water services are identified (e.g.
recycled water provision). There is no clear approach to the identification of
relevant water uses in the Article 9 context across the RBDs.
The methodology for calculation of cost
recovery rates shows differences depending on the RBD, but overall it is based
on fragmentary data and various assumptions and extrapolations regarding both
the methodology and data. 
The information provided on existing
cost recovery (CR) levels varies: cost recovery rates (financial, but
additionally including environmental and resource costs (ERC) are calculated
for agricultural water supply and urban water supply and sewage treatment (as
one). In some cases (e.g. GR06/7), more disaggregated CR numbers are given for
the financial costs of “households/state users” and “industry”. In other cases
(e.g. GR01/2/3), disaggregated numbers are given for public water supply and
sewage companies and municipalities providing these services directly.
Self-abstractions are included in the ERC calculations of GR06/07. 
Significant gaps are apparent regarding
the identification and consideration of subsidies for organised irrigation
(especially investments).
Environmental and resource costs have
been calculated and included in the cost recovery calculations in all RBDs,
however they are based on many assumptions and simplifications, which are not
adequately justified. 
No information was found on the
application of flexibility provisions or provisions of Article 9(4) of the WFD,
or on international cooperation regarding the implementation of Article 9.
One “other basic” measure of all the
PoMs is “adjusting the water pricing policy in a flexible and efficient way in order
to serve the primary target of environmental sustainability and avoiding water
wastage” (but not referring to pricing regarding pollution or sewage-related
services). It remains unclear if this revision of the water pricing policy will
also cover agricultural water pricing (when describing the measure GR11/12 also
refer explicitly to irrigation water; the other RBMPs do not). Some general
principles that this revision will be based on are given, but without
indicating the specific content so far (the measure is indicated as “short
term”, thus to be implemented by 2015). In this context, there is no discussion
or specific measures for dealing with non-metered water consumption in
agriculture.

12.7    
Additional measures in protected areas

Overall, no specific additional measures
in protected areas are part of the WFD-PoMs, since no specific, additional
objectives going beyond the WFD-objectives are included in the RBMPs (beyond
what is required for the implementation of “other” Directives, Natura 2000,
etc.).
The measures to comply with the
objectives of other Directives (all of them indicated as “already implemented”)
are mentioned in the PoMs as measures taken for the implementation of these
Directives. Some of the “other basic” measures mentioned in the PoMs also refer
to the Directives related to protected areas.
Regarding the drinking water collection
areas, the RBMPs refer to the establishment of safeguard zones for these; one
of the measures described in the PoMs is related to finalising the
establishment of safeguard zones based on hydrological studies. While safeguard zones have not
been finally or specifically established yet, some “other basic measures” have
been mentioned that are linked to safeguarding drinking water quality. These
include: the implementation of Water Safety Plans in large water supply
companies; establishing  or updating General Water Supply Plans Water Supply
(Masterplan) from the public water and sewage companies; the detailed
delineation of protection zones of groundwater abstraction points (springs, boreholes)
for water supply abstractions greater than 1 million cubic metres per year; the
definition of protected areas for abstractions for drinking water; the
protection of groundwater bodies included in the register of protected areas
for drinking water; and, setting an institutional protection framework.
In some cases, specific measures are
related to the protection of the water abstractions from specific dams or
reservoirs (e.g. in GR06/7/12). 

13.        
 Climate change adaptation, water scarcity and droughts,
flood risk management and other emerging and linked issues as part of the rbmp
13.1    
Water Scarcity and Droughts

Water scarcity and droughts are
identified as significant issues in most RBDs; for all, there are specific
areas or times of the year where these phenomena are of importance.
For all RBDs, a drought management plan
has been established (for GR01/2/3, it is a combined one); in most cases the
specific sub-units or specific river basins are looked at separately. Quantity
issues are discussed in the RBMP and some measures related to quantity
management have been identified in the PoMs, but the links between the two
plans are weak. For the characterisation of Drought & Water Scarcity
conditions the Standard Precipitations Index (SPI) and the Water Exploitation
Index (WEI) have been used (in some RBDs differentiated between surface and
groundwater – e.g. GR06/07). 
The information used in the Drought
Management Plans (DMPs) is based on historical data for water availability,
without consideration of e.g. the impacts of Climate Change on this
availability in all RBDs. For water demands, theoretical data is used since
actual information on water abstractions is fragmentary or missing. The water
balances at the catchment scale are based on modelling carried out in the
framework of a previous national project, and thus they have not been updated.
The actual calculation methods, time horizons, etc. differ between RBDs.
The “proposals” for measures identified
in the DMPs are in most cases early warning and emergency response measures
(sometimes called “reactive” measures) to a drought situation, while some RBDs
also list preventive (pro-active) measures.  In GR06/07 a methodology for early
warning based on precipitation is developed, and alert levels have been established
on the basis of the observed 3-month and 6-month precipitation (SPI3 and SPI6
respectively) during the month of March. A list of measures for each alert
level are also provided, mainly focusing on demand management and awareness
measures.  In GR01/2/3/4/5/9/10 the link is built to the PoM according to the
WFD by identifying the PoM-measures proposed that support the prevention and
mitigation of water scarcity and droughts (not done in GR06/7/11/12). Most of
the PoM-measures linked to combatting water scarcity and droughts are
construction works in order to increase available water to cover demands (e.g.
new dams), but there are few demand-side measures (reduction of water losses,
changes in the way agriculture is using water). 
It remains unclear what the next
activities are to put the DMPs into practice, since the measures described in
the DMPs are “proposals”, thus not fully decided (evident in the “next steps”
section - in the cases where it exists - of the DMPs). Thus, further work is
required to develop the DMPs into operational plans.
No international coordination has taken
place so far on the DMPs, while in GR11/12 some future activities regarding
early drought warning data exchange with neighbouring countries have been
proposed. 

13.2    
Flood Risk Management

The RBMPs by and large make very few
references to floods and flood risk management or the Floods Directive (FD);
there is no reference to the coordination needed for the implementation of the
WFD and the FD.
There is no clear, practical reference
or link in the RBMPs to the development of the Flood Risk Management Plans
currently underway. According to information provided by the Greek authorities
in late 2014, all data developed and used for the first cycle implementation of
the WFD was available and used for preliminary flood risk assessment (PFRA) and
for Flood Mapping elaboration. Also, more detailed information derived from the
PFRA and from the FD-flood mapping on water bodies' hydromorphological
alterations and on environmental pressures due to flooding will be used in the
second cycle of the WFD (for a better analysis of hydromorphological pressures
and for the elaboration of PoMs). The information and programme of measures
contained in each future management plan (WFD or FD), will consider all the
information and measures produced in previous cycles. 
Most RBMPs mention floods as a side
issue, such that some measures are also being targeted to provide security
against floods (mainly related to dam infrastructure and related to HMWB/AWB
designation and the Art. 4.7 – new modifications issue). At the same time,
there is no specific discussion or chapter building the links of the PoM to
floods management. Overall, no natural water retention measures were found that
can serve towards reducing flood risk.

13.3    
Adaptation to Climate Change

Climate change has not been taken into
consideration in any of the RBMPs, PoMs or DMPs, (no specific chapter or
discussion), e.g. regarding expected changes in water availability. No plans or
related measures to do so in the future can be found.
The only exceptions to this are
GR04/5/8, in the DMP of which a two-page chapter is dedicated to the issue of
climate change. It summarises two studies that are annexed to the DMPs, dealing
with (for GR04, 05 and 08 combined) the “Effects of climate change on rainfall,
temperature and evaporation”, which develops different relevant scenarios, and
another on the “Effects of climate change on agriculture and irrigation”, which
describes changes in irrigation needs and proposes some measures for increasing
irrigation water productivity in order to reduce irrigation water needs and to
conserve water. These two studies use different assumptions and thus reach
different results on the climate change effects and are not taken into further
consideration in the relevant DMP/RBMP/PoM. Similar studies cannot be found for
the other RBDs.
A climate check of the Programmes of
Measures was not performed. The PoMs do not include specific adaptation
measures.
A
national strategy for climate change adaptation was not in place when the RBMPs
were in preparation; however, preparatory steps have recently been taken to
establish one (commissioning a study on the development of a National Climate
Change Adaptation Strategy is underway as of September 2014). 

14.        
RECOMMENDATIONS 

Greece should:
§  
Urgently adopt and report to the Commission the two outstanding Greek RBMPs.
§   Improve
transboundary cooperation, building on the progress achieved so far; additional
efforts in the context of WFD-implementation are needed, so that the second
RBMPs for international RBDs are developed in close cooperation with
neighbouring countries.
§   Make
fully operational the new National Monitoring Programme (NMP). All outstanding
assessment methods should be developed and made operational as soon as
possible. All water bodies should be classified according to WFD compliant
methods. The one-out all-out principle should be used across the board. Data
must be collected on a regular basis for all relevant quality elements. The
recommendations of the RBMPs regarding the proposed modifications to the NMP
need to be carefully considered and actions for their implementation pursued.
The data of the new NMP must be quality assured, organised and archived. It is
recommended that these data are made available to all users and the general
public through easily accessible formats.
§  
Develop publicly available WFD compliant
National Guidance Documents, addressing the key implementation steps where
significant weaknesses have been identified (characterisation of pressures, typology, reference conditions,
monitoring and grouping of water bodies, methods for the status classification, HMWB designation,
application of exemptions and in particular regarding Article 4.7, etc.),
necessary to ensure WFD compliance and increased comparability and
transparency.
§   The
information obtained regarding chemical pollution needs to be extended by
filling gaps in monitoring, including the monitoring of mercury and other
relevant pollutants in biota, and trend monitoring in biota and/or sediment. 
§   Ensure
in the updated RBMPs a better understanding and identification of the main
risks and pressures in each river basin, based on detailed harmonised
methodologies, and underpinned by consolidated and robust data. 
§   Particularly
urgent is the development of sound methodologies to address hydromorphological
pressures. The current combination of weak pressure analysis (with not
precautionary enough thresholds of significance), lack of ecological status
assessment methods sensitive to hydromorphological pressures, unclear process
for designation of HMWB and lack of development of GEP makes it very likely
that significant hydromorphological pressures are completely overlooked in the
implementation process. Potential effects of “smaller” modifications such as
dams lower than 15 m, dredging, river straightening, drainage, etc., including
impacts to transitional and coastal waters, should be assessed.
§   Agriculture
is indicated as exerting a significant pressure on the water resource in most
Greek RBDs. There needs to be further investigation regarding the
hydromorphological pressures from agriculture. In addition, the measures taken
as regards agriculture need to be more specific, in order to have more reliable
positive results regarding the WFD-objectives. 
§   Regarding
GW quantity issues, very limited information about actual abstractions has been
used. The latter are based on estimates. Even if the revised NMP will provide
better information the issue of illegal abstractions/boreholes, their potential
effects and ways to deal with them needs to be considered most thoroughly.
§   Regarding
exemptions: overall and even if a large number of water bodies are in “unknown”
status, there is a limited number of exemptions, linked to the fact that only a
limited number of water bodies “fail” the objectives of the WFD. This needs to
be significantly re-considered after monitoring information becomes available -
and consequently, most probably, more measures will need to be taken.
§   The
application of exemptions needs to be more transparent and the reasons for the
exemptions should be clearly justified in the plans. This especially holds true
for a coherent and complete approach regarding Article 4.7 exemptions. The use
of exemptions under Article 4.7 should be based on a thorough assessment of all
the steps as requested by the WFD, in particular a proper assessment of whether
the project will cause deterioration or prevent the achievement of good status,
whether the project is of overriding public interest, whether the benefits to
society outweigh the environmental degradation, and regarding the absence of
alternatives that would be a better environmental option. Furthermore, these
projects may only be carried out when all possible measures are taken to
mitigate the adverse impact on the status of the water.
§   No
clear link between measures and status assessment is made. In order to address
this, the gaps in the steps leading to the Programme of Measures, such as
pressure and impact assessment, monitoring and status classification, should be
addressed. This is important in order to implement measures where they are
needed to reach the WFD objectives.
§   In
relation to chemical pressures, the intention to compile inventories of
emissions in accordance with Directive 2008/105/EC needs to be carried out, but
does not in itself count as a measure against chemical pollution. More
information on relevant measures needs to be included in the 2nd
RBMPs.
§   In
relation to hydromorphological pressures, and based on a sound assessment,
measures should be taken to mitigate the impacts (e.g. river restoration,
removal of structures, etc.).  
§   Meaningful
information regarding the scope, the timing and the funding of the measures
should be included in the PoM so the approach to achieve the objectives is
clear and the ambition in the PoM is transparent. 
§   PoM
in RBMPs: the limited level of ambition, and lack of clarity regarding expected
effects, need to be rectified. The PoM includes mostly administrative acts that
may not make a difference (particularly if implementation is not enforced).
Many projects that are in apparent conflict with the WFD (e.g. new dams not
properly justified, new irrigation network projects) are included in the PoM
(e.g. for improving GW quantitative status since the irrigation water will come
from a new reservoir in the future). A thorough check of such projects that are
included in the PoM is needed in order to check if they really are WFD-relevant
measures (linked also to the Article 4.7 issue above). This inclusion of new dams/irrigation
schemes, etc. in most of the PoM also affects the costs indicated: a part of
the costs of the PoM-supplementary measures (as defined up to 2015) come for
such projects (often financed through the EU). Otherwise, there is very limited
financing included for “core” WFD-measures to achieve the environmental
objectives (e.g. restoration/mitigation, etc.) without clear commitments for
after 2015. There needs to be a clear separation of measures designed to
achieve WFD environmental objectives from measures designed to increase water
supply and other objectives.
§   Develop
fully the economic analysis of water use (including the polluter pays
principle, including a clear definition of water services, harmonising
methodologies and data in all RBMPs) and ensure that the water tariffs/fees
lead to adequate recovery of the costs of water services and provide incentives
for users to use water resources efficiently. This is particularly important
for agriculture. The implementation of measures on cost recovery and water
pricing based on a common approach across RBDs is urgent, in order to fulfil
the Article 9 requirements and to achieve economic sustainability.
§   Up to
now, there is no consideration of climate change - no “climate proofing” of the
RBMP/PoMs. These issues need to be dealt with urgently.
§   The
Drought Management Plans (DMP) developed as supplementary to the RBMPs are a
valuable addition. However, they need to be taken a step further, be more
harmonised, and evolve into an operational level with the “measures proposals”
being implemented in areas where relevant.
§   Ensure
that the authorities responsible for water management are fully in charge of
the contents and development of the RBMPs. Support from consultants and
researchers is often necessary, but the authorities' ownership of the RBMP
should be ensured to embed the WFD principles and obligations into practice and
avoid the disconnection of the planning process from the water management
reality. Long-term capacity and expertise building should be ensured in the
water administration, based on sufficient resources and personnel available at
all relevant administrative levels.
§   The
consultation process needs to be strengthened. More efforts should be done to
ensure active participation of all relevant stakeholders and the comments
should be taken under consideration in a more transparent way.
[1] Eurostat
data for 2014.
[2] Greece country fiche (http://europa.eu/about-eu/countries/member-countries/greece/index_en.htm)

[3]     This report reflects the corrections submitted by EL in late
2014. There are some discrepancies between the information reported in the
RBMPs and the information provided by EL/submitted to WISE.
[4]     Categorisation determined under the EC Comparative study of
pressures and measures in the major river basin management plans in the EU
(Task 1b: International co-ordination mechanisms).
[5] According to Greece, the Albanian authorities have been invited
during the RBMP consultation process.
[6]     This information corresponds to the reporting of protected
areas under the WFD. More/other information may have been reported under the
obligations of other Directives.
[7] This table refers to the New National Monitoring Programme, which
was established with the Common Ministerial Decree ΚΥΑ
140384/9-9-2011, but was not used during the 1st cycle of the RBMPs.

[8]     Number of sites calculated from data reported at site level. If
no data reported at site level, then table supplemented with data reported at
programme level. The reported information refers to the new National Monitoring
Programme
[9] Exemptions are combined for ecological and chemical status. Source:
WISE, corrections provided by EL in late 2014
[10]
According to information from the Greek authorities provided in late 2014, the
PoM-Implementation Progress Report- submitted by EL as a reply to an EU enquiry
in December 2014 contains more information on costs of individual measures. The
PoM-Implementation Progress Report (national level) was provided via WISE on
22.1.15 and has not been assessed to date.