COMMISSION STAFF WORKING DOCUMENT Second River Basin Management Plans - Member State: Bulgaria 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: Bulgaria, 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) 39 final  COMMISSION STAFF WORKING DOCUMENT Second River Basin Management Plans - Member State: Bulgaria 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) 40 final} - {SWD(2019) 41 final} - {SWD(2019) 42 final} - {SWD(2019) 43 final} - {SWD(2019) 44 final} - {SWD(2019) 45 final} - {SWD(2019) 46 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} - 
 
 
Table of contents 
Acronyms and definitions ............................................................................................................. 4 

Foreword...................................................................................................................................... 5 

General Information .................................................................................................................... 6 

Status of second river basin management plan reporting ........................................................... 8 

Key strengths, improvements and weaknesses of the second River Basin Management Plan(s) 9 

Recommendations ...................................................................................................................... 19 

Topic 1

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

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

1.2

  Main changes in implementation and compliance since first cycle ............................. 26 

1.3

  Progress with Commission recommendations .............................................................. 27 

Topic 2

  Characterisation of the River Basin District............................................................. 28 

  Assessment of implementation and compliance with WFD requirements in second 
2.1
cycle   ...................................................................................................................................... 28 

2.2

  Main changes in implementation and compliance since first cycle ............................. 44 

2.3

  Progress with Commission recommendations .............................................................. 44 

Topic 3 Monitoring, assessment and classification of ecological status in surface water bodies
.................................................................................................................................................... 47 

3.1.  Assessment of implementation and compliance with WFD requirements in second 
RBMPs.................................................................................................................................... 47 

3.2.  Main changes in implementation and compliance since first cycle ............................. 68 

3.3.  Progress with Commission recommendations .............................................................. 69 

Topic 4 Monitoring, assessment and classification of chemical status in surface water bodies72 

4.1.  Assessment of implementation and compliance with WFD requirements in second 
cycle   ...................................................................................................................................... 72 

4.2.  Main changes in implementation and compliance since first cycle ............................. 89 

4.3.  Progress with Commission recommendations .............................................................. 90 

Topic 5 Monitoring, assessment and classification of quantitative status of groundwater bodies
.................................................................................................................................................... 94 

5.1.  Assessment of implementation and compliance with WFD requirements in second 
cycle   ...................................................................................................................................... 94 

Topic 6 Monitoring, assessment and classification of chemical status of groundwater bodies
.................................................................................................................................................. 102 

6.1  Assessment of implementation and compliance with WFD requirements in second 
cycle   .................................................................................................................................... 102 

1 

 
 
 
6.2.  Main changes in implementation and compliance since first cycle ........................... 108 

6.3.  Progress with Commission recommendations ............................................................ 109 

Topic 7 Designation of Heavily Modified and Artificial Water Bodies and definition of Good 
Ecological Potential................................................................................................................. 111 

7.1.  Assessment of implementation and compliance with WFD requirements in second 
cycle for designation ............................................................................................................. 111 

7.2.  Main changes in implementation and compliance since first cycle ........................... 115 

7.3.  Progress with Commission recommendations ............................................................ 116 

Topic 8 Environmental objectives and exemptions .................................................................. 118 

8.1.  Assessment of implementation and compliance with WFD requirements in second 
cycle   .................................................................................................................................... 118 

8.2.  Main changes in implementation and compliance since first cycle ........................... 127 

8.3.  Progress with Commission recommendations ............................................................ 128 

Topic 9 Programme of measures ............................................................................................. 130 

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

9.2   Main changes in implementation and compliance since first cycle ........................... 139 

9.3   Progress with Commission recommendations ............................................................ 139 

Topic 10 Measures related to abstractions and water scarcity ............................................... 141 

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

 ................................................................................................................................. 141 

10.2.  Main changes in implementation and compliance since first cycle ........................ 142 

10.3. 

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

Topic11 Measures related to pollution from agriculture ........................................................ 143 

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

 ................................................................................................................................. 143 

11.2.  Main changes in implementation and compliance since first cycle ........................ 145 

Topic 12 Measures related to pollution from sectors other than agriculture.......................... 148 

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

 ................................................................................................................................. 148 

12.2.  Main changes in implementation and compliance since first cycle ........................ 150 

12.3. 

Progress with Commission recommendations ........................................................ 151 

Topic 13 Measures related to hydromorphology ..................................................................... 155 

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

 ................................................................................................................................. 155 

13.2.  Main changes in implementation and compliance since first cycle ........................ 157 

2 

 
13.3. 

Progress with Commission recommendations ........................................................ 158 

Topic 14 Economic analysis and water pricing policies ......................................................... 160 

14.1.  Assessment of implementation and compliance with WFD requirements in second 
cycle and main changes in implementation and compliance since first cycle ...................... 160 

14.2. 

Progress with Commission recommendations ........................................................ 161 

Topic 15 Considerations specific to Protected Areas (identification, monitoring, objectives and 
measures) ................................................................................................................................. 165 

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

 ................................................................................................................................. 165 

15.2.  Main changes in implementation and compliance since first cycle ........................ 169 

15.3. 

Progress with Commission recommendations ........................................................ 169 

Topic 16 Adaptation to drought and climate change ............................................................... 170 

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

 ................................................................................................................................. 170 

16.2.  Main changes in implementation and compliance since first cycle ........................ 170 

16.3. 

Progress with Commission recommendations ........................................................ 170 

3 

 
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. 

4 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Foreword 

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

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

2015 and reported to the European Commission in March 2016. 

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

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

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

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

5 

 
 
 
 
 
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 information on areas of the national river basin districts including sharing countries is 
provided in the following table: 

6 

Aegean SeaBGRO1000BG1000BG2000BG3000TRGR12GR11BG4000RSMKGR09GR10TRAegean Sea050100kmBlackSea 
 
 
 
 
 
 
 
 
 
 
 
 
Table A: Overview of Bulgaria‘s River Basin Districts  

RBD 

BG1000 

Name 

Danube 

BG2000 

Black Sea 

Size (km2) 
47235 

18043 (terrestrial) / 
6358 (marine) 

BG3000 

East Aegean 

BG4000 

West Aegean 

35236 

11947 

Countries sharing borders 

Serbia, Romania 

Romania, Turkey 

Greece, Turkey 

Greece, Serbia, Former Yugoslav Republic of 
Macedonia 

    Source: River Basin Management Plans reported to WISE 

A number of catchments are shared with other Member States (Romania and Greece) and with 

third  countries  (Turkey,  Serbia,  Former  Yugoslav  Republic  of  Macedonia)  and  there  is  a 
varying degree of co-operation with them. 

Table B: Transboundary river basins by category and % share in Bulgaria  

Name 
international 
river basin 

National 
RBD 

Countries sharing borders 

1 

3 

Co-ordination category 

Danube 

Rezovska / 
Mutludere 

Veleka 

Mesta-Nestos 

BG1000 

Serbia, Romania 

BG2000 

Turkey 

BG2000 

BG4000 

Turkey 

Greece 

Struma-Strymonas  BG4000 

Greece, Serbia, Former Yugoslav 
Republic of Macedonia  

Maritsa-
Evros_Meric 

BG3000 

Greece, Turkey 

km² 

47235 

% 

5.8 

km² 

% 

184 

792 

2785 

24.9 

80 

49.6 

8545 

47.2 

35230 

66.0 

  Source: WISE electronic reports  
Note: Bulgaria’s reports to WISE did not include any category of international cooperation for the Black Sea 
RBD. It was category 3 in the first RBMP. 

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. 

7 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Status of second river basin management plan reporting 

A total of four RBMPs of Bulgaria (Danube, Black Sea, East Aegean and West Aegean) were 

published  on  30  December  2016.  Documents  are  available  from  the  European  Environment 
Agency EIONET Central Data Repository https://cdr.eionet.europa.eu/. 

8 

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

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

 

Governance and public consultation 

 

Bulgaria  has  improved  coordination  with  Greece,  including  exchange  of  information 

regarding methodologies and the implementation of joint Interreg projects. 

 

A  wide  range  of  stakeholders  were  actively  engaged  in  the  preparation  of  Bulgaria’s 

RBMPs.   

 

Bulgaria carried out joint consultation of its RBMP and Flood Risk Management Plans; 

and in the Black Sea RBD, also with the Marine Strategy Framework Directive. 

 

Bulgaria did not adopt and publish the RBMP in accordance with the timetable in the 

Water Framework Directive. 

 

Characterisation of the RBD 

 

Type  specific  reference  conditions  have  not  been  established  for  all  quality  elements. 

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

 

Further  characterisation  work  has  been  undertaken  since  the  first  RBMPs  with  the 

inclusion  of  the  assessment  of  linkages  with  surface  water  bodies  and  terrestrial 
ecosystems.   

 

For  surface  and  groundwater  bodies  (except  in  the  Black  Sea  RBD)  significance  of 
pressures  is  reported  to  be  defined  in  terms  of  thresholds  and  linked  to  the  potential 

failure of objectives according to the established national approaches. Not all pressure 
types were assessed and RBMPs do not provide information as to why some pressures 

have been excluded from the risk assessment. 

 

The approach used for defining pressures on surface water bodies in  the first  RBMPs 

was refined to determine the relations 'driving force-pressure-status-impact', expand the 
analysis  of  pressures  (for  example  by  considering  more  sources  of  pressures)  and 

implement  results  from  models,  projects  and  research.  However  the  approaches  still 
differed  among  RBDs  and  some  national  methodologies  are  missing,  for  example  for 

9 

 
diffuse  pressures.  For  surface  water  pressure  assessment,  there  is  still  a  high 

dependence  on  expert  judgement,  which  raises  questions  about  the  comparability  of 
assessments.  

 

Bulgaria reported that between four and six of the 41 Priority Substances were included 
in the inventories in each RBD. A combination of Tier 1 (point source information) and 

Tier  2  (riverine  load)  was  implemented,  in  accordance  with  the  Guidance  Document 
n°28. The data quality was assessed as uncertain. 

  Monitoring, assessment and classification of ecological status  

 

Although there were errors in reporting, it is clear that the number of monitoring sites 
increased  significantly  since  the  first  RBMP.  This  is  particularly  the  case  for 

surveillance  monitoring  in  rivers  and  for  surveillance  and  operational  monitoring  in 
coastal waters. 

 

Both  surveillance  and  operational  monitoring  sites  have  been  reported  in  transitional 

waters,  contrary  to  what  happened  for  the  first  RBMP.  However,  there  was  a  large 
decrease  of  the  number  of  monitoring  sites  in  lakes.  This  was  mainly  the  case  with 

surveillance  monitoring,  but  also  affected  operational  monitoring.  In  particular, 
operational monitoring in lakes was only done in the West Aegean RBD, even though 
significant pressures were reported for lakes in the other RBDs. 

 

There  is  an  improvement  in  the  monitoring  of  quality  elements  compared  to  the  first 

RBMP, although there are still some significant gaps. There is very little monitoring of 
hydromorphological  quality  elements,  which  was  not  done  in  lakes  and  transitional 

water bodies and only for some of them in two river water bodies. 

 

All  coastal  water  bodies  included  in  surveillance  monitoring  were  monitored  for  all 

required  biological,  hydromorphological  and  physicochemical  quality  elements. 
However,  none  of  the  lake  and  transitional  water  bodies  and  only  some  of  the  river 

water  bodies  included  in  surveillance  monitoring  were  monitored  for  all  required 
biological quality elements. 

 

The minimum recommended frequency for monitoring biological quality elements was 
only met at a small proportion of the sites monitored in all water categories. 

10 

 
 

Assessment methods were reported for all relevant biological quality elements in rivers. 

However  there  are  significant  gaps  for  the  assessment  methods  in  the  other  water 
categories. 

 

In addition to the very limited monitoring of hydromorphological quality elements, the 
classification  boundaries  for  those  quality  elements  are  not  related  to  the  class 

boundaries  for  the  sensitive  biological  quality  elements.  The  hydromorphological 
quality elements were only used in the classification of rivers in terms of hydrological 

regime and morphological conditions. 

 

All the relevant supporting general physicochemical quality elements were assessed in 

terms of ecological status/potential in all water categories. However, the classification 

boundaries  for  some  of  them  are  not  related  to  the  class  boundaries  for  the  sensitive 
biological quality elements. 

 

All  the  standards  for  coastal  and  transitional  waters  are  consistent  with  the  good-
moderate status boundary of the relevant sensitive biological quality elements, but this 

is not the case for rivers and lakes. 

 

63 chemicals  that are not  Priority Substances and are, therefore,  assumed to  be River 

Basin Specific Pollutants are monitored, in water only. Not all of them are monitored at 
least  at  the  minimum  recommended  frequency  at  all  of  the  sites  where  they  are 

monitored for surveillance and operational purposes.  

 

Environmental  Quality  Standards  were  reported  for  42  substances,  relevant  to  both 

rivers and lakes. 36 of these substances also had Standards relevant to transitional and 
coastal waters.   

 

The  classification  of  all  quality  elements  in  lakes,  coastal  and  transitional  waters  was 

based  solely  on  monitoring  results,  in  rivers  it  was  based  on  a  combination  of 
monitoring results, expert judgment and grouping. The use of expert judgment for fish, 

benthic invertebrates, phytobenthos and macrophytes for some river water bodies may 
indicate some weaknesses in the assessment methods for biological quality elements in 

rivers. 

 

Very  few  river  water  bodies  were  classified  according  to  hydromorphological  quality 

elements, even when they were monitored. 

11 

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

 

Chemical status was monitored and assessed in all water categories except for territorial 

waters.  

 

Between the two RBMPs, there was a large decrease in the proportion of water bodies 

in good status and a large increase in the proportion in unknown status across all water 
categories.  Overall,  23  %  of  surface  water  bodies  in  Bulgaria  were  classified  for 

chemical status with high confidence 44 % with medium confidence and 33 % with low 
confidence.  

 

Since  the  first  RBMP,  there  has  been  an  increase  in  the  number  of  sites  and  water 

bodies  monitored,  and  the  adoption  of  new  common  national  methodologies  for  the 
assessment of chemical status. 

  More  than  60  %  of  sites  and  water  bodies  in  transitional  and  coastal  water  are 
monitored however the proportion was lower for surface fresh waters (14 % and 28 % 

of  lake  and  river  water  bodies  respectively).    Grouping  seemed  to  be  used  to  some 
extent  to  classify  non  monitored  water  bodies,  however  the  proportion  of  unknown 

status remains high. 

 

The  operational  monitoring  programme  covered  all  surface  water  bodies  failing  to 

achieve good status in the Black Sea, East Aegean and West Aegean RBDs, and 67 % 
of surface water bodies failing to achieve good status in the Danube RBD. 

 

All  Priority  Substances  listed  in  inventories  and  discharged  (between  four  and  six 
Priority  Substances  depending  on  the  RBD)  were  monitored  in  all  four  RBDs  in 

Bulgaria.  The  monitoring  frequency  for  status  assessment  met  the  recommended 
minimum  frequency  for  operational  and  surveillance  monitoring  at  some  sites  not  at 

others.  The  RBMPs  and  background  documents  provided  no  specific  justification  for 
the reduced frequency of monitoring. Six substances were not monitored in any RBDs, 

and  they  were  not  considered  in  the  inventories,  so  it  is  unclear  whether  they  are 
discharged. 

 

Hexachlorobenzene,  mercury  and  hexabutadiene  are  not  monitored  in  biota  for  status 

assessment in Bulgaria. 

 

For trend assessment, there is no monitoring of sediments and/or biota in any RBD. 

12 

 
  Monitoring,  assessment  and  classification  of  quantitative  status  of  groundwater 

bodies 

 

 

About  29  %  of  groundwater  bodies  are  not  monitored  for  quantitative  status,  but  in 
these cases self-monitoring data was used or the balance method was applied. 

National  methodologies  and  guidance  documents  have  now  been  adopted.  It  remains 
unclear though how status was assessed without monitoring data. 

 

The environmental  objectives related to  groundwater dependent terrestrial ecosystems 

and groundwater associated surface waters have partially been considered in the second 
cycle although they do not cause risk in all river basin districts. 

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

 

 

 

The  coverage  of  groundwater  bodies  by  monitoring  is  not  fully  complete.  However, 
Bulgaria  clarified  that  the  total  number  of  monitoring  points  for  chemical  status  of 

groundwater bodies in Bulgaria has increased. 

Not all substances causing risk are yet subject to monitoring. 

The  chemical  status  situation  has  worsened:  The  total  groundwater  area  failing  good 

chemical status increased from 42 % to 45 %. Bulgaria subsequently clarified that this 
is  due  to  changes  in  the  delineation  of  groundwater  bodies,  a  new  assessment 

methodology and the additional monitoring data. 

 

Groundwater  dependent  terrestrial  ecosystems  have  been  considered  in  status 

assessment in all river basin districts where they exist and are related to risk. 

 

Groundwater associated surface waters have been considered in status assessment in all 

river  basin  districts  where  they  exist  and  are  related  to  risk.  They  have  not  been 
considered in threshold value establishment in the West Aegean RBD although there is 

related risk in seven groundwater bodies. Bulgaria subsequently clarified that there was 
a  reporting  error  and  groundwater  associated  aquatic  and  groundwater  dependent 

terrestrial ecosystems are not causing a risk of not achieving good chemical status for 
groundwater bodies. 

13 

 
 
 

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

Ecological Potential 

 

The  national  methodology  for  designation  of  heavily  modified  water  bodies  and 
artificial water bodies provides a detailed step-by-step approach for designating heavily 

modified  water  bodies  and  artificial  water  bodies,  including  consideration  of  the 
significant  adverse effects of restoration measures and achievement of the benefits by 

other means. 

 

A national method for determining the ecological potential of rivers, lakes and coastal 

waters  has  been  developed  since  the  first  reporting  cycle.  However,  good  ecological 
potential is reported as defined, including reporting of mitigation measures, only in two 

out the four RBDs (the Danube RBD and the Black Sea RBD). 

 

Environmental objectives and exemptions 

 

Environmental  objectives  for  ecological  and  chemical  status  of  surface  water  bodies 

were  reported  in  all  RBDs  as  well  as  for  chemical  and  quantitative  status  of 

groundwater  bodies.  Information  is  also  provided  on  when  it  is  expected  that  the 
objectives will be achieved. 

 

 

 

Pressures  and pollutants leading  to  exemptions  are reported. Drivers behind pressures 
and impacts leading to exemptions are not reported. 

Justification  of  exemptions  regarding  natural  conditions  might  be  an  issue  of 
insufficient implementation of WFD requirements, as relevant information is lacking in 

the RBMPs and reported background documents, or is not fully in line with the WFD 
requirements. 

The  application  of  Article  4(7)  might  be  an  issue  of  insufficient  implementation  of 
WFD requirements in some basins as not enough information is reported and a generic 

approach is followed which is not site and project specific. 

 

Programme of Measures 

 

Uncertainties  in  the  status  of  water  bodies  means  that  the  gap  to  good  status  and  the 

progress required from the implementation of the measures cannot be quantified. 

14 

 
 

The annual  operation  and maintenance costs of the measures have  generally not  been 

quantified, so it is not clear how the financing of these measures can have been agreed. 

 

KTMs have been reported to be in place to address the failure of objectives caused by 

the  substances  in  groundwater  identified  in  three  RBDs  -  no  information  has  been 
provided for the East Aegean RBD. 

 

In  general  KTMs have been reported for all significant  pressure types  in  both  surface 

water and groundwater.  For  surface  water,  some  pressure  types  are  not  addressed  by 
KTMs in the Black Sea RBD. 

 

 

The number of River Basin Specific Pollutants reported as causing failure is very small. 
No relevant KTMs have been reported for the East Aegean. No data is reported in any 

RBD on the number of surface water bodies failing objectives as a result of River Basin 
Specific Pollutants, although KTMs have been reported in some RBDs. 

Information  is  reported  for  a  small  number  of  substances.  Not  all  Priority  Substances 
reported as causing failures are covered by KTMs. The number of Priority Substances 

reported is very small. 

 

Due to the significant number of water bodies assessed in “unknown” ecological and/or 

chemical  status,  Bulgaria  has  not  been  able  to  assess  the  level  of  significance  of  the 

different pressure types and to evaluate the extent of the pressure or chemical substance 
that is to be reduced to achieve the Environmental Objectives. 

 

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

plans  have  not  been  integrated,  all  aspects  have  been  co-ordinated,  and  a  financial 

commitment has been made.  

 

Article 9(4) has only been applied in the East Aegean RBD. 

  Measures related to abstractions and water scarcity 

  Water  quantity  data  have  been  reported  to  support  the  European  State  of  the 
Environment  Report.  Water  abstraction  pressure  is  not  reported  as  relevant  for 

Bulgaria;  however  all  river  basin  districts  face  water  quantity-related  problems.  The 
Water Exploitation Index + is not calculated 

15 

 
  Measures  promoting  efficient  and  sustainable  water  use  were  implemented  in  the 
previous  cycle  in  all  river  basin  districts  except  in  West  Aegean,  and  new  measures 
and/or significant changes are planned for the second cycle. No information is reported 

by  when  the  existing  gaps  will  be  closed.  Bulgaria  reports  that  it  is  not  possible  to 
quantify  the  pressures  to  reduce  and  measures  that  are  still  needed  for  achieving  the 

environmental objectives. 

 

The RBMPs do not include a water resource allocation and management plan. 

  Measures related to pollution from agriculture 

 

 

 

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

No gap assessment for nutrients has been undertaken in any RBDs. 

Safeguard zones have been established for abstractions for drinking water but also for 

other purposes (e.g. economically valuable fish species and protected areas). 

 

Implementation of basic measures for the control of diffuse pollution from agriculture 

at source as per Article 11(3)(h) is applied only in Nitrate Vulnerable Zones, except in 

the West Aegean RBD where the same rules apply across the whole RBD.   

 

 

Supplementary measures for reducing pollution from agriculture are reported. 

Financing  of  measures  related  to  agricultural  pressures  is  secured  in  all  basins  and 
estimations  of  the  potential  financial  contributions  of  different  sectors  (domestic, 

agriculture,  industry  and  services)  in  the  period  2016-2021  for  the  financing  of  the 
Programme of Measures are provided.   

 

Information whether the measures are mandatory or voluntary is not available either in 

WISE or in the RBMPs. 

 

The  level  of  ambition  is  unclear,  as  the  area  covered  by  measures  to  achieve 

environmental objectives is not reported. 

  Measures related to pollution from sectors other than agriculture 

  Bulgaria  has  identified  a  wide  range  of  KTMs  relevant  to  non-agricultural  sources  of 
pressures causing failure of WFD objectives, and at least some relevant KTMs have been 
reported for each RBD 

16 

 
  Measures to tackle urban point sources are reported in all four RBDs, and several actions 

have been identified corresponding to KTM1.  

  However,  the  RBMP  does  not  make  clear  whether  the  funding  to  tackle  urban  point 
sources has already been ‘secured’ for each of the coming years. Nor is it clear whether 
the measures will be sufficient to fulfil the legal  obligations, and whether measures for 

agglomerations above 2000 population equivalent. have been prioritised in the process. 

  Most of the measures presented in the Programmes of Measures do not refer to specific 
Priority Substances or River Basin Specific Pollutants but only address such pollution in 

general. 

  KTM15 measures (“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”) have not been identified in the East or West Aegean RBDs. 

  Measures related to hydromorphology 

  Significant  hydromorphological  pressures  and  operational  KTMs  to  deal  with  these 
pressures  are  reported  in  all  RBDs.  However,  it  is  not  possible  to  draw  specific 

conclusions  on  the  level  of  ambition  because  indicators  on  the  gap  to  be  filled  for 
significant pressures and KTM value indicators are not reported.  

  Ecological flows have been derived and implemented partly, i.e. for some relevant water 
bodies, and only in one RBD (Danube) but the work is still on-going. In the other three 
RBDs  (Black  Sea,  East  Aegean  and  West  Aegean),  no  ecological  flows  have  been 
derived  but  there  are  plans  to  do  it  during  the  second  cycle.  The  Programmes  of 

Measures for the Black Sea, East Aegean and West Aegean RBDs indicate that relevant 
measures will start in 2017-2018. At the same time, no specific information was found 

that ecological flows will be applied through a review of permits. 

  Natural Water Retention Measures are planned to tackle significant hydromorphological 
pressures in three RBDs (Danube, Black Sea and East Aegean), although these measures 

are not described in detail in any of the RBMPs.  

17 

 
 
 
 

Economic analysis and water pricing policies  

  Concerning  cost  recovery  calculations,  it  is  unclear  how  environmental  and  resource 

costs have exactly been included. 

  No  detailed  information  on  the  application  of  the  Polluter  Pays  Principle  was  found  in 

the RBMPs.  

 

Considerations  specific  to  Protected  Areas  (identification,  monitoring,  objectives 

and measures) 

 

In  terms  of  the  numbers  of  Protected  Areas  designated,  only  the  number  of  Drinking 

Water Protected Areas has changed since the first RBMP. This has decreased by around 
a third in the second cycle. 

  The  numbers  of  surface  water  monitoring  sites  for  Habitat  and  Urban  Waste  Water 
Treatment Protected Areas have decreased significantly in the second cycle compared to 

the first. 

 

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. The West  Aegean RBD also  addressed  climate change when 

monitoring change at reference sites.  

  KTM24 (climate change adaptation measures) address significant pressures in two of the 

river basin districts.   

18 

 
 
 
Recommendations  

  The  preparation  of  the  next  RBMP  should  be  carried  out  in  accordance  with  the  WFD 

timetable, to ensure the timely adoption of the third RBMP. 

  Bulgaria  should  continue  to  improve  international  cooperation,  including  coordinated 
assessments of the technical aspects of the Water Framework Directive 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. 

  Bulgaria  needs  to  continue  its  work  in  order  to  harmonise  the  assessment  of  pressures 
among RBMPs and to make further progress on the assessment of agricultural pressures 

on water bodies. 

  Bulgaria  needs  to  eliminate  inconsistencies  between  significant  pressures  and  the 

measures planned to mitigate their effect. 

  Bulgaria should continue to strengthen monitoring, in order to increase the confidence in 
the  assessment  of  water  body  status.  In  particular,  operational  monitoring  needs  to 

include  all  lake  water  bodies  which  are  subject  to  significant  pressures.  Monitoring 
should also cover all relevant quality elements. 

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

for the classification of ecological status/potential. 

  Bulgaria  should  have  a  clear  and  transparent  method  for  the  selection  of  River  Basin 

Specific Pollutants. 

  Bulgaria 

should 

strengthen 

its  assessment  method 

for  biological,  general 

the 
physicochemical  and  hydromorphological  quality  elements  by  completing 
development of assessment methods which are sensitive to all significant pressures and 
by progressing in the transfer of the results of intercalibration into national types.  

  Bulgaria needs to reduce the number of unknowns. Monitoring should be performed in 
the  relevant  matrix,  in  a  way  that  ensures  sufficient  spatial  coverage  and  temporal 
resolution to reach sufficient confidence in the assessment, if necessary in combination 

with robust grouping/extrapolation methods. Develop the missing analytical methods. 

19 

 
  Perform trend monitoring in all RBDs, for all relevant substances, in a way that provide 

sufficient temporal resolution and spatial coverage. 

  The  definition  of  good  ecological  potential  needs  to  be  completed  for  all  RBDs, 

specifically for the East Aegean RBD and the West Aegean RBD. 

  Progress in the justification of exemptions should be continued. The specific drivers and 
impacts which may lead to the application of Article 4(4) and 4(5) exemptions should be 

assessed  and  clearly  outlined  in  all  RBMPs.  The  justification  should  be  elaborated  in 
more detail at water body level.  In case there is clear evidence that natural background 

levels  are  the  cause  for  elevated  concentrations,  the  appropriate  adaptation  of  the 
reference conditions should be considered instead of applying exemptions. Furthermore, 

the potential use of 'natural conditions' as an exemption type under Article 4(5) should be 
revised because exemption types Article 4(5) refers to are either that the achievement of 

good  status  would  be  'infeasible'  or  'disproportionately  expensive',  whereas  'natural 
conditions' as such is not considered as an exemption type under Article 4(5). 

  With  regard  to  the  application  of  Article  4(7),  the  types  of  modifications  and 
justifications  should  be  clearly  outlined  and  made  more  transparent  in  all  RBDs, 

including  an  ex-ante  assessment  whether  planned  new  modifications  may  lead  to 
deterioration / non-achievement of good status/potential at quality element level. 

  Quantification of indicators of gaps should be quantified for any pressures in any RBD. 

  A cost-effectiveness analysis should be carried out and specific prioritisation of measures 

based on cost-effectiveness analysis should be provided. 

  Bulgaria  should  make  sure  that  all  relevant  KTMs  are  reported  to  control  Priority 

Substances in the East and West Aegean RBDs. 

  Bulgaria should ensure that KTMs are in place to address the failure of objectives caused 

by substances in groundwater in the East Aegean RBD. 

  Bulgaria  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.  These  measures 

should be specific, have a clear legal  basis, and  include appropriate  advice, monitoring 
and inspection regimes to ensure their effective implementation. 

20 

 
 

In the third RBMPs, it should be stated clearly to what extent, in terms of area covered 

and  pollution  risk  mitigated,  basic  measures  (minimum  requirements  to  be  complied 
with)  or  supplementary  measures  (designed  to  be  implemented  in  addition  to  basic 

measures) will contribute to achieving the WFD objectives.  Sources of funding should 
be  identified  (e.g.  CAP  Pillar  1,  Rural  Development  Programme),  as  appropriate,  to 

facilitate successful implementation of these measures. 

  Bulgaria  should  continue  to  encourage  coordination  between  water  and  agriculture 
departments  in  the  review  and  development  of  the  strategy  for  the  delivery  of  WFD 
objectives,  in  cooperation  with  the  farming  community  to  ensure  the  third  RBMP  is 

technically  feasible  and  aligned  with  all  relevant  policies  and  instruments  (e.g.  Rural 
Development Programme, CAP Pillar 1, ND etc.). The measures in the strategy should 

be  specific,  have  a  clear  legal  basis,  and  include  appropriate  advice,  monitoring  and 
inspection regimes to ensure their effective implementation. Irrigation investments made 

in  the  Rural  Development  Programmemust  be  carried  out  to  ensure  water  saved  goes 
back to restore depleted aquifers.  

  KTM and specific measures have been identified to tackle the significant pressures from 
waste disposal sites, contaminated sites or abandoned industrial sites. No gap analysis is 

provided so it is not clear whether the measures planned will be sufficient to reach good 
status by the deadline, and to avoid further deterioration. Bulgaria should perform a gap 

analysis to assess whether the measures planned are sufficient to reach good status and 
avoid further deterioration, and if necessary to identify additional measures. 

  KTM have been reported to tackle diffuse and point source pollution. However it is not 
clear that  all relevant  diffuse and point sources have been properly identified. Bulgaria 
should complete the inventories of emissions, by considering all Priority Substances and 

other  substances  from  part  A  of  annex  I  of  the  EQS  Directive.  It  is  strongly 
recommended  to  use  the  methodology  from  guidance  document  n°28  for  all  these 

substances,  and  point  sources  as  well  as  diffuse  sources  should  be  considered  where 
relevant.  Bulgaria  should  make  sure  all  individual  substances  causing  failures  are 

addressed by appropriate KTMs and measures, and a gap analysis should be provided to 
ensure that the measures planned will be sufficient to reach the objective. 

  Bulgaria  should  make  sure  that  the  planned  measures  will  ensure  compliance  with 
Article  5  of  the  Urban  Waste  Water  Treatment  Directive  as  regards  more  stringent 

treatment, especially in big cities. Bulgaria should make sure funding is secured for the 
planned actions, and make sure measures are sufficient to tackle the significant pressures 

21 

 
from  UWWTP,  by  performing  a  gap  analysis,  prioritising  where  necessary 

agglomerations above 2000 population equivalent. 

  Bulgaria should ensure the full application of ecological flows, which are now planned in 
all RBMPs, and that these are applied at the appropriate level and implemented through 
the revision of permits as necessary. 

  The  revision  and,  if  necessary,  the  amendment  of  all  existing  permits  should  be 
continued, in order to ensure that these permits are compatible with the achievement of 

the WFD objectives. 

  Bulgaria should continue prioritising the use of green infrastructure and/or natural water 
retention  measures  that  provide  a  range  of  environmental  (improvements  in  water 

quality, flood protection, habitat conservation, etc.), social and economic benefits which 
can be in many cases more cost-effective than grey infrastructure. 

  Bulgaria  should  continue  to  apply  cost  recovery  for  water  use  activities  having  a 
significant impact on water bodies or justify any exemptions using Article 9(4). It should 

continue  to  transparently  present  how  financial,  environmental  and  resource  costs  have 
been  calculated  and  how  the  adequate  contribution  of  the  different  users  is  ensured. 

Bulgaria  should  also  continue  to  transparently  present  the  water-pricing  policy  and 
provide a transparent overview of estimated investments and investment needs. 

  Bulgaria should continue its work on groundwater Protected Areas designated under the 
Birds and Habitats Directives. These Protected Areas should be identified and reported.  

It  also  needs  to  set  more  stringent  objectives  for  drinking  water  safeguard  zones  and 
include them in the PoMs as mentioned in previous recommendation. 

 

Bulgaria  should  ensure  that  a  clear  distinction  is  made  between  water  scarcity  and 
drought  in  water  policy  and  that  a  Drought  Management  Plan  or  a  Water  resource 

allocation  and  management  plan  is  adopted,  particularly  in  light  of  the  fact  that 
abstraction  is  identified  as  one  of  the  significant  pressures  for  surface  water  and 

groundwater bodies in the country. 

22 

 
 
 
Topic 1

 Governance and public participation 

1.1

Assessment  of 
requirements in second cycle 

implementation  and  compliance  with  WFD 

1.1.1  Administrative arrangements – river basin districts 

Bulgaria  has  reported  four  river  basin  districts:  Danube,  Black  Sea,  East  Aegean  and  West 
Aegean. All four RBDs are part of international RBDs.  

1.1.2   Administrative arrangements – competent authorities 

Bulgaria reports a large number of competent authorities. Key among these are the four River 

Basin Directorates, whose main roles are: the monitoring and assessment of groundwater and 
implementation,  economic  analysis,  enforcement  of 
surface  water,  co-ordination  of 

regulations,  implementation  of  measures,  preparation  of  the  RBMPs  and  Programme  of 
Measures, public participation, and reporting to the European Commission.  

The  Ministry  of  Environment  and  Water  has  the  following  main  roles:  co-ordination  of 
implementation, economic analysis, enforcement of regulations, implementation of measures, 

reporting to the European Commission, and monitoring of groundwater and surface water. The 
Ministry has a supporting role on public participation. Several other Ministries have main roles 

for  the  implementation  of  measures:  Energy;  Economy;  Regional  Development  and  Public 
Works;  Transport,  Information  Technology  and  Communications;  and  Agriculture  and  Food. 

Moreover, all these ministries have supporting roles for the enforcement of regulations, while 
the Ministry of Health also has supporting roles for the monitoring and assessment of status of 

surface water. 

Several  national  agencies  are  also  identified.  The  Executive  Agency  for  Exploration  and 
Maintenance of the Danube River undertakes monitoring of surface water1, as does the Institute 
of Oceanography2. The Executive Environment Agency undertakes monitoring of groundwater 
and  surface  water,  and  so  does  the  National  Institute  of  Meteorology  and  Hydrology.  The 
National Statistical Office carries out economic analysis.  

The Association ViK is also involved in the implementation of measures; so are municipalities 

in the RBDs (265 authorities). 

1   Bulgaria clarified subsequently that this agency carries out water quantity monitoring of the Danube River. 
2   Bulgaria clarified subsequently that the Institute carries out monitoring of marine waters. 

23 

 
 
                                                      
1.1.3   River  Basin  Management  plans  –  structure  and  Strategic  Environmental 

Assessment   

No sub-plans are reported for Bulgaria's RBMPs; Bulgaria informed that national programmes 

for the application of the RBMPs were developed by the economic sector. 

1.1.4   Public consultation 

For all four RBMPs, the public and interested parties were informed via Internet, invitations, 
local authorities, media (papers, TV and/or radio), meetings and printed material. In addition, 

direct mailing was used in the Danube RBD, and written consultation in both the Danube and 
East  Aegean  RBDs.  For  all  four  RBDs,  documents  were  made  available  by  direct  mailing 

(post) and were downloadable. Documents were available for the required six months. In the 
Danube,  Black  Sea  and  East  Aegean  RBDs,  documents  were  also  made  available  by  direct 

mailing (e-mail). In the West Aegean RBD, documents were distributed at exhibitions.  

The  following  stakeholder  groups  were  actively  involved  in  all  Bulgaria's  RBMPs: 

agriculture/farmers,  fisheries/aquaculture,  industry,  local/regional  authorities,  NGOs/nature 
protection  and  water  supply  and  sanitation.  Consumer  groups  were  actively  involved  in  the 
Danube  and  East  Aegean  RBDs.  Energy/hydropower  was  actively  involved  in  the  Danube, 

East Aegean, and West Aegean RBDs. Navigation/ports were actively involved in the Danube 
and  Black  Sea  RBDs.  In  the  West  Aegean  RBD,  universities  and  scientific  institutes  were 

involved.  In  all  four  RBDs,  active  involvement  included  regular  exhibitions;  in  the  Danube, 
Black  Sea  and  East  Aegean  RBDs  -  involvement  in  drafting;  in  the  East  Aegean  RBD, 

advisory groups; and in the West Aegean RBD, opinions and proposals. 

For all four RBMPs, consultation led to: addition of new information, changes to selection of 

measures,  commitment  to  action  in  the  next  RBMP  and  commitment  to  further  research. 
Adjustment  to  specific  measures  was  a  result  for  the  Danube  and  East  Aegean  RBDs,  and 

changes to the methodology used for the East Aegean RBD. For the Danube only, there was 
international  co-ordination  on  public  participation.  Further  information  on  international 

cooperation with respect to measures is provided in Chapter 9 of this report. 

24 

 
1.1.5  

Integration  with  the  Floods  Directive  and  the  Marine  Strategy  Framework 

Directive 

Bulgaria  did  not  integrate  its  RBMPs  and  Flood  Risk  Management  Plans  (under  the  Floods 
Directive3)  in  joint  plans  but  did  undertake  joint  consultation  of  its  RBMPs  and  Flood  Risk 
Management Plans. 

For the Black Sea RBD, joint consultation with the Marine Strategy Framework Directive4 was 
organised. 

1.1.6  

International coordination and co-operation  

For  the  Danube  RBD,  Bulgaria  reported  that  an  international  agreement,  permanent  co-

operation  body  and  an  international  RBMP  in  place  (designated  as  category  1  cooperation): 
indeed,  Bulgaria  is  a  member  of  the  International  Commission  for  the  Protection  of  Danube 

River. Explicit links were made with national RBMPs within the international RBMP. In this 
RBD, there was international co-ordination of public participation.  

For the East Aegean RBD, shared with Greece and Turkey and the West Aegean RBD, shared 
with  Greece,  Former  Yugoslav  Republic  of  Macedonia  and  Serbia),  Bulgaria  reports  that  an 
international agreement and permanent co-operation body was in place (designated as category 

2). It is not clear, however, the extent to which co-operation covers all Member States and third 
countries. Bulgaria and Greece signed a Joint Declaration at ministerial level for cooperation 

on the implementation of European Union water legislation: an important element has been the 
coordination  and  exchange  of  information  on  methodologies.  Bulgaria’s  RBMPs  for  East 

Aegean  and  West  Aegean  also  mention  that  cooperation  with  Greece  took  place  through 
international projects funded primarily by Interreg programmes. No information was found on 

cooperation  activities  with  the  Former  Yugoslav  Republic  of  Macedonia  and  Serbia  in  these 
international RBDs.  

Bulgaria's  Black  Sea  RBD  is  shared  with  Romania  and  Turkey.  Bulgaria  and  Romania  have 
signed a Bilateral Agreement on Water Management that covers coordination of shared RBDs, 

both  Danube  and  the  Black  Sea.  The  two  Member  States  have  shared  information  on 
methodologies and on the development of their RBMPs.  

3   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  

4   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  

25 

 
                                                      
Information was not found on the extent of Bulgaria’s cooperation with Turkey. Both countries 

(as well as Romania) are among the parties to the Convention on the Protection of the Black 
Sea  Against  Pollution,  but  information  was  not  found  on  cooperation  under  this  framework 

related to the development of RBMPs. 

1.2

  Main changes in implementation and compliance since first cycle 

Bulgaria's  Administrative  Arrangements  appear  to  be  more  complex  compared  to  the  first 
cycle: the 2012 Commission Staff Working Document5 listed the Ministry of Environment and 
Water  and  the  four  RBD  Directorates,  while  the  WISE  reporting  indicates  several  other 

national  ministries,  several  national  agencies  and  265  local  authorities.  These  bodies  are 
mentioned  in  the  Member  State  fact  sheet  on  administrative  arrangements  for  Bulgaria 
prepared under the Pressures & Measures study6: consequently, it is not clear if this represents 
a change in governance or simply more detailed reporting in the second cycle.  

In  the  first  cycle,  Bulgaria  prepared  sub-plans  for  economic  sectors;  although  no  sub-plans 
were  reported  for  the  second  cycle,  Bulgaria  informed  that  national  programmes  for  the 

application  of  the  RBMP  were  developed  by  the  economic  sector:  consequently,  no  major 
change was seen. 

International  co-operation  appears  to  have  strengthened  for  the  East  Aegean  and  the  West 
Aegean  RBDs  as  both  are  indicated  in  the  WISE  reporting  as  RBD  with  co-operation 

agreement  and  body  in  place  (Category  2),  implying  that  steps  were  taken  to  improve  co-
operation  with  neighbouring  countries  in  these  international  RBMPs.  For  the  East  Aegean 

RBD, shared with Greece and Turkey, the 2012 Commission Staff Working Document listed 
one  river  basin  as  having  an  international  agreement  in  place  (Category  3).  For  the  West 

Aegean  RBD,  the  2012  Commission  Staff  Working  Document  listed  one  RBD  as  having  an 
international  agreement  in  place  (shared  with  Greece)  and  a  RBD  without  co-operation 

formalised  (Category  4)  which  is  shared  with  Greece,  Former  Yugoslav  Republic  of 
Macedonia  and  Serbia.  Information  gathered  indicates  the  co-operation  with  Greece  was 

strengthened;  it  is  not  clear  if  this  was  also  the  case  for  Former  Yugoslav  Republic  of 
Macedonia and Serbia. The level of co-operation for the Black Sea RBD was reported as "Null. 

5    http://ec.europa.eu/environment/water/water-framework/pdf/3rd_report/CWD-2012-379_EN-Vol3_BG.pdf  
6  http://ec.europa.eu/environment/archives/water/implrep2007/pdf/Governance-

Pressures%20and%20measures.pdf  

26 

 
                                                      
1.3

Progress with Commission recommendations 

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

 

 

Recommendation:  There  are 
international  cooperation/coordination 
mechanisms  established  with  neighbouring  countries  like  Greece  and  Turkey  in 

insufficient 

international  river  basins.  This  cooperation  needs  to  improve  significantly.  The  river 
basins shared with Turkey should be correctly designated as international RBDs. 

Include in the second RBMPs results of the international cooperation with neighbouring 
countries. 

Assessment: It appears that international co-ordination has improved for the East Aegean RBD 
and  the  West  Aegean  RBD.  In  particular,  it  appears  that  cooperation  with  Greece  improved, 

including  via  a  joint  declaration  at  ministerial  level  as  well  as  the  development  of  Interreg 
projects.  It  is  not  clear,  however,  if  cooperation  with  non-member  countries  –  Former 

Yugoslav Republic of Macedonia, Serbia and Turkey – has also improved for the second cycle. 
These recommendations are partially fulfilled. 

 

Recommendation: Ensure the necessary coordination of approaches and methodologies 
among  its  four  RBDs  in  the  second  RBMPs.  Co-ordination  during  the  RBMP 

development  between  the  basin  and  state  level  as  well  as  among  RBDs  should  be 
improved  in  the  next  RBMP  cycle.  Elaboration  of  common  methodologies  would  be 

necessary. 

Assessment:  A  review  of  the  different  WFD  topics  suggests  that  considerable  progress  has 

been  achieved  since  the  first  RBMPs  in  developing  and  applying  common  national 
methodologies that are used in  all four RBDs. This  was achieved in  part via projects  carried 

about by the Ministry of Environment and Water, and in part by work at international and at 
RBD  levels  (e.g.  the  methodology  used  for  determining  confidence  levels  of  water  bodies 

status assessments was original developed for the international Danube RBD, adopted by the 
Bulgarian Danube RBD and then adopted as a national methodology). The four RBMPs used 

the common methodologies (when available) and either include copies of these documents in 
their  annexes  or  contain  links  to  the  online  documents  on  the  Ministry  of  Environment  and 

Water’s website.  
It can also be noted that the four RBMPs follow the same structure, with the same number and 

titles of chapters and very similar content provided in these chapters. There are differences in 
the number and format of annexes provided to each chapter across the RBDs, but overall they 

contain  similar  annexes.  Key  annexes  such  as  overview  of  status  of  water  bodies  or 
Programme of Measures follow the same templates.  

This recommendation is fulfilled. 

27 

 
 
Topic 2

 Characterisation of the River Basin District 

2.1

Assessment  of 
requirements in second cycle  

implementation  and  compliance  with  WFD 

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

water bodies 

Overall there is a significant change in the number of water bodies delineated between the first 

cycle  and  the  second  cycle  (Table  2.1).  For  river  water  bodies  there  was  a  27  %  increase 
overall,  including  a  63  %  increase  in  the  Danube  RBD.  For  lake  water  bodies,  there  was  a 

decrease of 35 % in the East Aegean RBD and 46 % in the Danube RBD, whilst there were 
increases of 33 % in the Black Sea RBD and 50 % in the West Aegean RBD. In the Black Sea 

RBD, there was an 87 % increase in transitional water bodies and a 31 % increase in coastal 
water bodies.  

In  the  second  cycle,  95  %  of  identified  surface  water  bodies  were  natural  with  4  %  being 
designated  as  heavily  modified  and  1  %  as  artificial  water  bodies.  It  was  a  fairly  similar 

situation in the first cycle but there was a very slight increase in the proportion of natural water 
bodies between the first cycle and the second cycle (Figure 2.1). The water uses and physical 

alterations  have  been  reported  for  each  heavily  modified  water  body  category.  The  RBMPs 
reported  that  a  national  approach  for  designation  of  heavily  modified  water  bodies  was 
developed and first applied in the second RBMPs (for details see Topic 7).  

The RBMPs reported that the delineation of the surface water bodies was updated as a result of 

the updated typology, updated objectives and pressures information, new data gathered through 
monitoring and update of the protected areas, as well as to address some technical errors from 

the  first  RBMPs  and  recommendations  received  from  the  European  Commission  on  the  first 
RBMPs. The revised typology resulted in both merging and splitting of water bodies. 

Transitional waters (only relevant for the Black Sea RBD) were re-delineated as a result of a 
study on the typology and classification of surface water bodies carried  out  in  the first  cycle 
("Update of the typology and classification system for assessment of surface water bodies of 

categories 'river', 'lake' and 'transitional waters' in the period of the first RBMP"). There is no 
information about re-delineation of the coastal waters. 

The consequences of the re-delineation of surface water bodies mentioned in the RBMPs were: 
firstly,  that  there  was  a  need  to  apply  the  'grouping'  approach,  especially  for  small  water 

28 

 
 
bodies, and update the programmes of monitoring; secondly, direct comparison of the status of 

water bodies between the first and second RBMPs is not possible due to the changes. 

Table 2.1 

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

the second and first cycles 

Year 

RBD 

2016  BG1000 

2016  BG2000 

2016  BG3000 

2016  BG4000 

2016  Total 

2010  BG1000 

2010  BG2000 

2010  BG3000 

2010  BG4000 

2010  Total 

Lakes 

Rivers 

Transitional 

Coastal 

Number 
of water 
bodies 

Total 
area 
(km2) of 
water 
bodies 

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 

7 

4 

11 

15 

37 

13 

3 

17 

10 

43 

14 

3 

38 

61 

116 

21 

4 

42 

9 

75 

249 

156 

300 

168 

873 

153 

124 

291 

122 

688 

27 084 

2 957 

10 543 

2 837 

43 421 

6 690 

6 009 

10 551 

2 319 

25 568 

0 

28 

0 

0 

28 

0 

15 

0 

0 

15 

0 

816 

0 

0 

816 

0 

109 

0 

0 

109 

Source: WISE electronic reports 

0 

17 

0 

0 

17 

0 

13 

0 

0 

13 

0 

1 464 

0 

0 

1 464 

0 

1 428 

0 

0 

1 428 

29 

 
  
 
 
 
 
 
 
 
 
 
 
Figure 2.1 

Proportion of surface water bodies in Bulgaria 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 reports. 

Table  2.2  shows  the  differences  in  size  distribution  of  surface  water  bodies  in  Bulgaria 
between  the  first  and  second  and  cycles.  The  minimum  length  of  river  water  bodies  has 

decreased in the Danube RBD and the minimum size of coastal water bodies decreased in the 
Black Sea RBD. The minimum size criteria reported were a 10 km2 catchment area for rivers 
and a 0.5 km2 surface area for lakes.  

30 

 
 
 
 
Table 2.2 

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

Lake area (km2) 

River length (km) 

Transitional (km2) 

Coastal (km2) 

Year  RBD 

2016  BG1000 

2016  BG2000 

2016  BG3000 

2016  BG4000 

2010  BG1000 

2010  BG2000 

2010  BG3000 

2010  BG4000 

Mini-
mum 

0.79 

0.26 

0.13 

0.4 

0.5 

0.58 

0.03 

0.09 

Maxi-
mum 

6.27 

1.87 

20.97 

19.64 

4.43 

2.25 

20.97 

2 

Average  Mini-
mum 

1.93 

0.87 

3.46 

4.04 

1.62 

1.22 

2.44 

0.85 

0.17 

0.5 

0.02 

0.55 

0.5 

0.02 

0.8 

Maxi-
mum 

27.18 

17.54 

26.35 

30 

18.7 

26.35 

22 

Average  Mini-
mum 

Maximu
m 

Average  Mini-
mum 

Maxi-
mum 

Average 

3.56 

4.27 

3.9 

4.16 

4.77 

3.36 

5.83 

0.04 

32.93 

7.14 

14.82 

401.91 

86.13 

0.04 

32.6 

7.26 

7.01 

453.55 

109.85 

Source: WISE electronic reports. 

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
For  groundwater  bodies  there  was  a  slight  decrease  overall  of  5  %  in  the  number  of  water 

bodies between the first cycle and the second cycle (Table 2.3). The RBMPs explained that the 
delineation of the groundwater bodies was updated to address some technical errors and reduce 

fragmentation, to address recommendations from the Commission from the first RBMPs and to 
use  updated  data  from  geological  research.  The  re-delineation  was  based  on  geological 

information,  maps  and  new/targeted  research  used  for  the  water  abstraction  permits.  The 
RBMPs do not mention the consequences of these changes to groundwater bodies. 

Transboundary river water bodies have been designated for three RBDs: Danube, East Aegean 
and West Aegean. The same three RBDs also identified transboundary groundwater bodies.7  

Table 2.3 

Number and area of delineated groundwater bodies in Bulgaria for the 
second and first cycles  

Year 

RBD 

Number 

Area (km2) 

Minimum  Maximum  Average 

2016 

2016 

2016 

2016 

2016 

2010 

2010 

2010 

2010 

2010 

BG1000 

BG2000 

BG3000 

BG4000 

Total 

BG1000 

BG2000 

BG3000 

BG4000 

Total 

50 

40 

41 

38 

169 

50 

40 

48 

39 

177 

27.71 

3.21 

20.19 

7.24 

19 

3 

20.18 

8.01 

13,158.04 

1,480.44 

3,474.01 

6,596.79 

3,080.28 

737.29 

963.68 

409.93 

13,034.00 

1,471.28 

3,466.00 

5,094.83 

2,409.11 

729.9 

816.25 

379.91 

Source: WISE electronic reports. 

Table 2.4 summarises the information provided by Bulgaria on how water bodies have evolved 
between the two cycles. The water bodies with the most significant changes were river and 

lake water bodies with some deletions and in addition there was a significant amount of 
splitting of river water bodies (n = 348). 

7  Bulgaria  subsequently clarified that transboundary  water  bodies (surface and  groundwater) are  agreed in the 
framework of the ICPDR in the overall management plan of the international basin of the Danube River Basin. 
Bulgaria further stated that for the second management cycle, a mapping exercise was carried out to fine-tune 
the boundaries on one cross-border groundwater body.  
Bulgaria subsequently clarified for the Black Sea RBD and East Aegean RBD, the changes in border water 
bodies with the Republic of Turkey have been discussed during a bilateral meeting in Sofia in 2015. 
Bulgaria  subsequently  clarified  for  the  East  Aegean  RBD  and  the  West  Aegean  Aegean  RBD,  changes  in 
transboundary  groundwater  bodies  are  justified  in  the  project  “Study  of  transboundary  groundwater  bodies 
between Bulgaria and Greece” in which Greek experts are also involved. The variation of cross-border water 
bodies was discussed during a bilateral workshop held on 13 May 2016, Sandanski, Bulgaria. 
Bulgaria subsequently clarified for the West Aegean RBD, changes in the granite water bodies were presented 
for  the  first  time  at  the  third  meeting  of  the  Greek  group,  the  Bulgarian  expert  working  sub-group  held  in 
Athens on 23 June 2015.  

32 

 
 
 
 
 
 
 
 
                                                      
Table 2.4 

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

Bulgaria between the second and first cycles 

Type of water body 
change for second cycle  
Aggregation 
Splitting 
Aggregation and splitting 
Change 
Extended area 
Creation 
Deletion 
Change in code 
No change 

Total water bodies before 
deletion 
Delineated for second cycle 
(after deletion from first 
cycle) 

Groundwater 

Rivers 

Lake 

Transitional  

Coastal 

19 
348 
46 
4 
9 
7 
26 
5 
435 

899 

873 

5 
1 
1 
2 
20 
14 
14 

57 

37 

12 

16 

28 

28 

3 
11 
3 

17 

17 

Source: WISE electronic reports. Access to Groundwater data was restricted. 

2.1.2  Delineation of small water bodies 

Small  water  bodies  are  not  explicitly  discussed  in  the  RBMPs.  However,  the  national 
methodological  document  'Method  for  determining/updating  the  borders  of  surface  water 

bodies  during  the  update  of  RBMP'  contains  some  information  about  small  water  bodies. 
According  to  this  methodology  small  water  bodies  can  either  be  designated  as  water  bodies 

based on some significance criteria (e.g. category, type, status, pressures), or managed as part 
of the larger water bodies. The methodology states that small water bodies can be designated as 
separate water bodies in the following cases: 

 

the  water  body  is  a  drinking  water  safeguard  zone  (protected  area)  or  another 

type of protected area under national legislation (the Water Law); 

 

its  designation  as  a  water  body  is  the  most  effective  way  for  achieving  the 

environmental objectives. 

2.1.3  Typology of surface water bodies 

The  number  of  surface  water  body  types  appears  to  have  decreased  overall  by  about  20  % 
between the first cycle and the second cycle. The national methodology for typology of surface 

water bodies has been developed since the first RBMP based on the projects 'Determining the 
reference  conditions  and  maximum  ecological  potential  for  certain  types  of  surface  water 

bodies  (rivers  and  lakes)  on  the  territory  of  Bulgaria'  and  'Development  of  a  classification 

33 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
system and assessment of ecological status and ecological potential for certain types of surface 

water bodies (rivers and lakes) on the territory of Bulgaria (based on the typology system B)' in 
2009-2012.  The  projects  resulted  in  the  designation  of  common  national  types  for  surface 

water bodies - 16 types for rivers and 17 types for lakes. These types and other findings from 
the  projects  were  integrated  in  the  national  legislation  with  the  'Ordnance  N4  on  the 

characterisation  of  surface  water  bodies'  from  14  September  2012  and  applied  in  the  second 
RBMPs.  

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

natural) have been intercalibrated. Several of the national types for Bulgaria in all of the RBDs 
do not appear to have corresponding intercalibration types for all river water body types and 10 
lake types8.  In the Black Sea RBD there are also no equivalent intercalibration types for five 
transitional water bodies and six coastal water body types9.  

The  coordination  of  typology  is  not  discussed  at  length  in  the  RBMPs.  The  chapters  on 

transboundary  cooperation  focus  on  presenting  the  framework  for  cooperation  with  each 
neighbouring  country,  listing  the  meetings  that  took  place  and  providing  summaries  of  the 

main  issues  discussed  at  each  meeting.  The  methodology  for  designating  the  types  and  the 
typology  of  water  bodies  was  discussed  at  bilateral  meetings  with  Romania  (Danube,  Black 

Sea RBDs), Greece (East Aegean, West Aegean RBDs) and Turkey (Black Sea, East Aegean 
RBDs)10.  

8  Bulgaria  subsequently  clarified  that  all  national  types  were  involved  in  the  intercalibration  exercise,  which 
established conformity with the generic European types (TEC): 1 lake type and 5 type of rivers with the East 
AGS,  a single type of rivers  in the  Mediterranean gears and 7 Black Sea  area Black.  All identified national 
types for the Danube Region (ecoregion 12) are intercalibrated, with the exception of 2 category ‘river’ (R9 
and R15), as they do not have matching types in the GIG. The GIG (XLarge Rivers) — Danube (border water 
body  with  Romania  type  R6)  is  continuing  the  process  of  incorporation  in  the  GIG  (XLarge  Rivers)  and 
Bulgaria and Romania participate in GIG. 

9  Bulgaria  subsequently  clarified  that  to  date,  common  types  of  transitional  water  bodies  have  not  been 
identified  at  European  level  through  the  Black  Sea  ID  as  well  as  common  types  of  rivers  and  lakes  in  the 
catchment area of the River Maritsa, River Struma, River Miles and Dospat (ecoregion 7).  

10 Bulgaria highlighted that A survey on the conformity of national surface water types with other neighbouring 
countries  types  was  carried  out  between  2014  and  2016,  with  detailed  information  on  a  national  supporting 
document  
http: 
//cdr.eionet.europa.eu/bg/eu/wfd2016/documents/national/envwcq9cw/SWB_Posible_Common_Types.doc/m
anage_document ). The report suggests possible actions for cross-border cooperation in this regard.  

34 

 
                                                      
Table 2.5 

Number of surface water body types at RBD level in Bulgaria for the first 
and second cycles 

RBD 

Rivers 

Lakes 

Transitional 

Coastal 

BG1000 

BG2000 

BG3000 

BG4000 

TOTAL 

2010 

2016 

2010 

2016 

2010 

2016 

2010 

2016 

22 

9 

10 

17 

55 

13 

8 

10 

6 

6 

3 

5 

4 

3 

4 

4 

5 

20 (15) 

18 

10 (6) 

0 

5 

0 

0 

5 

0 

5 

0 

0 

5 

0 

6 

0 

0 

6 

0 

9 

0 

0 

9 

Source: WISE electronic reports. Note that the total is not the sum of the types in each RBD as some types are 
shared by RBDs. Values in brackets were subsequently reported by Bulgaria but do not match the data reported 

to WISE.        

2.1.4  Establishment of reference conditions for surface water bodies 

Table  2.6  shows  the  percentage  of  surface  water  body  types  in  Bulgaria  with  reference 
conditions established for the first and second cycles11. Type specific reference conditions have 
been established for all relevant biological quality elements for 44 % of lakes12, 64 % of rivers 
and 20 % of transitional waters13 but only for some biological elements in coastal waters. Type 
specific  reference  conditions  have  not  been  established  for  hydromorphological  quality 
elements  in  transitional  or  coastal  waters.  Physicochemical  quality  elements  have  been 

established  for  78  %  of  elements  in  lakes,  56  %  in  rivers  and  40  %  transitional  but  none  in 
coastal waters.  

Reference  conditions  have  been  coordinated  with  some  but  not  all  Member  States  for 
biological  quality  elements,  physico-chemical  quality  elements  and  hydromorphological 

quality  elements.  Reference  conditions  were  only  mentioned  in  the  East  Aegean  and  West 
Aegean RBMPs in relation to issues discussed at bilateral meetings with Greece. However, it is 

not  specified  which  elements  these  reference  conditions  refer  to.  The  other  RBMPs  do  not 
mention if reference conditions were discussed at transboundary coordination meetings. 

11  Bulgaria  subsequently  highlighted  that  as  the  summaries  in  WISE  are  made  per  category,  they  are  not  the 
correct  basis  for  specific  analysis  for  Bulgaria  e.g.  the  river  category  includes  rivers  with  the  performance 
characteristics of lakes (rivers which are dammed).  

12    Bulgaria  subsequently  clarified  that  in  the  case  of  lakes,  there  are  no  specified  reference  conditions  for 
biological quality elements and macroinvertebrates, due to the absence of a legally established classification 
system for the assessment of the ecological condition. 

13  Bulgaria subsequently clarified that transitional waters in the Black Sea RBD are identified in estuaries and in 
coastal  lakes  rather  than  in  marine  waters.  In  this context  biological quality elements,  such as,  macrophytes 
and not macroalgae and angiosperms are used for ecological status assessment; phytoplankton is used for lakes 
type and phytobenthos for rivers . Bulgaria stated that some of the biological quality elements in this category 
are subject to reference conditions and others have to be determined. 

35 

 
 
                                                      
Table 2.6 

Percentage of surface water body types in Bulgaria with reference conditions 

established for all, some and none of the biological, hydromorphological and 
physicochemical quality elements  

Waterbody 
category 

Waterbody 
types 

Rivers 

Lakes 

All  

Some 

None 

All  

Some 

None 

All  

Transitional 

Some 

Coastal 

None 

All  

Some 

None 

Biological quality 
elements 
64% 

Hydromorphological 
quality elements 
48% 

Physicochemical quality 
elements 
56% 

12% 

24% 

44% 

44% 

17% 

20% 

60% 

20% 

100% 

52% 

78% 

22% 

100% 

16% 

28% 

78% 

22% 

40% 

60% 

100% 

100% 

Source: WISE electronic reports 

2.1.5  Characteristics of groundwater bodies 

The geological formation of the aquifer types where there are groundwater bodies, along with 
details of whether groundwater bodies are layered or not, are reported. Further characterisation 

work has been reported since the first cycle with the inclusion of the assessment of linkages to 
surface water bodies and terrestrial ecosystems. The methodology used in the first RBMPs was 

refined  and  a  common  national  methodology  entitled  'Methodology  for  characterisation  of 
groundwater bodies' was developed and applied in the second RBMPs. 

2.1.6 

Significant pressures on water bodies 

In the second cycle, “no significant pressure” was reported most often (39 % of water bodies) 

and  the  most  significant  pressures  on  surface  waters  were  reported  to  be  anthropogenic 
pressure – unknown (23 %), point - urban waste water (22 %) and diffuse – agricultural (19 %) 
(Figure 2.2. In the first cycle, Bulgaria only reported pressures at an aggregated level making it 
difficult  to  compare  reporting  of  the  first  and  second  cycle  pressures.  There  has  been  an 

apparent increase in the reporting of hydromorphological pressures (Figure 2.3) and unknown 
anthropogenic pressures (or other pressures). Diffuse pressures appear to have decreased in the 

East Aegean and West Aegean RBDs. 

36 

 
  
  
  
  
  
  
  
  
  
  
  
  
For groundwater bodies, diffuse – agricultural (50 %) and diffuse - discharges not connected to 

sewerage network (49 %) were reported to be the most significant pressures (Figure 2.2). “No 
significant pressure” however, was also reported for 41 % of water bodies.  

For the second cycle, it was reported which significant pressures were not assessed for surface 
waters, which were different in each RBD. For surface water bodies the pressures and activities 

covered are: 

 

point  sources:  urban  wastewater,  industrial  wastewater;  animal  farms  and 

aquaculture (only in the East Aegean RBD); 

 

diffuse  sources:  urban  areas  without  sewage  systems,  waste 

landfills, 

agriculture, aquaculture, erosion, land use, atmospheric and transport pollution; 
mining  activities  (only  in  the  Danube  and  West  Aegean  RBDs);  tourism,  past 

activities (only in the West Aegean RBD); 

 

physical/  hydromorphological  alterations:  water  abstraction,  morphological 

alterations, water flow regulation; 

pressures from invasive species; 

pressures from climate change; 

pressures from fisheries, dredging and ports (only the Black Sea RBD); 

pressures from navigation (only Danubian and Black Sea RBDs). 

 

 

 

 

Overall,  the  same  types  of  pressures  and  related  activities  are  covered  in  each  RBMP,  for 

groundwater bodies the pressures and activities covered are: 

 

point  sources:  urban  WWTPs,  industrial  installations;  farms  and  storage 

facilities  for  pesticides  and  fertilisers,  waste  landfills,  mines  and  quarries,  past 
activities; 

 

 

 

diffuse sources: agriculture, landfills, mines, past activities, urban areas without 
sewage systems; 

pressures from water abstraction; 

pressures from climate change. 

37 

 
There were 14 pressures in the Danube RBD not assessed, 13 in the  Black Sea RBD, five in 
the  East  Aegean  RBD  and  1214  in  the  West  Aegean  RBD.  The  RBMPs  do  not  provide  any 
information as to why some pressures have been excluded from the risk assessment. The RBDs 

did not report any significant pressures that were not assessed for groundwater.  

Figure2.2 

The  most  significant  pressures  on  surface  water  bodies  and  groundwater 
bodies in Bulgaria for the second cycle  

Source: WISE electronic reports. 

14    Bulgaria  subsequently  clarified  that  reporting  for  the  West  Aegean  RBD  had  an  error,  under  the  element  of 
“SWPressures_swPressuresNotAssessed”,  completed  information  indicated  that  46  types  of  pressure  have 
been assessed but in reality, 44 pressures have been assessed and 12 pressures have not been assessed. 

38 

 
 
 
 
 
                                                      
Figure 2.3  Comparison of pressures on surface water bodies in Bulgaria in the first and 

second cycles. Pressures presented at the aggregated level. Note there were 
955 identified surface water bodies for the second cycle and 759 for the first 

cycle 

Source: WISE electronic reports. 

2.1.7  Definition and assessment of significant pressures on surface and groundwater 

For  surface  waters  the  tools  used  to  define  significant  pressures  varied  depending  on  the 

pressure. A combination of both expert judgement and numerical tools were used for defining 
diffuse  and  point  pressures  in  all  RBDs15.  For  surface  water  bodies  the  significance  of 
pressures is reported to be defined in terms of thresholds and linked to the potential failure of 
objectives for all RBDs except the Black Sea RBD.  

For  groundwaters  a  combination  of  expert  judgement  and  numerical  tools  were  used  for 
defining  diffuse  and  point  source  pressures  and  abstractions  in  the  Danube  RBD.  Numerical 

tools  were  used  in  the  Black  Sea  and  West  Aegean  RBDs.  For  the  East  Aegean  RBD  a 
combination  of  both  were  used  for  defining  diffuse  and  point  pressures  and  numerical  tools 
only for abstractions pressures16. For groundwater, the significance of pressures is reported to 
be defined in terms of thresholds and linked to the potential failure of objectives for all RBDs17. 

15    Only  expert  judgement  was  reported  to  be  used  in  the  East  Aegean  RBD  however  Bulgaria  subsequently 

clarified that this is a reporting error.  

16    Artificial  recharge  pressures  were  reported  in  WISE  to  have  been  assessed  in  the  West  Aegean  RBD  using 
numerical  tools;  however,  Bulgaria  subsequently  clarified  that  this  was  a  technical  error  and  there  is  no 
pressure from artificial recharge of groundwater in any of their RBDs 

17  For groundwater, significance of pressures is reported not to be defined in terms of thresholds or linked to the 
potential  failure  of  objectives  for  the  Black  Sea  RBD.  Bulgaria  subsequently  clarified  that  pressure 
assessments in all RBDs have been carried out according to the adopted national approaches. 

39 

 
 
                                                      
The use of common national methodologies for analysing the pressures from point and diffuse 

pollution sources, water abstraction and climate change was reported. 

The  approach  used  for  defining  pressures  on  surface  water  bodies  in  the  first  RBMPs  was 

refined  to  determine  the  'driving  force-pressure-status-impact'  relationships,  expand  the 
analysis of pressures (e.g. by considering more sources of pressures) and to implement results 

from models, projects and research (e.g. MONERIS, WATER, PegOpera). These changes are 
only explicitly summarised in the Danube RBMP. 

The RBMPs do not explicitly discuss the tools or methodologies for assessment of each type of 
pressure; they only briefly present the general approach and then the results for each type of 

pressure for each type of water body. However, the RBMPs contain tables with the potential 
impacts of different types of pressure and the indicators for their reporting.. The main text of 

all RBMPs list the data sources of the information used to analyse the pressures. The website 
of  the  Ministry  of  Environment  and  Water  (MOEW)  suggests  the  following  national 
methodologies exist:  

 

'Pressures  and  impact  on  the  quantitative  status  of  groundwater  bodies  and 

Methodology  for  assessment  of  the  risk  that  groundwater  bodies  do  not  reach 
good quantitative status'; 

 

'Methodology for assessment of the pressure and impact on surface water bodies 
and groundwater bodies of climate change and assessment of the availability of 

water for economic sectors'; 

 

'Methodology for analysis of the pressure and impact of anthropogenic activities 

related to water abstraction from surface waters'. 

The  Danube  and  East  Aegean  RBMPs  provide  brief  overviews  of  the  remaining  gaps  in 

relation to pressure analysis that could be the reasons for the different approaches reported for 
different RBDs. Examples of gaps mentioned in these two RBMPs are: 

 

no  common  methods  or  methodologies  for  some  pressure  assessments  i.e. 

diffuse sources, and quantitative source apportionment 

 

insufficient monitoring data or data of insufficient quality (credibility, coverage, 

format) for some pressures assessments; 

 

no  models  to  assess  the  impacts  of  different  pressures,  including  their 
cumulative impacts. 

40 

 
2.1.8 

Significant impacts on water bodies  

In the second cycle, the most significant impact on surface water bodies was nutrient pollution 
(40 %) and organic pollution (25 %), with 36 % classified as having “no significant impact”.  

For groundwaters over 50 % were classified as “no significant impact”. The most significant 
impacts were classified as nutrient pollution (27 %) and chemical pollution (11 %). Bulgaria 

did not report on impacts in the first cycle. 

41 

 
Figure 2.4 

Significant impacts on surface water and groundwater bodies in Bulgaria for 

the second cycle. Percentages of numbers of water bodies 

Source: WISE electronic reports 

42 

 
 
 
 
 
2.1.9  Quantification of the gap and apportionment of pressures  

There are some inconsistencies in significant pressures reported at the water body level and the 
pressures  for  which  measures  are  planned.  For  example,  in  the  Danube  RBD,  diffuse  - 

contaminated  sites  or  abandoned  industrial  sites  has  been  reported  at  the  groundwater  body 
level but this pressure has not been reported as being tackled in the Programme of Measures. 

Similarly,  in  the  Black  Sea  RBD,  abstraction  or  flow  diversion  -  public  water  supply  is 
reported at a surface water body level but not in the Programme of Measures18. 

Priority Substances and other substances causing the failure of good chemical status have been 
reported.  The  measures  to  tackle  these  substances  to  achieve  good  status  by  2027  or  the 

indicator gap have not been reported and were listed in Annex 0 by Bulgaria. 

2.1.10  Groundwater bodies at risk of not meeting good status 

In each RBD groundwater bodies were reported to be at risk of failing to meet good chemical 
status, ranging from 24 to 72 % of water bodies. The pollutants putting groundwater bodies at 
risk of failing good chemical status have been reported. 

In  each  RBD  groundwater  bodies  were  reported  to  be  at  risk  of  failing  to  meet  good 
quantitative status, ranging from 15 to 26 % of water bodies. 

2.1.11  Inventories of emissions, discharges and losses of chemical substances 

Article  5  of  the  Environmental  Quality  Standards  Directive  2008/105/EC19  (EQS  Directive)  
requires  Member  States  to  establish  an  inventory  of  emissions,  discharges  and  losses  of  all 
Priority  Substances  and  the  eight  other  pollutants  listed  in  Part  A  of  Annex  I  of  the  EQS 

Directive  for  each  RBD,  or  part  thereof,  lying  within  their  territory.  This  inventory  should 
allow Member States to further target measures to tackle pollution from priority substances. It 

should  also  inform  the  review  of  the  monitoring  networks,  and  allow  the  assessment  of 
progress  made  in  reducing  (respectively  suppressing)  emissions,  discharges  and  losses  for 

priority substances (respectively priority hazardous substances). 

Bulgaria reported an inventory of emissions for each of the RBDs, however these inventories 

included only between four and six of the 41 Priority Substances.  

18  Bulgaria  subsequently  clarified  that  this  was  because  only  the  national  measures  were  reported  in  the 

Programme of Measures but not the actions to implement these measures. 

19 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 

43 

 
                                                      
These  inventories  were  based  on  Common  Implementation  Strategy  Technical  Guidance 
Document No. 2820 and on additional guidance documents developed at national level such as 
'Methodological guidance for determining the mass weight of pollutants in waste waters from 

point sources when compiling the first inventory of emissions, discharges and losses of Priority 
Substances and some other pollutants' and 'Instructions for implementing the first inventory of 

emissions, discharges and losses of Priority Substances and some other pollutants'.  

The two step approach from the Common Implementation Strategy Guidance Document no 28 

has  been  followed  for  the  substances  considered  in  the  inventories.  For  these  substances  a 
combination of Tier 1 (point source information) and Tier 2 (riverine load) was implemented 

(the  Guidance  Document  recommends  using  at  least  Tier  1+2  for  the  substances  relevant  at 
RBD level). The data quality was assessed as uncertain. 

The  RBMP  specifies  that  between  2017  and  2018  an  action  plan  for  improving  the 
implementation of inventory of Priority Substances will be carried out where the main aim will 
be to refine the tools and methods for the inventory. 

2.2

  Main changes in implementation and compliance since first cycle 

Overall there was a significant change in the number of water bodies delineated between the 

first cycle and the second cycle. For example, for river water bodies there was a 27 % increase 
overall with the increase as high as 63 % in the Danube RBD and for the Black Sea RBD there 

was an 87 % increase in transitional water bodies and a 31 % increase in coastal water bodies. 
For  groundwater  bodies  there  was  a  slight  decrease  overall  of  5  %.  The  number  of  surface 

water body types appears to have decreased overall by about 20 % between the first cycle and 
the second cycle. 

There  has  been  an  apparent  increase  in  the  reporting  of  hydromorphological  pressures  and 
unknown  anthropogenic  pressures  (or  other  pressures)  for  surface  waters  between  the  first 

cycle and the second cycle. Diffuse pressures appear to have decreased in the East Aegean and 
West  Aegean  RBDs.  This  is  likely  a  result  of  changes  in  methodologies  as  discussed  in  the 

previous section. 

2.3

Progress with Commission recommendations 

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

20 

CIS 

Guidance 

N° 

28 

- 

Preparation 

of 

Priority 

Substances 

Emissions 

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

44 

 
 
                                                      
 

Recommendation: The existing pressures are not being sufficiently detected, particularly 

where  complex  pressure  factors  exist,  e.g.  combined  pollution  from  diffuse  and  point 
sources,  or  combined  pressures  from  pollution  and  hydromorphological  alterations. 

Pressures should be sufficiently detected.  

Assessment: For the second cycle, it was reported which significant pressures were not 

assessed for surface waters. The pressures listed were different in each RBD. There were 
14 pressures not assessed in the Danube, 13 in the Black Sea, 5 in the East Aegean RBD 

and 12 the West Aegean RBD. However, pressures from aquaculture were addressed in 
all  RBDs  as  were  diffuse  atmospheric  deposition,  with  the  exception  of  the  Black  Sea 

RBD.  No  explanation  for  why  certain  pressures  were  not  assessed  was  found  in  the 
RBMPs.  The  approach  used  for  defining  pressures  on  surface  water  bodies  in  the  first 

RBMPs was refined to determine the 'driving force-pressure-status-impact' relationships, 
expand the analysis of pressures (for example by considering more sources of pressures) 

and  to  implement  results  from  models,  projects  and  research.  Therefore,  this 
recommendation has partially been fulfilled.  

  Recommendation:  Set  out  in  the  second  RBMPs  a  clear  assessment  of  the  pressure 

agriculture is exerting on the status of water bodies. 

Assessment:  In terms  of characterisation, diffuse  – agricultural  has been  identified as a 
significant  pressure  in  each  RBD  and  accounts  for  8  %  of  the  pressures  overall.  The 

review of the RBMPs revealed that there are no common methods or methodologies for 
some  pressure  assessments  i.e.  diffuse  sources  and  their  source  apportionment.  Further 

progress is therefore required to meet this recommendation.  

 

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.  

Assessment:  In  terms  of  characterisation,  the  following  conclusions  on  the  progress  to 

this recommendation are made below: 

The  minimum  size  criterion  for  delineating  river  water  bodies  was  reported  to  be  a  10 
km2  catchment  size  for  each  RBD  which  is  the  same  as  the  European  Union  average. 
When comparing the minimum reported catchment areas of rivers between the first cycle 

and the second cycle, it was observed that for the Danube RBD there was a decrease in 
minimum size from 0.55km2 to 0.17km2, there was no change for the Black Sea and East 
Aegean RBDs, and the West Aegean RBD did not report the minimum size in the second 

45 

 
cycle. The two main criteria for designating small water bodies according to the national 

methodology was if the water body is a drinking water safeguard zone (protected area) or 
another  type  of  protected  area  under  national  legislation  (the  Water  Law)  or  if  its 

designation  as  a  water  body  is  the  most  effective  way  for  achieving  the  environmental 
objectives.  

There  are  gaps  in  the  development  of  type  specific  reference  conditions,  for  example, 
type specific reference conditions have only been established for all relevant biological 

quality elements  for 33  % of lakes, 57 % of rivers and 20 % of transitional waters but 
only for some biological elements in coastal waters.  

Overall, this recommendation has been partially fulfilled. 

 

Recommendation: Review the pressures and impacts analysis and status assessment in a 

consistent  manner  across  all  RBDs  in  the  second  RBMP  and  ensure  that  the  measures 
are based on the updated pressures and impacts analysis and status assessment of water 

bodies. 

Assessment:  There  have  been  significant  changes  in  the  delineation  of  water  bodies 

between the first and second cycle. For example, for river water bodies there was a 27 % 
increase overall with the increase as high as 63 % in the Danube RBD. The tools used to 

define  significant  pressures  varied  depending  on  the  pressure  and  the  approaches  also 
sometimes  differed  between  RBDs.  For  groundwater  either  a  combination  of  expert 

judgement and numerical tools or just numerical tools were used for all pressure types. 
Expert  judgement  was  used  for  defining  water  flow  pressures  in  all  RBDs  except  the 

Black Sea, and expert judgement was also used for abstraction pressures in the Danube 
RBD. The significance of pressures from navigation appears to have been addressed only 

in  the  Black  Sea  RBD  and  Danube  RBD.  There  appears  to  be  some  progress  made  in 
implementing this recommendation but there is still some inconsistency between RBDs. 

Therefore this recommendation has been partially fulfilled. 

46 

 
Topic 3 Monitoring, assessment and classification of ecological 
status in surface water bodies 

3.1.  Assessment of implementation and compliance with WFD requirements 

in second RBMPs 

3.1.1  Monitoring of ecological status/potential 

Monitoring programmes 

Article  8.1  of  the  WFD  requires  Member  States  to  establish  monitoring  programmes  for  the 
assessment of the status of surface water and of groundwater in order to provide a coherent and 

comprehensive overview of water status within each RBD.  

Bulgaria  reported  54  different  monitoring  programmes  for  the  second  cycle  covering 

groundwater,  coastal  waters,  transitional  waters,  lakes  and  rivers.  Generally  the  programmes 
are  specific  for  each  RBD,  for  each  water  category  in  the  RBD  and  for  surveillance  and 
operational  purposes.  Bathing  water  and  Nitrates  Directive21  programmes  are  reported  for 
surface waters. 

Monitoring sites  

Table  3.1  compares  the  number  of  monitoring  sites  used  for  surveillance  and  operational 
purposes  between  the  cycles,  and  Table  3.2  gives  the  number  of  sites  used  for  different 

purposes for the second cycle. 

Table 3.1 

Number of sites used for surveillance and operational monitoring in Bulgaria 

for the second and first RBMPs. Note that for reasons of comparability with 
data reported in the first cycle, the second cycle data does not take into 

account whether sites are used for ecological and/or chemical monitoring 

second RBMP  

BG_1000 

BG_2000 

Rivers 

Lakes 

Transitional 

Coastal 

Surv. 

Op 

131 
(288) 

307 
(307) 

0 (58) 

20 
(23) 

Sur
v. 

1 
(6) 

2 
(2) 

Op 

Surv
. 

Op 

Surv
. 

Op 

0 

0 

28 
(28) 

15 
(18) 

14 
(14) 

6 
(6) 

21   Council  Directive  91/676/EEC  of  12  December  1991  concerning  the  protection  of  waters  against  pollution 

caused by nitrates from agricultural sources  
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:31991L0676  

47 

 
  
  
  
  
  
  
  
  
  
 
 
 
 
                                                      
 
BG_3000 

BG_4000 

Total by type of site 

Total number of monitoring sites 
used for surveillance and/or 
operational monitoring 

first RBMP 

BG_1000 

BG_2000 

BG_3000 

BG_4000 

34 
(34) 

20 
(32) 

492 
(661) 

147 
(149) 

118 
(257) 

285 
(487) 

1 
(1) 

1 
(5) 

5 
(14) 

0 (1) 

14 
(15) 

14 
(16) 

28 
(28) 

15 
(18) 

14 
(14) 

6 
(6) 

756 (1107) 

19 (30) 

35 (35) 

20 (20) 

97 

10 

12 

27 

59 

18 

74 

67 

40 

9 

8 

5 

0 

14 

4 

4 

7 

3 

Total by type of site 

146 

218 

62 

22 

0 

0 

7 

3 

Total number of monitoring sites 
used for surveillance and/or 
operational monitoring 
Sources: Member States electronic reports to WISE. The Bulgaria Authorities subsequently stated that there had 
been some errors in reporting the purpose of monitoring information at site level. The values in brackets in the 
Table above for the second RBMP are the values from the reported information at the monitoring programme 
level and their associated monitoring sites.   

364 

84 

10 

0 

 Table 3.2   Number of monitoring sites in relevant water categories used for different 

purposes in Bulgaria  

Monitoring Purpose 

Lakes 

Rivers 

Transitional 

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 

NID - Nutrient sensitive area under the Nitrates 
Directive - WFD Annex IV.1.iv 

OPE - Operational monitoring 

REF - Reference network monitoring site 

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

SHE - Shellfish designated waters - WFD Annex 
IV.1.ii 

SOE - EIONET State of Environment monitoring 

SUR - Surveillance monitoring 

UWW - Nutrient sensitive area under the Urban 
Waste Water Treatment Directive - WFD Annex 
IV.1.iv 

7 

8 

35 

1 

10 

14 

7 

6 

5 

2 

48 

4 

302 

319 

1562 

112 

266 

285 

58 

12 

171 

492 

326 

26 

35 

17 

5 

15 

6 

8 

28 

35 

90 

17 

20 

10 

6 

6 

4 

7 

14 

20 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
Monitoring Purpose 

Lakes 

Rivers 

Transitional 

Coastal 

Total sites irrespective of purpose 

40 

1790 

35 

110 

Source: WISE electronic reports. Bulgaria subsequently stated that there has been a technical error in reporting 

and the number of sites reported for operational and surveillance monitoring may not be correct. 

There were no monitoring sites in transitional waters for the first RBMPs, but there were sites 

for  surveillance  and  operational  purposes  reported  in  the  second  RBMPs.  There  were 
operational sites in lakes in three RBDs reported for the first RBMPs but only in two for the 

second.  

Because  of  reporting  errors  in  WISE  for  the  second  RBMPs  it  is  not  possible  to  make 

quantitative  comparisons  of  the  numbers  of  monitoring  sites  between  the  two  RBMPs. 
However, it can be concluded that there have been increases in the number of surveillance and 

operational  sites  in  rivers,  transitional  and  coastal  waters,  and  decreases  in  the  numbers  of 
surveillance and operational sites in lakes from the first to the second RBMPs.  

Monitored quality elements (excluding River Basin Specific Pollutants) 

Table  3.3  illustrates  the  quality  elements  used  for  the  monitoring  of  surface  waters  for  the 
second RBMP: no differentiation is made between purposes of monitoring. 

Table 3.3  Quality elements monitored for the second RBMP in Bulgaria (excluding River 
Basin  Specific  Pollutants).  Note:  quality  element  may  be  used  for  surveillance  and/or 

operational monitoring 

Biological quality elements 

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

Yes 

Yes 

Yes 

Yes 

s
e
t
y
h
p
o
r
c
a
M

Yes 

Yes 

Yes 

No 

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

Yes 

Yes 

No 

c
i
h
t
n
e
B

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

Yes 

Yes 

Yes 

Yes 

h
s
i
F

Yes 

Yes 

Yes 

s

m
r
e
p
s
o
i
g
n
A

e
a
g
l
a
o
r
c
a
M

No 

Yes 

No 

Yes 

c
i
t
a
u
q
a

r
e
h
t
O

a
r
o
l
f

No 

No 

No 

No 

s
e
i
c
e
p
s

r
e
h
t
O

Lakes 

Rivers 

Transitional 

Coastal 

49 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Hydromorphological quality elements 

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

No 

Yes 

No 

Yes 

y
t
i
u
n
i
t
n
o
C

s
n
o
i
t
i
d
n
o
c

Yes 

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

s
n
o
i
t
i
d
n
o
c

No 

Yes 

No 

Yes 

Lakes 

Rivers 

Transitional 

Coastal 

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 

Yes 

l
a
m
r
e
h
T

s
n
o
i
t
i
d
n
o
c

Yes 

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 

Yes 

y
t
i
n
i
l
a
S

s
n
o
i
t
i
d
n
o
c

Yes 

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 

No 

n
e
g
o
r
t
i

N

s
n
o
i
t
i
d
n
o
c

Yes 

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 

Yes 

Source: WISE electronic reports 

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 

No 

e
t
a
c
i
l
i
S

No 

No 

No 

No 

Lakes 

Rivers 

Transitional 

Coastal 

There  was  no  monitoring  of  transitional  waters  reported  for  the  first  RBMPs.  All  expected 

biological quality elements were reported to be monitored in coastal waters and rivers for the 
first RBMPs and in lakes all biological quality elements except phytobenthos were monitored. 

All  expected  hydromorphological  and  physicochemical  quality  elements  were  reported  to  be 
monitored in coastal waters, rivers and lakes for the first RBMP.  

There are some significant gaps in the quality elements monitored in Bulgaria  for the second 
RBMPs.  The  monitoring  of  macroalgae  and  angiosperms  is  missing  in  transitional  waters, 
though macrophytes and phytobenthos are used, which are generally required for freshwaters22. 
Macrophytes and benthic invertebrates are not monitored in lakes in one RBD, and fish are not 
monitored  in  lakes  in  two  RBDs23.  The  monitoring  of  phytobenthos  in  lakes  is  missing24. 

22   Bulgaria subsequently indicated that transitional waters in the Black Sea RBD are identified in estuaries and in 
coastal  lakes  rather  than  in  marine  waters.  They  are  therefore  monitored  for  phytobenthos  rather  than  for 
macroalgae and angiosperms. 

23    Bulgaria  subsequently  indicated  that  lakes  in  the  Danube  RBD  have  been  monitored  for  fish  and  benthic 
invertebrates, and lakes in the West Aegean RBD for macrophytes and benthic invertebrates. In addition 1 lake 
in the East Aegean RBD was monitored for macrophytes and benthic invertebrates in 2011. However, these 
results were not reported. 

24  Bulgaria subsequently indicated that this BQE was included in lakes in the third intercalibration phase, which 

was not completed at the time of preparation of the second RBMPs and continued afterwards. 

50 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
Hydromorphological  quality elements are not  monitored in  lakes and transitional waters, and 
only monitored in coastal waters and, in one of the four RBDs, in rivers25.  

Annex  V  of  the  WFD  provides  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 

should be done twice during the monitoring year and for the other biological quality elements 
once during the year. As a guideline, operational monitoring should take place at intervals not 

exceeding once every six months for phytoplankton and once every three years during the six 
year cycle for the other biological quality elements. Greater intervals may be justified on the 

basis of technical knowledge and expert judgement. 

For the surveillance monitoring of phytoplankton, all sites in coastal waters were monitored at 
least at the minimum frequency; this was not the case in the other three water categories26.  All 
sites used for the surveillance monitoring of the other biological quality elements in all water 
categories  were  monitored  at  least  at  the  minimum  frequency.  In  terms  of  operational 

monitoring, phytoplankton was monitored at least at the minimum frequency in all sites where 
they were monitored in coastal waters, lakes and rivers; none of the sites were in transitional 

waters. 

Six of the 12 biological quality elements used for the operational monitoring of surface waters 

were  monitored  at  all  sites  where  they  were  monitored  at  least  at  the  minimum  sampling 
frequency.  Two  biological  quality  elements,  fish  and  macrophytes,  were  not  sampled  at  the 

minimum sampling frequency in any of the sites at which they were monitored in transitional 
waters.  

Monitoring of River Basin Specific Pollutants  

River Basin Specific Pollutants are reported to be monitored (at the generic level) in all of the 

water categories relevant to each RBD, except for lakes in the Black Sea RBD. 

63  different  River  Basin  Specific  Pollutants  (reported  at  the  chemical  substance  level)  are 

monitored  in  Bulgaria:  one  in  coastal  waters,  22  in  lakes,  62  in  rivers,  none  in  transitional 
waters  (even  though  they  were  reported  at  a  generic  level).  All  are  only  monitored  in  water. 

The  highest  number  of  sites  were  for  the  monitoring  of  iron  (464  sites),  followed  by 
manganese (463 sites) and copper (315 sites).  

25  Bulgaria subsequently stated that monitoring for hydromorphological quality elements had been performed in 
2012 in the Black Sea, East Aegean, and West Aegean RBD. This information was not reported to WISE. 
26  Note that this assessment is based on monitoring purpose data reported to WISE at the monitoring site level. 
Bulgaria  has  subsequently  indicated  that  some  of  these  data  may  not  have  been  fully  reported:  the  analysis 
should therefore be treated with caution.  

51 

 
                                                      
Annex  V  of  the  WFD  provides  guidance  on  the  frequency  of  monitoring  of  the  different 

quality  elements:  once  every  three  months  is  recommended  for  “other  pollutants”  which  are 
taken  here  to  equate  to  river  basin  specific  pollutants.  Surveillance  monitoring  should  be 

carried  out  for  each  monitoring  site  for  a  period  of  one  year  during  the  period  covered  by  a 
river  basin  management  plan  i.e.  six  years.  For  river  basin  specific  pollutants  this  should  be 

done four times in the surveillance year, and for operational monitoring four times a year for 
each year of the cycle. 

Of the 47 River Basin Specific Pollutants included in surveillance monitoring of surface waters 
in Bulgaria, seven were monitored at least at the minimum frequency at all of the sites where 
they were monitored, and 24 pollutants at none of the sites27. Of the 36 River Basin Specific 
Pollutants included in operational monitoring of surface waters in Bulgaria, 23 were monitored 

at  least  at  the  minimum  frequency  at  all  of  the  sites  where  they  were  monitored,  and  four 
pollutants at none of the sites. 

Table  3.4  shows  the  number  of  sites  used  to  monitor  River  Basin  Specific  Pollutants  in 

Bulgaria in the first and second RBMPs. 

Table 3.4 

Number  of  sites  used  to  monitor  River  Basin  Specific  Pollutants  reported  in 

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

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

were no equivalent data for the first cycle 

RBMP 

first  

second  

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

Sites used to monitor River Basin Specific 
Pollutants  

Lakes  Rivers  Transitional  Coastal 

66 

11 

283 

599 

0 

25 

10 

20 

Sources: WISE electronic reports 

Surveillance monitoring of surface water bodies28 

All  nine  coastal  water  bodies  included  in  surveillance  monitoring  were  monitored  for  all 
required biological, hydromorphological and physicochemical quality elements. 

27  Note that this assessment is based on monitoring purpose data reported to WISE at the monitoring site level. 
Bulgaria subsequently indicated that some of these data may not have been fully reported; the analysis should 
therefore be treated with caution. 

28  Note that this assessment is based on monitoring purpose data reported to WISE at the monitoring site level. 
Bulgaria  has  subsequently  indicated  that  some  of  these  data  may  not  have  been  fully  reported;  the  analysis 
should therefore be treated with caution 

52 

 
 
                                                      
None  of  the  lake  and  transitional  water  bodies  included  in  surveillance  monitoring  was 

monitored  for  all  required  biological  quality  elements,  whereas  a  proportion  of  river  water 
bodies  in  surveillance  monitoring  in  three  of  the  four  RBDs  were  monitored  for  all  required 

biological quality elements: the minimum was 11 % in the West Aegean RBD and maximum 
61 % in the Black Sea RBD.  

Lakes  and  transitional  water  bodies  were  not  monitored  for  any  hydromorphological  quality 
elements. Only two river water bodies included in surveillance monitoring were monitored for 

hydromorphological quality elements but neither was monitored for all the required ones. 

Lakes  in  three  of  the  four  RBDs  were  monitored  for  all  required  physicochemical  quality 

elements in surveillance monitoring; in the other RBD none were. Nearly all river water bodies 
in  surveillance  monitoring  in  three  of  the  four  RBDs  were  monitored  for  all  required 

physicochemical  quality  elements;  in  the  other  RBD,  70  %  were.  63  %  of  transitional  water 
bodies  in  surveillance  monitoring  were  monitored  for  all  required  physicochemical  quality 
elements. 

At  the  national  level  around  a  quarter  of  water  bodies  in  each  category  were  included  in 
operational  monitoring.  There  were  greater  differences  in  the  proportion  of  water  bodies 

included in the surveillance monitoring of each category than for operational monitoring: 86 % 
of transitional water bodies, 53 % of coastal water bodies, 30 % of river water bodies and 14 % 

of lake water bodies were included in surveillance monitoring. 

It  should  be  noted  that  there  were  significant  increases  in  the  number  of  delineated  coastal, 

river  and  transitional  water  bodies  for  the  two  cycles.  For  example,  688  river  water  bodies 
were  delineated  for  the  first  RBMP  compared  to  873  for  the  second.  For  lakes  there  was  a 

decrease from 43 for the first to 37 for the second RBMP. Figure 3.1 shows the proportion of 
water bodies subject to surveillance and operational monitoring. 

53 

 
Figure 3.1 

Percentage  of  water  bodies  included  in  surveillance  and  operational 

monitoring in Bulgaria for the first cycle (2010) and second cycle (2016). 
Note no differentiation is made between water bodies included in ecological 

and/or chemical monitoring 

Source:  WISE electronic reports 

Similar  proportions  of  coastal  water  bodies  were  included  in  operational  and  surveillance 
monitoring for both cycles. A significant difference was that transitional water bodies were not 

operationally  monitored  for  the  first  RBMPs  but  29  %  were  for  the  second  RBMPs.  The 
comparison between the two cycles should be treated with caution as there are uncertainties in 

the data reported for Bulgaria in the first RBMPs. In particular some river and lake water body 
codes were reported as part of the WISE reporting on monitoring sites but were not included in 

the reporting of surface water bodies itself.  

Figure 3.2 shows the proportion of water bodies subject to surveillance monitoring. 

54 

 
 
Figure 3.2 

Proportion of water bodies in each ecological status/potential class that are 

included in surveillance monitoring in Bulgaria  

Operational monitoring of surface water bodies29 

Source: WISE electronic reports  

Lakes  are  only  operationally  monitored  in  the  West  Aegean  RBD  even  though  significant 
pressures  were  reported  for  lakes  in  the  other  RBDs.  The  nine  lakes  included  in  operational 

monitoring are all monitored for phytoplankton and benthic invertebrates, and four of them for 
macrophytes.  Rivers  in  the  Danube  RBD  are  not  included  in  operational  monitoring,  while 

those  in  the  other  three  RBDs  are.  The  most  used  biological  quality  element  for  rivers  is 
benthic  invertebrates  (85  %  of  river  water  bodies  in  operational  monitoring),  followed  by 

phytobenthos  (33  %),  macrophytes  (16  %)  and  fish  (9  %).  All  four  coastal  water  bodies  in 
operational  monitoring  are  monitored  for  all  of  the  relevant  biological  quality  elements. 

Transitional water bodies  in  operational  monitoring  are monitored  for  four biological  quality 
elements,  though  macrophytes  are  reported  to  be  monitored  rather  than  the  expected 
angiosperms and macroalgae30. 

In the three RBDs (the Danube RBD, the Black Sea RBD and the East  Aegean RBD) where 

lakes  are  not  operationally  monitored  and  one  RBD  (the  Danube  RBD)  where  rivers  are  not 
operationally  monitored,  there  is  a  number  of  water  bodies  reported  to  be  at  less  than  good 

29  Note that this assessment is based on monitoring purpose data reported to WISE at the monitoring site level. 
Bulgaria subsequently indicated that some of these data may not have been fully reported: the analysis should 
therefore be treated with caution 

30  Bulgaria subsequently indicated that transitional waters in the Black Sea RBD are identified in estuaries and in 
coastal  lakes  rather  than  in  marine  waters.  They  are  therefore  monitored  for  phytobenthos  rather  than  for 
macroalgae and angiosperms. 

55 

 
 
                                                      
ecological  status/potential:  it  would  be  expected  that  at  least  some  of  these  would  be 

operationally  monitored.  Furthermore,  19  significant  pressures  types  were  reported  on  river 
water bodies in the Danube RBD and a number of significant pressures on lakes in the Danube, 

Black Sea and East Aegean RBDs.  

Transboundary surface water body monitoring 

Bulgaria  reported transboundary river  and groundwater bodies in  three of the four RBDs. 12 
river monitoring sites in the Danube RBD were reported to be part of an international network 

of a river convention. 

Ecological Status/potential of surface water  

The most recently assessed ecological status/potential of surface water bodies in Bulgaria for 
the second RBMP is illustrated in Map 3.1. 

The proportion of surface water at  good or better status/potential increased from 43 % in the 
first RBMPs to 46 % in the second. In terms of less than good status/potential, the proportions 
were 57 % for the first RBMPs and 45 % for the second. However, there was a large increase 

of unknown status surface water bodies from 0.1 % in the first RBMPs to 9 % in the second: 
this may confound any comparison between the first and second cycles in terms of classified 

water bodies. 

Figure  3.3  compares  the  ecological  status  of  surface  water  bodies  in  Bulgaria  in  the  first 
RBMPs with that in the second RBMPs and that expected by 2015. 

56 

 
 
 
Map 3.1 

 Ecological status or potential of surface water bodies in Bulgaria based on the 
most recently assessed status/potential of the surface water bodies 

Note: Standard colours based on WFD Annex V, Article 1.4.2(i). 
Source: WISE, Eurostat (country borders) 

High 

Good 

Moderate 

Poor  

Bad 

Unknown 

River Basin Districts 

Countries outside the European Union 

57 

 
 
 
  
  
  
  
  
  
  
  
 
 
 
 
Figure 3.3  Ecological  status  or  potential  of  surface  water  bodies  in  Bulgaria  for  the 

second  RBMP,  for  the  first  RBMP  and  expected  in  2015.  The  number  in 
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 the first RBMP is not known 

Source: WISE electronic reports  

Member States were asked to report the expected date for the achievement of good ecological 
status/potential.  The  information  for  Bulgaria  is  shown  in  3.4.  For  coastal  and  transitional 

waters in  the Black Sea RBD, good  ecological  status/potential is  expected to  be achieved by 
2027. For rivers and lakes, there remain some uncertainties on when this objective will be met, 

with  a  proportion  with  reported  dates  as  unknown  or  beyond  2027.    For  the  several  water 
bodies with unknown ecological status/potential (especially in the East Aegean RBD), this is 

perhaps understandable but needs to be resolved.  

58 

 
  
 
 
Figure 3.4  Expected  date  of  achievement  of  good  ecological  status/potential  of  surface 

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

Source: WISE electronic reports  

Confidence in the classification of ecological status/potential 

Figure 3.5 shows the confidence in the classification of ecological status/potential. 

The  number  of  surface  water  bodies  increased  from  759  for  the  first  RBMPs  to  955  for  the 
second.  This  makes  comparison  between  the  cycles  difficult.  However,  it  is  clear  that  the 

confidence in the classification of ecological status/potential has improved significantly for the 
second  cycle.  In  particular,  no  water  body  was  classified  with  high  confidence  in  the  first 

RBMPs, while 19 % were in the second. In addition, the proportion of water bodies classified 
with low confidence decreased from 87 % to 16 %. 

59 

 
 
 
 
Figure 3.5  Confidence  in  the  classification  of  ecological  status  or  potential  of  surface 

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

Classification of ecological status at the quality element level 

Source: WISE electronic reports  

Figure   3.6 shows the percentage of  water bodies in  terms  of the biological  quality  elements 

used  for  classification.  Benthic  invertebrates  are  the  most  commonly  used  biological  quality 
element  in  the  classification  of  ecological  status  across  each  of  the  water  categories,  with 

phytoplankton also widely used. This perhaps reflects the traditional use of these elements in 
the assessment of ecological status. The coverage in terms of the proportion of surface water 

bodies  covered  by  each  biological  quality  element  is  not  complete,  especially  in  rivers  and 
lakes, suggesting that some further progress is required in the monitoring of biological quality 

elements and their use in classification. 

60 

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

classification  of  lakes  and  rivers  in  Bulgaria.  Note  that  water  bodies  with 
unknown  status/potential,  and  those  that  are  monitored  but  not  classified  or 

reported as not applicable, are not presented 

Source: WISE electronic reports  

Figure  3.7  compares  the  classification  of  biological  quality  elements  in  terms  of  ecological 
status/potential  for  the  two  cycles.  It  should  be  noted  that  this  comparison  should  be  treated 

with  caution  as  there  are  differences  in  the  numbers  of  surface  water  bodies  classified  for 
individual  elements  between  the  two  cycles.  Progress  is  demonstrated  in  each  biological 

quality element with a greater number of surface water bodies monitored in the second cycle 
than in the first. 

61 

 
 
Figure 3.7  Comparison of ecological status/potential by number of surface water bodies 

in  Bulgaria  according  to  classified  biological  quality  elements  in  surface 
water bodies between the two cycles 

Source: WISE electronic reports  

Figure  3.8  illustrates  the  basis  of  the  classification  of  ecological  status/potential  of  surface 

water  bodies  in  Bulgaria  for  the  second  RBMPs.  The  majority  of  surface  water  bodies  are 
classified  with  up  to  three  of  the  main  groups  of  quality  elements  but  none  with  all  four  of 

them.  Hydromorphological  quality  elements  are  still  not  widely  used  in  the  classification  of 
ecological status.  

62 

 
 
 
Figure 3.8 

The  classification  of  the  ecological  status  or  potential  of  rivers  and  lakes  in 

Bulgaria using one, two, three or four types of quality element 

Note: The four types are: biological; hydromorphological, general physicochemical and River Basin Specific 
Pollutants. 

Source: WISE electronic reports  

The basis of the classification of the individual quality elements is illustrated in Figure 3.9. The 

vast majority of quality elements are classified on the basis of monitoring with limited use of 
grouping (in rivers only) and expert judgement (in rivers and transitional waters). 

63 

 
 
 
Figure 3.9 

Basis  of  the  classification  of  ecological  status/potential  in  Bulgaria.  The 

percentages are in terms of the number of waterbodies in each category. 

Source: WISE electronic reports 

64 

 
 
Assessment methods for the biological quality elements 

There  is  a  lack  of  reference  conditions,  especially  for  river  hydromorphological  quality 
elements, but also for some physicochemical and biology quality elements.  

Assessment  methods  were  reported  for  all  relevant  biological  quality  elements  in  rivers. 
However there are significant gaps for the assessment methods in the other water categories: 

 

 

phytobenthos and benthic invertebrates in lakes; 

phytoplankton,  angiosperms,  macroalgae,  benthic  invertebrate  and  fish  in 

transitional waters; the only method was for macrophytes; 

 

angiosperms and macroalgae in coastal waters. 

There are biological assessment methods that are sensitive to most impacts, with the exception 

of saline pollution, which was not reported to be a significant impact on surface water bodies. 

Intercalibration of biological assessment methods  

Many national types are not linked to common intercalibration types31. 

Assessment methods for hydromorphological quality elements 

The assessment of the relevant supporting hydromorphological quality elements is in terms of 
ecological  status/potential  of  rivers,  lakes  and  coastal  waters.  For  transitional  waters,  only 
morphological  conditions  and  river  continuity  were  reported  to  be  assessed  in  terms  of 

ecological 
the 
hydromorphological  quality  elements  are  not  related  to  the  class  boundaries  for  the  sensitive 

status/potential.  However, 

classification  boundaries 

the 

for 

all 

biological  quality  elements.  In  addition,  hydromorphological  quality  elements  were  only 
reported to be monitored in rivers and coastal waters, and were only used in the classification 

of rivers in terms of hydrological regime and morphological conditions. 

31   Bulgaria subsequently stated that all national river types for the Danube ecoregion are intercalibrated, with the 
exception  of  2  river  categories    (R9  and  R15),  as  they  do  not  have  matching  types  in  the  Geographic 
Intercalibration  Group  for  very  large  rivers.  Common  types  of  transitional  water  bodies  have  not  been 
identified  at  European  level  through  the  Black  Sea  Geographic  Intercalibration  Group  as  well  as  common 
types of rivers and lakes in the catchment area of the Rivers Maritsa, Struma, Miles and Dospat (ecoregion 7). 
A  survey  on  the  conformity  of  national  surface  water  types  with  other  neighbouring  countries  types  was 
carried out between 2014 and 2016. 

65 

 
                                                      
Assessment methods for general physicochemical quality elements 

The assessment of all of the relevant supporting physicochemical quality elements was done in 
terms  of  ecological  status/potential  of  rivers,  lakes,  transitional  waters  and  coastal  waters. 

However, the classification boundaries for some of the physicochemical  quality  elements  are 
reported not to be related to the class boundaries for the sensitive biological quality elements. 

Standards  were  reported  for  all  relevant  physicochemical  quality  elements  except  thermal 
conditions  in  all  water  categories.  All  the  standards  for  coastal  and  transitional  waters  are 

consistent with the good-moderate status boundary of the relevant sensitive biological quality 
elements. 11 of the 21 standards for rivers and 11 of the 22 standards for lakes are consistent 

with the good-moderate status boundary of the relevant sensitive biological quality elements, 
while the others are not. There are some cases where different values for the standards for the 

same  element  are  defined  in  different  RBDs.  The  East  Aegean  RBD  did  not  provide  in  the 
WISE reporting water body type-specific values for the standards.32 

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

No information  was found in  the RBMPs on how River  Basin  Specific  Pollutants have been 
identified. 

Environmental  quality  standards  were  reported,  in  water  only,  for  42  different  substances 
relevant  to  both  rivers  and  lakes.  36  of  these  substances  also  had  standards  relevant  to 

transitional and coastal waters. As a comparison, 63 chemical substances that are not priority 
substances were reported to be monitored only in water; these are deemed to be equivalent to 

River Basin Specific Pollutants. There is some overlap between the substances reported to be 
monitored  as  River  Basin  Specific  Pollutants  and  those  for  which  an  Environmental  Quality 

Standard exists, but the two lists are not similar. Some substances are monitored but without an 
environmental  quality  standard,  while  some  of  the  substances  for  which  an  environmental 

quality standard is reported seem not to be monitored. 

All  standards  were  reported  to  have  been  derived  in  accordance  with  the  Common 

Implementation Strategy Technical  Guidance Document No 27. The analytical  methods used 
for  24  substances,  standard  types  and  water  category  met  the  minimum  performance  criteria 
laid down in Article 4(1) of Directive 2009/90/EC33 for the strictest standard applied, while 24 

32    Bulgaria subsequently indicated that the lack of information for the East Aegean RBD was a reporting error 
33   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  

66 

 
                                                      
did not. For those 24 that did not, the analytical method complies with the requirements laid 

down in Article 4(2) of Directive 2009/90/EC for the strictest standard applied. 

Use of monitoring results for classification 

In coastal waters, the classification of all quality elements was based on monitoring results and 
in general in all directly monitored water bodies they were subsequently used in classification. 

However,  hydromorphological  quality  elements  were  monitored  but  were  not  used  in 
classification, perhaps indicating inadequate assessment methods for these elements. 

As  for  coastal  waters,  the  classification  of  quality  elements  in  lakes  is  solely  based  on 
monitoring  results  and  often  more  water  bodies  are  directly  monitored  for  a  quality  element 

than are subsequently classified. Hydromorphological quality elements were neither monitored 
nor used in the classification. One lake in the Black Sea RBD was classified for fish based on 

monitoring results even though fish were not reported as being directly monitored in this RBD. 

The classification of the quality elements  for rivers is  based on a combination of monitoring 
results,  expert  judgment  and  grouping.  The  use  of  expert  judgment  for  fish,  benthic 

invertebrates,  phytobenthos  and macrophytes for some river water bodies may indicate some 
weaknesses  in  the  assessment  methods  for  biological  quality  elements.  Very  few  river  water 

bodies  are  classified  according  to  hydromorphological  quality  elements;  more  are  monitored 
for  these  elements,  including  river  continuity  which  was  not  used  in  the  classification  at  all. 

This indicates potentially non-compliant methods for these elements in rivers. 

The  classification  of  quality  elements  in  transitional  waters  was  only  based  on  monitoring 

results  and  for  some  elements  more  water  bodies  were  directly  monitored  than  subsequently 
classified. 

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

Figure  3.10  illustrates  the  basis  of  the  classification  of  ecological  status/potential  of  surface 

water bodies in Bulgaria for the second RBMPs. 

67 

 
Figure 3.10 

The  percentage  of  river  and  lake  water  bodies  in  Bulgaria  where  no 

biological  quality  element  or  no  hydromorphological  (HYMO)  or  no 
general  physicochemical  (PHYSCHEM)  or  no  River  Basin  Specific 

Pollutants  (River  Basin  Specific  Pollutant)  has  been  used  in  the 
classification of ecological status or potential 

Source: WISE electronic reports 

The  ‘one-out,  all-out’  principle  was  reported  as  having  been  applied  in  deriving  the  overall 

classification of the ecological status of a water body in all RBDs in Bulgaria. 

3.2.  Main changes in implementation and compliance since first cycle34 

There were no monitoring sites in transitional waters in the first RBMPs, while there were sites 
for  surveillance  and  operational  purposes  in  the  second  RBMPs.  Operational  sites  were 

reported  for  the  monitoring  of  rivers  in  the  Danube  RBD  in  the  first  RBMP  but  not  in  the 
second  RBMP.  Similarly,  there  were  operational  sites  in  lakes  in  three  RBDs  in  the  first 

RBMPs but only in one in the second. Overall in Bulgaria there was over a 10 fold decrease in 
lake surveillance sites for the second RBMPs and a smaller decrease in the number of sites for 

operational  monitoring.  In  contrast,  there  were  significant  increases  in  the  number  of  rivers 
sites  used  for  surveillance  (146  to  492  sites)  and  operational  (218  to  285  sites)  monitoring. 

There  was  also  a  doubling  of  sites  used  for  the  surveillance  and  operational  monitoring  of 
coastal waters. 

Phytobenthos  were  not  monitored  in  lakes  for  both  cycles.  All  expected  hydromorphological 
quality elements were reported to be monitored for the first RBMPs in all three reported water 

categories: for the second RBMPs they were only monitored in coastal waters, and in rivers in 

34   Note that this assessment is based on the data reported to WISE. Bulgaria has subsequently indicated that some 

of the data may not have been fully reported: the analysis should therefore be treated with caution. 

68 

 
 
 
                                                      
one  of  the  four  RBDs.  This  represents  a  significant  deterioration  in  the  level  of  monitoring 

required by the WFD compared to the first cycle. 

3.3.  Progress with Commission recommendations 

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

 

Recommendation:  Complete  the  development  of  methods  for  the  status  assessment  of 
water    bodies    and    determination    of    reference    conditions.    An    adequate    WFD-

compliant  assessment  and  monitoring  framework  is  a  necessary  pre-requisite  to  
design  effective  PoMs  and  ultimately to achieve the WFD objectives. 

Assessment: There are still significant gaps in the establishment of reference conditions 
for all water categories and quality elements in Bulgaria. In coastal waters all types have 

reference  conditions  for  some  biological  quality  elements  but  for  none  of  the 
hydromorphological  or  physicochemical  quality  elements.  31  %  and  34  %  of  lake  and 

river types,  respectively, have reference  conditions  for all types  of quality  elements.  In 
transitional waters, there are no reference conditions for any hydromorphological quality 

elements  in  any  of  the  types.  There  are  reference  conditions  for  all  biological  and 
physicochemical  quality  elements  in  one  of  the  five  types.  Biological  assessment 

methods  were  reported  for  all  relevant  biological  quality  elements  in  rivers:  however, 
there  are  significant  gaps  for  the  assessment  methods  in  the  other  water  categories  for 

example  for  phytobenthos  and  benthic  invertebrates  in  lakes.  The  assessment  of  the 
relevant  supporting  hydromorphological  and  physicochemical  quality  elements  is  in 
terms  of  ecological  status/potential  of  rivers,  lakes  and  coastal  waters.  However,  the 

classification boundaries for all the hydromorphological and for some physicochemical 
quality elements are not related to the class boundaries for the sensitive biological quality 

elements.  There  are  still  some  significant  gaps  in  the  quality  elements  monitored  in 
Bulgaria for the second RBMPs. For example, hydromorphological quality elements are 

not monitored in lakes and transitional waters. 

This recommendation has been partially fulfilled. 

 

Recommendation: Review in the second RBMP the environmental quality standards for 

the  river  basin  specific  pollutants  and  take  the  updated  standards  into  account  when 
designing measures for those pollutants. 

Assessment:  Environmental  quality  standards  were  reported,  in  water  only,  for  42 
different  substances  relevant  to  both  rivers  and  lakes.  36  of  these  substances  also  had 

69 

 
standards relevant to transitional and coastal waters. All standards were reported to have 

been  derived  in  accordance  with  the  Common  Implementation  Strategy  Technical 
Guidance  Document  No  27.  The  analytical  methods  used  for  24  substances,  standard 

types  and  water  category  met  the  minimum  performance  criteria  laid  down  in  Article 
4(1) of Directive 2009/90/EC for the strictest standard applied: 24 did not. For those 24 

that did not, the analytical method complies with the requirements laid down in Article 
4(2) of Directive 2009/90/EC for the strictest standard applied. 

The part of the recommendation relating to setting of Environmental Quality Standards 
has been fulfilled. 

 

Recommendation: Develop a proper methodology for establishing ecological flow linked 
with  good  ecological  status  in  the  second  RBMPs  and  ensure  this  e-flow  is  applied 

through review of permits. 

Assessment:  This  recommendation  is  assessed  in  the  chapter  on  hydromorphological 

measures. 

 

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.  

Assessment:  Significant  progress  has  been  made  to  fill  the  gaps  in  the  assessment 

methods in use for the first cycle; however, gaps remain in assessment methods for lakes 
and transitional waters. This recommendation has been partially fulfilled. 

 

Recommendation: There is a significant gap in the intercalibration and the development 
of  methodologies,  the  expert  judgement  approach  is  often  used.  There  is  no  fully 

developed  and  formally  adopted  classification  system  for  the  assessment  of  the 
ecological status. These gaps should be filled.  

Assessment:  Many  national  types  are  not  linked  to  common  intercalibration  types:  this 
raises questions on how the results of the intercalibration have been transferred into the 

national types and on the consequences in terms of the robustness of the classification of 
ecological status/potential. Bulgaria subsequently stated that there has been considerable 

progress in the process of intercalibration, with concrete action having been undertaken 
on transferring intercalibration results into the classification system for national types for 

which a match was established. This recommendation has been partially fulfilled. 

70 

 
 

Recommendation: The identification of River Basin Specific Pollutants needs to be more 

transparent, with clear information on how pollutants were selected, how and where they 
were  monitored,  where  there  are  exceedances  and  how  such  exceedances  have  been 

taken into account in the assessment of ecological status.  

Assessment:  No  information  was  found  in  the  RBMPs  on  how  River  Basin  Specific 

Pollutants  have  been  identified.  Detailed  site  level  information  was  reported  on  the 
monitoring  of  63  chemical  substances  that  are  not  Priority  Substances,  which  are 

assumed  to  be  River  Basin  Specific  Pollutants.    River  Basin  Specific  Pollutants  have 
been used in the classification of ecological status/potential in all four water categories. 

Nine  different  River  Basin  Specific  Pollutants  were  reported  to  be  causing  failure  of 
good  ecological  status/potential  with  some  water  bodies  in  each  water  category  being 

affected. 

This recommendation has been partially fulfilled. 

 

Recommendation: Monitoring should be strengthened as there is not enough monitoring 
data  related  to  biological  and  chemical  elements  and  this  is  also  a  reason  for  low 

confidence in the assessment of their status.  

Assessment:  Phytobenthos  are  not  monitored  in  lakes  for  both  cycles.  All  expected 

hydromorphological quality elements were reported to be monitored in the first RBMPs 
in  all  three  reported  water  categories,  but  in  the  second  RBMPs  they  were  only 

monitored  in  coastal  waters,  and  in  rivers  in  one  of  the  four  RBDs.  This  represents  a 
significant  deterioration  in  the  level  of  monitoring  required  by  the  WFD.  On  a  more 

positive note, transitional waters are now monitored, which was not the case for the first 
RBMPs,  and  there  were  increases  in  the  number  of  sites  in  rivers  and  coastal  waters. 

There also has been an increase in the number of sites used for the monitoring of River 
Basin Specific Pollutants in rivers, transitional and coastal waters for the second RBMPs. 

However,  there  was  a  decrease  in  the  sites  used  for  monitoring  River  Basin  Specific 
Pollutants  in  lakes  and  there  has  been  a  large  decrease  in  the  number  of  surveillance 
monitoring sites for lakes. 

In conclusion this recommendation has been partially fulfilled, although on some issues 

there was a deterioration of the previous situation. 

71 

 
 
Topic 4 Monitoring, assessment and classification of chemical 
status in surface water bodies 

4.1.  Assessment  of 

implementation  and 

compliance  with  WFD 

requirements in second cycle  

4.1.1. 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 Bulgaria for the second RBMP. 

Figure  4.1  summarises  the  proportion  of  sites  used  for  the  monitoring  of  chemical  status  in 

surface waters for the second RBMP. 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 Agency35.  

According  to  the  WFD,  chemical  status  should  be  monitored  and  assessed  up  to  12  nautical 

miles, however territorial waters have not been identified, monitored or assessed by Bulgaria. 

In  all  water  categories  considered  by  Bulgaria,  fewer  sites  are  monitored  for  chemical  status 

than for ecological status with the disparity greatest in surface fresh waters (rivers and lakes). 
Overall  in  Bulgaria  in  the  second  RBMP,  there  has  been  a  net  increase  in  the  number  of 

monitoring sites and water bodies since the first RBMP.  

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

72 

 
                                                      
Figure 4.1 

Proportion  of  sites  used  for  monitoring  of  chemical  status  and,  for 

comparison, ecological status, in Bulgaria. The number in parenthesis next to 
the  category  is  the  total  number  of  monitoring  sites  irrespective  of  their 

purpose  

Source: WISE electronic reporting  

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

waters  for  the  second  RBMP.  In  this  figure,  no  distinction  is  made  between  sites  used  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. 

73 

 
 
 
 
Figure 4.2 

Proportion  of  total  water  bodies  in  each  category  monitored,  monitored  for 

chemical  status  and,  for  comparison,  monitored  for  ecological  status,  in 
Bulgaria. The number in parenthesis next to the category is the total number 

of water bodies in that category 

Source: WISE electronic reporting 

Between 70 and 94 % of surface water bodies in  the relevant  categories  were  reported to  be 

monitored in the second RBMP. A larger proportion (between 59 to 86 %) was included in the 
monitoring of ecological status than for chemical status (14 to 65 %). 

Of the surface water bodies failing to achieve good chemical status, 92 % were reported to be 
monitored under operational monitoring in Bulgaria as a whole.  

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

(version 

force 

in 

standard.  

74 

 
 
Spatial coverage 

Monitoring of priority substances is reported in water only.  

About 18 % of sites and less than a third of water bodies are monitored, with generally lower 

proportions of sites and water bodies monitored in lakes and rivers compared to coastal waters.  

Bulgaria  has  subsequently  provided  further  information  stating  that  research  was  carried  out 

for  the  Black  Sea  RBD  in  2014  on  mercury,  hexachlorobenzene  and  hexachlorobutadiene 
concentrations  in  biota  in  transitional  and  river  water  bodies.  The  results  indicated  that  only 

mercury exceeded the biota EQS. Water bodies, for which values were found to be above the 
EQS for mercury in biota were assessed as failing to achieve good chemical status. Data from 

pilot sampling and analysis of mercury in biota carried out as part of an applied research study 
entitled  “Research  and  assessment  of  the  chemical  status  of  surface  waters”  confirmed  the 

reported degraded chemical status. 

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. 

According  to  the  WISE  reporting,  about  one  third  of  the  substances  monitored  are  sampled 

with an intra-annual frequency of 12 times per year at all sites where they are monitored. Other 
substances are monitored at or above the minimum intra-annual frequency at some sites, and 

below  that  frequency  at  other  sites.  The  RBMPs  and  background  documents  provided  no 
specific justification for the reduced monitoring frequency. 

75 

 
 
 
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  substances36  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 

Bulgaria  has  not  reported  results  from  the  monitoring  of  sediments  and  biota  in  the  second 
RBMPs.  Bulgaria  also  reports  that  arrangements  are  not  in  place  for  the  long-term  trend 

analysis  of  concentrations  of  those  Priority  Substances  that  tend  to  accumulate  in  sediment 
and/or  biota  in  three  RBDs  in  Bulgaria  (Danube,  East  Aegean  and  West  Aegean).  No 

information was reported for the Black Sea RBD.  

The RBMPs and background documents provided some evidence of preparatory work in terms 

of  the  development  of  a  method  for  trend  assessment  of  the  concentrations  of  pollutants  in 
sediment and biota and some pilot monitoring and testing. The second RBMPs indicated that 
monitoring would commence in the second cycle. 

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

quantities.” 

36  Anthracene,  brominated  diphenylether, 

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

chloroalkanes,  DEHP, 

cadmium,  C10-13 

76 

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

into the river basin or sub-basin.  

Section 2.1.1 of this report describes the implementation of the requirement for establishing an 

inventory  of  emissions  in  Bulgaria.  The  information  reported  to  WISE  confirms  that  all 
Priority  Substances  listed  in  inventories  and  discharged  (between  four  and  six  Priority 

Substances depending on the RBD) are monitored in all four RBDs in Bulgaria.  

The four RBDs monitored many more substances than just those identified as discharged in the 

inventories.    According  to  WISE,  in  the  Danube  RBD  overall  38  individual  Priority 
Substances37 were monitored. In the Black Sea RBD, East Aegean and West Aegean RBDs this 
was the case for 30, 34 and 35 individual substances, respectively.  

The RBMPs and background documents explain that all 41 Priority Substances and groups of 

Priority  substances  should  be  monitored  (where  methods  exist)  to  meet  the  requirements  of 
national  legislation38.  According  to  the  RBMPs,  the  analytical  methods  have  not  been 
developed yet for the following substances: brominated diphenylether, C10-13 chloralkanes, di 
(tributyltin-cation),  diuron, 
(2-ethylhexyl)  phthalate 
isoproturon.  The  East  Aegean  RBMP  mentions  a  project  that  is  expected  to  provide  such 
methodologies by 201839. These substances are also not included in the inventories, so there is 
no assessment of whether they were discharged. 

tributyltin  compounds 

(DEHP), 

Performances of analytical methods used  

In  Bulgaria, the performances  of the analytical  methods used differ between RBDs. For nine 

Priority Substances, the analytical methods used meet the minimum performance criteria laid 
down in Article 4(1) of Directive 2009/90/EC40 for the strictest standard applied in all RBDs.  

For  six  Priority  Substances  in  the  Black  Sea,  East  Aegean  and  West  Aegean  RBDs,  the 
analytical methods appear not to comply with the requirements in Article 4(1) or 4(2). These 

substances  are  DEHP,  diuron,  isoproturon,  TBT,  chloroalkanes  C10-13  and  brominated 

37  The 41 Priority Substances and groups of Priority Substances are made of 46 « individual » substances. 
38  Ordinance  on  environmental  quality  standards  for  Priority  Substances  and  some  other  pollutants  from  1 

November 2010, last updated 11 December 2015 

39  Bulgaria  subsequently  clarified  that  in  the  WISE  reporting,  some  of  these  six  substances  were  incorrectly 
reported  as  monitored  in  the  Danube  RBDs,  and  confirmed  that  these  substances  are  neither  monitored  nor 
used in the assessment of status. Bulgaria also mentioned that a limited number of substances were  wrongly 
reported as not monitored (e.g. polycyclic aromatic hydrocarbons in the West Aegean RBD). 

40   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  

77 

 
                                                      
diphenylethers.  The  RBMPs  and  background  documents  clarify  that  there  are  currently  no 

common methods for laboratory analysis for these 6 substances. Bulgaria confirmed that this is 
the case also in the Danube RBD.    

The  method  for  dealing  with  measurements  of  Priority  Substances  lower  than  the  limit  of 
quantification is as specified in Article 5 of Directive 2009/90/EC for three RBDs in Bulgaria 

but not for one RBD (East Aegean). . 

4.1.2.  Chemical Status of surface water bodies 

Member States  are  required to  report the  year on which the  assessment of chemical  status  is 
based. This  may be the  year that 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  Bulgaria,  the  assessment  of  chemical  status  was  undertaken  between  2010  and 
2014.  The  chemical  status  of  surface  water  bodies  in  Bulgaria  for  the  second  RBMP  is 

illustrated in Map 4.1. This is based on the most recent assessment of status. 

78 

 
 
 
Map 4.1 

 Chemical  status  of  surface  water  bodies  in  Bulgaria  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) 

The chemical status of lakes and rivers in Bulgaria for the first and second RBMPs is given in 
Table 4.1. 

Overall between the two cycles, there has been a large decrease in  the proportion with  good 
status and a large increase in the proportion with unknown status across all categories between 

two RBMPs, despite the increase in the number of monitoring sites. (This holds true also for 
Natural/Heavily Modified/Artificial water body categories).  This seems to reflect a change in 

the methodology used to classify non monitored waterbodies. 

79 

GoodFailing to achieve to goodUnknownRiver Basin DistrictsCountries outside the EU 
 
 
 
 
 
Table 4.1 

Chemical status of surface water bodies in Bulgaria 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 

Category 

second RBMP 

Lakes (37) 

Rivers (873) 

Transitional (28) 

Coastal (17) 

Total (955) 

first RBMP 

Lakes (43) 

Rivers (688) 

Transitional (15) 

Coastal (13) 

Total (759) 

Good 

Failing to achieve 
good 

Unknown 

Number 

% 

Number 

% 

Number 

% 

10 

309 

3 

322 

40 

545 

11 

596 

27% 

35% 

18% 

34% 

93% 

79 % 

73% 

20 

2 

3 

25 

2% 

7% 

18% 

3% 

23 

3% 

79% 

23 

3% 

27 

544 

26 

11 

608 

3 

120 

4 

13 

140 

73% 

62% 

93% 

65% 

64% 

7% 

17% 

27% 

100% 

18% 

More information on the chemical status in each RBD and water category can be found on the 
website of the European Environment Agency41. 

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

for  each  status  class.  Overall,  44  %  of  surface  water  bodies  in  Bulgaria  were  classified  for 
chemical  status  with  medium  confidence,  33  %  with  low  confidence  and  23  %  with  high 

confidence. Bulgaria applies the methodology developed for the international Danube RBD as 
a  common  national  methodology  for  determining  the  confidence  level  of  status  assessments 

using the following criteria: 

 

High:  Either  there  is  no  pollution  from  Priority  Substances/no  discharges  of 

Priority Substances, or all of the following criteria are met: 

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

80 

 
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
o 

the monitoring data meets the frequency requirements of the WFD (12 samples 

per year); 

o 

there is high credibility in the grouping process in terms of meeting  the criteria 

for grouping of the water bodies and they meet the requirements of the WFD. 

  Medium: all of the following criteria are met: 

o 

there is monitoring data; 

o 

the frequency does not  meet  the requirements of the WFD (less  than 12 times 

per year); 

o  medium credibility concerning the criteria for grouping of the water bodies. 

 

Low: one or more of the following criteria are met: 

o 

there is no data; 

o  expectation  that  good  status  cannot  be  achieved  as  a  result  of  the  emissions 

(analysis of the risk).  

In the RBMPs, Bulgaria highlights that the approach to the assessment of confidence benefits 
from the implementation of clear criteria in the international RBD of the Danube. 

81 

 
Figure 4.3 

Confidence in the classification of chemical status of surface water bodies in 

Bulgaria based on the most recently assessed status/potential 

Source: WISE electronic reporting 

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

with  that  for  the  second  RBMP  (based  on  the  most  recent  assessment  of  status)  and  that 
expected by 2015.  

The  assessment  of  chemical  status  for  the  second  RBMP  was  expected  to  be  based  on  the 
standards  laid  down  in  EQS  Directive  2008/105/EC  (version  in  force  on  13 January  200942). 
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. 

There was a large decrease in the proportion of surface water bodies classified as good for the 
second RBMP compared to the first which is consistent with that expected by the end of 2015 

but with a much larger proportion with unknown status. This may result at least partly from the 
implementation of the new guidance documents adopted at national level (see section on Main 

changes in implementation and compliance since first cycle.) 

42   Directive  2013/39/EU,  which  amended  the  Environmental  Quality  Standards  Directive,  introduced  a  less 
stringent  annual  average  Environmental  Quality  Standards  for  naphthalene  in  transitional  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.  

82 

 
 
 
 
                                                      
Figure 4.4 

Chemical  status  of  surface  water  bodies  in  Bulgaria  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 

The RBMPs explain that the approach to the assessment of chemical status is derived from a 
'National methodology for assessment of the chemical status of surface water bodies’ and the 

Ordinance  on  environmental  quality  standards  for  Priority  Substances  and  some  other 
pollutants from 1 November 201043. According to the Ordinance all Priority Substances should 
be monitored. The national methodology outlines the steps for analysing the concentrations of 
Priority Substances, comparing these to  the Environmental Quality Standards and classifying 

the status of the water body based on the results.  

The one-out-all-out principle is not explicitly mentioned in the RBMPs, but it is corresponds to 
the methodology described in the plans.  

The  Black  Sea  and  East  Aegean  RBMPs  state  that  water  bodies  for  which  there  is  no 

monitoring data are classified with unknown chemical status. The East Aegean RBMP further 
states  that  water  bodies  for  which  not  all  Priority  Substances  planned  in  the  monitoring 

programmes  are  monitored  are  also  classified  with  unknown  chemical  status.  Bulgaria 

43  Last updated 11 December 2015. This ordinance transposes the latest Environmental Quality Standards into the 

national legislation. 

83 

 
 
 
                                                      
subsequently clarified that in the Danube RBD, grouping has been used for the assessment of 

good status water bodies only. Grouping is also used in the West Aegean RBD.  

Directive  2013/39/EU44  adopted  more  stringent  Environmental  Quality  Standards  for  seven 
substances45. Member States were required to indicate if the new standard caused the status of 
the  surface  water  body  to  appear  to  deteriorate,  however  Bulgaria  didn’t  apply  these  more 

stringent standards. 

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)  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 Bulgaria is shown in Figure 4.5. However, the numbers reported do 

not sum to the total number of water bodies expected for each category. The values for rivers 
appear to be cumulative, and it is unclear why the values for transitional and coastal waters do 

not match the expected number of water bodies.  

The  date  of  achievement  of  good  chemical  status  is  unknown  for  a  significant  proportion  of 
surface water bodies. Most of the remaining water bodies are expected to reach good chemical 

status by 2027.  

The first RBMPs for the Black Sea RBD and the West Aegean RBD provided no data on the 

expected achievement of good status, so no comparison is possible. For the East Aegean RBD 
the  first  RBMP  anticipated  that  the  objectives  would  be  fully  met  in  2027,  whereas  in  the 

second RBMP only about 20 % of river water bodies are expected to be in good status at that 
time  (the  date  of  achievement  of  good  status  for  other  water  bodies  is  unknown).  This  is 

probably  at  least  partly  linked  to  the  increase  in  the  proportion  of  water  bodies  in  unknown 
status in the second RBMP. 

44   Directive 2013/39/EU of the European Parliament and of the Council of 12 August 2013 amending Directives 
2000/60/EC  and  2008/105/EC  as  regards  priority  substances  in  the  field  of  water  policy  http://eur-
lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32013L0039  

45  Anthracene,  Brominated  diphenylether,  Fluoranthene,  Lead  and  its  compounds,  Naphthalene,  Nickel  and 

itscompounds, Polyaromatic hydrocarbons (PAH) 

84 

 
                                                      
Figure 4.5 

Expected  date  of  achievement  of  good  chemical  of  surface  water  bodies  in 

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

Priority substances causing the failure of good chemical status 

Source: WISE electronic reporting 

Bulgaria reported exceedances based on the standards from the Directive in its version in force 

in 2009 (the same as those used for the assessment of status presented above). 

Seven Priority Substances were reported to be causing failure to achieve good chemical status 

in surface water bodies in Bulgaria. The proportion of water bodies failing because of each of 
these substances are shown in Figure 4.6.  

The  substances  causing  the  greatest  proportion  of  water  bodies  to  fail  good  chemical  status 
were cadmium (1.3 %), mercury (1 %) and nickel (0.6 %). Information on Priority Substances 
causing  failure  of  good  chemical  status  for  the  first  RBMP  was  not  systematically  reported 
making  comparison  with  the  second  RBMP  difficult.  However,  examination  of  the  first 

RBMPs  showed  that  lead,  nickel,  cadmium  and  mercury  were  causing  the  greatest  failure  in 
Bulgaria (1-3 % of failing surface water bodies in the Danube and East Aegean RBDs only). 

85 

 
 
 
Figure 4.6 

The top  Priority Substances causing failure to  achieve good chemical status 

in surface water bodies in Bulgaria 

Source: WISE electronic reporting 

In terms of the most commonly exceeded Environmental Quality Standards, overall for surface 

water bodies in Bulgaria, the largest proportion of exceedances were for the Annual Average 
Environmental  Quality  Standards  for  cadmium  (1  %  of  water  bodies).  Exceedances  of 

Maximum Allowable Concentration Environmental Quality Standards were most frequent for 
Trichloromethane (0.1 % of water bodies). In terms of exceedance of both types of standard, 

the largest proportion was for mercury (0.8 % of water bodies). 

Overall  in  Bulgaria,  two  Priority  Substances  are  reported  have  been  responsible  for 

improvements  in  chemical  status  from  failing  to  achieve  good  chemical  status  to  good 
chemical status since the first RBMP. These improvements occurred in the East Aegean RBD 

and were for lead (20 river water bodies representing 6 % of the total) and for nickel (seven 
river  water  bodies  representing  2  %  of  the  total).  These  improvements  concur  with  the 

improvements from the first plans described above for lead and nickel (which were reported in 
the first RBMPs to be having a greater impact on chemical status). 

86 

 
 
Ubiquitous persistent, bioaccumulative and toxic Priority Substances 

According  to  article  8(a)  of  the  EQS  Directive46,  eight  priority  substances  and  groups  of 
priority  substances  are  behaving  like  ubiquitous,  persistent,  bioaccumulable  and  toxic 
substances47.  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.  

In the Black Sea RBD   a ubiquitous persistent, bioaccumulative and toxic Priority Substance 

(in this case, mercury) is primarily responsible for causing failure to achieve good status across 
all water body types.  In the Danube and West Aegean RBDs, uPBTs are assess as having little 

or no influence but there were a number of water bodies that failed to achieve good chemical 
status. This may be due in particular to the absence of monitoring of mercury in biota. Further 

information on ubiquitous, persistent, bioaccumulative and toxic substances is available in the 
2018 State of Water report of the European Environment Agency48. 

Priority Substances used in the assessment of chemical status compared to those monitored 

Not  all  substances  are  taken  into  account  in  the  assessment  of  status.  The  following  six 
substances are not taken into account in any of the RBDs: di(2-ethylhexyl)phthalate (DEHP), 

diuron,  isoproturon,  tributyltin-cation,  chloroalkanes  C10-13  and  brominated  diphenylethers. 
Eight additional substances and groups of priority substances are not taken into account in the 

East Aegean RBD, according to WISE. 

According to WISE, some (groups of) Priority Substances used in the assessment of status are 
not  monitored  (this  was  the  case  for  two  cyclodiene  pesticides  in  the  Danube,  13  individual 

priority substances in the Black Sea, and 11 in the West Aegean RBD).  

46 Amended by Directive 2013/39/EU 
47  Brominated  diphenylether,  Mercury  and  its  compounds,  Polyaromatic  hydrocarbons  (PAH),  Tributyltin,  

PFOS,dioxins, hexabromocyclodecane and heptachlor 

48 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/SWB_F
ailing_Good_Chemical_Status_RBD?iframeSizedToWindow=true&:embed=y&:showAppBanner=false&:display
_count=no&:showVizHome=no 

87 

 
                                                      
Bulgaria  however  subsequently  clarified  that  these  are  reporting  mistakes:  substances  not 
monitored  are  not  taken  into  account  in  the  assessment  of  status49  (also  see  section  entitled 
“Monitoring of Priority Substances that are discharged in each RBD”). 

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. 

The  Danube  RBD  reported  that  alternative  and/or  additional  standards  for  particular  Priority 
Substances  had  been  applied  for  many  different  substances  in  different  RBDs.  Bulgaria 

however  subsequently  clarified  that  this  is  a  reporting  mistake  and  that  no  alternative  EQS 
have been used in the assessment of chemical status.   

 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. 

Mixing zones have not been designated under Article 4 of the EQS Directive in Bulgaria. 

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; 

49   Bulgaria also clarified that some of the substances reported in WISE as not monitored were actually monitored, 
for example benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(g,h,i)perylene, indeno(1,2,3-cd)pyrene in the 
West Aegean. 

88 

 
                                                      
(b) hardness, pH or other water quality parameters that affect the bioavailability of metals. 

Natural  background  concentrations  for  metals  and 
into 
consideration where such concentrations prevent compliance with the relevant Environmental 

their  compounds  are 

taken 

Quality Standards in three RBDs of Bulgaria but not in one RBD (East Aegean).  

Water  quality  parameters  that  affect  the  bioavailability  of  metals  have  not  been  taken  into 

account in Bulgaria when assessing monitoring results against relevant Environmental Quality 
Standards. 

4.2.  Main changes in implementation and compliance since first cycle 

For the first RBMP, no national methodology for the monitoring and assessment of chemical 
status had been adopted. The second RBMPs report progress with the development of a range 

of common national methodologies and guidance documents, namely: 

 

'National methodology for assessment of the chemical status of surface water bodies'; 

 

'Method for determining background concentrations of chemical elements'; 

 

'Method  for  using  the  determined  background  concentrations  when  assessing  the 
ecological and chemical status of surface water bodies'; 

 

'Method  for  trends  assessment  of  the  concentrations  of  pollutants  in  sediment  and 

biota'; 

 

'Method for using results, which are under the limits for quantitative determination of 

the  analysis  method  and  not  meeting  the  requirements  of  EQS  Directive  2009/90/EC 
(Article  84  of  Ordinance  1  from  11  April  2011  on  the  monitoring  of  waters)'  -  when 

using monitoring data that does not meet the requirements of the WFD; 

 

'Methodology for determining the confidence level of the assessment of ecological and 

chemical status'. 

The application of these methodologies has improved coherence between RBDs in the second 

RBMPs.  Though  some  issues  remain;  notably  the  very  large  proportion  of  water  bodies  in 
unknown status. 

89 

 
Overall  in  Bulgaria  in  the  second  RBMP,  there  has  been  a  net  increase  in  the  number  of 

monitoring sites and water bodies monitored for chemical status in all water categories since 
the first RBMP. 

Small  percentages  of  surface  water  bodies  have  been  monitored  for  10  or  more  Priority 
Substances in water with no reported monitoring in sediment or biota. Comparable information 

from  the  first  RBMP  is  not  readily  available.  However,  no  progress  has  been  made  with  the 
development  of  analytical  methods  for  six  Priority  Substances  that  were  reported  as  not 

available in the first cycle and have yet to be developed and implemented in the second cycle. 

Overall  between  the  two  RBMPs  there  was  a  large  decrease  in  proportion  of  surface  water 

bodies with good chemical status but little change in the proportion that fail to achieve good 
status.  The  proportion  with  unknown  status  has  increased.  The  decrease  in  the  proportion  of 

water bodies with good chemical status and the increase of those with unknown status occurred 
across  all  RBDs.  In  terms  of  Natural/Heavily  Modified/Artificial  water  body  categorisation; 

there  was  a  large  decrease  in  the  proportion  with  good  status  and  a  large  increase  in  the 
proportion with unknown status across all categories. The reported changes in status have been 
attributed  to  improvements  in  the  extent  of  monitoring  and  to  changes  in  the  national 

methodologies. 

The  main  substances  causing  failures  were  cadmium,  mercury  and  nickel  in  both  RBMPs. 

Some improvements have been reported from the first to the second RBMP,  for lead and for 
nickel in the East Aegean RBD.  

Good chemical status of surface water bodies is not expected to be fully achieved by the end of 
the third planning cycle in Bulgaria or it is unknown when it will be achieved (see details in 

section  above).    The  timetable  for  reaching  the  chemical  status  objectives  appears  to  have 
deteriorated in the East Aegean RBD. 

4.3.  Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMPs  and  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. 

90 

 
Assessment:  This  recommendation  is  relevant  to  several  topics.  In  terms  of  the 

assessment  of  status,  Bulgaria  acknowledges  that  for  the  first  RBMP,  no  national 
methodology  for  the  monitoring  and  assessment  of  chemical  status  had  been  adopted. 

The  second  RBMPs  report  significant  progress  with  the  development  of  a  range  of 
common national methodologies and guidance documents and these are listed in Section 

4.2  above.  However,  there  has  been  an  increase  in  the  proportion  of  waterbodies  in 
unknown status, despite the increase in the number of sites and waterbodies monitored. 

A significant proportion of waterbodies in good chemical status are also classified with a 
low confidence, and not all substances are used in the assessment of status. Progress has 

therefore  been  made  in  terms  of  developing  methodologies  but  the  part  of  the  above 
recommendation related to the assessment of status has not been fulfilled yet. 

 

Recommendation:  Complete  the  development  of  methods  for  the  status  assessment  of 

water  bodies  and  determination  of  reference  conditions.  An  adequate  WFD-compliant 
assessment  and  monitoring  framework  is  a  necessary  pre-requisite  to  design  effective 

PoMs and ultimately to achieve the WFD objectives. 

Assessment:  With  regard  to  the  development  of  methods,  as  stated  under  the 
recommendation  above,  the  second  RBMPs  report  significant  progress  with  the 

development of a range of common national methodologies and guidance documents and 
these  are  listed  in  section  4.2  above.  In  terms  of  the  monitoring  programme,  the 

proportions  of  monitoring  sites  and  water  bodies  monitored  for  chemical  status  for 
surface  fresh  waters  in  particular  are  limited  to  about  one  sixth  of  sites,  and  about  a 

quarter  of  water  bodies,  although  the  number  of  sites  and  waterbodies  monitored  have 
increased  between  the  two  RBMPs,  which  represents  a  progress  compared  to  the  first 

RBMP. Monitoring frequencies are not always in line with the recommended minimum 
frequency, and no explanation could be found for the reduced frequencies. Progress has 

been made on this recommendation, but it is only partially fulfilled. 

 

Recommendation:  Mercury,  hexachlorobenzene  and  hexachlorobutadiene  should  be 
monitored in biota for comparison with the biota standards in the EQS Directive, unless 

water Environmental Quality Standards providing an equivalent level of  protection are 
derived.  Biota  Environmental  Quality  Standards  should  also  be  considered  for  other 

substances  where  analysis  in  water  is  problematic.  Trend  monitoring  in  sediment  or 
biota is specified for several Priority Substances in Directive 2008/105/EC Article 3(3) 

and will need to be reflected in the next RBMP 

91 

 
Assessment: According to WISE, mercury, hexachlorobenzene and hexachlorobutadiene 

are  not  monitored  in  biota  for  status  assessment.  Monitoring  for  these  substances  is 
undertaken in water but no evidence could be found in the RBMPs assessed to indicate 

that an equivalent level of protection to the biota standard is provided. Bulgaria reported 
to  WISE  that  no  results  from  monitoring  of  sediment  or  biota  were  available  for  the 

second  RBMPs.  Bulgaria  has  provided  further  information  stating  that  research  was 
carried  out  for  the  Black  Sea  RBD  in  2014  on  mercury,  hexachlorobenzene  and 

hexachlorobutadiene  concentrations  in  biota  in  transitional  and  river  water  bodies.  The 
results  indicated  that  only  mercury  exceeded  the  biota  EQS.  Water  bodies  for  which 

values were found to be above the EQS for mercury in biota were assessed as failing to 
achieve good chemical status. 

Bulgaria  has  not  reported  trend  monitoring  in  sediment  or  biota.  The  RBMPs  and 
background  documents  provided  some  evidence  of  preparatory  work  in  terms  of  the 

development  of  a  method  for  trend  assessment  of  the  concentrations  of  pollutants  in 
sediment and biota and some pilot monitoring and testing. The second RBMPs indicated 

that monitoring would be implemented in the second cycle.  

This recommendation has therefore been partially fulfilled. 

 

Recommendation: Monitoring should be strengthened as there is not enough monitoring 

data  related  to  biological  and  chemical  elements  and  this  is  also  a  reason  for  low 

confidence in the assessment of their status.  

Assessment: Bulgaria has reported a net increase in the number of monitoring sites and 

water bodies monitored for chemical status in all water categories since the first RBMP. 
Small percentages of surface water bodies have been monitored for 10 or more Priority 

Substances  in  water  with  no  reported  monitoring  in  sediment  or  biota  in  the  second 
RBMP. Bulgaria subsequently clarified that some monitoring in biota took place in the 

Black Sea for status assessment.  

Comparable  information  from  the  first  RBMP  is  not  readily  available.  However,  no 

progress  has  been  made  with  the  development  of  analytical  methods  for  six  Priority 
Substances  that  were  reported  as  not  available  in  the  first  RBMP  and  have  yet  to  be 

developed and implemented. Overall between the two RBMP, there was a large increase 
in the proportion of water bodies in unknown status, and this occurred across all RBDs 

which indicates that the monitoring performed is still not sufficient to provide an overall 

92 

 
assessment of the status of all water bodies (in combination with  grouping if relevant), 

despite  the  above  mentioned  increase  in  the  number  of  monitoring  sites.  Overall  and 
regardless  of  status  class,  44  %  of  surface  water  bodies  in  Bulgaria  were  classified  for 

chemical status with medium confidence, 33 % with low confidence and 23 % with high 
confidence. Whilst there has been progress with some aspects of this recommendation, it 

is partially fulfilled.  

93 

 
 
 
Topic  5  Monitoring,  assessment  and  classification  of  quantitative 
status of groundwater bodies 

5.1.  Assessment of implementation and compliance with WFD requirements 

in second cycle 

5.1.1. Monitoring of quantitative status in groundwater 

The total number of groundwater bodies in Bulgaria is 169 (Table 2.3). 49 groundwater bodies 

are not subject to monitoring for quantitative status (Table 5.1 and Table 5.2). This means that 
29 % of groundwater bodies are not monitored. The information available in the RBMPs does 

not  indicate  that  grouping  of  groundwater  bodies  was  applied  for  monitoring  or  assessment 
purposes. 

The number of groundwater bodies decreased from 177 in the first RBMP to 169 in the second 
RBMP but the total groundwater body area increased slightly. 88 groundwater bodies remained 

unchanged  since  the  first  RBMP.  The  number  of  monitored  groundwater  bodies  decreased 
from 135 in the first RBMP to 120 in the second RBMP. The number of monitoring sites for 
quantitative status is listed in Table 5.3 and shows a decrease from 366 in the first RBMP to 

323 in the second RBMP. 

156  of  the  169  groundwater  bodies,  located  in  all  RBDs,  are  identified  as  Drinking  Water 

Protected Areas. 

Table 5.1 

Proportion of groundwater bodies in Bulgaria monitored for quantitative 
status 

RBD 

BG1000 

BG2000 

BG3000 

BG4000 

No of groundwater bodies with 
quantitative monitoring 

Total No. 
groundwater 
bodies 

% of total groundwater bodies 
monitored for quantitative status 

42 

35 

16 

27 

50 

40 

41 

38 

Source: WISE electronic reports  

84.0% 

87.5% 

39.0% 

71.0% 

94 

 
 
Table 5.2 

Number of water bodies in Bulgaria directly monitored and the purpose of monitoring 

Monitoring Purpose 

RBD 

Total 
groundwater 
bodies 
directly 
monitored 

AGR – 
Ground-
water 
abstraction 
site for 
irrigation 

CHE – 
Chemical 
status 

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

IND – 
Ground-
water 
abstraction 
site for 
industrial 
supply 

NID - 
Nutrient 
sensitive area 
under the 
Nitrates 
Directive - 
WFD Annex 
IV.1.iv 

OPE – 
Operational 
monitoring 

QUA – 
Quantitative 
status 

SOE - 
EIONET 
State of 
Environment 
monitoring 

SUR – 
Surveillance 
monitoring 

TRE – 
Chemical 
trend 
assessment 

BG1000 

BG2000 

BG3000 

BG4000 

50 

37 

36 

30 

0 

0 

3 

0 

0 

37 

35 

23 

49 

32 

30 

15 

0 

6 

15 

12 

20 

36 

33 

23 

21 

10 

16 

0 

42 

35 

16 

27 

35 

13 

19 

0 

34 

36 

32 

23 

50 

13 

9 

0 

Table 5.3 

Number of groundwater monitoring sites in Bulgaria and their purpose  

Source: WISE electronic reports  

Monitoring Purpose 

RBD 

Total 
groundwater 
monitoring 
sites 

AGR – 
Ground-
water 
abstraction 
site for 
irrigation 

CHE – 
Chemical 
status 

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

BG1000 

BG2000 

BG3000 

BG4000 

305 

184 

179 

58 

3 

128 

113 

32 

83 

97 

79 

17 

IND – 
Ground-
water 
abstraction 
site for 
industrial 
supply 

NID - 
Nutrient 
sensitive area 
under the 
Nitrates 
Directive - 
WFD Annex 
IV.1.iv 

10 

21 

15 

52 

109 

120 

28 

OPE – 
Operational 
monitoring 

QUA – 
Quantitative 
status 

SOE - 
EIONET 
State of 
Environment 
monitoring 

SUR – 
Surveillance 
monitoring 

TRE – 
Chemical 
trend 
assessment 

40 

36 

45 

171 

78 

43 

31 

42 

31 

39 

57 

81 

68 

32 

96 

21 

18 

Source: WISE electronic reports 

95 

 
 
 
 
 
 
 
 
 
 
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 161 of 169 groundwater bodies (95 %) were in good quantitative status and eight (5 

%) are failing good status (Figure 5.1). In terms of area this means that about 1.4 % is failing 
good quantitative status. About 23 % of the groundwater bodies are at risk. Figure 5.2 shows 

the  confidence  in  status  classifications.  All  groundwater  bodies  had  and  still  have  a  known 
status, in the first and in the second RBMPs.  

For  all  four  RBDs,  water  balance  was  assessed  by  a  comparison  of  annual  average 
groundwater  abstraction  against  the  ‘available  groundwater  resource’  for  every  groundwater 

body. 

The  reasons  for  the  failure  of  good  quantitative  status  of  groundwater  bodies  are  shown  in 

Figure  5.3.  Four  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,  two  groundwater  bodies  are  failing  due  to 
damage  to  groundwater  dependent  terrestrial  ecosystems  and  two  groundwater  bodies  are 
failing due to saline intrusions. The expected date of achievement of good quantitative status in 

Bulgaria is shown in Figure 5.4. 

In  all  RBDs,  the  criterion  of  ‘available  groundwater  resource’  has  been  fully  applied  in 

accordance  with  WFD  Article  2(27).  Only  in  the  West  Aegean  RBD  have  all  environmental 
objectives been considered in status assessment. 

In total 39 groundwater bodies are at risk of failing good quantitative status by failing the water 
balance test. 

96 

 
Map 5.1 

Map of the most recently assessed quantitative status of groundwater bodies  

Note: Standard colours based on WFD Annex V, Article 2.2.4.  

Source: WISE, Eurostat (country borders) 

97 

GoodPoorUnknownRiver Basin DistrictsCountries outside the EU 
 
 
 
 
Figure 5.1  Quantitative  status  of  groundwater  bodies  in  Bulgaria  for  the  second  cycle 

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 2010 to 2014. The year of the 
assessment of status for the first RBMP is not known. 

Source: WISE electronic reports  

Figure 5.2 

Confidence in the classification of quantitative status of groundwater bodies 

in Bulgaria based on the most recent assessment of status  

Source: WISE electronic reports  

98 

 
 
 
Figure 5.3  Reasons for the failure of good quantitative status of groundwater in Bulgaria 

based on the most recent assessment of status 

Source: WISE electronic reports  

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. 

99 

 
 
 
Figure 5.4  Expected date of achievement of good quantitative and good chemical status 

of  groundwater  bodies  in  Bulgaria.  169  groundwater  bodies  delineated  for 
second RBMP 

Source: WISE electronic reports  

5.1.3.  Consideration  of  groundwater  associated  surface  waters  and/or  groundwater 

dependent ecosystems 

Groundwater associated surface waters have been reported in all RBDs. They are not related to 

risk and they have only been considered in status assessment in the West Aegean RBD.  

Groundwater  bodies  linked  with  groundwater  dependent  terrestrial  ecosystems  exist  in  all 

RBDs except the Black Sea RBD. They are not related to risk and they have been considered in 
status assessment in the East Aegean and West Aegean RBDs. 

5.2  Main changes in implementation and compliance since first cycle 

88 of 169 groundwater bodies remained unchanged since the first RBMP. 

The monitoring situation shows overall drawbacks although the situation improved in certain 

RBDs: The number of groundwater bodies decreased from 177 in the first RBMP to 169 in the 
second  RBMP  but  the  total  groundwater  body  area  increased  slightly.  The  number  of 

monitored  groundwater  bodies  decreased  from  123  in  the  first  RBMP  to  120  in  the  second 
RBMP.  

The status changes show mixed results, with some improvement and some deterioration: In the 
Danube RBD the seven groundwater bodies formerly in poor status are now in good status but 

100 

 
 
there  are  eight  groundwater  bodies  (two  in  the  Black  Sea  RBD  and  six  in  the  West  Aegean 

RBD) which were in good status in the first RBMP and are now in poor status. The reported 
reasons for the changes are the re-delineation of groundwater bodies and the new methodology 

for  status  assessment.  But  the  availability  of  more  data  compared  to  the  first  RBMP  also 
explains changes in status classification for some groundwater bodies. 

The  changes  in  the  monitoring,  assessment  and  classification  of  the  quantitative  status  of 
groundwater bodies are explicitly summarised only in the Danube RBMP. Although the same 

changes  have  taken  place  also  for  the  other  three  RBDs,  their  RBMPs  do  not  explicitly 
summarise the differences between the previous and current RBMPs. 

The assessment of  groundwater quantitative status improved:  The preparation of the RBMPs 
follows  nationally  approved  guidelines  and  methodologies  that  did  not  exist  during  the 

preparation of the first RBMPs. Hence, the main change since the first RBMPs is the adoption 
of national methodologies and guiding documents, which are relevant for the assessment of the 

quantitative  status  of  groundwater  bodies  and  have  been  used  in  all  four  RBMPs.  These 
documents are: 

 

Pressures  and  impacts  on  the  quantitative  status  of  groundwater  bodies  and 

Method for the assessment of risk that groundwater body would not reach good 

quantitative status; 

  Method for the assessment of the quantitative status of groundwater bodies; 

  Method  for  the  planning  of  networks  and  programmes  of  monitoring, 

characteristics of the points and programmes. 

According to the summary available in the Danube RBD, another important change since the 
first  RBMPs  has  been  the  improvement  of  the  monitoring  networks  and  the  availability  of 

more data for the analysis of the quantitative status of the groundwater bodies. In addition, all 
RBMPs  report  that  some  changes  took  place  also  with  the  delineation  of  the  groundwater 

bodies  and  together  with  the  application  of  the  new  methodologies  and  guidance  documents 
this influenced the number of groundwater bodies classified in good/poor quantitative status. 

5.3  Progress with Commission recommendations 

There  were  no  Commission  recommendations  based  on  the  first  RBMPs  and  Programme  of 

Measures. 

101 

 
 
Topic  6  Monitoring,  assessment  and  classification  of  chemical 
status of groundwater bodies 

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

6.1.1.  Monitoring of chemical status in groundwater50 

The  total  number  of  groundwater  bodies  in  Bulgaria  is  169  (Table  2.3).  In  total  44  (27  %) 

groundwater bodies are not subject to surveillance monitoring. 78 groundwater bodies (46 %) 
are at risk but only 47 groundwater bodies are subject to operational monitoring. There is no 

operational monitoring at all in the West Aegean RBD with nine groundwater bodies at risk. 
The  RBMPs  do  not  indicate  that  grouping  of  groundwater  bodies  was  applied  e.g.  for 

monitoring or assessment purposes. 

The number of groundwater bodies decreased from 177 in the first RBMP to 169 in the second 

RBMP but the total groundwater body area increased slightly. 88 groundwater bodies remained 
unchanged since the first RBMP. 

The  number  of  groundwater  bodies  with  surveillance  monitoring  decreased  from  141  of  177 

(80 %) in the first cycle to 125 of 169 groundwater bodies (74 %) in the second RBMP. The 
number  of  monitoring  sites  is  listed  in  table  14 and  shows  a  slight  decrease  from  241  in  the 

first cycle to 238 in the second RBMP. The number of operational monitoring sites is 121 and 
has not changed since the first RBMP. 

Not all substances  causing  risk of deterioration in chemical  status  are subject  to  surveillance 
and operational monitoring.51 The Groundwater Directive52 Annex II substances are included in 
operational  monitoring  as  well  as  basic  parameters,  substances  causing  risk,  substances  with 
increasing trends and further substances indicative of the pressure situation. 

50      Bulgaria subsequently clarified that there  was an error in the reported data. The total number of  monitoring 
points  for  chemical  status  of  groundwater  bodies  increased  from  477  in  the  1st  cycle  RBMP  to  1016  in  the 
second  RBMP.  Surveillance  monitoring  is  carried  out  in  164  groundwater  bodies  (157  during  the  1st  cycle 
RBMP)  and  operational  monitoring  in  92  groundwater  bodies  (48  in  the  1st  cycle  RBMP).  Operational 
monitoring includes all groundwater bodies at risk. 

51  Bulgaria subsequently clarified that certain substances that are emitted from surface sources and which have 
the potential to reach the groundwater body through leaching but which have not yet reached the groundwater 
body are not yet subject to monitoring. They are identified as being at risk to the groundwater body and they 
are monitored in the second RBMPs period. 

52   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 

against 

groundwater 

and 
of 
content/EN/TXT/?uri=CELEX:02006L0118-20140711  

102 

 
                                                      
No  dedicated  trend  monitoring  has  been  established  but  the  results  from  surveillance  and 

operational monitoring will be used for trend assessments. All WFD core parameters (nitrate, 
ammonium, electrical conductivity, oxygen and pH) are monitored in all RBDs. 

6.1.2.  Assessment and classification of chemical status in groundwater 

Map 6.1 and Figure 6.1 display the chemical status of groundwater bodies for the most recently 

assessed status.  It shows that 111 of 169  groundwater bodies (66 %) were of  good chemical 
status,  and  the  remaining  58  groundwater  bodies  (34  %)  are  failing  good  status.  In  terms  of 

area, this means that about 45 % is failing good chemical status. All groundwater bodies had, 
and still have, a clearly defined status in both the first and second RBMPs.  

The total number of groundwater bodies failing good chemical status increased since the first 
RBMP from 54 (31 %) to 58 (34 %) groundwater bodies (Figure 6.1) (from 42 % to 45 % of 

the total groundwater body area). Figure 6.2 shows the confidence in status classifications. The 
RBMPs  report  some  changes  to  the  delineation  of  the  groundwater  bodies  between  the  two 

periods, the introduction and application of a common national methodology for assessment of 
the chemical status and the availability of more data for analysis, which may have impacted the 
groundwater  bodies  classified  chemical  status.  The  expected  date  of  achievement  of  good 

chemical status in Bulgaria is shown in Figure 25 

The reasons for the failure of good chemical status of groundwater bodies are shown in Figure 

6.3.  For  42  groundwater  bodies,  the  general  assessment  of  the  chemical  status  for  the 
groundwater body as a whole was that they had failed, based on the significant environmental 

risk from pollutants across a groundwater body and a significant impairment of the ability to 
support  human  uses.  33  groundwater  bodies  are  failing  the  drinking  water  test  which  means 

that the requirements of Drinking Water Protected Areas have not been met. Two groundwater 
bodies are failing good chemical status due to saline or other intrusion.  Figure 6.4 shows the 

top 10 pollutants causing failure of status and the pollutants causing a sustained upward trend.  

The calculation of the extent of exceedance of a groundwater quality standard or a groundwater 

threshold value is in all RBDs based on the groundwater body area. 

In all RBDs groundwater threshold values have been established for all pollutants or indicators 

of pollution causing a risk of failure of good chemical status and background levels have been 
considered in the groundwater threshold value establishment. 

A trend methodology is available and assessments have been performed in all RBDs. 

103 

 
Map 6.1 

Map of chemical status of groundwater bodies in Bulgaria based on the most 
recently assessed status of the groundwater water bodies 

Note: Standard colours based on WFD Annex V, Article 2.4.5. 
Source: WISE, Eurostat (country borders) 

104 

GoodPoorUnknownRiver Basin DistrictsCountries outside the EU 
 
 
 
 
Figure 6.1 

Chemical status of groundwater bodies in Bulgaria 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 2007 to 2014. The year of 
the assessment of status for the first RBMP is not known. 

Source: WISE electronic reports  

Figure 6.2 

Confidence in the classification of chemical status of groundwater  bodies 

in Bulgaria based on the most recent assessment of status  

Source: WISE electronic reports  

105 

 
 
 
Figure 6.3 

Reasons  for  failing  good  chemical  status  in  Bulgaria  for  the  most  recent 

assessment of status 

Source: WISE electronic reports  

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. 

6.1.3.  Consideration  of  groundwater  associated  surface  waters  and/  or  groundwater 

dependent ecosystems53 

In all RBDs surface water bodies are associated to groundwater bodies and in the West Aegean 

RBD  a  related  risk  is  indicated.  These  aquatic  ecosystems  have  been  considered  in  status 
assessment in two of four RBDs (in the Black Sea RBD and the West Aegean RBD). 

Groundwater  bodies  linked  with  groundwater  dependent  terrestrial  ecosystems  exist  in  all 
RBDs except the Black Sea RBD. They are related to risk in the West Aegean RBD and they 

have been considered in status assessment in all RBDs where such ecosystems exist. 

53      Bulgaria  subsequently  clarified  that  due  to  a  reporting  error  groundwater  dependent  aquatic  and  terrestrial 

ecosystems are in fact not causing a risk of not achieving good chemical status for groundwater bodies. 

106 

 
 
 
                                                      
Groundwater associated aquatic ecosystems and groundwater dependent terrestrial ecosystems 

have not been considered in the establishment of groundwater threshold values, although they 
are related to risk in the West Aegean RBD in seven groundwater bodies. 

Figure 6.4  Top 10 groundwater pollutants causing failure of good chemical in Bulgaria  

Source: WISE electronic reports  

Figure 6.5  Top 10 pollutants with upward trends in groundwater bodies in Bulgaria  

Source: WISE electronic reports  

107 

 
 
 
 
 
 
 
 
Figure 6.6  Percentage of groundwater bodies in Bulgaria at risk of failing good chemical 

status and good quantitative status for the second RBMP 

Source: WISE electronic reports  

6.2.  Main changes in implementation and compliance since first cycle 

88 of 169 groundwater bodies remained unchanged from the first RBMP. 

The initial assessment showed that the monitoring situation is not fully complete and has even 
deteriorated:  In  the  first  RBMP  surveillance  monitoring  covered  about  80  %  of  the 

groundwater bodies and now only 74 % of the groundwater bodies are covered. The number of 
operational  monitoring  sites  remained  but  78  groundwater  bodies  are  at  risk  and  only  47 
groundwater bodies are subject to operational monitoring.  

However  Bulgaria  subsequently  clarified  that  the  total  number  of  monitoring  points  for 

chemical status of groundwater bodies increased. Surveillance monitoring is carried out in 164 
groundwater  bodies  (157  during  the  first  RBMP)  and  operational  monitoring  in  92 

groundwater bodies (48 in the first RBMP). Operational monitoring includes all groundwater 
bodies at risk. 

The  changes  in  the  monitoring,  assessment  and  classification  of  the  quantitative  status  of 
groundwater bodies are explicitly summarised in a dedicated box only in the Danube RBMP. 

Although the same changes have taken place also for the other three RBDs, their RBMPs do 
not explicitly summarise the differences between the previous and current RBMPs. 

108 

 
 
The  chemical  status  situation  worsened  as  the  total  groundwater  area  failing  good  chemical 

status  increased  from  42  %  to  45  %.  Bulgaria  clarified  that  this  was  not  caused  by  the 
deterioration of water quality due to increased pressures or not effective measures but because 

of  the  improvements  of  assessing  the  groundwater  bodies  described  in  the  following.  The 
preparation of the RBMPs follows nationally approved guidelines and methodologies that did 

not  exist  during  the  preparation  of  the  first  RBMPs.  Hence,  the  main  change  since  the  first 
RBMPs is the adoption of national methodologies and guiding documents, which are relevant 

for the assessment of the chemical status of groundwater bodies and have been used in all four 
RBMPs. These documents are: 

  Method for the assessment of the chemical status of groundwater bodies; 

  Method  for  the  planning  of  networks  and  programmes  of  monitoring, 

characteristics of the points and programmes. 

Another  important  change  since  the  previous  RBMPs  has  been  the  improvement  of  the 

monitoring networks and the availability of more data for the analysis of the chemical status of 
the groundwater bodies. In addition, all RBMPs report that some changes took place also with 

the  delineation  of  the  groundwater  bodies  and  together  with  the  application  of  the  new 
methodologies  and  guidance  documents  this  influenced  the  number  of  groundwater  bodies 

classified in good/poor chemical status. 

6.3.  Progress with Commission recommendations 

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

  Recommendation:  Monitoring  should  be  strengthened  as  there  is  not  enough 
monitoring data related to biological and chemical elements and this is also a reason 

for low confidence in the assessment of their status. 

Assessment: Initial assessment showed that the recommendation is not fulfilled. In the 

first  RBMP  coverage  of  surveillance  monitoring  was  80  %  but  now  it  is  74  %  of 
groundwater bodies. Operational monitoring is still not covering all groundwater bodies 

at risk because 78 groundwater bodies are at risk but only 47 groundwater bodies are 
subject to operational monitoring.  

However,  Bulgaria  clarified  that  the  total  number  of  monitoring  points  for  chemical 
status of groundwater bodies in Bulgaria increased,  with surveillance monitoring being 

109 

 
carried out in 164 water bodies (157 during the first RBMP) and operational monitoring  

in 92 water bodies (48 in the first RBMP), while the number of total water bodies was 
reduced  from  177  to  169.  The  authorities  also  mentioned  this  is  also  part  of  in  the 

published monitoring programmes for the period 2010-2017.  

Therefore,  despite  the  WISE  reported  data,  the  additional  information  provided  by 

Bulgaria indicates that for groundwater bodies this recommendation is largely fulfilled. 

  Recommendation: Groundwater trend assessments should be carried out at all RBDs. 

Assessment: The recommendation is fulfilled as trend assessment is done in all RBDs. 
Groundwater  associated  aquatic  ecosystems  and  groundwater  dependent  terrestrial 

ecosystems  have  been  fully  considered  in  chemical  status  assessment  in  those  RBDs 
where such ecosystems exist and are related to risk. 

110 

 
 
 
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 

The  WFD  requires  a  review  of  designation  of  heavily  modified  and  artificial  water  bodies 

every six years. Several changes in the numbers of designated heavily modified water bodies 
and artificial bodies are noted since the first RBMPs (Figure 7.1). River heavily modified water 

bodies increased in the Danube RBD (from 42 to 51) and decreased in the East Aegean RBD 
(from 87 to 71). Lake heavily modified water bodies increased in the East Aegean RBD (from 

one to six) and in the West Aegean RBD (from 6 to 11). Transitional heavily modified water 
bodies increased in the Black Sea RBD from 9 to 10 (but decreased from 60 % to 35 % of total 

transitional water bodies). Lake artificial water bodies decreased in the Danube RBD (from 12 
to 5) and in the East Aegean RBD (from 14 to 4). River artificial water bodies increased from 
one to five in the East Aegean RBD. 

Figure 7.1 

Proportion of total water bodies in each category in Bulgaria that has been 
designated as heavily modified or artificial  

Second RBMP

Transitional

4% 

Lakes

Rivers

First RBMP

Transitional

0,6% 

20% 

7% 

36% 

49% 

32% 

Lakes

Rivers

0% 

19% 

26% 

60% 

67% 

0%

20%

40%

60%

80%

100%

% of water bodies 

Source: WISE electronic reports 

Heavily Modified

Artificial

Several of the designated heavily modified water bodies are reservoirs. The majority of these 

were originally rivers and are mainly designated as river heavily modified water bodies. Some 
of  the  reservoirs  which  were  originally  rivers  are  designated  as  lake  heavily  modified  water 

111 

 
 
bodies (the East Aegean RBD, the West Aegean RBD) and a few are designated as transitional 

heavily modified water bodies (in the Black Sea RBD). According to Common Implementation 
Strategy guidance54 on this issue, though, it is recommended to designate such water bodies as 
river heavily modified water bodies. 

The  main  water  uses  for  which  river  water  bodies  are  designated  as  heavily  modified  water 

bodies are irrigation, flood protection, storage for fisheries and hydropower. The main water 
uses  of  lake  heavily  modified  water  bodies  are  irrigation,  storage  for  fisheries  and  urban 

development.  The  main  uses  of  transitional  heavily  modified  water  bodies  are  transport  and 
urban development.  The main physical  alterations of river heavily modified water bodies are 

channelisation/straightening/bed  stabilisation/bank  reinforcement  and  weirs/dams/reservoirs. 
Lake  heavily  modified  water  bodies  are  mainly  affected  by  weirs/dams/reservoirs  and 

transitional  heavily  modified  water  bodies  by  weirs/dams/reservoirs  and  dredging/channel 
maintenance. 

The national methodology for designation of heavily modified water bodies and artificial water 
bodies provides a detailed step-by-step approach for designating heavily modified water bodies 
and  artificial  water  bodies,  including  consideration  of  the  significant  adverse  effects  of 

restoration measures and achievement of the benefits by other means.  

The  adverse  effects  of  the  restoration  measures  are  assessed  for  the  environment  and  the 

following  uses:  navigation,  tourism/recreation,  water  supply,  energy  generation,  irrigation, 
water control, flood protection, urbanization and other uses. The national methodology outlines 

examples for which it can be considered that the restoration measures have adverse effects on 
the  environment  or  uses.  The  examples  include  (but  are  not  limited  to)  cases  where  the 

restoration measures cause: 

  significant  losses  to  the  energy  generation  or  reduced  security  of  energy  supply  at 

regional or national level; 

 

increases of the flood risks and risks to the infrastructure; 

 

reduction  of  the  quantity  of  drinking  water  leading  to  a  risk  of  insufficient  drinking 

water supply; 

 

impacts on the agricultural production; 

54https://circabc.europa.eu/sd/a/f9b057f4-4a91-46a3-b69a-e23b4cada8ef/Guidance%20No%204%20-

%20heavily%20modified%20water%20bodies%20-%20HMWB%20(WG%202.2).pdf  

112 

 
                                                      
 

impacts on other water bodies; 

  negative  impacts  on  existing  habitats,  Natura  2000  sites  and  protected  areas,  sites  of 

special scientific interest or sites of cultural and natural heritage. 

Concerning  the  beneficial  effects  of  the  modifications  by  other  means,  the  national 
methodology  specifies  that  as  'other  means'  should  be  considered  alternatives  that  partly  or 

completely replace the current uses of the modifications. Once the other means are identified, it 
is determined whether these other means are technically feasible. Finally, a comparison of the 

overall benefits to the environment and the overall costs of each technically feasible alternative 
is made. When the cost-benefit analysis shows disproportionately high costs the water bodies 

are designated as heavily modified water bodies. In other cases, measures for the achievement 
of good ecological status are formulated. 

The step-by-step results per water body from the application of the national methodology are 
presented in Annexes for three of the RBMPs (Danube, East Aegean and West Aegean). 

In  the  Danube  RBD,  the  Danube  river  is  designated  as  a  heavily  modified  water  body.  The 
step-by-step  methodology  for  determining  heavily  modified  water  bodies  was  applied  and 

reported.  The  assessment  based  on  the  criteria  for  preliminary  identification  of  heavily 
modified  water  bodies  showed  that  there  is  no  need  to  classify  the  Danube  as  a  heavily 

modified water body. However, the RBMP explains that due to the transboundary nature of the 
river, the pressures from the Romanian side could not be adequately included in the analysis. 

Furthermore, the national methodology is not meant for large transboundary rivers such as the 
Danube  and  some  modifications  are  necessary  before  it  can  be  applied  to  such  rivers.  The 

designation  of  the  Danube  as  a  heavily  modified  water  body  was  discussed  at  the  regular 
bilateral  meetings  with  Romania and given the results of the Romanian RBMPs, the Danube 

was  finally  designated  as  a  heavily  modified  water  body  due  to  flood  protection,  navigation 
and urbanisation. 

7.1.2.  Definition of Good Ecological Potential for Heavily Modified and Artificial Water 

Bodies 

Good  ecological  potential  is  reported  as  defined  in  two  out  of  four  RBDs  (the  Danube  RBD 
and  the  Black  Sea  RBD).  It  has  not  been  defined  in  the  East  Aegean  RBD  and  the  West 

Aegean  RBD.  The  approach  used  for  good  ecological  potential  definition  is  the  Common 
Implementation Strategy Guidance approach (approach based on biological quality elements as 
illustrated in Common Implementation Strategy Guidance No 4) and good ecological potential 
is defined at water body level. 

113 

 
Good  ecological  potential  is  also  reported  as  defined  in  terms  of  biology.  The  biological 

quality elements for which biological values have been derived to define maximum ecological 
potential  and  good  ecological  potential  are  mainly  fish  (in  all  RBDs)  and  in  addition 

macrophytes, phytobenthos, benthic invertebrates, and phytoplankton  in  one RBD (the Black 
Sea  RBD).  The  estimation  of  biological  values  of  biological  quality  elements  for  maximum 

ecological  potential and  good ecological  potential  is  based on available data and monitoring, 
similar to the estimation of biological values for ecological status. 

The  national  method  for  determining  ecological  potential  addresses  rivers,  lakes  and  coastal 
waters  in  Bulgaria.  It  provides  detailed  information  and  examples  for  identifying  mitigation 

measures for the different hydromorphological pressures and impacts which the different types 
of  heavily  modified  water  bodies  face  as  a  result  of  their  economic  use.  The  examples  of 

pressures include creation of barriers and reservoirs, fishing, water use for economic purposes, 
navigation  and  recreation.  The  sensitivity  of  five  biological  quality  elements  (phytoplankton, 

phytobenthos,  macrophytes,  macrozoobenthos  and  fish)  and  hydromorphological  quality 
elements  to  these  pressures  and  expected  impacts  is  described.  A  four-level  range  of  the 
impacts  on  biological  quality  elements  is  defined  for  determining  the  Maximum  Ecological 

Potential  and  the  Good  Ecological  Potential.  The  different  levels  of  the  range  are  described 
qualitatively for each type of hydromorphological pressure, surface water body (rivers, lakes or 

coastal  waters)  and  each  of  the  five  biological  quality  elements.  Furthermore,  qualitative 
biological  definitions  are  provided  for  maximum,  good,  moderate,  bad  and  poor  ecological 

potential.  The  method  also  qualitatively  outlines  the  expected  ecological  impact,  indicative 
biological  quality  elements,  potential  adverse  effects  on  the  use  and  examples  of  specific 

implementation actions for each of the considered mitigation measures. 

The  assessment  of  the  ecological  potential  of  heavily  modified  water  bodies/artificial  water 

bodies  uses  the  classification  system  for  biological  quality  elements  developed  in  Ordinance 
N4  for  the  characterisation  of  surface  waters  (of  2012  and  updated  in  2014)55.  In  this 
classification  system,  ranges  of  threshold  values  are  outlined  for  different  biological  quality 
elements  and  types  of  surface  water  bodies.  Overall,  the  methods  for  estimating  biological 

quality elements values are not distinguished between good ecological status and potential and 
the national classification system for determining ecological status and ecological potential is 

partly overlapping. A separate range for ecological status and ecological potential is available 
only  for  fish  fauna  in  rivers.  For  the  remaining  biological  quality  elements,  the  ranges  for 

55  This  ordinance  sets  out  the  general  requirements,  definitions  and  threshold  values  for  determining  the 
ecological  status  of  rivers,  lakes,  transitional  and  coastal  waters  and  the  ecological  potential  of  rivers  and 
lakes. 

114 

 
                                                      
ecological status and ecological potential are the same (for macrophytes) or are not developed 

(phytobenthos, phytoplankton, macrozoobenthos). 

For  rivers,  methods  for  assessing  fish,  macrophytes,  phytobenthos  and  benthic  invertebrates 

are  reported  as  sensitive  to  altered  habitats  due  to  both  hydrological  and  morphological 
changes.  Two  methods  for  phytobenthos  and  invertebrates  are  only  sensitive  to  morphology 

but not to hydrology. For lakes and transitional waters, no biological quality elements methods 
sensitive  to  hydromorphology  are  reported.  For  coastal  waters,  only  one  method  for  benthic 

invertebrates  is  sensitive  to  altered  habitats  due  to  both  hydrological  and  morphological 
changes. 

Mitigation  measures  for  defining  good  ecological  potential  have  been  reported  in  two  out  of 
four RBDs (the Danube RBD and the Black Sea RBD). Ecological changes expected due to the 

mitigation  measures  are  described  in  a  qualitative  way,  as  the  method  outlines  the  expected 
ecological  impact,  indicative biological  quality  elements,  potential adverse effects  on the use 

and  examples  of  specific  implementation  actions  for  each  of  the  considered  mitigation 
measures.  Tables  detailing  the  mitigation  measures,  possible  adverse  effects  on  the  use,  key 
biological quality elements indicators, additional indicators and expected ecological effects and 

results are presented for each surface water category (river, lake and coastal waters) and each 
type of pressure.  

7.2.  Main changes in implementation and compliance since first cycle 

As described above, there have been modifications in the extent of designation of water bodies 

as heavily modified or artificial in several RBDs since the first RBMPs.  

The reason for the differences in the designation of heavily modified water bodies and artificial 

water  bodies  is  the  application  of  new  national  methodology  and  guidance  for  their 
designation.  This  methodology  (and  accompanying  guidance)  was  developed  after  the  first 

RBMPs and has been applied for the second RBMPs. Two of the second RBMPs (Black Sea 
and  West  Aegean)  state  that  the  designation  of  heavily  modified  water  bodies  and  artificial 

water bodies in the first cycle was prepared primarily based on expert judgement and a list of 
activities considered to lead to significant modifications, while in the second cycle the national 

methodology was applied; this explains the difference in the number of heavily modified water 
bodies  and  artificial  water  bodies  between  the  two  reporting  cycles.  The  other  two  RBMPs 

(Danube  and  East  Aegean)  only  state  that  the  national  methodology  for  the  designation  of 
heavily  modified  water  bodies  and  artificial  water  bodies  was  applied  in  this  cycle,  without 
providing comparisons with the methods for the designation in the first RBMPs.  

115 

 
The national  supporting  documents on the method for designation of heavily modified water 

bodies do not provide explanations on whether and how these methods differ between the two 
reporting cycles. 

Concerning the definition of good ecological potential, a national method for determining the 
ecological  potential  of  rivers,  lakes  and  coastal  waters  has  been  developed  since  the  first 

reporting  cycle.  None  of  the  RBMPs  explicitly  report  what  are  the  differences  in  the 
assessment of the ecological potential of heavily modified water bodies compared to the first 

cycle;  however  the  national  methodology  for  designating  heavily  modified  water  bodies  and 
determining  their  good  ecological  potential  was  developed  after  the  first  reporting  cycle  and 

first applied for the second RBMPs, indicating a key improvement. 

7.3.  Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMPs  and  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). The assessment of significant adverse effects 

on  their  use  or  the  environment  and  the  lack  of  significantly  better  environmental 
options  should  be  specifically  mentioned  in  the  RBMPs.  This  is  needed  to  ensure 

transparency of the designation process.  

Assessment:  Heavily  modified  water  bodies  are  designated  due  to  various  uses, 

including  irrigation,  flood  protection,  storage  for  fisheries,  hydropower,  urban 
development  and  transport.  The  national  methodology  for  designation  of  heavily 
modified  water  bodies  and  artificial  water  bodies  in  the  second  RBMPs  provides  a 

detailed  step-by-step  approach  for  designating  heavily  modified  water  bodies  and 
artificial  water  bodies,  including  consideration  of  the  significant  adverse  effects  of 

restoration measures and achievement of the benefits by other means. The step-by-step 
results per water body from the application of the national methodology are presented 

in Annexes for three of the RBMPs (Danube, East Aegean and West Aegean). 

Therefore, this recommendation has been fulfilled. 

  Recommendation:  (report  2015)  Develop  in  the  second  RBMPs  an  appropriate 
methodology to establish good ecological potential including the necessary mitigation 
measures linked to water uses and quality level.  

116 

 
For the second RBMPs,  a national method for determining the ecological potential of 

rivers,  lakes  and  coastal  waters  has  been  developed  and  applied  for  the  heavily 
modified  water  bodies  and  artificial  water  bodies  of  the  RBMPs.  However,  good 

ecological  potential  has  been  defined  and  mitigation  measures  for  good  ecological 
potential reported only in two out of four RBDs (the Danube RBD and the Black Sea 

RBD). Good ecological potential has not been defined in the East Aegean RBD and the 
West Aegean RBD. 

Therefore, this recommendation has been partially fulfilled.   

117 

 
 
 
Topic 8 Environmental objectives and exemptions 

8.1.  Assessment  of 

implementation  and 

compliance  with  WFD 

requirements in 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 201556), 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 in surface waters and quantitative 
and chemical status in groundwaters have been reported in all RBDs. They have been set for 

2021, 2027 and beyond 2027. 

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  Bulgaria  is  provided  in 

Chapter 15 of this report. 

Assessments of the current status of surface and groundwater bodies in Bulgaria 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  Bulgaria  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).  

56 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. 

118 

 
                                                      
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  Bulgaria  for  the  4  main  sets  of  environmental 

objectives. 

Figure 8.1 

Water bodies in Bulgaria 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 report. 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:  an  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 is 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 

cost,  technical  feasibility  or  natural  conditions,  and  Article  4(5)  by  disproportionate  cost  or 
technical feasibility. 

119 

 
 
Figure 8.2 summarises the percentage of water bodies subject to each type of exemption (and 

reason) in relation to the four types of environmental objectives in Bulgaria. 

Figure 8.2 

Type  of  exemptions  reported  to  be  applied  to  surface  water  and 

groundwater  bodies  for  the  second  RBMP  in  Bulgaria.  Note:  Ecological 
status and groundwater quantitative status  exemptions are reported at the 

water body level. Chemical exemptions for groundwater are 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 reports 

120 

 
 
Application of Article 4(4) 

Article  4(4)  was  applied  in  the  first  cycle  in  surface  waters  and  groundwaters  and  is  again 
applied  in  the  second  cycle.  In  the  first  cycle,  the  justification  for  surface  waters  in  relation 

Article 4(4) referred to  technical  feasibility and  natural  conditions.  This has not  changed and 
again disproportionate costs have not been used as a justification for any exemption. 

The  main  parts  of  the  RBMPs  provide  only  some  general  information  about  the  exemptions 
applied in the respective RBDs summarising changes in the number of exemptions compared 

to  the  previous  period.  However,  annexes  to  the  RBMPs  list  the  exemptions  on  water  body 
level  together  with  justifications  for  the  exemptions  by  water  body.  The  format  and 

information provided differs. In the case of the East Aegean RBMP the main text presents the 
justifications for the exemptions by water body.  

The  RBMPs  list  only  generic  reasons  or  types  of  reasons  as  defined  in  the  national 
methodology  (e.g.  the  Danube  and  Black  Sea  RBMPs  list  generic  reasons;  the  West  Aegean 

RBMP  quotes  the  reasons  from  the  national  methodology  that  apply  for  the  RBD). 
Nevertheless,  all  RBMPs  refer  to  the  national  methodology  for  applying  exemptions 
("Methodology for application of the exemptions according to Articles 156(b) to 156(e) of the 
Water  Law"57)  as  the  basis  on  which  exemptions  were  defined  and  a  focussed  review  of  the 
methodology suggests that technical reasons for applying Article 4(4) and Article 4(5) can be 

used in the following situations: 

 

time  needed  for  implementation  of  the  measures  -  when  the  improvements/measures 

can be accomplished over a longer period due to technical reasons such as the time for 

preparation of construction works and their implementation; 

 

lack  of  sufficient  technical  capacity  for  the  completion  of  larger  and  multiple 

investments  (including  the  time  needed  to  organise  and  conduct  public  procurement 
procedures); 

 

lack of existing technical  solution  - when, to date, there is  no suitable and practically 
applicable  technical  solution/technology  that  can  be  used  to  address  the  specific 

problem and when there is information about a certain technology (e.g. for treatment) 
but it is not clear if it will be effective in practice; 

57http://www.moew.government.bg/bg/vodi/planove-za-upravlenie/planove-za-upravlenie-na-rechnite-basejni-

purb/  

121 

 
                                                      
  no known reason  for the observed impacts  -  when the impacts/sources of impacts  for 
not  achieving  good  status  are  not  determined  and  therefore,  an  appropriate 
solution/measure cannot be defined; 

 

Impossibility to take measures - cases where measures cannot be taken as the reason for 
no achieving good status (source of the impact) is outside the jurisdiction of Bulgaria 

and there are no transboundary mechanisms for joint actions defined. 

According to the national methodology for using exemptions, natural conditions can be used as 

reasons for applying Article 4(4) and Article 4(5) in the following circumstances: 

 

time for ecological recovery - when the necessary measures are being implemented but 

a longer period is necessary to  achieve their effects on the water body and to achieve 

good status (e.g. restoration of meanders will have an impact on the biological quality 
elements and the development of the biocenosis after a certain time, the application of 

good  agricultural  practices  will  impact  the  concentration  of  nitrates  after  a  certain 
time); 

  natural  conditions  -  e.g.  when  the  reason  for  not  achieving  environmental  quality 
standards for a certain quality element is not human activity but is natural, the natural 

background  levels  are  such  that  the  concertation  of  this  element  in  the  water  body 
cannot  be  significantly  decreased  as  to  achieve  the  necessary  improvement  i.e.  to 

achieve the environmental quality standards of this quality element. 

 

time  for  recovery  of  groundwater  -  in  cases  where  the  climatic  and  geological 

conditions  determine longer time for recovery the status  of the  groundwater e.g. time 
for  recovering  the  level  of  groundwater  after  adopting  measures  concerning 

abstraction/use. 

The justification of natural conditions might be an issue of insufficient and/or non-compliant 

implementation  of  WFD  requirements,  as  relevant  information  is  lacking  in  the  RBMPs  and 
reported background documents. It is mentioned that "natural conditions - e.g. when the reason 

for not achieving Environmental Quality Standards for a certain quality element is not human 
activity  but  is  natural,  the  natural  background  levels  are  such  that  the  concentration  of  this 

element  in  the  water  bodies  cannot  be  significantly  decreased  so  as  to  achieve  the  necessary 
improvement  i.e.  to  achieve  the  Environmental  Quality  Standards  of  this  quality  element.  A 

correction/adaptation  of  the  reference  conditions  seems  to  be  more  appropriate  instead  of 
applying an exemption in case there is evidence that the concentrations are indeed natural. 

122 

 
The main pressures to surface waters in the Danube RBD come from a broad range of activities 

including urbanisation, industry, agriculture, mining, aquaculture, atmospheric deposition and 
activities causing changes in hydromorphology. For the Black Sea RBD, the main pressures to 

surface  waters  are  resulting  from  urbanisation,  industry,  aquaculture,  agriculture,  abstraction, 
activities  causing  changes  in  hydromorphology  but  also  the  introduction  of  species  and 

diseases,  litter  and  exploration  of  animals  or  plants.  In  the  East  Aegean  RBD,  the  main 
pressures  to  surface  waters  are  resulting  from  abstraction  and  activities  causing  changes  in 

hydromorphology,  point  source  pollution  from  industry,  mining  and  settlements.  Diffuse 
pollution is also an issue. The main pressures to surface waters in the West Aegean RBD are 

urbanisation, 
in 
hydromorphology. Most of these pressures are also responsible for Priority Substances failing 

industry,  agriculture,  aquaculture  and  activities  causing  changes 

to achieve good chemical status (Table 8.1).  

For groundwater, the main driver causing chemical pressures is agriculture in all RBDs (Table 

8.2).  The  Danube,  Black  Sea  and  East  Aegean  RBDs  also  report  industry  as  a  pressure  on 
groundwater  with  the  East  Aegean  RBD  reporting  in  addition  mining  and  discharges  not 
connected to the sewerage network. The latter is also a pressure to  groundwater in the Black 

Sea RBD. 

The  impacts  causing  exemptions  under  Article  4(4)  are  chemical  pollution,  altered  habitats, 

nutrient and organic pollution in all RBDs. In addition, for groundwater, diminution of quality 
reasons  and  saline 
of  associated  surface  waters 

for  chemical  and  quantitative 

pollution/intrusion are reported in the Black Sea RBD together with unknown impacts. 

Table 8.1 

Pressure responsible for Priority Substances in Bulgaria failing to achieve 

good chemical status and for which exemptions have been applied 

Significant pressure on surface water 
bodies 

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 

1.7 - Point - Mine waters 

2.2 - Diffuse - Agricultural 

2.8 - Diffuse - Mining 

8 - Anthropogenic pressure - Unknown 

Failing Priority 
Substances 

Article 4(4) - 
Technical feasibility 
exemptions 

Article 4(5) - 
Technical feasibility 
exemptions 

Number 

Number 

Number 

3 

1 

3 

2 

4 

2 

2 

3 

2 

1 

4 

3 

2 

2 

2 

3 

2 

1 

4 

0 

7 

0 

2 

0 

Source: WISE electronic reports  

123 

 
 
Table 8.2 

Pressure  responsible  for  pollutants  in  Bulgaria  failing  to  achieve  good 

chemical  status  in  groundwater  and  for  which  exemptions  have  been 
applied  

Significant pressure on groundwater 

Number 
of failing 
pollutants 

Number of exemptions 

Article 4(4) - 
Natural 
conditions 

Article 4(4) - 
Technical 
feasibility 

Article 4(5) - 
Technical 
feasibility 

1.1 - Point - Urban waste water 

1.3 - Point - IED plants 

1.5 - Point - Contaminated sites or 
abandoned industrial sites 

2.10 - Diffuse - Other 

2.2 - Diffuse - Agricultural 

2.5 - Diffuse - Contaminated sites or 
abandoned industrial sites 

2.6 - Diffuse - Discharges not 
connected to sewerage network 

2.8 - Diffuse - Mining 

3.2 - Abstraction or flow diversion - 
Public water supply 

8 - Anthropogenic pressure - Unknown 

1 

2 

6 

4 

7 

3 

3 

1 

1 

7 

2 

6 

3 

35 

1 

1 

7 

1 

2 

10 

1 

1 

14 

2 

4 

17 

2 

6 

1 

4 

Source: WISE electronic reports  

No  information  on  the  drivers  and  impacts  of  the  Article  4(4)  exemptions  are  provided  in 

WISE. The main parts of the RBMPs do not mention specific drivers or impacts causing the 
exemptions.  

Application of Article 4(5) 

Article 4(5) was only applied in the Danube RBD for surface waters in the first RBMP but in 
the second cycle it is applied in all RBDs. For groundwaters, Article 4(5) was only applied in 
the Danube and Black Sea RBDs in the first cycle. In the second cycle it is applied in the Black 
Sea, East Aegean and West Aegean RBDs. The potential justifications for Article 4(5) are set 

out  in  the  national  methodology  for  applying  exemptions  (see  above).  The  application  and 
justification  of  Article  4(5)  might  be  an  issue  of  insufficient  and/or  non-compliant 

implementation  of  WFD  requirements  as  natural  conditions  can  potentially  be  used  as  a 
justification.  However,  in  the  second  RBMP  in  all  cases,  the  reason  quoted  is  technical 

feasibility. 

124 

 
 
 
 
 
 
 
 
 
 
 
 
No  information  on  the  drivers  and  impacts  of  the  Article  4(5)  exemptions  are  provided  in 

WISE. 

Application of Article 4(6) 

While  in  the  first  cycle  Article  4(6)  was  applied  in  the  Black  Sea  RBD,  in  the  second  cycle 
Article 4(6) was not applied in any RBD. 

Application of Article 4(7) 

Article  4(7)  was  only  applied  in  the  West  Aegean  RBD  in  the  first  cycle  but  in  the  second 

cycle  it  is  also  applied  in  the  Danube  and  East  Aegean  RBDs.  The  types  of  modifications 
leading  to  the  application  of  exemptions  under  Article  4(7)  are  only  reported  for  the  West 

Aegean RBD ("other" type of modifications), but not for the Danube and East Aegean RBDs. 
According  the  RBMPs,  the  impact  of  new  modifications  or  relevant  flood  risk  management 

measures from the Flood Risk Management Plans that can have an impact on the water status 
have  been  assessed.  Even  though  the  reasons  for  applying  Article  4(7)  exemptions  are  not 

discussed at length in the main parts of the RBMPs, all relevant RBMPs contain annexes that 
provide  further  details  about  the  exemptions.  The  annexes  to  the  Danube  and  East  Aegean 
RBMPs  contain  information  about  the  Article  4(7)  exemptions  per  water  body  and  their 

justifications. The annexes to the West Aegean RBMP only list the exemptions per water body 
without  specific  justification.  In  addition,  the  Danube  and  West  Aegean  RBMPs  contain 

annexes  with  'potential'  Article  4(7)  exemptions  resulting  from  e.g.  infrastructure  projects  in 
the territory of the RBDs. 

The  methods  for  assessing  the  need  for  Article  4(7)  exemptions  are  not  discussed  in  the 
RBMPs  but  as  indicated  previously  all  RBMPs  refer  to  the  national  methodology  for  using 

exemptions. According to this national methodology, the assessment of new modification has 
also to assess cumulative effects. However, further details are not available; the methodology 

only provides examples where the cumulative effects are considered.  

The  RBMPs  do  not  explicitly  discuss  if  any  steps  have  been  taken  to  mitigate  the  adverse 

impacts  on  the  status  of  the  affected  water  bodies.  However,  the  national  methodology  for 
using  exemptions  requires  that  exemptions  are  defined  only  when  'all  practical  steps'  to 

mitigate the adverse impacts on the affected water bodies are taken. As regard to public interest 
or  the  fact  that  the  benefits  of  the  project  outweigh  the  benefits  of  achieving  the  WFD 

environmental  objectives,  the  annexes  of  the  RBMP  provide  only  the  conclusions  from  the 
assessments  and  do  not  provide  details  about  the  methodologies  used.  Nevertheless,  they  all 

include a section that sums up why  the project is of overriding public interest and the public 

125 

 
benefits cannot be achieved in another way. As all new modifications refer to flood protection, 

the  main  argument  is  that  these  measures  aim  to  protect  citizens'  health  and  safety. 
Furthermore, the national methodology for using exemptions requires that the public benefits 

of  projects  or  their  overriding  public  interest  is  analysed  any  time  a  potential  exemption  is 
sought.  Even  if  there  is  little  information  in  the  RBMPs  in  relation  to  better  environmental 

options  taken  into  account  when  applying  Article  4(7),  in  all  cases  alternative  options  are 
mentioned and a reference to the national methodology is made. 

Application of Article 6(3) of the Groundwater Directive 

No exemptions according to Article 6(3) of the Groundwater Directive58 have been applied. 

8.2.  Main changes in implementation and compliance since first cycle 

Article 4(7) was only applied in  the West  Aegean RBD in  the first  RBMP but in  the second 
RBMP it has also been applied in the Danube and East Aegean RBDs. Article 4(4) was applied 

in the first cycle in surface waters and groundwaters and has also been applied in the second 
cycle. Article 4(5) was only applied in the Danube RBD for surface waters in the first cycle but 

has  been  applied  in  all  RBDs  in  the  second  cycle.  For  groundwaters,  Article  4(5)  was  only 
applied in the first cycle in the Danube and Black Sea RBDs. Now it has been applied in the 

Black Sea, East Aegean and West Aegean RBDs. Article 4(6) was applied in the first cycle in 
the Black Sea RBD; however, in the second cycle it has not been applied in any RBD. 

Changes  in  the  methodology  to  define  environmental  objectives  and  exemptions  are  not 
explicitly discussed in the RBMPs. However, all RBMPs explain that a national methodology 

concerning the use of exemptions has been developed. This methodology refers to Article 4(3) 
to  Article  4(7)  of  the  WFD  and  was  adopted  in  2016.  It  was  used  for  the  preparation  of  the 

Plans.  Only  the  West  Aegean  RBMP  explicitly  lists  different  relevant  normative  and 
methodological changes that took place in the period 2010-2015. These include: 

  changes in the delineation of the water bodies; 

  designation of protected areas for drinking water; 

  a common national methodology for characterisation and status classification of surface 

water bodies has been introduced; 

58   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  
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02006L0118-20140711 

126 

 
                                                      
 
  common  national  methods  for  monitoring  and  analysis  of  biological  quality  elements 

and new criteria for Environmental Quality Standards have been introduced. 

8.3.  Progress with Commission recommendations 

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

  Recommendation: The ecological objectives defined are of a very general nature, there 
are  no  quantitative  dimensions  and  easily  measurable  and  verifiable  criteria  for 
monitoring their achievement. Ecological objectives should be better specified.  

Assessment:  Environmental  objectives  for  ecological  and  chemical  status  in  surface 
waters and qualitative and quantitative status in groundwaters have been reported in all 

RBDs. Expected dates of achieving these objectives have been reported for the majority 
of water bodies (Ecological status - Figure 9; Chemical status – Figure 20; groundwater 

quantitative and chemical status – Figure 25) though there are some gaps with respect 
to  ecological  status  and  for  a  greater  number  with  respect  to  the  chemical  status  of 

surface water bodies where dates are unknown or beyond 2027. Where objectives are 
not  going  to  be  met,  exemptions  have  been  applied.  This  recommendation  has  been 

partially fulfilled. 

  Recommendation:  The  identification  of  exemptions  is  incomplete  and  should  be 
completed in the next RBMP cycle. While the WFD does provide for exemptions, there 
are specific criteria that must be fulfilled for their use to be justified. The application of 

exemptions needs to be more transparent and the reasons for the exemptions should be 
clearly justified in the plans.   

Assessment: This recommendation has been partly implemented as a national approach 
for exemptions  has been developed. However, the justifications in  the RBMPs are on 
water body level but generic. The extent to which a harmonisation between RBDs has 
taken  place  was  not  possible  to  assess.  In  relation  to  Article  4(7),  a  national 

methodology  has  been  developed,  but  it  is  unclear  if  it  is  applied  in  accordance  with 
water bodies and project specific circumstances.   

  Recommendation: It is unclear whether there are new physical modifications planned 
in RBMPs. If this is the case, 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 

127 

 
assessment  of  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)  is  applied  in  three  basins,  but  the  types  of  modifications 
leading  to  the  application  of  this  exemptions  are  only  reported  for  the  West  Aegean 

RBD. Even though the reasons for applying Article 4(7) exemptions are not discussed 
at  length  in  the  main  parts  of  the  RBMPs,  all  relevant  RBMPs  contain  annexes  that 

provide further details about the exemptions. Therefore, this recommendation has been 
partly fulfilled.  

  Recommendation: Ensure that the RBMPs clearly identify the gap to good status, and 
that  the  Progammes  of  Measures  are  designed  and  implemented  to  close  that  gap. 

Exemptions should be adequately justified at water body level. 

Assessment:  Environmental  objectives  for  ecological  and  chemical  status  of  surface 

water bodies were reported in all RBDs as well as for chemical and quantitative status 
of  groundwater  bodies.  Information  is  also  provided  on  when  it  is  expected  that  the 

objectives will be achieved. Exemptions are justified at water body level, but in generic 
terms. Therefore, this recommendation has been partly fulfilled. 

128 

 
 
 
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 Measure (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 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. A large number of pressure types causing failure of objectives 
in groundwater and surface waters in all RBDs were reported by Bulgaria. For surface waters, 

KTMs were reported for all significant pressure types causing failure of objectives in all RBDs 

129 

 
  
except  the  Black  Sea  RBD,  where  several  are  missing,  including  point  and  diffuse  sources 

from  contaminated/abandoned sites, other diffuse sources,  some abstractions/flow diversions, 
dams,  hydrological  alterations  and  exploitation  of  animals/plants.  For  groundwater,  all 

significant  pressure types causing failure of objectives, were covered by  KTMs in  all RBDs, 
except KTM2.5 – “diffuse from contaminated/abandoned sites” in the Danube RBD, although 

this pressure was covered by a KTM for surface water.  

Bulgaria  has  mapped  105  national  basic  measures  and  82  national  supplementary  measures 

against all the pre-defined KTMs except KTM25 – “Measures to counteract acidification”. 12 
%  of  the  national  basic  measures  and  22  %  of  the  national  supplementary  measures  were 

mapped against KTM14 – “Research, improvement of knowledge base reducing uncertainty”, 
a  further  11  %  of  national  basic  measures  were  mapped  against  KTM8  –  “Water  efficiency, 

technical  measures  for  irrigation,  industry,  energy  and  households”.  Basic  measures  are  in 
place to address all the requirements of Article 11(3) (see Table 9.2). 

Links  to  documents  on  Article  11(3)(c-k)  basic  measures  were  provided.  An  inventory  of 
national basic measures was also provided. 

For  all  RBDs,  the  KTMs  reported  to  be  tackling  significant  pressures  are  covered  by  KTMs 

mapped  against  national  measures.  For  the  Black  Sea  RBD,  one  additional  KTM  has  had 
national  measures  mapped  against  it.  For  the  Danube  and  West  Aegean  RBDs,  several 

additional  KTMs  have  had  national  measures  mapped  against  them,  compared  with  those 
reported to be tackling significant pressures; therefore it is not clear if these are relevant / will 

be made operational.  

The  percentage  of  water  bodies  not  expected  to  achieve  good  status/  potential  by  2027  has 

been indicated as zero or 0-10 in most cases in surface water and groundwater in all RBDs (20-
50 % for diffuse agricultural pollution in the East Aegean RBD). 

No data has been provided for any of the RBDs on the number of surface water bodies failing 
to achieve objectives due to River Basin Specific Pollutants. Information has been provided for 

all  4  RBDs  for  groundwater  bodies,  although  the  range  of  substances  reported  is  limited  to 
nutrients (only nitrate is reported in the West Aegean RBD), inorganic contaminants (e.g. iron, 

magnesium, chloride, sulphate) and other physicochemical parameters (e.g. conductivity). The 
KTMs  in  place  to  address  the  failure  of  objectives  caused  by  the  substances  in  groundwater 

identified have been reported in three RBDs  - no information has been provided for the East 
Aegean RBD.  Information on KTMs to  address  failures of objectives  caused by River  Basin 

130 

 
Specific  Pollutants  in  surface  waters  is  also  provided  for  the  Danube,  Black  Sea  and  West 

Aegean RBDs – the substances addressed are all inorganic contaminants. 

The  number  of  surface  water  bodies  where  Priority  Substances  are  causing  a  failure  of 

objectives has been reported in all four RBDs. Four substances have been found to be causing 
failures in the East Aegean RBD, with the other RBDs each reporting three substances causing 

failure. No information on the KTMs used to address these failures has been reported for the 
East Aegean RBD. For the other RBDs, KTMs are reported for all substances causing failure 

in  the  Danube  RBD,  in  the  Black  Sea  RBD  KTMs  are  reported  for  hexachlorbutadiene  and 
mercury,  but  not  for  octylphenol,  and  in  the  West  Aegean  RBD  KTMs  are  reported  for  lead 

and cadmium, but not for nickel. 

Indicators  of  the  gap  to  good  status,  and  the  progress  expected  from  the  implementation  of 

measures  have  been  reported  for  most  significant  pressure  types  in  groundwater  and  surface 
water in all RBDs. However, these have not been quantified for any pressures in any RBD. In 

the Annex 0 document, Bulgaria reports that for the indicators for the gap to good status “due 
to  the  significant  number  of  water  bodies  assessed  in  ‘unknown’  ecological  and/or  chemical 
status, it is not possible to assess the level of significance of the different pressure types and to 

evaluate the extent of the pressure or chemical substance that is to be reduced to achieve the 
Environmental Objectives; respectively, it is not possible to estimate and report a quantitative 

indicator.”  The  indicators  of  progress  of  measures  is  also  covered  in  the  Annex  0  where 
Bulgaria  report  “due  to  the  significant  number  of  water  bodies  assessed  in  ‘unknown’ 

ecological  and/or  chemical  status,  it  is  not  possible  to  assess  the  gap  to  the  achievement  of 
100% compliance with the Environmental Objective. It is not possible to quantify the pressures 

that  are  to  be  reduced;  it  is  not  possible  to  assess  the  scale  of  measures  still  needed  for 
achievement of 100% compliance and to report the expected value of the KTM- indicator.” 

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. Cost-effectiveness analysis was not used in the selection of measures for the 
first  Programme  of  Measures  –  no  information  was  provided  on  this  topic  for  the  second 

Programme  of  Measures.  Further  information  on  the  methods  used  for  the  prioritisation  of 
measures could not be found in the RBMPs or background documents. 

A  critical  factor  in  the  success  of  the  implementation  of  the  Programme  of  Measures  is  the 
availability of funding to support the investments required. For the first cycle (covering years 

2010-15)  investment  costs  have  been  reported  separately  for  Article  11(3)(a)  requirements 
(measures  required  to  implement  Community  legislation  for  the  protection  of  water)  and 

131 

 
Article 11(3)(b-l), Article 11(4) and Article 11(5) (all other measures) for the Danube and East 

Aegean RBDs, and as a total of all measures for the Black Sea and West Aegean RBDs. The 
total cost of the first Programme of Measures for Bulgaria was reported to be €1311 m. 

For  the  second  cycle  investment  costs  are  presented  for  the  years  2017-21  (2016-21  for  the 
East  Aegean  RBD)  separately  for  Article  11(3)(a)  requirements  (measures  required  to 

implement  Community  legislation  for  the  protection  of  water)  and  Article  11(3)(b-l),  Article 
11(4) and Article 11(5) (all other measures) for all RBDs, depreciation has not been included 

in any calculations. The capital investment required for Article 11(3)(a) measures ranges from 
€192.6 m  in  the  West  Aegean  RBD  to  €1018  m  in  the  East  Aegean  RBD.  The  total  capital 

investment required is €2462 million. The capital investment required for measures required by 
Article 11(3)(b-l), Article 11(4) and Article 11(5) ranges from €1.9 million in the West Aegean 

RBD  to  €108 million  in  the  Black  Sea  RBD.  The  total  capital  investment  required  is 
€186 million.  The  annual  operation  and  maintenance  costs  have  not  been  reported.  In  the 

Annex 0 Bulgaria reports that “it is difficult to quantify these costs due to the different type of 
measures  and  the  diversity  of  operators.”  European  Union  investment  funding  figures  are 
presented for the first cycle only (2009-15) for all four RBDs – the total investment reported 

was  €49020.  No  information  was  reported  for  the  second  cycle,  in  the  Annex  0  document 
Bulgaria  report  “the  information  about  expected  European  Union  financing  for  the  second 

management  plan  is  not  reported.  It  is  difficult  to  estimate  the  expenditure,  which  will  be 
financed by different European Union funds.” 

A clear financial commitment has been reported as having been secured for the implementation 
of  the  Programme  of  Measures  in  all  RBDs.  On  a  sectoral  basis,  commitments  have  been 

secured where considered relevant, i.e. for Agriculture, Industry, Urban and Flood Protection 
in  all  RBDs;  Transport  (not  applicable  in  the  West  Aegean  RBD);  Hydropower  and 

Aquaculture (not applicable in the Black Sea RBD); Energy (not applicable in the Danube and 
Black Sea RBDs); Recreation (only applicable in the East Aegean RBD).  

Co-ordination of the preparation of all RBMPs and Programmes of Measures with the Marine 
Strategy Framework Directive59 is reported for the Black Sea RBD only (the other RBDs are 
landlocked).  The preparation of the RBMPs and  marine strategy were co-ordinated and joint 
consultation  on  the  RBMPs  and  the  Marine  Strategy  was  carried  out,  but  the  need  for 

additional 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 

59    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  

132 

 
                                                      
and marine environments was not considered. However, KTMs that are relevant to the Marine 

Strategy Framework Directive are reported for the Black Sea RBD, with an indication of the 
type and number of basic measures, but not indicating the pressures they are addressing. 

The RBMPs and Floods Directive60 Flood Risk Management Plans have not been integrated in 
any  of  the  four  RBDs;  but  in  all  RBDs  (i)  joint  consultation  of  RBMPs  and  Flood  Risk 

Management Plans was carried out, (ii) the objectives and requirements of the Floods Directive 
were considered in the second RBMPs and Programme of Measures, (iii) drought management 

and  use  of  Natural  Water  Retention  Measures  have  been  included  in  the  Programme  of 
Measures,  (iv)  the  design  of  new  and  existing  structural  measures,  such  as  flood  defences, 

storage  dams  and  tidal  barriers,  has  been  adapted  to  take  account  of  WFD  Environmental 
Objectives, and financial commitments have been made. WFD Article 9(4) has been applied to 

impoundment for flood protection in the East Aegean RBD only. 

9.1.2   Measures related to other significant pressures 

Other  significant  pressures  have  been  reported  for  groundwater  and  surface  water  for  the 
Danube, Black Sea, and East Aegean RBDs (no information was reported for the West Aegean 
RBD).  These  relate  mainly  to  “Anthropogenic  pressures  –  unknown  and  historical”  in  all  3 

RBDs, plus introduced species/diseases in surface water in the Black Sea and East Aegean, and 
fly  tipping  in  the  Black  Sea.  Whilst  KTMs  are  listed  for  all  pressures,  together  with  gap 

indicators and measure indicators, no gap values are provided (see also section 9.1.1). 

9.1.3   Mapping of national measures to KTMs 

It was expected that Member States would be able to report their Programme of Measures by 
associating their national measures with predefined KTMs. KTMs are expected to deliver the 

bulk  of  the  improvements  through  reduction  in  pressures  required  to  achieve  WFD 
Environmental  Objectives.  A  KTM  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  KTM,  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 

KTM in Bulgaria. Also shown is the number of RBDs for which the KTM has been reported. 
Table  9.2  then  summarises  the  type  of  basic  measures  associated  with  the  national  measures 

mapped against the KTM. 

60  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  

133 

 
 
                                                      
Table 9.1 

Mapping  of  the  types  of  national  measures  to  Key  Types  of  Measure  in 

Bulgaria  

Key Type of Measure 

KTM1 - Construction or upgrades of wastewater 
treatment plants 

KTM10 - Water pricing policy measures for the 
implementation of the recovery of cost of water 
services from industry 

KTM11 - Water pricing policy measures for the 
implementation of the recovery of cost of water 
services from agriculture 

KTM12 - Advisory services for agriculture 

KTM13 - Drinking water protection measures (e.g. 
establishment of safeguard zones, buffer zones etc) 

KTM14 - Research, improvement of knowledge 
base reducing uncertainty 

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). 

KTM17 - Measures to reduce sediment from soil 
erosion and surface run-off 

KTM18 - Measures to prevent or control the 
adverse impacts of invasive alien species and 
introduced diseases 

KTM19 - Measures to prevent or control the 
adverse impacts of recreation including angling 

KTM2 - Reduce nutrient pollution from agriculture 

KTM20 - Measures to prevent or control the 
adverse impacts of fishing and other 
exploitation/removal of animal and plants 

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 

KTM3 - Reduce pesticides pollution from 
agriculture. 
KTM4 - Remediation of contaminated sites 
(historical pollution including sediments, 
groundwater, soil) 

National 
basic 
measures 

National 
supplementary 
measures 

Number of 
RBDs where 
reported 

2 

1 

5 

18 

4 

3 

1 

2 

2 

5 

3 

7 

2 

3 

3 

1 

4 

4 

4 

3 

4 

4 

3 

4 

3 

3 

4 

4 

4 

4 

1 

3 

4 

4 

3 

3 

2 

2 

1 

7 

13 

7 

7 

1 

1 

2 

9 

2 

9 

1 

6 

4 

1 

134 

 
 
 
 
 
Key Type of Measure 

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 
KTM8 - Water efficiency, technical measures for 
irrigation, industry, energy and households 
KTM9 - Water pricing policy measures for the 
implementation of the recovery of cost of water 
services from households 
Total number of Mapped Measures 

National 
basic 
measures 

National 
supplementary 
measures 

Number of 
RBDs where 
reported 

3 

2 

8 

12 

2 

105 

2 

6 

8 

4 

82 

4 

4 

4 

4 

4 

4 

Source: Member States reports to WISE 

Table 9.2 

Type of basic measure mapped to Key Type of Measures in Bulgaria  

Basic Measure Type 

n
o
i
t
u
l
l
o
p
l
a
t
n
e
d
i
c
c
A

n
o
i
t
c
a
r
t
s
b
a
r
e
t
a
w
s
l
o
r
t
n
o
C

r
e
t
a
w
y
r
e
v
o
c
e
r

t
s
o
C

s
e
c
i
v
r
e
s

e
s
u
r
e
t
a
w

t
n
e
i
c
i
f
f

E

s
d
r
i
B
r
o
s
t
a
t
i
b
a
H

y
g
o
l
o
h
p
r
o
m
o
r
d
y
H

D
E
I
C
P
P
I

s
e
t
a
r
t
i

N

r
e
h
t
O

e
s
u
f
f
i
d
s
t
n
a
t
u
l
l
o
P

t
c
e
r
i
d
s
t
n
a
t
u
l
l
o
P

r
e
t
a
w
d
n
u
o
r
g

r
e
t
a
w
n
o
i
t
c
e
t
o
r
P

n
o
i
t
c
a
r
t
s
b
a

s
e
g
r
a
h
c
s
i
d
e
c
r
u
o
s

t
n
i
o
P

2 

n
o
i
t
a
t
n
e
m
g
u
a
e
g
r
a
h
c
e
R

s
r
e
t
a
w
d
n
u
o
r
g

s
e
c
n
a
t
s
b
u
S
y
t
i
r
o
i
r
P
e
c
a
f
r
u
S

r
e
t
a
W

e
t
s
a
W
n
a
b
r
U

1 

2 

2 

2 

3 

1 

1 

1 

1 

7 

4 

3 

5 

1 

4 

1 

6 

1 

1 

1 

Key Type of Measure 

KTM1 - Construction or 
upgrades of wastewater 
treatment plants 
KTM10 - Water pricing 
policy measures for the 
implementation of the 
recovery of cost of water 
services from industry 
KTM11 - Water pricing 
policy measures for the 
implementation of the 
recovery of cost of water 
services from agriculture 
KTM12 - Advisory services 
for agriculture 
KTM13 - Drinking water 
protection measures (e.g. 
establishment of safeguard 
zones, buffer zones etc) 
KTM14 - Research, 
improvement of knowledge 
base reducing uncertainty 

135 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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). 
KTM17 - Measures to reduce 
sediment from soil erosion 
and surface run-off 
KTM18 - Measures to prevent 
or control the adverse impacts 
of invasive alien species and 
introduced diseases 
KTM19 - Measures to prevent 
or control the adverse impacts 
of recreation including 
angling 
KTM2 - Reduce nutrient 
pollution from agriculture 
KTM20 - Measures to prevent 
or control the adverse impacts 
of fishing and other 
exploitation/removal of 
animal and plants 
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 
KTM24 - Adaptation to 
climate change 

KTM3 - Reduce pesticides 
pollution from agriculture. 
KTM4 - Remediation of 
contaminated sites (historical 
pollution including sediments, 
groundwater, soil) 
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 
KTM8 - Water efficiency, 
technical measures for 
irrigation, industry, energy 

1 

2 

2 

1 

4 

1 

4 

2 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

2 

1 

2 

1 

2 

2 

1 

1 

1 

1 

1 

1 

3 

2 

5 

1 

1 

2 

2 

1 

1 

1 

1 

1 

1 

3 

1 

1 

1 

4 

6 

2 

1 

2 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

2 

1 

1 

2 

1 

1 

3 

1 

1 

1 

1 

1 

1 

1 

2 

1 

1 

2 

1 

1 

1 

1 

3 

1 

2 

2 

3 

5 

6 

1 

1 

8 

9 

136 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
and households 

KTM9 - Water pricing policy 
measures for the 
implementation of the 
recovery of cost of water 
services from households 

Key 

2 

Source: Member States reports to WISE 

‘Urban Waste Water’ = Urban Waste Water Treatment Directive (91/271/EEC) . 
‘Nitrates’ = Nitrates Directive (91/676/EEC) . 
‘IPPC IED’ = Integrated Pollution Prevention Control Directive (96/61/EC) and the Industrial Emissions Directive 
(2010/75/EU) . 
‘Habitats or Birds’ = Habitats Directive (92/43/EEC)  or Birds Directive (2009/147/EC)  
‘Cost recovery water services’ = Article 11(3)(b): Measures for the recovery of cost of water services (Article 9). 
‘Efficient water use’ = Article 11(3)(c): Measures to promote efficient and sustainable water use. 
‘Protection water abstraction’ = Article 11(3)(d): Measures for the protection of water abstracted for drinking water (Article 
7) including those to reduce the level of purification required for the production of drinking water. 
‘Controls water abstraction’ = Article 11(3)(e): Controls over the abstraction of fresh surface water and groundwater and 
impoundment of fresh surface waters including a register or registers of water abstractions and a requirement for prior 
authorisation of abstraction and impoundment. 
‘Recharge augmentation groundwaters’ = Article 11(3)(f): Controls, including a requirement for prior authorisation of 
artificial recharge or augmentation of groundwater bodies. 
‘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. 
‘Hydromorphology’ = Article 11(3)(i): Measures to control any other significant adverse impact on the status of water, and 
in particular hydromorphological impacts. 
‘Pollutants direct groundwater’ = Article 11(3)(j): Prohibition of direct discharge of pollutants into groundwater. 
‘Surface Priority Substances’ = Article 11(3)(k): Measures to eliminate pollution of surface waters by Priority Substances 
and to reduce pollution from other substances that would otherwise prevent the achievement of the objectives laid down in 
Article 4. 
‘Accidental pollution’ = Article 11(3)(l): Any measures required to prevent significant losses of pollutants from technical 
installations and to prevent and/or reduce the impact of accidental pollution incidents. 
‘Other’ = Other Directives mentioned in Part A of Annex VI of the WFD. 

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. 

137 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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. 

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 first cycle 

The level of implementation of the first cycle of Programme of Measures in all 4 RBDs was 
reported as “some measures completed”. The obstacles to implementation reported in all RBDs 

are delays, lack of finance and changes in surface water body delineation in all RBDs, and a 
lack  of  mechanism  in  all  RBDs  with  the  exception  of  the  Danube.  A  large  number  of 

significant  pressures  have  been  identified  and  many  (but  not  all)  are  being  addressed  with 
measures. New legislation or regulations to implement the Programme of Measures in the first 

cycle  was  reported  necessary  and  already  adopted  in  all  RBDs.  No  further  information  was 
provided in the RBMPs. 

9.3  

Progress with Commission recommendations 

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

requested action on the following: 

138 

 
 
  Recommendation: Review the pressures and impacts analysis and status assessment in 
a  consistent  manner  across  all  RBDs  in  the  second  RBMP  and  ensure  that  the 
measures  are  based  on  the  updated  pressures  and  impacts  analysis  and  status 

assessment of water bodies. 

Assessment: A large number of significant pressures have been reported and many (but 

not all) seem to be addressed with measures.  In the programme of measures, for each 
KTM  there  are  linked  national  measures,  which,  for  their  part,  contain  one  or  more 

specific  actions  for  the  application  of  the  measure.  Further  examination  of  RBMPs 
found  that  only  the  Black  Sea  RBD  seems  to  have  addressed  this  recommendation 

fully.  The  East  Aegean  RBD  has  not  identified  the  expected  results  of  the  measures, 
and  the  West  Aegean  RBD  has  not  identified  water  body  specific  objectives.  No 

information could be found for the Danube RBD. It should be noted that this was not 
explicitly  presented  in  the  RBMP,  but  information  was  found  in  the  Annexes.  This 

recommendation has been partially fulfilled. 

  Recommendation: Ensure that the RBMPs clearly identify the gap to good status, and 
that  the  Programme  of  Measures  is  designed  and  implemented  to  close  that  gap. 
Exemptions should be adequately justified at water body level.  

Assessment:  No  gap  analyses  have  been  completed  for  any  RBD  and  Bulgaria  has 
reported in the Annex 0 that “due to the significant number of water bodies assessed in 

“unknown”  ecological  and/or  chemical  status,  it  is  not  possible  to  assess  the  level  of 
significance of the different pressure types and to evaluate the extent of the pressure or 

chemical substance that is to be reduced to achieve the Environmental Objectives; and 
It  is  not  possible  to  estimate  and  report  the  expected  value  of  the  indicator”61.  This 
recommendation has not been fulfilled. 

61  Bulgaria subsequently noted the additional difficulties that arose as a result of the significant re-delineation of 

water bodies. 

139 

 
 
 
                                                      
Topic 10 Measures related to abstractions and water scarcity  

10.1. Assessment of implementation and compliance with WFD requirements 

in second cycle 

10.1.1. Water exploitation and trends 

Water abstraction pressures are reported as not relevant for Bulgaria; however, all RBDs face 
water quantity-related problems. The Black Sea and West Aegean RBDs do not achieve good 

quantitative status for 5 % and 15 % of ground water bodies, and water abstraction pressures 
significantly  affect  23,  23  and  29  %  of  surface  waters  in  the  Danube,  Black  Sea  and  East 

Aegean  RBDs  respectively.  The  self-assessment  does  not  appear  consistent  with  these  water 
body-related data. The Water Exploitation Index + has not been reported62; but water quantity 
data  have  been  reported  to  support  the  European  State  of  the  Environment  Report.  Water 
scarcity  is  not  considered  an  issue  at  the  international  level.  The  RBMPs  include  no  water 

resource allocation and management plan.  

10.1.2. Main uses for water consumption  

No  data  have  been  reported63  for  the  uses  of  water  consumption,  because  water  quantity 
pressures are not reported as significant. However, significant water abstraction pressures are 

registered in all RBDs.  

10.1.3. Measures related to abstractions and water scarcity  

Regarding  basic  measures  (Article  11(3)(e)),  there  is  a  concession,  authorisation  and/or 
permitting  regime  to  control  water  impoundment  and  a  register  of  impoundments;  and  small 

abstractions are exempted from these controls; there is also an authorisation regime to control 
water abstractions in all RBDs. Measures promoting efficient and sustainable water use (Basic 

Measure Article 11(3)(c)) were implemented in the previous cycle in all RBDs except the West 
Aegean RBD64, and new measures and/or significant changes are planned for the second cycle, 
except  the  East  Aegean  RBD.  Given  the  high  figures  of  water  abstraction  pressures,  further 
assessment may be required on the expected impact of the new basic measures. 

62   Bulgaria subsequently clarified that on the basis of the calculated WEI +, the pressure from water abstraction is 
not considered significant. Important pressures from water abstraction have been assessed in individual water 
bodies or parts of water bodies. Relevant information can be found in section 6 of the RBMPs. In addition, an 
operational water abstraction index is calculated for groundwater bodies.  

63   Bulgaria clarified that data on water consumptions can be found on sections 2, 4 and 6 of the RBMPs.  
64   Bulgaria clarified that KTM 8 on water efficiency was reported in the previous cycle for West Aegean.  

140 

 
                                                      
Measures  for  the  prior  authorisation  of  artificial  recharge  or  augmentation  of  groundwater 

bodies (Article 11(3)(f)) have been implemented in the previous cycle in all RBDs except the 
West Aegean RBD, and new measures and/or significant changes are planned for the second 
cycle, except the East Aegean RBD65. 

Complementary measures under KTMs are reported for addressing abstraction pressures, with 

a varied approach for the different RBDs, which might be due to lack of coordination: KTM9 – 
“Water  pricing  policy  measures  for  the  implementation  of  the  recovery  of  cost  of  water 

services  from  households”  and  KTM10  –  “Water  pricing  policy  measures  for  the 
implementation of the recovery of cost of water services from industry” for the Black Sea and 

East Aegean RBDs, and KTM11 – “Water pricing policy measures for the implementation of 
the  recovery  of  cost  of  water  services  from  agriculture”  for  the  Danube,  Black  Sea  and  East 

Aegean RBDs. KTM12 – “Advisory services for agriculture” is planned for the Danube RBD, 
KTM13 – “Drinking water protection measures (e.g. establishment of safeguard zones, buffer 

zones etc.)” for the East Aegean RBD, KTM21 – “Measures to prevent or control the input of 
pollution  from  urban  areas,  transport  and  built  infrastructure,  for  groundwater  related 
pressures” in the Black Sea RBD, and KTM24 – “Adaptation to climate change” for the East 

Aegean  RBD.  No  information  is  reported  regarding  when  the  existing  gaps  will  be  closed. 
Bulgaria reports that it is not possible to quantify the pressures that are to be reduced and the 

scale of measures still needed for achievement of 100 % compliance. 

Water reuse was reported as a measure in all RBDs except the East Aegean RBD66.  

10.2. Main changes in implementation and compliance since first cycle 

Regarding  basic  measures  (Article  11(3)(e)),  there  is  a  concession,  authorisation  and/or 

permitting  regime  to  control  water  impoundment  and  a  register  of  impoundments;  and  small 
abstractions are exempted from these controls. Measures on this topic have been implemented 

in the previous cycle in all RBDs, and new measures and/or significant changes are planned for 
the 2016-2021 period, except the East Aegean RBD. 

10.3. Progress with Commission recommendations 

There  were  no  Commission  recommendations  based  on  the  first  RBMPs  and  Programme  of 

Measures. 

65   Bulgaria subsequently clarified that prior authorisation of artificial recharge is mandatory under the Water Act, 
regardless of whether it is intended as a measure in the RBMPs. Since there are no water shortages, there is no 
provision for such measure. 

66  Bulgaria clarified however, that this was a reporting error. 

141 

 
                                                      
Topic11 Measures related to pollution from agriculture  

11.1.  Assessment  of 

implementation  and 

compliance  with  WFD 

requirements in second cycle 

Pressures  related  to  agriculture  are  clearly  identified,  both  for  surface  and  groundwater.  For 

water  quality,  the  reported  pressures  are  organic  pollution,  nitrogen  and  phosphorus  from 
diffuse  sources  and  pesticides  from  diffuse  sources.  In  relation  to  water  quantity  over-

abstraction from surface water bodies is reported. Significant impact of engineering activities 
(bank  reinforcement,  dams,  flow  regulation,  weirs,  drainage  systems)  and  significant  soil 

erosion represent hydromorphological pressures.  

Overall it seems that these pressures have not changed significantly in the Danube, Black Sea 

and East  Aegean RBDs  since the first  RBMPs. In the first  cycle the West  Aegean RBD was 
not listed to be affected significantly by agriculture but this is the case in the second cycle.  

The Programme of Measures identifies a broad range of measures to address pressures arising 
from agriculture but the measures applied vary significantly across RBDs. Basic measures as 

defined  in  Article  11(3)(h)  for  the  control  of  diffuse  pollution  from  agriculture  at  source  are 
applied  only  in  Nitrate  Vulnerable  Zones  except  in  the  West  Aegean  RBD  where  the  same 

rules  apply  across  the  whole  RBD.  General  binding  rules  to  control  diffuse  pollution  are 
applied  for  nitrates,  organic  pollution  and  phosphorus  in  all  RBDs.  In  the  East  Aegean  and 

West Aegean RBDs, this applies also for pesticides. No information is provided on the area of 
agricultural land to be covered by measures to achieve the environmental objectives. 

Information has been reported on whether the measures are basic (the minimum requirement to 
be  complied  with)  or  supplementary.  KTM2  –  Reduce  nutrient  pollution  from  agriculture  is 

planned  in  all  four  RBMPs  and  refers  to  organic  methods  for  limiting  eutrophication  and 
reducing  nitrates  pollution.  Other  measures  include  ecological  practices  for  discharge  in 

groundwater bodies (Black Sea RBD), rules for the reuse of sewage sludge (Danube and Black 
Sea RBDs) and reducing pollution from mining activities (East Aegean RBD). These include 
both basic and supplementary measures. For supplementary measures information on whether 

the measures are mandatory or voluntary is not available either in WISE or in the RBMPs. 

The same KTM3 – “Reduce pesticides pollution from agriculture” measures have been planned 

in all four RBMPs. It refers to the protection of waters against pesticide pollution. KTM3 has 
both basic and supplementary measures in all RBDs, except the West Aegean RBD where they 

are only basic.  

142 

 
The same KTM12 – Advisory services for agriculture measures, also relevant for KTMs 2 and 

3, have been planned in three RBDs. KTM12 is not planned in the West Aegean RBD. KTM12 
refers  to  raising  the  awareness  of  agriculture  stakeholders  concerning  the  Good  Ecological 

Status of waters. KTM12 measures are only basic in the Black Sea RBD, only supplementary 
in the East Aegean RBD, and both basic and supplementary in the Danube RBD. 

The  main  KTM13  –  Drinking  water  protection  measures  (e.g.  establishment  of  safeguard 
zones,  buffer  zones  etc.),  planned  in  all  four  RBMPs,  refer  to  the  sanitary  safeguard  zones 

(bans or limitations of the activities that can be carried out in these zones or buffer zones) and 
protection of the surface water bodies that are used for drinking water. They are both basic and 

supplementary.  Other  measures  include:  update  of  the  normative  base  concerning  water 
management (Danube and Black Sea RBDs);  limiting all other use that can pose risks to  the 

drinking water supply (Danube, Black Sea and East Aegean RBDs); control and prevention of 
chemical,  biological  and  other  pollution  or  activities  that  can  pose  risks  to  the  quantity  or 

quality of the waters (Danube, East Aegean and West Aegean RBDs); studies and development 
of infrastructure for improvement of the drinking water supply  (Danube, Black Sea  and East 
Aegean RBDs). 

According  to  the  RBMPs,  safeguard  zones  have  been  established  in  all  4  RBDs  and  include 
safeguard  zones  for:  i)  waters  used  for  abstraction  of  drinking  water,  ii)  waters  used  for 

bathing, iii) waters sensitive to biogen elements (primarily nitrogen and phosphorus vulnerable 
zones  in  accordance  with  Directives  91/676/EEC  and  sensitive  areas  in  accordance  with 

91/271/EEC),  iv)  economically  valuable  fish  species  and  v)  protected  areas  related  to  the 
nature protection policies. In the process of updating the RBMPs the safeguard zones were also 

updated and in some RBDs this led to the designation of new safeguard zones. All 4 RBMPs 
include  KTMs  specifically  targeting  the  protection  of  safeguard  zones  for  waters  used  for 

abstraction  of  drinking  water.  These  measures  include  establishment  of  sanitary  safeguard 
zones around sources and facilities for drinking water, control of the sanitary safeguard zones 

and  safeguard  zones  for  drinking  water,  bans  or  limitations  on  investments  in  the  catchment 
areas of water bodies used for drinking water, banning of economic activities in dams used for 

drinking water, a ban of tree cutting in the catchment areas of water bodies for drinking water, 
control and prevention of pollution from chemical, biological and other substances. 

Farmers and Farmers' Unions have been consulted under the Public Consultation process in all 
RBDs.  The  information  available  concerning  the  public  consultation  of  the  draft  RBMPs 

suggests that consultation took place with the Ministry of Agriculture, the National Agriculture 
Fund, the regional directorates ‘Agriculture’, the public irrigation systems and the association 

of grain producers. 

143 

 
Financing  of  agricultural  measures  is  secured  in  all  RBDs.  While  in  the  first  RBMPs  very 

limited information on the funding resources and the costs associated with part of the measures 
was  provided,  these  have  been  included  in  the  second  RBMPs.  The  RBMPs  provide 

estimations for the potential financial contributions of different sectors (domestic, agriculture, 
industry  and  services)  in  the  second  cycle  for  the  financing  of  the  Programme  of  Measures. 

They  also  describe  the  sources  of  public  funding  for  financing  the  Programme  of  Measures: 
state  budgets,  private  investments  and  European  Structural  and  Investment  Funds.  In  the 

annexes  to  the  RBMPs  the  complete  Programme  of  Measures  per  RBD  provide  information 
about the funding source of each specific measure. 

11.2.  Main changes in implementation and compliance since first cycle 

Overall it seems that the situation as regards the pressures has not changed significantly in the 
Danube, Black Sea or the East Aegean RBDs. In the first RBMP, the West Aegean RBD was 

not  listed  to  be  affected  significantly  by  agriculture  but  this  is  the  case  in  the  second  cycle. 
While  in  the  first  cycle  very  limited  information  on  the  funding  resources  and  the  costs 

associated with part of the measures have been given, this is available in the second RBMPs. 

11.3  Progress with Commission recommendations 

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

 

Recommendation:  Ensure  coordination  between  water  and  agriculture  departments  to 
make  sure  that  developments  supported  by  these  investments  do  not  undermine  the 

achievement  of  WFD  objectives.  (Bulgaria  is  considering  significant  investment  in 
irrigation and drainage under the Rural Development Programme 2014-2021). 

Assessment:  Based  on  the  East  Aegean  RBMP,  it  appears  that  Good  Agricultural  and 
Environmental  Conditions  have  been  defined  with  an  ordinance  of  the  Minister  of 

Agriculture  and  to  support  their  implementation  ‘Guidance  for  practical  application  of 
the  conditions  for  maintaining  the  land  in  good  agricultural  and  ecological  condition’ 

was  issued  in  2010.  The  Rural  Development  Programmes  and  the  application  of 
Article 4(4)  are  not  mentioned  in  relation  to  the  measures,  the  Rural  Development 

Programmes are mentioned only as funding sources.  

Concerning irrigation, the RBMPs mention only that relevant KTM8 - “Water efficiency, 
technical  measures  for  irrigation,  industry,  energy  and  households”  measures  are 
planned.  Review  of  the  Programme  of  Measures  annexes  indicates  that  the  following 

144 

 
national measures are classified as KTM8 and are relevant for agriculture (other KTM8 

measures  are  more  aimed  at  industry  or  urban  areas):  i)  Improving  the  awareness  of 
stakeholders in the agriculture sector concerning the effective use of water (Danube and 

East Aegean RBDs); ii) Adoption/update of legislative or other regulatory documents in 
the  sphere  of  protection,  use  and  management  of  waters  (Danube  and  West  Aegean 

RBDs); iii) Ensuring the quantity of surface and groundwaters used is measured (Danube 
RBD);  iv)  Application  of  the  permitting  regime  in  accordance  with  the  Water  Law 

concerning  water  abstraction  from  surface  or  groundwaters  including  construction  of 
necessary facilities (Danube RBD). The main text of the Black Sea RBMP mentions that 

KTM8  measures 
‘reconstruction  of  hydromeliorative 

‘construction  of  new  hydromeliorative 

infrastructure’  and 
infrastructure’  will  address  pressures  from 

agriculture,  but  those  measures  were  not  found  in  the  Programme  of  Measures  annex. 
Therefore, this recommendation has partially been fulfilled. 

  Recommendation:  Agriculture  is  indicated  as  exerting  a  significant  pressure  on  the 
water resources in Bulgaria. 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 farming 

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  Common  Agricultural  Policy  funds  can 
adequately  set  up  Rural  Development  programmes  and  cross  compliance  water 

requirements. 

Assessment:  The  measures  are  listed  in  annexes  of  the  RBMPs  with  their  codes  and 

relevant  water  bodies.  However,  the  actions  taken  to  address  this  recommendation  are 
not discussed. Plans and strategies are just described and their impacts do not seem to be 

analysed in detail. Measures to address pollution from agriculture have been planned in 
all  RBMPs.  Article  11(3)(a),  Article  11(3)(b-l)  and  supplementary  measures  (Article 

11(4))  have  been  applied  but  no  gap  assessment  was  carried  out.  Both  basic  and 
supplementary measures have been planned for compliance with the Urban Waste Water 
Treatment Directive67 and for addressing pressures on water bodies from agriculture. The 
chapters  of  the  RBMPs  which  covers  the  Programme  of  Measures  focus  on  presenting 
the approach used for planning the measures in the second RBMPs (e.g. with information 

about  responsible  authorities,  funding  sources,  analysis  of  climate  change,  economic 

67  Council  Directive  91/271/EEC  of  21  May  1991  concerning  urban  waste-water  treatment  http://eur-

lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31991L0271  

145 

 
                                                      
analysis, etc.) rather than on discussing specific measures. However, information on the 

effectiveness and what will be achieved to close the gaps is not provided. Only the East 
Aegean RBMP presents some more details of the measures planned for specific pressures 

(all other RBMPs either mention generic measures or list the KTMs).  

Therefore, this recommendation has partially been fulfilled. 

  Recommendation:  Review  the  degree  to  which  the  existing  measures  to  implement  the 
Nitrates  Directive68  are  sufficient  to  address  agricultural  pressures  and  concentrate 
efforts on ensuring farmers understand their obligations in this regard and can finance 
the  necessary  investments.  Additionally,  Bulgaria  should  ensure  basic  measures  as  per 

Article  11(3)(h)  of  the  WFD  are  put  in  place  to  control  other  diffuse  pollutants  –  e.g. 
phosphate,  pesticides,  particulate  matter.  These  measures  should  be  specific,  have  a 

clear legal basis, and include appropriate advice, monitoring and inspection regimes to 
ensure their effective implementation. In addition to the basic measures, it should be set 

out clearly what supplementary measures will be needed to bridge the gap to good status 
and which of these measures will be included in the second Programme of Measures and 

what funding sources will be used to deliver these. Clear references to expectations for 
the  Rural  Development  Programs  in  this  regard  (and  to  other  funding  sources)  are 

expected. 

Assessment:  Basic  measures  as  defined  in  Article  11(3)(h)  for  the  control  of  diffuse 

pollution from agriculture at source are applied only in Nitrate Vulnerable Zones, except 
in  the  West  Aegean  RBD  where  the  same  rules  apply  across  the  whole  RBD.  General 

binding  rules  to  control  diffuse  pollution  are  applied  for  nitrates,  organic  pollution  and 
phosphorus in all basins. In the East Aegean and West Aegean RBDs this also applies for 
pesticides69. No information is provided on the area of agricultural land to be covered by 
measures to achieve the environmental objectives. 

Therefore, this recommendation has partially been fulfilled. 

68    Council  Directive  91/676/EEC  of  12  December  1991  concerning  the  protection  of  waters  against  pollution 
http://eur-lex.europa.eu/legal-
agricultural 

sources 

caused 
from 
content/EN/TXT/?uri=celex:31991L0676  

nitrates 

by 

69    Bulgaria subsequently clarified that this is also the case for the Danube Basin. 

146 

 
 
                                                      
Topic  12  Measures  related  to  pollution  from  sectors  other  than 
agriculture  

12.1.  Assessment  of 

implementation  and 

compliance  with  WFD 

requirements in 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  measure  (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  limited  to  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 Bulgaria. These KTMs include: 

KTM1- "Construction or upgrades of wastewater treatment plants" 

KTM4  -  "Remediation  of  contaminated  sites  (historical  pollution  including  sediments, 

groundwater, soil)" 

KTM7 - "Improvements in flow regime and/or establishment of ecological flows" 

KTM10  -  "Water  pricing  policy  measures  for  the  implementation  of  the  recovery  of  cost  of 
water services from industry" 

KTM12 - "Advisory services for agriculture" 

KTM13 -" Drinking water protection measures (e.g. establishment of safeguard zones, buffer 

zones etc.)" 

KTM14 - "Research, improvement of knowledge base reducing uncertainty" 

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” 

147 

 
KTM16  –  “Upgrades  or  improvements  of  industrial  wastewater  treatment  plants  (including 

farms)” 

KTM17 – "Measures to reduce sediment from soil erosion and surface run-off" 

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 Programme of Measures indicates that KTM15 measures are planned only in the Danube 

and  Black  Sea  RBDs.  They  include  both  basic  and  supplementary  measures,  and  measures 
relevant  to  preventing  pollution  of  both  surface  water  bodies  and  groundwater  bodies.  The 

Programme  of  Measures  does  not  indicate  which  sectors  or  sources  will  be  affected,  the 
geographic coverage of the measures or whether they are voluntary or mandatory. 

KTM16  measures  are  reported  in  all  four  Bulgarian  RBMPs,  and  in  all  cases  they  are  both 
basic and supplementary. The KTM16 measures reported are as follows:  

 

 

 

 

 

 

ensuring proper treatment  of industrial waste waters (Danube,  Black Sea, East 
Aegean RBDs); 

implementation of the procedure for review of issued permits for discharges of 
waste waters (Danube and Black Sea RBDs);  

reduction  of  the  pollution  from  mining  activities  (Danube  and  East  Aegean 
RBDs);  

reduction of the diffuse pollution from industrial activities (Danube RBD);  

application  of  a  permitting  regime  for  discharges  of  waste  waters  in  surface 
water bodies according to the Water Act (Danube RBD);  

change or cancellation of permits for discharges of waste waters based on their 
review (West Aegean RBD). 

Most of these measures  are  relevant  only for surface water bodies;  however the Danube and 
Black  Sea  RBMPs  indicate  that  some  of  the  KTM16  measures  are  relevant  also  for 

groundwater bodies. The Programme of Measures does not indicate which sectors or sources 

148 

 
will  be  affected,  the  geographic  coverage  of  the  measures  or  whether  they  are  voluntary  or 

mandatory. 

The  WFD  specifies  that  the  Programme  of  Measures  shall  include,  as  a  minimum,  “basic 

measures” and, where necessary to achieve objectives, “supplementary measures” when basic 
measures  are  not  enough  to  address  specific  significant  pressures  (see  the  chapter  9  in  this 

report).  

Quantitative information on basic and supplementary  measures used to  tackle pollution  from 

non-agricultural sources  (number of measures per KTM) has been provided for all Bulgarian 
RBDs. This includes information on basic measures in 10 KTM categories. All four Bulgarian 

RBMPs  contain  basic  measures  for  addressing  point  source  pollution  such  as  change  or 
cancellation  of  permits  for  discharges  of  waste  waters  based  on  their  review;  and  ensuring 

appropriate treatment of industrial waste waters.  

Bulgaria provided more targeted information on basic measures required under Article 11(3)(c 

to k). The use of an authorisation and/or permitting regime to control waste water point source 
discharges (Basic measures Article 11(3)(g)) was reported for three out of the four Bulgarian 
RBDs  for  surface  and  groundwater.  For  the  West  Aegean  RBD  the  use  of  an  authorisation 

and/or  permitting  regime  to  control  waste  water  point  source  discharges  was  reported  for 
surface water only. A register of waste water discharges (Basic measures Article 11(3)(g)) is 

available in three out of the four Bulgarian RBDs for surface and groundwater. For the West 
Aegean RBD a register of waste water discharges is available for surface water only. 

As regards thresholds below which waste water discharges do not require permits and are not 
subject to registration (Basic measure Article 11(3)(g)), small discharges are exempted in three 

out of the four Bulgarian RBDs, i.e. in all but the West Aegean RBD. Some direct discharges 
to  groundwater  are  authorised  in  accordance  with  Article  11(3)(j)  in  three  out  of  the  four 

Bulgarian RBDs. There is prohibition of all direct discharges in the West Aegean RBD. 

Bulgaria reported that there are measures in place to eliminate or reduce pollution from Priority 

Substances and other substances in all RBDs. 

12.2.  Main changes in implementation and compliance since first cycle  

In  the  first  RBMPs,  the  measures  provided  to  reduce  or  phase  out  the  emissions  of  Priority 
Substances and River Basin Specific Pollutants were formulated in a very general way and did 

not refer to any individual pollutants except nitrogen and phosphorus. 

149 

 
At present, according to information reported to WISE, there are measures in place to eliminate 

or  reduce  pollution  from  Priority  Substances  and  other  substances  (Basic  measures  Article 
11(3)(k))  in  all  RBDs.  Bulgaria  reported  to  WISE  that  KTMs  have  been  made  operational 

based  on  pressures  from  Priority  Substances  and  River  Basin  Specific  Pollutants  causing 
non-compliance, including KTM15 measures in two out of four RBDs. 

Concerning  measures  for  Priority  Substances  causing  failure,  according  to  information 
reported  to  WISE  the  Black  Sea  and  East  Aegean  RBDs  reported  that  mercury  and  its 

compounds cause failures of good status. However, all four RBDs reported Priority Substances 
that cause failure of good status, e.g. trichloromethane (Danube RBD), nickel (Danube RBD), 

cadmium (Danube, East Aegean and West Aegean RBDs), hexachlorobutadiene (the Black Sea 
RBD), octyphenol (the Black Sea RBD), mercury (the Black Sea and East Aegean RBDs) and 

lead (East Aegean and West Aegean RBDs). According to the information reported to WISE 
all  four  RBMPs  include  basic  measures  to  target  pollution  from  Priority  Substances,  even 

though only two include KTM15 measures. The descriptions of most measures provided in the 
annexes  with  the  Programme  of  Measures  do  not  refer  to  individual  Priority  Substances  but 
only to tackling such pollution in general. 

As far as measures for River Basin Specific Pollutants causing failure are concerned, according 
to  information  reported  to  WISE,  three  RBDs  reported  specific  pollutants  that  are  causing 

failure of good status and in all these RBDs relevant KTM measures are reported (e.g. KTM1, 
KTM  14,  KTM  21).  However,  the  descriptions  of  most  measures  (except  for  nitrates  and 

phosphates  from  agriculture)  provided  in  the  annexes  with  Programme  of  Measures  do  not 
refer to individual substances/pollutants but only to tackling such pollution in general. 

12.3.  Progress with Commission recommendations 

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

Measures: 

 

Recommendation:  “Identify  in  the  second  RBMP  a  solution  to  address  the  significant 

pressure  from  landfills,  and  commit  to  accelerating  the  implementation  of  measures  to 
comply with the Urban Waste Water Treatment Directive.” 

Assessment:  According  to  the  information  reported  to  WISE,  KTM4  measures  are  in 
place in three out of the four RBDs in Bulgaria. The following national  measures have 

been  classified  as  KTM4:  (i)  Reducing  the  pollution  from  past  activities  (Danube  and 
West Aegean RBDs) and (ii) Reducing the pollution from mining activities (Danube and 

150 

 
East Aegean RBDs). The actions mentioned for those measures are: (i) Development and 

implementation of programmes for limiting the pollution from past activities (including 
landfills)  (Danube  and  West  Aegean  RBDs);  (ii)  Re-cultivation  of  areas  polluted  by 

mining  activities  (Danube  and  East  Aegean  RBDs);  (iii)  Re-cultivation  of  areas 
impacted/disturbed by mining activities (Danube RBD). 

It therefore appears that the recommendation has been acted upon in relation to landfills 
for two of the four RBDs. 

As regards the Urban Waste Water Treatment Directive, KTM1 measures are particularly 
relevant  and  are  listed  for  all  four  of  the  RBDs,  with  reference  in  all  cases  to  point 

sources and in two RBDs also to diffuse sources as pressures. 

This recommendation is considered as partially fulfilled.  

 

Recommendation:  “Ensure  that  significant  point  and  diffuse  sources  of  chemical 
pollution are proactively identified and measures put in place to control them.” 

Assessment: According to the information reported to WISE, Bulgaria has put in place a 
number  of  KTM  measures  tackling  point  and  diffuse  sources  of  chemical  pollution.  In 

addition  to  KTM4  and  KTM1  mentioned  above,  KTM15,  KTM16,  KTM21,  KTM22, 
and KTM25, and two other KTMs (other basic and supplementary prevention measures 

and improvement of governance/management) are planned in Bulgarian RBMPs.  

As noted above, however, there is no substance-specific detail, therefore it is not possible 

to consider the recommendation as completely fulfilled. 

 

Recommendation:  “Prioritize  the  agglomerations  with  more  than  2000  population 

equivalent (p.e.) in terms of the WFD principles and of financing in the second RBMPs 
but  also  assess  the  pressures  due  to  waste water  from  small  agglomerations  (less  than 

2000 p.e.) in the second RBMP cycle.” 

Assessment: Measures to tackle urban point sources are reported in all 4 RBDs.  

The  following  national  measures  are  classified  as  KTM1:  Ensuring  collection, 
conveyance and treatment  of industrial waste waters, released in  water bodies (Danube 

and  East  Aegean  RBDs);  and  use  of  natural  methods  for  treatment  of  waste  waters 
(Danube  RBD).  The  Programme  of  Measures  mentions  a  large  variety  of  actions  for 

those measures, such as:  

151 

 
 

implementation  of  projects  for  construction,  reconstruction  or  modernisation  of 

sewage  systems  for  agglomerations  of  less  than  2000  population  equivalent 
including finishing the construction of sewage systems when there is a wastewater 

treatment  plant  or  ensuring  proper  treatment  (through  construction  of  wastewater 
treatment plants or transportation of waste to another wastewater treatment plants) 

when there is an existing sewage system (all RBMPs);  

 

ensuring conveyance and proper treatment of waste waters from urban areas with 

less  than  2000  population  equivalent  including  construction  of  proper  sewage 
systems,  wastewater  treatment  plants,  connection  to  larger  wastewater  treatment 

plants;  and  development  of  a  wet  zone  for  treatment  of  waste  waters  in 
agglomerations  of  less  than  2000  population  equivalent.  (Danube,  Black  Sea  and 

West Aegean RBDs);  

 

implementation  of  projects  for  construction,  reconstruction  or  modernisation  of 

sewage  systems  including  city  wastewater  treatment  plants  defined  for  specific 

agglomerations  over  2000  population  equivalent  according  to  the  national 
catalogue of measures (Danube, Black Sea and West Aegean RBDs);  

 

construction, 

reconstruction  or  modernisation  of 

sewage 

systems 

for 

agglomerations  of  over  2000  population  equivalent  (Danube,  Black  Sea  and  East 

Aegean RBDs). 

Each of the RBMPs provides an economic analysis of the Programme of Measures that 

provides  estimates  of  the  total  costs  of  the  Programme  of  Measures  together  with  the 
possible  sources  of  financing  and  expected  amounts  of  financing  from  each  source. 

Based  on  this  analysis  each  RBMP  provides  an  ‘indicative  financial  plan  of  projected 
financing’ for each year of the second cycle and per funding source. The financing of all 

measures  is  expected  to  come  from  a  combination  of  public  and  private  sources  (e.g. 
national  budget,  Operation  Programme  Environment,  water  users).  The  Programme  of 
Measures annexes list the sources of financing for each specific measure. For KTM1, the 
financing  sources  are  state  budget,  municipal  budget,  Operation  Programme 

Environment, the public water supply and sewage company, the Bulgarian Enterprise for 
Management of Environmental Protection Activities, and private investors). However, it 
is not explicitly mentioned in RBMPs if the funding is already ‘secured’ for each of the 

coming years. 

152 

 
Overall,  the  recommendation  appears  to  have  been  acted  upon  in  the  planning  of 

significant actions, but prioritisation of agglomerations is not mentioned in the RBMPs, 
and  it  is  not  clear  whether  funding  has  been  secured.  Thus,  the  recommendation  is 

considered partially fulfilled.  

 

Recommendation:  “Ensure  compliance  with  Article  5  of  the  Urban  Waste  Water 

Treatment Directive for more stringent treatment, especially in big cities.” 

Assessment:  Measures  to  tackle  urban  point  sources  are  reported  in  all  4  Bulgarian 

RBDs. Another example of an action relevant to the national measures classified as KTM 
1 is the introduction of a third stage of wastewater treatment for the removal of nitrogen 

and phosphorus (Danube and East Aegean RBDs). RBMPs do not indicate whether the 
planned measures will be sufficient to comply with Article 5 of the Urban Waste Water 

Treatment Directive. 

Therefore, the recommendation has been partly fulfilled. 

 

Recommendation: “[The identification of river basin specific pollutants needs to be more 
transparent, with clear information on how pollutants were selected, how and where they 

were  monitored,  where  there  are  exceedances  and  how  such  exceedances  have  been 
taken into account in the assessment of ecological status.] It is important that to take an 

ambitious  approach  to  combatting  chemical  pollution  and  that  adequate  measures  are 
put in place.” 

While Bulgaria has identified several KTMs as relevant to addressing the pressures from 
chemical  pollutants,  substance  specific  information  is  lacking.  Therefore,  the  extent  to 

which  the  measures  will  be  successful  is  difficult  to  judge.  Furthermore,  it  is  not  clear 
why KTM15 measures are not mentioned in the RBMPs for the East and West Aegean 

RBDs. The recommendation is considered partially fulfilled.  

153 

 
 
 
 
Topic 13 Measures related to hydromorphology  

13.1.  Assessment  of 

implementation  and 

compliance  with  WFD 

requirements in second cycle 

Significant  hydromorphological  pressures  and  operational  KTMs  to  deal  with  these  are 

reported  in  all  RBDs.  The  significant  hydromorphological  pressures  are  assigned  to  specific 
sectors.  Hydrological  alterations  are  mainly  related  to  hydropower.  Dams,  barriers  and  locks 

are  mainly  related  to  hydropower,  irrigation  and  flood  protection.  Physical  alterations  are 
mainly related to agriculture and flood protection. 

To  tackle  continuity  barriers,  mainly  KTM5  –  “Improving  longitudinal  continuity  (e.g. 
establishing fish passes, demolishing old dams)” and KTM6 – “Improving hydromorphological 

conditions of water bodies other than longitudinal continuity” are made operational; in 1 RBD 
(Black  Sea),  also  KTM10  –  “Water  pricing  policy  measures  for  the  implementation  of  the 

recovery  of  cost  of  water  services  from  industry”  and  KTM24  –  “Adaptation  to  climate 
change” are applied. To tackle significant physical alterations, KTM6, 23 and 24 are applied, 

while  for  significant  hydrological  alterations,  KTM6  –  “Improving  hydromorphological 
conditions  of  water  bodies  other  than  longitudinal  continuity”,  KTM7  –  “Improvements  in 

flow regime and/or establishment of ecological flows” and KTM14 – “Research, improvement 
of  knowledge  base  reducing  uncertainty”  are  applied.  For  hydrological  alterations  from 

aquaculture, also KTM19 – “Measures to prevent or control the adverse impacts of recreation 
including  angling”  and  KTM20  –  “Measures  to  prevent  or  control  the  adverse  impacts  of 

fishing and other exploitation/removal of animal and plants” are made operational. 

The measures listed in the Programme of Measures (annexes to the RBMPs) are rather broad. 

The  national  measures  identified  for  addressing  pressures  include  ensuring  the  continuity  of 
water  flows  and  fish  movement,  reconstruction  and  protection  of  river  banks  and  river  beds 

against  erosion,  ensuring  ecological  flow,  improving  the  hydromorphological  conditions  of 
rivers, 
the  assessment  of  hydromorphological  elements  for  quality  and 
hydromorphological  status,  reducing  the  erosion  of  the  catchment  area,  restoration  of  areas 

improving 

impacted by 'extraction of aggregate materials' (dredging), restoration of the natural condition 
of the bottom of lakes. Measures also include actions such as ban of 'extraction of aggregate 

materials'  (dredging)  of  less  than  50m  from  the  river  banks  and  ban  of  prolongation  of  the 
validity and/or change of existing permits for water abstraction from surface waters and/or use 

of water bodies with the purpose of energy production from hydropower plants which do not 
have a construction permit in accordance with the Law for Spatial Planning as of the date of 

154 

 
adoption of the RBMP. In addition, the Programme of Measures lists the more concrete actions 

that fall in the scope of each measure. 

In  terms  of  the  basic  measures  planned  to  tackle  hydromorphological  pressures,  there  is  an 

authorisation and/or permitting regime in place to control physical modifications in all RBDs, 
which covers changes to the riparian area of water bodies according to WFD Article 11(3)(i). 

There is also a register of physical modifications of water bodies. 

Overall management objectives in terms of restoring river continuity have been set in two out 

of four RBDs (Danube and West Aegean RBDs); in the Danube RBMP, these objectives are 
also quantitative. No such objectives are set for the other RBDs. 

Win-win  measures  in  terms  of  achieving  the  objectives  of  the  WFD  and  Floods  Directive70, 
drought  management  and  use  of  Natural  Water  Retention  Measures  are  included  in  the 

Programme  of  Measures  of  all  RBDs.  In  addition,  KTM23  –  “Natural  Water  Retention 
Measures”  has  been  made  operational  to  tackle  significant  hydromorphological  pressures  in 

three out of four RBDs (Danube, Black Sea and East Aegean RBDs). The national measures 
classified  as  KTM23  include  improving  the  natural  retention  of  water  and  measures  on 
drainage of wetlands/ wet zones. In general, Natural Water Retention Measures are not further 

discussed  in  any  of  the  RBMPs.  The  RBMPs  for  the  Danube  and  the  East  Aegean  RBDs 
mention  the  planned  Natural  Water  Retention  Measures  and  their  actions  only  in  relation  to 

flood  risk  management  and  synergies  with  the  Flood  Risk  Management  Plans  but  no  further 
details are provided. 

In addition, the design of new and existing structural measures, such as flood defences, storage 
dams and tidal barriers, is reported to have been adapted to take into account WFD objectives 

in all RBDs. 

Ecological  flows  have  been  derived  and  implemented  partly,  i.e.  for  some  relevant  water 

bodies, and only in one out of four RBDs (Danube) but the work is still on-going. In the other 
three  RBDs  (Black  Sea,  East  Aegean  and  West  Aegean),  no  ecological  flows  have  been 

derived but there are plans to do it during the second cycle. The Programmes of Measures for 
the Black Sea, East Aegean and West Aegean RBDs indicate that relevant measures will start 

in 2017-2018. 

70    Council  Directive  91/676/EEC  of  12  December  1991  concerning  the  protection  of  waters  against  pollution 
http://eur-lex.europa.eu/legal-
agricultural 

sources 

caused 
from 
content/EN/TXT/?uri=celex:31991L0676  

nitrates 

by 

155 

 
                                                      
The measure 'ensuring ecological flow' has been planned in all RBMPs and the Programmes of 

Measures  outline  specific  actions  that  this  measure  encompasses,  such  as  ensuring  the 
minimum  allowed  flow  in  rivers  after  facilities  for  water  abstraction  or  flow  control, 

optimising the water management of dams for ensuring water quantities of the ecological flow 
and achieving good ecological status/potential, ban of water abstraction in cases of low water 

(in accordance with the methodology for ecological flow). 

Concerning  the  level  of  ambition  for  tackling  significant  hydromorphological  pressures,  it  is 

not  possible  to  draw  specific  conclusions  as  indicators  on  the  gap  to  be  filled  for  significant 
hydromorphological  pressures  and  KTM  value  indicators  are  not  reported.  Due  to  the 

significant number of water bodies assessed in unknown ecological and/or chemical status, it is 
not possible for Bulgaria to quantify the pressure that is to be reduced or to assess the scale of 

measures still needed for achievement of 100 % compliance and to report the expected value of 
the KTM value indicators in 2015. 

13.2.  Main changes in implementation and compliance since first cycle 

The information on the links between the water use, the hydromorphological pressure and the 
measures has improved due to the improved WISE reporting linking KTM with pressures and 

specific sectors. These links were not considered and analysed in the first RBMPs. 

However,  no  change  is  noted  on  other  aspects,  for  example  on  the  assessment  of  progress 

expected  by 
in 
hydromorphological  pressures  and  achieving  the  environmental  objectives.  In  the  first  cycle 

the  hydromorphological  measures 

terms  of  closing 

the  gap 

in 

RBMPs,  no  assessment  of  the  expected  effects  was  carried  out  and  in  the  second  cycle,  no 
information  is  reported  on  the  extent  to  which  the  gap  will  be  closed  in  terms  of  tackling 

significant pressures. 

The  second  RBMPs  do  not  provide  information  about  differences  between  the  planned 

hydromorphological measures compared to the first RBMPs. However, all RBMPs provide a 
brief  summary  of  the  implementation  of  the  Programme  of  Measures  from  the  first  cycle. 

Although these summaries are rather general and less focused on specific measures, there are 
some examples of progress concerning hydromorphological measures, such as on the number 

of  constructed  or  reconstructed  fish  passes  and  number  of  negative  decisions  concerning 
permits or investment proposals. 

156 

 
13.3.  Progress with Commission recommendations 

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

 

Recommendation: Develop a proper methodology for establishing ecological flow linked 
with  good  ecological  status  in  the  second  RBMPs  and  ensure  this  ecological  flow  is 

applied through review of permits. 

Assessment: The measure 'ensuring ecological flow' has been planned in all RBMPs with 

specific  actions,  some  of  which  make  specific  reference  to  the  achievement  of  good 
ecological status and potential. No specific information was found that ecological flows 

in  the second RBMPs go beyond the already established 10 % or that ecological  flows 
will be applied through review of permits. 

Therefore,  it  is  concluded  that  the  recommendation  is  partially  fulfilled,  based  on  the 
information found as part of this assessment. 

 

Recommendation: Review all existing permits in all RBDs and where necessary, amend 
them to ensure that they are compatible with the WFD objectives.  

Assessment: The permitting systems are not explicitly discussed in the second RBMPs. 
However,  the  RBMPs  have  planned  different  hydromorphological  measures  to  address 

pressures from different sectors (including energy) including ban of prolongation of the 
validity  and/or  change  of  existing  permits  for  water  abstraction  from  surface  waters 

and/or  use  of  water  bodies  with  the  purpose  of  energy  production  from  hydropower 
plants which do not  have a construction permit  in  accordance with  the  Law for Spatial 

Planning as of the date of adoption of the RBMP. This measure is explicitly reported for 
the Danube RBMP. 

Other  relevant  references  in  the  RBMPs  and  especially  the  Programme  of  Measures 
include measures on the introduction of a condition in the permits for water abstraction 

and/or  use  of  water  bodies  for  compulsory  monitoring  by  the  holder  of  the  permits  to 
assess the ensuring of continuity of the river and the overall hydromorphological impact. 

The  second  RBMP  of  the  Black  Sea  RBD  also  mentions  the  implementation  of  a 
procedure for review of issued permits for water abstraction from surface water bodies, 

while the RBMP of the East Aegean RBD indicates a ban on issuing permits for water 
abstraction  by  hydropower  plants  in  the  areas  for  protection  of  economically  valuable 

fish species and other water organisms. 

157 

 
Overall,  based  on  the  information  found,  some  progress  is  noted  with  respect  to  this 

recommendation. 

 

Recommendation: Implement measures to mitigate the effects of navigation and related 

activities in the Black sea RBD. 

Assessment: Both the Danube RBD and the Black Sea RBD have made specific KTMs 

operational  to  address  significant  hydromorphological  pressures  from  the  navigation 
sector.  In  particular,  in  the  Danube  RBD,  KTM7  is  applied  to  tackle  hydrological 

alterations  from  transport  and  in  the  Black  Sea  RBD,  KTM6  and  24  are  applied  to 
address  physical  alterations  from  navigation  and  KTM6  and  KTM5  are  applied  to 

address continuity barriers from navigation. In the Black Sea RBD, no specific KTM are 
made  operational  to  tackle  hydrological  alterations  from  transport;  however,  this  is 

identified as a significant pressure only for one single coastal water body. 

Based  on  the  information  found  in  the  second  RBMPs,  this  recommendation  has  been 

fulfilled. 

 

Recommendation: Consider and prioritise the use of green infrastructure and/or natural 

water retention measures that provide a range of environmental (improvements in water 
quality, flood protection, habitat conservation etc.), social and economic benefits which 

can be in many cases more cost-effective than grey infrastructure. 

Assessment: KTM23 – “Natural Water Retention Measures” has been made operational 

to  tackle significant  hydromorphological  pressures in  three out  of four RBDs (Danube, 
Black  Sea  and  East  Aegean).  In  general,  Natural  Water  Retention  Measures  are  not 

further discussed in any of the RBMPs. The RBMPs for the Danube RBD and the East 
Aegean RBD mention  the planned Natural  Water Retention  Measures and their actions 

only  in  relation  to  flood  risk  management  and  synergies  with  the  Flood  Risk 
Management Plans but no further details are provided. No information was found in the 

second RBMPs  on prioritisation of the implementation  of Natural  Water Retention  and 
green infrastructure measures compared to grey infrastructure. 

This recommendation is partially fulfilled. 

158 

 
Topic 14 Economic analysis and water pricing policies  

14.1.  Assessment  of 

implementation  and 

compliance  with  WFD 
requirements in second cycle and main changes in implementation and 
compliance since first cycle 

A  broad  definition  of  water  services  is  used  in  the  second  cycle,  in  all  RBDs  uniformly 
according to a common national approach. The water services defined are: 

1.  Public water supply (drinking and irrigation); 
2.  Public conveyance of waste water (sewage); 
3.  Public waste water treatment; 
4.  Own water supply in the industry; 
5.  Own water supply in agriculture for irrigation; 
6.  Own water supply in agriculture for livestock and aquaculture;  
7.  Production of hydropower; 
8.  Flood prevention (sometimes noted as "protection from the harmful effects of water"); 
9.  Water storage; 
10. Navigation and related activities; 
11. Own water supply for drinking. 

For these 11 water services, cost recovery is analysed in all four RBDs. It is not explained if all 
activities creating significant pressures and which are not exempted according to Article 9(4) 
are considered water services. 

In  all  of  the  RBDs  five  groups  of  water  users  were  identified  as  being  "significant",  namely 
agriculture, industry, services, households and navigation. For these significant water uses, an 

economic analysis is provided in all RBMPs. 

With  regard  to  an  adequate  contribution  to  cost  recovery,  the  incentive  function  of  water 
pricing  and  the  Polluter  Pays  Principle,  the  Water  Act  (Article  192,  amended  in  2015)  and 
relevant legislation at the national level in Bulgaria are stated to cover these issues adequately, 

mainly by fees for water abstraction, use and pollution. 

The  environmental  and  resource  costs  have  been  calculated  but  they  are  not  considered 

significant.  Although  not  considered  significant,  the  environmental  and  resource  costs  are 
considered to be internalised, as stated in the RBMPs (through the fees defined in the tariffs for 

water abstraction, the use of a water source and water pollution, plus a correction coefficient).  

159 

 
 
The economic analysis is reported as updated. A series of national methodology and guidance 

documents  has  been  prepared  since  the  first  cycle.  These  common  national  approaches  were 
applied across all four RBMPs in the second cycle with regard to Article 9 issues. 

14.2.  Progress with Commission recommendations 

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

requested action on the following: 

 

Recommendation:  The  cost-recovery  should  address  a  broad  range  of  water  services, 

including  impoundments,  abstraction,  storage,  treatment  and  distribution  of  surface 
waters, and collection, treatment and discharge of waste water, also when they are "self-

services",  for  instance  self-abstraction  for  agriculture.  The  cost  recovery  should  be 
transparently presented for all relevant user sectors, and environment and resource costs 

should  be  included  in  the  costs  recovered.  Information  should  also  be  provided  on  the 
incentive  function  of  water  pricing  for  all  water  services,  with  the  aim  of  ensuring  an 

efficient use of water. Information on how the polluter pays principle has been taken into 
account should be provided in the RBMPs. 

Assessment: A broad definition of water services is used in the second cycle, in all RBDs 
uniformly according to a common national approach. The water services defined are: 

1.  Public water supply (drinking and irrigation); 
2.  Public conveyance of waste water (sewage); 
3.  Public waste water treatment; 
4.  Own water supply in the industry; 
5.  Own water supply in agriculture for irrigation; 
6.  Own water supply in agriculture for livestock and aquaculture;  
7.  Production of hydropower; 
8.  Flood  prevention  (sometimes  noted  as  "protection  from  the  harmful  effects  of 

water"); 

9.  Water storage; 
10. Navigation and related activities; 
11. Own water supply for drinking. 

For these 11 water services, cost recovery is analyzed in all four RBDs. The results of the cost 

recovery  analysis  are  presented  per  significant  water  user  and  per  water  service,  except  for 

160 

 
 
navigation.  Here,  it  is  stated  that  sufficient  quantitative  information  about  the  water  use  in 

navigation  was  not  available  and,  consequently,  quantitative  estimates  are  provided  only  for 
the other four types of significant water users (see below for the water users defined).  

It  is  not  explained  if  all  activities  creating  significant  pressures  and  which  are  not  exempted 
according to Article 9(4) are considered water services. 

While for the Danube and Black Sea RBDs, no use of Article 9(4) is indicated in WISE, in the 
West Aegean RBD, the use of Article 9(4) is indicated for drinking water and waste water. In 

the  East  Aegean  RBD,  the  same  two  services  are  exempted,  plus  also  flood  protection, 
irrigation,  self-abstraction and water storage. The reasons  for these differences across RBDs, 

and how they are explained is not detailed 

In all of the  RBDs,  five groups of water users  were identified as being  "significant", namely 

agriculture, industry, services, households and navigation. For these significant water uses, an 
economic analysis is provided in all RBMPs. 

With  regard  to  an  adequate  contribution  to  cost  recovery,  the  incentive  function  of  water 
pricing  and  the  Polluter  Pays  Principle,  the  Water  Act  (Art.  192,  amended  in  2015)  and 
relevant legislation at the national level in Bulgaria are stated to cover these issues adequately 

(the texts in the RBMPs are identical regarding this issue). 

The RBMPs explain that the regulation of efficient water use is ensured mainly by the fees for 

water  abstraction,  water  use  and  water  pollution  and  partly  by  the  introduction  of  norms  for 
water use in certain sectors where this is feasible. According to the tariffs for the fees for water 

abstraction, use of a water source and pollution, the different fees are formulated as follows: 

-  The water abstraction fees are determined on the basis of the annual water volume used (in 
cubic meters) multiplied by the individual fee. Different individual fees are established for 
surface and groundwater bodies and according to the purpose of the water use. The highest 

singular  water  abstraction  fees  are  applied  for  own  water  supply  (drinking  water  and 
everyday use) from groundwater sources with the goal of limiting this type of abstraction 

and stimulating the use of the public water supply services. 

-  There is a fee for using a water source and disrupting its continuity/flow, this fee is paid 

until a facility that restores the continuity/flow is put in place. 

-  The fee for release of pollutants to groundwater bodies is determined on the basis of the 
annual amount of discharged pollution, the chemical status of the groundwater body and 

161 

 
the individual fees for different types of pollutants. The maximum allowed concentration 

of typical pollutants established in the issued permit for discharge is taken into account in 
the  development  of  the  coefficients  for  the  chemical  status  of  the  groundwater  body  in 

each case.  

-  The fees for discharge of waste waters of urban type from sewage and industrial facilities 
in surface water bodies are calculated using correction coefficients that take into account 
the type of water body, the number of discharges and the level of treatment. 

-  The fees for discharges  from industrial facilities other than the urban type are calculated 
using  correction  coefficients  that  take  into  account  the  number  of  watchlist,  priority  and 

specific  substances  and  the  fee  for  urban  waste  waters  calculated  based  on  the  annual 
amount of urban waste water discharged into surface water bodies. 

-  The fees for pollution from  industrial waste waters other than the urban type released in 
sewage  systems  are  calculated  based  on  the  amount,  substances  and  parameters  of  the 

waste  waters  in  accordance  with  the  public  sewage  operator  and  correction  coefficients 
reflecting the type of in water body, number of discharges and level of treatment. 

-  The  fee  for  diffuse  pollution  from  agricultural  sources  is  determined  on  the  basis  of  an 
ordinance, proposed by the Minister of Agriculture and Food and agreed with the Minister 
of  Environment  and  Water,  which  determines  the  amount,  procedures  and  method  for 

calculation and payment of the fee. This fee is paid individually by the owner or user of 
the farm or by the person who releases crop protection products to the market.  

Furthermore,  the  Ordinance  on  the  norms  for  water  use  sets  optimal  water  amounts  for  the 
irrigation  of  crops  considering  the  irrigation  norms  of  the  different  crops,  the  different  agro-

climatic  conditions  in  the  country  and  the  different  types  of  irrigation.  The  aims  of  this 
ordinance  are  to  safeguard  the  quantitative  status  of  the  waters,  stimulate  efficient  water  use 

and ensure different water users contribute to the cost recovery of water services. The RBMPs 
state that these norms will be applied in  the process  of permit  issuance  for water abstraction 

and  the  calculation  of  the  annual  fees  for  water  abstraction  according  to  the  procedures  in 
Article 194 (6) of the Law on water for irrigation of crops. 

The  environmental  and  resource  costs  have  been  calculated  but  they  are  not  considered 
significant.  As  an  explanation,  it  is  stated  that  when  environmental  and  resource  costs  are 

included in  the  calculation of total  cost  recovery, the percentage of cost  recovery diminishes 
just a little in most cases, as the sum of the environmental and resource costs is much smaller 

than the sum of the financial costs (which is a product of the methodology applied).  

162 

 
The  different  RBMPs  provide  varying  degrees  of  details  as  to  the  national  methodology 

developed  on  the  basis  of  the  Common  Implementation  Strategy  Guidance  Document  No.  1 
"Economics  and  the  Environment  –  The  Implementation  Challenge  of  the  Water  Framework 

Directive" and applied for the calculation of the environmental and resource costs in all RBDs. 
According to the information provided in the East Aegean RBMP, the environmental costs are 

estimated based on the financial costs. The Danube RBMP provides a list of the different costs 
considered for each of the 11 water services in the analysis. It shows that environmental and 

resource costs have been identified and considered for all of the 11 water services except "own 
water supply in the industry", "water storage" and "own water supply for drinking". Similarly, 

resource  costs  have  been  identified  and  considered  for  all  11  water  services  except  "public 
conveyance  of  waste  water  (sewage)",  "public  waste  water  treatment",  "protection  from  the 

harmful effects of water", "water storage" and "navigation and related activities". In the East 
and West Aegean River basin Districts, environmental and resource costs are not calculated for 

self-abstraction. 

Although not considered significant, the environmental and resource costs are considered to be 
internalised,  as  stated  in  the  RBMPs  (through  the  fees  defined  in  the  tariffs  for  water 

abstraction, the use of a water source and water pollution, plus a correction coefficient).  

It remains unclear how environmental and resource costs are exactly calculated, and whether 

the arguments regarding their significance are valid or not. Because of these uncertainties, how 
the Polluter Pays Principle has been considered is similarly not entirely clear. Water services 

are  broadly  defined,  and  cost  recovery  rates  are  provided  for  most  of  them.  The 
recommendation is partially fulfilled. 

163 

 
 
 
Topic 15 Considerations specific to Protected Areas (identification, 
monitoring, objectives and measures) 

15.1. Assessment of implementation and compliance with WFD requirements 

in second cycle 

Bulgaria has reported Protected Areas of all types in the second RBMPs with respect to surface 
waters  (Table  15.1).  However,  only  Protected  Areas  designated  under  Article  7  of  the  WFD 

have  been  reported  to  be  associated  with  groundwater  bodies.  While  groundwater  bodies 
linked with groundwater dependent terrestrial ecosystems exist in all RBDs except the Black 
Sea  RBD71,  Protected  Areas  designated  under  the  Birds  or  Habitats  Directive  have  not  been 
identified.   

Table 15.1  Number of Protected Areas of all types in each RBD of Bulgaria, 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/EEC72 

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)73 

Number of Protected Areas associated with 

Rivers 

Lakes 

Transitional 

Coastal 

Groundwater 

197 

6 

156 

4 

90 

109 

12 

16 

18 

Protection of habitats or species where 

209 

16 

21 

18 

71     Bulgaria subsequently clarified that there  has been an error in reporting and the dependent ecosystems have 

also been identified in the Black Sea RBD. 

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 

73    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  

164 

 
 
 
 
 
 
 
 
                                                      
Protected Area type 

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)74 

Nutrient-sensitive areas, including 

areas designated as vulnerable zones 
under Directive 91/676/EEC (Nitrates 
Directive)75 and areas designated as 
sensitive areas under Directive 

91/271/EEC (Urban Wastewater 
Treatment Directive)76 

Number of Protected Areas associated with 

Rivers 

Lakes 

Transitional 

Coastal 

Groundwater 

18 

11 

5 

1 

5 

Areas designated for the protection of 
economically significant aquatic 

94 

9 

29 

species 

Other 

Source: Member States reports to WISE 

A good overview of the status (chemical and ecological and for ground water also quantitative) 

of water bodies associated with Protected Areas is reported (Figure 15.1); a large proportion of 
surface water bodies associated with Protected Areas have unknown chemical status. 

74  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  

75    Council  Directive  91/676/EEC  of  12  December  1991  concerning  the  protection  of  waters  against  pollution 
http://eur-lex.europa.eu/legal-
agricultural 

sources 

by 

caused 
from 
content/EN/TXT/?uri=celex:31991L0676  

nitrates 

76  Council  Directive  91/271/EEC  of  21  May  1991  concerning  urban  waste-water  treatment  http://eur-

lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31991L0271  

165 

 
 
 
 
 
 
 
 
 
 
                                                      
Figure 15.1   Status of water bodies associated with the Protected Areas reported for 

Bulgaria. Note: based on status/potential aggregated for all water bodies 
associated with all Protected Areas 

Source: WISE electronic reporting 

Bulgaria  has  set  additional  objectives  for  Protected  Areas  designated  under  the  Habitats  and 
Birds Directives where needed; in some Protected Areas it is reported that WFD objectives are 

sufficient to meet the requirements of the water dependent interest features of these Protected 
Area and so specific objectives have not been set. This suggests that the requirements in each 
Protected Area have been assessed separately to set the appropriate additional objective.  

No specific objectives have been set for shellfish Protected Areas and for most drinking water 

areas.  

The reported surface water monitoring programme covers all relevant types of Protected Areas 

(Table 15.2). The numbers of monitoring sites for each Protected Area type is consistent with 
the  numbers  of  Protected  Areas  in  each  type  suggesting  that  the  monitoring  programme  is 

166 

 
 
 
adequate in this regard.  For Protected Areas associated with groundwater bodies monitoring is 

reported  for  drinking  water  and  Nitrates  Directive  related  Protected  Areas  and  is  also 
proportionate to the numbers of Protected Areas reported.   

Table 15.2  Number of monitoring sites associated with Protected Areas in Bulgaria 

Protected Area type 

Abstraction of water intended for human 
consumption under Article 7 

Nutrient-sensitive areas, including areas 

designated as vulnerable zones under 
Directive 91/676/EEC (Nitrates Directive) 

Areas designated as sensitive areas under 
Directive 91/271/EEC (Urban Wastewater 
Treatment Directive) 

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) 

Recreational waters, including areas 
designated as bathing waters under 
Directive 76/160/EEC77 

Shellfish designated waters - WFD Annex 
IV.1.ii 

Number of monitoring sites associated with Protected Areas in 

Lakes 

Rivers 

Transitional  Coastal  Groundwater 

10 

317 

126 

10 

268 

5 

6 

112 

2 

326 

35 

20 

1 

112 

17 

10 

4 

90 

7 

Source: WISE electronic reporting 

All RBDs have implemented Safeguard Zones for the protection of Drinking Water Protected 

Areas. In three of the four RBDs, changes to these Safeguard Zones are planned for the current 
cycle of implementation. 

All  RBDs  have  reported  planned  measures  for  all  relevant  types  of  Protected  Areas.  The 
specific  measures  are  listed  either  in  the  general  Programme  of  Measures  or  specific 

Programmes  of  Measures  for  Protected  Areas  in  the  RBMP  annexes.  No  information  is 
reported on the magnitude of these measures and whether they will be sufficient  to  meet  the 

77    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 

167 

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
objectives  of the Protected Areas. The measures  described in  the RBMP and Programmes of 

Measures are mainly administrative, but to also include some physical measures.  

No exemptions have been made for surface water Protected Areas. 

For groundwater Drinking Water Protected Areas, exemptions have been made for 22% of the 
reported Protected Areas across two of the four RBDs. These exemptions are mainly based on 

technical feasibility and, in some cases, natural conditions. 

15.2.  Main changes in implementation and compliance since first cycle 

In  terms  of  the  numbers  of  Protected  Areas  designated,  only  the  number  of  Drinking  Water 

Protected Areas has changed since the first RBMP. This has decreased by around a third in the 
second cycle.  

The numbers of surface water monitoring sites for Habitat and Urban Waste Water Treatment 
Protected  Areas  have  decreased  significantly  in  the  second  cycle  compared  to  the  first.  The 

number of monitoring sites for other types of surface water and groundwater Protected Areas 
have not changed significantly.  

15.3.  Progress with Commission recommendations 

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

Measures requested action on the following: 

  Recommendation: Set more stringent objectives for all Drinking Water Protected Areas in 
the second RBMP cycle and complete the establishment of drinking water safeguard zones. 
These measures should be included in the Programme of Measures. 

Assessment: Objectives  for  groundwater Drinking Water Protected Areas have only been 
set in the West Aegean RBD. For surface water Drinking Water Protected Areas objectives 
have been set (and met) for all RBDs except the East Aegean RBD78. The recommendation 
has been fulfilled. 

78    Bulgaria  subsequently  clarified  that  reporting  errors  were  made.  Annex  5.3.2  Environmental  objectives  of 
areas for the protection of the protection of groundwater intended for drinking and domestic water supply are 
included in Tables 11 and 12, Section 5, paragraph 5.3.1, detailing the objectives of the areas for the protection 
of water intended for drinking and domestic water supply. 

168 

 
 
                                                      
Topic 16 Adaptation to drought and climate change 

16.1. Assessment of implementation and compliance with WFD requirements 

in second cycle 

Climate change was considered in various ways in all RBDs and it is stated that the guidance 

on  how  to  adapt  to  climate  change  (Common  Implementation  Strategy  Guidance  Document 
No.  24)  was  used.  All  RBDs  considered  climate  change  when  assessing  direct  and  indirect 

climate  pressures,  forecasting  the  economics  of  water  supply  and  demand  and  checking  the 
effectiveness  of  measures.  It  was  also  considered  in  flood  risk  management  and  detecting 

climate  change  signals.  The  East  Aegean  RBMP  also  addressed  climate  change  when 
monitoring change at reference sites.  

KTM24 – “Adaptation to climate change” is made operational to address significant pressures 
in  2  of  the  RBDs  (Black  Sea  and  East  Aegean)  and  national  measures  are  mapped  against 

KTM24.  KTM24  is  applied  to  tackle  abstractions  and  hydromorphological  pressures.  No 
specific sub-plans addressing climate change are reported.  

Bulgaria  reports  that  droughts  are  not  relevant  for  the  RBDs.  This  is  consistent  with  the 
situation in the first cycle (Topic report on: Assessment of Water Scarcity and Drought aspects 
in  a  selection  of  European  Union  RBMPs79)  when  there  was  no  clear  distinction  in  Bulgaria 
between droughts and water scarcity or the situation was unclear. 

No change has occurred in terms of the development of Drought Management Plans, which are 
not reported in comparison to the situation in the first cycle  (Topic report on: Assessment of 

Water  Scarcity  and  Drought  aspects  in  a  selection  of  European  Union  RBMPs),  when  there 
were no such plans or the situation was unclear. 

16.2.  Main changes in implementation and compliance since first cycle 

While  climate  proofing  of  measures  was  not  carried  out  in  the  first  cycle,  it  has  now  been 
considered in the second cycle. 

16.3.  Progress with Commission recommendations 

No recommendation was made by the European Commission regarding adaptation to climate 

change. 

79 http://ec.europa.eu/environment/water/quantity/pdf/Assessment%20WSD.pdf  

169