COMMISSION STAFF WORKING DOCUMENT Second River Basins Management Plans - Member State: Finland Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC) Second River Basin Management Plans First Flood Risk Management Plans
Date: 2019-02-26
Institutions: Directorate-General for Environment, European Commission
Subjects: Finland, adaptation to climate change, application of EU law, environmental risk prevention, flood, risk management, water, water management, water pollution, watercourse

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 26.2.2019  SWD(2019) 46 final  COMMISSION STAFF WORKING DOCUMENT Second River Basins Management Plans - Member State: Finland Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC) Second River Basin Management Plans First Flood Risk Management Plans {COM(2019) 95 final} - {SWD(2019) 30 final} - {SWD(2019) 31 final} - {SWD(2019) 32 final} - {SWD(2019) 33 final} - {SWD(2019) 34 final} - {SWD(2019) 35 final} - {SWD(2019) 36 final} - {SWD(2019) 37 final} - {SWD(2019) 38 final} - {SWD(2019) 39 final} - {SWD(2019) 40 final} - {SWD(2019) 41 final} - {SWD(2019) 42 final} - {SWD(2019) 43 final} - {SWD(2019) 44 final} - {SWD(2019) 45 final} - {SWD(2019) 47 final} - {SWD(2019) 48 final} - {SWD(2019) 49 final} - {SWD(2019) 50 final} - {SWD(2019) 51 final} - {SWD(2019) 52 final} - {SWD(2019) 53 final} - {SWD(2019) 54 final} - {SWD(2019) 55 final} - {SWD(2019) 56 final} - {SWD(2019) 57 final} - {SWD(2019) 58 final} - {SWD(2019) 59 final} - {SWD(2019) 60 final} - {SWD(2019) 61 final} - {SWD(2019) 62 final} - {SWD(2019) 63 final} - {SWD(2019) 64 final} - {SWD(2019) 65 final} - {SWD(2019) 66 final} - {SWD(2019) 67 final} - {SWD(2019) 68 final} - {SWD(2019) 69 final} - {SWD(2019) 70 final} - {SWD(2019) 71 final} - {SWD(2019) 72 final} - {SWD(2019) 73 final} - {SWD(2019) 74 final} - {SWD(2019) 75 final} - {SWD(2019) 76 final} - {SWD(2019) 77 final} - {SWD(2019) 78 final} - {SWD(2019) 79 final} - {SWD(2019) 80 final} - {SWD(2019) 81 final} - {SWD(2019) 82 final} - {SWD(2019) 83 final} - {SWD(2019) 84 final}  
 
 
Table of contents 
Acronyms and definitions ............................................................................................................. 5 

Foreword...................................................................................................................................... 6 

General Information .................................................................................................................... 7 

Status of second river basin management plan reporting ......................................................... 10 

Key strengths, improvements and weaknesses of the second River Basin Management Plan(s)
.................................................................................................................................................... 11 

Recommendations ...................................................................................................................... 20 

Topic 1

  Governance and public participation ....................................................................... 23 

1.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle   ...................................................................................................................................... 23 

1.2  Main changes in implementation and compliance since the first cycle ....................... 25 

1.3  Progress with Commission recommendations .............................................................. 26 

Topic 2

  Characterisation of the River Basin District............................................................. 27 

2.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle   ...................................................................................................................................... 27 

2.2  Main changes in implementation and compliance since the first cycle ....................... 40 

2.3  Progress with Commission recommendations .............................................................. 41 

Topic 3
bodies 

  Monitoring, assessment and classification of ecological status in surface water 

 ................................................................................................................................... 43 

3.1  Assessment of implementation and compliance with WFD requirements in the second 
RBMPs.................................................................................................................................... 43 

3.2  Main changes in implementation and compliance since the first RBMPs ................... 63 

3.3  Progress with Commission recommendations .............................................................. 64 

Topic 4

  Monitoring, assessment and classification of chemical status in surface water bodies 
 ................................................................................................................................... 67 

4.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle   ...................................................................................................................................... 67 

4.2.  Main changes in implementation and compliance since the first cycle ....................... 83 

4.3.  Progress with Commission recommendations .............................................................. 84 

1 

 
 
 
 
 
Topic 5

  Monitoring, assessment and classification of quantitative status of groundwater 

bodies 

 ................................................................................................................................... 87 

5.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle   ...................................................................................................................................... 87 

5.2  Main changes in implementation and compliance since the first cycle ....................... 93 

5.3  Progress with Commission recommendations .............................................................. 94 

Topic 6

  Monitoring, assessment and classification of chemical status of groundwater bodies 

96 

6.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle   ...................................................................................................................................... 96 

6.2  Main changes in implementation and compliance since the first cycle ..................... 102 

6.3  Progress with Commission recommendations ............................................................ 103 

Topic 7
  Designation of Heavily Modified and Artificial Water Bodies and definition of Good 
Ecological Potential................................................................................................................. 105 

7.1  Assessment of implementation and compliance with WFD requirements in second 
cycle for designation ............................................................................................................. 105 

7.2  Main changes in implementation and compliance since the first cycle ..................... 107 

7.3  Progress with Commission recommendations ............................................................ 108 

Topic 8

  Environmental objectives and exemptions .............................................................. 109 

8.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle   .................................................................................................................................... 109 

8.2  Main changes in implementation and compliance since the first cycle ..................... 117 

8.3  Progress with Commission recommendations ............................................................ 117 

Topic 9

  Programme of measures.......................................................................................... 119 

9.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle   .................................................................................................................................... 119 

9.2  Main changes in implementation and compliance since the first cycle ..................... 127 

9.3  Progress with Commission recommendations ............................................................ 127 

Topic 10

  Measures related to abstractions and water scarcity .......................................... 130 

2 

 
 
 
10.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle .......................................................................................................................... 130 

10.2 

Progress with Commission recommendations ........................................................ 130 

Topic 11

  Measures related to pollution from agriculture................................................... 131 

11.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle .......................................................................................................................... 131 

11.2  Main changes in implementation and compliance since the first cycle .................. 132 

11.3 

Progress with Commission recommendations ........................................................ 132 

Topic 12

  Measures related to pollution from sectors other than agriculture ..................... 135 

12.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle .......................................................................................................................... 135 

12.2  Main changes in implementation and compliance since the first cycle .................. 136 

12.3 

Progress with Commission recommendations ........................................................ 136 

Topic 13

  Measures related to hydromorphology ................................................................ 138 

13.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle .......................................................................................................................... 138 

13.2  Main changes in implementation and compliance since the first cycle .................. 139 

13.3 

Progress with Commission recommendations ........................................................ 140 

Topic 14

Economic analysis and water pricing policies .................................................... 142 

14.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle and main changes in implementation and compliance since the first cycle .... 142 

14.2 

Progress with Commission recommendations ........................................................ 142 

  Considerations specific to Protected Areas (identification, monitoring, objectives 

Topic 15
and measures) .......................................................................................................................... 144 

15.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle .......................................................................................................................... 144 

15.2  Main changes in implementation and compliance since the first cycle .................. 147 

15.3 

Progress with Commission recommendations ........................................................ 147 

Topic 16

Adaptation to drought and climate change .......................................................... 149 

3 

 
 
 
 
16.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle .......................................................................................................................... 149 

16.2  Main changes in implementation and compliance since the first cycle .................. 149 

16.3 

Progress with Commission recommendations ........................................................ 149 

4 

 
 
Acronyms and definitions 

EQS Directive 

Environmental Quality Standards Directive 

FD 

Km 

km2 

KTM 

PoM 

Floods Directive 

Kilometre 

Kilometre squared 

Key Type of Measure 

Programme of Measures 

QA/QC Directive 

Quality Assurance / Quality Control Directive  

RBD 

RBMP 

WFD 

WISE 

Annex 0 

River Basin District 

River Basin Management Plan 

Water Framework Directive 

Water Information System for Europe 

Member States reported the structured information on the 
second  RBMPs  to  WISE  (Water  Information  System  for 
Europe).  Due  to  the  late  availability  of  the  reporting 
guidance, Member States could include in the reporting an 
Annex 0, consisting of a short explanatory note identifying 
what  information  they  were  unable  to  report  and  the 
reasons  why.  This  Annex  was  produced  using  a template 
included  in  the  reporting  guidance.  If  Member  States 
reported all the required information, this explanatory note 
was not necessary. 

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Foreword 

The  Water  Framework  Directive  (WFD)  (2000/60/EC)  requires  in  its  Article  18  that  each 

Member  State  (MS)  reports  its  River  Basin  Management  Plan(s)  (RBMPs)  to  the  European 
Commission. The second RBMPs were due to be adopted by the Member States in December 

2015 and reported to the European Commission in March 2016. 

This  Member  State  Assessment  report  was  drafted  on  the  basis  of  information  that  was 

reported  by  Member  States  through  the  Water  Information  System  for  Europe  (WISE) 
electronic reporting.  

The  Member  State  Reports  reflect  the  situation  as  reported  by  each  Member  State  to  the 
European Commission in 2016 or 2017 and with reference to River Basin Management Plans 

(RBMP) prepared earlier. The situation in the Member States may have changed since then. 

6 

 
 
 
 
 
 
General Information 

Map A  

Map of River Basin Districts 

Source: WISE, Eurostat (country borders) 

  International River Basin Districts (within European Union) 
  International River Basin Districts (outside European Union) 
  National River Basin Districts (within European Union) 
  Countries (outside European Union) 
  Coastal Waters 

The population of Finland is 5.38 m (ref. Eurostat 2011) and the total surface area is 370 807 
km2, including coastal waters. 

Tornionjoki RBD is the Finnish part of the Torne river, shared with Sweden, which forms part 
of  the  border  between  the  countries,  and  to  a  smaller  extent  with  Norway.  The  Teno, 

Näätämöjoki, and Paatsjoki RBD has river basins shared both with the Russian Federation and 
Norway.  The  other  eastern  RBDs  Kemijoki  and  Vuoksi  share  river  basins  with  the  Russian 

Federation. 

7 

FIFIVHA6NO1103SENO1103NOSE1NOSE2SENO1102NOSE5SENO5101SE5RURURUGulfofBothniaGulf of FinlandBarents SeaNorwegianSeaWhite SeaFIVHA3FIVHA4FIVHA1FIVHA5FIWDASE2SE1FIVHA2NO1105SE3FIVHA7SE5EE2EE1SE1TONO1104NO1102NOSE2NO5101NOSE5NOSE1TONOSE1SENO1103SENO1104NOFIVHA6NOFIVHA50100200km 
 
 
 
 
 
 
 
 
 
 
 
 
 
The Åland is an autonomous region of the Finnish republic with its own legislation related to 

water. There are also some differences between water management on the Mainland of Finland 
and Åland. 

Information on areas of the national RBDs including sharing countries is provided in Table A 
and Finland’s share of the international RBDs is shown in Table B. 

Table A 

Overview of Finland‘s River Basin Districts  

Name 

Size* (km2)  Countries sharing RBD 

RBD 

FIVHA1 

Vuoksi  

FIVHA2 

Kymijoki-Gulf of Finland  

FIVHA3 

Kokemäenjoki-Archipelago Sea-Bothnian Sea  

FIVHA4 

Oulujoki-Iijoki  

FIVHA5 

Kemijoki 

FIVHA6 

Tornionjoki (Finnish part) 

FIVHA7 

Teno-, Näätämöjoki- and Paatsjoki (Finnish part) 

FIWDA 

Åland 

58 158 

57 074 

83 357 

68 084 

54 850 

14 587 

25 566 

9 379 

RU 

- 

- 

RU 

RU 

NO, SE 

NO, RU 

- 

Source: RBMP reported to WISE.  

Finland subsequently clarified that there are no RBDs shared with Russia 

Table B 

Transboundary river basins by category and % share in Finland  

Name international 
river basin 

National RBD 

Countries sharing 
borders 

Munkelelva/Uutanjoki 

FIVHA7  

NO, RU 

Kem (Viena)  

Kemijoki  

Naatamo  

Oulujoki  

Pasvik/Paatsjoki  

Teno/Tana  

Torneälven/ 
Tornionjoki  

FIVHA4 

FIVHA5 

FIVHA7 

FIVHA4 

FIVHA7 

FIVHA7 

RU 

RU 

NO, RU 

RU 

NO, RU 

NO, RU 

FIVHA6 

NO, SE 

Tuloma/Tuulomajoki  

Vuoksi  

 FIVHA7 

 FIVHA1 

NO, RU 

RU 

Source: WISE electronic reporting  

Co-ordination category 

2 

km² 

174 

1 297 

49 467 

2 354 

22 509 

14 492 

5 133 

14 587 

3 241 

58 158 

% 

73.4 

4.7 

96.8 

81.0 

98.5 

99.9 

31.3 

36.2 

12.6 

76.9 

8 

 
 
 
 
 
Category 1: International agreement, permanent co-operation body and international 
RBMP in place.  
Category 2: International agreement and permanent co-operation body in place. 
Category 3: International agreement in place. 
Category 4: No co-operation formalised. 

9 

 
 
 
Status of second river basin management plan reporting 

A  total  of  eight  RBMPs  for  Finland  (Vuoksi,  Kymijoki-Gulf  of  Finland,  Kokemäenjoki-

Archipelago  Sea-Bothnian  Sea,  Oulujoki-Iijoki,  Kemijoki,  Tornionjoki  (Finnish  part),  Teno-, 
Näätämö- and Paatsjoki (Finnish part), Åland) were published between 8 October 2015 and 3 

December 2015. Documents  are available from the European Environment  Agency  EIONET 
Central Data Repository https://cdr.eionet.europa.eu/.  

10 

 
 
 
 
Key strengths, improvements and weaknesses of the second River 
Basin Management Plan(s) 

The main strengths and shortcomings of the second RBMP of Finland are as follows: 

 

Governance and public consultation 

  A  broad  range  of  stakeholders  was  actively  involved  in  the  preparation  of  Finland’s 

RBMPs, including via advisory groups. 

  Finland  has  strengthened  cooperation  with  Sweden  and  Norway,  including  via  the 
preparation of common “roof reports” for their shared iRBDs. Finland also strengthened 
cooperation with the Russian Federation.  

 

Characterisation of the RBD 

  Many  new  water  bodies  have  been  delineated,  particularly  if  they  were  relevant  for 
water management or for other reasons such as nature conservation or water use.  

 

The  typology  of  rivers  and  lakes  in  mainland  Finland  is  based  on  geographical, 

geological, chemical and physical characteristics and therefore it is unclear if they have 
been  made  biologically  relevant.  There  are  several  river,  lake  and  coastal  water  body 

that  were  reported  not 

types 
approximately 60 % in total.  

to  have  a  corresponding 

intercalibration 

type, 

 

 

 

Type specific reference conditions were reported not to have been established for any 
water  body  for  relevant  hydromorphological  quality  elements.  This  may  lead  to 

weaknesses in the classification of status/potential according to the hydromorphological 
quality elements. 

For  groundwater  bodies,  further  characterisation  work  has  been  undertaken  since  the 
first  RBMPs,  by  describing  the  geological  formation  and  whether  or  not  they  are 

layered.  Finland  have  also  made  an  assessment  of  linkages  with  surface  water  bodies 
and terrestrial ecosystems. 

For surface waters and groundwaters, significance of pressures was linked to failure of 
objectives.  However,  it  is  unclear  how  numerical  tools  have  been  used  and  expert 

judgement  was  extensively  used.  This  is  likely  to  give  a  qualitative  rather  than  a 
quantitative assessment of the significance on this pressure. In addition thresholds were  
reported not to be used to assess the significance of pressures in surface water. 

11 

 
 
 

36  substances  were  included  in  an  inventory  for  each  of  the  RBDs,  out  of  the  41 

Priority  Substances.    Tier  1  of  the  methodology  was  implemented  for  most  of  the 
substances in the inventories, including for some of the substances deemed relevant at  

RBD level. Higher tiers of the methodology were also implemented but only for some 
substances. The data quality was not reported. 

  Monitoring, assessment and classification of ecological status  

  The  number  of  monitoring  sites  in  Finland  have  more  than  doubled  since  the  first 
RBMPs, with increased numbers for both surveillance and operational sites in the three 

relevant  water  categories.  However,  the  proportion  of  water  bodies  with  surveillance 
monitoring for some biological quality elements decreased since the first RBMPs. 

  A  high  proportion  of  sites  were  sampled  at  least  at  the  minimum  recommended 
frequencies  for  all  biological  quality  elements  used  for  surveillance  and  operational 
purposes in all relevant water categories. 

  River Basin Specific Pollutants were not monitored for surveillance purposes in coastal 
waters and in a very few cases in lakes and rivers. Furthermore, none of the substances 

was  monitored  at  the  minimum  recommended  frequency  at  any  of  sites  at  which  they 
were monitored. 

  Only  in  6  %  of  water  bodies  included  in  surveillance  monitoring  were  all  the  required 

biological quality elements monitored. 

  Only  69  %  of  water  bodies  included  in  operational  monitoring  included  at  least  one 
biological quality element, while 98 % of river water bodies were monitored for at least 

one physicochemical quality element. 

 

In  all  water  categories,  the  ecological  status/potential  classification  is  often  based  on 

more quality elements than had been used for the first RBMPs. However, for many water 

bodies  in  lakes  and  coastal  waters,  the  assessment  is  still  based  on  phytoplankton  and 
nutrients only. 

  The overall ecological status/potential in Finland has not improved significantly since the 
first RBMPs, but there has been a significant improvement in the level of confidence of 

the classification. 

  There are now methods developed for all relevant biological quality elements in all water 
categories, and these were reported to be sensitive to most reported significant impacts, 

12 

 
 
although  none  of  them  seems  to  be  sensitive  to  chemical  pollution  and  acidification  in 

coastal waters. 

  All  the  relevant  hydromorphological  quality  elements  were  reported  to  be  assessed  in 
terms  of  ecological  status/potential.  However,  the  classification  boundaries  are  not 
related to the class boundaries for the sensitive biological quality elements. 

  Only a limited number of physicochemical quality elements were used in the assessment 

of ecological status/potential of surface water bodies and significant gaps remain. 

  Environmental Quality Standards were reported for 13 River Basin Specific Pollutants in 
water and one in sediment, but these did not include any metals. There is no information 
available on how the River Basin Specific Pollutants have been identified in the second 

RBMPs.  Finland subsequently indicated that there were no changes in  the list  of River 
Basin Specific Pollutants since the first RBMPs. 

  Environmental  Quality  Standards  have  not  been  derived  in  accordance  with  the 
Technical Guidance n° 27. The analytical methods used are in line with Articles 4(1) or 

4(2) of Directive 2009/90/EC for the strictest standard applied. However, both these have 
been reported in the first cycle. 

  River Basin Specific Pollutants are classified mainly using expert judgement, with only a 

few using monitoring results. 

  Finland reported that the one-out-all-out principle has been used in all RBDs, which had 

not been the case for the first  RBMPs. 

  Monitoring, assessment and classification of chemical status in surface water bodies 

  Comparing  the  number  of  sites  and  water  bodies  monitored  for  operational  and 
surveillance  purposes  between  the  first  and  second  RBMPs,  there  appears  to  be  a  net 
increase in monitoring sites and surface water bodies monitored. However, there remains 

a significant proportion of surface water bodies that is not monitored for chemical status. 
Territorial waters are not monitored or assessed for chemical status in Finland. While the 

increase in the number of sites and water bodies monitored from the first cycle represents 
some  progress,  the  proportion  of  surface  water  bodies  monitored  for  operational  and 

surveillance purposes is low. 

  Finland  reported  that  36  of  the  41  groups  of  Priority  Substances  were  included  in  an 
inventory  for  each  of  the  RBDs.  However,  across  the  eight  RBDs  in  Finland  only 

13 

 
 
between  three  and  eight  of  the  groups  of  Priority  Substances  in  an  inventory  were 

reported as being discharged. For seven of the eight RBDs, with the exception of DEHP 
in  the  Oulujoki-Iijoki  RBD,  all  of  the  substances  discharged  were  reported  to  be 

monitored. 

  For status assessment, where monitoring for chemical status does occur, the number of 
groups  of  Priority  Substances  monitored  varies  widely:  in  coastal  waters  up  to  five,  in 
lakes  only  one  and  in  rivers  up  to  10  groups  of  Priority  Substances  were  monitored. 

Finland  clarified  that  mercury,  hexachlorobenzene  and  hexachlorobutadiene  were 
monitored  in  biota  for  status  assessment  (hexachlorobenzene  and  hexachlorobutadiene 

being  also  monitored  in  water).  Finland  also  clarified  that  water  is  supposed  to  be 
monitored  every  month,  but  in  practice,  water  monitoring  may  sometimes  happen  less 

than  12  times  per  year.  No  explanation  was  provided  for  the  reduced  frequency.    The 
monitoring frequency in biota was once per year and every three years in the monitoring 

cycle  for  each  monitoring  site,  which  is  lower  than  the  minimum  recommended 
frequency in the Directive. No explanation was found for the reduced frequency. 

  There  is  no  monitoring  reported  in  Finland  for  long-term  trend  analysis  in  sediment 

and/or biota. 

  Overall  between  the  two  cycles  there  was  a  decrease  in  proportion  of  surface  water 
bodies with good chemical status from 64 % down to 49 %, similar decreases occurred 

across all water body types (artificial, heavily modified and natural). The proportion of 
surface  water  bodies  failing  to  achieve  good  status  dramatically  increased  between  the 

two cycles, from 0.44 % to 49 %. While 36 % of surface water bodies were reported with 
unknown status in the first RBMP, all water bodies were classified in the second RBMP 

which represents an improvement from the first cycle.  

 

40  out  of  the  41  groups  of  Priority  Substances  in  the  classification  of  chemical  status 

were monitored in all the RBDs however in different proportions (i.e. from 0 in one RBD 
to  40).  This  would  explain  that  the  overall  93  %  of  surface  water  bodies  in  Finland 
classification for chemical  status  is  with low confidence, 6 % with  medium  confidence 

and only 1 % with high confidence regardless of class. 

  Monitoring,  assessment  and  classification  of  quantitative  status  of  groundwater 

bodies 

 

There is very limited monitoring for quantitative status, which has even decreased since 
the first RBMPs.  

14 

 
 
 

How quantitative status was assessed without monitoring data is not fully clear. Yet, 98 

% of groundwater bodies are in good quantitative status.  

 

Groundwater  dependent  terrestrial  ecosystems  and  groundwater  associated  surface 

waters  were  considered  in  status  assessment  of  all  river  basin  districts  where  such 
ecosystems exist. Also, their needs have been considered in all river basin districts  

  Monitoring, assessment and classification of chemical status of groundwater bodies 

 

 

 

The coverage of monitoring for chemical status in groundwater is still very low. 

A  number  of  groundwater  bodies  is  still  reported  with  unknown  chemical  status.  The 
total  number  of  groundwater  bodies  failing  good  chemical  status  has  increased. 

Monitoring of WFD core substances and of substances causing risk of deterioration in 
chemical status is very limited. 

Groundwater  dependent  terrestrial  ecosystems  and  groundwater  associated  surface 
waters  were  considered  in  status  assessment  in  all  river  basin  districts  where  such 

ecosystems exist. 

 

Designation of Heavily Modified and Artificial Water Bodies and definition of Good 

Ecological Potential 

 

There is no exact description of the changes made to the methodology  for designating 

heavily  modified  water  bodies,  but  the  criteria  seem  to  be  defined  in  a  more  detailed 
form than in the first RBMPs. Furthermore, the basis of evaluation of hydrological and 

morphological  status  is  described  in  more  detail.  Information  is  also  provided  on  the 
methodology  used  to  assess  significant  adverse  effects,  however,  no  information  was 
found on the assessment of other means to achieve the beneficial objectives served by 

the  modifications  of  the  heavily  modified  water  body.  Specific  information  on  the 
outcome  of  the  assessment  of  significant  adverse  effects  and  better  environmental 

options is not given on a water body level. 

 

Good  ecological  potential  is  defined  with  the  Prague  approach  on  the  basis  of 

mitigation  measures.  Mitigation  measures  for  defining  good  ecological  potential  have 

been reported and the ecological changes expected due to the mitigation measures are 
described in a qualitative way. However, good ecological potential has not been defined 
fully in biological terms yet (using all relevant biological quality elements).  

15 

 
 
 

Environmental objectives and exemptions 

  Environmental objectives for ecological and chemical status of surface water bodies have 
been reported in all RBDs as well as for chemical and quantitative status of groundwater. 
Information is also provided on when the objectives will be achieved. 

 

Justifications  of  technical  feasibility  for  the  application  of  Article  4(4)  exemptions  are 
provided, however, further elaboration and clarification may be needed.  

  Further  information  and  assessments  are  needed  in  order  to  ensure  that  the  procedures 
under Article 4(7) are in line with the requirements of the WFD. The fact that expected 
deterioration  from  high  to  good  status  seems  not  to  trigger  an  Article  4(7)  assessment 

might  be  an  issue  of  insufficient  and/or  non-compliant  implementation  of  WFD 
requirements. 

 

 

Programme of Measures 

Finance  was  reported  to  have  been  secured  in  all  RBDs.  Costs  were  reported  in  each 
RBMP. However, no information on the costs of the measures for  either Programme of 

Measures was provided in WISE. 

 

All RBDs in  Finland have reported that new legislation or regulations are required and 

are in progress. 

 

The KTMs addressing some, but not all significant pressures in both surface water and 

groundwater have been identified. 

 

 

National basic and supplementary measures have been mapped against KTMs. 

14 national basic measures have been mapped against only four pre-defined KTMs. Not 

all measures apply in all RBDs. 

 

No information has been provided on the River Basin Specific Pollutants causing surface 

water  bodies  to  fail  to  reach  good  status.  Some  individual  substances  were  reported  as 
causing  groundwater  bodies  to  fail  to  be  of  good  status,  however  no  KTMs  to  control 

these substances were reported. 

 

Information on the Priority Substances causing surface water bodies to fail to be of good 
status  has  not  been  reported  for  three  RBDs.  For  those  RBDs  where  failures  were 

16 

 
 
reported  they  cover  only  three  substances.  KTMs  were  reported  for  two  of  these 

substances.  

 

Indicators of the gap to the achievement of environmental objectives have been provided 

but only for 2015.  

 

The  objectives  of  the  Floods  Directive  have  been  considered  in  the  RBMPs.  Win-win 

measures and Natural Water Retention Measures have been included. The design of new 
and  existing  structural  measures  has  been  adapted  for  the  WFD.  Article  9(4)  has  been 

applied. 

 

The  RBMPs  and  Flood  Risk  Management  Plans  have  not  been  integrated.  The  flood 

protection was reported as “not applicable” to the financing of measures. 

  Measures related to abstractions and water scarcity 

  Water abstraction and scarcity have not been reported to be relevant for Finland. 

 

All  water  uses  are  subject  to  permitting  procedures  under  Article  11(3)(e),  with  the 

exception of small abstractions. 

 

Under  Article  11(3)(c),  measures  promoting  efficient  and  sustainable  water  use  (e.g. 

water metering and allocations) were implemented in the previous cycle. 

  Measures related to pollution from agriculture 

 

 

 

 

There is a clear link between agricultural pressures and agricultural measures. 

No gap assessment in terms of reduction needed has been performed, though the area 

on which each measure is implemented is provided. For pesticides, the number of water 
bodies failing EQS are reported for all basins except Aland RBD. 

Safeguard zones for drinking water have been established for abstractions. 

Implementation of basic measures Article 11(3)(h) for the control of diffuse pollution 
from agriculture at source is ensured in all RBDs, with the same rules applying across 

the whole RBD. 

 

Supplementary  measures  for  reducing  pollution  from  agriculture  were  reported. 

Financing of measures is secured. 

17 

 
 
 

The Programme of Measures heavily relies on voluntary measures. 

  Measures related to pollution from sectors other than agriculture 

  Measures  to  tackle  non-agricultural  sources  of  pressures  include  the  construction  and 
upgrade of urban waste water treatment plants, but it is not clear how effective this will 

be at reducing the emission of nutrients in low-temperature environments. 

  Where  measures  were  reported  for  Priority  Substances  causing  non-compliance,  no 

indication was given of their effectiveness at achieving the objectives. 

  Measures related to hydromorphology 

  Operational KTMs to address all or part of the significant hydromorphological pressures 
were  reported  for  all  RBDs.  However,  indicators  on  the  gap  to  be  filled for  significant 

hydromorphological  pressures  are  only  reported  for  2015  but  not  for  2021  or  2027, 
which does not allow any conclusions on the level of ambition in closing the gap. 

 

In the seven mainland RBDs, ecological flows have been derived for some relevant water 
bodies but the work is still on-going. The ecological flows which have been derived have 

not  been  implemented  yet  but  there  are  plans  to  do  so  during  next  cycle.  At  the  same 
time, no clear measure is yet included in the RBMPs to review all existing hydropower 

permits  to  ensure  the  achievement  of  WFD  objectives,  in  particular  in  relation  to 
ecological flow, fish passes and other mitigation measures. 

  Natural  Water  Retention  Measures  are  applied  in  four  of  eight  RBDs  to  address 
hydromorphological  pressures  related  to  agriculture  and  flood  protection.  Examples  of 
Natural Water Retention Measures included are restoration of flood meadows and flood 
forests as well as constructed wetlands in agricultural areas. 

 

Economic analysis and water pricing policies  

 

Cost recovery calculations remain limited – environmental and resource costs have not 

been included. 

 

 

No information has been provided on ‘adequate incentives’ of pricing policies. 

No  detailed  information  has  been  provided  on  the  application  of  the  polluter  pays 
principle. 

18 

 
 
 

A  narrow  definition  of  water  services  has  been  used.  There  is  no  consideration  of 

(cross-) subsidies in  the  calculated and reported  cost  recovery  rates for the two water 
services identified. 

 

Considerations  specific  to  Protected  Areas  (identification,  monitoring,  objectives 
and measures) 

 

The reported monitoring activities for each Protected Area type were similar to that in 

the  first  cycle  with  the  exception  of  that  for  Protected  Areas  related  to  Birds  and 
economically significant species where no monitoring was reported in the second cycle. 

 

The  RBMPs  indicate  that  two  additional  measures  are  to  be  implemented  for  the 

protection of drinking water Protected Areas. However, these are poorly defined. 

 

Adaptation to drought and climate change 

 

Climate  change  was  considered  in  various  ways  in  all  river  basin  districts  and  it  is 

stated that the Common Implementation Strategy guidance document on how to adapt 
to climate change was used. 

 

All  Finnish  river  basin  districts  recognise  the  existence  of  local  or  sub-basin  drought 
spells as one of the effects of climate change. However, none of the river basin districts 

has developed a drought management plan. 

19 

 
 
 
 
Recommendations  

 

Clear  information  should  be  included  in  national  RBMPs  on  international  coordination 

efforts in order to increase transparency.  

 

 

Finland  should  continue  to  improve  international  cooperation,  including  coordinated 
assessments of the technical aspects of the WFD such as ensuring a harmonized approach 

for status  assessment and a coordinated Programme of Measures in  order to  ensure the 
timely achievement of the WFD objectives. 

Finland should describe clearly the methodology used to identify significant pressures on 
both surface waters and groundwater. 

 

Finland should further improve monitoring of surface waters, as there are still important 

gaps.  Monitoring  should  be  extended  to  cover  all  water  bodies  for  all  relevant  quality 
elements,  including  hydromorphological  quality  elements  and  River  Basin  Specific 

Pollutants  in  coastal  waters.  For  the  latter,  the  coverage  for  lakes  and  rivers  should 
increase. 

 

Finland  should  have  a  clear  and  transparent  method  for  the  selection  of  River  Basin 
Specific  Pollutants,  and  provide  clear  information  on  how  the  status  of  River  Basin 

Specific  Pollutants  has  been  determined,  in  particular  for  non-monitored  substances. 
Finland  should  ensure  that  Environmental  Quality  Standards  meet  the  minimum 

requirements  for  the  protection  of  freshwater  and  marine  ecosystems  from  possible 
adverse effects, as well as of human health, following the requirements of the WFD and 

the Directive on environmental quality standards. 

 

An increased level of monitoring should lead to a lower dependence on expert judgement 

for  the  classification  of  ecological  status/potential,  especially  for  hydromorphological 
quality elements and for River Basin Specific Pollutants. 

 

Finland  should  strengthen  its  assessment  methods.  In  particular,  the  classification 
boundaries of hydromorphological quality elements should be related to the classification 

boundaries  for  the  sensitive  biological  quality  elements,  and  all 
the  relevant 
physicochemical  quality  elements  should  be  used  in  the  assessment  of  ecological 

status/potential. 

 

Finland  should  continue  improving  the  monitoring  for  status  assessment  to  reach 

sufficient  confidence,  spatial  coverage  and  temporal  resolution  for  all  the  Priority 

20 

 
 
Substances  (including  territorial  waters  whose  status  should  be  also  assessed).  If  a 

different matrix or reduced frequencies are used, the corresponding explanations should 
be provided, as required by the Directives. 

 

Finland should ensure that the trend monitoring is up and running so that all the relevant 
substances  specified  in  Directive  2008/105/EC  are  monitored  in  order  to  provide 

sufficient data for long-term trend analysis 

 

Groundwater  monitoring  should  continue  to  be  enhanced  in  Finland,  especially  for 

substances posing risk. 

 

The improvement of the methodology and subsequent application for the designation of 

heavily modified water bodies needs to be continued. The assessment of other means to 

achieve  the  beneficial  objectives  served  by  the  modifications  of  the  heavily  modified 
water bodies and the outcome of the assessment of significant adverse effects on the use 

or the wider environment at water body level need to be made transparent. 

 

The  definition  of  good  ecological  potential  needs  to  be  continued  for  all  relevant 

biological quality elements. 

 

Progress  in  the  application  of  Article  4(4)  exemptions  should  be  continued.  The 

justifications  for  technical  feasibility  and  disproportionate  cost  should  be  elaborated  in 
more detail and further clarified.  

 

 

 

 

The issue that expected deterioration from high to good status may not trigger an Article 
4(7) assessment is an issue of concern. Finland needs to ensure a thorough assessment of 

proposed  new  modifications  in  line  with  the  requirements  of  the  WFD  and  as  further 
specified by the Judgment of the European Court of Justice in case C-461/13. 

Finland should ensure that KTMs addressing all the significant pressures are identified. 

Indicators  of  the  gap  to  the  achievement  of  the  environmental  objectives  should  be 
provided. 

KTMs to tackle River Basin Specific Pollutants should be presented, in order to control 
these  reported  substances,  and  assess  the  likely  effectiveness  of  measures  planned  to 

tackle  them  and  Priority  Substances  causing  failure,  taking  account  of  the  low-
temperature conditions. 

21 

 
 
 

Finland should continue improving the linkage of the analysis of pressures and impacts 

with the identification of measures in the RBMPs in relation to chemical pollution. 

 

A  clear  financial  commitment  for  all  the  RBDs  should  be  ensured.  However,  FI  stated 

that information on the costs of the measures is provided, but not reported in WISE. 

 

Finland  should  complete  a  comprehensive  gap  assessment  for  diffuse  pollutant  loads 

from agriculture (nutrients, agri-chemicals, sediment, organic matter) across all waters in 

all  RBDs  and  link  it  directly  to  mitigation  measures  in  the  third  RBMPs  (as  per  WFD 
Article 11(3)(h)), to facilitate the achievement of WFD objectives. 

 

In  the  third  RBMPs,  Finland  should  make  more  effective  use  of  the  cross  compliance 
regime  to  support  WFD  objectives,  make  the  links  between  the  WFD  and  Nitrates 

Directive  more  explicit  and  ensure  that  an  expert  and  effective  advisory  service  is 
available to  farmers to  aid  successful  implementation of measures.  Finland should also 

ensure  that  RDP  funds  are  made  available  to  support  the  successful  implementation  of 
the RBMPs’ agricultural measures. 

 

 

Finland should continue the work on defining ecological flow, and make sure that this is 
implemented  in  all  RBDs.  The  revision  of  all  existing  hydropower  permits  should  be 

done to ensure the achievement of WFD objectives, in particular in relation to ecological 
flow, fish passes and other mitigation measures. 

Finland should apply cost recovery for water use activities having a significant impact on 
water bodies or justify any exemptions using Article 9(4). It should transparently present 

how  financial,  environmental  and  resource  costs  have  been  calculated  and  how  the 
adequate  contribution  of  the  different  users  is  ensured.  Further,  it  should  transparently 

present  the  water-pricing  policy  and  provide  a  transparent  overview  of  estimated 
investments and investment needs. 

 

Finland  should  improve  the  information  in  the  RBMPs  regarding  the  exemptions  and 

measures  put  in  place  for  Drinking  Waters.  Finland  has  only  informed  that  safeguard 
zones are in place, but there are no plans to change the regulations.  

 

Based  on  the  prevalence  of  local  or  sub-basin  drought  spells  as  one  of  the  effects  of 
climate change, Finland should re-consider preparing drought management plans where 

appropriate. 

22 

 
 
 
Topic 1

  Governance and public participation 

1.1  Assessment  of 

implementation  and 

compliance  with  WFD 

requirements in the second cycle 

1.1.1 Administrative arrangements – river basin districts 

Finland  has  designated  eight  RBDs,  seven  in  mainland  Finland  and  one  for  Åland.  Five  of 

these RBDs are part of international RBDs, shared with Norway, Russia and Sweden. 

1.1.2 Administrative arrangements – competent authorities 

Finland  lists  14  authorities  at  sub-national  level:  13  Centres  for  Economic  Development, 

Transport and the Environment; and the Government of Åland. These authorities all have roles 
for the preparation and implementation of the RBMPs, except coordination and reporting to the 

European Commission. 

The  two  national  ministries  are  listed:  the  Ministry  of  Agriculture  and  the  Ministry  of 

Environment.  Both  ministries  are  responsible  for  the  coordination  of  implementation  of  the 
WFD,  and  the  Ministry  of  Environment  is  also  responsible  for  reporting  to  the  European 

Commission. 

1.1.3 RBMP – structure and Strategic Environmental Assessment  

Finland reported that no sub-plans to the RBMPs were prepared. 

A Strategic Environmental Assessment was prepared for seven of Finland's eight RBMPs. For 
Åland,  a  Strategic  Environmental  Assessment  was  not  reported  to  WISE;  however,  Finland 

informed that a Strategic Environmental Assessment had been carried out for this RBMP. 

1.1.4 Public consultation 

RBMP documents were available for public consultation for the required six months in all of 

Finland's RBDs. The public and interested parties were informed by a broad  range of means, 
including: internet, invitations to stakeholders, media (newspaper, TV and radio), meetings and 

social  networking.  For all RBDs, copies of the draft documents were available for download 
and paper  copies were available in  municipal buildings, and consultation  was carried out  via 

direct involvement in drafting the RBMP (see active involvement, below), via Internet and via 
social  networking.  For  all  RBDs  except  Åland,  an  online  questionnaire  was  also  used. 
According  to  information  reported  to  WISE,  in  the  Vuoksi,  Kymijoki-Gulf  of  Finland  and 

Oulujoki-Iijoki RBDs, announcements were made in newspapers and in  each municipality of 
the  RBDs;  Finland  subsequently  informed,  however,  that  newspaper  announcements  were 
made in all RBDs. 

23 

 
 
In  all  of  Finland's  RBDs,  stakeholders  were  actively  involved  via  the  establishment  of 

stakeholder  groups  as  well  as  involvement  in  drafting  the  RBMPs.  The  stakeholder  groups 
fisheries/aquaculture, 
actively 

involved  were:  agriculture/farmers,  energy/hydropower, 

industry,  local/regional  authorities,  navigation/ports,  NGOs/nature  protection,  water  supply 
and  sanitation,  land  owners’  associations,  forestry  associations,  water  owners’  associations, 

research institutes. (All these groups participated in each RBD except for energy/hydropower - 
not listed for Åland - and navigation/ports, not listed for the Vuoksi RBD).  

In all Finland's RBDs, public consultation had the following impacts on each of the RBMPs: 
addition  of  new  information,  adjustment  to  specific  measures,  changes  to  the  selection  of 

measures and commitment to further research. 

1.1.5 Integration  with  the  Floods  Directive  and  the  Marine  Strategy  Framework 

Directive 

Finland  reported  RBMPs  and  Floods  Directive1  Flood  Risk  Management  Plans  in  separate 
plans for the RBDs. In six of Finland's eight RBDs, there was joint consultation of RBMPs and 
Flood Risk Management Plans (the exceptions being the Vuoksi and Åland RBDs, where no 
flood  risk  areas  were  identified  and  thus  FRMPs  were  not  prepared).  Further  information  on 

integration  with  respect  to  the  implementation  of  measures  is  provided  in  Chapter  8  of  this 
report. 

Seven of Finland's eight RBDs organised joint consultation on the RBMPs and on the Marine 
Strategy Framework Directive2 (the exception being the Åland RBD). 

1.1.6 International coordination 

Finland  reports  on  international  co-ordination  in  two  RBDs.  Finland  reports  agreement  on 
international  RBMPs  for  the  Tornionjoki  RBD,  shared  with  Sweden,  and  for  the  Teno, 

Näätämöjoki and Paatsjoki RBD, shared with Norway. Finland’s reporting to WISE indicates 
that joint RBMPs were prepared for these two RBDs shared with Sweden and Norway.    

For  the  catchments  shared  between  Finland  and  Norway  (which  are  part  of  Finland’s  Teno, 
Näätämökjoki  and  Paatsjoki  RBD,  FIVHA7)  cooperation  has  included  monitoring,  the 

includes  descriptions  of  co-operation, 
preparation  of  a  common  “roof  report” 
characteristics  of  the  international  river  basin  district,  impact  of  human  activity,  state  of  the 

that 

1   Directive 2007/60/EC on the assessment and management of flood risks entered into force on 26 November 

2007 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32007L0060 

2   Directive  2008/56/EC  of  the  European  Parliament  and  of  the  Council  of  17  June  2008  establishing  a 
framework  for  community  action  in  the  field  of  marine  environmental  policy  (Marine  Strategy  Framework 
Directive) http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008L0056  

24 

 
 
                                                      
waters,  monitoring  network,  environmental  objectives  and  measurements.  This  document  is 

available in Finnish, Norwegian, Sami and English. 

Finland’s  Tornionjoki  RBD  (FIVHA6)  is  shared  with  Sweden  and  Norway.  Sweden  and 

Finland  have  prepared  a  common  “roof  report”  which  includes  descriptions  of  co-operation, 
characteristics  of  the  international  river  basin  district,  impact  of  human  activity,  state  of  the 

waters,  monitoring  networks,  environmental  objectives  and  measurements.  This  report  has 
been published in four languages; Finnish, Swedish, Sami and Tornedalian Finnish, Meänkieli. 

For  each  international  RBD,  the  common  roof  report  plus  the  national  RBMPs  are  together 
considered as the international RBMP (for further information see the reports on international 

coordination on the Water Framework Directive). 

Finland has bilateral agreements with Sweden and Norway: under each, there is a commission 

for coordination on shared surface water bodies that has addressed water management.  

Four of Finland's RBDs are part of international RBDs shared with Russia: Vuoksi, Oulujoki-

Iijoki,  Kemijoki  and  Teno,  Näätämöjoki  and  Paatsjoki.  Under  the  Finnish-Russian  Cross-
Border Commission3 , there are working groups on water resources and water protection, plus 
a sub-group on fisheries. Cooperation has covered monitoring activities and research projects. 

The Finnish-Russian Cross-Border Commission established a cooperation which aims to reach 
good  water  status.  Recent  cooperation  milestones  included,  for  example,  an  updated 

monitoring programme in 2015, a revised map of transboundary catchment areas in 2014 and a 
decision to start preparing a joint risk management programme in 20134. 

Russia  has  an  observer  status  in  the  Finnish-Norwegian  Transboundary  Water  Commission's 
meetings5.  Murmansk  regional  environment  authorities  work  in  cooperation  with  matters 
related to the international River Paatsjoki catchment (shared also with Norway).  

1.2  Main changes in implementation and compliance since the first cycle 

The  main  change  has  been  the  strengthening  of  cooperation  with  Sweden  and  Norway, 
including the development of common International RBD “roof reports” that bring together the 

respective national RBMPs.   

3   http://rajavesistokomissio.fi/  
4   More information about co-operation projects is available at http://www.pasvikmonitoring.org/. 
5See:http://www.ymparisto.fi/fi-

FI/Vesi/Vesiensuojelu/Rajavesistoyhteistyo_Lapissa/Suomalaisnorjalainen_rajavesistokomissio  

25 

 
 
                                                      
 
1.3  Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMPs  and  Programme  of  Measures 
requested action on the following: 

  Recommendation: International co-ordination with Sweden and Norway as well as the 

Russian Federation need to be extended. 

Assessment: Finland has deepened its coordination with Sweden and Norway in shared 
RBDs, including via the preparation of common “roof reports” that bring together the 

respective national RBMPs. Finland’s ongoing cooperation activities with the Russian 
Federation  have  also  strengthened,  including  activities  such  as  monitoring  and 

mapping.  

Consequently, Finland has implemented this recommendation.  

26 

 
 
 
Topic 2

  Characterisation of the River Basin District 

2.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle  

2.1.1 Delineation of water bodies and designation of heavily modified and artificial water 

bodies 

There has been an overall increase in the number of river water bodies (19 %) but particularly 

in  the  Kokemäenjoki  -Archipelago  Sea-Bothnian  Sea  (56  %),  Vuoksi  (32  %)  and  Kymijoki-
Gulf  of  Finland  (21  %)  RBDs  (  Table  2.1).  There  has  also  been  an  overall  increase  in  the 

number  of  lake  water  bodies  of  8  %,  with  the  highest  increase  in  the  Kokemäenjoki-
Archipelago Sea-Bothnian Sea RBD of 29 %. The numbers of coastal water bodies remained 

the same.  

Table 2.2 shows the differences in size distribution of surface water bodies in Finland between 

the second and first RBMPs. There was a slight decrease overall in the minimum size of rivers. 
The  minimum  size  criteria  reported  were  100  km2  catchment  area  for  rivers  and  0.5  km2 
surface  area  for  lakes.  The  RBMP  reported  that  smaller  rivers  and  lakes  have  also  been 
considered if they were particularly relevant for water management or other reasons like nature 

conservation or water use. This is the reason many new water bodies have been delineated. For 
example,  the  Vuoksi  RBD  delineated  new  water  bodies  because  of  their  nature  value  or 

because of the need to consider a wider river network.  

In  the  second  RBMP,  98  %  of  identified  surface  water  bodies  were  natural  with  2  %  being 

designated as heavily modified and only 0.5 % artificial. Overall there were very little changes 
in the numbers of heavily modified and artificial water bodies between the first cycle and the 

second cycle, less than 1 % difference (Figure 2.1).  

The numbers of groundwater bodies remained largely the same with the exception of the Åland 
RBD which decreased from 34 to 56 (Table 2.3). The water uses and physical alteration have 
been reported for each water body type. 

Table 2.4 summarises the information provided by Finland on how water bodies have evolved 
between the two cycles. The water body types with the most changes were river and lake water 
bodies, with water bodies created, split and deleted. 

6   Finland subsequently stated this must be a reporting error from the first RBMP. 

27 

 
 
 
                                                      
Table 2.1 

 Number and area/length of delineated surface water bodies in Finland for 

the second and first cycles 

Rivers 

Lakes 

Coastal 

Year 

RBD 

Number of 
water bodies 

Total length 
of water 
body (km) 

Number of 
water bodies 

Total area 
(km2) of 
water bodies 

Number of 
water bodies 

Total area 
(km2) of 
water bodies 

2016 

2016 

2016 

2016 

2016 

2016 

2016 

2016 

2016 

2010 

2010 

2010 

2010 

2010 

2010 

2010 

2010 

2010 

FIVHA1 

FIVHA2 

FIVHA3 

FIVHA4 

FIVHA5 

FIVHA6 

FIVHA7 

FIWDA 

328 

323 

437 

278 

301 

103 

143 

0 

3 880 

3 999 

7 215 

7 180 

7 974 

2 334 

3 172 

0 

1 182 

10 400 

910 

621 

969 

435 

169 

317 

14 

6 619 

3 639 

4 202 

1 683 

481 

1 793 

11 

Total 

1 913 

35 753 

4 617 

28 826 

FIVHA1 

FIVHA2 

FIVHA3 

FIVHA4 

FIVHA5 

FIVHA6 

FIVHA7 

FIWDA 

248 

267 

281 

274 

300 

99 

133 

0 

2 758 

3 154 

5 027 

6 436 

6 849 

2 044 

2 607 

0 

1 040 

10 207 

850 

482 

975 

432 

166 

316 

14 

6 447 

3 473 

4 157 

1 641 

494 

1 742 

11 

Total 

1 602 

28 875 

4 275 

28 172 

Source: WISE electronic reporting. 

0 

54 

134 

19 

5 

3 

0 

61 

276 

0 

54 

134 

19 

5 

3 

0 

61 

276 

0 

6 108 

14 295 

3 320 

913 

105 

0 

7 766 

32 507 

0 

6 092 

14 337 

3 327 

916 

106 

0 

7 791 

32 570 

Figure 2.1 

 Proportion of surface water bodies in Finland designated as artificial, heavily 

modified and natural for the second and first cycles. Note that the numbers in 
parenthesis are the numbers of water bodies in each water category  

Source: WISE electronic reporting. 

28 

 
 
 
 
 
 
 
 
 
 
 
Table 2.2 

Size distribution of surface water bodies in Finland in the second and first cycles  

Year 

RBD 

River length (km) 

Lake area (km2) 

Coastal (km2) 

Minimum 

Maximum 

Average 

Minimum 

Maximum 

Average 

Minimum 

Maximum 

Average 

2016 

2016 

2016 

2016 

2016 

2016 

2016 

2016 

2010 

2010 

2010 

2010 

2010 

2010 

2010 

2010 

FIVHA1 

FIVHA2 

FIVHA3 

FIVHA4 

FIVHA5 

FIVHA6 

FIVHA7 

FIWDA 

FIVHA1 

FIVHA2 

FIVHA3 

FIVHA4 

FIVHA5 

FIVHA6 

FIVHA7 

FIWDA 

0.24 

0.14 

0.17 

1.02 

0.81 

1.82 

0.78 

0.14 

0.2 

0.42 

0.96 

0.4 

1.7 

2.1 

70.41 

83.75 

78.36 

187.81 

230.51 

250.37 

115.38 

68.89 

81.93 

86.29 

183 

227.2 

251.8 

152.6 

11.83 

12.38 

16.51 

25.83 

26.49 

22.66 

22.18 

11.12 

11.81 

17.89 

23.49 

22.83 

20.64 

19.6 

0.03 

0.04 

0.04 

0.03 

0.09 

0.36 

0.12 

0.17 

0.04 

0.02 

0.01 

0.03 

0.09 

0.46 

0.12 

0.17 

853.72 

459.15 

210.49 

902.71 

326.72 

52.84 

1 083.91 

1.99 

847.93 

458.67 

208.71 

878.14 

315.4 

53.34 

1 040.28 

1.98 

8.8 

7.27 

5.86 

4.34 

3.87 

2.84 

5.66 

0.78 

9.81 

7.58 

7.21 

4.26 

3.8 

2.98 

5.51 

0.77 

Source: WISE electronic reporting

2.67 

0.14 

0.9 

31.73 

15.58 

1 051.87 

1 532.13 

1 341.87 

767.59 

69.53 

113.12 

106.68 

174.73 

182.57 

35.14 

0.11 

1 561.26 

127.31 

2.7 

0.15 

0.73 

34.14 

15.31 

1 050.37 

1 542.39 

1 342.18 

767.76 

69.5 

112.82 

106.99 

175.12 

183.15 

35.51 

0.11 

1 565.93 

127.73 

29 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 2.3 

Number and area of delineated groundwater bodies in Finland for the second 

and first cycles  

Year 

RBD 

Number 

Area (km2) 

Minimum  Maximum  Average 

2016 

2016 

2016 

2016 

2016 

2016 

2016 

2016 

2016 

2010 

2010 

2010 

2010 

2010 

2010 

2010 

2010 

2010 

FIVHA1 

FIVHA2 

FIVHA3 

FIVHA4 

FIVHA5 

FIVHA6 

FIVHA7 

FIWDA 

705 

946 

1 078 

570 

331 

115 

23 

5 

Total 

3 773 

FIVHA1 

FIVHA2 

FIVHA3 

FIVHA4 

FIVHA5 

FIVHA6 

FIVHA7 

FIWDA 

705 

961 

1 093 

555 

322 

110 

24 

34 

0.01 

0.01 

0.01 

0.01 

0.1 

0.14 

0.12 

0.01 

0 

0 

0.08 

0.05 

0.1 

0.14 

0.12 

0.38 

55.48 

61.07 

80.08 

97.39 

13.14 

6.06 

52.1 

2.65 

55.48 

61.09 

80.2 

97.39 

13.14 

5.62 

52.1 

2.66 

3.12 

2.35 

2.52 

3.89 

1.23 

1.08 

3.51 

0.79 

3.17 

2.38 

2.7 

3.88 

1.21 

1.07 

3.38 

1.28 

Total 

3 804 

Source: WISE electronic reporting. 

30 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 2.4 

 Type of change in delineation of groundwater and surface water bodies in 

Finland between the second and first cycles  

Type of water body change for second cycle 
(wiseEvolutionType) 

Groundwater  

Rivers 

Lakes 

Coastal 

Aggregation 

Splitting 

Aggregation and splitting 

Creation 

Deletion 

Extended area 

No change 

2 

26 

301 

18 

8 

23 

1 

361 

51 

103 

146 

3 670 

1 584 

4 224 

276 

Total water bodies before deletion 

Delineated for second cycle (after deletion from first 
cycle) 

3 919 

3773 

1 931 

1 913 

4 668 

4 617 

276 

Source: WISE electronic reporting. 

2.1.2 Identification of transboundary water bodies  

Transboundary  river  and  lake  water  bodies  have  been  identified  in  all  the  following  RBDs: 

Vuoksi, Oulukoki-Iijoki, Kemijoki, Tornionjoki and Teno,  Näätämöjoki and Paatsjoki.  In the 
Tornionjoki RBD, there is a common basin with Sweden, and there was reported to be strong 

coordination. Status classification was coordinated for all transboundary surface water bodies 
(three lakes, two rivers and one coastal area), but coordination of delineation was not explicitly 

mentioned. Finland clarified that the coordination of delineation took place in preparation for 
the first RBMP and the same delineation was used again in the second RBMP, so no additional 

coordination  was  required.  In  the  Teno,  Näätämöjoki  and  Paatsjoki  RBD,  coordination  is  in 
place in delineation of transboundary surface water bodies with Norway. In the Vuoksi RBD, 

there was no mention of coordination with Russia on the delineation of water bodies. 

2.1.3 Typology of surface water bodies 

In  general,  the  number  of  types  remained  largely  the  same  between  the  first  and  the  second 

cycle (Table 2.5), with a 1 % increase overall. However, in the RBMPs it was noted that there 
was a review of typologies but the outcome is unclear. The Åland RBMP reported that lakes 

were reclassified more precisely into the calcium rich category (Rk) following the splitting of 
the  type  RrRk  into  two  in  the  national  typology,  however  only  the  national  type  Rk  was 

reported to WISE. 

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 2.5 

 Number of surface water body types at RBD level in Finland for the first and 

second cycles  

RBD 

Rivers 

Lakes 

Coastal 

2010 

2016 

2010 

2016 

2010 

2016 

FIVHA1 

FIVHA2 

FIVHA3 

FIVHA4 

FIVHA5 

FIVHA6 

FIVHA7 

FIWDA 

TOTAL 

10 

10 

10 

8 

10 

11 

11 

0 

17 

12 

10 

10 

8 

10 

11 

11 

0 

19 

13 

12 

12 

11 

11 

9 

6 

3 

14 

13 

12 

11 

12 

11 

10 

7 

1 

15 

0 

4 

9 

2 

2 

2 

0 

3 

0 

4 

9 

2 

2 

2 

0 

3 

14 

14 

Source: WISE electronic reporting. Note that the total is not the sum of the types in each RBD as some types are 
shared by RBDs. 

The typology of rivers and lakes in mainland Finland is based on the geographical, geological 
as  well  as  chemical  and  physical  characteristics  and  therefore  it  is  unclear  if  they  have  been 

made  biologically  relevant.  The  typology  of  lakes  in  the  Åland  RBD  is  also  based  on 
macrophytes in the case of calcium rich soil types. The typology of coastal waters is based on 

the geographical, chemical and physical characteristics, and it is made biologically relevant by 
using data on flora and fauna as an additional typology criteria. 

Member  States  were  asked  to  report  “Not  applicable”  if  there  is  no  corresponding 
intercalibration  type  for  national  types.  Many  national  types  (heavily  modified,  artificial  and 

natural) have been intercalibrated. However, in each of the RBDs there are several river, lake 
and coastal water bodies that were reported not to have a corresponding intercalibration type, 
approximately 60 % in total. 

The typology has been coordinated between Finland and Sweden in the Tornionjoki RBD and 
there  is  a  report  defining  the  common  typology.  For  the  Teno,  Näätämöjoki  and  Paatsjoki 

RBD, there is information on coordination with Norway of the international water bodies, but 
there is no direct reference to typology. In the Vuoksi RBD, there is coordination with Russia 

on monitoring, but typology again is not mentioned. 

2.1.4 Establishment of reference conditions for surface water bodies 

Table  2.6  shows  the  percentage  of  surface  water  body  types  in  Finland  with  reference 

conditions established for the first and second cycles. Type specific reference conditions have 

32 

 
 
 
 
been  established  for  most  relevant  biological  quality  elements  and  some  relevant 

physicochemical  biological  quality  elements  for  most  river  types.  Type  specific  reference 
conditions  were  reported  to  have  not  been  established  for  any  water  body  for  relevant 

hydromorphological  biological  quality  elements.  This  may  lead  to  some  weaknesses  in  the 
classification  of  status/potential  according  to  the  hydromorphological  biological  quality 

elements.  

Finland have been active in the EU intercalibration process for biological quality elements and 

the results of these intercalibration exercise has been transferred into national types. 

Table 2.6 

 Percentage of surface water body types in Finland with reference conditions 

established for all, some and none of the biological, hydromorphological and 
physicochemical quality elements. Numbers in parenthesis are the number of 

types in each category  

Water category  Water types 

Biological quality 
elements 

Hydromorphological 
quality elements 

Physicochemical 
quality elements 

Rivers (19) 

Lakes (15) 

Coastal (14) 

All  

Some 

None 

All  

Some 

None 

All  

Some 

None 

79 % 

11 % 

11 % 

40 % 

47 % 

13 % 

100 % 

89 % 

11 % 

87 % 

13 % 

100 % 

100 % 

100 % 

100 % 

Source: WISE electronic reporting 

2.1.5 Characteristics of groundwater bodies 

The geological  formation of the aquifer types  in which groundwater bodies reside have been 
reported.  All  groundwater  bodies  were  reported  not  to  be  layered.  Further  characterisation 

work has  been  reported  since the first  cycle  with  the inclusion of the  assessment  of linkages 
with surface water bodies and terrestrial ecosystems for all RBDs. 

2.1.6 Significant pressures on water bodies 

In the second cycle,  atmospheric deposition was  reported to affect  the largest  proportion (53 
%) of surface water bodies, followed by  no significant  pressures  (33 %)  and then by  diffuse 

agricultural pressures (24 %) (Figure 2.2). In the first cycle, Finland only reported pressures at 
an aggregated level. Overall there appears there was a large decrease in the number of water 

bodies  where  “No  pressures”  were  reported  between  the  first  and  the  second  cycle 

33 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
(approximately  a  50  %  reduction),  with  an  increase  in  the  reporting  of  point  and 

hydromorphological  pressures  and  a  significant  increase  in  the  number  of  diffuse  pressures 
(Figure 2.3).  

For  groundwater  bodies  the  significant  pressure  reported  most  frequently  was  diffuse  – 
transport with 7 % of groundwater bodies affected (Figure 2.2) and “no significant pressures” 

were reported most frequently. 

For the second RBMP, it was reported that all significant pressures were assessed for surface 

waters or groundwaters. 

34 

 
 
Figure 2.2 

 The  most  significant  pressures  on  surface  water  bodies  and  groundwater 

bodies in Finland for the second cycle 

Source: WISE electronic reporting 

35 

 
 
 
 
 
Figure 2.3 

 Comparison of pressures on surface water bodies in Finland in the first and 

second cycles. Pressures are presented at the aggregated level. Note there were 
6806 identified surface water bodies for the second RBMPs and 6153 for the 

first RBMPs 

Source: WISE electronic reporting. 

2.1.7 Definition and assessment of significant pressures on surface and groundwater 

For  surface  waters  numerical  tools  and  expert  judgement  were  used  for  defining  significant 
pressures  from  point  and  diffuse  sources,  abstraction  and  water  flow  pressures.  In  the  Åland 

RBD all the pressures on surface water were assessed using numerical tools. For surface water 
bodies,  significance  of  pressures  was  reported  as  being  linked  to  the  potential  failure  of 

objectives. Pressures were reported not to be defined in terms of thresholds, but significance is 
assessed using a type and extent of activity and pressure type7.  

For example, for point sources, the pressure was considered to be significant if the loading (or 
in combination with other pressures) may cause the status to be less than good. A significant 

pressure due to abstractions on surface water is similarly defined when there is potential for the 
status  to  be  less  than  good.  The  determination  of  the  significance  of  hydromorphological 

pressures (changes) was described as an expert assessment in the RBMP, using criteria set for 
assessing changes and scoring system. For diffuse sources there is an indication that thresholds 

are used for significant loading of phosphorus.  

7   Finland  clarified  that  for  Åland  thresholds  are  used  for  surface  water  and  this  is  an  error  in  the  WISE 

reporting. 

36 

 
 
 
                                                      
 
For  groundwaters,  numerical  tools  and  expert  judgement  were  used  for  defining  significant 

pressures  from  point  and  diffuse  sources,  abstraction  and  artificial  recharge  pressures.  The 
Åland RBD used expert judgement only for assessing diffuse pressures and artificial recharge 
pressures  were  not  assessed8.  For  groundwater  bodies  significance  of  pressures  has  been 
defined in terms of thresholds and the significance of pressures was reported to be linked to the 

potential failure of objectives. 

For  point  source  and  diffuse  pressures  in  groundwater,  the  RBMPs  explained  that  expert 

judgment was used to assess the risk using a classification scale and considering the chemical 
state  of  the  groundwater.  The  thresholds  were  based  on  the  chemical  quality  of  the 

groundwater and no “artificial” organic compounds should be detected in groundwater and no 
inorganic  compounds  over  a  defined  threshold.  No  thresholds  were  used  to  assess  water 

abstraction pressures. It is unclear from the RBMP and background documents how numerical 
tools were used to assess the significance of pressures on groundwater. 

2.1.8  Significant impacts on water bodies  

In  the  second  cycle,  the  most  significant  impact  on  surface  water  bodies  was  chemical 
pollution (51 % of surface water bodies)9, followed by nutrient pollution (29 %) (Figure 2.4). 
33  %  of  surface  water  bodies  were  reported  to  have  no  significant  impact.  97  %  of 

groundwater bodies were reported to have an “unknown impact type”. Finland did not report 
on impacts in the first cycle. 

8   Finland subsequently clarified that Åland do not have artificial recharge pressures.  
9   Finland further clarified that the reason chemical pollution is the most significant impact is due to the long-

range transport of airborne mercury. 

37 

 
 
                                                      
Figure 2.4 

 Significant impacts on surface water and groundwater bodies in Finland for 

the second cycle. Percentages of numbers of water bodies  

2.1.9 Groundwater bodies at risk of not meeting good status 

Source: WISE electronic reporting 

In five of the eight RBDs between 1.5 and 8 % of groundwater bodies were reported to be at 

risk of failing to meet good chemical status. The pollutants putting groundwater bodies at risk 
of failing good chemical status have been reported for all RBDs. 

38 

 
 
 
 
 
In four of the eight RBDs between 0.21 and 6.32 % of groundwater bodies were reported to be 

at risk of failing to meet good quantitative status. Further information on the quantitative and 
chemical status of groundwater bodies is provided in Chapters 5 and 6 of this report. 

2.1.10  Quantification of the gap and apportionment of pressures  

There  are  some  inconsistencies  in  the  pressures  for  which  measures  are  planned  and  the 
significant  pressures  reported  at  the  water  body  level.  For  example,  in  the  Kymijoki-Gulf  of 

Finland RBD, dams, barriers and locks from irrigation has been reported at the surface water 
body  level,  but  this  pressure  has  not  been  reported  as  being  tackled  in  the  Programme  of 

Measures. Similarly, in  the Vuoksi RBD, pressure diffuse  - atmospheric  deposition has  been 
reported  at  the  groundwater  bodies  level  but  this  pressure  has  not  been  reported  as  being 

tackled in the Programme of Measures. 

Four Priority Substances (mercury and its compounds, nickel and its compounds, cadmium and 

its  compounds,  tributyltin-cation)  were  reported  to  be  causing  the  failure  of  good  chemical 
status in Finland. The indicator gap values have not been reported for 2021 (or 2027), therefore 
it does not appear that there are measures to tackle these substances causing failure to achieve 
good  status  by  2027  in  all  RBDs10.  Further  information  on  the  implementation  of  the 
Programme of Measures is provided in Chapters 9 to 13 of this report. 

2.1.11  Inventories of emissions, discharges and losses of chemical substances 
Article 5 of the Environmental Quality Standards Directive (2008/105/EC11) requires Member 
States to establish an inventory of emissions, discharges and losses of all Priority Substances 

and the eight other pollutants listed in Part A of Annex I EQS Directive for each RBD, or part 
thereof,  lying  within  their  territory.  This  inventory  allows  Member  States  to  further  target 

measures to tackle pollution from priority substances. It should also inform the review of the 
monitoring networks, and allow the assessment of progress made in reducing (or suppressing) 

emissions, discharges and losses for priority substances. 

Finland reported that 36 substances consistently appeared in all the inventories for all RBDs. 
Only two substances (tributyltin-cation and brominated diphenylethers (congener numbers 28, 
47, 99, 100, 153 and 154)) were listed as being excluded from the inventories in each of the 

10   Finland highlighted that in case of mercury, a statement was made in Annex 0 that national measures do not 

exist for long-range transport of airborne pollutants (see also e.g. Oulujoki-Iijoki RBMP, p. 104-105). 

11   Directive 2008/105/EC of the European Parliament and of the Council of 16 December 2008 on environmental 
quality  standards  in  the  field  of  water  policy,  amending  and  subsequently  repealing  Council  Directives 
82/176/EEC, 83/513/EEC, 84/156/EEC, 84/491/EEC, 86/280/EEC and amending Directive 2000/60/EC of the 
European Parliament and of the Council  
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008L0105-20130913  

39 

 
 
                                                      
 
 
eight RBDs and three substances were not reported on, no explanation of this was found in the 
RBMPs12.  

The two step approach from the Common Implementation Strategy Guidance Document n°2813 
has been followed for all substances considered in the inventories.  

Tier  1  of  the  methodology  was  implemented  for  most  of  the  substances  in  the  inventories, 

including 
at  
RBD  level  (the  Guidance  Document  recommends  implementing  at  least  Tier  1+  2  for 

substances 

relevant 

deemed 

some 

the 

for 

of 

substances  deemed  relevant  at  RBD  level).  For  the  remaining  substances,  Tier  4  (source 
oriented  approach)  or  a  combination  of  Tier  1  (point  source  information)  +Tier  2  (riverine 

load) + sometimes Tier 3 (pathway oriented approach) were implemented.  

The data quality was not reported. 

2.2  Main changes in implementation and compliance since the first cycle 

There has been an overall increase in the number of river water bodies (19 %) but particularly 
in  the  Kokemäenjoki-Archipelago  Sea-Bothnian  Sea  (56  %),  Vuoksi  (32  %)  and  Kymijoki-

Gulf of Finland (21 %) RBDs. There has also been an overall increase in the number of lake 
water bodies of 8 %, with the highest increase in the Kokemäenjoki-Archipelago Sea-Bothnian 

Sea RBD of 29 %. The numbers of coastal water bodies remained the same. The numbers of 
groundwater  bodies  remained  largely  the  same.  In  general,  the  number  of  types  remained 

largely the same between the first and the second cycle, with a 1 % increase in types overall. 
However there was a review of typologies but the outcome was unclear.  

Overall it appears there was a large decrease in the number of occasions were “No pressures” 
were reported between the first cycle and the second cycle (approximately a 50 % reduction), 

with  an  increase  in  the  reporting  of  point  and  physical  and  hydrological  pressures  and  a 
significant increase in the number of diffuse pressures.  

12  Finland  further  stated  that  All  the  inventories  for  each  RBDs  are  published  in  the  web  pages 

http://www.ymparisto.fi/fi-
FI/Vesi/Vesiensuojelu/Vesienhoidon_suunnittelu_ja_yhteistyo/Suunnitteluopas/Vesipuitedirektiivin_mukaine
n_vesiympari%2829371%29 
Guidance 

Preparation 
Inventoryhttp://ec.europa.eu/environment/water/water-framework/facts_figures/guidance_docs_en.htm 

Substances 

Priority 

N° 

28 

of 

Emissions 

- 

13   CIS 

40 

 
 
 
 
                                                      
2.3  Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMPs  and  first  Programme  of 
Measures requested action on the following: 

  Recommendation: Finland needs to review its designation of water bodies, since whilst 
using system B, they have not achieved the same degree of differentiation as required 

by  system  A,  notably  as  regards  the  size  of  water  bodies.  Very  large  minimum  size 
thresholds  for  both  rivers  and  lakes,  that  is  not  in  compliance  with  the  WFD 

requirement, have been used. As a result, many waters are excluded from the RBMPs 
and only 4261 lake water bodies have been identified. 

Assessment:  There  was  a  slight  decrease  overall  in  the  minimum  size  of  rivers.  The 
minimum  size  criteria  reported  were  100  km2  catchment  area  for  rivers  and  0.5  km2 
surface area for lakes. The RBMP reported that smaller rivers and lakes have also been 
considered  if  they  were  particularly  relevant  for  water  management  or  other  reasons 

like nature conservation or water use. This is the reason why many new water bodies 
have  been  delineated.  For  example,  the  Vuoksi  RBD  delineated  new  water  bodies 

because of their nature value or because of the need to consider a wider river network. 
This recommendation has therefore been fulfilled. 

  Recommendation:  Clarify  the  methods  used  and  criteria  applied  for  determining 

pressures in the RBMPs.  

Assessment: For surface waters a combination of numerical tools and expert judgement 
were used for defining significant pressures from point and diffuse sources, abstraction 

and  water  flow  pressures.  In  the  Åland  RBD  all  the  pressures  were  assessed  using 
numerical  tools.  For  groundwaters  numerical  tools  and  expert  judgement  were  also 

used for defining significant pressures from point and diffuse sources, abstraction and 
artificial  recharge.  The  Åland  RBD  used  expert  judgement  only  for  assessing  diffuse 
pressures and artificial recharge pressures were not assessed.  

For surface water bodies it was reported that pressures were not to be defined in terms 

of thresholds but for groundwater bodies thresholds were reported as being used.  

The methodology  and thresholds for determining  significant  pressures were described 

but it is unclear if this recommendation has been fulfilled.  

41 

 
 
  Recommendation:  Moreover,  the  links  between  different  pressure-impact-measures 
should be further explained. Measures should be more concrete and include the final 
expected  achievements  and,  if  possible,  quantify  the  impact  in  terms  of  the  WFD 

objectives.  

  Recommendation:  Ensure close linkage of  the analysis  of  pressures  and impacts  with 

the determination of measures in the RBMPs in relation to chemical pollution. 

Assessment:  These  recommendations  apply  to  a  number  of  Topics.  In  terms  of 

characterisation  of  significant  pressures  or 
impacts,  for  surface  waters  and 
groundwaters  a  combination  of  numerical  tools  and  expert  judgement  were  used  for 

defining  significant  pressures.  It  is  not  possible  to  determine  how  quantitative  these 
methods were, based on the information available, but there appears to be a reliance on 

expert judgement. It has not been reported whether there are measures to achieve good 
status by 2027 in all RBDs by tackling Priority Substances reported to be causing the 

failure  of  good  chemical  status  in  Finland.  The  indicator  gap  values  do  not  appear  to 
have been reported for 2021 and 2027.Therefore this recommendation does not appear 

to have been fulfilled.  

42 

 
 
 
 
Topic 3

  Monitoring,  assessment  and  classification  of  ecological 

status in surface water bodies 

3.1  Assessment of implementation and compliance with WFD requirements 

in the second RBMPs 

3.1.1. Monitoring of ecological status/potential 

Monitoring programmes 

Article  8.1  of  the  WFD  requires  Member  States  to  establish  monitoring  programmes  for  the 

assessment of the status of surface water and of groundwater in order to provide a coherent and 
comprehensive overview of water status  within each RBD. Territorial waters are not  a water 

body category under WFD. However, it should be noted that under Article 2(1) of the WFD, 
territorial waters are included for the assessment and reporting of chemical status. 

Finland  reported  monitoring  programmes  for  each  of  the  water  categories  identified  in  the 
RBDs. No programmes were reported for transitional and territorial waters.  

Monitoring  sites  and  monitored  water  bodies  used  for  surveillance  and  operational 
monitoring  

Finland  reported  monitoring  programmes  for  each  of  the  water  categories  identified  in  the 

RBDs. Table 3.1 gives the number of sites used for different purposes for the second RBMPs 
and Table 3.2 compares the number of monitoring sites used for surveillance and operational 

purposes from the first to the second RBMPs. 

43 

 
 
 
 
Table 3.1 

 Number of monitoring sites in relevant water categories used for different 

purposes in Finland  

Monitoring Purpose 

Rivers  Lakes  Coastal  

BWD - Recreational or bathing water - WFD Annex IV.1.iii 

CHE - Chemical status 

DWD - Drinking water - WFD Annex IV.1.i 

ECO - Ecological status 

HAB – Protection of habitats or species depending on water - WFD Annex IV.1.v 

INT - International network of other international convention 

INV - Investigative monitoring 

MSF - Marine Strategy Framework Directive monitoring network 

OPE – Operational monitoring 

REF – Reference network monitoring site 

RIV - International network of a river convention (including bilateral agreements) 

SOE - EIONET State of Environment monitoring 

SUR - Surveillance monitoring 

Total sites irrespective of purpose 

Source: WISE electronic reporting  

16 

281 

281 

58 

227 

3 

9 

44 

962 

1 648 

18 

1 648 

102 

5 

2 

627 

166 

1 

208 

5 

962 

71 

3 

3 

4 

591 

81 

15 

136 

481 

962 

1 126 

1 648 

93 

281 

Table 3.2 

Number of sites used for surveillance and operational monitoring in Finland 

for the second and first RBMPs. Note that for reasons of comparability with 
data reported in 2010, the 2016 data does not take into account whether sites 

are used for ecological and/or chemical monitoring 

Rivers 

Lakes 

Coastal 

Surv. 

Op 

Surv. 

Op 

Surv. 

Op 

second RBMP 

FI_VHA1 

FI_VHA2 

FI_VHA3 

FI_VHA4 

FI_VHA5 

FI_VHA6 

FI_VHA7 

FI_WDA 

151 

124 

82 

71 

22 

14 

17 

0 

93 

165 

220 

77 

21 

11 

4 

0 

429 

318 

156 

149 

32 

17 

11 

14 

Total by type of site 

481 

591 

1 126 

130 

201 

191 

69 

13 

7 

2 

14 

627 

15 

61 

6 

6 

1 

4 

93 

78 

113 

12 

3 

3 

18 

227 

Total number of monitoring sites 

962 

1648 

281 

first RBMP 

FI_VHA1 

FI_VHA2 

268 

152 

88 

86 

6 

18 

93 

56 

44 

77 

44 

 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Rivers 

Lakes 

Coastal 

Surv. 

Op 

Surv. 

FI_VHA3 

FI_VHA4 

FI_VHA5 

FI_VHA6 

FI_VHA7 

FI_WDA 

Surv. 

28 

24 

23 

16 

22 

0 

Op 

31 

31 

16 

7 

4 

0 

51 

30 

36 

19 

20 

14 

38 

28 

12 

5 

0 

14 

271 

28 

2 

4 

2 

2 

44 

Op 

39 

6 

4 

3 

12 

82 

Total by type of site 

262 

210 

590 

Total number of monitoring sites 

472 

861 

126 

Sources: Member States electronic reporting to WISE 

Figure 3.1 

Percentage  of  water  bodies  included  in  surveillance  and  operational 
monitoring in Finland for the first RBMP (2010) and second RBMP (2016). 

Note  no  differentiation  is  made  between  water  bodies  included  in  ecological 
and/or chemical monitoring 

Source: WISE electronic reporting  

Overall there has been a 2.3 fold increase in the number of monitoring sites in Finland since 
the first RBMPs. Proportionally the largest increase was in coastal waters (2.8 fold), followed 

by  rivers  (2.4  fold)  and  lakes  (2.1  fold).  Generally  there  were  increased  numbers  of  sites  in 
most  RBDs  though  there  were  small  decreases  in  lakes  sites  in  three  RBDs,  and  in  coastal 

waters and rivers in one RBD. 

45 

 
 
  
  
  
 
 
In  general  there  were more surveillance than operational  sites in  lakes in  Finland whereas in 

rivers and coastal  waters there  were more operational  than surveillance sites. At the national 
level there have been increases in the number of surveillance and operational sites in the three 

water  categories  for  the  second  RBMPs  compared  to  the  first.  At  the  RBD  level,  there  were 
small decreases in the number of surveillance sites for the second RBMPs in some RBDs but 

much larger increases in some of the other RBDs. The numbers of operational sites increased 
in all RBDs and categories except for one RBD for coastal waters where there was no change 

and for another one where there was a decrease by one site. 

Monitoring sites and monitored water bodies used for ecological status/potential 

Figure 3.2 shows the proportion of water bodies subject to surveillance monitoring within each 
ecological status class. 

Figure 3.2 

Proportion  of  water  bodies  in  each  ecological  status/potential  class  that  is 
included in surveillance monitoring in Finland  

A differentiated presentation between ecological status and potential and including all types of quality element 
can be viewed here -  

Source: WISE electronic reporting  

Overall  there  has  been  a  significant  change  towards  a  science-based  assessment  of  the 
ecological  status.  In  the  Kymijoki-Gulf  of  Finland  RBMP  it  is  stated  that  the  focus  of 

monitoring  has  changed.  Previously  mostly  water  samples  were  taken.  Nowadays,  more 
benthic invertebrates, macrophytes, phytoplankton and phytobenthos samples are taken, water 

vegetation is mapped and the structure of the fish population is investigated to determine the 
overall  ecological  status  of  the  watercourses.  New  water  bodies  have  been  involved  in  the 

46 

 
 
 
typing,  classification  and  monitoring  of  watercourses  which  have  improved  the  regional 

coverage  of  monitoring.  At  the  same  time,  the  amount  and  density  of  sampling  has  been 
reduced  in  watercourses,  which  are  already  better  known.  Also  in  the  Åland  RBMP  it  is 

mentioned that more biological parameters are used in the monitoring than before. 

Transboundary surface water body monitoring 

Finland reported that eight monitoring sites in rivers or lakes were included in an international 
network of other international conventions and 16 were included in international network of a 

river convention including one lake site. 

Quality elements monitored (excluding River Basin Specific Pollutants) 

Table  3.3  illustrates  the  quality  elements  used  for  the  monitoring  of  lakes  and  rivers  for  the 
second plan: no differentiation is made between purposes of monitoring. 

Table 3.3 

 Quality elements monitored for the second RBMP in Finland (excluding 
River Basin Specific Pollutants). Note; quality elements may be used for 

surveillance and/or operational monitoring 

Biological quality elements 

Hydromorphological quality elements 

n
o
t
k
n
a
l
p
o
t
y
h
P

s
e
t
y
h
p
o
r
c
a
M

s
o
h
t
n
e
b
o
t
y
h
P

c
i
h
t
n
e
B

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

h
s
i
F

s

m
r
e
p
s
o
i
g
n
A

e
a
g
l
a
o
r
c
a
M

Rivers  Yes14  Yes  Yes  Yes  Yes 

s
e
i
c
e
p
s

r
e
h
t
O

c
i
t
a
u
q
a

r
e
h
t
O

a
r
o
l
f

Yes 

Lakes 

Yes  Yes  Yes  Yes  Yes  No  No  Yes 

Coastal  Yes  Yes 

Yes 

No  Yes  Yes 

r
o
l
a
c
i
g
o
l
o
r
d
y
H

e
m
i
g
e
r

l
a
d
i
t

Yes 

Yes 

No 

y
t
i
u
n
i
t
n
o
C

s
n
o
i
t
i
d
n
o
c

No 

l
a
c
i
g
o
l
o
h
p
r
o
M

s
n
o
i
t
i
d
n
o
c

No 

No 

No 

General physicochemical quality elements 

y
c
n
e
r
a
p
s
n
a
r
T

s
n
o
i
t
i
d
n
o
c

Yes 

Yes 

Yes 

l
a
m
r
e
h
T

s
n
o
i
t
i
d
n
o
c

Yes 

Yes 

Yes 

n
o
i
t
a
n
e
g
y
x
O

s
n
o
i
t
i
d
n
o
c

Yes 

Yes 

Yes 

y
t
i
n
i
l
a
S

s
n
o
i
t
i
d
n
o
c

Yes 

Yes 

Yes 

n
o
i
t
a
c
i
f
i
d
i
c
A

s
u
t
a
t
s

Yes 

Yes 

Yes 

n
e
g
o
r
t
i

N

s
n
o
i
t
i
d
n
o
c

Yes 

Yes 

Yes 

s
u
r
o
h
p
s
o
h
P

s
n
o
i
t
i
d
n
o
C

Yes 

Yes 

Yes 

r
e
h
t
O

r
o
f
d
n
a
n
i
m
r
e
t
e
d

t
n
e
i
r
t
u
n

s
n
o
i
t
i
d
n
o
c

No 

No 

No 

e
t
a
c
i
l
i
S

Yes 

Yes 

Yes 

Rivers 

Lakes 

Coastal 

14   Finland subsequently informed that phytoplankton was not monitored or used in the classification of river in 

spite of being reported as being monitored in the electronic reports to WISE. 

47 

 
 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
Source: WISE electronic reporting  

For the second RBMPs phytoplankton was the biological quality element predominantly used 
in the surveillance monitoring of coastal waters (97 % of water bodies included in surveillance 

monitoring)  and  lakes  (98  %).  Macroalgae  (52  %  of  water  bodies)  and  benthic  invertebrates 
(15 %) were used to a lesser extent in coastal waters, and benthic invertebrates (45 % of water 

bodies),  fish  (26  %  of  water  bodies),  macrophytes  (21  %  of  water  bodies)  and  phytobenthos 
(20 %) in  lakes.  For the surveillance monitoring of rivers, phytobenthos  were predominantly 

used  (73  %  of  water  bodies  included  in  surveillance  monitoring),  along  with  benthic 
invertebrates (60 %), fish (41 %), macrophytes (4 %) and phytoplankton (14 %). 

The  biological  quality  element  predominantly  used  for  surveillance  monitoring  for  the  first 
RBMPs in each water category was the same as those used for the second RBMPs. The other 

biological  quality  elements  used  were  also  the  same  but  the  proportion  of  water  bodies 
monitored for some biological quality elements decreased for the second RBMPs compared to 

the first.  For example, benthic invertebrates were monitored in  94 % of  coastal water bodies 
included  in  surveillance  monitoring  for  the  first  RBMPs  compared  to  15  %  for  the  second: 

there  were  similar  reductions  in  lakes  and  rivers.  In  addition,  there  was  a  reduction  in  the 
proportion of water bodies in surveillance monitoring where fish were monitored in lakes (-10 

%) and rivers (-13 %). 

Hydromorphological  quality  elements  were  not  reported  as  monitored  for  surveillance 
purposes in coastal waters in Finland for the second RBMPs15. Morphological conditions were 
not  monitored  in  lakes  and  rivers;  river  continuity  was  also  not  monitored  and  hydrological 
regime was monitored in rivers (13 % of water bodies in surveillance monitoring) and lakes (5 

% of water bodies). This was also the situation for the first RBMPs.  

General  physicochemical  quality  elements  were  monitored  to  the  same  extent  in  each  water 

category  for  the  first  and  second  RBMPs:  generally  over  95  %  of  water  bodies  included  in 
surveillance monitoring were monitored. 

Annex V of the WFD provide guidance on the frequency of monitoring of the different quality 
elements. Surveillance monitoring should be carried out for each monitoring site for a period 

of  one  year  during  the  period  covered  by  a  RBMP  i.e.  six  years.  For  phytoplankton  this 
equated  to  twice  during  the  monitoring  year  and  the  other  biological  quality  elements  once 

during the year. 

All four biological quality elements monitored for surveillance purposes in coastal waters were 

sampled at the minimum frequency at all sites. There is also a very high rate of sites monitored 

15   Finland  subsequently  informed  that  hydromorphological  quality  elements  were  monitored  in  coastal  waters 

even though this had not been reported in the Finland electronic reports to WISE. 

48 

 
 
                                                      
at the minimum frequencies in lakes and rivers for all used biological quality elements: at least 

94 % of sites were sampled at least at the minimum frequency. 

There  was  also  a  relative  high  proportion  of  sites  in  all  three  water  categories  that  were 

sampled  at  the  minimum  recommended  frequency  for  the  operational  monitoring  of  the 
biological  quality  elements.  The  lowest  rate  of  compliance  was  for  phytoplankton:  50  %  of 

sites in lakes, 66 % of sites in rivers and 88 % of sites in coastal waters. 

River Basin Specific Pollutants and matrices monitored 

Finland reported that nine different substances that are not Priority Substances were monitored 
as River Basin Specific Pollutants. These substances were monitored in water only.  

River Basin Specific Pollutants were not monitored in coastal waters, they were monitored in 
lakes (in one water body included in surveillance monitoring) and in rivers (in 4 % of the water 

bodies included in surveillance monitoring). 

Five substances were monitored in water in lakes (all in the Kokemäenjoki-Archipelago Sea-

Bothnian Sea RBD): Metamitron, dimethoate, MCPA, bronopol and prochloraz.  

Nine  substances  were  monitored  in  water  in  rivers:  Metamitron  (three  RBDs),  Dimethoate 
(three  RBDs),  dibutylphthalate  (three  RBDs),  Butyl  benzyl  phthalate  (BBP)  (four  RBDs), 

MCPA  (three  RBDs),  ethylenethiourea  (ETU)  (one  RBD),  tribenuron-methyl  (one  RBD), 
bronopol (three RBDs) and prochloraz (three RBDs). 

The  largest  number  of  sites  used  to  monitor  these  substances  in  Finland  was  18  for  five 
substances in rivers. The overall spatial coverage is low. 

the  monitoring  frequencies.  Finland 
Inconsistent 
subsequently  clarified  that  there  has  been  screenings  with  8-12  samples  per  year  in  rivers, 

information  has  been  reported  on 

which is above the WFD recommended minimum frequency in water. No reliable information 
is available for lakes. 

Table 3.4 shows the number of sites used to monitor River Basin Specific Pollutants in Finland 
in the first and second RBMP.  

49 

 
 
 
 
Table 3.4 

 Number of sites used to monitor River Basin Specific Pollutants for the 

second RBMP and non-priority specific pollutants and/or other national 
pollutants for the first RBMP in Finland. Note the data from both RBMP may 

not be fully comparable as different definitions were used and also not all 
Member State reported information at the site level meaning that there were 

no equivalent data for the first RBMP  

RBMP 

1st 

2nd 

Sites used to monitor non-priority specific pollutants and/or other 
national pollutants  

Sites used to monitor River Basin Specific Pollutants  

Source: WISE electronic reporting 

Rivers 

Lakes 

15 

20 

10 

1 

3.1.2.  Ecological Status/potential of surface water  

The  ecological  status/potential  of  surface  water  bodies  in  Finland  for  the  second  RBMP  is 
illustrated in Map 3.1. This is based on the most recent assessment of status. 

50 

 
 
 
 
 
Map 3.1 

 Ecological status or potential of surface water bodies in Finland based on the 

most recently assessed status/potential of the surface water bodies 

Note: Standard colours based on WFD Annex V, Article 1.4.2(i).  

High 

Good 

Moderate 

Poor  

Bad 

Unknown 

River Basin Districts 

Countries outside the European Union 

Source: WISE, Eurostat (country borders) 

A differentiated presentation of this data between ecological status and potential and including all types of quality 
element can be viewed here -  

Figure 3.3 shows the confidence in the classification of ecological status/potential. There has 
been  a  significant  improvement  in  the  confidence  of  the  classification  of  ecological 

status/potential of surface water bodies since the first RBMPs. For the second RBMPs 31 % of 
surface water bodies were classified with high confidence compared to 3 % for the first, and 1 

51 

 
 
 
 
  
  
  
  
  
  
  
  
 
% of surface water bodies with no information on confidence for the second RBMPs compared 

to 52 % for the first. 

Figure 3.3   Confidence  in  the  classification  of  ecological  status  or  potential  of  surface 

water bodies in Finland based on the most recently assessed status/potential  

Source: WISE electronic reporting  

Figure 3.4 compares the ecological status of surface water bodies in Finland for the first plan 
with that for the second plan (based on the most recent assessment of status/potential) and that 

expected by 2015). Overall ecological status has been reported for all delineated water bodies, 
which was not done for the first RBMPs, when only 50 % were classified. The confidence has 

improved compared to the first RBMPs, especially for rivers and lakes.  

The  overall  ecological  status  has  not  improved  significantly  since  the  first  RBMPs,  and  the 

status changes at the quality element level is not reported, due to lack of available data for the 
first  RBMPs  (Annex  0).  This  lack  of  data  is  hard  to  understand,  as  Finland  has  compiled  a 

substantial amount of data for several biological  quality elements during that first RBMPs in 
order to develop and intercalibrate the assessment methods. In the Åland RBD, the ecological 

status/potential in coastal waters and lakes is much worse than reported for the first RBMP, but 
this is probably due to changes in monitoring and assessment methods. 

52 

 
 
 
 
 
Figure 3.4   Ecological  status  or  potential  of  surface  water  bodies  in  Finland  for  the 

second RBMPs, for the first RBMPs and expected in 2015. The number in the parenthesis is 
the  number  of  surface  water  bodies  for  both  cycles.  Note  the  period  of  the  assessment  of 

status for the second RBMPs was 2006 to 2013. The year of the assessment of status for the 
first RBMPs is not known 

Source: WISE electronic reporting 

According  to  the  Kymijoki-Gulf  of  Finland  RBMP  the  ecological  status  of  surface  water 

bodies has generally remained the same in comparison to the previous classification. In most of 
the  cases,  changes  in  class  are  caused  by  methodological  changes,  new  monitoring  data  and 

changes  in  the  typology.  In  the  Åland  RBD,  the  ecological  status  of  coastal  water  bodies 
(measured  by  chlorophyll  a)  has  improved  in  three  areas  and  deteriorated  in  five  areas.  The 

changes  are  considered  to  be  mainly  caused  by  the  general  state  of  the  Baltic  Sea.  The 
chlorophyll  levels  increased  in  all  reported  lakes.  Changes  cannot  be  assessed  using  more 

parameters since the data from the first RBMPs is missing. 

Member States were asked to report the expected date for the achievement of good ecological 
status/potential. The information for Finland is shown in Figure 3.5. 

53 

 
 
 
 
 
Figure 3.5   Expected  date  of  achievement  of  good  ecological  status/potential  of  surface 

water  bodies  in  Finland.  The  number  in  the  parenthesis  is  the  number  of  water  bodies  in 
each category  

Source: WISE electronic reporting  

Classification of ecological status in terms of each classified quality element 

Figure  3.6  shows  the  ecological  status/potential  of  water  bodies  for  each  biological  quality 

elements used in the classification of surface water bodies. 

54 

 
 
 
 
 
Figure 3.6   Ecological  status/potential  of  the  biological  quality  elements  used  in  the 

classification of surface waters in Finland 

Note that water bodies with unknown status/potential have been excluded from 

the presentation 

Source: WISE electronic reporting. A differentiated presentation of this data between ecological status and 

potential and including all types of quality element can be viewed here  

Figure  3.7  compares  the  classification  of  biological  quality  elements  in  terms  of  ecological 

status/potential  for  the  two  cycles.  It  should  be  noted  that  this  comparison  should  be  treated 
with  some  caution  as  there  are  differences  between  the  numbers  of  surface  water  bodies 

classified for individual elements from the first to the second RBMPs. 

55 

 
 
 
 
 
Figure 3.7   Comparison  of  ecological  status/potential  in  Finland  according  to  classified 

biological quality elements in rivers and lakes from the first to the second RBMPs. Note the 
number in brackets is the number of surface water bodies with status 

Source: Surface water bodies: Quality element status  

Figure 3.8 and Figure 3.9 illustrate the basis of the classification of ecological status/potential 

of rivers and lakes in Finland for the second RBMP. The classification is more often based on 
several  quality  elements  in  all water  categories and on more than had been used for the first 

RBMPs,  although  for  many  water  bodies  in  lakes  and  coastal  waters,  the  assessment  is  still 
based on phytoplankton  and nutrients  only. The  nutrient  quality  elements are reported as not 

being  monitored,  or  assessed  in  coastal  waters  in  the  Åland  RBD.    Finland  subsequently 
clarified that there is monitoring in more than 100 sites in coastal waters of the Åland RBD. 
The  results  of  monitoring  are  used  for  classification.  This  information  is  contrary  to  the 

information reported electronically to WISE for this RBD. 

56 

 
 
 
 
Figure 3.8   The  classification  of  the  ecological  status  or  potential  of  surface  waters  in 

Finland using 1, 2, 3 or 4 types of quality element  

Note: The 4 types are: biological; hydromorphological, general physicochemical 

and River Basin Specific Pollutants 

Source: WISE electronic reporting  

Figure 3.9   The  percentage  of  surface  water  bodies  in  Finland  where  no  biological 

quality  element  or  no  hydromorphological  (HYMO)  or  no  general  physicochemical 
(PHYSCHEM)  or  no  River  Basin  Specific  Pollutant  (RBSP)  has  been  used  in  the 

classification of ecological status or potential 

Source: WISE electronic reporting  

The basis of the classification of the individual quality elements is illustrated in Figure 3.10  

57 

 
 
 
 
Figure 3.10   Basis of the classification of ecological status/potential in Finland. The 

percentages are in terms of all waterbodies in each category.16 

Source: WISE electronic reporting 

16 Finland subsequently explained that migratory barriers in the mouth of a river system or in the outlet of a lake 

inside a river system have been considered as part of river continuity when they affect the migratory species of 
the respective river system. Continuity has been used in the classification of coastal waters and lakes as well as 
rivers. 

58 

 
 
 
                                                      
There is very little change in ecological status since the first RBMPs, and quality element level 

change  is  not  reported  due  to  lack  of  comparable  data  for  the  first  RBMPs  (Annex  0 
justification). The ecological status in coastal waters is still less than good for all water bodies 

in the Kymijoki-Gulf of Finland RBD and for 93 % of water bodies in the Åland RBD, which 
is a deterioration compared to the first RBMPs as 68 % were less than good. For rivers in the 

Kymijoki-Gulf  of  Finland  RBD,  the  proportion  less  than  good  is  53  %,  which  is  almost  the 
same  as  for  the  first  RBMPs.  (No  rivers  are  delineated  in  the  Åland  RBD).  For  lakes,  the 

proportion less than good is now 26 % in the Kymijoki-Gulf of Finland RBD, which is a slight 
improvement  from  31  %  less  than  good  for  the  first  RBMP,  while  in  the  Åland  RBD  the 

proportion less than good is higher for the second RBMP (57 %) than for the first, when all the 
lakes  were  reported  to  be  in  high  or  good  ecological  status.  The  reason  for  the  negative 

changes  is  probably  a  change  of  methods  from  expert  judgement  for  the  first  RBMPs  to 
monitoring for the second. 

Use of monitoring results for classification 

The  majority  of  water  bodies  was  reported  to  be  classified  based  on  monitoring  at  quality 
element  level.  Of  the  hydromorphological  quality  elements,  hydrological  regime  is  the  only 

element monitored in rivers and lakes: all elements are used in classification only on the basis 
of expert judgement.  

Finland  reported  that  the  grouping  of  water  bodies  has  been  used  in  extrapolating  the 
assessment and classification of ecological status from monitored water bodies to those water 

bodies with no monitoring sites. However, this is not consistent with the information reported 
on the means of classification of quality elements where grouping was reported not to be used. 

For the first and the second RBMPs, no water bodies were reported as being directly monitored 
for  morphological  quality  elements,  and  close  to  zero  monitoring  of  River  Basin  Specific 

Pollutants were reported. However, all those quality elements have been classified for all water 
bodies in all water categories (based on expert judgement), and all water bodies were classified 

in  good  status  for  the  River  Basin  Specific  Pollutants.  River  continuity  is  reported  as  being 
classified for rivers, coastal waters and for lakes17. Hydromorphological  quality elements  are 
used  for  classification,  but  no  reference  conditions  have  been  established  and  they  are  not 
for  classification  of  both 
linked 

the  biological  quality  elements.  The  basis 

to 

17 Finland subsequently explained that migratory barriers in a river system or in the outlet of a lake inside a river 
system  have  been  considered  as  part  of  river  continuity  when  they  affect  the  migratory  species  of  the 
respective river system. 

59 

 
 
                                                      
hydromorphological  quality  elements  and  River  Basin  Specific  Pollutants  seems  to  be 

unreliable.  

For  general  physicochemical  quality  elements,  the  classification  is  based  only  on  expert 

judgement  in  the  Åland  RBD  for  total  nitrogen  and  total  phosphorus.  No  general 
physicochemical standards have been reported for this RBD. In the Kymijoki-Gulf of Finland 

RBD,  many  parameters  were  monitored,  but  not  used  for  classification  (oxygen  in  all  water 
categories,  transparency  in  lakes,  acidification  parameters  in  lakes,  thermal  conditions  and 

salinity conditions). It is not clear whether the data will be used for development of assessment 
methods or for other purposes. 

Assessment methods and classification of biological quality elements 

There  are  now  assessment  methods  developed  for  all  relevant  biological  quality  elements, 

including  angiosperms  in  coastal  waters,  macrophytes  in  rivers  and  phytobenthos  in  lakes, 
which were missing for the first RBMPs. However, the method for macrophytes in rivers is not 

reported  in  the  electronic  report  to  WISE,  probably  due  to  very  recent  completion  and 
intercalibration of the method.  

The assessment methods were reported to be sensitive to most reported significant impacts, the 

exception being for chemical pollution and acidification in coastal waters. 

Intercalibration of biological assessment methods and national classification systems 

Many Finnish water body types are linked to the common intercalibration types, but it is not 
clear  which  biological  quality  element  methods  have  been  intercalibrated,  and  how  the  class 

boundaries  have  been  set  for  national  types  not  linked  to  the  common  intercalibration  types. 
For example, none of the three national types for coastal waters in the Åland RBD are linked to 

any  common  intercalibration  type,  although  the  methods  used  are  the  same  that  were 
intercalibrated for Sweden and Finland. 

Assessment methods for hydromorphological quality elements 

All the relevant hydromorphological quality elements were reported to be assessed in terms of 

ecological status/potential in rivers, lakes and coastal waters but the classification boundaries 
are not related to the class boundaries for the sensitive biological quality elements. There are 

no  reference  conditions  reported  for  hydromorphological  quality  elements  in  any  water 
category.  

60 

 
 
Hydromorphological quality elements are nevertheless used for assessment of ecological status 
based on expert judgement: the basis for this expert judgement is not clear18. 

The second RBMPs were examined for information on the major changes between the first and 

second RBMPs in the assessment methodologies for the hydromorphological quality elements. 
For rivers and lakes the approach is the same, but more care is taken that a detailed assessment 

is  carried  out  for  all  water  bodies  where  hydromorphological  aspects  are  identified  as  a 
significant factor deteriorating the quality  of the  water body.  For  coastal  waters,  also  similar 

approach is used as during the first RBMPs but more care is taken to include expert views and 
the  views  of  different  stakeholders  when  the  significance  of  the  effects  is  assessed.  The 

methodology is the same in all RBMPs. 

Assessment methods for general physicochemical quality elements 

Only  a  limited  number  of  general  physicochemical  quality  elements  were  used  in  the 
assessment  of  ecological  status/potential  of  surface  water  bodies:  nutrient  conditions  in  all 

three water categories, transparency in coastal waters and acidification status in rivers. There 
are therefore significant gaps in the elements required to be assessed in all categories. 

Type-specific  standards  were  reported  for  nutrients  in  all  water  categories  in  many  types  of 

water bodies, acidification parameters in rivers and secchi depth in coastal waters, and all are 
reported as being compatible with the good-moderate status/potential boundaries for sensitive 

biological quality elements. Standards are not developed for oxygen in any water category, or 
for secchi depth in lakes, but these quality elements were monitored. 

Selection of River Basin Specific Pollutants and use of Environmental Quality Standards 

There is no information on how the River Basin Specific Pollutants have been identified in the 
second RBMPs19. No metal has been identified as River Basin Specific Pollutants. 

Finland  reported  nine  different  River  Basin  Specific  Pollutants  that  are  monitored  and  13 
different  River  Basin  Specific  Pollutants  for  which  Environmental  Quality  Standards  have 
been set. Environmental Quality Standards have been set for all substances monitored. It is not 

18 Finland subsequently stated that expert judgement is based on existing reports, field measurements, databases 

and map investigations for most of the quality elements in large water bodies. 

19 Finland subsequently clarified that there were no changes since the first RBMPs. The selection of River Basin 
Specific  Pollutants  was  reported  for  the  first  RBMPs  according  to  rules  that  are  outlined  in  the  following 
documents: 
-  Londesborough, S.  2003 Proposal for a Selection of National Priority Substances. Finnish Environment 

622. 

-  Londesborough,  S.    2005  Proposal  for  Environmental  Water  Quality  Standards  in  Finland.  Finnish 

Environment 749 

61 

 
 
                                                      
clear whether and how the substances not monitored were taken into account in the assessment 

of status. 

13 Environmental  Quality  Standards  apply to  coastal  waters though none was  reported to  be 

monitored in coastal waters. There were Environmental Quality Standards for 12 substances in 
rivers and for 13 substances in lakes.  

12  Environmental  Quality  Standards  were  reported  in  water,  one  in  sediment  (for  3,  5-
dimethyl-phenol, although this substance is not reported as monitored). The standards have not 
been derived in accordance with the 2011 Technical Guidance Document No 2720.  

The  analytical  methods  used  for  the  substances  meet  the  minimum  performance  criteria  laid 
down in Article 4(1) of Directive 2009/90/EC21 for the strictest standard applied in river and 
lakes. However, for four substances in coastal water the analytical method does not meet the 

minimum  performance  criteria  laid  down  in  Article  4(1),  but  does  comply  with  the 
requirements laid down in Article 4(2) for the strictest standard applied.  

River Basin Specific Pollutants are classified mainly using expert judgement, only a few water 
bodies are classified based on monitoring results. It is not clear on what information this expert 
judgment  was  based.  All  water  bodies  were  reported  to  be  in  good  status  for  River  Basin 

Specific Pollutants. However it should be highlighted that the spatial coverage of monitoring is 
low,  and  environmental  quality  standards  were  not  set  according  to  the  Technical  Guidance 

Document, which reduces the reliability of the assessment. 

Overall classification of ecological status (one-out, all-out principle) 

The  one-out,  all-out  principle  has  been  used  in  all  RBDs.  It  is  not  clear  how  the  change  in 
combination rules from the weight-of-evidence approach used for the first RBMPs to the one-

out-all-out  approach  for  the  second  RBMPs  affects  the  comparability  of  ecological  status 
assessment. There is no information available on how the no-deterioration principle has been 

applied, nor on how they deal with spatial variability within water bodies. 

20   https://circabc.europa.eu/sd/a/0cc3581b-5f65-4b6f-91c6-433a1e947838/TGD-EQS%20CIS-

WFD%2027%20EC%202011.pdf 

21   Directive  2009/90/EC  of  31  July  2009  laying  down,  pursuant  to  Directive  2000/60/EC  of  the  European 
Parliament and of the  Council,  technical specifications  for chemical analysis and  monitoring of  water status 
http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1524565750309&uri=CELEX:32009L0090 

62 

 
 
                                                      
3.2  Main changes in implementation and compliance since the first RBMPs 

Overall there has been a 2.3 fold increase in the number of monitoring sites in Finland since 
the first RBMPs. Proportionally the largest increase was in coastal waters (2.8 fold), followed 

by rivers (2.4 fold) and lakes (2.1 fold): Finland did not identify any transitional water bodies. 
Generally  there  were  increased  numbers  of  sites  in  most  RBDs  though  there  were  small 

decrease in lakes sites in three RBDs, and in coastal waters and rivers in one RBD. 

For Finland as a whole, for the second RBMPs around 20 % of water bodies in coastal waters, 
lakes and rivers were included in surveillance monitoring. This was an increase from the first 

RBMPs where 11 % to 15 % of water bodies were included in surveillance monitoring. 

The  biological  quality  element  predominantly  used  for  surveillance  monitoring  for  the  first 

RBMPs in each water category was the same as those used for the second. The other biological 
quality  elements  used  were  also  the  same  but  the  proportion  of  water  bodies  monitored  for 

some biological quality elements decreased for the second RBMPs compared to the first. For 
example,  benthic  invertebrates  were  monitored  in  94  %  of  coastal  water  bodies  included  in 

surveillance  monitoring  for  the  first  RBMPs  compared  to  15  %  for  the  second:  there  were 
similar reductions in  lakes and rivers.  In  addition,  there was a reduction in  the proportion of 

water bodies in surveillance monitoring where fish were monitored in lakes (-10 %) and rivers 
(-13 %). 

Ecological status has deteriorated for lakes and coastal waters in the Åland RBD, probably due 
to improved monitoring and assessment methods. Lakes in the Åland RBD are assessed with 

more biological quality elements / quality elements for the second RBMP than for the first. 

The proportion of surface water bodies of unknown status/potential has decreased from 50 % 

to 2 %. The confidence the classification has also improved. 

The classification is based on more comprehensive methods that consider more of the relevant 

biological  quality  elements,  all  hydromorphological  quality  elements  (although  not  all  are 
relevant) and some physicochemical quality elements (mainly nutrients). 

The gaps in the biological quality element methods highlighted from the assessment of the first 
RBMPs have now been covered, although some very recently, so not reported electronically to 

WISE. Physicochemical  standards have been reported for nutrients  for specific types and are 
related  to  the  good-moderate  status/potential  boundaries  for  the  sensitive  biological  quality 

elements. Hydromorphological quality elements are used for classification, but are reported not 
to be monitored.  

63 

 
 
The one-out, all-out principle has been used for the second RBMPs, in contrast to the first. 

3.3  Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMPs  and  first  Programme  of 

Measures requested action on the following: 

  Recommendation 8: There is a large proportion of surface water bodies in Finland for 
which the status  is  unknown. Some RBDs have a high  proportion  of  water bodies for 
which  status  is  unknown.  Finland  therefore  needs  to  increase  its  efforts  in  this  first 

cycle  to  decrease  this  lack  of  knowledge  and  uncertainty.  Some  recommendations 
below  are  crucial  to  ensure  this  improvement.  Finland  needs  to  improve  the  surface 

water  monitoring  and 
the  reporting  of  monitoring  networks, 
methodologies and results, and to extend the monitoring programmes to cover all water 

the  quality  of 

bodies (including smaller water bodies) and all required quality elements. 

Assessment: A large percentage of surface water bodies have been reported as having 

unknown status/potential in the first RBMP (52.8 % of 6153 surface water bodies). For 
the  second  RBMPs  this  was  reduced  to  1.4  %  of  the  6806  surface  water  bodies. 

Significant progress has therefore been made. 

Some  required  quality  elements  were  not  monitored  (e.g.  morphological  conditions, 

macrophytes  in  rivers  etc.).  Considering  hydromorphology  only  in  operational 
monitoring programmes (as was in 2013) and not in surveillance ones is not consistent 

with the WFD.  

Macrophytes  in  rivers  are  only  monitored  in  around  1  %  of  river  water  bodies. 
Morphological conditions are not included in surveillance monitoring. There has been 

very limited progress on this aspect. 

The number of small water bodies (less than 0.5 km²) monitored in the second RBMPs 

has increased since the first RBMPs. For coastal water bodies, 1 of the 5 water bodies 
which are smaller than 0.5 km² is monitored in the second RBMPs, compared to none 

in the first. For lakes, the proportion of small water bodies monitored increased from 4 
% of the total number of monitored lakes to 6 %. For rivers, the number of small water 

bodies  monitored  increased  from  2  to  17  Therefore,  regarding  the  number  of  small 
water bodies monitored, there has been progress from the first to the second RBMPs. 

64 

 
 
A  significant  proportion  of  surface  water  bodies  included  in  surveillance  monitoring 

were  not  monitored  for  all  required  biological  quality  elements.  There  is  still  a 
predominant focus on the monitoring of phytoplankton in coastal waters and lakes, and 

on the physicochemical quality elements in all water categories. There has been some 
progress on this aspect but there are still important gaps on this issue. 

Some of the biological quality element methods missing for the first RBMPs have now 
been  developed.  The  following  new  biological  quality  element  methods  have  been 

developed:  rivers  macrophytes,  lakes  phytobenthos  and  coastal  waters  angiosperms. 
The sensitivity to impacts has been reported for each biological quality element though 

there are gaps for two impact types in coastal waters.  

In conclusion, the recommendation has been partially fulfilled. 

  Recommendation  9:  Finland  needs  to  base  its  classification  on  such  extended 
monitoring  results.  The  ecological  status  assessments  are  based  primarily  on  expert 

judgement but not on WFD compliant methods, and there is a significant shortcoming 
in the availability of data for classification. 

Assessment:  The  results  of  monitoring  have  been  overwhelmingly  used  for  the 
classification of biological and physicochemical quality element with expert judgment 

only  being  used  in  a  very  few  cases.  However,  the  hydromorphological  quality 
elements have been exclusively classified by expert judgment. Hydrological regime is 

monitored in rivers and lakes, but morphological quality elements and river continuity 
are  not  monitored  in  any  water  category.  The  recommendation  has  been  partially 

fulfilled because of the lack of monitoring of, and the use of expert judgement for the 
classification of, hydromorphological quality elements. 

  Recommendation 10: The identification of River Basin Specific Pollutants needs to be 
more  transparent,  with  clear  information  of  how  pollutants  were  selected,  how  and 

where  they  were  monitored,  and  where  there  are  exceedances  and  how  such 
exceedances have been taken into account in the assessment of ecological status. 

Assessment:  It  is  not  clear  how  River  Basin  Specific  Pollutants  have  been  identified. 
(However  Finland  reported  that  the  CIS  Guidance  Document  n°27  was  not  used  to 

the  Environmental  Quality  Standards).  Finland  has  provided  detailed 
derive 
information on how and where the substances are monitored. It is important to note that 
River  Basin  Specific  Pollutants  were  not  monitored  in  coastal  waters,  and  the  spatial 
coverage of monitoring  for lakes and rivers is low. Overall nine River Basin Specific 

65 

 
 
were  reported  to  be  monitored  (only  in  water)  while  standards  were  reported  for  13 

substances:  it  is  not  clear  whether  and  how  the  substances  not  monitored  were  taken 
into  account  in  the  assessment  of  status.  Information  reported  on  monitoring 

frequencies  is  inconsistent,  but  Finland  subsequently  clarified  that  the  monitoring 
frequencies in rivers are higher than the minimum recommended frequency. No reliable 

information  is  available  on  monitoring  frequencies  in  lakes.  No  failures  of  good 
ecological status/potential were reported for River Basin Specific Pollutants. The one-

out-all-out has been applied to assess ecological status. In most cases, the status of river 
basin  specific  Pollutants  has  been  determined  based  on  expert  judgment,  and  no 

information  is  available  on  the  basis  for  this  expert  judgment.  In  conclusion,  the 
recommendation has been partially fulfilled. 

  Recommendation  11:  Provide  more  information  about  the  threshold  values/standards 
that  have  been  set  to  support  good  status,  not  only  for  surface  waters,  but  also  for 

groundwater, including coastal waters. 

Assessment:  The  Commission  advised  Finland  to  set  out  the  calculations  they  have 

made of the nitrate and phosphate loading from agriculture that needs to be reduced in 
order to allow for nutrient conditions in water bodies that would be consistent with the 

achievement of good status.  

Finland reported standards for total nitrogen and total phosphorus in rivers, lakes and 

coastal  waters,  and  are  related  to  the  good-moderate  boundary  of  the  sensitive 
biological quality element i.e. support good status. Finland did not report the loads of 
phosphorus and nitrogen that need to be reduced to achieve WFD objectives22. On this 
basis the recommendation has been partially fulfilled. 

22 Finland subsequently stated that this information was not reported in WISE but was included in the reports. 

66 

 
 
 
                                                      
Topic 4

  Monitoring,  assessment  and  classification  of  chemical 

status in surface water bodies 

4.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle  

4.1.1. Monitoring of chemical status in surface waters 

Monitoring sites and monitored water bodies used for monitoring of chemical status  

Member  States  have  to  implement  surveillance  and  operational  monitoring  programmes  in 
accordance with the requirements of the WFD and of the EQS Directive, for the assessment of 

ecological status/potential and chemical status.  

Surveillance monitoring programmes should allow Member States to supplement and validate 

the  impact  assessment  procedure,  to  efficiently  and  effectively  review  the  design  of  their 
monitoring programmes, and to  assess the long-term  changes in  natural  conditions  and those 

resulting  from  widespread  anthropogenic  activity.  For  operational  purposes,  monitoring  is 
required to establish the status of waterbodies identified as being at risk of failing to meet their 

environmental objectives, and to assess any changes in the status of such waterbodies resulting 
from the programme of measures. 

Section 3.1.1 of this report summarises the characteristics of the surveillance and operational 
monitoring programmes in Finland for the second RBMP.  

Figure  4.1  summarises  the  proportion  of  sites  used  for  the  monitoring  of  chemical  status  in 
rivers, lakes and coastal waters for the second RBMP (territorial waters are not monitored and 

their chemical status is not assessed). In this figure, no distinction is made between sites used 
for  surveillance  and/or  operational  purposes.  More  detailed  information  can  be  found  on  the 
website of the European Environment Agency23.  

 Figure 4.1 shows that all sites are used for the monitoring of chemical and ecological status. 

However, Finland provided additional information stating that there has been a reporting error 
and  in  fact  not  all  monitoring  sites  are  used  for  monitoring  of  chemical  status.  Finland  also 

stated that data is rarely available compared with the large number of waterbodies.  

23   https://www.eea.europa.eu/publications/state-of-water 

67 

 
 
 
                                                      
For the second RBMP, for surface water bodies across all RBDs in Finland, there are a similar 

proportion  of  sites  monitored  for  Priority  Substances  under  surveillance  monitoring  and 
operational monitoring (11 % and 10 % respectively). 

Figure 4.1 

 Proportion  of  sites  used  for  monitoring  of  chemical  status  and,  for 
comparison, ecological status, in Finland. The number in parenthesis next to 

the  category  is  the  total  number  of  monitoring  sites  irrespective  of  their 
purpose24 

Source: WISE electronic reporting - Finland subsequently clarified that there has been a reporting error and that 

not all monitoring sites are used for monitoring of chemical status. 

Figure 4.2 summarises the proportion of water bodies monitored for chemical  status  in  lakes 

and rivers for the second RBMP. In this figure, no distinction is made between water bodies 
monitored for surveillance and/or operational purposes. Also given is the proportion of water 

bodies monitored for any purpose and, for comparative purpose, those for ecological status. 

In Finland overall, 48 % of river water bodies, 35 % of lake water bodies and 74 % of coastal 

water bodies were monitored for chemical status.  

24   Finland subsequently clarified that there has been a reporting error and that not all monitoring sites are used 

for monitoring of chemical status. 

68 

 
 
 
 
                                                      
In most RBDs in  Finland, there is  a small number of surface  water bodies failing to  achieve 

good  chemical  status  being  monitored  as  part  of  the  operational  monitoring  programme  for 
chemical status i.e. on average  4.5 % . However, a higher percentage of water bodies failing to 

achieve  good  chemical  status  are  monitored  in  the  following  RBDs:  Kemijoki  (100  %), 
Kokemäenjoki-Archipelago  Sea-Bothnian  Sea  (50  %  of  coastal  waters  and  13  %  of  rivers), 

Kymijoki-Gulf  of  Finland  (33  %  of  coastal  waters).  All  of  the  surface  water  bodies  in  the 
Tornionjoki,  Teno, Näätämöjoki  and Paatsjoki  and Åland RBDs were  reported to  be at  good 

status. 

Figure 4.2 

 Proportion  of  total  water  bodies  in  each  category  which  are  monitored, 

monitored for chemical status and monitored for ecological status, in Finland. 
The number in parenthesis next to the category is the total number of water 

bodies in that category  

Source: WISE electronic reporting 

Long-term trend monitoring and monitoring of Priority Substances in water, sediment and 
biota for status assessment 

Monitoring for status assessment 

Requirements 

Article 8.1 of the WFD requires Member States to establish monitoring programmes in order to 

provide  inter  alia  a  coherent  and  comprehensive  overview  of  water  status  within  each  RBD. 
The amount of monitoring undertaken in terms of priority substances, frequency and numbers 

69 

 
 
 
of sites should be sufficient to obtain a reliable and robust assessment of status. According to 

the  EQS  Directive 
in  2009),  mercury,  hexachlorobenzene  and 
hexachlorobutadiene  have  to  be  monitored  in  biota  for  status  assessment,  unless  Member 

(version 

force 

in 

States  derived  a  standard  for  another  matrix,  which  is  at  least  as  protective  as  the  biota 
standard.  

Spatial coverage 

According to WISE, a large number of coastal waters in Finland were not monitored for any 

Priority Substances: 100 % in the Tornionjoki and Åland RBDs, 92 % for the Kokemäenjoki-
Archipelago  Sea-Bothnian  Sea  RBD  and  between  78  %  and  80  %  for  the  Kymijoki-Gulf  of 

Finland,  Oulujoki-Iijoki  and  Kemijoki  RBDs.  The  remaining  coastal  water  bodies  in  these 
RBDs were monitored for between one and five Priority Substances. The Åland RBD however 

subsequently  clarified  that  priority  substances  are  monitored  in  coastal  waters,  in  water, 
sediment and biota. 

There are also large numbers of lake waters with no monitoring for Priority Substances across 
all the RBDs. The monitoring sites for lake water bodies are predominantly monitored for only 
one Priority Substance. Similarly, for river water bodies across seven RBDs, between 90 and 

99  %  are  not  monitored  for  Priority  Substances.  2  %  of  river  waters  in  Kokemäenjoki-
Archipelago  Sea-Bothnian  Sea  were  monitored  for  more  than  10  Priority  Substances.  The 

remaining river waters were monitored for between 1 and 10 Priority Substances.  

In  WISE,  only  mercury  is  reported  to  be  monitored  in  biota  for  status  assessment  with 

hexachlorobenzene  and  hexachlorobutadiene  being  monitored  in  water.  There  is  no 
information available to confirm whether the water environmental quality standard is at least as 

protective  as  the  biota  standard.  However,  Finland  subsequently  clarified  that  mercury, 
hexachlorobenzene  and  hexachlorobutadiene  were  monitored  in  biota  for  status  assessment 

(hexachlorobenzene  and  hexachlorobutadiene  being  also  monitored  in  water  according  to 
WISE reporting).  

Frequencies 

The WFD indicates that, for the surveillance and operational monitoring of Priority Substances 

in water, the frequency of monitoring should be at least monthly for one year during the RBMP 
cycle and at least monthly every year, respectively. Monitoring in biota for status assessment 

should take place at least once every year according to the EQS Directive. In all cases greater 
intervals can be applied by Member States if justified on the basis of technical knowledge and 

expert judgement. 

70 

 
 
Monitoring frequencies in water were reported in WISE for 26 Priority Substances at the site 

level  in  the  Kymijoki-Gulf  of  Finland  RBD  and  for  22,  21,  12  and  four  substances  in  the 
Kokemäenjoki-Archipelago Sea-Bothnian Sea, Oulujoki-Iijoki, Vuoksi and Tornionjoki RBDs 

respectively. The monitoring frequency in both  water and biota was once per  year and every 
three  years in  the monitoring  cycle for each monitoring site  within each of the seven RBDs. 

These  reported  frequencies  do  not  meet  the  guidelines  for  operational  or  surveillance 
monitoring  in  water  or  biota  for  status  assessment  in  the  Directive.  The  RBMPs  provide  no 

specific information on frequencies. No explanation was provided for the reduced frequency. 

Monitoring for long-term trend assessment 

Requirements 

Article 3.3 of the EQS Directive (version in force in 2009) requires Member States to monitor 
14  priority  substances25  that  tend  to  accumulate  in  sediment  and/or  biota,  for  the  purpose  of 
long-term  trend  assessment.  Monitoring  should  take  place  at  least  once  every  three  years, 

unless technical knowledge and expert judgment justify another interval.  

Spatial coverage and frequencies 

There  is  no  monitoring  reported  in  Finland  for  long-term  trend  analysis  in  sediment  and/or 

biota.  Finland  has  provided  additional  information  stating  that  they  will  be  monitoring 
ubiquitous  persistent,  bioaccumulative  and  toxic  substances  in  fish  (although  it  is  not  totally 

clear  whether  this  will  be  part  of  a  trend  assessment),  and  that  they  are  also  considering 
monitoring sediment in undisturbed lakes. 

Monitoring of Priority Substances that are discharged in each RBD  

Annex  V  of  the  WFD  states,  in  Section  1.3.1  (Design  of  surveillance  monitoring),  that 

“Surveillance monitoring shall be carried out for each monitoring site for a period of one year 
during  the  period  covered  by  a  river  basin  management  plan  for  [inter  alia]:  priority  list 
pollutants  which  are  discharged  into  the  river  basin  or  sub-basin.”  Section  1.3.2  (Design  of 
operational  monitoring)  of  the  Directive  states  that  “In  order  to  assess  the  magnitude  of  the 

pressure to  which bodies of surface water  are subject  Member States shall monitor for those 
quality elements which are indicative of the pressures to which the body or bodies are subject. 

In order to assess the impact of these pressures, Member States shall monitor as relevant [inter 

25   Anthracene,  brominated  diphenylether, 

fluoranthene, 
hexachlorobenzene,  hexabutadiene,  hexachlorocyclohexane,  lead,  mercury,  pentachlorobenzene,  PAH, 
Tributyltin. 

chloroalkanes,  DEHP, 

cadmium,  C10-13 

71 

 
 
                                                      
alia]:  all  priority  substances  discharged,  and  other  pollutants  discharged  in  significant 

quantities.” 

Member States are therefore required to monitor all Priority Substances which are discharged 

into the river basin or sub-basin. 

Finland reported that 36 substances were included in an inventory for each of the RBDs. (See 

section  2.1.11  of  this  report  for  further    information).  However,  not  all  the  substances  were 
reported to be discharged. Across the eight RBDs in Finland only between three and eight of 

the  Priority  Substances  in  an  inventory  were  reported  as  being  discharged.  For  seven  of  the 
eight  RBDs,  with  the  exception  of  DEHP  in  the  Oulujoki-Iijoki  RBD,  all  of  the  substances 

discharged were reported to be monitored.  In the Åland RBD 3 substances were reported as 
being  discharged  but  none  were  monitored  (although  a  reporting  error  with  regard  to 
monitoring is suspected26).  

Performance of analytical methods used  

According to WISE for 25 groups of Priority Substances the analytical methods used meet the 
minimum  performance  criteria  laid  down  in  Article  4(1)  of  Directive  2009/90/EC27  for  the 
strictest  standard  applied.  For  the  remaining  16  reported,  Finland  reported  that  the  analytical 

methods complied with the requirements laid down in Article 4(2) of Directive 2009/90/EC for 
the strictest standard applied. 

The  method  of  dealing  with  measurements  of  Priority  Substances  lower  than  the  limit  of 
quantification was as specified in Article 5 of Directive 2009/90/EC. 

4.1.2.  Chemical Status of surface water bodies 

Member States are required to report the year on which the assessment of chemical status was 
based. This  may be the  year the surface water body was monitored.  In  case of  grouping this 

may be the year in which monitoring took place in the surface water bodies within a group that 
are used to  extrapolate results to non-monitored surface water bodies within the same group. 
For Finland, the assessment of chemical status was undertaken between 2010 and 2014.  

26   Finland  subsequently  clarified  that  in  the  Åland  RBD  monitoring  is  undertaken  for  Priority  Substances  and 
that lists are available of the substances monitored. They state that they have monitored in water, in sediments 
and in biota (fish and mussels). See for example report: http://www.regeringen.ax/nyheter/analys-fiskmuskel-
fisklever-fran-gos-alands-landskapsregering 

27   Directive  2009/90/EC  of  31  July  2009  laying  down,  pursuant  to  Directive  2000/60/EC  of  the  European 
Parliament and of the  Council,  technical specifications  for chemical analysis and  monitoring of  water status 
http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1524565750309&uri=CELEX:32009L0090 

72 

 
 
                                                      
The chemical status of surface water bodies in Finland for the second RBMP is illustrated on 

the map below. This is based on the most recent assessment of status. 

The chemical  status  of surface waters in  Finland for the first  and second RBMPs is  given in 

Table  4.1.  More  information  on  the  chemical  status  in  each  RBD  and  water  category  can  be 
found on the website of the European Environment Agency28. 

Map 4.1 

Chemical status of surface water bodies in Finland based on the most recently 
assessed status of the surface water bodies  

Note: Standard colours based on WFD Annex V, Article 1.4.3. 

Source: WISE, Eurostat (country borders) 

28   https://www.eea.europa.eu/publications/state-of-water 

73 

GoodFailing to achieve to goodUnknownRiver Basin DistrictsCountries outside the EU 
 
 
 
 
 
                                                      
Overall between the first and second RBMPs, there was a decrease in the proportion of surface 

water bodies with good chemical status from 64 % down to 49 %, similar decreases occurred 
across  all  water  body  types  (artificial,  heavily  modified  and  natural)29.  The  proportion  of 
surface water bodies that fail to achieve good chemical status dramatically increased between 
the two cycles, from 0.44 % to 49 %. In the first cycle there were surface water bodies listed as 

having  an unknown status which were not  observed in  the second cycle. The increase in  the 
number of surface water bodies failing to achieve good status may result from the classification 

of water bodies that were in unknown status in the first RBMPs. The considerable reduction in 
surface  water  bodies  at  unknown  status  in  the  second  RBMP  represents  a  significant 

improvement compared to the first RBMP. 

Table 4.1 

Chemical  status  of  surface  water  bodies  in  Finland  for  the  second  and  first 

RBMP.  Note:  the  number  in  parenthesis  next  to  the  water  category  is  the 
number  of  water  bodies.  Note:  Chemical  status  assessment  is  based  on  the 

standards  laid  down  in  EQS  Directive  2008/105/EC  (version  in  force  on  13 
January  2009).  Some  Member  States  did  not  implement  the  Directive  in  the 
first RBMPs as the transposition deadline was in July 2010, after the adoption 

of the first RBMPs 

Good 

Failing to achieve good 

Unknown 

Number 

% 

Number 

% 

Number 

% 

Category 

Second 
RBMP 

Lakes (4617) 

Rivers (1913) 

Coastal (276) 

Total (6806) 

First RBMP 

1 778 

1 322 

266 

3366 

Lakes (4275) 

2 639 

Rivers (1602) 

1 026 

Coastal (276) 

Total (6153) 

273 

3938 

2 839 

591 

10 

3440 

3 

24 

39 % 

69 % 

96 % 

50 % 

62 % 

64 % 

99 % 

61 % 

31 % 

4 % 

50 % 

0.07 % 

1 633 

38.20 % 

1.50 % 

552 

3 

2188 

34 % 

1 % 

35.6 % 

64 % 

0.4 % 
Source: WISE electronic reporting 

27 

Figure 4.3 shows the confidence in the classification of chemical status for the second RBMP. 

Overall 93 % of surface water bodies in Finland were classified for chemical  status with low 

29   The decrease in surface water bodies at good status has been explained by the additional information provided 
by Finland. The reason given is that in the second cycle the biota (fish) environmental quality standard was 
applied for  mercury. In  the  first cycle,  the environmental quality standard for  mercury  was only applied  for 
water and it was stated that it was not possible to assess status regionally. 

74 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
confidence,  6  %  with  medium  confidence  and  only  1  %  with  high  confidence  regardless  of 

class. For surface water bodies, most of the classifications of good status and those that fail to 
achieve good status are given a low or medium level of confidence. The RBMPs indicated that 

confidence was assigned according to a national methodology comprising four classes: (1) no 
classification;  (2)  expert  opinion  based  on  use,  emission  and  transport  data;  (3)  chemical 
analyses,  some  data;  (4)  chemical  analyses,  good  data30.  Confidence  in  the  classification  of 
chemical status for the first RBMPs was not reported. 

Figure 4.3 

 Confidence in the classification of chemical status of surface water bodies in 
Finland based on the most recently assessed status/potential  

Source: WISE electronic reporting 

On  average,  for  seven  out  of  eight  RBDs,  approximately  90  %  of  surface  water  bodies  have 
been classified via expert judgement. The Åland RBD only includes lakes and coastal waters; 

100  %  of  coastal  waters  were  classified  through  expert  judgement,  71.4  %  of  lakes  were 
classified  through  monitoring,  with  the  remaining  28.6  %  being  classified  through  expert 

judgement.  The extensive use of expert judgement is reflected in the reported low confidence 
in the classification. 

30   The  national  methodology  was  used  to  indicate  the  confidence  of  the  data.  The  WISE  system  had  different 

categories for assessing the confidence. These translate as follows: 
• No classification = no reporting to WISE 
• Expert opinion = low confidence level 
• Chemical analyses, some data =  medium confidence level 
• Chemical analyses, good data = high confidence level 

75 

 
 
 
 
                                                      
 
 
 
 
In contrast to the information reported to WISE and summarised above (which states that water 

bodies  are  classified  through  either  monitoring  or  expert  judgement),  the  RBMPs  include 
descriptions of the use of grouping and modelling in the assessment of chemical status. In the 

Vuoksi RBMP, grouping is especially used for the assessment of lakes in relation to mercury 
and  according  to  the  national  methodology  document;  grouping  is  combined  with  expert 

opinion  both  in  the  case  of  mercury  and  other  chemical  substances.  It  is  therefore  not  clear 
which techniques have been used in the absence of monitoring data. 

Finland  also  stated  that  all  available  measured  data  was  used  for  the  classification  and  that 
expert  assessment  was  used,  when  no  measured  data  existed.  The  classification  was  carried 

first  by  carrying  out  a  specific  generic  expert  assessment  to  all  water  bodies,  and  this  was 
subsequently replaced by measured data when available. 

The expert assessment is reported to have involved the following: 

•  No  environmental  quality  standard  exceedances  were  expected  for  substances,  which 
were  not  detected  or  detected  only  in  trace  level  in  Finnish  surface  water  (many  of 
those chemicals had either never or were no longer used in Finland); 

•  For  mercury,  which  was  the  most  important  substance  in  chemical  classification  in 

Finland, a simple grouping model was developed and used31; 

• 

In addition to mercury, only a few other substances were expected to exceed their EQS 

values occasionally or in specific areas. Regional authorities undertook the assessment 
according case specific potential loading routes; 

•  For  tributyltin,    measurements  were  available  only  from  expected  ‘risky’  locations 

(such as harbours); 

Cadmium  and  Nickel  presented  a  risk  in  certain  areas  (rivers  on  the  central  western  coast  in 
acid sulphate soil areas) and downstream from some mining areas, scattered in different parts 
of Finland. 

Figure 4.4 compares the chemical status of surface water bodies in Finland for the first RBMP 

with  that  for  the  second  RBMP  (based  on  the  most  recent  assessment  of  status)  and  that 
expected  by  2015.  This  illustrates  the  reduction  in  the  proportion  of  surface  water  bodies  in 

31   The  model  was  based  on  available  mercury  data  in  perch  and  the  water  body  type  and  latitude.  The  EQS 
exceedance was simulated, if this “statistical” model indicated concentration higher than 0.7 x EQSbiota. The 
model  was  assumed  to  be  slightly  more  conservative/precautionary  than  measured  data.  According  to  the 
model, there were no EQS exceedances for Hg in Northern Finland (North from river Oulujoki cathcment) and 
in the Southern and Central Finland the exceedances depended on water body type. 

76 

 
 
                                                      
good status from the first to the second cycles which was anticipated in the expected status in 

2015. 

The  assessment  of  chemical  status  for  the  second  RBMP  was  expected  to  be  based  on  the 
standards  laid  down  in  the  EQS  Directive  (version  in  force  on  13  January  200932).  Some 
Member States did not fully implement the Directive in the first RBMPs as the transposition 

deadline was in July 2010, after the adoption of the first RBMPs. 

Good  chemical  status  should  be  reached  by  2021  in  relation  to  the  revised  environmental 

quality standards, unless Member States apply exemptions under WFD Article 4(4) and/or less 
stringent objectives under WFD Article 4(5). 

Member States were asked to report the expected date for the achievement of good chemical 
status.  The  information  for  Finland  is  shown  in  Figure  4.5.  Good  chemical  status  of  surface 

water bodies is  expected to  be achieved by the end of the third planning  cycle in  five of the 
eight RBDs. In the remaining three RBDs (Tornionjoki, Teno, Näätämöjoki and Paatsjoki and 

Åland)  surface  waters  were  reported  to  already  be  at  good  status.  The  expected  or  actual 
improvement  in  the  chemical  status  of  surface  water  bodies  at  the  end  of  the  first  cycle  was 
reported to be as described in the RBMP. 

32   Directive  2013/39/EU,  which  amended  the  Environmental  Quality  Standards  Directive,  introduced  a  less 
stringent  annual  average  EQS  for  naphthalene  in  transitional  and  coastal  waters.  This  less  stringent 
environmental quality standard should be taken into account for the determination of surface water chemical 
status by the 2015 deadline laid down in Article 4 of the WFD.  

77 

 
 
                                                      
Figure 4.4 

 Chemical status of surface water bodies in Finland for the second RBMP, for 
the  first  RBMP  and  expected  in  2015.  The  number  in  the  parenthesis  is  the 
number  of  surface  water  bodies  for  both  cycles.  Note  the  period  of  the 

assessment of status for the second RBMP was 2010 to 2014. The year of the 
assessment of status for first RBMP is not known  

Source: WISE electronic reporting 

Figure 4.5 

 Expected  date  of  achievement  of  good  chemical  of  surface  water  bodies  in 

Finland. The number in the parenthesis is the number of water bodies in each 
category 

Source: WISE electronic reporting 

78 

 
 
 
 
Priority Substances causing the failure of good chemical status 

Three Priority Substances were reported to be causing failure to achieve good chemical status 
in  surface  water  bodies  in  Finland.  The  most  common  priority  substances  causing  failure  to 

achieve  good  chemical  status  are  shown  in  Figure  4.6.  The  substances  causing  the  greatest 
proportion to fail good chemical status in the  second RBMP were mercury (50 %), cadmium 

(0.71 %) and nickel (0.35 %). 

Figure 4.6 

The  most  common  Priority  Substances  causing  failure  to  achieve  good 

chemical status in surface water bodies in Finland 

Source: WISE electronic reporting. 

Overall for surface water bodies in Finland, the largest proportion of exceedances was for the 
Annual Average-Environmental Quality Standard for mercury (98 %). In terms of exceedance 

of both types of standard at the same time (noting that separate exceedances for the maximum 
allowable  concentration  and  not  the  annual  average  were  not  observed  and/or  reported),  the 

largest proportion was for cadmium (0.31 %).  

In terms of Priority Substances resulting in an improvement in the chemical status of a water 

body,  nickel  showed  an  improvement  in  3.2  %  of  the  river  water  bodies  and  cadmium  an 
improvement of 1 % in the Kokemäenjoki-Gulf of Finland RBD. No improvements occurred 

in the other RBDs. 

79 

 
 
 
Directive  2013/39/EU  amended  the  EQS  Directive.  In  particular,  it  sets  more  stringent 
environmental  quality  standards  for  seven  substances33.  Member  States  were  required  to 
indicate  if  the  new  standards  caused  the  status  of  the  surface  water  body  to  appear  to 

deteriorate. The new standards were not reported by Finland to cause surface water bodies to 
deteriorate. 

Ubiquitous persistent, bioaccumulative and toxic Priority Substances 

According  to  Article  8(a)  of  the  EQS  Directive34,  eight  priority  substances  and  groups  of 
priority substances are behaving like ubiquitous, persistent, bioaccumulative and toxic (uPBT) 
substances35.  These  substances  are  generally  expected  to  cause  widespread  exceedances,  and 
their emissions can be challenging to tackle (e.g. due to long-range atmospheric transport and 
deposition). In order to show the progress made in tackling other priority substances, Member 

States have the possibility to present the information related to chemical status separately for 
these substances. The assessment of uPBT substances for Finland has been based on the 2008 

EQSs. 

In Finland overall, there were 3440 water bodies reported to be failing to achieve good status 
in the second RBMP. Of these 3419 (over 99 %) are reported to have at least one uPBT that is 

failing its environmental quality standards; however, for approximately half of these the uPBT 
substance was determining the status alone. This is illustrated in the 2018 State of Water report 
of the European Environment Agency36. 

The influence of uPBT substances on the cause of the failure to achieve good chemical status 

in Finland is therefore significant; in the vast majority of cases this is due to mercury with a 
few coastal water bodies affected by tributyltin. 

Priority Substances used in the assessment of chemical status compared to those monitored 

For the seven mainland RBDs, chloroalkanes was the only Priority Substance reported as not 

being  used  in  the  assessment  and  not  monitored.  The  remaining  40  out  of  the  41  Priority 
Substances reported for these RBDs were used in the assessment of status. However, not all of 

33   Anthracene,  Brominated  diphenylether,  Fluoranthene,  Lead  and  its  compounds,  Naphthalene,  Nickel  and  its 

compounds, Polyaromatic hydrocarbons (PAH) 

34   Amended by Directive 2013/39/EU 
35   Brominated  diphenylether,  Mercury  and  its  compounds,  Polyaromatic  hydrocarbons  (PAH),  Tributyltin,  

PFOS, dioxins, hexabromocyclodecane and heptachlor 

36   https://www.eea.europa.eu/publications/state-of-water  (p40-41  of  the  report).  Also  available  in  a  more 

interactive format at :  
https://tableau.discomap.eea.europa.eu/t/Wateronline/views/WISE_SOW_SWB_Chemical_Status_Maps/SW
B_Failing_Good_Chemical_Status_RBD?iframeSizedToWindow=true&:embed=y&:showAppBanner=false&
:display_count=no&:showVizHome=no 

80 

 
 
                                                      
these substances were reported as being monitored across these seven RBDs: between 4 and 30 

out of 40 Priority Substances were monitored in the mainland RBDs. For the Åland RBD, the 
following 6 out of 41 Priority Substances were reported as not being used in the  assessment: 

carbon  tetrachloride;  trichloroethylene;  4-nonylphenol;  di(2-ethylhexyl)phthalate  (DEHP); 
tetrachloroethylene,  and;  octylphenol  (4-(1,1',3,3'-tetramethylbutyl)-phenol).  According  to 

WISE, no Priority Substances were reported to be monitored in this RBD, however the Åland 
RBD subsequently clarified that monitoring of priority substances is performed as described in 

the RBMP. The fact that more Priority Substances were used in the classification of chemical 
status  than  in  monitoring  would  explain  the  widespread  use  of  expert  judgement  in  the 

assessment of chemical status. 

Application of alternative environmental quality standards for water, biota and sediment 

According  to  the  EQS  Directive,  Member  States  may  opt  to  apply  environmental  quality 
standards for  another matrix than the one specified in  the Directive for a given substance.  If 

they do so, they have to ensure the environmental quality standard they set in the other matrix 
(or  matrices)  offers  at  least  the  same  level  of  protection  as  the  standard  established  in  the 
Directive. 

Finland reported that all of the Environmental Quality Standards laid down in Part A of Annex 
I of the Directive 2008/105/EC37 (in force in 2009) had been applied and no alternative and/or 
additional standards had been applied. 

Use of mixing zones  

Article 4 of the EQS Directive provides Member States with the option of designating mixing 
zones adjacent to points of discharge in surface waters. Concentrations of priority substances 

may exceed the relevant environmental quality standard within such mixing zones if they do 
not affect the compliance of the rest of the surface water body with those standards. Member 

States that designate mixing zones are required to include within their RBMPs a description of 
the  approaches  and  methodologies  applied  to  define  such  zones,  and  a  description  of  the 

measures taken to reduce the extent of the mixing zones in the future. 

For three of the eight RBDs in Finland (Vuoksi, Kokemäenjoki-Archipelago Sea-Bothnian Sea 

and Oulujoki-Iijoki), mixing zones have been designated under Article 4 of the EQS Directive. 

37   Directive 2008/105/EC of the European Parliament and of the Council of 16 December 2008 on environmental 
quality  standards  in  the  field  of  water  policy,  amending  and  subsequently  repealing  Council  Directives 
82/176/EEC, 83/513/EEC, 84/156/EEC, 84/491/EEC, 86/280/EEC and amending Directive 2000/60/EC of the 
European Parliament and of the Council  
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008L0105-20130913 

81 

 
 
                                                      
 
For the remaining five RBDs, mixing zones have not been designated. Mixing zones have been 

designated following the tiered approach as laid down in the ‘Technical Background Document 
on  Identification  of  Mixing  Zones’38.  Measures  reported  to  be  taken  to  reduce  the  extent  of 
mixing zones in the future include a review of the permits referred to in Directive 2008/1/EC 
(the IPPC Directive). 

Finland  provided  additional  information  stating  that  in  Kemijoki  RBD  in  addition  to  those 
identified above, one mixing zone has been designated.39  

Background Concentrations and Bioavailability 

The  EQS  Directive  stipulates  that  Member  States  have  the  possibility,  when  assessing  the 

monitoring results against the environmental quality standard, to take into account: 

(a)  natural  background  concentrations  for  metals  and  their  compounds,  if  they  prevent 

compliance with the environmental quality standard, and; 

(b) hardness, pH or other water quality parameters that affect the bioavailability of metals. 

No information has been reported for any of the eight RBDs in Finland, as to whether natural 
background concentrations for metals and their compounds are taken into consideration where 
such concentrations prevent compliance with the relevant Environmental Quality Standards. 

Finland subsequently clarified that the typical background level for metals has been established 
in the Government Degree 1040/2006 on the harmful and hazardous substances in the surface 

waters (in the Annex C2). Measured concentrations are reported to be compared to the sum of 
the background level and the given EQS-value. 

Finland  states  that  in  all  of  its  RBDs,  in  assessing  monitoring  results  against  EQSs,  the 
application of water quality parameters that affect the bioavailability of metals have been taken 

into account.  

4.2.  Main changes in implementation and compliance since the first cycle 

Comparing  the  number  of  sites  and  water  bodies  monitored  for  operational  and  surveillance 
purposes between the first and second cycles, there appears to be a net increase in monitoring 

sites and surface water bodies monitored for operational purposes (an increase of 876 sites and 

38   https://circabc.europa.eu/sd/a/78ce94bb-6f1c-4379-87ac-

88a18967c4c3/Technical%2520Background%2520Document%2520on%2520the%2520Identification%2520o
f%2520Mixing%2520Zones.doc+&cd=1&hl=en&ct=clnk&gl=uk 

39   RBMP p. 49 in Kemijoen vesienhoitoalueen vesienhoitosuunnitelma vuosiksi 2016-2021. 

82 

 
 
                                                      
843  water  bodies  noting  that  these  numbers  are  for  a  range  of  parameters,  not  just  Priority 

Substances)  both  due  to  relatively  large  increases  in  both  river  and  lake  monitoring.  For 
surveillance  monitoring,  the  number  of  sites  has  increased  by  802  and  the  number  of  water 

bodies  has  increased  by  799  since  the  first  cycle.  However,  there  remains  a  significant 
proportion  of  surface  water  bodies  not  monitored  for  chemical  status  (48  %  of  coastal  water 

bodies, 35 % of lake water bodies and 74 % of river water bodies were monitored for chemical 
status). 

Where monitoring for chemical status does occur, the number of Priority Substances monitored 
varies widely: in coastal waters up to 5, in lakes one and in rivers up to 10 Priority Substances 

were monitored. Only 1 of the 14 Priority Substances for which the EQS Directive requires the 
monitoring  of  the  long-term  trends  in  biota  and/or  sediment  in  coastal,  lake  and  river  water 

bodies in all RBDs. Finland has reported that that all of the Environmental Quality Standards 
laid down in Part A of Annex I of the Directive 2008/105/EC40 for assessment of the chemical 
status  of  bodies  of  surface  water  had  been  applied  and  that  alternative  and/or  additional 
standards  for  particular  Priority  Substances  had  not  been  applied.  This  represented  progress 
from the first cycle when these Environmental Quality Standards were not used. 

Overall between the two cycles there was a decrease in the proportion of surface water bodies 
with  good  chemical  status  from  64  %  down  to  49  %,  similar  decreases  occurred  across  all 

water  body  types  (artificial,  heavily  modified  and  natural).  The  first  cycle  also  listed  some 
unknown water body types, these were not present in the second cycle so no comparison can 

be  made.  The  proportion  of  surface  water  bodies  that  fail  to  achieve  good  chemical  status 
dramatically increased between the two cycles, from 0.44 % to 49 %. In the first cycle, there 

were surface water bodies listed as having an unknown status, these were not observed in the 
second cycle; the increase in the number of surface water bodies failing to achieve good status 

may  result  from  the  classification  of  water  bodies  that  were  in  unknown  status  in  the  first 
RBMPs. 

In  terms  of  Priority  Substances  causing  an  improvement  in  chemical  status  between  the  two 
RBMPs, nickel  showed  an improvement in  3.2  % of the  river water bodies and cadmium  an 

improvement of 1 % in the Kokemäenjoki-Gulf of Finland RBD. No improvements occurred 
in the other RBDs. 

40   Directive 2008/105/EC of the European Parliament and of the Council of 16 December 2008 on environmental 
quality  standards  in  the  field  of  water  policy,  amending  and  subsequently  repealing  Council  Directives 
82/176/EEC, 83/513/EEC, 84/156/EEC, 84/491/EEC, 86/280/EEC and amending Directive 2000/60/EC of the 
http://eur-lex.europa.eu/legal-
European 
content/EN/TXT/?uri=CELEX:02008L0105-20130913 

Parliament 

Council 

and 

the 

of 

83 

 
 
                                                      
Where  available,  classification  of  chemical  status  is  based  on  the  results  of  monitoring. 

However,  on  average,  for  seven  out  of  eight  RBDs,  approximately  90  %  of  surface  water 
bodies  have  been  classified  via  expert  judgement  and  the  remaining  10  %  by  monitoring. 

Consequently,  the  majority  of  the  classifications  of  good  and  those  that  fail  to  achieve  good 
status are made with either low or medium confidence. 

4.3.  Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMPs  and  first  Programme  of 
Measures requested action on the following: 

  Recommendation: There is a large proportion of surface water bodies in Finland for which 
the status is unknown. Some RBDs have a high proportion of water bodies for which status 
is  unknown.  Finland  therefore  needs  to  increase  its  efforts  in  this  first  cycle  to  decrease 

this lack of knowledge and uncertainty.  

  Assessment: Progress has been made in addressing this recommendation. The proportion of 
surface  water  bodies  that  fail  to  achieve  good  chemical  status  increased  between  the  two 
cycles, from  0.44 % to  49 %.  In the first  cycle,  there were surface water bodies listed as 

having  an  unknown  status,  but  it  was  not  the  case  in  the  second  cycle.  Therefore  the 
increase  in  the  number  of  surface  water  bodies  failing  to  achieve  good  status  may  result 

from the classification of water bodies that were in unknown status in the first RBMPs. It is 
worth noting in this regard that expert judgement has been widely used in the assessment of 

chemical  status  in  the  second  cycle  and  that  the  resulting  classifications  are  made  with  a 
low degree of confidence. All assessments across Finland were carried out between 2010 

and 2014. This recommendation has therefore been partially fulfilled. 

  Recommendation: Finland needs to improve the surface water monitoring and the quality 
of  the  reporting  of  monitoring  networks,  methodologies  and  results,  and  to  extend  the 
monitoring programmes to cover all water bodies (including smaller water bodies) and all 

required  quality  elements).  Finland  needs  to  base  its  classification  on  such  extended 
monitoring results. 

Assessment:  Limited  progress  has  been  made  with  this  recommendation.  Comparing  the 
number  of  sites  and  water  bodies  monitored  for  operational  and  surveillance  purposes 

between the first and second cycles, there appears to be a net increase in monitoring sites 
and  surface  water  bodies  monitored  for  operational  purposes  both  due  to  relatively  large 

increases  in  both  river  and  lake  monitoring.  For  surveillance  monitoring,  the  number  of 

84 

 
 
sites has increased as well. However, there remain a significant proportion of surface water 

bodies  not  monitored  for  chemical  status.  Where  monitoring  for  chemical  status  does 
occur,  the  number  of  Priority  Substances  monitored  varies  widely.  Finland  provided 

additional information stating that measured data for Priority Substances is rarely available, 
compared to the large number of waterbodies.  

Finland  clarified 
that  mercury,  hexachlorobenzene  and  hexachlorobutadiene  were 
monitored  in  biota  for  status  assessment  (hexachlorobenzene  and  hexachlorobutadiene 

being also monitored in water). No information is available to confirm whether the water 
EQS is at least as protective as the biota standard. 

The  majority  of  the  classifications  of  good  and  those  that  fail  to  achieve  good  status  are 
made with either low or medium confidence. This recommendation is partially fulfilled. 

  Recommendation:  The  chemical  status  assessment  needs  to  include  all  the  substances  in 
the  Environmental  Quality  Standards  Directive,  and  Finland  should  specify  in  all  cases 

which substances are causing failure.  

Assessment:  Progress  has  been  made  with  this  recommendation.  Where  monitoring  for 

chemical status does occur, the number of Priority Substances monitored varies widely. As 
stated above, Finland clarified that mercury, hexachlorobenzene  and hexachlorobutadiene 

were  monitored 
and 
hexachlorobutadiene  being  also  monitored  in  water)  and  no  information  is  available  to 

(hexachlorobenzene 

assessment 

status 

biota 

for 

in 

confirm whether the water EQS is at least as protective as the biota standard. Finland has 
reported which substances are causing failure of good status.  

Finland has reported that that all of the Environmental Quality Standards laid down in Part 
A  of  Annex  I  of  the  Directive  2008/105/EC41  for  assessment  of  the  chemical  status  of 
bodies  of  surface  water  had  been  applied  and  that  alternative  and/or  additional  standards 
for particular Priority Substances had not been applied. 

  For  seven  of  the  eight  RBDs  in  Finland,  Chloroalkanes  C10-13  is  the  only  individual 
priority  substance  reported  as  not  being  used  in  the  assessment  and  not  monitored.  The 

remaining  priority  substances  reported  for  these  RBDs  are  reported  to  be  used  in  the 

41   Directive 2008/105/EC of the European Parliament and of the Council of 16 December 2008 on environmental 
quality  standards  in  the  field  of  water  policy,  amending  and  subsequently  repealing  Council  Directives 
82/176/EEC, 83/513/EEC, 84/156/EEC, 84/491/EEC, 86/280/EEC and amending Directive 2000/60/EC of the 
http://eur-lex.europa.eu/legal-
European 
content/EN/TXT/?uri=CELEX:02008L0105-20130913 

Parliament 

Council 

and 

the 

of 

85 

 
 
                                                      
assessment of status. However, as stated above, not all of these substances are reported as 

being monitored. This recommendation has been partially fulfilled. 

86 

 
 
 
Topic 5

  Monitoring, 

and 
quantitative status of groundwater bodies 

assessment 

classification 

of 

5.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle 

5.1.1 Monitoring of quantitative status in groundwater 

The  number  of  groundwater  bodies  has  decreased  slightly  from  3804  in  the  first  RBMP  to 
3773  in  the  second  RBMP  (Table.5.2).  3670  groundwater  bodies  remained  unchanged  since 

the  first  RBMP.  3 626  of  3 773  groundwater  bodies  are  not  subject  to  monitoring  for 
quantitative status (Table 5.1). This means that 96 % of groundwater bodies are not monitored. 

Monitoring  now  takes  place  in  four  of  eight  RBDs  (Table  5.2).  Some  RBMPs  indicated  that 
grouping was applied42 according to relatively broad geological areas but only for groundwater 
bodies  with  good  status  and  no  identified  risks.  For  each  group,  a  sufficient  number  of 
representative groundwater bodies and monitoring points were assigned. In the RBMP for the 
Åland RBD it is stated that “groundwater monitoring is not specifically well implemented"43. 
Quantitative  monitoring  was  reported  for  only  one  groundwater  body  and  one  source.  No 
further justification is given. 

Table 5.1 

Number and purpose of water bodies in Finland directly monitored  

Monitoring Purpose 

Total 
ground-
water 
bodies 
directly 
monitor-
ed 

CHE – 
Chemi-
cal 
status 

DRI – 
Ground-
water 
abstraction 
site for 
human 
consump-
tion 

DWD - 
Drinking 
water - 
WFD 
Annex 
IV.1.i 

IND – 
Ground-
water 
abstraction 
site for 
industrial 
supply 

OPE – 
Operation
-al 
monitor-
ing 

QUA – 
Quantita-
tive status 

SUR – 
Surveil-
lance 
monitor-
ing 

77 

111 

150 

42 

7 

2 

1 

3 

48 

68 

121 

7 

2 

1 

44 

66 

81 

37 

3 

1 

3 

44 

66 

81 

37 

3 

1 

3 

12 

11 

3 

8 

1 

1 

56 

81 

123 

7 

7 

2 

1 

3 

25 

43 

43 

36 

76 

111 

150 

42 

7 

2 

1 

3 

RBD 

FIVHA1 

FIVHA2 

FIVHA3 

FIVHA4 

FIVHA5 

FIVHA6 

FIVHA7 

FIWDA 

42   Finland subsequently clarified that due to the large number of small groundwater bodies, grouping is a general 
practice  in  all  RBDs  for  those  in  goods  status  and  with  no  human  pressure  or  risk.  In  addition,  some 
monitoring points could not be reported to WISE since they did not fall within the groundwater body area.   
43 Finland subsequently clarified that there is groundwater monitoring in two places in Åland (FIWDA), and that 
groundwater use is in general very limited. Water companies that use groundwater also carry out monitoring. 

87 

 
 
 
 
 
 
 
 
 
 
 
 
                                                      
Source: WISE electronic reporting 

Table 5.2 

Proportion of groundwater bodies in Finland monitored for quantitative 
status 

RBD 

No of groundwater 
bodies with 
quantitative 
monitoring 

Total No. 
groundwater 
bodies 

% of total groundwater bodies 
monitored for quantitative status 

FIVHA1 

FIVHA2 

FIVHA3 

FIVHA4 

FIVHA5 

FIVHA6 

FIVHA7 

FIWDA 

25 

43 

43 

36 

705 

946 

1 078 

570 

331 

115 

23 

5 

3.55 % 

4.55 % 

3.99 % 

6.32 % 

0.00 % 

0.00 % 

0.00 % 

0.00 % 

Source: WISE electronic reporting 

The number of monitored groundwater bodies decreased from 164 in the first RBMP to 147 (in 

four RBDs) in the second RBMP. The first RBMP reported monitoring in seven RBDs and the 
second RBMP reports monitoring in four RBDs. The number of quantitative monitoring sites 

is listed in Table 5.3 and shows that the number of sites has decreased significantly by about 
25 % from 211 in the first RBMP to 160 in the second RBMP. 

2 068 of 3 773 groundwater bodies are identified as drinking water protected areas, located in 
all RBDs. 

Table 5.3 

Number of groundwater monitoring sites in Finland and their purpose  

Total 
ground-
water 
monitor-
ing sites 

81 

129 

172 

47 

7 

2 

1 

3 

RBD 

FIVHA1 

FIVHA2 

FIVHA3 

FIVHA4 

FIVHA5 

FIVHA6 

FIVHA7 

FIWDA 

Monitoring Purpose 

CHE – 
Chemi-
cal 
status 

DRI - 
Groundwater 
abstraction site 
for human 
consumption 

DWD - 
Drinking 
water - WFD 
Annex IV.1.i 

IND - 
Groundwater 
abstraction site 
for industrial 
supply 

OPE – 
Operati-
onal 
monitor-
ing 

QUA – 
Quanti-
tative 
status 

SUR – 
Surveil-
lance 
monitor-
ing 

51 

78 

127 

0 

7 

2 

1 

0 

44 

72 

84 

37 

3 

0 

1 

3 

44 

72 

84 

37 

3 

0 

1 

3 

12 

12 

3 

8 

1 

1 

0 

0 

60 

90 

131 

8 

7 

2 

1 

3 

25 

50 

45 

40 

0 

0 

0 

0 

80 

129 

172 

47 

7 

2 

1 

3 

Source: WISE electronic reporting 

88 

 
 
 
 
 
 
5.1.2 Assessment and classification of quantitative status for groundwater 

Map  5.1  displays  the  most  recently  assessed  quantitative  status  of  groundwater  bodies.  It 

shows that 3 709 of 3 773 groundwater bodies (98 %) were of good quantitative status, three 
groundwater bodies were failing good status and 61 have unknown status (Figure 5.1). In terms 

of area this means that about 4 % have unknown status and 0.1 % are failing good quantitative 
status. Figure 5.2 shows that for all groundwater bodies there is medium confidence in status 

classifications.  

Map 5.1 

Map of quantitative status of groundwater bodies based on the most recently 

assessed status of the groundwater bodies 

Note: Standard colours based on WFD Annex V, Article 2.2.4. 

Source: WISE, Eurostat (country borders) 

89 

GoodPoorUnknownRiver Basin DistrictsCountries outside the EU 
 
 
 
 
Figure 5.1 

 Quantitative status of groundwater bodies in Finland for the second RBMP, 

for  the  first  RBMP  and  expected  in  2015.  The  number  in  parenthesis  is  the 
number  of  groundwater  bodies  for  both  cycles.  Note  the  period  of  the 

assessment  of  status  for  the  second  RBMP  was  in  2013.  The  year  of  the 
assessment of status for first RBMP is not known 

Good

Poor

Unknown

Not good

Expected good status in 2015

Second plan (3773)

First plan (3804)

100% 

98% 

98% 

0%

20%

40%

60%

80%

100%

Percentage of groundwater bodies 

Source: WISE electronic reporting 

Figure 5.2 

 Confidence in the classification of quantitative status of groundwater bodies 

in Finland based on the most recent assessment of status 

Source: WISE electronic reporting 

90 

 
 
 
 
 
The total  number of groundwater bodies failing good status  increased from  two groundwater 

bodies  in  the  first  RBMP  to  three  groundwater  bodies  in  the  second  RBMP.  The  number  of 
groundwater bodies with unknown status decreased slightly from 68 to 61. 

In  seven  RBDs  water  balance  was  assessed  by  a  comparison  of  annual  average  groundwater 
abstraction  against  the  ‘available  groundwater  resource’  for  every  groundwater  body  that  is 

monitored. In the Åland RBD this assessment was done for a subset of all groundwater bodies. 
In  all  eight  RBDs  the  criterion  of  ‘available  groundwater  resource’  has  been  applied  in 

accordance with WFD Article 2.27. 

In  fact,  three  groundwater  bodies  (one  in  the  Vuoksi  RBD  and  two  in  the  Kokemäenjoki-

Archipelago Sea Bothnain Sea RBD) are failing good status but reasons for failing good status 
were  reported  for  more  than  these  three  groundwater  bodies44.  The  reasons  for  the  failure  of 
good quantitative status of groundwater bodies are shown in Figure 5.3. 13 groundwater bodies 
are  failing  good  status  due  to  failing  the  water  balance  test  which  means  that  the  long-term 

annual  average  rate  of  groundwater  abstraction  is  exceeding  the  available  groundwater 
resource, three groundwater bodies are failing due to diminution of the status of groundwater 
associated aquatic ecosystems and six groundwater bodies are failing due to saline intrusions. 

The  expected  date  of  achievement  of  good  quantitative  status  in  Finland  is  shown  in  Figure 
5.4.  One  groundwater  body  is  expected  to  achieve  good  quantitative  status  at  the  end  of  the 

second RBMP and two are expected to achieve good quantitative status by the end of the third 
cycle which is in the year 2027.  

In  total  100  groundwater  bodies  (3  %)  are  at  risk  of  failing  good  quantitative  status.  In  all 
groundwater bodies the risk is related to uses or functions. 

44   Finland  subsequently  clarified  that  reasons  for  failure  of  good  quantitative  status  have  been  mistakenly 
reported for groundwater bodies that have failed the quantitative status tests, and are still considered to be in 
good quantitative status. 

91 

 
 
                                                      
Figure 5.3 

 Reasons for the failure of good quantitative status of groundwater in Finland 

based on the most recent assessment of status  

Source: WISE electronic reporting 

Notes: 
‘Water balance’ = long-term annual average rate of abstraction exceeds the available groundwater resource which 
may result in a decrease of groundwater levels. 

‘Surface water’ = Failure to achieve Environmental Objectives (Article 4 WFD) for associated surface water 
bodies resulting from anthropogenic water level alteration or change in flow conditions; significant diminution of 
the status of surface waters resulting from anthropogenic water level alteration or change in flow conditions. 

‘Groundwater dependent terrestrial ecosystems’ = Significant damage to groundwater dependent terrestrial 
ecosystems resulting from an anthropogenic water level alteration. 

‘Saline or other intrusion’ = Regional saline or other intrusions resulting from anthropogenically induced 
sustained changes in flow direction. 

92 

 
 
 
 
 
Figure 5.4 

 Expected date of achievement of good quantitative and good chemical status 

of  groundwater  bodies  in  Finland.  3773  groundwater  bodies  delineated  for 
second RBMP 

Source: WISE electronic reporting 

5.1.3 Consideration  of  groundwater  associated  surface  waters  and/or  groundwater 

dependent ecosystems 

Groundwater associated surface waters were considered in the status assessment in all RBDs, 
except for the Åland RBD where no such ecosystems exist45. In total 221 groundwater bodies 
in  three  RBDs  were  identified  to  be  associated  to  such  ecosystems.  No  risk  related  to 

groundwater associated surface waters was reported.   

Groundwater dependent terrestrial ecosystems were considered in the status assessment in all 
RBDs,  except  for  the  Åland  RBD  where  no  such  ecosystems  exist46.  For  164  groundwater 
bodies  in  seven  RBDs  groundwater  dependent  terrestrial  ecosystems  were  identified.  The 

needs of these ecosystems were considered in all eight RBDs. No risk related to groundwater 
dependent terrestrial ecosystems were reported. 

5.2  Main changes in implementation and compliance since the first cycle 

There was a summary of changes or updates for this topic in all the RBMPs assessed. In the 
Kokemäenjoki-Archipelago  Sea-Bothnian  Sea  RBD  it  was  explained  that  the  number  of 

groundwater  bodies  increased  as  new  groundwater  bodies  were  considered  important  or 

45   Finland subsequently clarified that these ecosystem could exist, but have not been investigated due to limited 

resources.   

46   Finland subsequently clarified that the information was not available for Åland at the time of the reporting, but 

is currently available and has been mapped. 

93 

 
 
 
                                                      
potential drinking water sources. Changes of the status are not explicitly described, but it was 

mentioned that the quantitative status of two groundwater bodies is poor. In the Åland RBMP 
changes are not explicitly described, but it refers to a new guideline (the same as in Sweden) 

from 2013, which is now used for the assessment of the quantitative status. 

Based  on  the  reported  information,  the  monitoring  situation  has  deteriorated.  The  number  of 

monitored  groundwater  bodies  decreased  from  164  in  the  first  RBMP  to  147  in  the  second 
RBMP. The number of RBDs with groundwater quantitative monitoring was reduced from 7 to 

4  RBDs.  There  is  no  quantity  monitoring  in  four  RBDs  (Kemijoki,  Tornionjoki,  Teno, 
Näätämöjoki and Paatsjoki and Åland). 

The  quantitative  status  of  groundwater  bodies  deteriorated  slightly  overall,  as  the  number  of 
groundwater bodies failing good quantitative status increased from only two to only 3 of 3 773 

groundwater bodies in total. 

5.3  Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMPs  and  first  Programme  of 

Measures required action on the following: 

  Recommendation: Finland needs to base its classification on such extended monitoring 
results. The ecological status assessments are based primarily on expert judgement but 

not  on  WFD  compliant  methods,  and  there  is  a  significant  shortcoming  in  the 
availability of data for classification. 

Assessment:  The  recommendation  mainly  focused  on  surface  water  quality. 
Nevertheless,  the  recommendation  to  base  the  classification  on  extended  monitoring 
results was not taken up. The number of groundwater quantitative monitoring sites has 

actually decreased. Therefore, this recommendation has not been fulfilled.  

  Recommendation: Groundwater monitoring should be enhanced in Finland and should 
be  made  capable  of  detecting  pollution  trends.  Trend  and  trend  reversal  assessments 

should  be  carried  out  in  the  second  RBMP  cycle  regard-less  of  whether  additional 
preventive measures have been applied. 

Assessment: The recommendation mainly focused on extending chemical groundwater 
monitoring  for  trend  assessment.  Nevertheless,  the  recommendation  to  enhance 

groundwater  monitoring  was  not  taken  up.  The  number  of  groundwater  quantitative 

94 

 
 
monitoring sites has actually decreased. Therefore, this recommendation has not been 

fulfilled. 

95 

 
 
 
Topic 6

  Monitoring,  assessment  and  classification  of  chemical 

status of groundwater bodies 

6.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle 

6.1.1 Monitoring of chemical status in groundwater 

The  total  number  of  groundwater  bodies  in  Finland  is  3 773  (Table  2.4).  3 526  groundwater 
bodies (93 % of all groundwater bodies) are not subject to surveillance monitoring (Table 5.1). 

Only 247 groundwater bodies in six RBDs out of 3 773 groundwater bodies in eight RBDs are 
monitored for chemical status. In the Oulujoki-Iijoki RBD47 with 570 groundwater bodies and 
in the Åland RBD with five groundwater bodies there was no surveillance monitoring for any 
groundwater  body.  Finland  subsequently  clarified  that  because  of  the  large  number  of  small 

groundwater bodies grouping was applied in each RBD. Grouping was applied for geologically 
similar  groundwater  bodies  and  only  for  groundwater  bodies  at  good  chemical  status  and  if 

there were no human pressure or risk identified. 

Not all groundwater bodies at risk (6 %) were reported to be subject to operational monitoring. 
In  the  Oulujoki-Iijoki  RBD  there  were  30  groundwater  bodies  at  risk  and  only  seven  are 
subject to operational monitoring48. In all other RBDs the number of groundwater bodies under 
operational monitoring is higher than the number of groundwater bodies at risk. 

The  number  of  groundwater  bodies  with  surveillance  monitoring  increased  from  169  in  the 
first RBMP to 392 in the second RBMP. The number of monitoring sites is listed in Table 5.3 

(see chapter 5) and shows an increase of surveillance sites from 206 in the first RBMP to 441 
in the second RBMP. The number of operational monitoring sites has been increased since the 

first RBMP, from 203 to 302. 

Monitoring of substances at risk of causing deterioration in chemical status is very limited. The 

WFD  core  parameters  nitrate,  ammonium,  electrical  conductivity,  oxygen  and  pH  were  not 
monitored at all in five RBDs, and in three RBDs only some were monitored. 

6.1.2 Assessment and classification of chemical status in groundwater 

Map  6.1  and  Figure  6.1  displays  the  most  recently  assessed  chemical  status  of  groundwater 
bodies. It shows that 3 526 of 3 773 groundwater bodies (93 %) were of good chemical status, 

47 Finland noted that there is surveillance monitoring in the  Oulujoki  - Iijoki RBD but it has not been correctly 

reported in WISE which led to a reporting error. 

48   Finland  subsequently  clarified  that  there  must  have  been  a  technical  reporting  error  as  some  of  the  existing 

monitoring sites in this RBD which were used for operational monitoring had not been reported. 

96 

 
 
                                                      
96  groundwater  bodies  (3  %)  are  failing  good  status  and  the  remaining  151  (4  %)  are  of 

unknown  status.  Figure  6.2  shows  that  the  confidence  in  status  classifications  is  of  medium 
level.  The  number  of  groundwater  bodies  with  unknown  status  declined  from  216  (in  four 

RBDs) in the first RBMP to 151 groundwater bodies (in seven RBDs) in the second RBMP.  

Map 6.1  Map of the most recently assessed status chemical status of groundwater bodies in 

Finland  

Note: Standard colours based on WFD Annex V, Article 2.4.5. 

Source: WISE, Eurostat (country borders) 

97 

GoodPoorUnknownRiver Basin DistrictsCountries outside the EU 
 
 
 
 
Figure 6.1 

Chemical  status  of groundwater bodies in Finland for the second RBMP, 

for the first RBMP and expected in 2015. The number in the parenthesis is 
the number  of groundwater bodies for both cycles. Note the period  of the 

assessment  of  status  for  the  second  RBMP  was  in  2013.  The  year  of  the 
assessment of status for first RBMP is not known  

Source: WISE electronic reporting  

Figure 6.2 

Confidence in the classification of chemical status of groundwater  bodies 
in Finland based on the most recent assessment of status  

Source: WISE electronic reporting 

The total number of groundwater bodies of poor status increased since the first RBMP from 81 
(of 3 804 groundwater bodies) to 96 (of in total 3 773) groundwater bodies. 

98 

 
 
 
 
 
The reasons for the failure of good chemical status of groundwater bodies are shown in Figure 

6.3  .  For  83  groundwater  bodies  the  general  assessment  of  the  chemical  status  for  the 
groundwater  body  as  a  whole  was  failed.  This  assessment  considered  the  significant 

environmental risk from pollutants across a groundwater body and a significant impairment of 
the ability to support human uses. 124 groundwater bodies were failing the drinking water test 

which means that the requirements of drinking water protected areas have not been met. Two 
groundwater  bodies  were  failing  the  groundwater  associated  surface  water  test  which  means 

that  there  is  diminution  of  the  status  of  groundwater  associated  surface  water.  Three  
groundwater  bodies  were  failing  the  groundwater  dependent  terrestrial  ecosystem  test  which 

means that there is damage to groundwater dependent terrestrial ecosystems. Figure 6.4  shows 
the top 10 pollutants causing failure of status and Figure 6.6 the pollutants causing sustained 

upward trends.  

Figure 6.3 

Reasons  for  failing  good  chemical  status  in  Finland  for  the  most  recent 

assessment of status 

Source: WISE electronic reporting  

Notes: 
‘Surface water’ = Failure to achieve Environmental Objectives (Article 4 WFD) in associated surface water 
bodies or significant diminution of the ecological or chemical status of such surface water bodies. 

‘Groundwater dependent terrestrial ecosystems’ = Significant damage to terrestrial ecosystems which depend 
directly on the groundwater body. 

‘Saline or other intrusion’ = Regional saline or other intrusions resulting from anthropogenically induced 
sustained changes in flow direction. 

‘Drinking Water Protected Area’ = Deterioration in quality of waters for human consumption. 

‘General water quality assessment’ = Significant impairment of human uses; significant environmental risk from 
pollutants across the groundwater body. 

99 

 
 
 
 
Figure 6.4 

Top 10 groundwater pollutants causing failure of good chemical status in 

Finland  

Source: WISE electronic reporting 

The extent of exceedance of a groundwater quality standard or a groundwater threshold value 
was not calculated in one RBD as there were no such exceedances. 

For seven RBDs the extent of exceedance of a groundwater quality standard or a groundwater 
threshold value was calculated according to a method classified as ‘other’. The Kokemäenjoki-

Archipelago Sea-Bothnian Sea RBMP provided an explanation that if elevated concentrations 
are  detected,  more  samples  are  taken  to  define  the  extent  of  contamination  (how  far  the 

contamination  is  spread).  The  national  methodology  is  described  in  a  background  document. 
The acceptability of an exceedance is estimated using the criteria of the most sensitive receptor 

(drinking  water  source,  protection  area,  surface  water  body  etc.).  If  the  exceeded  limits  are 
estimated not to affect the most sensitive receptor, the status was considered good. 

In  four  RBDs  groundwater  threshold  values  have  not  been  established  for  all  pollutants  or 
indicators  of  pollution  causing  a  risk  of  failure  of  good  chemical  status.  The  RBMPs 
investigated in an in-depth assessment and indicated that the Groundwater Directive49 Annex II 
substances  have  been  considered  and  threshold  values  had  been  established.50  In  all  RBDs, 
natural  background  levels  have  been  considered  in  the  groundwater  threshold  value 

49   Groundwater Directive (GWD): Directive 2006/118/EC of the European Parliament and of the Council of 12 

December 2006 on the protection of groundwater against pollution and deterioration. 

50   Finland  subsequently  clarified  that  the  term  ‘risk’  was  interpreted  more  widely  where  groundwater  bodies 
could  have  been  identified  at  risk  of  an  anthropogenic  impact  but  there  might  not  be  a  specific  substance 
causing that risk. This approach will be corrected for the 3rd cycle report. 

100 

 
 
 
 
 
 
                                                      
establishment. Figure 6.5  shows the percentage of groundwater bodies at risk of failing good 

chemical status and good quantitative status. 

Figure 6.5 

Percentage of groundwater bodies in Finland at risk of failing good chemical 

status and good quantitative status for the second RBMP 

Source: WISE electronic reporting 

A trend and trend reversal methodology was available and assessments have been performed in 
all eight RBDs.  

101 

 
 
 
Figure 6.6 

Top 10 pollutants with upward trends in groundwater bodies in Finland  

Source: WISE electronic reporting  

6.1.3 Consideration  of  groundwater  associated  surface  waters  and/  or  groundwater 

dependent ecosystems 

In  total  221  groundwater  bodies  in  three  RBDs  were  identified  to  be  associated  to  such 
ecosystems. There is related risk in one groundwater body of the Vuoksi RBD. Groundwater 

associated  surface  waters  were  considered  in  status  assessment  except  for  the  Åland  RBD 
where no such ecosystems exist.  

6.2  Main changes in implementation and compliance since the first cycle 

The RBMPs provided a summary of changes for this topic. In the Kokemäenjoki-Archipelago 

Sea-Bothnian Sea RBD it is explained that the number of groundwater bodies increased as new 
groundwater bodies were considered important or potential drinking water sources. Changes of 

the  status  are  not  explicitly  described,  but  it  is  mentioned  that  the  chemical  status  of  38 
groundwater  bodies  was  poor.  In  the  RBMP  of  the  Åland  RBD  changes  were  not  explicitly 
described,  but  a  new  2013  guideline  was  referred  to  (the  same  as  in  Sweden),  which  is  now 

used for the assessment of the chemical status. 

The  monitoring  situation  improved  slightly.  Grouping  of  groundwater  bodies  for  monitoring 

has  been  done  in  all  RBDs  and  covers  all  groundwater  bodies  of  good  chemical  status,  no 
human  pressures  and  without  risk.  Coverage  of  operational  monitoring  is  still  not  complete 

102 

 
 
 
although  it  has  improved51.  Monitoring  of  WFD  cores  parameters  and  substances  at  risk  of 
causing deterioration in chemical status is very limited.  

The  status  situation  deteriorated  as  the  number  of  groundwater  bodies  failing  good  status 

increased.  

6.3  Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMPs  and  first  Programme  of 
Measures requested action on the following: 

  Recommendation:  

Where  there  are  currently  high  uncertainties  in  the  characterisation  of  the  RBDs, 

identification of pressures, and in the assessment of status, these need to be addressed 
in the current cycle, to ensure that adequate measures can be put in place before the 

next cycle. 

Finland  needs  to  base  its  classification  on  such  extended  monitoring  results.  The 

ecological status assessments are based primarily on expert judgement but not on WFD 
compliant methods, and there is a significant shortcoming in the availability of data for 

classification. 

Assessment:  The  recommendation  mainly  focused  on  surface  water  quality. 

Nevertheless,  the  recommendation  to  base  the  classification  on  extended  monitoring 
results was not taken up. The number of groundwater chemical monitoring sites is still 

very limited. Therefore this recommendation has not been fulfilled.  

  Recommendation:  

A new groundwater  monitoring programme for  Åland  includes monitoring of  general 
parameters,  but  involvement  of  other  parameters  and  improvements  are  needed  to 

enable trend detection for the next RBMP cycles. 

Groundwater monitoring should be enhanced in Finland and should be made capable 

of detecting pollution trends. Trend and trend reversal assessments should be carried 
out  in  the  second  RBMP  cycle  regardless  of  whether  additional  preventive  measures 

have been applied. 

51   Finland  subsequently  clarified  that  there  must  have  been  a  technical  reporting  error  as  some  of  the  existing 

monitoring sites in this RBD which were used for operational monitoring had not been reported. 

103 

 
 
                                                      
Assessment:  The  recommendation  to  enhance  groundwater  monitoring  was  not  fully 

taken up. The number of groundwater surveillance and operational monitoring sites did 
increase  but  there  were  still  groundwater  bodies  with  unknown  status.  Grouping  of 

groundwater  bodies  for  monitoring  only  included  groundwater  bodies  of  good  status 
and without risk. In the Oulujoki-Iijoki RBD with 570 groundwater bodies and in the 

Åland  RBD  with  five  groundwater  bodies  no  groundwater  body  was  subject  to 
surveillance  monitoring.  However  Finland  subsequently  clarified  that  the  lack  of 

surveillance monitoring was due to technical error in reporting. Trend assessment has 
been performed in all RBDs and methodologies for trend reversal assessment are also 

available in all RBDs. Therefore this recommendation has been partially fulfilled.  

104 

 
 
 
 
 
Topic 7

  Designation  of  Heavily  Modified  and  Artificial  Water 

Bodies and definition of Good Ecological Potential 

7.1  Assessment of implementation and compliance with WFD requirements 

in second cycle for designation  

7.1.1 Designation of Heavily Modified and Artificial Water Bodies 

2 % of total surface water bodies are designated as heavily modified water bodies and 0.5 % as 
artificial  water  bodies  (Figure  7.1).  No  heavily  modified  water  bodies  and  artificial  water 

bodies were reported for the Teno, Näätämöjoki and Paatsjoki and the Åland RBD’s, similar to 
the first RBMPs. Information on whether reservoirs were originally rivers or lakes has not been 

reported. 

Figure 7.1 

Proportion of total water bodies in each category in Finland that has been 

designated as heavily modified or artificial 

Source: WISE electronic reporting 

The  main  water  uses  for  which  river  water  bodies  are  designated  as  heavily  modified  water 

bodies are hydropower production, land drainage for agriculture and flood protection. For lake 
water  bodies,  the  main  water  uses  for  designation  as  heavily  modified  water  bodies  are 

hydropower production and flood protection. For coastal water bodies, heavily modified water 
body  designation  is  related  to  navigation  /  ports,  drinking  water  supply  in  urban  areas  and 
industry supply. 

105 

 
 
 
The  main  physical  alterations  of  river  and  lake  heavily  modified  water  bodies  are 

channelisation /  straightening /  bed stabilisation / bank reinforcement and dredging /  channel 
maintenance. For coastal heavily modified water bodies, the main physical alterations are locks 

and channelisation / straightening / bed stabilisation / bank reinforcement. 

The  methodology  for  heavily  modified  water  bodies  designation  includes  information  on  the 

assessment  of  substantial  change  in  character.  Concerning  the  assessment  of  significant 
adverse effects of restoration measures on the use or the wider environment, the methodology 

notes that it must take into account the effects on the production of hydropower plants and the 
profitability  of  the  power  plant.  According  to  the  national  methodological  document  of  the 

RBMPs,  in  large  water  bodies,  5  to  10  %  of  loss  to  power  generation  can  be  considered 
significant with great certainty. The document suggests that the adverse effects should also be 

assessed  in  relation  to  the  ecological  benefits.  A  methodological  option  suggested  is  to 
consider different alternative definitions of significance of the adverse effects (e.g. more than 2 

%, more than 5 % or more than 10 % less hydropower produced) of the measures needed to 
achieve significant ecological benefits. No information was however found on the assessment 
of other means to achieve the beneficial objectives served by the modifications of the heavily 

modified water body. 

7.1.2 Definition of Good Ecological  Potential for Heavily Modified  and Artificial  Water 

Bodies 

Good ecological potential was reported as defined at water body level in six out of eight RBDs. 

(note that there  are no designated heavily  modified water bodies or  artificial water bodies in 
Teno, Naatamajoki and Paatsjoki and the Åland).  

The  Prague  approach  (based  on  the  identification  of  mitigation  measures)  was  used  for 
defining  good  ecological  potential.  Therefore,  the  good  ecological  potential  has  not  been 

defined  in  terms  of  biology.  However,  the  relevant  biological  quality  elements  were  derived 
and assessed, and those were reported in WISE (macrophytes, fish and benthic invertebrates). 

A  comparison  between  good  ecological  potential  to  good  ecological  status  has  not  been 
undertaken in any of the RBDs according to the WISE report.52 According to information from 
the RBMP, the ecological status class of a heavily modified water body is first determined as 
in  natural  water bodies.  Then the ecological  potential  for the heavily modified water body is 

defined by the water quality or hydro-morphological state, using the least good of those two. 
The actual classification works as follows: (1) The general water quality, as well as the status 

52   Finnish  authorities  have  informed  that  a  comparison  between  good  ecological  potential  to  good  ecological 
status  has  been  undertaken  whenever  information  on  biological  quality  elements  existed.  As  a  result,  the 
assessment  of  the  ecological  status  class  of  HMWB  contains  information  of  biological  quality  elements  in 
addition to water quality and hydro-morphological state. 

106 

 
 
                                                      
of the phytoplankton (lakes) or diatoms (rivers), has been estimated according to the ecological 

classification  guidelines;  (2)  The  effect  of  hydromorphological  measures  on  aquatic  plants, 
benthic invertebrates and fish has been evaluated; and 3) The status class is determined to be 

the poorest out of the estimations/evaluations under the previous steps 1) and 2). 

For rivers, methods  for  assessing  benthic invertebrates and fish were reported as sensitive to 

hydrological  and  morphological  changes.  For 
lakes,  methods  for  assessing  benthic 
invertebrates  are  sensitive  to  hydrological  and  morphological  changes  and  methods  for 

assessing  macrophytes  are  sensitive  only  to  hydrological  changes.  For  coastal  water  bodies, 
methods  for  assessing  macroalgae  are  sensitive  to  hydrological  changes  and  methods  for 

assessing benthic invertebrates and angiosperms are sensitive to morphological changes. 

Mitigation  measures  for  defining  good  ecological  potential  have  been  reported  and  the 

ecological changes expected due to the mitigation measures are described in a qualitative way. 
There is a classification scale of small, medium and large changes with examples for each class 

for fish populations, aquatic plants and benthic invertebrates. 

7.2  Main changes in implementation and compliance since the first cycle 

There  are  no  significant  changes  in  the  extent  of  heavily  modified  water  body  and  artificial 

water body designation since the first cycle. Only in the Kemijoki RBDs, the number of water 
bodies  designated  as  heavily  modified  water  body  is  almost  double  in  the  second  RBMPs 

compared to first cycle. However, the designated heavily modified water bodies are still a very 
small share of total water bodies. 

The reasons for changes in designation are not explicitly explained, although it is noted that the 
designations have been reviewed. 

There is no exact description of the changes made to the methodology for designating heavily 
modified water bodies, but the criteria seem to be defined in a more detailed form than in the 

first RBMPs. Furthermore, the basis of evaluation of hydrological and morphological status is 
described in more detail. 

Concerning the definition of good ecological potential, it is stated that the lists of hydrological 
and  morphological  measures  considered  and  the  assessment  scale  of  their  effects  have  been 

changed. No other relevant information or explanations were found. 

107 

 
 
7.3  Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMPs  and  first  Programme  of 
Measures requested action on the following: 

  Recommendation:  The  designation  of  heavily  modified  water  bodies  should  comply 

with all the requirements of Article 4(3). 

Assessment:  The  methodology  for  designation  of  heavily  modified  water  bodies 
includes  information  on  the  assessment  of  substantial  change  in  character  and 

significant adverse effects of restoration measures on the use or the wider environment. 
There is no exact description of the changes made to the methodology for designating 

heavily  modified  water  bodies,  but  the  criteria  seem  to  be  defined  in  a  more  detailed 
form than in the first RBMPs. Furthermore, the basis of evaluation of hydrological and 

morphological status is described in more detail. 

However, no information  was found on the assessment  of other means to  achieve the 

beneficial objectives served by the modifications of the heavily modified water body. 
Furthermore,  specific  information  on  the  outcome  of  the  assessment  of  significant 

adverse effects and better environmental options is not given on water body level. 

Concerning  the  definition  of  good  ecological  potential,  it  is  stated  that  the  lists  of 

hydrological and morphological measures considered and the assessment scale of their 
effects have been changed. Mitigation measures for defining good ecological potential 

have been reported and the ecological changes expected due to the mitigation measures 
are described in a qualitative way. Nevertheless, good ecological potential has not been 
defined fully in terms of biology yet (using all detailed information on all the relevant 

biological quality elements). 

Therefore, this recommendation has been partially fulfilled. 

108 

 
 
 
Topic 8

  Environmental objectives and exemptions 

8.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle 

8.1.1. Environmental objectives 

The  environmental  objectives  are  defined  in  Article  4  of  the  WFD.  The  aim  is  long-term 

sustainable water management based on a high level of protection of the aquatic environment. 
Article 4(1) defines the WFD general objective to be achieved in all surface and groundwater 

bodies,  i.e.  good  status  by  2015.  Within  that  general  objective,  specific  environmental 
objectives are defined for heavily modified water bodies (good ecological potential and good 
chemical status by 201553), groundwaters (good chemical and quantitative status by 2015) and 
for Protected Areas (achievement of the objectives of the associated Directive by 2015 unless 

otherwise specified). 

Environmental objectives for ecological and chemical status have been reported in all RBDs as 

well  as  for  good  quantitative  and  chemical  groundwater  status.  The  number  of  exemptions 
under Article 4(4) has increased compared to the first cycle.  

Member States are also required to specify additional environmental objectives and standards 
in  Protected  Areas  where  these  are  required  to  ensure  the  requirements  of  the  associated 

Directive  are  met.  An  assessment  of  such  additional  objectives  for  Finland  is  provided  in 
Chapter 15 of this report. 

Assessments  of the current  status  of surface and groundwater bodies in  Finland are provided 
elsewhere in this report: for ecological status/potential of surface waters (Chapter 3); chemical 

status  of  surface  waters  (Chapter  4);  quantitative  status  of  groundwater  bodies  (Chapter  5); 
chemical status of groundwater bodies (Chapter 6); status of surface and groundwater bodies 

associated with Protected Areas (Chapter 15). 

For the second RBMPs, Member States are required to report the date when they expect each 

surface  and  groundwater  body  to  meet  its  environmental  objective.  This  information  is 
summarised  for  Finland  elsewhere  in  this  report:  for  ecological  status/potential  of  surface 
waters  (Chapter  3);  chemical  status  of  surface  waters  (Chapter  4);  quantitative  status  of 

groundwater bodies (Chapter 5); chemical status of groundwater bodies (Chapter 6).  

53   For priority substances  newly introduced by Directive 2013/39/EU, good status should  be  reached by 2027, 
and for the 2008 priority substances, for which the Environmental Quality Standards were revised by Directive 
2013/39/EU, good status should be reached in 2021. 

109 

 
 
                                                      
8.1.2. Exemptions 

Where  environmental  objectives  are  not  yet  achieved  exemptions  can  be  applied  in  case  the 

respective conditions are met and the required justifications are explained in the RBMP. Figure 
8.1 summarises the percentage of water bodies expected to be at least in good status in 2015 

and  the  use  of  at  least  one  exemption  in  Finland  for  the  four  main  sets  of  environmental 
objectives.  Exemptions  are  most  widely  applied  in  relation  to  surface  water  chemical  status 

objectives. 

Figure 8.1 

Water bodies in Finland expected to be in at least good status in 2015 and 

use of exemptions. 1 = Surface water body ecological status/potential; 2 = 
Surface  water  body  chemical  status;  3  =  Groundwater  body  quantitative 

status; 4 = Groundwater body chemical status 

Source: WISE electronic reporting. For some water bodies the date for achievement of good status is unknown. 

Article  4  of  the  WFD  allows  under  certain  conditions  for  different  exemptions  to  the 

objectives:  extension  of  deadlines  beyond  2015,  less  stringent  objectives,  a  temporary 
deterioration,  or  deterioration  /  non-achievement  of  good  status  /  potential  due  to  new 

modifications, provided a set of conditions are fulfilled. The exemptions under WFD Article 4 
include the provisions in Article 4(4)  - extension of deadline, Article 4(5) - lower objectives, 

Article 4(6) - temporary deterioration and Article 4(7)  - new modifications / new sustainable 
human  development  activities.  Article  4(4)  exemptions  may  be  justified  by:  disproportionate 

110 

 
 
 
cost,  technical  feasibility  or  natural  conditions,  and  Article  4(5)  by  disproportionate  cost  or 
technical  feasibility.  In addition,  Article 6(3) of the Groundwater Directive54  allows Member 
States to exempt inputs of pollutants to groundwaters under certain specified circumstances. 

Figure 7.2 summarises the percentage of water bodies subject to each type of exemption (and 
reason) in relation to the four types of environmental objectives in Finland. 

54   Directive 2006/118/EC of the European Parliament and of the Council of 12 December 2006 on the protection 
http://eur-lex.europa.eu/legal-

deterioration 

and 

groundwater 

of 
content/EN/TXT/?uri=CELEX:02006L0118-20140711 

pollution 

against 

111 

 
 
                                                      
Figure 7.2 

Type  of  exemptions  applied  to  surface  water  and  groundwater  bodies  for 

the  second  plan  in  Finland.  Note:  Ecological  status  and  groundwater 
quantitative  status  exemptions  were  reported  at  the  water  body  level. 

Chemical  exemptions  for  groundwater  were  reported  at  the  level  of  each 
pollutant  causing  failure  of  good  chemical  status,  and  for  surface  waters 

for each Priority Substances that is causing failure of good chemical status  

Source: WISE electronic reporting 

112 

 
 
 
Application of Article 4(4) 

The application of Article 4(4) has increased in surface water from the first to the second cycle 
and  is  now  also  applied  in  groundwater  in  the  Vuoksi,  Kymijoki-Gulf  of  Finland, 
Kokemäenjoki-Archipelago Sea-Bothnian Sea and Oulujoki-Iijoki RBDs55.  

In  the  second  cycle,  the  justification  for  surface  water  in  relation  Article  4(4)  refers,  in  all 

RBDs,  to  technical  feasibility  and  natural  conditions.  In  the  Kymijoki-Gulf  of  Finland  RBD 
also  disproportionate  costs  are  used  as  an  argument.  The  Åland  RBD  is  not  using 

disproportional costs any longer (was used in the first cycle).  

For  groundwater  in  the  Kymijoki-Gulf  of  Finland  RBD  and  the  Kokemäenjoki-Archipelago 

Sea-Bothnian Sea RBD, natural conditions and technical feasibility are used as reason for the 
application  of  Article  4(4)  related  to  chemical  status.  In  the  Vuoksi  RBD  and  the  Oulujoki-

Iijoki  RBD,  only  technical  feasibility  is  used  as  reason  for  the  application  of  Article  4(4) 
related to  chemical status. In relation to quantitative status, technical  feasibility is used as an 

argument in the Vuoksi RBD and the Kokemäenjoki-Archipelago Sea-Bothnian Sea RBD.  

As  regards  technical  feasibility,  the  RBMPs  provide  general  information.  The  RBMP  of  the 
Kymijoki-Gulf  of  Finland  RBD  refers  to  the  long  timeframes  and  the  lack  of  technical 

solutions  to  control  the  diffuse  nutrient  loading  from  agriculture  (surface  waters).  For 
groundwater, there are contaminated groundwater sources where pollutants are spread so wide 

and deep into the groundwater that there is currently no economically and technically feasible 
method to purify them.  

According to WISE the detailed arguments behind disproportional costs refer to affordability, 
assessment of the consequences of non-action, benefits assessment, cost-benefit analysis, cost-

effectiveness  analysis  and  social  and  sectorial  impacts.  For  surface  waters  in  the  Kymijoki-
Gulf  of  Finland  RBD  mentions  in  relation  to  disproportionate  costs:  i)  affordability  ii), 

assessment of the consequences of non-action, iii) benefits assessment, iv) cost-benefit analysis 
and v) social and sectorial impacts. The justification of disproportionate costs was only used in 

four  cases.  Further  explanation  is  not  given  in  the  RBMP.  In  the  RBMP  of  the  Åland  RBD, 
two reasons  for disproportionate costs in the  coastal waters were mentioned: 1) nutrients  are 

stored in the bottom sediment and are slowly released. It is not economically wise to remove 

55   Finland subsequently clarified that there are several reasons for the increase of Article 4(4) exemptions. The 
main reason for increase is exemptions in chemical status, because of mercury. In the 1st cycle assessment of 
mercury  was  not  applied  to  all  designated  water  bodies.  Main  reason  for  mercury  exemptions  are  natural 
background levels and airborne pollution. Other reasons relate to increase of the  number of classified  water 
bodies and also to small increase of designated water bodies for the second RBMP’s. 

113 

 
 
                                                      
them  with  technology,  and  2)  there  are  areas  with  slow  circulation  of  water,  where  wider 

passages for water could be opened, but this is not economically feasible. 

As regards natural conditions, some general information on the justification is provided in the 

RBMPs.  The  RBMP  of  the  Kymijoki-Gulf  of  Finland  RBD  mentions  as  justification  the 
internal load coming from many lakes and coastal areas and that it takes time before the effect 

of  measures  are  seen  in  large  water  bodies.  The  ecosystem-level  changes  are  slow.  For 
groundwater bodies, the justification refers to contaminated groundwaters, where pollutants are 

spread very wide and deep into the groundwater aquifers. For the coastal waters of the Åland 
RBD,  the  argument  is  that  the  overall  state  of  the  Baltic  Sea  has  a  large  effect  on  the  water 

quality, and it can only be improved by international co-operation. There are also some areas 
with slow circulation of water. Also, the internal load of nutrients is used as an argument. 

The drivers causing exemptions in groundwater are mainly agriculture, industry and transport. 
For surface water no information was reported to WISE due to technical reasons.  

The pressures responsible for exemptions in surface water in relation to good ecological status 
come  from  a  broad  range  of  activities  including  urbanisation,  industry,  agriculture,  mining, 
atmospheric  deposition  and  activities  causing  changes  in  hydromorphology  (Table  8.1  ).  For 

groundwater, the main pressures are point source pollution from industry, waste disposal and, 
to a minor extent, agriculture (Table 8.2 ).  

The impacts caused by exemptions under Article 4(4) have not been reported to WISE56. For 
groundwater  the  impacts  are  chemical  and  nutrient  pollution,  abstraction  exceeds  available 

groundwater resource (lowering water table) and other significant impacts.  

Table 8.1 

Pressure responsible for Priority Substances  in Finland failing to achieve 

good chemical status and for which exemptions have been applied 

Significant pressure on surface water bodies 

Failing Priority 
Substances 

Article 4(4) - 
Technical 
feasibility 
exemptions 

Article 4(5) - 
Technical 
feasibility 
exemptions 

Number 

Number 

Number 

1.1 - Point - Urban waste water 

1.3 - Point - IED plants 

1.4 - Point - Non IED plants 

1.5 - Point - Contaminated sites or abandoned 
industrial sites 

1.6 - Point - Waste disposal sites 

4 

4 

3 

2 

2 

97 

23 

8 

7 

4 

0 

0 

0 

0 

0 

56 Finland subsequently clarified that this information can be found on a general level in the RBMP. 

114 

 
 
                                                      
Significant pressure on surface water bodies 

1.7 - Point - Mine waters 

1.9 - Point - Other 

2.1 - Diffuse - Urban run-off 

2.10 - Diffuse - Other 

2.2 - Diffuse - Agricultural 

2.3 - Diffuse - Forestry 

2.4 - Diffuse - Transport 

2.5 - Diffuse - Contaminated sites or abandoned 
industrial sites 

2.6 - Diffuse - Discharges not connected to 
sewerage network 

2.7 - Diffuse - Atmospheric deposition 

2.8 - Diffuse - Mining 

3.3 - Abstraction or flow diversion - Industry 

4.1.1 - Physical alteration of channel/bed/riparian 
area/shore - Flood protection 

4.1.2 - Physical alteration of channel/bed/riparian 
area/shore - Agriculture 

4.1.3 - Physical alteration of channel/bed/riparian 
area/shore - Navigation 

4.1.4 - Physical alteration of channel/bed/riparian 
area/shore - Other 

4.1.5 - Physical alteration of channel/bed/riparian 
area/shore - Unknown or obsolete 

4.2.1 - Dams, barriers and locks - Hydropower 

4.2.2 - Dams, barriers and locks - Flood protection 

4.2.4 - Dams, barriers and locks - Irrigation 

4.2.5 - Dams, barriers and locks - Recreation 

4.2.6 - Dams, barriers and locks - Industry 

4.2.8 - Dams, barriers and locks - Other 

4.3.1 - Hydrological alteration - Agriculture 

4.3.3 - Hydrological alteration - Hydropower 

4.3.4 - Hydrological alteration - Public water supply 

4.3.6 - Hydrological alteration - Other 

4.5 - Hydromorphological alteration - Other 

5.1 - Introduced species and diseases 

7 - Anthropogenic pressure - Other 

8 - Anthropogenic pressure - Unknown 

Failing Priority 
Substances 

Article 4(4) - 
Technical 
feasibility 
exemptions 

Article 4(5) - 
Technical 
feasibility 
exemptions 

Number 

Number 

Number 

33 

172 

7 

90 

814 

581 

1 

4 

433 

3 433 

2 

5 

70 

42 

4 

43 

1 

63 

39 

13 

5 

13 

6 

15 

26 

2 

6 

24 

1 

168 

6 

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 

3 

2 

2 

3 

4 

4 

1 

1 

4 

4 

2 

3 

3 

1 

1 

2 

1 

2 

2 

1 

1 

3 

2 

2 

2 

1 

1 

2 

1 

4 

1 

115 

 
 
Source: WISE electronic reporting 

Table 8.2 

Pressure  responsible  for  pollutants  in  Finland  failing  to  achieve  good 
chemical  status  in  groundwater  and  for  which  exemptions  have  been 

applied  

Significant pressure on 
groundwater 

1.4 - Point - Non IED plants 

1.5 - Point - Contaminated sites or 
abandoned industrial sites 

1.6 - Point - Waste disposal sites 

1.9 - Point - Other 

2.1 - Diffuse - Urban run-off 

2.2 - Diffuse - Agricultural 

2.3 - Diffuse - Forestry 

2.4 - Diffuse - Transport 

7 - Anthropogenic pressure - Other 

Application of Article 4(5) 

Number of 
failing 
pollutants 

Number of exemptions 

Article 4(4) - Natural 
conditions 

Article 4(4) - Technical 
feasibility 

54 

61 

10 

33 

21 

30 

1 

50 

6 

118 

90 

16 

16 

31 

1 

76 

6 

Source: WISE electronic reporting 

128 

125 

10 

37 

16 

25 

93 

7 

As in the first cycle, Article 4(5) has not been used.  

Application of Article 4(6) 

Article 4(6) exemptions are not applied.  

Application of Article 4(7) 

Article 4(7) exemptions are not applied. In the RBMPs of both the Kymijoki-Gulf of Finland 
RBD and the Kemijoki RBD, there is a section on new significant projects which might trigger 

Article 4(7). The RBMPs explain the process of the required assessment. The check included 
projects where the Environmental Impact Assessment process started at the latest in 2013. The 

first  check  was  if  projects  have  significant  effect  on  the  water  body  or  if  they  are  at  places 
where no surface or groundwater bodies are nearby. In the Kymijoki-Gulf of Finland RBD, all 

projects belonged to this category. For the Kemijoki RBD, the check continued by excluding 
those projects from further studies which had already a valid environmental or water permit or 
the  implementation  of  the  project  was  uncertain.  During  the  3rd  check,  the  remainder  of  the 
projects  were  excluded  from  the  further  application  of  Article  4(7)  for  two  reasons:  1)  The 
project was not expected to cause physical alterations in water bodies and will not compromise 

116 

 
 
 
 
the achievement of good status, and 2) The project was found only to deteriorate the ecological 

status  of  water  from  high  to  good.  The  information  for  the  check  has  been  taken  from  the 
Environmental Impact Assessment documents. In both RBMPs, it was concluded that there is 

no need to apply Article 4(7). The potential application of the exemptions are evaluated again 
as the project data becomes more accurate; for example, in connection with licensing.  

In the RBMP of the Åland RBD, no such section in the RBMP was found. In the RBMP of the 
Kemijoki RBD, there was no information on the planned Sierilä power plant project.  

Application of Article 6(3) of the Groundwater Directive 

Exemptions to groundwater under Article 6(3) of the Groundwater Directive57 have not been 
applied.  

8.2  Main changes in implementation and compliance since the first cycle 

The  application  of  Article  4(4)  has  increased  in  surface  water  and  is  now  also  applied  in 

groundwater.  Article  4(5),  Article  4(6)  and  4(7)  have  not  been  applied  in  either  the  first  or 
second cycle. 

8.3  Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMPs  and  Programme  of  Measures 

requested action on the following: 

  Recommendation:  Provide more detailed information in  the RBMPs on activities that 
may modify the hydromorphological conditions of the water bodies and have a negative 
impact  on  the ecological status, including  on the mitigation measures included in  the 

Water Act (587/2011). 

Assessment:  Some  of  the  assessed  RBMP  provide  an  explanation  on  the  process  of 

checking if activities that may modify the hydromorphological conditions of the water 
bodies  and  have  a  negative  impact  on  the  ecological  status.  The  fact  that  expected 

deterioration from high to good status seems not to trigger an Article 4(7) assessment 
might  be  an  issue  of  insufficient  and/or  potentially  non-compliant  implementation  of 

WFD requirements. This recommendation has been partially fulfilled. 

57   Directive 2006/118/EC of the European Parliament and of the Council of 12 December 2006 on the protection 
http://eur-lex.europa.eu/legal-

deterioration 

pollution 

and 

groundwater 

of 
content/EN/TXT/?uri=CELEX:02006L0118-20140711 

against 

117 

 
 
                                                      
  Recommendation:  Finland  needs  to  provide  more  transparency  in  the  RBMPs  on  the 
assessment of environmental objectives and exemptions. This is particularly important 
given  the  large  number  of  water  bodies  that  are  currently  classified  as  in  unknown 

status.  

Assessment: The recommendation has been partially fulfilled as objectives have been 

set  at  water body level.  The justifications on exemptions  are not  fully clear and there 
seems to be a mix of arguments. These arguments cannot always clearly be allocated to 

the three reasons for exemptions as set out in the WFD. 

  Recommendation:  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  an 
assessment  on  whether  the  project  is  of  overriding  public  interest  and  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. All conditions for the application of Article 

4(7) in individual projects must be included and justified in the RBMPs as early in the 
project planning as possible.  

  Assessment:  Article  4(7)  has  not  been  applied  but  some  procedures  have  been 
established for potential Article 4(7) cases in the context of the Environmental Impact 

Assessment. The fact that expected deterioration from high to good status seems not to 
trigger  an  Article  4(7)  assessment  might  be  an  issue  of  insufficient  and/or  potentially 

non-compliant implementation of WFD requirements. 

118 

 
 
 
 
Topic 9

  Programme of measures  

The aim of this chapter is to provide an overview of the Programme of Measures reported by 

Member  States;  more  specific  information  on  measures  relating  to  specific  pressures  (for 
example arising from agriculture) is provided in subsequent chapters. 

The Key Types of Measures (KTM) referred to in this section are groups of measures 
identified  by  Member  States  in  the  Programme  of  Measures,  which  target  the  same 

pressure  or  purpose.  The  individual  measures  included  in  the  Programme  of  Measure 
(being  part  of  the  RBMP)  are  grouped  into  Key  Types  of  Measure  for  the  purpose  of 

reporting.  The  same  individual  measure  can  be  part  of  more  than  one  Key  Types  of 
Measure because it may be multi-purpose, but also because the Key Types of Measure 

are  not  completely  independent  silos.  Key  Types  of  Measure  have  been  introduced  to 
simplify  the  reporting  of  measures  and  to  reduce  the  very  large  number  of 

Supplementary Measures reported by some Member States (WFD Reporting Guidance 
2016).  

A Key Type of Measure may be one national measure but it would typically comprise 
more than one national measure. The 25 predefined Key Types of Measure are listed in 

the WFD Reporting Guidance 2016. 

The Key Types of Measure should be fully implemented and made operational within 

the  RBMP  planning  period  to  address  specific  pressures  or  chemical  substances  and 
achieve the environmental objectives. 

9.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle 

9.1.1.  General issues 

An  indication  as  to  whether  or  not  measures  have  been  fully  implemented  and  made 

operational is when they have been reported as being planned to tackle significant pressures (at 
the  Key  Types  of  Measure  level).  Significant  pressures  are  also  reported  at  the  water  body 

level.  It  would  therefore  be  expected  that  there  would  be  measures  planned  in  the  RBMP  to 
tackle  all  significant  pressures.  Significant  pressures  considered  to  be  causing  failure  of 

objectives  for  groundwater  bodies  have  been  reviewed  for  a  selection  of  the  eight  RBDs  for 
which information is provided from Finland. In the Vuoksi RBD, significant pressures causing 

failure of objectives for groundwater cover point sources, diffuse sources, abstraction or flow 

119 

 
 
 
 
diversion,  groundwater  recharge/levels/volumes  and  diffuse  atmospheric  pollution.  However 

reported  do  not  cover 

KTMs 
to  groundwater 
recharge/levels/volumes  and  diffuse  atmospheric  pollution.  In  the  Oulujoki-Iijoki  RBD,  the 

the  significant  pressures 

relating 

KTMs  reported  do  not  cover  significant  pressures  associated  with  diffuse  atmospheric 
pollution, abstractions or flow diversions associated with public water supply and alterations of 

water levels/volumes.  In the Kemijoki RBD,  KTMs  reported do not  cover certain  significant 
pressures  causing  failure  associated  with  point  sources  (Point  -  Other),  diffuse  urban  run-off 

and abstractions or flow diversions associated with public water supply. For this RBD, a KTM 
was reported for ‘Diffuse - discharges not connected to the sewage network’ but this source is 

not  identified  as  a  significant  pressure  causing  failure.  For  surface  waters,  there  are  further 
examples of where KTMs do not cover all significant pressures identified. In the Vuoksi RBD, 

significant  pressures  from  dams,  barriers  and  locks  (for  irrigation,  industry,  and  others 
respectively) as well as from diffuse atmospheric and pollution and groundwater recharges are 

not covered. A very similar situation arises in the Oulujoki-Iijoki RBD except that abstraction 
or  flow  diversion  (industry)  replaces  groundwater  recharges.  For  the  Åland  RBD,  diffuse 
atmospheric pollution is not covered by a KTM. 

14  national  basic  measures  have  been  mapped  against  four  predefined  KTMs  (KTM1  - 
Construction or upgrades of wastewater treatment plants, KTM15 - Measures for the phasing-

out of emissions, discharges and losses of Priority Hazardous Substances or for the reduction 
of  emissions,  discharges  and  losses  of  Priority  Substances,  KTM16  -  Upgrades  or 

improvements  of  industrial  wastewater  treatment  plants  (including  farms)  and  KTM22  - 
Measures to prevent or control the input of pollution from forestry). KTM 15  - Measures for 

the phasing-out of emissions, discharges and losses of Priority Hazardous Substances or for the 
reduction  of  emissions,  discharges  and  losses  of  Priority  Substances  applies  to  only  three 

RBDs, the other each apply to seven of the eight RBDs. 59 national supplementary measures 
have  been  mapped  against  14  pre-defined  KTMs  and  one  nationally  developed  KTM  (Lake 

Restoration).  The  basic  measures  apply  in  a  variety  of  RBDs;  for  example,  nine  national 
supplementary  measures  have  been  mapped  against  KTM2  -  Reduce  nutrient  pollution  from 

agriculture  in  all  eight  RBDs,  whilst  one  national  supplementary  measure  has  been  mapped 
against  KTM3  -  Reduce  pesticides  pollution  from  agriculture  in  four  RBDs.  Basic  measures 

have  been  reported  against  only  three  of  the  requirements  of  Article  11(3)  (see  Table  7.2): 
Article  11(3)(g):  Requirement  for  prior  regulation  of  point  source  discharges  liable  to  cause 

pollution; Article 11(3)(h): Measures to prevent or control the input of pollutants from diffuse 
sources  liable  to  cause  pollution;  and  the  Urban  Waste  Water  Treatment  Directive 

(91/271/EEC). An inventory of national basic and supplementary measures has been reported. 
In general the KTMs reported to be mapped against national measures are aligned with those 

120 

 
 
KTMs  reported  for  significant  pressures  although  there  are  some  inconsistencies.  KTM4  - 

Remediation of contaminated sites (historical pollution including sediments, groundwater, soil) 
was  reported  as  addressing  significant  pressures  in  five  RBDs,  KTM8  -  Water  efficiency, 

technical  measures  for  irrigation,  industry,  energy  and  households  as  addressing  significant 
pressures in three RBDs and the national KTM Environmental management of soil extraction 

sites in five RBDs but none of these KTMs have any national measures mapped against it. On 
the other hand, KTM13 - Drinking water protection measures (e.g. establishment of safeguard 

zones, buffer zones etc.) and KTM24 - Adaptation to climate change have national measures 
mapped against them, but are not reported to be operational in addressing significant pressures.  

No  KTMs  have  been  reported  to  be  tackling  River  Basin  Specific  Pollutants.  A  direct 
explanation for this is not provided in the Annex 0 report for Finland. A considerable number 

of pollutants are identified to be causing failure of objectives in groundwater at least in the four 
RBDs  for  which  information  was  reported  (Vuoksi,  Kymijoki  –  Gulf  of  Finland, 

Kokemäenjoki  –  Archipelago  Sea–Bothnian  Sea,  and  Oulujoki-Iijoki).  No  information  on 
pollutants causing failure in surface waters is presented. 

Information on the Priority Substances causing failure of objectives was reported for only five 

of the eight RBDs (Vuoksi, Kymijoki – Gulf of Finland, Kokemäenjoki – Archipelago Sea – 
Bothnian  Sea,  Oulujoki-Iijoki,  and  Kemijoki).  The  Priority  Substances  causing  failures  of 

chemical status include: nickel and its compounds; cadmium and its compounds; mercury and 
its compounds and the tributyltin cation. KTMs have been identified for nickel and cadmium. 

No KTMs were reported for mercury and its compounds and the tributyltin (TBT) cation but 
explanations are proved in the Annex 0 report. For mercury, a statement is made that national 

measures  do  not  exist  for  long-range  transport  of  airborne  pollutants  such  as  mercury.  For 
tributyltin,  it  is  stated  that  observed  high  tributyltin  concentrations  in  certain  sites  originate 

from  historical  use  and  although  restrictions  were  put  in  place  prior  to  the  ban  across  the 
European Union in 2008, due to its slow degradation, it is still present in the environment. 

Reported  indicators  of  the  gap  to  good  status  for  significant  pressures  on  groundwater  and 
surface waters were reported fairly sporadically across RBDs and only for 2015. No values are 

available for 2021 and 2027. The same applies to the KTM indicator values. It is therefore not 
possible to track reductions in pressures with implementation of measures from 2015 to 2027. 

Explanations are provided in the Annex 0 including statements that data is not in the requested 
form and that certain measures (in the rural development programme) relating to nutrients are 

primarily steering instruments and reduction of nutrients cannot be quantified. 

121 

 
 
Cost-effectiveness  analysis  is  an  appraisal  technique  that  provides  a  ranking  of  alternative 

measures  on  the  basis  of  their  costs  and  effectiveness,  where  the  most  cost-effective  has  the 
highest ranking. Finland did not carry out a cost effectiveness analysis for the first Programme 

of Measures due to a lack of sufficient data, although a qualitative assessment of benefits was 
carried  out,  together  with  an  extensive  assessment  of  the  costs  of  measures.  For  the  second 

Programme  of  Measures,  a  combination  of  a  qualitative  and  quantitative  cost-effectiveness 
analysis  has  been  carried  out  in  all  eight  RBDs  for  supporting  the  selection  of  measures 

proposed under the second cycle Programme of Measures.  

The use of cost-effective analysis and the prioritisation of measures  was further examined in 

the RBMP and background documents, where two RBDs (Tornionjoki (Finnish part) and the 
Åland) were examined in further detail.  

In the Tornionjoki RBD, it was found that in general, prioritisation of measures is achieved by 
assessing the impacts of potential measures as well as their cost-efficiency. It is indicated in the 

RBMP that the measures to reduce nutrient and solids loads are the most important for surface 
water environmental objectives. All sectors with significant pressures are included. Modelling 
was used in the cost-effective analysis of water conservation measures for agriculture, sparsely 

populated  settlements  and  their  sewage  treatment  and  peat  production  (cost  per  unit  of 
Phosphorus).  Concerning  nutrient  loading  in  other  sectors,  cost-effectiveness  has  been 

examined within the industry by  comparing the  unit costs of the measures with  their impact. 
When  selecting  sector-specific  measures,  cost-effectiveness  has  been  assessed  on  the  basis, 

inter alia, of sector-specific design manuals. In this assessment, different pressures have been 
taken  into  account.  Concerning  nutrient  loading  in  other  sectors,  cost-effectiveness  has  been 

examined within the industry by  comparing the  unit costs of the measures with  their impact. 
The  cost-effective  analysis  for  sector-specific  measures  has  been  done  in  a  more  qualitative 

form  on  the  basis  of  the  design  manuals  for  the  sectors  concerned  and  in  this  assessment 
different pressures have been taken into account.  

In the Åland RBD, cost-effective analysis has  been described  in  principle in  an annex to  the 
RBMP  and  the  costs/unit  (kg  Nitrogen  and/or  Phosphorus)  has  been  calculated  for  seven 

different measures related to agriculture, aquaculture and point sources. It is not clear how this 
generic description has been implemented in practice. Specifically, it is indicated that treatment 

of waste water from single houses has a high priority (chapter 7.9.1 of the RBMP) and the only 
"physical"  measures  are  prioritised.  The  other  "needs"  for  the  Åland  RBD  are  more 

soft/administrative/educative measures such as  the long-term development  of sustainable fish 
production, promotion of local cooperation projects to reduce nutrient loss form agriculture etc. 

122 

 
 
It should be noted that treating waste water from single houses is the most expensive measure - 

so the principle of cost effectiveness seems not to have been followed.  

A  critical  factor  in  the  success  of  the  implementation  of  the  Programme  of  Measures  is  the 

availability  of  funding  to  support  the  investments  required.  Member  States  are  required  to 
report on the investment costs for the first cycle and those planned for the second cycle (2015 

to  2021)  for  Basic  Measures  under  Article  11.3(a),  Basic  Measures  under  Article  11.3(b-l), 
Supplementary Measures under Article 11.4 and Additional Measures under Article 11.5. No 

data  has  been  reported  for  Finland.  In  the  Annex  0  document  for  Finland  it  states  that  this 
information has not been gathered for the RBMPs. 

A clear financial commitment (e.g. approved budget or financial mechanism by the parliament, 
Ministry of Finance or other financial responsible authority) was reported to have been secured 

for only one out the eight RBDs, the Åland RBD which is administered in comparison to the 
other RBDs, through separate legislation than the other RBDs in Finland, via the Government 

of  Åland.  However,  for  the  other  7  RBDs,  finance  was  reported  to  have  been  secured  at  a 
sectoral  level  for  agriculture,  industry,  urban,  hydropower  and  aquaculture.  Finance  was 
reported  not  to  have  been  secured  from  the  transport  sector  for  any  of  the  eight  RBDs  and 

securing of finance was reported as “not applicable” for all eight RBDs in terms of the energy, 
recreational and flood protection sectors. For the Åland, the industry and hydropower sectors 

are also identified as being not applicable with regard to securing finance. 

The  Vuoksi  and  Teno-,  Näätämö-  and  Paatsjoki  (Finnish  part)  RBDs  are  landlocked.  The 

remaining six Finnish RBDs report that joint consultation was carried out on the RBMPs and 
Marine Strategy, and that the preparation of the RBMPs and Programme of Measures has been 

co-ordinated with the implementation of the Marine Strategy Framework Directive. However, 
the  need  for  additional  measures  or  more  stringent  measures  beyond  those  required  by  the 

WFD  in  order  to  contribute  to  the  achievement  of  the  relevant  Marine  Strategy  Framework 
Directive  objectives  in  coastal  and  marine  environments  have  not  been  considered  in  the 

Programme  of  Measures.  National/RBD  specific  measures  that  are  relevant  to  the  Marine 
Strategy  Framework  Directive  (basic  measures,  their  associated  KTMs  and  the  pressures 

and/or chemical substances that they are tackling to meet WFD objectives) are provided for all 
RBDs. These include the construction or upgrading of wastewater treatment plants, measures 

for  improving  longitudinal  continuity  (such  as  establishing  fish  passes)  and  measures  for 
phasing out/reducing emissions of priority hazardous/Priority Substances. 

123 

 
 
For the Finish RBDs, the RBMPs and Floods Directive58 Flood Risk Management Plans have 
not been integrated into a single plan. Joint consultation was reported to have been carried out 
on the RBMPs and Flood Risk Management Plans in seven out of the eight RBDs (not for the 

Vuoksi  RBD).  All  RBDs  report  that  the  objectives  and  requirements  of  the  Floods  Directive 
have  been  considered  in  the  second  RBMP,  that  specific  win-win  measures  in  terms  of 

achieving  the  objectives  of  the  WFD  and  Floods  Directive,  drought  management  and  use  of 
Natural Water Retention Measures have been included in the Programme of Measures and that 

the design of new and existing structural measures (such as flood defences, storage dams and 
tidal barriers) have been adapted to take into account WFD Environmental Objectives. In terms 

of  whether  a  clear  financial  commitment  has  been  secured  for  the  implementation  of  the 
Programme  of  Measures  in  the  flood  protection  sector,  “not  applicable”  was  reported 

indicating that the measures for this sector are not relevant in the RBD reported. However in 
all RBDs, Article 9(4) has not been applied to impoundments for flood protection and as such 

it would be an activity/use which should be subject to cost recovery under Article 9. 

9.1.2.  Measures related to other significant pressures 

Indicator gaps (the degree to which a particular pressure needs to be reduced to achieve WFD 
objectives)  for  other  significant  pressures  (e.g.  Introduced  species  and  diseases)  have  mostly 

been reported for the RBDs (seven out of the eight RBDs, not for the Åland RBD) but only for 
2015 (not for 2021 and 2027). The same applies to the reporting of indicator values for KTMs 

with values only being provided for 2015 for seven out of the eight RBDs. 

9.1.3.  Mapping of national measures to Key Types of Measure 

It was expected that Member States would be able to report their Programme of Measures by 

associating  their  national  measures  with  predefined  Key  Types  of  Measure.  Key  Types  of 
Measure are expected to deliver the bulk of the improvements through reduction in pressures 

required  to  achieve  WFD  Environmental  Objectives.  A  Key  Type  of  Measure  may  be  one 
national  measure  but  it  would  typically  comprise  more  than  one  national  measure.  Member 

States  are  required  to  report  on  the  national  measures  associated  with  the  Key  Types  of 
Measure, and whether the national measures are basic (Article 11(3)(a) or Article 11(3)(b-l)) or 

supplementary (Article 11(4)).  

Table 9.1  summarises the number of national measures that have been mapped to the relevant 

Key Types of Measure in Finland. Also shown is the number of RBDs for which the Key Type 
of Measure has been reported.  

58   Directive 2007/60/EC on the assessment and management of flood risks entered into force on 26 November 

2007 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32007L0060 

124 

 
 
 
                                                      
Table 9.2  then summarises the type of basic measures associated with the national measures 

mapped against the Key Type of Measure. 

Table 9.1 

Mapping  of  the  types  of  national  measures  to  Key  Types  of  Measure  in 

National 
basic 
measures 

National 
supplementary 
measures 

Number of 
RBDs where 
reported 

Finland  

Key Type of Measure 

KTM1 - Construction or upgrades of wastewater treatment 
plants 

KTM12 - Advisory services for agriculture 

KTM13 - Drinking water protection measures (e.g. 
establishment of safeguard zones, buffer zones etc) 

KTM15 - Measures for the phasing-out of emissions, 
discharges and losses of Priority Hazardous Substances or 
for the reduction of emissions, discharges and losses of 
Priority Substances 

KTM16 - Upgrades or improvements of industrial 
wastewater treatment plants (including farms). 

KTM2 - Reduce nutrient pollution from agriculture 

KTM21 - Measures to prevent or control the input of 
pollution from urban areas, transport and built infrastructure 

KTM22 - Measures to prevent or control the input of 
pollution from forestry 

KTM23 - Natural water retention measures 

KTM24 - Adaptation to climate change 

KTM25 - Measures to counteract acidification 

KTM3 - Reduce pesticides pollution from agriculture. 

KTM5 - Improving longitudinal continuity (e.g. establishing 
fish passes, demolishing old dams) 

KTM6 - Improving hydromorphological conditions of water 
bodies other than longitudinal continuity 

KTM7 - Improvements in flow regime and/or establishment 
of ecological flows 

KTM99 - Other key type measure reported under PoM - 
Lake restoration 

4 

1 

8 

1 

6 

1 

2 

8 

9 

7 

3 

2 

1 

2 

1 

2 

7 

2 

6 

Total number of Mapped Measures 

14 

59 

Source: Member States reporting to WISE 

125 

7 

7 

1 

3 

7 

8 

7 

7 

2 

1 

2 

4 

6 

6 

1 

4 

8 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 9.2 

Type of basic measure mapped to Key Type of Measures in Finland  

Key Type of Measure 

Point source 
discharges 

Basic Measure Type 

Pollutants diffuse 

Urban Waste 
Water 

KTM1 - Construction or upgrades of wastewater 
treatment plants 
KTM15 - Measures for the phasing-out of 
emissions, discharges and losses of Priority 
Hazardous Substances or for the reduction of 
emissions, discharges and losses of Priority 
Substances 
KTM16 - Upgrades or improvements of industrial 
wastewater treatment plants (including farms). 
KTM22 - Measures to prevent or control the input 
of pollution from forestry 

8 

1 

4 

1 

Source: WISE electronic reporting  

Key 

‘Point source discharges’ = Article 11(3)(g): Requirement for prior regulation of point source discharges liable to cause 
pollution. 
‘Pollutants diffuse’ = Article 11(3)(h): Measures to prevent or control the input of pollutants from diffuse sources liable to 
cause pollution. 

‘Urban Waste Water’ = Urban Waste Water Treatment Directive (91/271/EEC) . 

9.1.4. Pressures for which gaps to be filled to achieve WFD objectives have been reported 

and the Key Types of Measure planned to achieve objectives 

Member  States  are  required  to  report  the  gaps  that  need  to  be  filled  to  achieve  WFD 

Environmental  Objectives  in  terms  of  all  significant  pressures  on  surface  waters  and 
groundwaters, in  terms  of Priority Substances causing  failure of  good  chemical  status  and in 

terms  of  River  Basin  Specific  Pollutants  causing  failure  of  good  ecological  status/potential. 
Member  States  were  asked  to  report  predefined  indicators  of  the  gaps  to  be  filled  or  other 

indicators where relevant. Values for the gap indicators were required for 2015 and 2021, and 
were optional for 2027. 

The  information  reported  in  WISE  on  the  gaps  to  fulfil  to  achieve  good  ecological  status 
include detailed data on the significant pressures on surface and groundwaters that may cause 

failure on the environmental objectives. For chemical  status,  the Member States reported the 
specific chemical substances causing failure. 

This information is reported at the sub-unit level. Sub-units are smaller geographic areas within 
particular  RBDs  identified  by  Member  States.  Not  all  Member  States  have  defined  and 
reported sub-units. 

126 

 
 
 
 
 
 
 
 
 
 
 
 
Member States were required to report which KTMs are to be made operational to reduce the 

gaps to levels compatible with the achievement of WFD environmental objectives. A number 
of  indicators  were  predefined  for  each  KTM.  Values  of  the  indicators  for  the  second  and 

subsequent  planning  cycles  were  also  to  be  reported  to  give  an  indication  of  the  expected 
progress and achievements: the values for 2027 could be optionally reported. This means that 

the value of the indicator will be reduced with time as measures are implemented. A value of 
zero is comparable with 100 % good ecological status or potential or good chemical status.  

This  information  was  reported  at  sub-unit  level,  or  at  RBDs  level  if  sub-units  have  not  been 
reported by the Member State. 

9.2  Main changes in implementation and compliance since the first cycle 

In general the amount and quality of readily available information has improved between the 
two  cycles  but  mainly  because  of  the  revised  reporting  schema.  Often  there  is  no  equivalent 

information for the first cycle and it is difficult therefore to make direct comparisons between 
the 2 cycles on what has changed significantly. From a review of the baseline conditions for 

the  key  Commission  recommendations,  no  obvious  significant  changes  are  observed.  In  the 
RBMP and background documents, two RBDs were examined in more detail. In the RBMP for 

the Tornionjoki (Finnish part) RBD, it was mentioned that a national guide has been drawn up 
for the design of measures. The aim has been to design measures and groups of measures that 

allow the achievement of the environmental goals in the most cost-effective way. During the 
second  planning  period,  the  effectiveness  and  cost-effectiveness  of  the  measures  were  more 

reliable than the first  cycle, with  the help  of various  models (e.g. KUTOVA).  For the  Åland 
RBD, it is explained in the RBMP that the Programme of Measures has been updated and new 

supplementary measures have been developed. 

9.3  Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMPs  and  Programme  of  Measures 
requested action on the following: 

  Recommendation:  Moreover,  the  links  between  different  pressure-impact-measures 
should be further explained. Measures should be more concrete and include the final 

expected  achievements  and,  if  possible,  quantify  the  impact  in  terms  of  the  WFD 
objectives. 

Assessment: Finland states that good progress in reducing pollution from point sources 
has been achieved in urban and industry sectors and that there has also been progress 

127 

 
 
with measures associated with forestry, rehabilitation of watercourses and in managing 

hydromorphological pressures as well as in groundwater protection. It states that more 
measures are needed to tackle the treatment of rural waste water with the extension of 

deadlines  for  wastewater  purification  systems  of  individual  rural  houses  delaying 
implementation. A considerable delay in implementing agricultural measures from the 

first  cycle  was  reported  due  to  insufficient  resources  being  available,  regardless  of 
whether  a  high  percentage  of  farmers  are  committed  to  the  rural  development 

programme.  Furthermore,  reported  indicators  of  the  gaps  to  be  filled  for  significant 
pressures  on  groundwater  and  surface  waters  are  provided  only  fairly  sporadically 

across RBDs and only for 2015. No values are available for 2021 and 2027. The same 
applies to the KTM indicator values. It is therefore not possible to track reductions in 

pressures  with implementation of measures from  2015 to 2027. This recommendation 
has been partially fulfilled. 

  Recommendation:  Ensure close linkage of  the analysis  of  pressures  and impacts  with 

the determination of measures in the RBMPs in relation to chemical pollution. 

Assessment: The evidence suggests that limited progress has been made. No Key Types 
of Measure (KTMs) have been reported to be tackling River Basin Specific Pollutants 

(a considerable number of pollutants are identified to be causing failure of objectives in 
groundwater  at  least  in  the  four  RBDs  for  which  information  was  reported.  No 

information  on  pollutants  causing  failure  in  surface  waters  is  presented).  For  certain 
Priority  Substances  reported  to  be  causing  failure  of  objectives,  measures  associated 

with upgrades or improvements to industrial wastewater treatment plants are cited. This 
recommendation has been partially fulfilled. 

  Recommendation:  Although  the  Finnish  Programmes  of  Measures  are  relatively  well 
presented, meaningful information regarding the scope, the timing and the funding of 

the  measures  should  be  included  in  the  Programme  of  Measures  so  the  approach  to 
achieve  the  objectives  is  clear  and  the  ambition  in  the  Programme  of  Measures  is 
transparent. This is very relevant to improve the first RBMP, and also to improve the 
drafting of the next RBMP. 

Assessment: Progress against this recommendation appears to be fairly limited. A clear 
financial commitment (e.g. approved budget or financial mechanism by the parliament, 

Ministry of Finance or other financial responsible authority) was reported to have been 
secured  for  only  one  out  the  eight  RBDs  (the  Åland  RBD  which  is  administered  in 

comparison  to  the  other  RBDs,  through  separate  legislation  than  the  other  RBDs  in 

128 

 
 
Finland, via the Government of Åland). However, at a sectoral level for the other seven 

RBDs  finance  was  reported  to  have  been  secured  for  agriculture,  industry,  urban, 
hydropower  and  aquaculture.  As  stated  above,  indicators  of  the  gaps  to  be  filled  for 

significant  pressures  on  groundwater  and  surface  waters  were  reported  fairly 
sporadically  across  RBDs  and  only  for  2015.  No  values  are  available  for  2021  and 

2027.  The  same  applies  to  the  KTM  indicator  values.  It  is  therefore  not  possible  to 
track reductions in pressures with implementation of measures from 2015 to 2027 and 

thus  the level of ambition in  the POM is  not  at  all transparent.  This recommendation 
has been partially fulfilled. 

  Recommendation:  Provide  a  more  comprehensive  cost-effectiveness  and  cost-benefit 
analysis, to clarify the criteria applied for the selection of measures in the RBMPs. 

Assessment:  Progress  has  been  made  in  that  it  was  reported  that  a  combination  of  a 
qualitative and quantitative cost-effectiveness analysis has been carried out in all eight 

RBDs  for  supporting  the  selection  of  measures  proposed  under  the  second  cycle 
Programme  of  Measures  (no  cost-benefit  analysis  was  carried  out  for  the  first  cycle). 

This  recommendation  was  explored  further  in  the  RBMP  and  background  documents 
and it was found that whilst a methodology has been developed for the application of 

cost-effective  analysis  and  cost-benefit  analysis,  and  that  this  appears  to  have  been 
applied for some measures and some sectors, it is not clear how the principle of cost-

effective analysis has been applied in practice. This recommendation has therefore been 
partially fulfilled. 

129 

 
 
 
 
Topic 10

  Measures related to abstractions and water scarcity  

10.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle 

10.1.1  Water exploitation and trends  

Water abstraction and scarcity are not considered relevant for Finland, except for a few water 

bodies.  In  all  RBDs,  the  percentage  of  groundwater  bodies  in  bad  quantitative  status  or  of 
surface water bodies affected by abstraction pressures is below 1 %. No data were reported on 

the Water Exploitation Index +.  

10.1.2  Main uses for water consumption  

No  data  have  been  reported  for  the  uses  of  water  consumption,  because  water  quantity 

pressures are not reported as significant. 

10.1.3  Measures related to abstractions and water scarcity  

All water uses are subject to permitting procedures under Article 11(3)(e), with the exception 

of small abstractions. 

Under  Article  11(3)(c),  measures  promoting  efficient  and  sustainable  water  use  (e.g.  water 

metering  and  allocations)  were  implemented  in  the  previous  cycle  and  no  new  measures  nor 
significant changes are planned in any of the RBDs. 

Under  Article  11(3)(f),  controls,  including  a  requirement  for  prior  authorisation  of  artificial 
recharge or augmentation of groundwater bodies, were implemented in the previous cycle and 

no new measures nor significant changes are planned in any of the RBDs.  

Some  RBMPs  include  supplementary  measures  to  reduce  the  abstraction  pressures  where 

relevant  to  specific  water  bodies.  The  measures  are  included  in  KTM  8  -  "Water  efficiency, 
technical measures for irrigation, industry, energy and households" (e.g. on 36 water bodies in 
the Kokemäenjoki-Archipelago Sea-Bothnian Sea RBD). 

10.2 Progress with Commission recommendations 

There  were  no  Commission  recommendations  based  on  the  first  RBMPs  and  Programme  of 

Measures for this topic. 

130 

 
 
 
Topic 11

  Measures related to pollution from agriculture  

11.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle 

The link between pressures and measures has been established. For nutrients, a gap assessment 

is lacking and therefore it is not clear if the measures are sufficient. For pesticides, the number 
of  water  bodies  failing  environmental  quality  standards  are  reported  for  all  basins  except 

Åland,  but  KTM3  –  “Reduce  pesticides  pollution  from  agriculture”  is  not  reported  as  a 
measure in all basins (see below). 

Basic  (the  minimum  requirement  to  be  complied  with)  and  supplementary  measures  are  not 
clearly  reported  under  KTMs  in  WISE59.  According  to  WISE  KTM2  -  “Reduce  nutrient 
pollution from agriculture”, was reported in all RBDs. KTM3  – “Reduce pesticides pollution 
from  agriculture”, was  reported in  all RBDs except  the Kemijoki, the Tornionjoki, the Teno, 

Näätämöjoki  and  Paatsjoki  and  the  Åland  RBDs.  KTM12  –  “Advisory  services  for 
agriculture”, is applied in all RBDs except the Åland RBD. KTM13 - “Supplementary drinking 

water protection measures” (e.g. establishment of safeguard zones, buffer zones etc.), is only 
applied  in  the  Åland  RBD,  but  there  will  be  significant  changes  to  them  as  a  result  of  this 

RBMP.  

In the Kokemäenjoki-Archipelago Sea-Bothnian Sea RBD, according to the national guidance 

document  "Vesienhoidon 
toimenpiteiden  suunnittelu  vuosille  2016-2021.  Maatalous, 
turkistuotanto ja happamuuden torjunta" there are safeguard zones, and new measures will be 

established to control pollution from old fur farming sites. In addition, according to the RBMP, 
there  are  measures  targeted  at  groundwater  areas:  control  of  pollution  from  animal  shelters 

(related to Nitrates Directive and environmental permitting), monitoring of groundwater sites, 
and  establishing  multi-annual  grasslands  or  safeguard  zones  (buffer  zones)  near  groundwater 

areas to control pollution from field cultivation. 

Measures under KTM 2 – “Reduce nutrient pollution from agriculture” and KTM 3 – “Reduce 
pesticides pollution from agriculture” are voluntary as they are part of the Rural Development 

Program. There is information on the area on which a measure will be applied. 

Implementation  of  basic  measures  outlined  in  Article  11(3)(h)  for  the  control  of  diffuse 

pollution  from  agriculture  at  source  are  applied  with  the  same  rules  across  all  the  RBDs. 

59   Finland subsequently clarified that it has not linked all national basic and supplementary measures to KTM’s, 
which causes inconsistency in WISE reporting. In general, both basic and supplementary measures have been 
linked to individual KTM’s, 

131 

 
 
                                                      
General binding rules to control diffuse pollution from agriculture are applied to nitrates and 

phosphorus.  

Farmers/Farmers'  Unions  have  been  consulted  under  the  Public  Consultation  process  in  all 

RBDs 

Financing of agricultural measures is secured in all RBDs.  

11.2 Main changes in implementation and compliance since the first cycle 

The  information  reported  is  not  sufficient  to  provide  a  clear  judgment.  The  gap  assessment 
lacking in the first cycle is also not reported in the second cycle. Pressures and measures taken 

seem to be linked but the reporting is inconsistent.  

11.3 Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMPs  and  Programme  of  Measures 
requested action on the following: 

 

(first RBMP Report – 2012) Agriculture is indicated as exerting a significant pressure 

on  the  water  resource  in  all  Finish  RBDs.  This  should  be  translated  into  a  clear 
strategy  that  defines  the  basic/mandatory  measures  that  all  farmers  should  adhere  to 
and  the  additional  supplementary  measures  that  can  be  financed.  This  should  be 

developed with the farmers' community to ensure technical feasibility and acceptance. 
There needs to be a very clear baseline so that any farmer knows the rules this can be 

adequately advised and enforced and so that the authorities in charge of the CAP funds 
can  adequately  set  up  Rural  Development  programmes  and  cross  compliance  water 

requirements. 

  Recommendation: Address the gaps in basic measures (e.g. tools to control P pollution, 

especially in terms of monitoring the actual P applications). 

Assessment:  This  recommendation  has  partly  been  fulfilled  as  the  implementation  of 
basic  measures  outlined  in  Article  11(3)(h)  for  the  control  of  diffuse  pollution  from 

agriculture  at  source  are  applied  with  the  same  rules  across  the  whole  RBD.  Also, 
general binding rules to control diffuse pollution from agriculture are applied to nitrates 

and phosphorus.  

132 

 
 
  Recommendation: Introduce binding requirements for farmers to address their nutrient 
inputs,  particularly  of  phosphates,  where  the  voluntary  programmes/scheme  do  not 
work. 

Assessment: This recommendation has been partly fulfilled. The binding requirements 
are  based  on  existing  legislation:  Nitrates  Decree  and  environmental  legislation,  for 

example.  There  are  no  other  binding  requirements  as  the  environmental  payment 
scheme is  voluntary for farmers to  join. There is no information  on how the renewed 

Nitrates  Decree  (Valtioneuvoston  asetus  eräiden  maa-  ja  puutarhataloudesta  peräisin 
in  force  1.4.201560)  deals  with 
olevien  päästöjen  rajoittamisesta  (1250/2014) 
phosphates, because use of phosphates in fields is regulated with fertilizer product act 
(539/2006). Finland also monitors regularly phosphate and nitrates trends in fields. This 

statistics  are  available  on  http://stat.luke.fi/en/indicator/nitrogen-and-phosphorus-
balance. 

  Recommendation: Ensure the link between Nitrates Directive and WFD (e.g. measures 
used  to  track  and  monitor  compliance,  outcomes  of  the  Nitrates  Decree  amendment 

process and the resulting improved linkages, etc.). 

Assessment:  It  is  unclear  if  the  recommendation  has  been  implemented.  There  is  a 

measure  type  called  measures  according  to  the  Nitrates  Directive,  but  details  are  not 
clearly provided. 

  Recommendation:  Adopt  measures  oriented  towards  manure  handling  and  recycling, 

decrease nutrients discharges, etc. in order to improve nutrient balances. 

Assessment:  This  recommendation  has  been  fulfilled.  There  is  a  measure  type  on 
animal  shelters  related  to  the  Nitrates  Directive  and  environmental  permitting,  and 

another  measure  type  related  to  animal  shelters  on  groundwater  areas.  There  are 
investment cost estimates for the latter type. 

  Recommendation: Include information on the activities that will be undertaken in order 
to reduce the deficiencies in the requirements for cross-compliance (manure collection, 
storage,  etc.)  depending  on  the  outcome  of  the  impact  assessment  on  slurry  storage. 

Finland should ensure that  funding for these activities is  designated and enforcement 
ensured via the RBMPs. 

60   http://www.finlex.fi/fi/laki/alkup/2014/20141250  

133 

 
 
                                                      
Assessment:  Not  enough  information  was  reported  to  assess  progress  with  this 

recommendation. 

  Recommendation:  Provide  further  clarification  on  how  Common  Agricultural  Policy 
funding  will  be  targeted  once  the  approach  is  clarified  (budget  share  and 
implementation  schemes  –  voluntary  or  mandatory  -  of  measures  funded  by  Common 

Agricultural Policy Pillar II that help to achieve water objectives). Finland should take 
into account the measures highlighted during the bilateral meeting with COM services 

held on 17 September 2014. 

Assessment:  Not  enough  information  was  reported  to  assess  progress  with  this 

recommendation. 

134 

 
 
 
 
Topic 12

  Measures  related  to  pollution  from  sectors  other  than 

agriculture  

12.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle 

In  the  context  of  this  topic,  pollution  is  considered  in  terms  of  nutrients,  organic  matter, 
sediment, saline discharges and chemicals (priority substances, river basin specific pollutants, 

groundwater  pollutants  and  other  physico-chemical  parameters)  arising  from  all  sectors  and 
sources  apart  from  agriculture.  Key  types  of  measures  (KTM)  are  groups  of  measures 

identified by Member States in their Programmes of Measures which target the same pressure 
or  purpose.  A  KTM  could  be  one  national  measure  but  would  typically  comprise  more  than 

one national  measure. The same individual measure can also  be part of  more than one KTM 
because it may be multipurpose, but also because the KTMs are not completely independent of 

one another. 

KTMs  relevant  to  non-agricultural  sources  of  pressures  causing  failure  of  WFD  objectives 
have been reported for all RBDs in Finland. These KTMs include:  

KTM 1 - “Construction or upgrades of wastewater treatment plants” 

KTM4  -  "Remediation  of  contaminated  sites  (historical  pollution  including  sediments, 

groundwater, soil)" 

KTM15  –  "Measures  for  the  phasing-out  of  emissions,  discharges  and  losses  of  Priority 

Hazardous  Substances  or  for  the  reduction  of  emissions,  discharges  and  losses  of  Priority 
Substances" 

KTM16  –  "Upgrades  or  improvements  of  industrial  wastewater  treatment  plants  (including 
farms)" 

KTM 21 - “Measures to prevent or control the input of pollution from urban areas, transport 
and built infrastructure”.  

and  

KTM22 – “Measures to prevent or control the input of pollution from forestry” 

The  WFD  specifies  that  Programmes  of  Measures  shall  include,  as  a  minimum,  “basic 
measures” and, where necessary to achieve objectives, “supplementary measures” when basic 

135 

 
 
measures are not enough to address specific significant pressures. Quantitative information on 

basic  and  supplementary  measures  used  to  tackle  pollution  from  non-agricultural  sources 
(number  of  measures  per  KTM)  is  provided  in  the  RBMPs  for  all  RBDs  in  Finland. 

Quantitative information on types of basic measures to tackle pollution from non-agricultural 
sources  is  provided  for  six  out  of  eight  Finnish  RBDs.  For  the  Teno,  Näätämöjoki  and 

Paatsjoki  and  the  Åland  RBDs,  this  information  seems  to  be  missing  in  WISE.  Finland 
clarified that for the Åland RBD this information is available in the RBMP.  

Finland provided more targeted information on basic measures required under Article 11(3)(c 
to k). An authorisation and/or permitting regime to control waste water point source discharges 

(Basic measures Article 11(3)(g)) operates in all Finnish RBDs for surface and groundwater. A 
register of waste water discharges (Basic measures Article 11(3)(g)) is available in all RBDs in 

Finland for surface and groundwater. Small waste water discharges are exempted from controls 
in  all  Finnish  RBDs.  There  is  a  prohibition  of  all  direct  discharges  to  groundwater  in  all 

Finnish RBDs. 

According to the information reported to WISE, measures to eliminate / reduce pollution from 
Priority Substances and other substances have been applied in all Finnish RBDs and the KTMs 

are  related  to  significant  pressures.  In  the  second  RBMPs,  measures  are  reported  for  all 
substances causing failure in achieving the WFD objectives. 

12.2 Main changes in implementation and compliance since the first cycle  

The first RBMPs mentioned that measures to tackle chemical pollution were rather vague, not 

targeted  to  specific  pollutants  as  there  was  little  or  unclear  information  on  which  were  the 
substances  causing  problems.  Measures  did  not  seem  to  be  related  to  the  source/pressures. 

According  to  information  reported  to  WISE  for  the  second  cycle,  measures  to  eliminate  / 
reduce  pollution  from  Priority  Substances  and  other  substances  have  been  applied  in  all 

Finnish  RBDs  and  the  KTMs  are  related  to  significant  pressures.  In  the  second  RBMPs, 
measures were reported for all substances causing failure in achieving the objectives.  

12.3 Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMPs  and  Programme  of  Measures 

requested action on the following: 

  Recommendation:  “The  identification  of  river  basin  specific  pollutants  needs  to  be  more 
transparent,  with clear information  of  how pollutants were selected, how  and where they 
were  monitored,  and  where  there  are  exceedances  and  how  such  exceedances  have  been 

136 

 
 
taken into account in the assessment of ecological status.  It is important that there is an 

ambitious approach to combatting chemical pollution from such pollutants and therefore 
that  adequate  measures  are  put  in  place.”  “Ensure  close  linkage  of  the  analysis  of 

pressures  and  impacts  with  the  determination  of  measures  in  the  RBMPs  in  relation  to 
chemical pollution.” 

Assessment:  The  reported  data  indicated  that  measures  to  eliminate  or  reduce  pollution 
from Priority Substances and other substances (Basic measures Article 11(3)(k)) have been 

applied  in  all  RBDs.  In  the  second  RBMPs,  measures  were  reported  for  all  substances 
causing non-compliance. However, this recommendation is considered partially fulfilled, as 

no information on whether the measures are sufficient to reach good status could be found. 

  Recommendation: “Reducing the quantity of nutrients (N and P) from urban waste water is 
necessary  to  allow  the  achievement  of  WFD  objectives.  Finland  should  ensure  nitrogen 
removal  from  UWWTPs  in  order  to  achieve  good  environmental  status,  especially  in 

relation to problems in removing nitrogen in low-temperature environments.” 

Assessment: The reported data show that the basic measures to tackle pollution from non-

agricultural sources included construction or upgrades of wastewater treatment plants and 
also upgrades or improvements of industrial wastewater treatment plants (including farms) 

but no details were provided on how nitrogen removal from Urban Waste Water Treatment 
Plants especially in low-temperature environments will be ensured.  

In the national background document "Vesienhoidon toimenpiteiden suunnittelun ohjeistus 
v.  2016-2021.  Yhdyskunnat  ja  haja-asutus"  it  was  mentioned  that  new  Waste  Water 

Treatment Plants will be constructed and existing plants will be updated according to the 
plans of municipalities. In the RBMP of the Teno, Näätämöjoki and Paatsjoki RBD, there 

were  no  such  projects  mentioned.  No  description  of  specific  technologies  was  provided. 
This recommendation is considered partly fulfilled. 

137 

 
 
 
 
 
Topic 13

  Measures related to hydromorphology  

13.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle 

Significant  hydromorphological  pressures  are  identified  in  all  eight  RBDs.  The  sectors  most 

commonly associated to the significant hydromorphological pressures reported in Finland are 
hydropower, flood protection and agriculture. 

Operational  KTMs  to  address  all  or  part  of  the  specific  hydromorphological  pressures  were 
reported  for  all  RBDs.  The  main  KTMs  associated  with  significant  hydromorphological 

Improving 
pressures  are  KTM5 
hydromorphological  conditions  of  water  bodies  other  than  longitudinal  continuity,  KTM7  - 

longitudinal  continuity,  KTM6 

Improving 

- 

- 

Improvements in flow regime and/or establishment of ecological flows and KTM23 - Natural 
water  retention  measures.  Even  though  KTM5  -  Improving  longitudinal  continuity  was 

reported for seven out of eight RBDs (all except the Teno, Näätämöjoki and Paatsjoki RBD), 
management objectives in terms of river continuity have not been set in any of the RBDs.  

Examples  of  specific  measures  included  are  ecological  restoration  of  rivers  (for  example 
breeding  grounds),  development  of  water  regulation  practices  (including  multi-objective 

measures, such as improving the recreational use value of regulated lakes, more efficient use of 
hydropower,  managing  flood  and  drought  risks  or  reducing  impacts  caused  by  short-term 

regulation) and improvement of fish migration conditions (changes in flow rates that improve 
the migration conditions where barriers exist, fish ladders, fish lifts or natural bypasses).  

In  terms  of  basic  measures  to  tackle  hydromorphological  pressures,  there  is  an  authorisation 
and/or permitting regime in place to control physical modifications, which covers changes  to 

the riparian area of water bodies, as well as a register of physical modifications of water bodies 
in all eight RBDs, according to WFD article 11(3)(i).  

Win-win  measures  in  terms  of  achieving  the  objectives  of  the  WFD  and  Floods  Directive61, 
drought  management  and  use  of  Natural  Water  Retention  Measures  were  reported  to  be 
included  in  the  Programme  of  Measures  of  all  eight  RBDs.  The  specific  KTM23  on  Natural 

Water  Retention  Measures  is  applied  in  four  of  the  eight  RBDs  and  is  addressing  physical 
alterations  from  agriculture  and  flood  protection.  Examples  of  Natural  Water  Retention 

Measures included are restoration of flood meadows and flood forests as well as constructed 

61   Directive 2007/60/EC on the assessment and management of flood risks entered into force on 26 November 

2007 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32007L0060 

138 

 
 
                                                      
wetlands  in  agricultural  areas.  No  information  was  found  on  a  strategy  that  prioritises  the 

implementation of Natural Water Retention Measures and green infrastructure measures. 

The design of new and existing structural measures (such as flood defences, storage dams), is 

also reported to have been adapted to take into account WFD objectives in all eight RBDs.  

In  the  seven  mainland  RBDs,  ecological  flows  have  been  derived  for  some  relevant  water 

bodies but the work is still on-going. The ecological flows which have been derived have not 
been  implemented  yet  but  there  are  plans  to  do  so  during  next  cycle.  In  the  Åland  RBD, 

ecological flows have not been derived for the relevant water bodies and there are no plans to 
do it during the second cycle. It should be noted though that ecological flows are probably not 

relevant for this RBD, as there are no river water bodies. 

Indicators  on  the  gap  to  be  filled  for  significant  hydromorphological  pressures  are  only 

reported for 2015 but not for 2021 or 2027, which does not allow any conclusions on the level 
of  ambition  in  closing  the  gap  until  the  next  cycles.  Also  for  the  KTM,  indicator  values  are 

only reported for 2015, but not for 2021 and 2027. For the Åland RBD, no indicator values for 
KTM were reported62. 

13.2 Main changes in implementation and compliance since the first cycle 

The  improved  way  of  reporting  into  WISE  for  the  second  RBMPs  makes  it  easier  to  link 
specific  measures  to  significant  hydromorphological  pressures.  In  the  first  RBMPs,  the 

information was unclear as to which types of hydromorphological pressures were targeted with 
specific hydromorphological measures. 

In  the  second  RBMPs,  significant  hydromorphological  pressures  and  operational  KTMs  are 
identified in all eight RBD. Overall the measures planned in the second cycle are largely the 

same  as  in  the  first  cycle.  In  the  Åland  RBD,  there  were  no  significant  morphological 
pressures,  and  hence  no  relevant  measures  were  foreseen  in  the  first  RBMPs.  In  the  second 

cycle,  the  only  relevant  measure  mentioned  for  the  RBD  the  Åland  RBD  is  a  proposal  for 
changes in the regulation of sediment management63. 

62 Finland subsequently clarified that this was a reporting error, as the indicator values were included in the Åland 

RBD 

63 Finland subsequently informed the Commission that this was due to a reporting gap, as the Åland RBD includes 

this in the chapter on hydromorphological pressures. 

139 

 
 
                                                      
13.3 Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMPs  and  Programme  of  Measures 
requested action on the following: 

  Recommendation: Provide more detailed information in the RBMPs on activities that may 
modify the hydromorphological conditions of the water bodies and have a negative impact 

on  the  ecological  status,  including  the  mitigation  measures  included  in  the  Water  Act 
(587/2011).  Finland  should  include  in  the  RBMPs  a  clear  measure  to  review  all  existing 

hydropower permits to ensure the achievement of WFD objectives, in particular in relation 
to the ecological flow, fish passes and other mitigation measures. 

Assessment: The reporting for the second RBMPs indicates that measures are planned to 
address  hydromorphological  pressures  related  to  agriculture.  However,  no  specific 

information  was  found  in  the  RBMPs  on  mitigation  measures  included  in  the  Water  Act 
(587/2011), which were mainly relevant to agricultural activities such as drainage, thus no 

conclusion  can  be  drawn  on  progress  made  concerning 
recommendation. 

the  first  part  of 

this 

No  information  was  found  in  the  second  RBMPs  indicating  a  systematic  revision  of  all 
existing hydropower permits to address hydromorphological problems. However, there is a 

policy  instrument  measure  studying  the  need  for  the  development  of  water  legislation  so 
that  the  permits  and  the  obligations  can,  if  necessary,  be  amended  or  revised  in  order  to 

attain the objectives of river basin and marine management. There is reference to planned 
measures  related  to  water  regulation  practices  and  the  improvement  of  fish  migration 
conditions,  but  at  the  same  time,  ecological  flows  have  not  been  implemented  yet. 

Therefore, the second part of this recommendation has not been fulfilled. 

  Recommendation:  Consider  and  prioritise  the  use  of  green  infrastructure  and/or  natural 
water retention measures that provide a range of environ-mental (improvements in water 
quality,  prevention  of  diffuse  pollution  from  agriculture,  flood  protection,  habitat 
conservation  etc.),  social  and  economic  benefits  which  can  be  in  many  cases  more  cost-

effective than grey infrastructure.  

Assessment: KTM23 on Natural Water Retention Measures is applied in four of eight RBDs to 

address hydromorphological pressures related to agriculture and flood protection. Examples of 
Natural Water Retention Measures included are restoration of flood meadows and flood forests 
as well as constructed wetlands in agricultural areas. However, no information was found on a 

140 

 
 
strategy  that  prioritises  the  implementation  of  Natural  Water  Retention  Measures  and  green 

infrastructure measures. Therefore, this recommendation  is considered partly fulfilled. 

141 

 
 
 
Topic 14

  Economic analysis and water pricing policies  

14.1 Assessment of implementation and compliance with WFD requirements 
in  the  second  cycle  and  main  changes  in  implementation  and 
compliance since the first cycle 

For most issues - definition of water services, contribution of water uses to cost recovery, cost 
recovery  calculations  and  subsidies,  environmental  and  resource  costs  -  there  has  been  no 

progress  since  the  first  cycle.  The  RBMPs  mention  that  the  economic  analysis  has  been 
updated, but no reference is made to changed methodologies. 

Slight progress can be noted with regard to cost recovery rates, which were provided for water 
supply and sewage combined in the second cycle. 

14.2 Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMPs  and  Programme  of  Measures 

requested action on the following: 

  Recommendation: Finland should apply a broad definition of water services including 
water  services  such  as  storage,  abstraction,  and  impoundment  for  the  purpose  of 
article  nine  implementation,  to  ensure  also  self-services  are  included  and  water  uses 

such  as  navigation  are  considered.  Finland  should  present  the  calculation  for  the 
contribution  of  different  water  uses  disaggregated  at  least  into  households,  industry 

and agriculture to cost recovery of water services (broad definition). The cost recovery 
calculation should include environmental and resource costs valuated on the basis on a 

robust  methodology,  with  a  transparent  approach  to  subsidies  and  cross-subsidies. 
Finland  should  provide  precise  information  concerning  incentive  function  of  pricing 

policy,  especially  in  the  respect  of  application  of  metering,  volumetric  charging  or 
efficiency promoting tariffs within different water uses.  

Assessment:  Water  services  have  again  been  defined  in  a  narrow  way  (only  water 
supply  and  sewage  services).  Other  uses  such  as  self-services  and  navigation  are  not 

included  in  the  definition.  It  is  not  explained  why  these  two  have  been  selected  and 
others that are connected to significant pressures have not. Article 9(4) was not used. 

For  example,  according  to  the  Kokemäenjoki-Archipelago  Sea-Bothnian  Sea  RBMP, 

the  most  significant  pressures  are  point  sources,  diffuse  sources,  water  uptake  and 

142 

 
 
hydromorphological  pressures.  Major  activities  related  to  those  are  agriculture, 

hydropower  and  industry,  which  are  not  considered  water  services.  In  information 
reported  to  WISE  (for  the  RBD  Kokemäenjoki-Archipelago  Sea-Bothnian  Sea)  the 

following  sectors  are  mentioned  in  relation  to  drivers:  agriculture  -  land  drainage, 
energy  -  hydropower,  flood  protection,  industry  supply,  transport  -navigation/ports, 

urban  development  -  drinking  water  supply.  Of  these,  only  drinking  water  supply  is 
included in the definition of water services. Also, it is not explained which water uses 

have  been  identified  for  Article  9  purposes,  in  order  to  establish  their  contribution  to 
cost recovery. 

Cost recovery rates are provided for water supply and sewage services combined.  

The  calculation  was  done  for  the  second  cycle  as  a  consulting  project  for  the  whole 

country, but the results are presented at the RBD level. The data is collected from the 
financial statements (of the year 2011) of a sample of 156 water supply organizations. 

The  costs  included  are:  Material  and  service  costs,  labour  costs,  depreciation  and 
impairment  losses, other operating  expenses, capital  costs, other  costs.  It  is  explained 
that the water fees from all users (basic fee and use fee for both water and wastewater 

plus  a  connection  charge)  are  supposed  to  cover  the  costs.  It  is  unclear  whether  the 
calculation  of  cost  recovery  contributions  from  water  uses  such  as  agriculture  was 

done, including whether and how "adequate contribution" was identified. Subsidies are 
not shown explicitly in the calculations. 

Environmental and resource costs are not  included in  the calculation of cost  recovery 
rates. 

Finland  did  not  provide  precise  information  concerning  incentive  function  of  pricing 
policy,  especially  in  the  respect  of  application  of  metering,  volumetric  charging  or 

efficiency promoting tariffs within different water uses.  

The Polluter Pays Principle is not mentioned.  

Overall, the recommendation has not been fulfilled. 

143 

 
 
 
 
 
 
Topic 15

  Considerations 

specific 

to 

Protected 

Areas 

(identification, monitoring, objectives and measures) 

15.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle 

Protected Areas types associated with surface waters are both identified and characterized and 
include  those  designated  under  Article  7  of  WFD  (Drinking  Water  Protected  Areas,  Bathing 

Water, Birds, Habitats and economically significant species). None were identified in relation 
to  the  Nitrates  or  Urban  Waste  Water  Treatment  Directive  as  a  whole  territory  approach  is 

adopted  for  the  implementation  of  these  Directives  in  Finland.  For  groundwaters,  Protected 
Areas related to Drinking Water and Habitats have been identified (Table 15.1 ).  

Table 15.1 

Number  of  Protected  Areas  of  all  types  in  each  RBD  of  Finland,  for 
surface and groundwater 

Protected Area type 

Abstraction of water intended for human 
consumption under Article 7 

Recreational waters, including areas 
designated as bathing waters under 
Directive 76/160/EEC65 

Protection of species where the maintenance 
or improvement of the status 
of water is an important factor in their 
protection, including relevant Natura 2000 
sites designated under Directive 
79/409/EEC (Birds)66 

Protection of habitats or species where the 
maintenance or improvement of the status 
of water is an important factor in their 
protection, including relevant Natura 2000 
sites designated under Directive 92/43/EEC 
(Habitats)67 

Areas designated for the protection of 
economically significant aquatic species 

Number of Protected Areas Associated with64 

Rivers 

Lakes 

Coastal 

Groundwater 

19 

14 

43 

177 

2 

82 

2 068 

83 

111 

72 

145 

152 

120 

61 

10 

11 

64   Finland  subsequently  informed  the  Commission  that  the  reported  information  was  not  accurate.  This  table 

reflects the updated/corrected data 

65   Directive  2006/7/EC  of  the  European  Parliament  and  of  the  Council  of  15  February  2006  concerning  the 
management  of  bathing  water  quality  and  repealing  Directive  76/160/EEC  http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32006L0007  

66   Directive  2009/147/EC  of  the  European  Parliament  and  of  the  Council  of  30  November  2009  on  the 

conservation of wild birds http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009L0147  

67   Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and 

flora http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31992L0043  

144 

 
 
 
 
 
 
                                                      
Source: Member States reporting to WISE 

A  good  overview  of  the  status  of  water  bodies  associated  with  Protected  Areas  is  reported 

(Figure 15.1 ). 

Figure 15.1  Status of water bodies associated with the Protected Areas report for Finland. 

Note: based on status/potential aggregated for all water bodies associated with 
all Protected Areas 

Source: WISE electronic reporting 

Finland  reports  that  additional  objectives  have  been  set  for  Protected  Areas  designated  in 
relation to Drinking Water, Habitats and Birds in surface waters, but not for those relating to 

Bathing Water or economically significant aquatic species. For the Habitats and Birds related 
Protected Areas,  Finland reports that some specific water objectives have been set  to  protect 

dependent habitats and species but work is still on-going to determine needs. 

For Habitats related Protected Areas associated with groundwater bodies, Finland reports that 
no  specific  water  objectives  have  been  set  to  protect  dependent  habitats  and  species  because 

the achievement of WFD good status is sufficient to achieve favourable conservation status. 

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In surface waters, specific monitoring was reported for most types of Protected Areas - except 
for those related to Birds and economically significant species68.  

In groundwater, a significant monitoring programme for Drinking Water Protected Areas has 

been reported, but no monitoring was reported for groundwater dependent habitats (Table 15.2 
)69. 

Table 15.2  Number of monitoring sites associated with Protected Areas in Finland  

Protected Area type 

Abstraction of water intended for human 
consumption under Article 7 

Protection of habitats or species where the 
maintenance or improvement of the status 
of water is an important factor in their 
protection, including relevant Natura 2000 
sites designated under Directive 
92/43/EEC (Habitats)71 

Recreational waters, including areas 
designated as bathing waters under 
Directive 76/160/EEC72 

Number of monitoring sites associated with Protected Areas 
in70 

Rivers 

Lakes 

Coastal 

Groundwater 

5 

18 

244 

71 

102 

58 

9 

44 

16 

Source: WISE electronic reporting 

In relation to additional measures for Drinking Water related Protected Areas, Finland reports 

that ‘there are safeguard zones and there are no plans to  change the regulations as a result of 
this  RBMP’,  for  all  RBDs  except  for  the  Åland  RBD  where  it  is  stated  that  ‘There  are 

safeguard zones but there will be significant changes to them as a result of this RBMP.’ 

A  closer  analyse  of  the  RBMPs  has  not  revealed  any  information  on  the  implementation  of 

additional  measures  for  any  of  the  types  of  Protected  Area  except  for  the  use  of  safeguard 

68   Finland  subsequently  informed  the  Commission  that  it  was  not  possible  to  report  electronically  in  the 
Monitoring Schema, as in Annex 8i, enumerations for birds and fish were missing. Birds were reported with 
enumeration “HAB – Protection of habitats or species depending on water - WFD Annex IV.1.v”.   

69   Finland subsequently informed the Commission that monitoring of habitats is made according to the Habitats 
Directive, and groundwater monitoring (chemical and quantitative) is based on the WFD and the groundwater 
Directive. No option for directly reporting monitoring of Groundwater dependant habitats was available in the 
WISE reporting. 

70   Finland  subsequently  informed  the  Commission  that  the  reported  information  was  not  accurate.  This  table 

reflects the updated/corrected data 

71   Council Directive 92/43/EEC of 21 May 1992 on  the conservation of natural habitats and of wild fauna and 

flora http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31992L0043  

72   Directive  2006/7/EC  of  the  European  Parliament  and  of  the  Council  of  15  February  2006  concerning  the 
management  of  bathing  water  quality  and  repealing  Directive  76/160/EEC  http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32006L0007  

146 

 
 
 
 
 
 
                                                      
zones,  where  two  unspecified  measures  are  mentioned  (strategies  for  the  protection  of 

Drinking  Water  areas  and  protection  of  groundwater  areas).  This  is  consistent  with  the 
objectives set for Habitats related Protected Areas, as the needs of water dependent features are 

yet  to  be  determined  for  surface  waters  and  as  good  quantitative  and  chemical  status  of 
groundwater bodies is sufficient to meet objectives for groundwater dependent habitats.73 

Exemptions have been applied to a small number (approximately 4 %) of groundwater areas, 
mainly related to Drinking Water abstraction and mainly due to technical feasibility. 

15.2 Main changes in implementation and compliance since the first cycle 

Reporting  of  Protected  Area  types  in  the  first  cycle  was  not  clear  though  the  reporting  of 
monitoring  sites  associated  with  Protected  Area  types  indicated  that  most  types  of  Protected 

Area had been identified. In the first cycle, the only information reported was the number of 
drinking water related Protected Areas (2302), which is similar to the number reported in the 

second cycle.  

The reported monitoring activities for each Protected Area type were similar to that in the first 

cycle.  Monitoring  of  Protected  Areas  related  to  Birds  and  economically  significant  species 
could not be explicitly reported in the second cycle but was reported under monitoring for the 

other Protected Area types.   

15.3 Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMPs  and  Programme  of  Measures 
requested action on the following: 

  Recommendation: Clarify any reasoning for exemptions and explain the measures that 

have been put in place for Drinking Water. 

Assessment: The only information provided on this issue was that safeguard zones are 
in place and there are no plans to change the regulation as a result of this RBMP. Two 

unspecified measures were mentioned in relation to safeguard zones – strategies for the 
protection of drinking water areas and protection of groundwater areas. 

This recommendation has not been fulfilled. 

73   Finland  subsequently  clarified  that  some  specific  water  objectives  have  been  set  to  protect  water  dependent 
habitats  and  species,  but  work  is  still  on-going  to  determine  needs,  and  that  specific  water  objectives  set  to 
protect water dependent habitats and species are met.  

147 

 
 
                                                      
  Recommendation:  Approve  additional  more  stringent  standards  in  the  RBMP's  for 
water  bodies  that  appear  eutrophic  but  need  to  comply  with  Bathing  and  Habitats 
directives.  

Assessment: No information was reported for Bathing Water related Protected Areas on 
this  issue.  For  Habitats  it  was  reported  that  "work  is  still  on-going  to  determine  the 

needs".  

This recommendation has been partially fulfilled. 

148 

 
 
 
 
Topic 16

  Adaptation to drought and climate change 

16.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle 

All Finnish RBDs recognised the existence of local or sub-basin drought spells as one of the 

effects  of  climate  change.  These  appear  to  be  of  low  concern  as  no  Article  4(6)  exemptions 
have yet been requested due to prolonged droughts. Even though there is no legal obligation to 

prepare Drought Management Plans, many Member States have prepared them in order to cope 
with  droughts.  None  of  the  RBDs  has  developed  a  drought  management  plan.  Such  drought 

management plans or elements were not included in the first planning RBMPs either. 

Climate change was considered in various ways in all RBDs and it was stated that the guidance 

on  how  to  adapt  to  climate  change  (Common  Implementation  Strategy  Guidance  Document 
No.  24)  was  used.  Specific  climate  change  aspects  were  considered  when  selecting  robust 

adaptation measures, checking the effectiveness of measures and assessing direct and indirect 
climate pressures. Climate change was also considered in flood risk and drought management 

when  dealing  with  water  scarcity.  KTM24  -  "Adaptation  to  climate  change"  has  not  been 
applied to tackle pressures in any RBD. However, there are national measures mapped against 

KTM24  in  the  RBMPs.  No  specific  sub-plans  addressing  climate  change  were  reported  for 
Finland. 

16.2 Main changes in implementation and compliance since the first cycle 

While in the first cycle no specific measures related to climate change are mentioned, it is now 
indicated  that  specific  climate  change  aspects  have  been  considered  when  selecting  robust 

adaptation measures. 

16.3 Progress with Commission recommendations 

There  were  no  Commission  recommendations  based  on  the  first  RBMPs  and  Programme  of 
Measures. 

149