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: 2018-07-17
Institutions: Directorate-General for Environment, 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

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 17.7.2018  SWD(2015) 54 final/2  CORRIGENDUM This document corrects document SWD(2015) 54 final of 09.03.2015. [Document updated with River Basin Districts GR13 and GR14 in Greece].  The text should read as follows: COMMISSION STAFF WORKING DOCUMENT Report on the implementation of the Water Framework Directive River Basin Management Plans Member State: GREECE Accompanying the document COMMUNICATION FROM THE EUROPEAN COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL The Water Framework Directive and the Floods Directive: Actions towards the 'good status' of EU water and to reduce flood risks {COM(2015) 120 final}  - {SWD(2015) 50 final}  - {SWD(2015) 51 final}  - {SWD(2015) 52 final}  - {SWD(2015) 53 final}  - {SWD(2015) 55 final}  - {SWD(2015) 56 final}  
 
 
TABLE OF CONTENTS 

1.  GENERAL INFORMATION ........................................................................................................................ 4 

2. 

STATUS OF RIVER BASIN MANAGEMENT PLAN REPORTING AND COMPLIANCE ....................................... 7 

3.  GOVERNANCE ........................................................................................................................................9 

3.1 

3.2 

3.3 

3.4 

3.5 

3.6 

TIMELINE OF IMPLEMENTATION ....................................................................................................................... 9 

ADMINISTRATIVE ARRANGEMENTS - RIVER BASIN DISTRICTS AND COMPETENT AUTHORITIES ......................................... 9 

RBMPS - STRUCTURE, COMPLETENESS, LEGAL STATUS ...................................................................................... 10 

CONSULTATION OF THE PUBLIC, ENGAGEMENT OF INTERESTED PARTIES ................................................................. 11 

COOPERATION AND COORDINATION WITH THIRD COUNTRIES ............................................................................... 11 

INTEGRATION WITH OTHER SECTORS ............................................................................................................... 13 

4.  CHARACTERISATION OF RIVER BASIN DISTRICTS .................................................................................. 14 

4.1  WATER CATEGORIES IN THE RBD................................................................................................................... 14 

4.2 

4.3 

4.4 

4.5 

TYPOLOGY OF SURFACE WATERS .................................................................................................................... 14 

DELINEATION OF SURFACE WATER BODIES ....................................................................................................... 15 

IDENTIFICATION OF SIGNIFICANT PRESSURES AND IMPACTS .................................................................................. 16 

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 

7.2 

ECOLOGICAL STATUS ASSESSMENT METHODS ................................................................................................... 49 

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 

2 

 
 
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 

3 

 
 
 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 million1 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. 

1 Eurostat data for 2014. 
2 Greece country fiche (http://europa.eu/about-eu/countries/member-countries/greece/index_en.htm)  

4 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                            
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  
GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 
GR13 
GR14 

Name 
Western Peloponnese 
Northern Peloponnese 
Eastern Peloponnese 
Western Sterea Ellada 
Epirus 
Attica 
Eastern Sterea Ellada 
Thessalia 
Western Macedonia 
Central Macedonia 
Eastern Macedonia 
Thrace 
Crete 
Aegean Islands 

Size* (km2)  Countries sharing borders 

7,235 
7,418 
8,442 
10,432 
10,007 
3,139 
12,268 
13,153 
15,218 
14,264 
7,320 
11,242 
8,301 
9,118 

- 
- 
- 
- 
AL 
- 
- 
- 
AL, FYROM 
BG, FYROM 
BG, FYROM 
BG, TR 
- 
- 

Table 1.1: Overview of Greece’s River Basin Districts 
* Area in Greek territory 
Source: River Basin Management Plans reported to WISE3: http://cdr.eionet.europa.eu/be/eu/wfdart13 

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. 

5 

 
 
 
 
 
 
 
                                                            
Name international 
river basin 

National 
RBD 

Countries 
sharing 
borders 

Lake  Prespa  (Part  of 
Drin/Drim Sub-basin) 
Aoos/Vjosa 
Mesta-Nestos 
Struma-Strymonas 
Maritsa-Evros_Meric 
Axios/Vardar 
Axios/Vardar 

GR09 

AL, MK 

GR05 
GR12 
GR11 
GR12 
GR09 
GR10 

AL 
BG 
BG, FYROM 
BG, TR 
FYROM, BG 
FYROM, BG 

Co-ordination category 

3 
km²  % 

4 

km² 

% 

2 

% 

25.1 

33.0 
42.3% 
36.5% 
6.3% 

km² 

347 

2,154 
2,429 
6,295 
3,345 

863 
1,636 

3.9 
7.3 

Table 1.2: Transboundary river basins by category (see CSWD section 8.1) and % share in Greece4. 
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) 

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). 

6 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                            
STATUS OF RIVER BASIN MANAGEMENT PLAN REPORTING AND COMPLIANCE  

By late 2014 , Greece had adopted 12 RBMPs  (GR01, 02, 03, 04, 05, 06, 07, 08, 09, 10, 11, 
12),  which  have  also  been  fully  reported  in  WISE  (along  with  the  accompanying  Annexes) 
(see Table 2.1 below). In late 2014, in the context of a bilateral meeting between Commission 
Services and Greek authorities, some additions and corrections to specific tables of this report 
were  provided,  which  have  been  incorporated.  In  2015,  2  additional  RBMPs  have  been 
adopted  (GR13 and 14) which have been reported in WISE in March 2016 (yet without the 
full accompanying Annexes as it was done for the other 12 RBMPs). 

The  drafting  of  the  12  RBMPs  (GR01,  02,  03,  04,  05,  06,  07,  08,  09,  10,11,  12)  was 
commissioned  to  different  consultants  and  coordinated  by  the  Ministry  of  Environment, 
Energy and Climate Change – Special Secretariat for Water (EGY) assisted by a “coordinator 
consultant”. In contrary the drafting of the RBMPs for GR13 and GR14 has been undertaken 
by  the  EGY  in  close  collaboration  with  the  Water  Directorates  of  the  Decentralised 
Administration  (of  Crete  and  North  &  South  Aegean  respectively).  A  general  national 
approach has been followed, yet it is evident that the RBMPs’ implemented approaches and 
structures  present  commonalities  within  the  plans  assigned  to  the  same  consultant,  and 
differences  across  the  background  documents  (Annexes)  of  the  plans  assigned  to  different 
consultants.  Thus,  the  following  groups  can  be  observed:  GR01/02/03,  GR04/05/08, 
GR06/07,  GR09/10,  GR11/12,  GR13/14  The  role  of  the  “coordinator  consultant”  was  to 
support  the  EGY  and  provide  expertise  and  guidelines  (also  in  the  form  of  guidance 
documents,  which  were  nevertheless  not  officially  published)  for  the  streamlining  and 
harmonisation of the process.  

One of the main shortcomings of the Greek RBMPs is that they have been delayed due to a 
number  of  factors  which  relate  to  technical  issues,  as  well  as  legislative  and  administrative 
barriers  and  socio-economic  constraints.  Consequently,  time  to  implement  the  suggested 
Programme  of  Measures  (PoMs)  by  2015  and  revise  the  plans  for  the  second  WFD  cycle 
(considering  and  embedding  the  effects  of  the  measures)  is  very  tight  (even  impossible  for 
GR13/14 which were adopted in 2015). Nevertheless EL has specified that implementation of 
a  great  number  of  measures  included  in  the  PoMs  had  started  before  the  approval  of  the 
RBMPs  (detailed  information  on  this  aspect  is  reported  by  EL  to  be  available  in  the  PoM-
Implementation Progress Report – national level, due in December 2012 but submitted to the 
COM  in  late  2014,  and  uploaded  on  WISE  on  22.01.2015;  the  contents  of  that  Progress 
Report has not been assessed yet and therefore is not taken into account in this report).  

Another  significant  problem  with  the  RBMPs  was  the  lack  of  WFD-compliant  data.  The 
information used for the various assessments was based on the old monitoring network which 
was  obsolete  (with  regard  to  the  WFD  required  data)  and  the  time-series  fragmented  and 
incomplete. Thus, the embedded uncertainty in the characterisation is judged significant, and 
in  some  cases  it  is  not  transparent  how  water  bodies  have  been  classified  as  “good”  status 
(given  the  lack  of  complete  information),  as  opposed  to  “unknown”  status,  since  the 
characterisation is based on limited data and assumptions.  

The new National  Monitoring Programme (NMP), according to  the WFD requirements,  has 
been  established  late  in  the  process  (in  2012)  and  it  is  mentioned  that  it  will  furnish  the 
necessary data for the revision and update of the RBMPs in the second cycle. Yet, the RBMPs 
have proposed some modifications with regard to the sites and parameters of the NMP based 
on their current findings, which essentially resulted from the new typology using system B (as 

7 

 
 
opposed to the original typology using system A back in 2011 when the NMP was designed, 
see  section  5.1  below).  These  suggestions  have  not  been  taken  up  yet  by  the  Special 
Secretariat  for  Water,  and  would  in  some  cases  require  additional  financial  resources  (i.e. 
when supplementary sites are proposed). It is stated by EL that the NMP will be updated for 
the  planning  period  2016-2021,  taking  into  account  all  available  data  and  information  from 
the RBMPs and of course the proposed modifications in each RBD. After the adoption of the 
RBMPs  for  all  of  the  country’s  RBDs  and  a  cost-effectiveness  analysis  in  relation  to  the 
financial  resources  already  allocated  for  the  planning  period  2016-2021,  the  Special 
Secretariat  for  Water  will  propose  a  new  updated  National  Monitoring  Network  to  be 
consulted  on  with  all  involved  national  and  regional  authorities,  within  2015.  The  new 
updated  National  Monitoring  Network  will  be  defined  in  an  amendment  of  the  JMD 
140384/9-9-2011. 

With  regard  to  harmonisation  and  common  approaches  across  the  RBMPs,  a  national 
coordination  programme  was  in  place,  yet  it  is  not  clearly  reflected  that  all  RBMPs 
implemented exactly the same approaches (e.g. on issues with small water bodies, definition 
of  “significance”  of  pressures,  assessment  of  groundwater  quantitative  status)  when  reading 
the WISE summary reporting and the Annexes. The Annexes themselves are very different in 
structure  and  content  (for  the  same  topics)  which  confuses  the  reader.  A  common  structure 
and  content  across  the  RBMPs’  Annexes  would  have  increased  transparency  and 
understanding, while all the Annexes for GR13/14 have not been reported in WISE. 

Finally, a common approach to ensure adequate incentives for efficient use and an adequate 
contribution  from  different  users  was  not  in  place  (Art.  9).  Moreover,  economic  analysis 
varied  across  the  RBMPs,  partly  due  to  missing  information.  It  is  planned  that  the 
methodologies for the economic analysis will be increasingly harmonised in the second and 
future cycles of review of the RBMPs. 

An  important  strength  for  the  Greek  RBMPs  is  that  all  underwent  strategic  environmental 
assessment  (SEA).  Another  added  value  is  the  parallel  development  of  a  Drought  &  Water 
Scarcity  Management  Plan  (DMP)  for  each  RBD  (except  for  GR13/14).  In  most  cases  the 
specific  sub-units  or  specific  river  basins  are  looked  at  separately.  Quantity  issues  are 
discussed in the RBMPs and some  measures related to  quantity  management  (incl. efficient 
use of water resources) have been identified in the PoMs. The links between the RBMPs and 
the  DMPs  should  be  further  strengthened  and  the  DMPs  should  be  further  developed  into 
fully  operational  plans  complementing  the  RBMPs.  DMPs  for  GR13/14  are  planned  to  be 
developed, in fact these are mentioned in the PoMs as a basic measure. 

8 

 
 
 
RBD 

RBMP Date of Adoption 

GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 
GR13 
GR14 

08/04/2013 
08/04/2013 
08/04/2013 
18/09/2014 
04/09/2013 
08/04/2013 
08/04/2013 
18/09/2014 
30/01/2014 
30/01/2014   
04/09/2013 
04/09/2013 
27/02/2015 
17/09/2015 

RBMP Date of 
Reporting* 
13/09/2013 
13/09/2013 
13/09/2013 
05/12/2014 
28/01/2014 
05/09/2013 
05/09/2013 
05/12/2014 
25/09/2014 
25/09/2014 
19/03/2014 
12/02/2014 
16 /03/2016 
11/03/2016 

Table 2.1: Adoption and reporting to the Commission of Greece’s RBMPs. 
Source: RBMPs and CDR. *Latest date of WISE reporting including all annexes and background documents. 

9 

 
 
 
 
 GOVERNANCE 

Timeline of implementation 

The  dates  of  publication  of  RBMP  preparatory  documents  are  provided  in  Table  3.1.1  below; 
these are behind the due dates set in Art. 14 of the WFD. 

RBD 

Timetable 

Work 
programme 

Statement 
on 
consultation 

Significant 
water 
management 
issues 

Draft RBMP 

Final RBMP 

Due 
dates 
GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 
GR135 
GR146 

22/06/2006 

22/06/2006 

22/06/2006 

22/12/2007 

22/12/2008 

22/12/2009 

05/04/2013 
05/04/2013 
05/04/2013 
01/11/2011 
01/11/2011 
30/08/2010 
30/08/2010 
01/11/2011 
15/06/2011 
15/06/2011 
30/08/2010 
30/08/2010 

05/04/2013 
05/04/2013 
05/04/2013 
01/02/2012 
01/02/2012 
13/04/2011 
13/04/2011 
01/02/2012 
27/04/2012 
27/04/2012 
09/08/2010 
09/08/2010 
1126/04/2013  1126/04/2013 
30/05/2014 

30/05/2014 

05/04/2013 
05/04/2013 
05/04/2013 
05/04/2013 
05/04/2013 
03/05/2012 
03/05/2012 
05/04/2013 
30/07/2012 
30/07/2012 
15/10/2011 
15/10/2011 
11/07/2013 
-30/05/2014 

05/04/2013 
05/04/2013 
05/04/2013 
04/09/2013 
04/09/2013 
13/01/2012 
13/01/2012 
04/09/2013 
30/07/2012 
30/07/2012 
18/11/2011 
18/11/2011 
2711/07/2013 

05/04/2013 
05/04/2013 
05/04/2013 
30/10/2013 
04/09/2013 
03/05/2012 
03/05/2012 
30/10/2013 
01/02/2013 
01/02/2013 
07/05/2012 
07/05/2012 
-04/032014 

08/04/2013 
08/04/2013 
08/04/2013 
18/09/2014 
04/09/2013 
08/04/2013 
08/04/2013 
18/09/2014 
30/01/2014 
30/01/2014 
04/09/2013 
04/09/2013 
2731/03/2015 

1730/05/2014 

3007/10/2014 

17/09/2015 

Table 3.1.1: Timeline of the different steps of the implementation process 
Source:  WISE 
http://ec.europa.eu/environment/water/participation/map_mc/countries/greece_en.htm 
column). 

(for  all  columns  except  “Final  RBMP”)  and  DG  Environment  web  page: 
“Final  RBMP” 

(for 

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 

5 Dates as provided by Greece (March 2017). 
6 Dates as provided by Greece (March 2017). 

10 

 
 
                                                            
responsible  for  implementing  the  plans.  The  RBMPs  specifically  state  that  “the  RBMPs  of 
Greece  are  developed  under  the  responsibility  of  the  competent  authorities  for  each  RBD. 
Based  on  a  request  by  their  Secretaries,  the  Special  Secretariat  for  Water  took  over  the 
development of the RBMPs, which then were commissioned to consultants”. Other authorities 
including regional, municipal, and local authorities from other sectors have contributed under 
topics  of  their  expertise  and  interest.  Nevertheless,  this  has  not  been  the  case  for  GR13/14: 
they were not commissioned to consultants, but they were in fact drafted by the EGY with the 
direct contributions of the Regional Water Directorates of Crete, and North and South Aegean 
respectively. 

Finally,  in  the  relevant  Annexes  on  those  “responsible  for  specific  aspects  of  water 
management”,  long  lists  of  additional  authorities  are  presented  showing  how  complex  the 
overall setup is. With regard to the main next steps and difficulties, the RBMPs mention that 
many of the “responsible authorities” at the regional level are not sufficiently staffed, so they 
are in danger of not fully covering their responsibilities. Additionally, the fact that the RBMPs 
were  commissioned  to  consultants  may  have  limited  the  Regional  Water  Directorates’ 
opportunities  to  gain  further insight  into  WFD  issues  and  experience  (except  for  GR13/14). 
Capacity building has nevertheless been undertaken through seminars organised by the EGY. 

As mentioned above, the drafting of the RBMPs was commissioned to different consultants 
and  coordinated  by  the  EGY  (except  for  GR13/14).  A  general  national  approach  has  been 
followed.  There  are  some  differences  in  terms  of  the  methodologies  and  available  data  that 
were  used  among  the  different  groups  of  the  consultants  e.g.  the  GR01/02/03  plans  were 
compiled  by  one  team,  the  GR04/05/08  plans  by  another,  GR06/07  plans  by  a  third  team, 
GR09/10  plans  by  a  fourth,  GR11/12  plans  by  a  fifth,  while  GR13/14  by  the  EGY  and  the 
Regional Water Directorates (also assisted by the local universities of Crete and Aegean), as 
well as by other involved regional and local authorities).. However, as the Special Secretariat 
for Water coordinated all the teams there are several common specifications. There were no 
main  changes  announced  or  implemented  after  the  submission  of  the  RBMPs  (corrections 
dealt with clarifications or typos). 

RBMPs - Structure, completeness, legal status 

In  general  the  structure  of  the  RBMPs  follows  the  specifications  of  the  WFD.  In  terms  of 
clarity  there  are  certain  issues  regarding  the  implementation  of  the  methodology  that  is 
described in the relevant chapters of the RBMPs. In some cases it is not very clear whether 
and how a specific methodology, e.g. for assessing the water bodies, is applied. The different 
RBMPs have the same structure and content, but are accompanied by numerous Annexes, and 
harmonisation of structure and content is missing across them, thus confusing the assessment. 
In  terms  of  completeness,  it  is  explicitly  mentioned  on  several  occasions  that  there  was 
insufficiency  of  available  data  and  supporting  studies/surveys  for  the  assessment  of  water 
bodies. It is mentioned that in cases where no data were available, the assessment was done 
through  expert  judgment  and/or  through  grouping  of  water  bodies  with  similar  types  and 
levels  of  pressures,  and  thus  the  level  of  uncertainty  was  characterised  as  large.  An 
improvement  of  the  data  quality  and  the  water  bodies’  assessment  can  only  be  addressed 
through  the  implementation  of  the  National  Monitoring  Program  that  was  defined  with  the 
Common  Ministerial  Decree  140384/9-9-2011.  It  was  originally  foreseen  that  the  new 
network programme would provide the first monitoring results at the end of 2013. This new 
data  would  be  used  to  improve  the  knowledge  of  the  water  bodies’  status  and  thus  the 
completeness  of  the  RBMPs  in  the  next  cycle.    No  links  to  any  international  plans  are 
referenced within the RBMPs. 

11 

 
 
8  of  them  have  been  approved  and embedded  into  the  National  Law  by  September  of  2013 
(GR01/02/03/05/06/07/11/12),  another  4  by  September  2014  (GR04/08/09/10),  while  the 
remaining  2  by  September  2015  (GR13/14).  The  relevant  Strategic  Environmental 
Assessments/Environmental  Impact  Assessments  (SEA/EIAs)  have  been  approved  as  well 
and are publicly available. The 12 RBMPs officially approved by late 2014 should implement 
the Programmes of Measures in the following very short period as the second round of revised 
Plans  should  be  submitted  by  2015,  according  to  the  WFD,  taking  into  account  the 
implementation of the first RBMPs, while it is questionnable if this is even feasible for the 2 
RBMPs which have been approved in late 2015 (GR13/14)7. 

Consultation of the public, engagement of interested parties 

Regarding  the  RBMPs  of  GR01/02/03/09/10  there  was  a  critical  assessment  expressed  in  a 
rather  “positive”  way  about  most  consultation  activities  (in  WISE  1.3.6),  mentioning  that: 
“Unprecedented  for  the  Greek  situation  was  the  less  than  expected  participation  of  the 
public”.  A  “results  of  the  participation”  document  was  submitted  along  with  the  relevant 
RBMPs. Regarding  the consultation procedures, in  the RBMPs of GR04/05/06/07/08/11/12, 
the consultation document does not refer to the activities that took place, but is a “planning 
document” for the activities that should/would take place. According to WISE 1.3.6, the main 
activities include: (a) publication and commenting  of the public participation  plan, involved 
stakeholders,  Significant  Water  Management  Issues  report;  (b)  publication  and  commenting 
of  the  RBMP;  (c)  publication and  commenting  of  the  SEA/EIA;  (d) informational  meetings 
and  (e)  39  stakeholder  conferences/workshops  (attended  by  3,500  participants  in  total  as 
stated  by  the  EGY).  Moreover  the  EGY  has  set  up  an  interactive  internet  site 
http://wfd.ypeka.gr where the full content of the RBMPs is available and which facilitated the 
submission  of  comments  by  interested  stakeholders.  The  consultation  can  be  assessed  as 
adequate  but  “improvable”  in  terms  of  stakeholders’  participation  (almost  450  written 
comments/interventions  were  received  through  questionnaires  and  the  consultation  website) 
and  input.  Regarding  the  RBMPs  of  GR13/14,  there  was  a  positive  assessment  on  the 
consultation  activities,  and  a  statement  that  the  collaboration  with  the  stakeholders  was 
continuous and very active. 

It is difficult to describe the impact of the consultation on the final plans, since the document 
“results of the participation” was not submitted (however it is reported by EL as available in 
the EGY). A “general list of comments was received” during the consultation workshops but 
it cannot be inferred from the RBMP itself whether these comments were actually taken under 
consideration and were incorporated in the newer RBMPs version. It is stated by the EGY that 
they have been considered and incorporated. Most of the comments originated either from the 
scientific community or from other institutions, organisations, etc.  

There was no active continuous involvement of stakeholders and the general public but rather 
limited participation in certain consultation workshops. In general the consultation across all 
RBMPs  can  be  assessed  as  not  very  successful  in  terms  of  stakeholder  participation  and 
input.8  

7 Greek authorities clarified in March 2017 that in GR 13 and GR14 the implementation of the Programmes of 
Measures  started  right  after  the  adoption  of  the  RBMPs  or  in  some  cases  of  (basic)  PoMs  during  the 
development of the RBMPs. 
8 Greek authorities noted in March 2017 that local stakeholders were involved in the drafting of all 14 RBMPs. 
Across all RBDs the participation of stakeholders and the general public in the consultation process was active. 

12 

 
 
                                                            
 
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 participation9.  

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. 

Besides the workshops, the active participation was ensured through formal consultation with specific selected 
groups, further targeted meetings in the RBDs, in cooperation with the Regional Water Directorates - and by the 
comments and the questionnaires which were received through the consultation webpage. 
9 According to Greece, the Albanian authorities have been invited during the RBMP consultation process. 

13 

 
 
                                                                                                                                                                                          
For GR11, in spite of the fact that there has not been full international coordination between 
Greece  and  Bulgaria,  from  27th  July  2010,  there  has  been  a  Joint  Declaration  between  the 
Hellenic Ministry of Environment, Energy and Climate Change and the Bulgarian Ministry of 
Environment  and  Water  Resources  regarding  the  use  of  water  resources  in  the  territories  of 
shared  river  basins.  The  Joint  Declaration  confirmed  the  intention  of  the  two  countries  to 
cooperate  in  the  water  resources  management  issues  in  the  transboundary  basins.  For  this 
purpose, the Joint Expert Working Group was established; the Group initially met in Drama 
on 16th May 2011, then in Sofia on 12th October 2011, in Thessaloniki on 23rd April 2013 and 
in Athens on 8th May 2014. As regards the public participation there has been no international 
coordination between the two countries. For GR12, in spite of the fact that there has not been 
full  international  coordination  between  Greece,  Bulgaria  and  Turkey,  regarding  the 
cooperation  with  Bulgaria,  there  has  been  a  series  of  negotiations  that  started  in  1965  and 
resulted in an Agreement between Greece and Bulgaria that was signed in 1995, certified with 
the Greek Law 2402/96, Government Gazette (GG/A/98) and has 8 Articles. As with GR11, 
the  cooperation  of  the  two  countries  was  enhanced  on  27th  July  2010  with  the  Joint 
Declaration  of  the  two  responsible  Ministries  (see  further  details  above).  Additionally, 
regarding the cooperation with Turkey, an Ad Hoc Joint Committee has been established in 
November  2010  in  respect  to  cooperation issues  for  the  Evros  River  Basin.  The  Committee 
initially  met  on  30th  May  2011.  In  this  framework,  the  Joint  Expert  Working  Group  was 
established  in  order  to  exchange  data  and  information  for  the  Evros  River  and  the  relevant 
sub-basins  in  Greece  and  Turkey.  The  Joint  Expert  Working  Group  has  met  twice,  in 
Adrianoupolis  on  24th  June  2011  and  in  Alexandroupolis  on  8th  September  2011.  It  should 
also be mentioned that both the Greek and the Turkish sides give a great deal of emphasis on 
a  common  management  response  to  the  flood  issues  of  Evros,  a  subject  of  Greek  terms 
associated with the implementation of the corresponding Directive 2007/60/EC on flood risk 
management  in  the  EU.  As  regards  the  public  participation  there  has  been  no  international 
coordination between the interested countries. 

Integration with other sectors 

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

14 

 
 
CHARACTERISATION OF RIVER BASIN DISTRICTS 

Water categories in the RBD 

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

Typology of surface waters 

The  Presidential  Decree  51/2007  “Establishment  of  measures  and  procedures  for  integrated 
protection  and  management  of  water  in  compliance  with  the  provisions  of  the  Water 
Framework Directive 2000/60/EC” defines in Annex II that both systems A and B could be 
used in the characterisation of surface water bodies. In the Greek RBMPs, system B has been 
mostly applied for all the water categories, with the exception of GR13 where system A was 
used  for  river  and  lake  water  bodies.  More  specifically,  system  A  was  selected  because  the 
information required for its implementation was readily available for GR13, but also because 
it  contains  the  essential  factors  that  differentiate  the  rivers  and  streams  of  this  RBD,  i.e. 
distinguishing different geological types and different types of altitude. For lakes, system A 
was also selected for GR14 as the information was also readily available and could efficiently 
identify the environmental variations between the lakes. It is to be noticed that previously, in 
2009,  in  response  to  the  obligations  of  Art.  8  of  the  WFD,  system  A  was  used  for  all  the 
RBDs. In the current RBMPs there was a switch to system B for the 13 out of 14 RBDs (all 
obligatory descriptors for system B have been used), which resulted in the modification of the 
number, boundaries and characteristics of the surface water bodies. 

Overall  the  surface  water  typology  has  been  validated  with  biological  data.  For  river  water 
bodies it was based solely on benthic macroinvertebrates, for lakes on phytoplankton and for 
coastal  and  transitional  water  bodies  on  macroinvertebrates,  phytoplankton  and  macroalgae. 
In general, reference conditions have been established for each of the surface water types with 
the exception of the transitional waters where the work on reference conditions is at an early 
stage and the information provided so far is indicative until intercalibration is finalised. The 
methodology  used  was  based  both  on  spatially  based  methods,  as  well  as  on  expert 
judgement. It is unclear from the RBMPs and Annexes (provided as background documents) 
how much expert judgement was used. In terms of a national Guidance Document, guidelines 
were formulated by the coordinator consultant and the General Secretariat for Water to guide 
and  harmonise  the  work  and  methodological  approach  of  all  other  consultants  who  were 
commissioned with the drafting of the RBMPs, but these were not organised into a detailed 
guidance document. 

The number of surface water types that have been defined in different water categories is 
summarised in Table 4.2.1.  

15 

 
 
RBD 

Rivers 

Lakes 

Transitional 

Coastal 

GR01 

GR02 

GR03 

GR04 

GR05 

GR06 

GR07 

GR08 

GR09 

GR10 

GR11 

GR12 

GR13 

GR14 

6 

6 

5 

8* 
8 

1 

5 

8* 
10 

7 

6 

7 

  6** 
 No data 
reported in 
WISE1 
1** 

1 

4 

1 

3* 
3 

1 

1 

2* 
4 

4 

2 

2 
2** 

1 

2 

2 

2 

2* 
2 

0 

1 

0* 
2 

2 

1 

2 
2** 

0 

1 

1 

1 

1* 
1 

1 

1 

1* 
1 

1 

1 

1 
3** 

5 

Table 4.2.1: Surface water body types at RBD level 
Source: WISE; * corrections/additions provided by EL late 2014; ** no data reported in WISE-the information is extracted 
from the RBMP 

Delineation of surface water bodies 

The river delineation process excluded from the first step ephemeral streams, where 95% of 
the time there is no presence of water in them and neither is any aquatic environment present. 
After  this  exclusion  the  initial  water  bodies  selection  was  performed  on  the  basis  of  the 
Strahler  stream  classification  index.  Only  streams  of  the  4th  order  and  above  are  initially 
included in the set. This initial set is considered by definition to be comprised of “important 
and discrete” elements of surface water, but not including all such elements. Additional water 
bodies  (which  were  initially  excluded  due  to  their  ephemeral  flow)  were  then  added  to  this 
initial  set  if  deemed  important  elements  in  terms  of  aquatic  ecosystem  and  fish  population. 
This  assessment  of  importance  of  these  small  water  bodies  was  made  almost  exclusively 
based  on  expert  judgment  of  scientists  from  the  Hellenic  Centre  for  Marine  Research 
(HCMR) taking into account biological data (fish and benthic invertebrates) where available. 
In the RBMPs it is mentioned that an investigation was undertaken into whether small water 
bodies  can  be  aggregated  with  adjacent  water  bodies  (aggregation  was  performed  where 
feasible and essential). However, a different approach was followed in the case of GR13 using 
the  factors  that  were  defined  through  the  intercalibration  exercise  for  the  delination,  and 
mainly associated with the periodicity of the streamflow. More specifically, three categories 
have  been  distinguished  in  Crete:  the  1st  category  includes  river  water  bodies  where 
streamflow  occurs  for  8  to  9  months  during  the  wet  period.  In  the  2nd  category  streamflow 
occurs  for 6 to 8 months,while in the 3rd category it occurs for a very limited period (about 3 
months)  .  It  has  been  identified  that  in  GR13  the  dominant  type  of  rivers  is  small  and 
ephemeral. A special attention has been given on this aspect, and GR13 further introduced 2 
new  river  types  (RM-1a,  RM-5a)  expanding  on  the  results  of  theIntercalibration  exercise in 
the  Mediterranean  GIG.Finally,  some  further  additions  were  made  during  the  consultation 
process  where  some  additional  streams  to  be  included  were  indicated  by  local  officials  and 

16 

 
 
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. 

Rivers 

Lakes 

Transitional 

Coastal 

Surface Water 

RBD 

GR01 

GR02 

GR03 

GR04 

GR05 

GR06 

GR07 

GR08 

GR09 

GR10 

GR11 

GR12 

GR13 

GR14 
Total 

Number 

110 

63 

80 

102* 
85 

14 

81 

74* 
150 

104 

91 

188 

-118 

-75 
1335 

Average 
Length 
(km) 
8 

11 

7 

10* 
13 

9 

13 

19* 
10 

11 

9 

10 

-6 

-4 
10 

Number 

2 

6 

1 

5* 
1 

1 

3 

1* 
14 

6 

2 

6 

-5 

-8 
4861 

Average 
Area 
(sq km) 
2 

5 

1 

26* 
19 

3 

12 

35* 
39 

28 

24 

4 

-1 

-0 
17 

Number 

5 

9 

6 

4* 
7 

0 

1 

0* 
2 

3 

1 

5 

-4 

Average 
Area 
(sq km) 
1 

2 

1 

68* 
59 

- 

18 

0* 
20 

23 

7 

56 

-0 

-0 
4347 

-0 
2324 

Number 

11 

19 

13 

8* 
13 

14 

19 

7* 
2 

11 

4 

12 

-25 

-87 
133245 

Groundwater 

Number 

26 

26 

27 

25* 
26 

24 

46 

32* 
62 

39 

15 

18 

-91 

Average 
Area 
(sq km) 
262 

284 

299* 

410* 
349 

129 

268 

392* 
275 

348 

456 

578 

-92 

Average 
Area 
(sq km) 
95 

127 

206 

273* 
81 

288 

339 

134* 
564 

350 

183 

61 

-89 

-70 

-113 
225204  366570  338262 

-79 

Table 4.3.1: Surface water bodies, groundwater bodies and their dimensions  
Source: WISE; * corrections/additions provided by EL late 2014.  

Identification of significant pressures and impacts  

Even  though  in  certain  RBDs  limited  information  on  methods  for  defining  significant 
pressures  is  available,  the  WISE  summary  report  shows  that  determination  of  significant 
pressures  has  been  made  for  all  of  the  RBDs.  Table  4.4.1  gives  an  overall  picture  of  the 
significance  of  the  different  pressures  within  the  country.  These  data  indicate  that  diffuse 
pollution  is  assessed  as  the  most  significant  pressure  in  Greece,  affecting  48%  of  surface 
water bodies (808 SWBs) followed by point source pollution which affects 33% (549 SWBs). 
“Other  pressures”  affect  14%  (229  SWBs),  and  surface  water  abstraction  affects  4%  (74 
SWBs)  of  surface  water  bodies.  Additionally,  pressures  such  as  water  flow  regulations  and 
morphological alterations, other morphological alterations,river management and transitional 
and coastal water management are allocated smaller percentages, i.e. 3% (43 SWBs), 0.3% (4 

17 

 
 
SWBs), 1% (14 SWBs) and 1% (9 SWBs) respectively. It needs to be pointed out that GR13 
and GR14 have reported very small percentages of water bodies affected by diffuse and point 
source  pressures  (only  about  10%),  which  lowers  the  overall  country  average  (the  country 
average is decreased by about 12-15%). 

An explicit identification of the criteria used to determine the significance of pressures is not 
apparent  in  all  the  RBMPs,  yet  EL  clarified  that  criteria  (and  the  related  thresholds)  for 
individual pressures (point and diffuse pollution, and water abstraction) were identified from 
the  limits  contained  in  other  relevant  Directives,  studies  and  research  results  found  in 
literature, and expert judgement as being likely to impact on water status. 

on 

specific  methods 

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 
hand, 
the 
other 
GR01/02/03/05/06/07/09/10/13/14 
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)). 

or 
identify  specific 

used.  On 

thresholds 

criteria 

the 

source 

diffuse 

(e.g. 
Regarding 
GR01/02/03/04/05/06/07/08/09/10/13/14)  give  a  summary  table  of  criteria  (related  to  type, 
size  and  pollution  load)  for  all  pressures,  defining  specific  levels  of  N,  P  and  BOD 
concentrations  as  thresholds  connected  to  diffuse  pollution  (e.g.  when  BOD>10  mg/l, 
N>10mg/l and P >1mg/l the pressure is defined as significant).  

pollution 

RBDs 

most 

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: 

18 

 
 
  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 

19 

 
 
agriculture. The mining activity that relates to water pollution is located mainly in the 
region of Jerrissou, in the southeast of the water districts.  

  GR11/12:  most  of  the  pollution  loads  come  from  agriculture,  livestock  and  urban 

waste. 

  GR13/14:  most  of  the  pollution  loads  comes  from  agriculture,  livestock,  oil  mills, 
atmospheric  deposition  and  sewage  from  urban  settlements  that  are  not  served  by 
Urban Waste Water Treatment Plants (UWWTP).  

20 

 
 
 
River 
management 

Transitional 
and coastal 
water 
management 

Other 
morphological 
alterations 

Other 
pressures 

RBD 

GR01 

GR02 

GR03 

GR04 

GR05 

GR06 

GR07 

GR08 

GR09 

GR10 

GR11 

GR12 

GR13 

GR14 

Total 

No pressures 

Point source 

Diffuse source 

Water 
abstraction 

No. 
- 

- 

2 

% 
0 

0 

2 

53* 

44* 

42 

17 

19 

No. 
88 

48 

63 

54* 

46* 

23 

67 

% 
69 

49 

63 

45* 

42 

79 

64 

No. 
128 

97 

98 

41* 

44* 

19 

74 

% 
100 

100 

98 

34* 

41 

66 

71 

16* 

55* 

67* 

62* 

76* 

68 

41 

41 

54 

82 

95 

28 

26 

17 

5 

22 

7 

17 

21 

17 

2 

14 

4 

25 

67 

52 

95 

5 

1 

15 

54 

53 

45 

3 

1 

44% 

549 

33% 

808 

48% 

44 

5 

20 

13* 

115 

51 

40 

114 

124 

-161 

742 

% 
8 

19 

4 

9* 

9 

0 

5 

2* 

0 

1 

10 

1 

-0 

-0 

No. 
10 

18 

4 

11* 

11* 

0 

5 

2* 

0 

1 

10 

2 

-0 

-0 

74 

Water flow 
regulations 
and 
morphological 
alterations 
% 
No 
0 
0 

0 

0 

0 

0 

17* 

14* 

8 

0 

0 

8 

0 

0 

No. 
0 

0 

0 

5* 

0 

0 

0 

% 
0 

0 

0 

4* 

0 

0 

0 

2* 

2* 

7* 

9* 

0 

0 

6 

9 

0 

1 

0 

0 

6 

4.27 

-0 

1 

3% 

0 

0 

0 

2 

-0 

-0 

14 

0 

0 

0 

1 

-0 

-0 

1% 

4% 

43 

No. 
0 

0 

0 

4* 

5* 

0 

0 

0* 

0 

0 

0 

0 

-0 

-0 

9 

% 
0 

0 

0 

3* 

5* 

0 

0 

0* 

0 

0 

0 

0 

-0 

-0 

1% 

No. 
0 

0 

0 

0* 

0* 

0 

4 

0* 

0 

0 

0 

0 

-0 

-0 

4 

% 
0 

0 

0 

0 

0* 

0 

4 

0* 

0 

0 

0 

0 

-0 

-0 

0,3 

No. 
32 

39 

37 

53 

% 
25 

40 

37 

44 

44* 

42* 

0 

0 

0 

0 

13* 

16* 

0 

0 

0 

10 

1 

0 

0 

0 

0 

5 

1 

-0 

229 

14% 

Table 4.4.1: Number and percentage of surface water bodies affected by significant pressures 
Source: WISE; * corrections/additions provided by EL late 2014.  

21 

 
 
 
 
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

22 

 
 
 
Protected areas 

In  Greece  2,614  protected  areas  have  been  designated,  according  to  information  provided  to 
WISE (see Table 4.5.1).   Just over half of these areas (56%) are for bathing water (mostly from 
GR14), while 7% are for drinking water abstraction under Art. 7 of the WFD. Another  18% are 
for  habitats,  birds  and  fish  altogether,  4%  are  for  UWWTPs  and  12%  for  local  protected  areas 
(mostly  from  GR14)  With  regard  to  the  protected  areas  under  Art.  7  abstraction  for  drinking 
water, out of the total 178 protected areas 131 are for groundwater10 (i.e. 74%) and the remaining 
26% are for surface water. 

RBD 

7
e
l
c
i
t
r
A

r
o
f
n
o
i
t
c
a
r
t
s
b
A

r
e
t
a
w
g
n
i
k
n
i
r
d

Number of PAs 

g
n
i
h
t
a
B

s
d
r
i
B

n
a
e
p
o
r
u
E

r
e
h
t
O

h
s
i
F

s
t
a
t
i
b
a
H

l
a
c
o
L

l
a
n
o
i
t
a
N

s
e
t
a
r
t
i

N

h
s
i
f
l
l
e
h
S

T
W
W
U

10  The  Greek  authorities  clarified  in  March  2017  that  in  GR14  the  groundwater  bodies  designated  for  the 
abstraction  of  water  intended  for  human  consumption  under  Article  7  were  not  registered  as  protected  areas. 
Wells or drillings used for water abstraction for human consumption, which are providing more than 10m3 a day 
or  are  serving  more  than  50  persons  are  spread  across  the  Aegean  islands  and  therefore  the  total  number  of 
groundwater  bodies  covering  the  whole  surface  of  each  island  would  be  identified  as  protected  areas,  in 
accordance  with  WFD  Art.  7.  Taking  into  account  that  the  regional  authorities  do  not  agree  with  the 
characterisation of all islands (the whole surface of each island) as protected areas, the best approach to protect 
public drinking water was (in accordance with GD 16) the establishment of safeguard zones around groundwater 
abstraction  points,  as  a  basic  measure  of  the  adopted  RBMP  and  not  to  register  all  groundwater  bodies  as 
protected areas. The protection of groundwater abstracted for human consumption is being achieved by focusing 
on  the  necessary  measures  in  the  safeguard  zones.  Almost  the  same  approach  was  followed  in  GR13  (Crete), 
where  only  karstic  groundwater  bodies were registered  as  protected  areas  under WFD Art. 7,  considering  that 
they are more vulnerable and need increased protection. 

23 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                            
7
e
l
c
i
t
r
A

r
e
t
a
w
g
n
i
k
n
i
r
d

r
o
f
n
o
i
t
c
a
r
t
s
b
A
5 

9 

3 

21* 
10 

4 

16 

7* 
17 

4 

15 

20 

-47 

RBD 

GR01 

GR02 

GR03 

GR04 

GR05 

GR06 

GR07 

GR08 

GR09 

GR10 

GR11 

GR12 

GR13 

g
n
i
h
t
a
B

50 

114 

88 

60* 
87 

125 

170 

67* 
11 

84 

 23* 

36 

-143 

s
d
r
i
B

2 

4 

3 

15* 
21 

4 

14 

16* 
11 

9 

5 

14 

- 

-0 

GR14 
- 
Total  131178  9151463  118 

-405 

Number of PAs 

n
a
e
p
o
r
u
E

r
e
h
t
O

- 

- 

h
s
i
F

4 

6 

4 

6 

2 

5 

- 

- 

s
t
a
t
i
b
a
H

8 

15 

7 

22* 
23 

5 

16 

13* 
22 

15 

7 

12 

-53 

-89 

l
a
c
o
L

l
a
n
o
i
t
a
N

8 

5 

8 

9* 
33 

25* 
23 

5* 

-57 

-203 

- 

- 

s
e
t
a
r
t
i

N

1 

1 

2* 
2 

3 

4 

1* 
2 

1 

1 

3 

-2 

- 

h
s
i
f
l
l
e
h
S

T
W
W
U

12* 
6 

4 

11 

2* 
23 

6 

14 

27 

- 

- 

2 

4 

4 

7 

- 

- 

0 

27  165307  42302 

74  2123 

17  105 

Table  4.5.1:  Number  of  protected  areas  of  all  types  in  each  RBD  and  for  the  whole  country,  for  surface  and 
groundwater11 
Source: WISE; * corrections/additions provided by EL late 2014.  

MONITORING 

General description of the monitoring network 

The monitoring programme for Greece has been defined in the Common Ministerial Decree 
ΚΥΑ  140384/9-9-2011  while  the  standards  and  minimum  performance  criteria  of  the 
analytical  methods  for  the  chemical  analysis  and  monitoring  have  been  defined  in  the 
Common  Ministerial  Decree  38317/1621/Ε103/2011.  According  to  the  Ministerial  Decree 
140384/9-9-2011, the EGY is responsible for: i) the submission of the annual budget for the 
operation of the NMP to the Ministry, ii) the monitoring at national level of the quantity and 
quality of surface and groundwaters in cooperation with the Regional Water Directorates of 
the Decentralised Administrations, iii) the development and operation of the national network/ 
grid. At the time that the RBMPs were being drafted, the new WFD monitoring programme 
was  not  operational.  Thus,  the  monitoring  data  used  for  the  characterisation  of  the  water 
bodies  in  the  RBMPs  were  based  on  the  old  fragmented  monitoring  network  which  had 
significant data gaps with regard to the WFD-required assessment parameters.  

11   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. 

24 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
                                                            
The  new  National  Monitoring  Programme  -  NMP  (established  with  the  above  mentioned 
Ministerial  Decree  in  2011  and  currently  implemented  from  2012  onwards)  follows  a 
common national approach in terms of objectives, standards, definition of monitoring points, 
responsible authorities,  etc.  The  number,  type  and  location  of  monitoring  stations  per  water 
body  and  the  number,  type  and  frequency  of  the  sampling  parameters  are  listed  in  the 
Ministerial Decree. All these were originally defined in 2009 in response to the obligations of 
Article 8 of the WFD, considering the state-of-the-art knowledge at that time and the results 
of  a  relevant  study  commissioned  by  the  General  Secretariat  for  Water  (which  also  defined 
the  water  bodies,  pressures  and  impacts)  and  were  updated  and  finalised  in  2010  in  the 
framework of the national project “Development and application of methods and software for 
the assessment of the water quality related data of the Greek water bodies”.  A total of 616 
monitoring stations for surface water bodies are defined in the new programme for the whole 
territory,  and 1,387 for  groundwater bodies. It is foreseen  that the new network programme 
will  be  updated  periodically  in  order  to  better  meet  the  systems’  needs  based  on  the  first 
monitoring  results  (originally  expected  at  the  end  of  2013)  and  the  findings  of  the  current 
RBMPs.  

In  the  13  out  of  14  RBMPs  the  typology  used  for  the  characterisation  of  the  water  bodies 
changed with regard to the system that was used back in 2008-2009 (shifting from system A 
to system B). This resulted in the modification of the number, boundaries and characteristics 
of  the  water  bodies,  and  the  subsequent  need  to  perform  a  new  matching  between  the 
established monitoring points of the Ministerial Decree and the latest defined water bodies (in 
the  RBMPs).  The  matching  has  been  performed,  but  also  additional  information  from  the 
neighbouring RBDs, the water bodies’ grouping and the identified pressures and impacts has 
been integrated and led to suggestions on modification of the new monitoring programme to 
better serve its purpose. These suggestions are presented in all the RBMPs and are basically 
grouped  under  three  main  categories:  (i)  reallocation  of  the  monitoring  stations  to 
neighbouring  sites  (e.g.  upstream  or  downstream  in  rivers);  (ii)  switching  of  monitoring 
stations  from 
the  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. 

the  surveillance 

to 

25 

 
 
 
Figure 5.1: Maps of surface water (left) and groundwater (right) monitoring stations 

• 
• 
• 
• 
• 
• 

  River monitoring stations 
  Lake monitoring stations 
  Transitional water monitoring stations 
  Coastal water monitoring stations 
  Unclassified surface water monitoring stations 
  Groundwater monitoring stations 

 River Basin Districts 
 Countries outside EU 
Source: WISE, Eurostat (country borders)  

Monitoring of surface waters 

As explained above, the data used in the RBMPs originated from the old monitoring network, 
which was not compliant with WFD requirements. The available data were fragmented, with 
many  gaps  in  parameters  and  time-series  which  restricted  the  corresponding  assessments  in 
the  RBMPs.  The  data  of  the  old  monitoring  network  were  provided  by  different  agencies, 
mainly the Ministry for the Environment, Energy and Climate Change, the Ministry of Rural 
Development  and  Food  and  the  General  Chemical  State  Laboratory.  Data  from  regional 
authorities and sample monitoring from various existing surveys were also available in some 
cases.  As  a  result,  based  on  quality  assurance,  completeness,  accuracy,  etc.  the  following 
quality  elements  of  the  old  monitoring  system  have  been  considered  overall  for  the 
classification of surface water bodies (yet not in all cases, and not with continuous long time-
series) in the current RBMPs:   

  BQEs: 

  benthic  macroinvertebrates 

(lakes); 
macroinvertebrates,  phytoplankton  and  macroalgae  (coastal  and  transitional)  –more 
details in section 7. 

rivers);  phytoplankton 

(for 

  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. 

26 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  Priority  substances  and  other  specific  pollutants:  Ni,  Pb,  Hg,  Cd,  Brominated 
Endosulfan, 
Chlorfenvinphos,  Anthracene,  Hexachlorobenzene, 

diphenylether, 
Hexachlorocyclohexane, 
considered on a case-by-case basis –more details in section 9. 

Di(2-ethylhexyl)phthalate 

(DEHP), 

In  assessing  the  river  water  bodies  (in  the  current  RBMPs),  grouping  was  performed  when 
there was no monitoring station within a certain river water body (of the old network). Groups 
have been formulated so that each group contains at least one river water body which is being 
monitored.  The  grouping  was  based  on  the  hydromorphological  characteristics  of  the  rivers 
(biogeographical regions,  annual  discharge, slope,  altitude)  as  reflected  in  the  water  bodies’ 
typology,  as  well  as  on  the  type  and  intensity  of  pressures  that  are  identified  in  the  sub-
catchment  of  the  water  body.  The  heavily  modified  and  artificial  water  bodies  have  been 
excluded  from  grouping  and  are  considered  individually  even  when  monitoring  stations  are 
not present in them. 

With  regard  to  the  New  Monitoring  Programme  (established  by  the  Ministerial  Decree  in 
2011)  it  includes  both  surveillance  and  operational  monitoring  programmes  including  all 
relevant  quality  elements.  A  total  of  616  monitoring  stations  for  surface  water  bodies  are 
defined  in  the  NMP  for  the  whole  territory,  of  which  377  are  for  surveillance  and  239  for 
operational  monitoring.  Biological,  physico-chemical  and  hydromorphological  QEs  are 
defined to be monitored in all of them, priority substances in 326, specific pollutants in 282 
and  other  substances  in  29  of  them.  The  relevant  elements  that  are  monitored  per  RBD  are 
shown  in  Table  5.1  below  as  reported  in  the  WISE  Summary  Reports  4.1.7  and  4.1.8,  and 
further corrected by EL in late 2014 (except for the GR13/14 where corrections by EL are not 
made and it is not clear in WISE whether some elements are included or not). 

the  monitoring  stations  are  part  of 

Few  of 
the  International  Network  Barcelona 
Convention/Mediterranean  Action  Plan  (MEDPOL).  A  detailed  view  of  the  programmes 
(surveillance  &  operational),  station  locations,  elements  and  frequencies  foreseen  to  be 
monitored at each water body is provided in the Annexes of the Ministerial Decree, and also 
on WISE - CDR under the Art. 8 reporting (submitted 26.08.2009), and have been defined in 
the document “Updated Report of Article 8 of the WFD including the catalogue of elements 
and  parameters  to  be  monitored  in  each  station  of  the  NMP”.  The  sampling  and  frequency 
methodologies  are  also mentioned there. With regard to  the  methodologies  for selecting  the 
BQEs  of  the  operational  programme,  the  priority  substances  and  other  pollutants,  it  is 
mentioned  that  these  are  developed  within  the  guidance  documents  of  the  research  project 
“Development of network and monitoring of the internal, transitional and coastal water bodies 
of  the  country  –  Assessment/Classification  of  their  ecological  status”  undertaken  by  the 
HCMR-EKBY,  2008  (Hellenic  Centre  for  the  Marine  Research  –  Greek  Biotope/Wetland 
Centre).  As  mentioned  above,  upon  the  establishment  of  the  RBMPs  and  their  findings 
additional  suggestions  were  made  in  the  RBMPs  regarding  modifications  to  the  NMP 
(inclusion/exclusion  of  monitoring  stations  and/or  elements)  to  better  accommodate  the 
identified needs. 

Monitoring of groundwater 

As explained above, the data used in the RBMPs originated from the old monitoring network, 
which  was  not  compliant  with  the  WFD  requirements.  The  available  data  was  fragmented, 
with gaps in parameters and time-series which restricted the corresponding assessments in the 
RBMPs. The data of the old monitoring network were provided by different agencies, mainly 
the Institute of Geology and Mineral Exploration, the Ministry for the Environment, Energy 

27 

 
 
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 

28 

 
 
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.  

29 

 
 
BD 

GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 
GR13 
GR14 

Rivers 

Lakes 

a
r
o
l
f

c
i
t
a
u
q
a
r
e
h
t
O
2
.
1
E
Q

n
o
t
k
n
a
l
p
o
t
y
h
P
1
.
1
E
Q

s
e
t
y
h
p
o
r
c
a
M
3
.
2
.
1
E
Q

s
o
h
t
n
e
b
o
t
y
h
P
4
.
2
.
1
E
Q

s
e
t
a
r
b
e
t
r
e
v
n
i

c
i
h
t
n
e
B
3
.
1
E
Q

l
a
c
i
g
o
l
o
h
p
r
o
m
o
r
d
y
H
2
E
Q

s
E
Q

s
r
e
t
e
m
a
r
a
P

l
a
r
e
n
e
G
1
.
3
E
Q

c
i
f
i
c
e
p
s
y
t
i
r
o
i
r
p
n
o
N

3
.
3
E
Q

s
t
n
a
t
u
l
l
o
p

s
e
i
c
e
p
s

r
e
h
t
O
5
.
1
E
Q

l
a
n
o
i
t
a
n
r
e
h
t
O
4
.
3
E
Q

s
t
n
a
t
u
l
l
o
p

n
o
t
k
n
a
l
p
o
t
y
h
P
1
.
1
E
Q

a
r
o
l
f

c
i
t
a
u
q
a
r
e
h
t
O
2
.
1
E
Q

h
s
i
F
4
.
1
E
Q

s
e
t
a
r
b
e
t
r
e
v
n
i

c
i
h
t
n
e
B
3
.
1
E
Q

l
a
c
i
g
o
l
o
h
p
r
o
m
o
r
d
y
H
2
E
Q

s
E
Q

s
r
e
t
e
m
a
r
a
P

l
a
r
e
n
e
G
1
.
3
E
Q

c
i
f
i
c
e
p
s
y
t
i
r
o
i
r
p
n
o
N
3
.
3
E
Q

s
t
n
a
t
u
l
l
o
p

l
a
n
o
i
t
a
n
r
e
h
t
O
4
.
3
E
Q

s
t
n
a
t
u
l
l
o
p

s
e
i
c
e
p
s

r
e
h
t
O
5
.
1
E
Q

h
s
i
F
4
.
1
E
Q

s
e
t
y
h
p
o
r
c
a
M
3
.
2
.
1
E
Q

s
o
h
t
n
e
b
o
t
y
h
P
4
.
2
.
1
E
Q

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

30 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
RBD 

a
r
o
l
f

c
i
t
a
u
q
a
r
e
h
t
O
2
.
1
E
Q

n
o
t
k
n
a
l
p
o
t
y
h
P
1
.
1
E
Q

e
a
g
l
a
o
r
c
i

M
1
.
2
.
1
E
Q

s

m
r
e
p
s
o
i
g
n
A
2
.
2
.
1
E
Q

- 

- 

- 

- 

GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 
GR13 
- 
GR14 
- 
Table 5.1: Quality elements monitored12 

- 
- 

- 
- 

- 
- 

- 

- 

- 

- 

Transitional 

Coastal 

s
e
t
a
r
b
e
t
r
e
v
n
i

c
i
h
t
n
e
B
3
.
1
E
Q

- 

- 

- 
- 

l
a
c
i
g
o
l
o
h
p
r
o
m
o
r
d
y
H
2
E
Q

s
E
Q

- 

- 

- 
- 

s
r
e
t
e
m
a
r
a
P

l
a
r
e
n
e
G
1
.
3
E
Q

- 

- 

- 
- 

s
e
i
c
e
p
s

r
e
h
t
O
5
.
1
E
Q

- 

- 

- 
- 

h
s
i
F
4
.
1
E
Q

- 

- 

- 
- 

c
i
f
i
c
e
p
s

y
t
i
r
o
i
r
p
n
o
N
3
.
3
E
Q

s
t
n
a
t
u
l
l
o
p

l
a
n
o
i
t
a
n
r
e
h
t
O
4
.
3
E
Q

s
t
n
a
t
u
l
l
o
p

n
o
t
k
n
a
l
p
o
t
y
h
P
1
.
1
E
Q

a
r
o
l
f

c
i
t
a
u
q
a
r
e
h
t
O
2
.
1
E
Q

e
a
g
l
a
o
r
c
i

M
1
.
2
.
1
E
Q

s

m
r
e
p
s
o
i
g
n
A
2
.
2
.
1
E
Q

s
e
t
a
r
b
e
t
r
e
v
n
i

c
i
h
t
n
e
B
3
.
1
E
Q

l
a
c
i
g
o
l
o
h
p
r
o
m
o
r
d
y
H
2
E
Q

s
E
Q

s
r
e
t
e
m
a
r
a
P

l
a
r
e
n
e
G
1
.
3
E
Q

c
i
f
i
c
e
p
s

y
t
i
r
o
i
r
p
n
o
N
3
.
3
E
Q

s
t
n
a
t
u
l
l
o
p

l
a
n
o
i
t
a
n
r
e
h
t
O
4
.
3
E
Q

s
t
n
a
t
u
l
l
o
p

s
e
i
c
e
p
s

r
e
h
t
O
5
.
1
E
Q

h
s
i
F
4
.
1
E
Q

- 

- 

- 
- 

- 

- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

12 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.  

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                            
 
  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 

GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 
GR13 
GR14 
Total by type 
of site 
Total number 
of monitoring 
sites 

Rivers 

Lakes 

Transitional 

Coastal 

Groundwater 

Surv 

Op 

Surv 

Op 

Surv 

Op 

Surv 

Op 

17 

25 

12 

15* 

32 

4 

37 

19 

11 

10 

26* 

5* 

4 

6 

1 

2 

0* 

10* 

3 

0 

2 

24* 

33* 

2* 

19 

22 

26 

36 

21* 

10* 

11 

4 

10 

4 

5* 

0* 

300 

148 

2 

1 

1 

2 

1* 

0* 

27 

0 

1 

0* 

2* 

1* 

1 

1 

0* 

10 

4 

1 

3 

2* 

0* 

26 

0 

0 

0* 

0* 

0* 

0* 

0 

0* 

0 

0 

0 

0 

0* 

0* 

0 

2 

4 

0* 

5* 

6 

0* 

1 

0* 

2 

2 

1 

8 

0* 

4* 

35 

4 

4 

3 

1* 

2 

3 

3 

4* 

1 

3 

1 

3 

5* 

13* 

50 

0 

5 

2 

1* 

5* 

6 

6 

1* 

0 

2 

0 

1 

1* 

0* 

30 

Surv 

27* 

10 

13 

23* 

19* 

6 

11 

33* 

45* 

5 

16 

26 

36* 

24* 

Op 

59* 

95* 

113* 

42* 

71* 

74 

Quant 

86* 

105* 

126* 

65* 

90* 

80 

154* 

165* 

61* 

44 

108 

35 

53 

94* 

89* 

113 

51 

79 

76* 

108* 

112* 

132* 

294 

1093 

1387 

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 

late  2014.  Some  discrepancies  between 

in 

this 

information  and 

the  RBMPs/their  Annexes  are  observed.

32 

 
 
 
 
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.). 

33 

 
 
 
 
 
 
Surface waters 

RBD 

Surface 
drinking 
water 
abstraction 

Quality 
of 
drinking 
water 

Bathing 
water 

Birds 
sites 

Fish 

Habitats 
sites 

Nitrates 

Shell- 
Fish 

UWWT 

GR01 

GR02 

GR03 

GR04 

GR05 

GR06 

GR07 

GR08 

GR09 

GR10 

GR11 

GR12 

GR13 

GR14 

Total 

1* 

3* 

0 

7* 
0 

1 

3 

0* 
1* 

0 

0 

1* 

-0 

0 

17 

0 

0 

0 

 0* 
0 

0 

0 

 0* 
1* 

0 

0 

0 

0 

0 

1 

6* 

5* 

4* 

3* 
0 

8 

8 

5* 
0 

0 

1* 

3* 

0 

0 

43 

1* 

10* 

4* 

28* 
0 

3 

23 

35* 
14 

16* 

4* 

26* 

0 

0 

164 

4* 

4* 

3* 

6* 
0 

0 

0 

0* 
2* 

0 

1* 

1* 

0 

0 

21 

13* 

13* 

6* 

25* 
0 

6 

34 

12* 
15* 

11* 

6* 

17* 

0 

0 

158 

0 

0 

0 

0* 
0 

0 

15 

58* 
16* 

27* 

26* 

21* 

-1 

0 

164 

0 

0 

0 

0* 
0 

0 

0 

0* 
0 

4 

1 

3 

0 

0 

8 

Table 5.3.1: Number of monitoring stations in protected areas13. 
Source: WISE 
*corrections/additions provided by EL in late 2014 

Ground-
water 
drinking 
water 

9* 

12* 

17* 

4* 

20 

13* 

69* 

12* 

9* 

3* 

51* 

79* 

0 

0 

0 

0 

0 

61* 
0 

2 

5 

64* 
5* 

4* 

6* 

12* 

1 

0 

160 

298 

13   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 

34 

 
 
                                                            
OVERVIEW OF STATUS (ECOLOGICAL, CHEMICAL, GROUNDWATER) 

The  ecological  status  of  natural  surface  water  bodies  presented  in  the  RBMPs  shows  that 
49 %  are  in  high  or  good  status  (8%  and  41%  respectively).  Another  16%  are  in  moderate 
status,  9%  in  poor  and  bad  status  (8%  and  1%  respectively)  while  27%  remain  unknown. 
GR04 presents the lowest percentage of surface water bodies with unknown status (2%) while 
GR13 the highest (55%). Variations are observed across the RBDs (see Table 6.1): GR04 and 
GR05  have  the  highest  percentage  of  water  bodies  in  high  and  good  status  (84%  of  their 
surface water bodies), while GR08 and GR09 has the highest percentage of water bodies in 
poor  and  bad  status  (40%  and  25%  respectively).  With  regard  to  the  ecological  potential  of 
artificial and heavily modified water bodies (see Table 6.2), 6% across the RBDs are in good 
status,  22%  in  moderate,  22%  in  poor,  2%  in  bad  and  48%  in  unknown  status.  In 
GR01/02/03/10/13/14  more  than  60%  are  in  unknown  status  (in  GR14  it  reaches  92%).  It 
should  be  taken  into  consideration  that  in  these  classifications,  not  all  relevant  quality 
elements  have  necessarily  been  evaluated  or  considered,  and  that  the  available  data  were 
limited in many cases. As such the confidence in the classification is not high.  

RBD 

Total 

GR01 

GR02 

GR03 

GR04 

GR05 

GR06 

GR07 

GR08 

GR09 

GR10 

GR11 

GR12 

GR13 

GR14 

109 

88 

89 

101* 

90 

25 

96 

70* 

128* 

108 

66 

166 

130 

158 

9 

13 

10 

3* 

10 

2 

12 

5* 

3 

7 

0 

4 

20 

14 

Total 

1424 

112 

High 

Good 

Moderate 

Poor 

Bad 

Unknown 

No. 

(%)  No. 

(%)  No. 

(%)  No. 

(%)  No. 

(%)  No. 

8% 

15% 

11% 

51 

27 

20 

47% 

31% 

22% 

10 

8 

23 

9% 

9% 

26% 

4 

5 

6 

4% 

6% 

7% 

0 

0 

0 

0% 

0% 

0% 

3%* 

82*  81%*  13*  13%* 

1* 

1%* 

0* 

0%* 

11% 

66*  73%* 

10 

8% 

13% 

6 

38 

24% 

40% 

7 

17 

11% 

28% 

18% 

0 

4 

7 

0% 

16% 

7% 

0 

1 

3 

0% 

4% 

3% 

7%* 

11*  16%*  19*  27%*  28*  40%* 

0* 

0%* 

37%* 

20 

16% 

27*  21%* 

47 

38 

13 

81 

26 

74 

2% 

6% 

0% 

2% 

15% 

9% 

8% 

35% 

20% 

49% 

20% 

47% 

7 

31 

45 

15 

2 

6% 

47% 

27% 

12% 

1% 

20 

3 

11 

2 

0 

5 

1 

0 

0 

0 

0 

4% 

1% 

0% 

0% 

0% 

0% 

19% 

5% 

7% 

2% 

0% 

8% 

(%) 

32% 

40% 

34% 

2%* 

5%* 

20% 

20% 

10%* 

20%* 

32% 

29% 

15% 

55% 

43% 

35 

35 

30 

2* 

4* 

5 

19 

7* 

26 

35 

19 

25 

71 

68 

580 

41% 

227 

16% 

118 

10 

1% 

381 

27% 

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

35 

 
 
 
 
 
RBD 

Total 

High 

Good 

Moderate 

Poor 

Bad 

Unknown 

No. 

(%)  No. 

(%)  No. 

19 

9 

11 

0 

0 

0 

0% 

0% 

0% 

1 

0 

0 

5% 

0% 

0% 

3 

2 

4 

(%) 

16% 

22% 

36% 

No. 

(%)  No. 

(%)  No. 

3 

0 

0 

16% 

0% 

0% 

0 

0 

0 

0% 

0% 

0% 

12 

7 

7 

(%) 

63% 

78% 

64% 

19* 

0* 

0%* 

7* 

37%* 

2* 

11%* 

0* 

0%* 

0* 

0%* 

10* 

52%* 

16 

4 

8 

12* 

40* 

16 

32 

45 

18 

12 

261 

0 

0 

0 

0% 

0% 

0% 

3 

0 

0 

19% 

0% 

0% 

4 

1 

4 

25% 

25% 

50% 

1 

2 

2 

6% 

50% 

25% 

0 

0 

2 

0% 

0% 

25% 

0* 

0%* 

2* 

17%* 

2* 

17%* 

3* 

25%* 

0* 

0%* 

0 

0 

0 

0 

0 

0 

0 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0 

0 

0 

1 

2 

0 

16 

0% 

0% 

0% 

2% 

11% 

0% 

6% 

1 

1 

12 

19 

2 

1 

2% 

6% 

38% 

42% 

11% 

8% 

13* 

33%* 

4 

12 

18 

0 

0 

25% 

38% 

40% 

0% 

0% 

58 

22% 

58 

22% 

3 

0 

0 

0 

0 

0 

5 

7% 

0% 

0% 

0% 

0% 

0% 

2% 

8 

1 

0 

5* 

23 

11 

8 

7 

14 

11 

124 

50% 

25% 

0% 

41%* 

52% 

69% 

25% 

16% 

78% 

92% 

48% 

GR01 

GR02 

GR03 

GR04 

GR05 

GR06 

GR07 

GR08 

GR09 

GR10 

GR11 

GR12 

GR13 

GR14 

Total 

Table 6.2: Ecological potential of artificial and heavily modified water bodies. 
Source: WISE; *corrections/additions provided by EL in late 2014 

The chemical status of natural surface water bodies presented in the RBMPs shows that 23% 
are  good  status,  6%  in  poor  status,  while  71%  remain  unknown.  GR04  presents  the  lowest 
percentage  of  water  bodies  with  unknown  status  (yet  it  reached  29%)  while  GR13/14  the 
highest (99%). Variations are observed across the RBDs (see Table 6.3): among the classified 
surface water bodies GR04 has the highest percentage of water bodies in good status (71% of 
its surface water bodies). With regard to the chemical status of artificial and heavily modified 
water bodies (see Table 6.4), 11% across the RBDs are in good status, 24% in poor, and 65% 
in unknown status.  It should be taken into consideration that in these classifications not all 
relevant quality elements have necessarily been evaluated or considered (refer to section 9), 
and that the available data were limited in many cases. 

36 

 
 
 
 
 
RBD 

Total 

GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 
GR13 
GR14 
Total 

109 
88 
89 
101* 
90 
25 
96 
70* 
128* 
108 
66 
166 
134 
158 
1428 

Good 

Poor 

Unknown 

No. 

10 
5 
6 
72* 
54 
6 
34 
25* 
50* 
43 
8 
4 
3 
2 
322 

% 

No. 

% 

9% 
6% 
7% 
71%* 
60% 
24% 
35% 
36%* 
39%* 
40% 
12% 
2% 
2% 
1% 
23% 

5 
3 
18 
0* 
0 
0 
2 
5* 
9 
12 
9 
22 
0 
0 
85 

5% 
3% 
20% 
0%* 
0% 
0% 
2% 
7%* 
7% 
11% 
14% 
13% 
0% 
0% 
6% 

No. 

94 
80 
65 
29* 
36 
19 
60 
40* 
69* 
53 
49 
140 
131 
156 
1021 

% 

86% 
91% 
73% 
29%* 
40% 
76% 
63% 
57%* 
54%* 
49% 
74% 
84% 
98% 
99% 
71% 

Table 6.3: Chemical status of natural surface water bodies. 
Source: WISE 
*corrections/additions provided by EL in late 2014 

RBD 

Total 

Good 

Poor 

Unknown 

No.  % 

No.  % 

No.  % 

GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 
GR13 
GR14 

Total 

19 
9 
11 
19* 
16 
4 
8 
12* 
40* 
16 
32 
45 
18 
12 
261 

5 
1 
0 
9* 
8 
1 
1 
3* 
0* 
0 
2 
0 
0 
0 
30 

26% 
11% 
0% 
47%* 
50% 
25% 
13% 
25%* 
0%* 
0% 
6% 
0% 
0% 
0% 
11% 

2 
0 
4 
4* 
1 
0 
1 
2* 
12 
4 
12 
20 
0 
0 
62 

12 
11% 
8 
0% 
7 
36% 
6* 
21%* 
7 
6% 
3 
0% 
6 
13% 
17%* 
7* 
30%*  28* 
12 
25% 
18 
38% 
25 
44% 
0% 
18 
0% 
12 
24%  169 

63% 
89% 
64% 
32%* 
44% 
75% 
75% 
58%* 
70% 
75% 
56% 
56% 
100% 
100% 
65% 

Table 6.4: Chemical status of artificial and heavily modified surface water bodies. 
Source: WISE,  
*corrections/additions provided by EL in late 2014 

The chemical status of groundwater bodies presented in the RBMPs shows that 83 % are in 
good  status,  17%  in  poor,  while  none  remain  unknown.  Variations  are  observed  across  the 
RBDs (see Table 6.5): GR05 has the highest percentage of water bodies in good status (96.2% 
of  its  groundwater  bodies),  while  GR06  has  the  highest  percentage  of  water  bodies  in  poor 
status (45.8% of its groundwater bodies).  

37 

 
 
With regard to the quantitative status of the groundwater bodies, 82 % are in good status, 18% 
in  poor,  while  none  remain  unknown.  Variations  are  observed  across  the  RBDs  (see  Table 
6.6):  GR12  has  the  highest  percentage  of  water  bodies  in  good  status  (100%  of  its 
groundwater  bodies),  while  GR06  has  the  highest  percentage  of  water  bodies  in  poor  status 
(37.5%  of  its  groundwater  bodies).  It  should  be  taken  into  consideration  that  in  these 
classifications the available data were limited in many cases. 

GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 
GR13 
GR14 

RBD 

Total 

Good 

Poor 

No. 
24 
22 
17* 
24* 
25 
13 
40 
28* 
58 
31 
14 
14 
82 
81 
473 

% 
92.3% 
84.6% 
63%* 
96%* 
96.2% 
54.2% 
87% 
87,5%* 
93.5% 
79.5% 
93.3% 
77.8% 
90.1 
71.7 

83% 

No. 
2 
4 
10* 
1* 
1 
11 
6 
4* 
4 
8 
1 
4 
9 
32 
97 

% 
7.7% 
15.4% 
37%* 
4%* 
3.8% 
45.8% 
13% 
12,5%* 
6.5% 
20.5% 
6.7% 
22.2% 
9.9 
28.3 

17% 

Unknown 
% 
No. 
0% 
0 
0% 
0 
0% 
0 
0% 
0** 
0% 
0 
0% 
0 
0% 
0 
0%* 
0* 
0% 
0 
0% 
0 
0% 
0 
0% 
0 
0 
0 
0 
0 

0 

Table 6.5: Chemical status of groundwater bodies. 
Source: WISE 
*corrections/additions provided by EL in late 2014 

RBD 

Good 

Poor 

GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 
GR13 
GR14 

No. 
24 
24 
22 
23* 
25 
15 
41 
22* 
48 
28 
14 
18 
81 
80 

% 
92.3% 
92.3% 
81.5% 
92%* 
96.2% 
62.5% 
89.1% 
68.8%* 
77.4% 
71.8% 
93.3% 
100% 
89 
70.8 

Total 

465 

82% 

% 
No. 
7.7% 
2 
7.7% 
2 
18.5% 
5 
8%* 
2* 
3.8% 
1 
37.5% 
9 
10.9% 
5 
10*  31.2%* 
22.6% 
14 
28.2% 
11 
6.7% 
1 
0 
0 
11 
10 
33 
29.2 
105 

18% 

Table 6.6: Quantitative status of groundwater bodies. 
Source: WISE 
*corrections/additions provided by EL in late 2014 

38 

Unknown 
% 
No. 
0% 
0 
0% 
0 
0% 
0 
0%* 
0* 
0% 
0 
0% 
0 
0% 
0 
0%* 
0* 
0% 
0 
0% 
0 
0% 
0 
0% 
0 
0 
0 
0 
0 

0  0 

 
 
  
 
 
A total of 333 surface water bodies (i.e. 19.2%) are expected to achieve good or better global 
status  by  2015.  The  most  significant  increase  is  observed  in  GR03  (25%  increase  between 
2009  and  2015).  25%  of  the  surface  water  bodies  are  applying  exemptions  according  to 
Article  4.4.  No  exemptions  according  to  Art.  4.5  are  applied,  based  on  the  information 
provided by EL in late 2014. 

39 

 
 
 
 
Global status (ecological and chemical) 

RBD 

Total 

Good or 
better 2009 

Good or 
better 2015 

GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 
GR13 
GR14 

Total 

No.  % 
3.1 
4 
2.1 
2 
2 
2 
59* 
71* 
49.1 
52 
6.9 
2 
26 
27 
6* 
5* 
26.8 
45 
29 
36 
5.1 
5 
1.9 
4 
-0.7 
-1 
-1.2 
-2 
19%
2552
15.3 
58 

No.  % 
15.6 
20 
5.2 
5 
27 
27 
59* 
71* 
49.1 
52 
10.3 
3 
26 
27 
6* 
5* 
29.8 
50 
47* 
58* 
 8.2* 
 8* 
1.9 
4 
-0.7 
-1 
-1.2 
-2 
24%
3303
19.7 
33 

128 
97 
100 
120* 
106 
29 
104 
82* 
168 
124 
98 
211 
152 
170 
13671
689 

Increase 
2009 -
2015 
% 
12.5 
3.1 
25 
0* 
0 
3.4 
0 
0* 
3 
18* 
0 
0 
0 
-0 

5%4.4 

Good Global 
status 2021 

Good Global 
status 2027 

% 
100  
99  
100 
97* 
99* 
58* 
59* 
98* 

No. 
128 
95 
 100 
88* 
67* 
10* 
48* 
56* 

 - 
 - 

% 
100  
 98 
100 
73* 
63* 
34* 
46* 
68* 

No. 
128 
96 
 100 
116* 
105* 
17* 
62* 
80* 

-  
 - 

Global exemptions 2009 (% of 
all SWBs) 

Art 
4.4 

% 
4* 
4* 
33* 
15* 
14* 
48 
33 
62* 
14 
10 
 52* 
 40* 
-13 
-1.8 

Art 
4.5 

Art 
4.6 

% 
0 
0 
0 
0* 
0* 
0 
0 
0* 
0 
0 
0 
0 
-0 
-0 

% 
0* 
0* 
0* 
0* 
0* 

0* 

0 
0 

Art 
4.7 

% 
0* 
0* 
0* 
4* 
0.9* 

2* 
2* 

1 
 4.3* 
3.3 
0.6 

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 

40 

 
 
 
 
 
 
  
  
  
  
 
  
  
  
  
 
 
  
  
 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Good ecological 
status 2021 

Good 
ecological 
status 2027 

No. 

% 

No. 

13% 

109* 

100%* 

109* 

15% 

88* 

100%* 

88* 

89* 

92* 
86* 

100%* 

89* 

91%* 
96%* 

96* 
89* 

% 
100%
* 
100%
* 
100%
* 
95%* 
99%*  

61* 

87%* 

69* 

 99%* 

RBD 

Total 

Ecological status 

Good or better 
2009 

Good or better 
2015 

No. 

% 

No. 

% 

Increase 
2009 -
2015 
% 

GR01 

GR02 

GR03 

GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 

GR11 

GR12 

GR13 

GR14 

Total 

109 

88 

89 

101* 
90 
25 
96 
70* 
128* 
108 

66 

166 

60 

40 

30 

85* 
76* 
8 
50 
16* 
50 
45 

13 

85 

-134 

-46 

-158 
113614
28 

-88 
55869
2 

55% 

45% 

34% 

84%* 
84%* 
32% 
52% 
23%* 
39%* 
42% 

20% 

51% 

-
34.3% 

-56% 
49%4
8% 

74 

53 

59 
85* 
76* 
8 
50* 
16* 
92* 
65* 

68% 

60% 

66% 
84%* 
84%* 
32% 
52%* 
23%* 
72%* 
60%* 

 19* 

29%* 

 90* 

-45 

-88 
68782
0 

54%* 
-
33.6
% 
-56% 
60%5
7% 

32% 

0%* 
0% 
0% 
0%* 
0%* 
33%* 
18%* 

 9%* 

 3%* 

--0.7% 

-0 

11%9% 

Ecological exemptions (% of all 
SWBs) 

Art 
4.4 

% 

Art 
4.5 

% 

Art 
4.6 

% 

Art 4.7 

% 

 0%* 

0%* 

0%* 

0%* 

 2%* 

0%* 

0%* 

0%* 

 17%* 

0%* 

0%* 

0% * 

7%*  
11% 
48% 
28%* 
64%* 
6%* 
10% 

 41%* 

 27%* 

13% 

-1.8% 

5% * 
 1%* 

 1%* 
2% 
0.02%* 

2% 

 4%* 

-3.3% 

-0.6% 

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 

41 

 
 
  
  
  
  
 
 
 
 
  
  
  
 
 
 
 
  
  
  
  
  
 
 
 
  
  
  
 
 
 
  
  
  
 
 
 
 
 
  
  
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
 
 
 
 
 
 
Chemical status 

RBD 

Total 

Good or better 
2009 

Good or better 
2015 

GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 
GR13 
GR14 

Total 

No. 
10 
5 
6 
72* 
54 
6 
34 
25* 
50* 
43 
8 
4 
-3 
-2 
31732
2 

% 
9% 
6% 
7% 
71%* 
60% 
24% 
35% 
36%* 
40% 
40% 
12% 
2% 
-2% 
-1% 
28%2
3% 

No. 
15 
8 
24 
72* 
54 
6 
34 
25* 
51* 
48 
8 
4 
-3 
-2 
34935
4 

% 
14% 
9% 
27% 
71%* 
60% 
24% 
35% 
36%* 
40% 
44% 
12% 
2% 
-2% 
-1% 
31%2
5% 

109 
88 
89 
101* 
90 
25 
96 
70* 
128* 
108 
66 
166 
-134 
-158 
11361
428 

Increase 
2009 -
2015 
% 
5% 
3% 
20% 
0%* 
0% 
0% 
0% 
0%* 
0% 
4% 
0% 
0% 
-0% 
-0% 

3%2% 

Good chemical 
status 2021 

Good chemical 
status 2027 

No. 
109* 
88* 
89* 
79* 
54* 

% 
100%* 
100%* 
100%* 
78%* 
60%* 

No. 
109* 
88* 
89* 
97* 
89* 

% 
100%* 
100%* 
100%* 
96%* 
99% * 

30* 

43%* 

68* 

97%* 

Chemical exemptions (% of all 
SWBs) 

Art 4.4 

% 
 0%* 
 2%* 
 17%* 
5%* 
 0%* 

2% 
 7%* 
5%* 
9%* 
14% 
13% 
-0 
-0 

Art 
4.5 

% 
0%* 
0%* 
0%* 

Art 
4.6 

% 
0%* 
0%* 
0%* 

Art 
4.7 

% 
0%* 
0%* 
0% * 
4% * 
1%* 

3% * 

0 
0 

0 
0 

0 
0 

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 

42 

 
 
 
  
  
  
  
 
 
 
 
  
  
  
  
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
  
  
  
  
 
 
 
  
  
  
  
 
 
 
 
 
 
 
 
  
  
  
  
 
 
 
 
 
 
GW chemical status 

RBD 

Total 

Good or better 
2009 

Good or better 
2015 

GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 
GR13 
GR14 

Total 

No. 
24 
22 
17* 
24* 
25 
13 
40 
28* 
58 
31 
14 
14 
-82 
-81 
31047
3 

% 
92.3 
84.6 
63* 
96* 
96.2 
54.2 
87 
87.5* 
93.5 
79.5 
93.3 
77.8 
-90 
-72 
85%8
3% 

No. 
24 
22 
17* 
24* 
26 
13 
40 
28* 
58 
31 
14 
14 
-82 
-81 
31147
4 

% 
92.3 
84.6 
63* 
96* 
100 
54.2 
87 
87.5* 
93.5 
79.5 
93.3 
77.8 
-90 
-72 
85%8
3% 

26 
26 
27 
25* 
26 
24 
46 
32* 
62 
39 
15 
18 
-91 
-113 
36657
0 

Increase 
2009 -
2015 
% 
0 
0 
0 
0* 
3.8 
0 
0 
0* 
0 
0 
0 
0 
- 
- 

0.3%0.2% 

Good chemical 
status 2021 

Good chemical 
status 2027 

No. 
24* 
22* 
17* 
24* 
 25 

% 
92.3* 
84.6* 
63* 
 96* 
 96 

28* 

87.5* 

No. 
26 
26 
27 

24 
46 
28* 

% 
 100% 
 100% 
 100% 

100% 
100% 
87.5* 

 14 
 14 

 93 
 78 

15 
17  

 100 
94  

GW chemical exemptions (% of 
all GWBs) 

Art 
4.6 

% 

Art 
4.7 

% 

0%*  
 0%* 

0%*  
 0%* 

0%*  

0% * 

3% 

Art 4.4 

% 
7.7%* 
15.4%* 
37%* 
4%* 
4% 
46% 
13% 
12.5* 
6% 
18% 
7% 
28% 
-10% 
-28% 

Art 
4.5 

% 
0%* 
0%* 
0%* 
0%* 
0% 
0% 
0% 
- 
0% 
0% 
0% 
0% 
-0 
-0 

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 

43 

 
 
 
  
  
  
  
  
  
  
  
  
  
 
 
  
  
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
 
 
 
 
 
 
Groundwater quantitative status 

RBD 

Total 

Good or better 
2009 

Good or better 
2015 

GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 

GR08 

GR09 
GR10 
GR11 
GR12 
GR13 
GR14 

Total 

No. 
24 
24 
22 
23* 
25 
15 
41 

22* 

48 
28 
14 
18 
-81 
-80 
30446
5 

% 
92.3 
92.3 
81.5 
92* 
96.2 
62.5 
89.1 
68.87
* 
77.4 
71.8 
93.3 
100 
-89 
-71 
83.18
2 

No. 
24 
24 
22 
23* 
25 
15 
41 

22* 

48 
28 
14 
18 
-81 
-80 
30446
5 

26 
26 
27 
25* 
26 
24 
46 

32* 

62 
39 
15 
18 
-91 
-113 
36657
0 

Good 
quantitative 
status 2021 

Good 
quantitative 
status 2027 

No. 
24* 
24* 
22* 

 25 
19* 

% 
92.3* 
 92.3* 
 81.5* 

79* 

No. 
26 
26 
27 
25* 
26* 
24 
46 

32* 

% 
 100% 
 100% 
 100% 
100%* 
100%* 
100% 
100% 

GW quantitative exemptions (% 
of all GWBs) 

Art 4.4 

% 
7.7%* 
11.5%* 
33.3%* 
8%* 
4% 
38% 
11% 

Art 
4.5 

% 
0% 
0%* 
0% 
0%* 
0% 
0% 
0% 

Art 
4.6 

% 

Art 
4.7 

% 

0%* 
0%*  

0%* 
0%*  

100%* 

31%* 

0%* 

0%* 

0%* 

 14 

 93 

15  

 100 

- 
- 

- 
- 

- 
- 

- 
- 

23% 
28% 
7% 
0% 
-11% 
-29% 

0% 
0% 
0% 
0% 
-0 
-0 

5% 

Increase 
2009 -
2015 
% 
0 
0 
0 
0* 
0 
0 
0 

% 
92.3 
92.3 
81.5 
92* 
96.2 
62.5 
89.1 

68.87* 

0* 

77.4 
71.8 
93.3 
100 
-89 
-71 

83.182 

0 
0 
0 
0 
-0 
-0 

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 

44 

 
 
  
  
  
  
  
  
 
 
  
  
  
 
 
  
  
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
  
  
  
 
 
 
 
  
  
  
  
 
 
 
 
 
 
RBD 

Total 
HMWB 
and 
AWB 

Ecological potential 

Good or better 
2009 

Good or better 
2015 

GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 
GR13 
GR14 

19 
9 
11 
19* 
16 
4 
8 
12* 
40* 
16 
32 
45 
-18 
 -12 

No. 
1 
0 
0 
7* 
3 
0 
0 
2* 
0* 
0 
0 
1 
-2 
-0 

% 
5% 
0% 
0% 
37%* 
19% 
0% 
0% 
17%* 
0%* 
0% 
0% 
2% 
-11% 
-0 

No. 
7 
2 
4 
7* 
3 
1 
0 
2* 
5* 
0 
0 
1 
-1 
-0 

Total 

231261 

1416 

6% 

3233 

% 
37% 
22% 
36% 
37%* 
19% 
25% 
0% 
17%* 
12%* 
0% 
0% 
2% 
-5.6% 
-0 
14%13
% 

Increase 
2009 -
2015 
% 
32% 
22% 
36% 
0%* 
0% 
25% 
0% 
0%* 
12%* 
0% 
0% 
0% 
--5.6% 
-0 

8%7% 

Good ecological 
potential 2021 

Good 
ecological 
potential 2027 

No. 
19* 
7* 
11* 
9* 
8* 

% 
100%* 
78%* 
100%* 
47%* 
50%* 

No. 
19* 
8* 
11* 
19* 
16* 

% 
100%* 
89%* 
100%* 
100%* 
100%* 

7* 

58%* 

12* 

100* 

Ecological exemptions (% of all 
HMWB/AWB) 

Art 4.4 

% 
16%*  
22%* 
 55%* 
10%* 
31%* 
50% 
100% 
42%* 
30%* 
31%* 
75% 
80% 
- 
 - 

Art 
4.5 

% 
0%* 
0%* 
0%* 
- 

Art 
4.6 

% 
0% * 
0% * 
0% * 

Art 
4.7 

% 
0% * 
0% * 
0% * 
- 

- 

- 
 - 

- 

2% 
- 
 -  

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 

45 

 
 
 
 
  
  
 
 
 
 
  
  
  
 
 
 
 
  
  
  
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
 
 
 
  
  
  
  
 
 
 
  
  
  
 
 
 
 
 
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
RBD 

Total 
HMWB 
and 
AWB 

Chemical status 

Good or better 
2009 

Good or better 
2015 

GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 
GR13 
GR14 

Total 

19 
9 
11 
19* 
16 
4 
8 
12* 
40* 
16 
32 
45 
-18 
12 
261 

No. 
5 
1 

9* 
8 
1 
1 
3* 
0* 

2 

-0 
-0 
30 

% 
26% 
11% 
0% 
47%* 
50% 
25% 
13% 
25%* 
0%* 
0% 
6% 
0% 
-0 
-0 
11% 

No. 
7 
1 
4 
9* 
8 
1 
1 
3* 
1* 
0 
2 
0 
-0 
-0 
37 

% 
37% 
11% 
36% 
47%* 
50% 
25% 
13% 
25%* 
3%* 
0% 
6% 
0% 
-0 
-0 
14% 

Increase 
2009 -
2015 
% 
11% 
0% 
36% 
0%* 
0% 
0% 
0% 
0%* 
3%* 
0% 
0% 
0% 
-0 
-0 
3% 

Good chemical 
status 2021 

Good chemical 
status 2027 

No. 
19* 
7* 
11* 

% 
100%* 
78%* 
100%* 

No. 
19* 
8* 
11* 

% 
100%* 
89%* 
100%* 

Chemical exemptions (% of all 
HMWB/AWB) 

Art 4.4 

% 
16%*  
22%* 
 55%* 
21%* 
6% 

13% 
 17%* 
27%* 
25% 
38% 
44% 
-0 
0 

Art 
4.5 

% 
0%* 
0%* 
0%* 
0%* 
0%* 

Art 
4.6 

% 
0%*  
0%* 
0%* 
0%* 
0%* 

Art 
4.7 

% 
0%* 
0%* 
0%* 
0%* 
0%* 

0%* 

0%* 

0%* 

0 
0 

0 
0 

0 
0 

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 

46 

 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
  
 
 
 
 
 
 
  
 
 
 
  
 
 
 
  
 
 
 
 
 
 
 
  
  
  
  
 
 
 
 
 
 
 
 
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 

47 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

48 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
49 

 
 
 
 
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 

50 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
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.  

51 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

52 

 
 
 
 
 
 
 
 
 
 
 
 
 
  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 

53 

 
 
 
 
 
 
 
 
 
 
 
  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 

54 

 
 
 
 
 
 
 
 
 
ASSESSMENT OF ECOLOGICAL STATUS OF SURFACE WATERS 

It  seems  that  the  different  projects  commissioned  for  the  development  of  the  different 
RBMPs  were  centrally  coordinated  by  the  Special  Secretarial  for  Water;  thus,  generally  a 
national approach is followed. At the same time, for GR01/02/03 the actual classification was 
done (partly) based on a specific sampling study. For the different RBMPs the information is 
provided in a very different way, so it remains unclear if a national approach is transparently 
used  for  all  RBDs  (it  is  also  unclear  due  to  the  lack  of  national  published  guidance  on 
different  issues,  although  EL  has  stated  that  internal  guidelines  have  been  provided  to  the 
different  consultants).  Out  of  the  14  RBMPs  that  should  have  been  approved  by  2009,  12 
RBMPs  were  approved  by  late  2014  and  2  RBMPs  by  late  2015.  The  12  RBMPs  (that 
become  official  in  2014)  should  implement  the  Programmes  of  Measures  in  the  following 
very  short  period  as  the  second  round  of  revised  Plans  should  be  submitted  by  2015, 
according to the WFD, taking into account the implementation of the first RBMPs, while this 
is even more challenging (even not feasible) for the other 2. A PoM-Implementation Progress 
Report  (national  level)  has  been  submitted  by  EL  to  the  Commission  as  a  reply  to  an  EU 
enquiry in December 2014, and was uploaded on WISE on 22.01.2015.  

Ecological status assessment methods 

The assessment methods for the classification of ecological status are only partly developed 
for  some  BQEs  and  are  explicitly  described  in  the  Annexes  A/6,  Annex  I  (Reference 
conditions  of  SWBs)  and  in  the  RBMPs  For  rivers  only  the  benthic  fauna  was  used;  it  is 
stated that "in agreement with the managing authority, for the classification of rivers in the 
current RBMPs cycle it was decided to rely only on the biological quality element (BQE) of 
benthic  macroinvertebrates”.  Accordingly,  phytoplankton  is  the  only  BQE  that  is  able  to 
produce reliable assessment methods of the ecological status in lakes. For most of the BQEs 
specified  in  the  WFD,  national  methods  for  assessing  ecological  status  have  not  been 
developed. This is due to the insufficiency of available data to describe reference conditions, 
due to the lack of development of indicators for the parameters estimation for each BQE, or 
due  to  inadequate  experience  and  knowledge  on  the  biology  of  specific  BQEs  to  link  the 
status  of  the  habitats  with  the  condition  of  the  water  bodies.  There  are  therefore  important 
gaps in the assessment system. 

The overall approach of classification according to the WFD is described, and was principally 
based on the One-Out-All-Out  principle. It is clearly mentioned that “for water bodies where 
there are  measurements of priority substances, the One-Out-All-Out principle was followed 
among the qualitative data, regardless of the number of parameters for which data have been 
available;  that  is,  if  a  priority  substance  exceeded  the  boundaries  set,  the  water  body  was 
classified in a lower than good status”. Similarly, in cases where, based on the available data, 
the BQEs resulted a good status but physicochemical parameters failed, the ecological status 
has  been  classified  as  moderate.  In  cases  where  correlation  in  the  monitoring  data  was  not 
evident, at the time and the position of the sampling for physicochemical parameters, and the 
BQEs exhibited discrepancies, the physicochemical data were not used for the classification 
of the water bodies (mainly in the RBDs GR06/GR07/GR13/GR14).  At the same time, and 
based  on  the  way  the  classification  was  done,  it  is  not  possible  to  say  if  this  principle  was 
followed in practice. 

It  is  highly  questionable  whether  the  classification  system  is  responsive  to  all  pressures  as 
relevant information is insufficient. In some RBMPs there is a brief mention of the different 

55 

 
 
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 
for 
programmes,  a  process  of  grouping  of 
GR04/05/08/09/10/13/14 in relation to the different pressures. The main idea of grouping is 
that  water  bodies  of  the  same  type  which  are  subject  to  similar  levels  of  anthropogenic 
pressures  are  likely  to  have  the  same  ecological  quality.  The  purpose  was  to  minimise  the 
number of water bodies that would be characterised as of unknown ecological status. As this 
approach is indirect, this type of assessment has a low level of confidence. 

the  water  bodies  was 

followed 

In general, it is mentioned that the classification of water bodies in terms of physico-chemical 
QEs  was  supplementary  to  the  assessment  of  the  BQEs  (respecting  the  One-Out-All-Out 
(OOAO) principle); that is these QEs are used to assist in determining the ecological status of 
surface  water  bodies.  The  elements  that  are  assessed  include  the  transparency,  thermal 
conditions, oxygen conditions, salinity, acidification conditions and nutrient conditions. For 
the  RBMPs  of  GR01/02/03,  regarding  the  classification,  there  was  very  limited  monitoring 
information  available.  One  specification  regarding  the  way  the  physico-chemical  QEs  were 
dealt with in practice is the sampling study used for some water bodies. The study collected 
samples and measurements concerning the biodiversity and carrying capacity of rivers such 
as for macroinvertebrates. In this case, the physico-chemical parameters were determined in 
situ with a portable multi-parameter instrument. For the RBMPs of GR06/07/GR13/GR14 it 
is  clearly  stated  that  physico-chemcial  QEs  were  not  used  for  the  classification  of  the 
ecological  status  for  surface  water  bodies.  For  the  RBMPs  of  GR04/05/08/09/10/11/12,  the 
assessment is conducted through measured data (limited years) of the General Chemical State 
Laboratory, the Ministry of Rural Development and Food, Universities, and the Decentralised 
Administrations, Water Directorates. These are then compared to the relevant environmental 
quality  standards  (EQS)  for  each  water  body  category.  When  the  value  of  the  parameters 
complies with standards, the water body is classified as in good status; in the opposite case 
the  water  body  is  classified  as  in  a  less  than  good  status.  The  values  refer  to  the  boundary 
between  good  and  moderate  status,  which  according  to  the  general  classification  scheme, 
determines the possibility of relegation measured by the BQEs of ecological status of a water 
body from good to moderate. 

relevant  Ministerial  Decision 
Theoretically,  EQSs  have  been  established.  The 
(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 

56 

 
 
provided on how the EQSs were established. Additionally, it is noted that only very limited 
monitoring information is available regarding these pollutants in the RBDs.  

The overall approach of classification according to the WFD is described, including the One-
Out-All-Out principle. It is implied on several occasions that the total ecological status of the 
water  system  is  determined  by  the  results  of  the  biological,  physico-chemical  and 
hydromorphological quality elements taking into account the worst category (i.e. the part of 
the  quality  most  affected  by  human  activity);  that  is  the  One-Out-All-Out  principle.  The 
hydromorphological data were taken into account only to rank the “high” status. At the same 
time,  and  based  on  the  way  the  classification  was  done,  it  is  not  possible  to  say  if  this 
principle was followed in practice. 

Based on the very limited information available for the classification of the surface water 
bodies and the common use of expert judgement, etc., the uncertainty is classified in three 
categories as follows: 

  Large Uncertainty: concerns water bodies in which there was no monitoring station;  

  Medium  Uncertainty  :  where  there  is  one  monitoring  station  (either  from  the  sampling 

study, or from the existing monitoring network); 

  Small  Uncertainty:  where  there  is  more  than  one  monitoring  station.  If  in  a  water  body 
several monitoring results exist and the assessments do not agree, then the uncertainty is 
characterised as medium.  

  Not defined uncertainty: where the situation remains unknown.  

Specifically, in the GR04/05/08/11/12, regardless of the parameter for which the analysis was 
conducted the level of uncertainty was considered: 

  Limited Uncertainty for the types with more than 7 samples;  

  Medium Uncertainty for the types that did not comply with the above condition; 

  High Uncertainty for the types with less than 4 samples or 4 stations; 

  Large  Uncertainty  in  cases  where  no  data  were  available  and  the  determination  of  the 

values was done through the expert judgment. 

There is no classification in terms of uncertainty for GR13/14.  

It  has  to  be  noted  that  regarding  the  main  data  gaps  and  uncertainties  relating  to  surface 
waters  there  are  delays  in  determining  the  physico-chemical  and  hydromorphological 
standards so it is not possible to set reference conditions and class boundaries between high, 
good condition, etc. 

All water body types are covered by a classification system. For most of the BQEs specified 
in the WFD, national methods for assessing ecological status for the case of Greece have not 
been  developed.  This  is  due  to  the  insufficiency  of  available  data  to  describe  reference 
conditions,  due  to  the  lack  of  development  of  indicators  for  the  parameters  estimation  for 
each BQE, or due to inadequate experience and knowledge on the biology of specific BQEs 
to link the status of the habitats with the condition of the water bodies. For GR05/09/10/11/12 
the transitional waters are assessed based on the criteria that are used for the coastal waters 
and for the coastal waters there is only one water body type for the whole country in order to 
avoid  increased  fragmentation.  This  is  not  the  case  for  GR13/14  as  it  is  clear  from  the 

57 

 
 
RBMPs  that  three  types  of  coastal  waters  (different  in  each  RBD)  have  been  identified  as 
well as with different methodological approaches.  

The intercalibration work is mentioned only in general. The class boundaries are in almost all 
cases not used for the actual classification of water bodies due to the lack of data. No data is 
available to cross-check the intercalibration decision with what is mentioned in the relevant 
Annexes. The boundaries used for the case of Greece for the respective types (R-M1, R-M2 
and RM-4), referred only to the biological quality element of benthic macroinvertebrates; the 
purpose  was  to  evaluate  which  is  the  common  Intercalibration  Common  Metrics  index 
(ICMi),  as  a  national  assessment  method  for  the  ecological  status  to  be  involved  in  the 
exercise was not fully developed. Additionally, Greece’s involvement in the intercalibration 
exercise  of  the  countries  of  the  Mediterranean  eco-region  was  fragmented.  As  a  result  any 
national methods that were developed in the context of individual pilot projects implementing 
the WFD cannot be matched with the methods developed by other countries. Consequently, 
there is a lack of commonly accepted values of reference conditions and class boundaries of 
the ecological status classification including national methods that have been used at times in 
other  Mediterranean  countries.  The  background  documents  that  have  been  reported  as 
Annexes  to  the  RBMPs  are  Annexes  A/6  (Reference  conditions  for  SWBs)  and  A/9 
(Classification of  SWBs)  (with the exception  of GR14 where  these  Annexes have  not  been 
reported)  In  terms  of  a  national  Guidance  Document,  guidelines  were  formulated  by  the 
coordinator consultant and the General Secretariat for Water to guide/harmonise the work and 
methodological approach of all other consultants who were commissioned with the drafting 
of the RBMPs, but these were not organised into a detailed guidance document. 

58 

 
 
 
Rivers 

Lakes 

Transitional 

Coastal 

RBD 

s
e
t
a
r
b
e
t
r
e
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B

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A

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s

m
r
e
p
s
o
i
g
n
A

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). 

- 

59 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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.  This  is  not  the 
case for GR13/14 where in certain types of surface water bodies the new monitoring program 
seems  to  have  been  used.  However,  this  information  is  not  clear  and  it  needs  clarification 
from the Greek authorities.14 

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.  

14 The Greek authorities clarified in March 2017 that in GR13 and GR14 results that were available from the 
National Monitoring Network (http://nmwn.ypeka.gr/), which is operational since mid-2012, were used for the 
assessment of the status of all water categories, in combination with other relevant data that were available (e.g. 
in local universities). 

60 

 
 
 
 
                                                            
RBD 

CAS Number 

Substance 

Percentage Water Bodies 
Failing Status (%) 

GR01 

GR02 

GR03 

GR04* 

GR05* 

GR08* 

GR09* 
GR10* 

GR11 

GR12 

GR13 

GR14 

Zinc (3 failing out of 128 SWBs) 
Molybdenum  (3  failing  out of  128 
SWBs) 
Sulfonic acid/LAS (4 failing out of 
128 SWBs) 
Zinc (1 failing out of 97 SWBs) 
Copper (1 failing out of 97 SWBs) 
Sulfonic acid/LAS (2 failing out of 
97 SWBs) 
Cyanide  (2  failing  out  of  97 
SWBs) 

Zinc (2 failing out of 100 SWBs) 
Sulfonic acid/LAS (1 failing out of 
100 SWBs) 
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)  
Molybdenum (16 WBs out of 106) 
Monolinuron  (ISO)  (1WBs  out  of 
106) 
Tin (1WBs out of 106) 
Monolinuron  (ISO)  (6WBs  out  of 
86) 
Methamidofhos(iso)  (6WBs  out  of 
86) 
Copper (1WBs out of 86) 
Zinc (1WBs out of 86) 
LAS (19 failing out of 150 SWBS) 
Selinum  -Sn  (2  failing  out  of  104 
SWBS) 
Molybdenum (1 WB out of 98)  
Zinc (1 WB out of 98)  
Sn (Tin) (16 WBS out of 211)  
Cu (Copper) (1 WB out of 211)  
Molybdenum (9 WB out of 211)  
As (Arsenic) (3 WBs out of 211)  
-chemical status has not been 
assessed 
chemical status has not been 
assessed - 

2.3 

2.3 

3.1 

1 
1 

2.1 

2.1 

2 

1 

1  
1  
7.6  
0.5  
4.3  
1.4  

5 

15 

14 

12,6 
1,9 

Table 7.3.1: River basin specific pollutants causing failure of status15 
Source: RBMPs (Template 12 (Chemical Measures), question 3) 
* corrections/additions provided by EL in late 2014 

15 According to the Greek authorities (March 2017), in RBD GR13 and GR14 specific pollutants and chemical 
status were assessed, but no exceedance of any pollutant was detected according to the data available. 

61 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                            
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) 

1.1  Designation of HMWBs 

Based on the information submitted by EL, 265 water bodies are designated as HMWB/AWB 
in  the  14  RBDs  (219  HMWBs  and  46  AWBs).  These  represent  approximately  16%  of  the 

62 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
reported  1689  surface  water  bodies.  There  are  some  differences  between  the  information 
submitted by EL, 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, 9/10,11/12 and 13/14. 

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 
GR4/5/8/11/12/13/14). 

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 

63 

 
 
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. 

64 

 
 
 
HMWB 
or 
AWB 

HMWB 

AWB 

RBD 

GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 
GR13 
GR14 
Total 
GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 

Rivers 

Number 

% of 
category 

Lakes 

Number 

Transitional water  Coastal water 

All water bodies 

% of 
category 

Number 

% of 
category 

Number 

% of 
category 

Number  % 

Water category 

15 
4 
9 
18* 
10* 
1 
3 
6* 
26 

2 

27 

34 

-14 

-4 

14 
6 
11 
12* 
13* 
7 
4 
8* 
17 

2 

30 

18 

-12 

-5 

2 
3 
1 
0* 
1* 
1 

1* 
8 

1 

2 

5 

-4 

-8 

155173 

1413 

2537 

2 
0 
1 
0* 
3 
0 
5 
4* 
10 

10 

3 

5 

2 
0 
1 
0* 
3 
0 
6 
5* 
7 

10 

3 

3 

 0 
1 
 0 
0* 
 0 
 0 
 0 
0* 
0  

1 

 0 

 0 

100 
50 
100 
0* 
100 
100 
0 
100* 
57 

17 

100 

83 

-80 

-100 

5260 

0 
17 
0 
0* 
0 
0 
0 
0* 
0 

17 

0 

0 

0  
1 
 0 
1* 
2 
2 
 0 
1* 
0  

1 

 0 

1 

-0 

-0 

9 

 0 
 0 
 0 
0* 
 0 
 0 
 0 
0* 
 0 

1 

 0 

 0 

0 
5 
0 
11* 
15 
14 
0 
14* 
0 

9 

0 

8 

-0 

-0 

7 

0 
0 
0 
0* 
0 
0 
0 
0* 
0 

9 

0 

0 

17 
8 
10 
19* 
13 
4 
3 
8* 
34 

4 

29 

40 

18 

12 

219 

2 
1 
1 
0* 
3 
0 
5 
4* 
10 

12 

3 

5 

13% 
8% 
10% 
16% 
12% 
14% 
3% 
10% 
20% 

3% 

30% 

19% 

12% 

7% 

13 

2% 
1% 
1% 
0 
3% 
0% 
5% 
5 
6% 

10% 

3% 

2% 

0 
0 
0 
0* 
0 
0 
0 
0* 
0 

0 

0 

0 

-0 

-0 

0 

0 
0 
0 
0* 
0 
0 
0 
0* 
0 

0 

0 

0 

0 
0 
0 
0* 
0 
0 
0 
0* 
0 

0 

0 

0 

-0 

-0 

0 

0 
0 
0 
0* 
0 
0 
0 
0* 
0 

0 

0 

0 

65 

 
 
  
HMWB 
or 
AWB 

RBD 

GR13 
GR14 
Total 

Water category 

Rivers 

Number 

% of 
category 

Lakes 

Number 

Transitional water  Coastal water 

All water bodies 

% of 
category 

Number 

% of 
category 

Number 

% of 
category 

Number  % 

0 

-0 

43 

0 

0 

4 

0 

0 

2 

0 

0 

4 

0 

0 

0 

0 

0 

0 

0 

0 

1 

0 

0 

1 

0 

0 

46 

0 

0 

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.  

66 

 
 
1.2  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. 

1.3  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,  GR1/2/3/13/14  just  mention  GEP  as  the  objective  for 
HMWB/AWB, without any further specification.  

67 

 
 
ASSESSMENT OF CHEMICAL STATUS OF SURFACE WATERS 

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. No chemical assessment was implemented in GR13/14 due to lack of 
data.16 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.  

1
0
R
G

4 

2
0
R
G

1 

3
0
R
G

6 

5 

10 

Substance causing 
exceedance 

1 Heavy Metals - 
aggregated 
1.1 Cadmium 
1.2 Lead 
1.3 Mercury 
1.4 Nickel 
2 Pesticides – aggregated 
2.5 Diuron 
2.5 Isopruton 
3 Industrial Pollutants - 
aggregated 

Exceedances per RBD 

4
0
R
G

5
0
R
G

6
0
R
G

7
0
R
G

8
0
R
G

9
0
R
G

0
1
R
G

*
*
3
1
R
G

*
*
4
1
R
G

1
1
R
G

9 

2
1
R
G

42 

1* 

1* 

3* 

1 

3 

5* 

4* 
2* 

16 

11 

2 
3 

2 

14 

25 

1 

13 

10 

16 According to the Greek authorities (March 2017), in RBD GR13 and GR14 specific pollutants and chemical 
status were assessed, but no exceedance of any pollutant was detected according to the data available. 

68 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                            
Substance causing 
exceedance 

3.3 Brominated 
Diphenylether 
3.8 Di(2-
ethylhexyl)phthalate 
(DEHP) 
4 Other pollutants - 
aggregated 
4.9 Hexachlorobutadiene 
4.11 Polyaromatic 
hydrocarbons 
4.17 Tributyltin 
compounds 

Exceedances per RBD 

1
0
R
G

2
0
R
G

3
0
R
G

4
0
R
G

5
0
R
G

1 

6
0
R
G

7
0
R
G

8
0
R
G

1* 

9
0
R
G

0
1
R
G

1
1
R
G

2
1
R
G

*
*
3
1
R
G

*
*
4
1
R
G

7 

3 

11 

1 

2 

1 

3 

2 

15 

4 

3* 

1 

3 

4* 

Table 9.1.1: Substances responsible for exceedances 
Source: WISE  
*corrections/additions provided by EL in late 2014. 

** No chemical assessment was implemented in GR13/14 due to lack of data. 

69 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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)  (570  in  total)  have  been  assessed  for  both  chemical  and 
quantitative  status.  There  are  17%  of  GWBs  in  poor  chemical  status  and  18%  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 

GR02 

GR03 

GR04 

GR05 

GR06 

GR07 

GR08 

GR09 

GR10 

GR11 

GR12 

GR13 

GR14 

2 

4 

10* 

1* 

1 

11 

6 

4* 

4 

8 

1 

4 

-9 

-32 

2 

2 

5 

3* 

1 

9 

5 

10* 

14 

11 

1 

0 

10 

-33 

24 

22* 

17* 

23* 

25 

12 

38 

21* 

48 

26 

14 

14 

-80 

-80 

Total 

5697 

63103 

284444 

Table 10.1: Number of groundwater bodies and their status. 
Source: WISE 
*corrections/additions provided by EL in late 2014 

Quantitative status 

In  the  14  RBDsof  EL,  approximately  82%  of  groundwater  bodies  are  in  good  quantitative 
status and 18% 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, while saline intrusion was reported as an additional 
reason for GR13 and as the main reason for GR14. 

For the assessment of the GW quantitative status the following criteria are mentioned to be 
considered in principle: 

1) Checking the water balance.  

70 

 
 
 
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. 

Groundwater chemical status 

In the 14 EL RBDs, approximately 83% of groundwater bodies are in good chemical status 
and 17% 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 

71 

 
 
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. 

Protected areas 

The status of groundwater drinking water protected areas is presented in Table 10.3.1 below. 
In total 135 groundwater drinking water protected areas are identified for the whole territory, 
of  which  96%  are  classified  in  good  status,  1%  failing  to  achieve  good  status  and  3%  in 
unknown status. 

72 

 
 
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).  

73 

 
 
 
 
RBD 

Good 

Failing to 
achieve good 

Unknown 

GR01 

GR02 

GR03 

GR04 

GR05 

GR06 

GR07 

GR08 

GR09 

GR10 

GR11 

GR12 

GR13 

GR14 

4 

5 

3 

4* 

8 

3 

10 

4* 

9 

3 

14 

18 

-44 

-0 

Total 

85129 

-  

-  

-2 

-0 

02 

- 

4 

- 

-0 

-0 

4 

Table 10.3.1: Status of groundwater drinking water protected areas 
Source: WISE 
*corrections/additions provided by EL in late 2014 

74 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
ENVIRONMENTAL OBJECTIVES AND EXEMPTIONS 

Based on the information submitted by EL in late 2014 as well as from the additional RBMPs 
(GR13/14) that were submitted in early 2016, Greece has set the objective to achieve good or 
better  status  in  333  surface  water  bodies  (19.7%)  by  2015,  with  a  4.4%  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  across  the  RBDs 
regarding the increase expected (from 0 to 18%) as well as regarding the number (and %) of 
water bodies in good status in 2015 (0.7 to 59% of the water bodies), even though the number 
and types of measures taken does not differ significantly among the RBDs. 

The  issue  ofRegarding  the  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  (81.6%)).  There  is  a  similar  situation  regarding  chemical  status  (Table  6.10), 
with  an increase of 0.2%  (from the already high percentage of groundwater bodies in  good 
chemical status (83%)). 

1.4  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. 

1.5  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 497 
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 (289 for SWBs) 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.  

75 

 
 
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 

GR01 

GR02 

GR03 

GR04 

GR05 

GR06 

GR07 

GR08 

GR09 

GR10 

GR11 

GR12 

GR13 

GR14 

Total 

Article 4(4) 

Article 4(5) 

R 

5* 

3* 

32* 

7* 

6* 

7 

28 

L 

0 

0 

0 

5* 

1 

0 

0 

50* 

1* 

17 

9 

46* 

74* 

-20 

-3 
3030
7 

5 

2 

2 

4 

-0 

-0 

20 

T 

0 

0 

0 

4* 

4 

0 

1* 

0* 

1 

1 

1 

5 

-0 

-0 

17 

C 

0 

1* 

1 

2* 

4 

7 

6 

GW 

2 

4* 

10 

2* 

1* 

12 

8 

R 

0 

0 

0 

0* 

0* 

0 

0 

L 

0 

0 

0 

T 

0 

0 

0 

C 

0 

0 

0 

0* 

0* 

0* 

0 

0 

0 

0 

0 

0 

0 

0 

0 

GW 

0 

0* 

0* 

0* 

0 

0 

0 

2* 

11* 

0* 

0* 

0* 

0* 

0* 

0 

1 

2 

2 

-0 

-0 

28 

14 

12 

1 

4 

-11 

-33 
8112
5 

0 

0 

0 

0 

-0 

-0 

0 

0 

0 

0 

0 

-0 

-0 

0 

0 

0 

0 

0 

-0 

-0 

0 

0 

0 

0 

0 

-0 

-0 

0 

0 

0 

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. 

76 

 
 
 
 
 
RBD 

Technical feasibility 

Global17 
Disproportionate 
costs 

Natural conditions 

GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 
GR13 
GR14 

Total 

Article 
4(4) 
2* 
3* 
21* 
18* 
15* 
14 
35* 
 53* 
17 
5 
51* 
85* 
- 20 
- 3 
2289 

Article 
4(5) 
0* 
0* 
0 
0 
0* 
0 
0 
0 
0 
0 
0 
0 
- 0 
- 0 
0 

Article 
4(4) 
3* 
1* 
12* 
0 
0 
0 
0 
0 
0 
8 
0 
0 
- 0 
- 0 
24 

Article 
4(5) 
0* 
0* 
0* 
0 
0 
0 
0 
0 
0 
0 
0 
0 
- 0 
- 0 
0 

Article 
4(4) 
0* 
0* 
0* 
0 
0 
0 
0 
0 
6 
0 
0 
0 
- 0 
- 0 
6 

Article 
4(5) 
0* 
0* 
0* 
0 
0 
0 
0 
0 
0 
0 
0 
0 
- 0 
- 0 
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 surface water bodies with Article 4(4) and 4(5) exemptions 
T = Technical feasibility, D = Disproportionate costs; N = Natural conditions 

17 Exemptions are combined for ecological and chemical status. Source: WISE, corrections provided by EL in 
late 2014 

77 

 
 
 
                                                            
1.6  Exemptions according to Article 4(6) 

No exemptions according to Art. 4.6 have been applied.  

1.7  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,GR11/12,  and  GR13/14).  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 9 RBDs (GR4/5/8/9/10/11/12/13/14), 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 

78 

 
 
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. 

79 

 
 
 
 
 
RBD 

GR01 
GR02 
GR03 
GR04 
GR05 
GR06 
GR07 
GR08 
GR09 
GR10 
GR11 
GR12 
GR13 
GR14 
Total 

Number of Water 
Bodies acc. to 
corrections provided by 
EL in late 2014  
0 
0 
0 
5 
1 
0 
0 
2 
3 
4 
1 
9 
- 
- 
25 

Number of 
Water Bodies 
acc. to WISE-
submission 
0 
0 
0 
0 
0 
0 
0 
0 
3 
1 
1 
5 
-5 
01 
116 

Number of Water 
Bodies acc. to the 
RBMPs/Annexes 

0 
0 
0 
11 
2 
0 
0 
4 
3 
4 
1 
9 
- 
- 
34 

Table 11.4.1 Number of WBs with Article 4(7) exemptions 
Source: WISE, corrections provided by EL in late 2014, RBMPs/Annexes. 

1.8  Exemptions to Groundwater Directive 

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

80 

 
 
 
 
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. 

1.9  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 GR11/12/13/14). 

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,GR11/12 and GR13/14): 

 

 

 

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. GR1/2/3/13/14) 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 

81 

 
 
 
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  GR01/2/3/13/14.  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.  GR01/2/3/9/10/13/14  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 with the exception of 
GR13/14. 

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 
the 
implementation  level  is  indicated  as  national,  RBD,  part  of  RBD  or  groundwater  body  for 
each measure). 

for  GR11/12/13/14 

level”  while  e.g. 

indicate  “national 

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).  For  GR13/14,  this  information  is  only  apparent  for 
basic  measures  (Group  A),  and  occasionally  it  is  mentioned  within  the  description  of  the 
measure for the rest of the measures listed.  

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. This was not done forGR13/14.18 

18 According to the Greek authorities (March 2017), cost-effectiveness analysis and prioritisation of all measures 
was done also for GR13/14 (to be reflected in the updated RBMPs). 

82 

 
 
                                                            
Some  information  regarding  costs  of  individual  measures  is  provided  (mostly  for 
supplementary  measures),  but  is  not  clearly  identified  for  all  measures.19  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. There is no information on costs for GR13/14.  

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//11/12/13/14, 
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. 

1.10  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. 

19 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. 

83 

 
 
                                                            
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.  

84 

 
 
Measures 

Technical measures 
Reduction/modification 
fertiliser application 
Reduction/modification 
pesticide application 
Change to low-input farming 

of 

of 

Hydromorphological measures 

Measures against soil erosion 

Multi-objective measures 

Water saving measures 

Economic instruments 

Compensation for land cover 

Co-operative agreements 

Water pricing 

Nutrient trading 

Fertiliser taxation 

1
0
R
G

 

 

 

2
0
R
G

 

 

 

3
0
R
G

 

 

 

 

 

 

 

 

 

Non-technical measures 
Implementation  and  enforcement 
of existing EU legislation 
Controls 

Institutional changes 

Codes of agricultural practice 

Advice and training 

Awareness raising 
Measures  to  increase  knowledge 
for improved decision-making 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

4
0
R
G

 

 

 

 

 

 

 

 

 

 

 

 

 

 

8
0
R
G

 

 

 

 

 

 

 

 

 

 

 

 

 

 

9
0
R
G

 

 

 

 

 

 

 

 

 

 

 

 

 

0
1
R
G

 

 

 

 

 

 

 

 

 

 

 

 

 

1
1
R
G

 

 

 

 

 

 

 

 

 

 

2
1
R
G

3
1
R
G

4
1
R
G

 

   

   

 

 

 

 

 

 

 

 

 

 

 

   

   

   

   

   

   

   

   

   

6
0
R
G

 

 

7
0
R
G

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

5
0
R
G

 

 

 

 

 

 

 

 

 

 

 

 

85 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1
0
R
G

2
0
R
G

3
0
R
G

4
0
R
G

5
0
R
G

6
0
R
G

7
0
R
G

8
0
R
G

9
0
R
G

0
1
R
G

1
1
R
G

2
1
R
G

3
1
R
G

4
1
R
G

Measures 

Certification schemes 

Zoning 
Specific 
plans/programmes 
Land use planning 

action 

Technical standards 
Specific  projects 
agriculture 
Environmental  permitting  and 
licensing 

related 

to 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

   

   

Table 12.2.1: Types of WFD measures addressing agricultural pressures, as described in the PoM 

Source: RBMPs 

86 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1.11  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. GR11/12/13/14), 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. 

87 

 
 
Measures 

Fish ladders 

Bypass channels 

Habitat  restoration,  building  spawning  and 
breeding areas 

1
0
R
G







2
0
R
G







3
0
R
G







4
0
R
G






5
0
R
G







*
6
0
R
G







7
0
R
G







Sediment/debris management 

 

 

 

Removal  of  structures:  weirs,  barriers,  bank 
reinforcement 

0
1
R
G





8
0
R
G









9
0
R
G









1
1
R
G





2
1
R
G





3
1
R
G





  

  

Reconnection of meander bends or side arms 













 

4
1
R
G



















Lowering of river banks 

Restoration of bank structure 









Setting 
requirements 

minimum 

ecological 

flow 

   

Operational modifications for hydropeaking 









Inundation of flood plains 

Construction of retention basins 

Reduction or modification of dredging 

Restoration of degraded bed structure 

Remeandering of formerly straightened water 
courses 
Other: Reduction/control/ban of sand/material 
extractions from river beds 
Other: research/study at the basin level on the 
impact  of  dams  on  fish  populations  and 
determining  best  methods 
to  overcome 
impacts 
Other:  Determination  of  selected  areas  for 
abstracting materials for engineering needs 



























































   

















  



 





















  

  



















      

   







  



   

   

88 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measures 

1
0
R
G

2
0
R
G

3
0
R
G

Other:  development  of  criteria  for  defining 
the limits of overall abstractions per WB 
Other: improving the water supply to one lake 
through reconnection to 2 springs 

Other: various (investigative) studies 

Other:  Investigation  of  potential  artificial 
wetlands sites. 
Other:  Studies  regarding  sediment  transport 
of the Strimonas river 
Other:  Specific  actions  for  the  protection  / 
lagoons/lakes/deltas 
rehabilitation 
(including  studies,  but  also  "water  balance 
rehabilitation") 

of 

4
0
R
G

5
0
R
G

  

*
6
0
R
G



  







  







7
0
R
G





8
0
R
G

9
0
R
G

0
1
R
G

   







    

1
1
R
G

 





2
1
R
G

 





3
1
R
G

4
1
R
G

 

















   

 















   

  

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. 

89 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1.12  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;  improving  the  water  supply  netwοrks  to 
minimize  losses,  reducing  abstraction  through  the  adoption  of  better  irrigation 
practices,  creating  incentives  for  rainwater  harvesting  in  agricultural  areas  and  for 
converting  to  less  water  demanding  crops;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 
intrusion;  promoting 
that 
voluntaryagreements  with  big  water  users  and  especially  the  agricultural  sector;  awareness 
raising and information activities. 

coastal  groundwater 

saltwater 

face 

for 

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.  

90 

 
 
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  or  to  rainwater 
harvesting (i.e. incentives provided in GR13/14). 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 
GR5/6/7/8/13/14basic 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.  

1.13  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. 

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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). 

1.14  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,  GR11/12  and  GR13/14. 
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 between 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  as  costs  the  costs  related  to  water  abstraction,  assuming  in  many 
cases  that  irrigation  does  not  entail  environmental  costs,  assuming  in  some  cases  that  no 
environmnetal  cost  is  associated  with  industries  since  they  are  subject  to  environmental 
permits 
treatment-hence  no  additional 
implemented  adequate 
environmental impacts, etc.). 

they  have  already 

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There is no consideration or discussion of the polluter pays principle, the implementation of 
incentive  pricing,  or  the  contribution  of  water  users  to  the  costs  of  water  services  in  some 
cases.. 

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. GR13 identifies three main users (domestic/urban water use, irrigation, industry), 
yet the analysis is conducted for the ones connected to the public water supply systems (no 
consideration  of  self-supplied  users),  while  industry  is  not  clearly  separated  from  the 
domestic/urban public water supply. 

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.  GR01/2/3/14),  disaggregated 
numbers  are  given  for  public  water  supply  and  sewage  companies  and  municipalities 
providing  these  services  directly,  or  calculation  at  the  River  Basin  level  are  provided 
(GR13/14). 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.  For  example,  in  GR13  the  resource  cost  has  been 
accounted equal to zero for domestic water use given the fact that in cases of water deficit the 
water for irrigation will be used to cover the needs and cover the deficit. Respectively, given 
the  fact  that  the  industrial  facilities  are  subject  to  environmental  permits  it  has  been 
considered  that  they  already  implement  adequate  treatment  and  thus  there  is  no  additional 
environmental  cost,  while  for  the  oil  mills  (546  in  total  over  Crete)  calculations  were  not 
feasible. 

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 

93 

 
 
specific  measures  for  dealing  with  non-metered  water  consumption  in  agriculture.  For 
GR13/14,  it  is  mentioned  that  the  new  irrigation  pricing  strategy  should  consider  the 
importance (development and social) of this primary sector, and any price increase should not 
try to achieve a full cost recovery of irrigation water services if the actual capacity/ ability to 
pay for these services is not feasible (i.e. an analysis of the cost, competitiveness and water 
pricing elasticity should be carried out for the main crops). The new irrigation water pricing 
schema could apply a mixed pricing system, with a flat rate fee for covering basic costs, and 
the  fluctuating  fee  based  on  volumetric  charging  for  covering  the  fluctuating  costs.  The 
overall relation between these two should be properly adjusted to prevent irrational water use 
and water wastage. It is concluded that there are potential margins to increase irrigation water 
pricing in the area without impact on the productivity. 

1.15  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. 

 Some  “other  basic  measures”  have  also  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).  

94 

 
 
 
 
 CLIMATE  CHANGE  ADAPTATION,  WATER  SCARCITY  AND  DROUGHTS,  FLOOD  RISK 
MANAGEMENT AND OTHER EMERGING AND LINKED ISSUES AS PART OF THE RBMP 

1.16  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 12 RBDs, a Drought Management Plan (DMP) has been established (for GR01/2/3, it is a 
combined  one,  while  for  GR13/14  no  DMPs  have  been  established);  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 (also on efficient use of water resources e.g. in GR13/14), 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). For GR13/14 no DMP has been developed, yet its development is foreseen in the 
PoMs as a basic measure. 

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). In GR13/14, where no DMP are drafted, this is foreseen as a basic 
measure in the PoMs. 

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.  

95 

 
 
1.17  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. 

1.18  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  were  being  taken  to  establish  one.  The  Greek 
National Climate Change Adaptation Strategy was eventually adopted in August 2016. 

96 

 
 
 
 
RECOMMENDATIONS  

Greece should: 

  Report  to  the  Commission  the  supporting  Annexes  of  the  RBMPs  GR13/14  which  the 
RBMP  itself  references  for  additional  information.  Enrich  and  provide  additional 
information/details in the RBMPs of GR13/14 to harmonise them with the remaining 12 
RBMPs in terms of completeness, clarity,detailand supporting evidence. 

 

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 (particularly 
for GR13 and 14) 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 
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. 

in 

  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.  

97 

 
 
  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 

98 

 
 
(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. For GR13/14  it would also be  valuable to develop DMPs (this  is 
also mentioned as a basic measure in the PoMs).  

  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. 

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