COMMISSION STAFF WORKING DOCUMENT First Flood Risk 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, disaster area, environmental risk prevention, flood, risk management, water, water management, watercourse

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 26.2.2019  SWD(2019) 66 final  COMMISSION STAFF WORKING DOCUMENT First Flood Risk 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) 39 final} - {SWD(2019) 40 final} - {SWD(2019) 41 final} - {SWD(2019) 42 final} - {SWD(2019) 43 final} - {SWD(2019) 44 final} - {SWD(2019) 45 final} - {SWD(2019) 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) 67 final} - {SWD(2019) 68 final} - {SWD(2019) 69 final} - {SWD(2019) 70 final} - {SWD(2019) 71 final} - {SWD(2019) 72 final} - {SWD(2019) 73 final} - {SWD(2019) 74 final} - {SWD(2019) 75 final} - {SWD(2019) 76 final} - {SWD(2019) 77 final} - {SWD(2019) 78 final} - {SWD(2019) 79 final} - {SWD(2019) 80 final} - {SWD(2019) 81 final} - {SWD(2019) 82 final} - {SWD(2019) 83 final} - {SWD(2019) 84 final}  
 
 
Table of contents 

Acronyms .................................................................................................................................... 3 

Introduction ................................................................................................................................. 4 

Overview ..................................................................................................................................... 5 

Overview of the assessment .................................................................................................... 6 

Good practices ....................................................................................................................... 12 

Areas for further development .............................................................................................. 14 

Recommendations ................................................................................................................. 15 

1. Scope of the assessment and sources of information for the assessment ............................. 16 

1.1  Reporting of the FRMPs ............................................................................................ 16 

1.2  Assessment of the FRMPs ......................................................................................... 16 

2. Integration of previously reported information ..................................................................... 17 

2.1  Conclusions drawn from the preliminary flood risk assessment................................ 17 

2.2 

Presentation of FHRMs in the FRMPs ....................................................................... 19 

2.3  Changes to the APSFRs or other Flood Risk Areas ................................................... 22 

2.4  Areas for further development in the earlier assessment of the FHRMs ................... 22 

2.5  Good practices and areas for further development in the FRMP regarding integration 
of previously reported information ....................................................................................... 22 

3. Setting of Objectives ............................................................................................................. 23 

3.1 

3.2 

Focus of objectives ..................................................................................................... 23 

Specific and measurable objectives ............................................................................ 24 

3.3  Objectives to reduce adverse consequences from floods ........................................... 24 

3.4  Objectives to address the reduction of the likelihood of flooding ............................. 25 

3.5 

Process for setting the objectives ............................................................................... 25 

3.6  Good practices and areas for further development regarding setting objectives ....... 25 

4. 

 Planned measures for the achievement of objectives ....................................................... 27 

4.1  Cost of measures ........................................................................................................ 27 

4.2 

Funding of measures .................................................................................................. 29 

4.3  Measurable and specific (including location) measures ............................................ 30 

4.4  Measures and objectives............................................................................................. 31 

4.5  Geographic coverage/scale of measures .................................................................... 31 

4.6 

Prioritisation of measures ........................................................................................... 31 

4.7  Authorities responsible for implementation of measures ........................................... 33 

4.8 

Progress of implementation of measures ................................................................... 34 

4.9  Measures taken under other Community Acts ........................................................... 34 

4.10  Specific groups of measures ....................................................................................... 34 

4.11  Recovery from and resilience to flooding .................................................................. 35 

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4.12  Monitoring progress in implementing the FRMPS .................................................... 36 

4.13  Coordination with the WFD ....................................................................................... 37 

4.14  Good practices and areas for further development with regard to measures ............. 39 

5. 

 Consideration of climate change ...................................................................................... 40 

5.1. Specific measures planned to address climate change ................................................... 41 

5.2. Good practices and areas for further development concerning climate change ............. 41 

6.  Cost-benefit analysis.......................................................................................................... 42 

6.1.  Good practices and areas for further development ..................................................... 43 

7.  Governance including administrative arrangements, public information and consultation44 

7.1. Competent authorities .................................................................................................... 44 

7.2. Public information and consultation .............................................................................. 44 

7.3. Active involvement of Stakeholders .............................................................................. 46 

7.4. Effects of consultation .................................................................................................... 49 

7.5. Strategic Environmental Assessment ............................................................................. 49 

7.6. Good practices and areas for further development regarding Governance .................... 50 

Annex A: 

Supplementary tables and charts on measures .................................................... 51 

Background & method .......................................................................................................... 51 

Types of measures used in reporting ..................................................................................... 52 

List of Annex A tables and figures........................................................................................ 53 

Measures overview ................................................................................................................ 54 

Measure details: cost ............................................................................................................. 57 

Measure details: name & location ......................................................................................... 57 

Measure details: objectives ................................................................................................... 59 

Timetable ............................................................................................................................... 61 

Measure details: authorities ................................................................................................... 61 

Measure details: progress ...................................................................................................... 64 

Measure details: other ........................................................................................................... 67 

Annex B:  Definitions of measure types .............................................................................. 68 

Catalogue of Natural Water Retention Measures (NWRM) ................................................. 69 

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Acronyms 

APSFR 
CBA 
EEA 
FD 
FHRM 
FRMP 
NGO 
NWRM 
PFRA 
PoM 
RBD 
RBMP 
SEA 
UoM 
WFD 
WISE 

Areas of Potential Significant Flood Risk 
Cost-Benefit Analysis 
European Environment Agency 
Floods Directive 
Flood Hazard and Risk Map 
Flood Risk Management Plan 
Non-Governmental Organisation 
Natural Water Retention Measures 
Preliminary Flood Risk Assessments 
Programme of Measures 
River Basin District 
River Basin Management Plan 
Strategic Environmental Assessment 
Unit of Management 
Water Framework Directive 
Water Information System for Europe 

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Introduction 

The Floods Directive (FD) (2007/60/EC) requires each Member State to assess its territory for 
significant  risk  from  flooding,  to  map  the  flood  extent,  identify  the  potential  adverse 

consequences  of  future  floods  for  human  health,  the  environment,  cultural  heritage  and 
economic activity in these areas, and to take adequate and coordinated measures to reduce this 

flood  risk.  By  the  end  of  2011,  Member  States  were  to  prepare  Preliminary  Flood  Risk 
Assessments (PFRAs) to identify the river basins and coastal areas at risk of flooding (Areas of 

Potential Significant Flood Risk – APSFRs). By the end of 2013, Flood Hazard and Risk Maps 
(FHRMs) were to be drawn up for such areas. On this basis, Member States were to prepare 

Flood Risk Management Plans (FRMPs) by the end of 2015.  

This  report  assesses  the  FRMPs  for  Bulgaria1.  Its  structure  follows  a  common  assessment 
template used for all Member States. The report draws on two main sources:   

  Member State reporting to  the European Commission on the FRMPs2 as per Articles 7 
and 15 of the FD: this reporting provides an overview of the plans and details on their 
measures. 

  The FRMPs: Bulgaria has four Units of Management (UoMs) and it reported an FRMP 

for each UoM. All four FRMPs are covered in this assessment. 

1  The  present  Member  State  assessment  reports  reflect  the  situation  as  reported  by  each  Member  State  to  the 
Commission in 2016 or 2017 and with reference to FRMPs prepared earlier. The situation in the Member States 
may have altered since then. 
2   Referred to as “Reporting Sheets” throughout this report. Data must be reported in a clear and consistent way 
by all Member States. The format for reporting was jointly elaborated by the Member States and the Commission 
as part of a collaborative process called the “Common Implementation Strategy”: 
http://ec.europa.eu/environment/water/water-framework/objectives/implementation_en.htm  
Whereas a  key role of the Commission is to check compliance  with EU legislation, the Commission also seeks 
information to allow it to determine whether existing policies are adequate. It also requires certain information to 
create a European-wide picture to inform the public. 

4 

 
 
 
 
                                                           
Overview 

Figure 1 

 Map of Units of Management/River Basin Districts 

  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 
Source: WISE, Eurostat (country borders) as presented in the 2012 RBMP assessment reports 

In  Bulgaria,  the  UoMs  designated  under  the  FD  are  identical  to  the  River  Basin  Districts 
(RBDs) under the Water Framework Directive (WFD). For each of the four UoMs (or RBDs) 

the responsible authorities are Basin Directorates, which prepared one FRMP per UoM.   

Water  policy  is  set  at  the  national  level  and  the  four  FRMPs  followed  nationally  approved 

methodologies  and  a  catalogue  of  objectives  and  measures.  The  content  of  the  FRMPs  is 
similar to the extent that they follow the national approach, however there are small differences 

5 

 
 
 
 
 
 
 
 
e.g. due to  the size of the UoMs, the presence of coastal  waters or other  specific  features of 
each  UoM.  Each  FRMP  is  accompanied  by  a  number  of  annexes  or  other  supporting 

documents such as maps, methodologies etc. The content of the annexes is similar across the 
FRMPs, but  the exact  number of  annexes differs per  FRMP as each  Basin  Directorate had a 

different  approach  in  grouping  maps,  tables  with  information  about  the  objectives,  measures 
and other detailed information. 

All FRMPs and the national programmes for their implementation were approved with special 
Decisions of the Council of Ministers in December 20163.  

Table 1 below gives an overview of all UoMs in Bulgaria, including the UoM code, the name, 

and the number of APSFRs reported. It also shows if the UoM reported all documents required 
to the European Environment Agency’s (EEA) Water Information System for Europe (WISE)4 
– the FRMP as a PDF and the reporting sheet as an XML.  

Table 1 

 Overview of UoMs in Bulgaria 

UoM 

BG1000 

BG2000 

BG3000 

BG4000 

TOTAL 

Name 

DANUBE 

BLACK SEA 

EAST AEGEAN 

WEST AEGEAN 

Number of 
APSFRs 

26 

45 

31 

14 

116 

XML Reported 

PDF Reported 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

The final version of the FRMPs can be downloaded from the following web pages:  

  Danube RBD/UoM: http://www.bd-dunav.org/content/upravlenie-na-vodite/upravlenie-

na-riska-ot-navodneniia/plan-za-upravlenie-na-riska-ot-navodneniia/  

  Black Sea RBD/UoM: https://www.bsbd.org/bg/page_purn_bsbd.html   

  East Aegean RBD/UoM: http://earbd.org/indexdetails.php?menu_id=611   

  West Aegean RBD/UoM: http://www.wabd.bg/index.php/2015-06-25-12-30-02/2016-

2021  

Overview of the assessment 

Table 2 below gives an overview of the evidence found during the assessment of the FRMPs. 
The following categorisation was used for the column concerning evidence: 

3   With  its  decisions  №1104  for  BG1000,  №1103  for  BG2000,  №1109  for  BG3000  and  №1105  for  BG4000, 
dated from 29th of December 2016, the Bulgarian Council of Ministers approved all FRMPs and the national 
programmes for their implementation. 

4   http://rod.eionet.europa.eu/obligations/603/deliveries?id=603&tab=deliveries&d-4014547-p=1&d-4014547-

o=2&d-4014547-s=3 

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  Evidence to the contrary: An explicit statement was found stating that the criterion was 

not met; 

  No evidence: No information found to indicate that the criterion was met; 

  Some evidence: Reference to the criterion is brief and vague, without a clear indication 
of  the  approach  used  for  the  criterion.  Depending  on  the  comment  in  the  adjacent 

column, “some evidence” could also be construed as “weak evidence”;  

  Strong  evidence:  Clear  information  provided,  describing  an  approach  followed  in  the 

FRMP to address the criterion. 

Table 2 

Overview of the evidence found during the assessment of the FRMPs 

Criterion 

Evidence 

Comments 

FRM objectives have been 
established 

Strong evidence 

FRM objectives relate to... 

...the reduction of potential 
adverse consequences 

Strong evidence 

Flood Risk Management objectives have been 
established in all four FRMPs based on five 
national priorities and 17 corresponding 
national objectives that constitute the 'national 
catalogue of objectives'. In most cases all 17 
national objectives were translated into UoM 
and ASPFR objectives considering the 
specific local characteristics of the area. When 
necessary, additional UoM or ASPFR-specific 
objectives were also developed. The 
objectives are grouped under five priority 
areas: 

1. Protecting human lives and public health; 

2. Higher level of protection of the critical 
infrastructure and businesses; 

3. Increasing the protection of the 
environment; 

4. Improving the preparedness and reactions 
of the population; 

5. Improving the administrative capacity for 
flood risk management. 

The objectives planned under the first three 
national priorities relate to the reduction of the 
potential adverse consequences of floods. 
They cover e.g. minimising the number of 
people hurt or impacted by floods, minimising 
the number of impacted social infrastructure, 
improving the protection of the technical 
infrastructure and important economic, 

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Criterion 

Evidence 

Comments 

...to the reduction of the 
likelihood of flooding 

Some evidence 

...to non-structural initiatives  Strong evidence 

cultural and historic sites, improving the 
protection of the sewage systems and 
industrial sites (mainly IPPC and SEVESO 
sites). 

The FRMPs state that this is not a separate 
priority but instead that it is integrated in the 
objectives under the other national flood 
protection priorities. 

The objectives planned under the last two 
national priorities relate to non-structural 
initiatives and administrative measures. They 
cover e.g. increasing the preparedness of the 
population in case of floods, improving the 
reactions of the population in case of floods, 
creating a modern normative base for 
territorial planning and FRM and ensuring the 
adequate reactions of the public institutions in 
case of floods. 

FRM objectives consider relevant potential adverse consequences to... 

...human health 

Strong evidence 

...economic activity 

Strong evidence 

...environment 

Strong evidence 

The objectives planned under the last two 
national priorities relate to non-structural 
initiatives and administrative measures. They 
cover e.g. increasing the preparedness of the 
population in case of floods, improving the 
reactions of the population in case of floods, 
creating a modern normative base for 
territorial planning and FRM and ensuring the 
adequate reactions of the public institutions in 
case of floods. 

The objectives planned under the national 
priority for higher level of protection of the 
critical infrastructure and businesses (priority 
2) specifically address the potential adverse 
effects on economic activity. There are two 
objectives: 2.1 Improving the protection of the 
technical infrastructure and 2.2 Improving the 
protection of important economic, cultural, 
and historic sites. 

The objectives planned under the national 
priority for increasing the protection of the 
environment (priority 3) specially focus on the 

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Criterion 

Evidence 

Comments 

...cultural heritage 

Strong evidence 

Measures have been... 

...identified 

Strong evidence 

...prioritised 

Strong evidence 

adverse consequences for the environment: 
3.1 Improving the protection of the sewage 
systems; 3.2 Improving the protection of 
industrial sites (mainly IPPC and SEVESO 
sites); 3.3 Minimising the impacted areas for 
protected waters, protected territories and 
protected zones; 3.4 Improving the water 
retention capabilities of agricultural, forest 
and coastal areas. 

The potential adverse effects on the cultural 
heritage are specifically addressed under the 
objectives of the national priority for higher 
level of protection of the critical infrastructure 
and businesses (see the row on economic 
activity above). 

In total 199 measures are reported across the 
four UoMs. The highest number of measures 
are reported for the East Aegean UoM 
(BG3000; 66 measures) followed by the 
Danube UoM (BG1000; 52 measures), the 
Black Sea UoM (BG2000; 49 measures) and 
the West Aegean UoM (BG4000; 32 
measures). Aggregated measures (66) are 
reported only for the East Aegean UoM, while 
individual measures (133) are reported only 
for the other three UoMs. However, Bulgaria 
does not specify the distinction between 
individual and aggregated measures. Measures 
are reported for all five aspects - prevention, 
protection, preparedness, recovery and review 
- and other. The most measures are reported 
for preparedness (61), prevention (60) and 
protection (53). 

Priority is reported for all measures. The 
majority of the measures are classified as 
'high' priority (107) and 'moderate' priority 
(36), while the fewest measures are classified 
as 'low' priority (10). Most of the prevention, 
protection and preparedness measures are 
ranked as 'high' priority followed by 
'moderate' and 'very high' priority.  

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Criterion 

Evidence 

Comments 

The prioritisation of the measures in all four 
FRMPs was based on the same methodology 
where the measures were analysed against five 
criteria: percentage of achieved objectives; 
urgency of the measure; cost of the measure; 
extent of problem solving (i.e. effectiveness); 
and timeline of implementation. 

Relevant aspects of Article 7 have been taken into account such as... 

...costs & benefits 

Strong evidence 

...flood extent 

Strong evidence 

...flood conveyance 

Some evidence 

...water retention 

Strong evidence 

...environmental objectives 
of the WFD 

Some evidence 

...spatial planning/land use 

Strong evidence 

A cost-benefit analysis (CBA) was used for 
the prioritisation and planning of all measures 
in all four of the FRMPs, based on a common 
national CBA methodology. 

The FRMPs contain summaries of the findings 
from the PRFAs and refer to the FHRMs, 
which show for several flood scenarios the 
geographical areas affected, the flood extent, 
water depths and flow velocity. 

According to the FRMPs this has been 
considered in the analysis and in the 
preparation of the programme of measures, 
but further details are not provided. 

According to the FRMPs this has been 
considered in the analysis and in the 
preparation of the programme of measures, 
and natural water retention measures 
(NWRMs) were included in all four FRMPs. 

To ensure compatibility and synergies 
between the FRMPs and the River Basin 
Management Plans (RBMPs), the analysis of 
the draft FRM measures included an 
assessment of the impacts of each draft 
measure on the objectives of the WFD and the 
needs for any exceptions in accordance with 
Art.4.7. Moreover, each of the FRMPs 
includes green infrastructure or NWRMs that 
are compatible with the objectives of the 
WFD. 

Spatial planning/land use measures are 
included in all four FRMPs. Most often these 
measures will remove illegal constructions, 
stored materials, fences or other objects in 

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Criterion 

Evidence 

Comments 

...nature conservation 

Strong evidence 

...navigation/port 
infrastructure 

No evidence 

...likely impact of climate 
change 

Some evidence 

Coordination with other 
countries ensured in the 
RBD/UoM 

Strong evidence 

Coordination ensured with 
WFD 

Strong evidence 

river beds and banks or impeding the water 
conveyance in the river beds or banks; and 
they will propose legislative measures for 
controlling construction in areas of flood risk 
or ban construction in areas of flood risk. 

Nature conservation is considered in all 
FRMPs as one of the five national priorities 
and corresponding national objectives concern 
environmental protection. Examples of 
specific measures from the four FRMPs 
include protection of wetlands or protected 
territories, reconstruction of wetlands, 're-
naturalisation' of rivers, protection of river 
coasts from erosion and afforestation. 

Ports and navigation do not seem to be 
included in the specific measures for any of 
the FRMPs. However, one of the five national 
priorities and corresponding national 
objectives concern the protection of critical 
infrastructure. Hence, it is possible that in 
some cases ports are considered critical 
infrastructure and addressed by general 
measures for protection of the critical 
infrastructure. 

According to the FRMPs this aspect has been 
considered in the analysis and in the 
preparation of the programme of measures, 
but only limited details are provided. 

Coordination with neighbouring countries 
took place at all steps of the FRMPs 
preparation (PFRA, APSFRs, FHRMs, draft 
programmes of measures (PoMs) and draft 
FRMPs) and the FRMPs provide details about 
specific meetings that took place and 
issues/topics that were covered at those 
meetings. 

The FRMPs and the RBMPs in Bulgaria are 
developed by the same authorities - the Basin 
Directorates. In addition, the national law 
requires the public consultations for both 
types of plans to be run in parallel so the 

11 

 
 
Criterion 

Evidence 

Comments 

Active involvement of 
interested parties 

Some evidence 

public consultations for each of the draft 
FRMPs and RBMPs for the 2016-2021 period 
were conducted in parallel. 

Each of the draft FRMPs was open for six-
month public consultations. The main 
mechanism for consultation was direct 
involvement in the preparation of the FRMPs 
through stakeholder meetings and meetings of 
the Basin Councils. The Basin Councils are 
multi-stakeholder advisory groups, which 
comprise of e.g. researchers, public 
administration, NGOs and water users, and 
support the Basin Directorates in their work. 

Good practices 

The assessment identified the following good practices in the Bulgarian FRMPs assessed 

Table 3 Good practices in the Bulgarian FRMPs 

Topic area 

Integration of previously 
reported information in the 
FRMP. 

Setting of objectives for 
the management of flood 
risk.  

Good practices identified 

The preparation of the APSFRs and the FHRMs followed a common 
national methodology and was coordinated with all neighbouring 
countries, even in the cases where no transboundary APSFRs were 
defined. 

The objectives in the FRMPs are based on a national catalogue of 
objectives. For each of the objectives, guidance is given on the 
priorities associated to objectives and how nine qualitative indicators 
can be used to set priorities. The indicators include applicability, 
economic effectiveness and likelihood to reduce the risk of floods. 
The objectives from the national ‘catalogue’ were translated into UoM 
or even APSFR objectives considering specific local characteristics. 
An Annex to each FRMP provides a version of the national catalogue 
of objectives specific for the UoM. Details on how the national 
catalogue has been tailored to the specific needs of an FRMP are 
unclear.  

In the FRMPs, the national indicators that will be used to assess the 
progress to achieving each of the objectives are described.  

The annexes to the FRMP for the Danube (BG1000) provide 
information how the objectives for each APSFR were set together 
with the level of confidence of the available information for each 
objective along three levels: low, medium and high confidence. 

In their annexes the FRMPs for the Black Sea (BG2000) and the East 

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Topic area 

Planning/implementing of 
measures and their 
prioritization for the 
achievement of objectives. 

Use of CBA in the FRMP 
assessed.  

Public participation.  

Flood risk governance.  

Good practices identified 
Aegean (BG3000) provide tables that not only describe the objectives 
from the national catalogue but also qualitatively assess their 
relevance to certain criteria (e.g. applicability, economic effectiveness, 
likelihood to reduce the risk of floods).  

The FRMP of the Black Sea UoM (BG2000) summarises the conflicts 
and synergies between the 17 national objectives. It is unclear how the 
trade-offs and synergies have been identified. 

All FRMPs provide information about the location, cost, responsible 
authority, priority and links to the WFD of each planned measure. In 
addition, this information is provided in a reader-friendly tabular 
format as annexes to the FRMPs. The prioritisation of all measures is 
based on a common national methodology. All FRMPs include 
NWRMs though they differ across the different UoMs.  

All FRMPs contain the national indicators for tracking progress 
towards achievement of the objectives (as explained above). The 
FRMPs for the Black Sea (BG2000), the East (BG3000) and West 
Aegean (BG4000) also define indicators for tracking the 
implementation of some of the planned measures (e.g. the measures 
for monitoring and control). The FRMP for the West Aegean 
(BG4000) goes one step further to define two separate indicators per 
planned measure - one for tracking implementation progress and one 
for tracking progress towards achieving the objectives. 

All FRMPs provide a description of the CBA methodology either in 
the main text or in Annexes. The methodology seems comprehensive 
and it is reported to be consistent with the Commission's 'Guide to 
CBA of Investment Projects: Economic Appraisal Tool for Cohesion 
Policy 2014 - 2020'. The applied CBA methodology was used to 
estimate the costs and benefits of all measures. 

All four FRMPs provide details about the public consultations in 
dedicated chapters often summarising the general stakeholder 
involvement strategy before describing the actions for consultation for 
the different steps of the FRMPs (i.e. PFRA, APSFRs, FHRMs). The 
information is detailed with references to locations and dates of the 
stakeholder meetings. In addition, each of the FRMPs includes an 
annex that summarises the changes to the PoMs resulting from the 
public consultations measure by measure.  

All four FRMPs also have dedicated chapters that summarise the 
results of the Strategic Environmental Assessments (SEAs). 
Furthermore, the public consultations for the draft FRMPs, their SEAs 
and the public consultations for the draft RBMPs run in parallel. 

The links between the FRMPs and the objectives of the WFD have 
been considered in all FRMPs. In addition to organising the public 
consultations of the FRMPs and the RBMPs at the same time, to 

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Topic area 

International issues in 
flood risk management.  

Good practices identified 
ensure compatibility and synergies between the plans, the analysis of 
the draft FRMP measures included an assessment of the impacts of 
each draft measure on the objectives of the WFD. Each of the FRMPs 
provides information (usually in annexes) about the identified 
synergies or impacts of the planned measures on the objectives of the 
WFD and the respective RBMPs (overall, conclusions are presented 
per type of measure from the national catalogue of RBMP measures 
or per water body/specific FRM measure).  

The authorities of the UoMs, i.e. the Basin Directorates, are 
responsible for the development of both the RBMPs and the FRMPs. 
In addition, each Directorate is supported in their work by Basin 
Councils that comprise a variety of stakeholders such as local, 
regional and national authorities, NGOs and public authorities for the 
drinking water and sewage systems. Other stakeholders can provide 
feedback through the public consultations as indicated above. 

Coordination with neighbouring countries took place at all steps of the 
FRMPs’ preparation (PFRA, APSFRs, FHRMs, draft PoMs and draft 
FRMPs) and dedicated chapters in the FRMPs summarise the 
outcomes of the coordination at each step with references to specific 
meetings (e.g. date and location) and concrete issues covered at those 
meetings. In addition to cooperation via meetings organised by 
International Commission for the Protection of the Danube River 
(ICPDR), bilateral meetings were held with Romania, Greece and 
with Bulgaria’s non-EU neighbouring countries: FYROM, Serbia and 
Turkey.  

Areas for further development 

The  assessment  identified  the  following  areas  for  further  development  in  the  Bulgarian  FRMPs 
assessed. 

Table 4  Areas for further development in the Bulgarian FRMPs 

Topic area 

Areas identified for further development 

Integration of previously 
reported information in the 
FRMPs. 

The reporting of the FHRMs was delayed and Bulgaria was not 
included in the preliminary EU study assessing the FHRMs.  

Although the FRMPs report that the results of the previous steps 
(PFRA, APSFRs and FHRMs) fed into the following steps and the 
preparation of the FRMPs, details are not provided. 

Setting of objectives for the 
management of flood risk.  

Overall, the FRMPs did not provide information about the 
timeline for achievement of the objectives 

Planning/implementation of 
measures and their 
prioritization for the 

Even though all FRMPs refer to the timely implementation of the 
measures and explain that the timelines will be considered when 
monitoring the progress of implementation, they do not report 

14 

 
 
Topic area 

Areas identified for further development 

achievement of objectives.   what the timeline for each measure or group of measures is. 

Although common national indicators for tracking progress to the 
national and UoM-specific objectives have been formulated, there 
is no information against what baseline values these indicators 
will be measured. 

While climate change is considered in the preparation of three of 
the four FRMPs, whereas in two of those even different scenarios 
were taken into account, the FRMPs do not explicitly relate the 
results of the climate change considerations to the measures 
planned e.g. to justify or explain the choice of measures. The 
national climate change adaptation strategy is under development. 
Nonetheless, all four FRMPs specify that climate change will be 
considered further in the update of the plans in the next period. 

The results of the CBA, measure by measure, are not presented in 
all FRMPs. Only the FRMPs for the Black Sea (BG2000) and the 
West Aegean (BG4000) provide annexes with the results of the 
CBA for all measures. Furthermore, it is unclear if and how the 
transboundary measures/effects have been considered in the CBA. 

The FRMPs do not include a list/summary of the types of 
stakeholders consulted during the public consultations, this 
information is available but scattered across the chapters on public 
consultation. 

Consideration of climate 
change in the FRMPs 
assessed.  

Use of CBA in the FRMPs 
assessed.  

Public participation. 

Recommendations 

Based on the reported information and the FRMPs, the following recommendations are made 
to enhance flood risk management (not listed in any particular order): 

  The application of previously generated information (on PFRA and FHRMs) towards the 
preparation of the FRMPs should be incorporated better, e.g. through providing concrete 

examples. 

  The elaboration of objectives and measures should be improved by clearly indicating the 
timeline  for  achievement  and  implementation.  The  baseline  values  against  which 
progress will be assessed, and which indicators will be tracked, should be considered.  

  The  second  cycle  FRMPs  should  provide  more  detail  on  how  climate  change 
considerations are addressed in the planned measures, including how these influence the 

selection  and  design  of  measures.  Coordination  between  the  Plans  and  the  national 
adaptation strategy should be ensured as soon as the strategy is adopted (and even before 

since it is still under development). 

  Providing  the  results  of  the  CBA,  measure  by  measure  where  possible  (e.g.  for 
prioritisation  of  measures  that  lend  themselves  to  it),  in  all  FRMPs  would  make  the 
FRMPs consistent amongst them. Furthermore, the FRMPs should clarify if and how the 

measures with transboundary effects have been considered in the CBA. 

15 

 
 
 
1. Scope of the assessment and sources of information for the 

assessment 

1.1 

Reporting of the FRMPs 

Bulgaria  has  reported  four  FRMPs,  one  for  each  of  its  four  UoMs.  In  addition,  other 

documents  have  been  reported  for  some  of  the  UoMs,  such  as  annexes  and  supporting 
documents. 

Bulgaria did  not  make use of Article 13(3) of the FD, which allows Member States to  make 
use of previous FRMPs (provided their content is equivalent to the requirements set out in the 

Directive).  

1.2 

Assessment of the FRMPs 

All  four  of  the  Bulgarian  FRMPs  have  been  assessed.  Each  FRMP  covers  one  of  Bulgaria’s 

four UoMs: 

Table 5 UoMs in Bulgarian National FRMPs 

UoM code 
BG1000 
BG2000 
BG3000 
BG4000 

UoM Name 
Danube 
Black Sea 
East Aegean 
West Aegean 

16 

 
 
 
 
 
2. Integration of previously reported information  

2.1 

Conclusions drawn from the preliminary flood risk assessment 

In  all  of  the  FRMPs,  the  conclusions  of  the  PRFA  are  provided  in  a  textual  description  and 

summary maps of the APSFRs (usually one map per UoM) are presented in the FRMPs.  

The  assessment  of  pre-existing  flood  risks  in  Bulgaria  was  undertaken  using  a  national 

methodology, approved by the Ministry of Environment and Water in July 2011. Although the 
structure  and  level  of  detail  of  the  PFRA  presentation  varies  across  the  four  UoMs,  they  all 
present  a  brief  description  of  the  assessment,  information  about  the  main  floods  and  their 

causes in the past, analysis of the potential floods in the future (e.g. causes and impacts) and 
designation of APSFRs. In the presentation of the conclusions of the PFRA, the FRMPs of the 

Black Sea (BG2000) and the East Aegean (BG3000) stand out as more detailed compared to 
the other two FRMPs. For example, the Black Sea FRMP provides a description of the national 

methodology  for  the  PFRA,  including  information  used  to  model  future  floods,  and  detailed 
description  of  the  significant  floods  in  the  past.  The  East  Aegean  FRMP  also  provides 

information  about  the  national  PFRA  methodology  and  its  annexes  contain  detailed  maps  of 
the past and potential future floods together with references and sources for the analysis5.  

In  addition  to  the  clear  references  to  the  APSFR  process  and  analysis,  all  FRMPs  indicate 
where all APSFR maps can be found. One map with all APSFRs per UoM is presented as an 

Annex  to  each  of  the  FRMPs.  However,  only  two  of  the  FRMPs  (BG1000  and  BG3000) 
contain  direct  weblinks  to  the  Basin  Directorates’  websites  where  all  relevant  APSFR 

information,  including  more  detailed  maps,  can  be  found.  One  FRMP  (BG4000)  explains  in 
the  text  that  more  detailed  maps  of  the  APSFRs  can  be  found  on  the  website  of  the  Basin 

Directorates but without providing direct weblinks. The Black Sea FRMP (BG2000) references 
only its own annexes that contain an overview  map and a list  of all APSFRs without further 
information  where  to  find  more  detailed  or  additional  APSFR  maps6.  A  quick  online  search 
suggests  that  detailed  maps  and  further  information  about  the  APSFRs  can  be  found  on  the 
websites of all Basin Directorates7. All four FRMPs state that the flood extent and conveyance 
routes were taken into account in the preliminary risk analysis (particularly in the PFRA) and 

5   FRMPs: BG1000, Chapter 2, pp.12-16 and Annexes 2 and 3; BG2000, Chapter 2, pp.14-39 and Annexes 2 and 
3; BG3000, Chapter 2, pp.34-46 and Annexes 2.2.1 and 2.2.2; BG4000, Chapter 2, pp.9-18 and Annexes 1 and 
2. 

6   FRMPs:  BG1000,  Chapter  2,  pp.12-16  and  Annex  3;  BG2000,  Chapter  2,  pp.14-39  and  Annex  2;  BG3000, 

Chapter 2, pp.34-46 and Annex 2.2.1 and 2.2.2; BG4000, Chapter 2, pp.9-18 and Annex 1 

7   APSFR information for the Danube UoM (BG1000) can be found at: 
   http://www.bd-dunav.org/content/upravlenie-na-vodite/upravlenie-na-riska-ot-navodneniia/rayoni-sas-

znachitelen-potencialen-risk-ot-navodneniia/   

  APSFR 

Black 
https://www.bsbd.org/bg/index_bg_2934486.html 

information 

the 

for 

Sea 

UoM 

(BG2000) 

can 

be 

found 

at:  

  APSFR information for the East Aegean UoM (BG3000) can be found at: 
  http://earbd.org/indexdetails.php?menu_id=178 
  APSFR information for the West Aegean UoM (BG4000) can be found at: 
  http://www.wabd.bg/index.php/2106-2021/2016-09-08-12-31-55  

17 

 
 
                                                           
the preparation of the programmes of measures (PoMs) together with other important aspects. 
However, further details are not provided8. 

2.1.1  Coordination with neighbouring Member States on shared RBDs/UoMs 

All four FRMPs contain chapters specifically about the cross-border/transnational coordination 

of  the  preparation  of  the  FRMPs.  During  each  step  of  the  FRMP  preparation  (e.g.  PFRA, 
development  of  APSFR,  FHRMs  etc.)  authorities  from  Bulgaria  coordinated  and  exchanged 
information  with  relevant  counterparts  in  neighbouring  countries.  The  FRMPs  provide 

summaries of the coordination at each step with references to specific meetings (including their 
dates and locations) and concrete issues that were covered9. 

During  the  coordination  of  PFRAs,  transboundary  APSFRs  were  defined  only  within  the 
Danube  (BG1000)  and  the  East  Aegean  (BG3000)  UoMs,  in  the  latter  case  for  the  Maritsa 

River  shared  with  Greece  and  Turkey.  Transboundary  coordination  for  Bulgaria’s  Danube 
UoM  takes  place  in  the  context  of  the  International  Commission  for  the  Protection  of  the 

Danube River (ICPDR) and the joint commission with Romania, in the context of the Bilateral 
Agreement  on  Cooperation  in  Water  Management.  Representatives  from  Bulgaria’s  Danube 

Basin  Directorate  participate  in  two  expert  groups  (EGs)  of  the  ICPDR  -  "Flood  protection" 
and  "Information  governance  and  GIS".  As  part  of  these  two  EGs,  the  Danube  Basin 

Directorate  presented  the  methodology  and  criteria  for  the  national  PFRAs  and  provided  the 
necessary  information  for  the  development  of  the  common  APSFR  for  the  internal  Danube 

UoM.  During  the  bilateral  coordination  with  Romania,  the  authorities  discussed  the 
methodologies  and  decided  to  designate  a  transboundary  APSFR  for  the  part  of  the  Danube 
shared by the two countries10.  

Transboundary coordination with Greece for the East Aegean UoM takes place in the context 

of the Joint Declaration for Cooperation in the Area of Water Management with  Greece. The 
national methodology, criteria and draft APSFRs for the UoM were discussed at the meetings 

of the joint expert group under this Declaration together with the transboundary APSFR for the 
Maritsa river11.  

Coordination  with  Member  States  took  place  also  in  the  UoMs  where  no  transboundary 
APSFRs were defined. For the Black Sea UoM (BG2000) the bilateral meeting with Romania 

(which  took  place  on  5  June  2013  in  Bucharest)  concluded  that  there  is  no  need  to  define 

8   FRMPs: BG1000, Chapter 5, p.65; BG2000, Chapter 2, p.14; BG3000, Chapter 5, p.102; BG4000, Chapter 3, 

pp.21-22. 

9   FRMPs:  BG1000,  Chapter  9,  pp.109-115;  BG2000,  Chapter  9,  pp.123-139;  BG3000,  Chapter  9,  pp.214-219; 

BG4000, Chapter 9, pp.80-85. 

10  This took place in the context of the second working meeting of the representatives of the competent authorities 
for implementation of the FD in Bulgaria and Romania and in line with the decisions of the joint commission; 
the meeting took place on 5 June 2013 in Bucharest 

11  APSFRs  were  discussed  at  two  meetings  of  the  joint  expert  group  (one  that  took  place  on  23  April  2013  in 
Thessaloniki and another that took place on 8 May 2014 in Athens) and a meeting of the technical sub-group to 
the joint expert group that was held 25-26 July 2013 in Blagoevgrad 

18 

 
 
                                                           
transboundary APSFRs. Even though no transboundary APSFRs were designated for the West 
Aegean UoM (BG4000), methodologies and data were exchanged with Greece in the context 
of bilateral meetings12.  

Coordination  took  place  also  with  non-EU  countries.  The  cross-border  coordination  with 

Turkey  takes  place  in  the  context  of  the  Joint  Declaration  for  Coordination  in  the  Area  of 
Water Resources (20 March 2012), which covers also flood risk management. An expert work 
group was created in the context of this Declaration. The work for designation of APSFRs in 

the Black Sea and East Aegean UoMs was discussed at the meeting of the expert group on 30-
31  May  2013  in  Sofia.  This  meeting  covered  issues  such  as  the  Bulgarian  methodology  for 

APSFR determination, criteria for classification of the flood risks and draft ASPFRs in the East 
Aegean.  

According  to  the  West  Aegean  FRMP,  the  methodologies  for  PFRA  and  APSFRs  were 
discussed at the first expert meeting for cooperation with FYROM in the context of the WFD 

and  the  FD  but  more  details  are  not  provided.  The  Danube  FRMP  explains  that  cooperation 
with  Serbia  is  at  an  initial  stage  and  on  24  February  2014  an  expert  meeting  on  water 
management  took  place  in  Belgrade  covering  e.g.  data  and  results  from  the  APSFR  analysis 
and assessment of the flood risks. 

2.1.2  Information how the PFRA was used in the development of the FHR maps 

The results of the PFRA and the APSFRs fed into the preparation of the FHRMs. All FRMPs 

state that the FHRMs were prepared using a national methodology approved by the Ministry of 
Environment  and  Water,  FHRMs  were  prepared  for  all  APSFRs  in  a  given  UoM  and  cover 

three  different  scenarios  as  requested  in  the  FD  (see  the  next  section  for  more  details).  The 
FHRMs confirmed the original findings and the APSFRs were not changed as a result of the 

FHRMs findings. However, further details about the use of the PFRA for the preparation of the 
FHRMs are not provided in the FRMPs13. 

2.2 

Presentation of FHRMs in the FRMPs 

FHRMs  are  provided  in  all  of  the  FRMPs  as  examples  reproduced  in  the  FRMPs  and  via 
weblinks to the websites of the Basin Directorates where all FHRMs can be found. Although 

the FRMPs provide details about the methodology for the preparation of the FHRMs, only two 
FRMPs  (BG2000  and  BG3000)  specify  what  kind  of  floods  have  been  considered.  In 

12  Meetings of the joint expert group held 22-24 April 2013 in Thessaloniki and on 8 May 2014 in Athens; and 

meetings of the technical sub-group held on 26 April 2012 in Kavala and 25-26 July 2013 in Blagoevgrad 

13  FRMPs: BG1000, Chapter 2, pp.12-16, Chapter 3, pp.17-27; BG2000, Chapter 2, pp.14-39, Chapter 3, pp.39-

77; BG3000, Chapter 2, pp.34-46, Chapter 3, pp.47-91; BG4000, Chapter 2, pp.9-18, Chapter 3, pp.19-27. 

   The national methodology 'Methodology for assessment of the threat and risk of floods in accordance with the   

requirements of Directive 2007/60/EC', referenced in each FRMPs, can be found at: 

   http://www5.moew.government.bg/wp-content/uploads/filebase/Water/Povarhnostnivodi/PORN/RZPRN/Final-

report.zip  

19 

 
 
                                                           
particular,  in  the  Black  Sea  FRMP  (BG2000)  risks  from  fluvial  and  seawater  floods  were 
considered, while in the East Aegean (BG3000) only fluvial floods were considered. 

The FRHMs were developed based on a common national methodology. As a first step, flood 
hazard  maps  were  developed  for  each  APSFR  under  three  flood  scenarios:  high  probability 

(20-year  occurrence),  medium  probability  (100-year  occurrence)  and  low  probability  (1000-
year  occurrence).  These  maps  show  several  aspects,  namely  the  geographical  areas  affected, 
the flood extent, water depths and flow velocity. One of the FRMPs (East Aegean, BG3000) 

reports  two  additional  scenarios  that  were  considered,  namely  an  extreme  scenario  in  which 
dam walls break and a special scenario for the transboundary region. As a next step, flood risk 

maps  were  prepared  for  each  APSFR  and  the  same  scenarios.  These  maps  show  potential 
adverse consequences associated with floods for several categories:  

  number of inhabitants potentially affected;  

 

 

types of economic activity and land area potentially affected;  

installations  that  can  cause  additional  pollution  if  affected  (according  to  the  national 

legislation for environmental protection) or other potential sources of pollution;  

  protected areas in accordance with the WFD or other policies (e.g. Natura 2000);  

  critical infrastructure (especially facilities of social infrastructure); and  

  sites of cultural or historical importance.  

In the Danube (BG1000) and West Aegean (BG4000) UoMs the potential impact of floods on 

the sources of public drinking water supply were considered but not mapped. For the Danube 
UoM (BG 1000) the results of the analysis are instead included as an Annex to the FRMP14. 
For the East Aegean UoM (BG3000), the sources for public drinking water supply have been 
taken into account and mapped as elements of the critical infrastructure15.  

Overall,  the  FRMPs  aim  to  summarise  the  methodology/process  and  key  results  from  the 
FHRMs rather than to present actual maps. All of the FRMPs provide one or several examples 

of the flood hazard maps and the flood risk maps but none of the FRMPs reproduces all of the 
FHRMs  prepared  for  the  respective  UoMs.  Three  of  the  FRMPs  (BG2000,  BG3000  and 

BG4000) provide weblinks to the websites of the Basin Directorates where all FHRMs can be 
found and explored. The FRMP for the East Aegean (BG3000) even references an interactive 

'module' for visualisation of the maps in addition to the complete database of maps. One FRMP 
(Danube,  BG1000)  includes  only  a  link  to  maps  for  BG1_APSFR_DU_001  but  does  not 

include  links  to  other  maps.  The  report  explains  that  there  have  been  some  delays  with 
finalising the maps. A survey of the Basin Directorate's website in 2018 shows that all maps 
are now available16. 

14   FRMPs: BG1000, Chapter 3, pp.17-27 and Annexes 10 and 11; BG2000, Chapter 3, pp.39-77 and Annexes 6-   

14; BG3000, Chapter 3, pp.47-91 and Annexes 3.1.1-3.1.4; BG4000, Chapter 3, pp.19-27. 

15   Information clarified by the national authorities. 
16   The maps are available at the following links: 

20 

 
 
                                                           
2.2.1  Maps for shared flood risk areas 

FHRMs  were  prepared  for  all  risk  areas  shared  with  other  Member  States  in  transboundary 
UoMs.  As  previously  noted,  transboundary  flood  risk  areas  were  defined  only  within  the 

Danube  (BG1000)  and  East  Aegean  (BG3000)  UoMs  for  the  Danube  and  Maritsa  rivers 
respectively.  The  development  of  the  FHRMs  for  these  two  transboundary  APSFRs  was 

coordinated and based on mutually agreed methodologies within the international Danube river 
basin and with Greece. The Danube FRMP explains that the FHRMs for the Bulgarian area of 
the  Danube  were  prepared  as  part  of  the  project  Danube  Floodrisk17,  which  included  all 
countries from the ICPDR as partners to the project – in Bulgaria the Ministry of Environment 
and  Water  and  the  University  of  Architecture,  Civil  Engineering  and  Geodesy  in  Sofia  were 

partners  –  and  the  ICPDR  as  one  of  the  observers  to  the  project.  As  part  of  the  project  all 
national methodologies were coordinated and a common database with all necessary data was 

set up. The preparation of the FHRMs for the transboundary area with Romania was bilaterally 
coordinated  at  each  step  of  the  preparation.  The  preparation  of  the  FHRMs  for  the 

transboundary APSFR shared with Greece was coordinated by the technical sub-group to the 
joint  expert  group  under  the  Joint  Declaration  for  Cooperation  in  the  Area  of  Water 

Management  with  Greece.  At  its  meetings,  the  methodologies  of  the  two  countries  were 
discussed,  a  common  methodology  (e.g.  concerning  the  scenarios  to  include)  for  the 

development  of  the  FHRMs  in  the  transboundary  areas  was  agreed  and  necessary  data 
exchanged18. 

2.2.2  Conclusions drawn from the FHRMs 

Generally,  the  conclusion  from  the  PFRA,  the  APSFRs  and  the  FHRMs  were  all  used  to 
prepare the draft FRMPs. Although not many details are provided, it appears that the FHRMs 

were  used:  firstly,  to  verify  the  defined  APSFRs  and  confirm  there  were  no  needs  for 
modifications to those areas; secondly, to define specific objectives and measures per APSFR 

based on a national ‘catalogue’ of priorities and measures (for further details see sections 3 and 
4).  

  Danube 

(BG1000)  FHRMs:  http://www.bd-dunav.org/content/upravlenie-na-vodite/upravlenie-na-riska-ot-

navodneniia/karti-na-zaplahata-i-riska-ot-navodneniia/;  

  Black Sea (BG2000) FHRMs: https://www.bsbd.org/bg/karti_na_zaplaha_i_risk_ot_navodnenia.html; 
  East  Aegean  (BG3000)  FHRMs:  http://earbd.org/indexdetails.php?menu_id=564;  and  interactive  module  for 

visualisation of the mapping results: http://bdibr.erp-bg.net/bdibr/map_default.phtml;  

  West  Aegean  (BG4000)  flood  hazard  maps:  http://www.wabd.bg/index.php/2106-2021/2016-08-25-08-31-36; 

17 

18 

and flood risk maps: http://www.wabd.bg/index.php/2106-2021/2016-08-25-08-33-09. 
 http://www.danube-floodrisk.eu/ 
 FRMPs:  BG1000,  Chapter  9,  pp.109-115;  BG2000,  Chapter  9,  pp.123-139;  BG3000,  Chapter  9,  pp.214-219; 
BG4000, Chapter 9, pp.80-85. Reporting sheets, Summary of coordination. 

21 

 
 
                                                                                                                                                                                       
2.3 

Changes to the APSFRs or other Flood Risk Areas 

No changes are reported concerning the APSFRs and the FHRMs. In fact, three of the FRMPs 
(BG2000, BG3000 and BG4000) report that the final APSFRs were confirmed only in 2013. 

Bulgaria was also late in reporting its FHRMs on time. 

2.4 

Areas for further development in the earlier assessment of the 
FHRMs 

There  is  no  information  about  Bulgaria  as  the  country  was  late  with  the  reporting  of  the 
FHRMs and the Commission has not assessed Bulgaria’s FHRMs as of yet. 

2.5  Good practices and areas for further development in the FRMP 
regarding integration of previously reported information 

The following good practice was identified: 

  The  preparation  of  the  APSFRs  and  the  FHRMs  followed  a  common  national 
methodology  and  was  coordinated  with  all  neighbouring  countries,  even  in  the  cases 
where no transboundary APSFRs were defined. 

The following areas for further development were identified: 

  Although the FRMPs  report that the results of the previous steps (PFRA, APSFRs and 

FHRMs) fed into the subsequent steps and eventually into the preparation of the FRMPs, 
more details, or specific examples illustrating how, should be provided. 

22 

 
 
 
 
3. Setting of Objectives 

3.1 

Focus of objectives 

The  Flood  Risk  Management  objectives  in  Bulgaria  were  set  at  the  national  level  through  a 

‘catalogue’ of five national priorities and 17 national objectives within these priorities. In most 
cases,  all  the  17  national  objectives  were  relevant  for  a  given  UoM  and  were  therefore 

translated into UoM and ASPFR objectives considering the specific local characteristics. When 
the analysis of the local characteristics and conclusions from the PFRA and FHRMs deemed it 
necessary,  additional  UoM  or  ASPFR-specific  objectives  were  developed  in  addition  to  the 

national objectives.  

The five national priorities and their corresponding national objectives are:  

1.  Protecting human lives and public health:  

1.1. Minimising the number of people hurt or impacted by floods;  
1.2. Ensuring  the  fast  conveyance  of  waters  from  urban  areas  in  cases  of  intensive 

rainfall or floods;  

1.3. Re-establishing normal living conditions;  
1.4. Minimising the number of impacted social infrastructure.  
2.  Higher level of protection of the critical infrastructure and businesses:  

2.1. Improving the protection of the technical infrastructure;  
2.2. Improving the protection of important economic and cultural and historic sites.  

3.  Increasing the protection of the environment:  

3.1. Improving the protection of the sewage systems;  
3.2. Improving the protection of industrial sites (mainly IPPC and SEVESO sites);  
3.3. Minimising  the  impacted  areas  for  protected  waters,  protected  territories  and 

protected zones;  

3.4. Improving the water retention capabilities of agricultural, forest and coastal areas.  

4.  Improving the preparedness and reactions of the population:  

4.1. Increasing the preparedness of the population in case of floods;  
4.2. Improving the reactions of the population in case of floods.  

5.  Improving the administrative capacity for FRM:  

5.1. Creating a modern normative base for territorial planning and FRM;  
5.2. Providing operative information for FRM;  
5.3. Enhancing the qualification/skills of the personnel responsible for FRM;  
5.4. Minimising the flood risk along the water route of the whole river basin;  
5.5. Ensuring the adequate reactions of the public institutions in case of floods19.  

Consequently, in the FRMPs assessed20: 

19 

 FRMPs: BG1000, Chapter 4, pp.27-35 and Annexes 4,5,6,7 and 8; BG2000, Chapter 4, pp. 77-81 and Annexes 
15, 16 and 17; BG3000, Chapter 4, pp. 91-100 and Annex 4.1.1; BG4000, Chapter 4, pp. 27-32 and Annex 3 

23 

 
 
                                                           
  The objectives aim to reduce the adverse consequences of floods.  
  The objectives aim to reduce the likelihood of flooding21.  
  The objectives refer to measures that will be implemented.  
  The objectives refer to non-structural measures22.  

3.2 

Specific and measurable objectives 

In  Bulgaria,  the  objectives  are  specific  and  measurable  to  a  certain  extent.  They  have 
quantitative targets to achieve and clearly defined locations but there is no information about 

how  or  by  when  they  should  be  achieved.  All  FRMPs  refer  to  the  national  ‘catalogue’  of 
objectives  and  have  formulated  APSFR-specific  variations  of  the  national  objectives.  In  the 
chapters  describing  the  implementation  of  the  FRMPs,  the  plans  report  indicators23.  Overall, 
the  reported  indicators  are  quantifiable  and  focus  on  e.g.  number  of  people,  percentages  or 

sizes of areas. There are quantifiable indicators for each of the 17 national objectives and other 
UoM/APSFR-specific objectives. Some good examples include: 

  number of people potentially impacted by floods with a probability of occurrence 1 %;  

  number  of  social  infrastructure  facilities  potentially  impacted  by  floods  with  a 
probability  of  occurrence  1  %;  similar  indicators  are  used  in  relation  to  industrial 

facilities, critical infrastructure, cultural and historical sites;  

  percentage of the area with ensured fast conveyance of water compared to the total urban 

area;  

  area of protected territories that is exposed to pollution from polluted waters in case of 

floods, measured in ha;  

  proportion  of  qualified  personnel24  compared  to  the  total  qualified  personnel  needed, 

measured by percentage. 

3.3  Objectives to reduce adverse consequences from floods 

In  the  FRMPs  assessed,  the  objectives  do  not  provide  further  specification  of  the  type  of 

adverse consequences that will be reduced.   

20 
21 

22 

23 

24 

 These categories are included in Art. 7 of the FD. 
 The assessment adopts the generally accepted definition of risk as a product of consequence times likelihood, 
thereby also in alignment with Art. 7(2) of the FD. 
 Non-structural measures include measures such as flood forecasting and raising awareness of flooding as well 
as land use planning, economic instruments and insurance 
 FRMPs:  BG1000,  Chapter  6,  pp.89-94  and  Table  9;  BG2000,  Chapter  6,  pp.98-103  and  Table  9;  BG3000, 
Chapter 6, pp.200-202 and Table on p.201; BG4000, Chapter 6, pp.68-70 and Table 14 
 As  this  is  an  indicator  for  the  objective  ‘enhancing  the  qualification/skills  of  the  personnel  responsible  for 
FRM’  it  can  be  assumed  it  refers  to  the  skills  or  qualification  of  personnel  in  FRM,  however  the  specific 
qualifications are not defined in the objective or the FRMPs. FRMPs: BG1000, Chapter 6, pp.92-94; BG2000, 
Chapter 6, pp. 101-102; BG3000, Chapter 6, pp. 201-202; BG4000, Chapter 6, pp. 68-69. 

24 

 
 
                                                                                                                                                                                       
3.4  Objectives to address the reduction of the likelihood of flooding  

According to the FRMPs, reducing the likelihood of flood risk was not defined as a separate 
priority  but  was  instead  integrated  in  the  other  priorities  and  objectives  of  the  national 

‘catalogue’. 

3.5 

Process for setting the objectives  

During  the  preparation  of  the  FRMPs  a  project  funded  by  the  European  Structural  and 
Investment Funds was implemented to outline a set of national FRM priorities and objectives 

i.e.  a  national  'catalogue'  of  objectives.  The  draft  FRMPs  (including  the  draft  objectives)  for 
each  UoM  were  open  for  public  consultation  in  the  process  of  ensuring  public  participation 

(for  more  details  see  section  7).  Although  climate  change  impacts  are  mentioned  in  the 
concluding  chapters  of  three  of  the  FRMPs  (Danube,  East  and  West  Aegean),  there  is  no 

information in the FRMPs to indicate whether and if  yes how climate change has influenced 
the definition of objectives25. 

3.6  Good practices and areas for further development regarding setting 

objectives 

The following good practices were identified: 

  The objectives in the FRMPs are based on a national ‘catalogue’ of objectives (formatted 
as a table).  For each of the objectives,  guidance is  given on the priorities  associated to 
objectives and how nine qualitative indicators can be used to set priorities. The indicators 

include applicability, economic effectiveness and likelihood to reduce the risk of floods. 

  The objectives from the national ‘catalogue’ were translated into UoM or even APSFR 
objectives  considering  the  specific  local  characteristics.  The  Annexes  to  the  FRMPs 
provide a FRMP specific version of the national catalogue of objectives. Details on how 

the national catalogue has been tailored to the specific needs of an FRMP are unclear.  

 

In Chapter 6 of the FRMPs assessed, the national indicators that will be used to assess 

the progress to achieving each of the objectives are described.  

  The  annexes  to  the  FRMP  for  the  Danube  UoM  (BG1000,  Annexes  5,  6,  7  and  8) 
provide information how the objectives for each APSFR were set together with the level 

of  confidence  of  the  available  information  for  each  objective  along  three  levels:  low, 
medium and high confidence26.  

25 

26 

 FRMPs:  BG1000,  Chapters  4,  11  and  13;  BG2000,  Chapters  4  and  11;  BG3000,  Chapters  4,  11  and  13; 
BG4000, Chapters 4, 11 and 13. 
 The  level  of  confidence  appears  to  assess  the  credibility  of  the  information  used  to  analyse  the  local 
characteristics and thus to define APSFR specific objectives. Examples of low levels of confidence include: no 
data for past floods, the PFRA was based only on modelling or flood risk management measures have already 
been taken. Examples of high levels of confidence include: lessons learnt from past floods, significant number 
of past floods or information based on the FHRMs. 

25 

 
 
                                                           
 

In their annexes the FRMPs for the Black Sea (BG2000, Annex 15) and the East Aegean 
(BG3000,  Annex  4.1.1)  provide  tables  that  not  only  describe  the  objectives  from  the 

national  catalogue  but  also  qualitatively  assess  their  relevance  to  certain  criteria  (e.g. 
applicability, economic effectiveness, likelihood to reduce the risk of floods). Annex 17 

to  the FRMP of the  Black Sea UoM  (BG2000)  summarises the conflicts and synergies 
between the 17 national  objectives.  It  is  unclear  how the trade-offs  and synergies have 

been identified. 

The following areas for further development were identified: 

  Overall, the FRMPs did not provide information about the timeline for the achievement 

of the objectives. This is the case for all four FRMPs.  

26 

 
 
 
 
4.   Planned measures for the achievement of objectives 

4.1 

Cost of measures 

 Bulgaria reported 194 measures in total for its four UoMs, without counting measures which 
have been allocated to more than one measure type27 28.  

The most measures were reported for the East Aegean (BG3000; 61 measures) followed by the 

Danube (BG1000; 52 measures), the Black Sea (BG2000; 49 measures) and the West Aegean 
(BG4000; 32 measures).  

Aggregated29  measures  (61)  were  reported  only  for  the  East  Aegean  UoM,  while  individual 
measures  (133)  were  reported  only  for  the  other  three  UoMs.  However,  the  FRMPs  do  not 
provide a definition distinguishing individual and aggregated measures. Furthermore, some of 

the aggregated measures reported for the East Aegean are assigned to more than one measure 
type. To compare the number of measures by type, a total count is used that includes each time 
a  measure  is  allocated  to  a  measure  type30:  this  total  is  199  measures  (including  measures 
which have been allocated to more than one measure type). 

Measures  were  reported  for  all  five  aspect  categories  -  prevention,  protection,  preparedness, 
recovery and review, as well as under the option, “other type of measure”. The most measures 

were  reported  for  preparedness  (61  measures  or  around  31  %  of  the  total  199  measures), 
prevention (60 measures or around 30 % of the total) and protection (53 measures or around 27 

%  of  the  total).  Bulgaria  reported  measures  of  nearly  all  types  (with  the  exception  of  type 
M1131 and M2332)33.  

Under ‘other type of measure’ Bulgaria reported measures such as: ‘assessment of the stability 

and safety of buildings and infrastructure impacted by floods’ (BG1000 and BG3000), ‘release 

27 

28 

 The information reported to WISE was the starting point for the assessment in this section. The majority of the 
statistics presented are based on processing of information reported to WISE. Assuming that the Member States 
accurately transferred the information contained in their FRMPs to the reporting sheets (the sheets are the same 
for  all  Member  States  and  are  not  customisable)  and  barring  any  undetected  errors  in  the  transfer  of  this 
information  to  WISE  arising  from  the  use  of  interfacing  electronic  tools,  these  statistics  should  reflect  the 
content of the FRMPs. 
 See Annex B for details about all measure aspects and measure types. 

29  The Reporting Guidance mentions “Measures can be reported as individual measures (recommended for major 
projects)  or  aggregated  measures,…”  and  also  notes  that  measures  may  be  comprised  of  “many  individual 
projects”. European Commission, Guidance for Reporting under the FD (2007/60/EC), 2013, pp. 54-58. 
 This approach implies double-counting. 
 No Action, No measure is proposed to reduce the flood risk in the APSFR or other defined area. 
 Prevention, Reduction, Measure to adapt receptors to  reduce the adverse consequences in the event of a flood 
actions on buildings, public networks, etc... 
 Reporting sheets. 

30 
31 
32 

33 

27 

 
 
                                                           
of  a  daily  hydro-meteorological  bulletin’,  ‘issuance  of  warnings  for  flood  danger’  and 
‘restoration of wet zones and coastal forests’ (BG2000)34. 

Please  see  Annex  A  for  detailed  tables  and  charts  on  measures  for  this  and  subsequent 
questions in this section. 

Table 6 

Overall budget for the measures in the assessed FRMPs 

Estimated overall budget of planned measures (2015-2021) in BGN 

BG1000 

BG2000 

BG3000 

BG4000 

216 687 949 

n/a 

370 593 837 

40 400 000 

Source: Reporting sheets and FRMP 

Three  of  the  Bulgarian  FRMPs  contain  aggregate  estimates  about  the  total  cost  or  necessary 

budget  to  implement  the  PoMs,  while  all  FRMPs'  annexes  with  detailed  description  of  the 
PoMs  provide  estimated  costs  for  each  measure  (where  such  a  value  could  be  provided). 

Therefore,  cost  estimates  for  specific  measures  are  available  in  the  PoM  annex  of  the  Black 
Sea FRMP (BG2000) but the format does not allow for an easy aggregation of these costs35.  

The  FRMPs  provide  cost  information,  either  as  aggregate  estimates  of  the  total  cost  of  the 
measures/PoMs  or  of  specific  measures  in  the  PoMs,  as  well  as  a  brief  summary  of  the 

methodology  used  to  estimate  these  costs  (often  as  part  of  the  description  of  the  CBA  e.g. 
BG2000, BG4000). Considering the descriptions provided in the FRMPs, it can be concluded 

that the cost estimations in the Danube UoM (BG1000) concern the investment and operational 
costs  of  the  measures  based  on  the  indicative  costs  provided  in  the  national  catalogue  of 

measures. The total costs reported for the East Aegean UoM (BG3000) and the costs reported 
in  the  annexes  to  all  four  FRMPs  are  based  on  the  same  principle  and  reflect  the  indicative 

costs provided in  the national  catalogue of measures. Furthermore, the estimates in  the West 
Aegean  FRMP  (BG4000)  concern  the  total  available  budget  for  the  PoM  based  on  the 

available  public  funding  sources.  However,  the  information  provided  in  the  West  Aegean 
FRMP36  suggests  this  budget  might  be  insufficient  to  cover  the  estimated  costs  in  the  three 

34 
35 

 FRMPs: BG1000, Annex 9; BG2000, Annex 18; BG3000, Annex 5. 
 The PoM annexes of the other FRMPs are available as Excel files (which allows for easy sorting and summing 
up of the data), however the PoM annex of the Black Sea FRMP is available only in PDF format that cannot be 
manipulated. 

36  The West Aegean FRMP reports the likely costs of the PoM in three scenarios: no floods in the UoM during the 
2016-2021 period (in this case the cost was estimated at around BGN 42 million); one flood of over 100-year 
occurrence happens in each of APSFRs over the 2016-2021 period (in this case the cost was estimated at around 
BGN 51.6 million); one flood of over 1000-year occurrence happens each year in each of the APSFRs over the 
same  period  (in  this  case  the  cost  was  estimated  at  around  BGN  99.6  million).  The  costs  given  to  individual 

28 

 
 
 
                                                           
scenarios considered. It does not clarify how the difference between the estimated costs, even 
in the 'no floods' scenario, and the available public budget would be covered37. 

In  their  reporting  sheets  Member  States  could  report  costs  for  each  measure  and  could  add 
relevant  information  or  explanations  about  these  costs  as  recommended  by  the  Guidance  for 

Reporting  under  the  FD  (2007/60/EC).  The  reporting  sheets  submitted  by  Bulgaria  contain 
measure-specific cost explanations only for 101 measures of all measures. They are located in 

UoMs BG1000 and BG2000, no cost explanation is available for UoMs BG3000 or BG4000 
(see Annex A for more details). 

4.2 

Funding of measures 

All  four  FRMPs  cite  as  sources  of  financing  for  the  measures  the  national  and  municipal 

budgets,  the  public  Enterprise  for  Management  of  the  Environmental  Protection  Activities 
(EMEPA)38,  the  Operational  Programme  (OP)  'Environment'  for  the  implementation  of  the 
European  Structural  and  Investment  Funds  (ESIF)  in  the  period  2014-2020.  The  FRMPs  for 
Danube (BG1000), East Aegean (BG3000) and West Aegean (BG4000) also cite as financing 

sources  the  European  Territorial  Cooperation  programmes  (also  known  as  INTERREG  and 
financed by the ESIF) that cover the respective UoMs. The same FRMPs also refer to the Rural 

Development Programmes of the CAP as sources of financing for the measures. The FRMP for 
the Black Sea (BG2000) is the only one that references the National Programme for Disaster 

Protection 2014-2018 and the European Solidarity Fund as sources of financing. Overall, the 
FRMP  for  the  East  Aegean  has  listed  the  largest  number  of  different  financing  sources, 
including the ESIF OP 'Regions in Growth' 2014-2020 and irrigation system enterprises39 40. 

Table 7 

Funding of measures 

Distribution of costs among those groups affected by flooding 

Use of public budget (national level)  

Use of public budget (regional level)  

Use of public budget (local level)  

Private investment  

BG1000  BG2000  BG3000  BG4000 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

measures in the PoM annex of the FRMP amount to around BGN 47 million in total. However, the FRMP does 
not provide information how these different cost estimates compare or how the available budget will be matched 
to the costs. 

37   FRMPs: BG1000, Chapter 5, p.87-88 and Annex 9; BG2000, Annex 18; BG3000, Chapter 5, pp.163-166 and 

Annex 5; BG4000, Chapter 5, 56-62 and Annex 4. 

38   The  EMEPA  is  a  public  enterprise  whose  purpose  is  to  finance  environmental  projects  in  different  areas  e.g. 

39 

40 

water, waste and biodiversity. 
 The  FRMP  for  East  Aegean  (BG3000)  refers  to  hydromeliorative  systems,  which  are  public  enterprises  or 
cooperatives that manage irrigation and channel systems, as another source of funding for the measures. 
 FRMPs:  BG1000,  Chapter  5,  pp.85-87;  BG2000,  Chapter  5,  pp.92-97;  BG3000,  Chapter  5,  pp.167-191; 
BG4000, Chapter 5, pp.54-56. 

29 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                                                                                                                                                       
EU funds (generic)  

EU Structural funds  

EU Solidarity Fund  

EU Cohesion funds  

EU CAP funds  

International funds  

EMEPA  

Irrigation system enterprises 

BG1000  BG2000  BG3000  BG4000 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

Source: FRMPs 

4.3  Measurable and specific (including location) measures 

All FRMPs include a clear and explicit description of the measures with regard to:  

  What they are trying to achieve; 

  Where they are to be achieved; 

  How they are to be achieved. 

The  FRMP  annexes  with  the  PoMs  provide  tables  with  details  about  each  specific  measure 

planned providing descriptions of the measures and information about e.g. their location, cost, 
priority, responsible institutions and financing source. However, details about the timeline are 

not available.  

The measures are grouped as measures applied at RBD/UoM-level, sub-basin or APSFR-level. 

Where relevant the specific water body is also indicated. The table below provides an overview 
of the location of measures (this is the same across all four UoMs)41. 

Table 8 

Location of measures  

International  

National  

RBD/UoM  

Sub-basin  

APSFR or other specific risk area  

Water body level  

More detailed than water body 

Source: Reporting sheets 

All UoMs assessed 

✔ 

✔ 

✔ 

✔ 

41   FRMPs: BG1000, Annex 9; BG2000, Annex 18; BG3000, Annex 5; BG4000, Annex 4. 

30 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
4.4  Measures and objectives 

The  main  parts  of  the  FRMPs  focus  on  describing  the  process  and  methodology  behind  the 
selection  of  the  measures.  While  the  annexes  with  PoMs  provide  descriptions  how  the 

measures will support the objectives, there is no clear indication how much the measures will 
contribute to the objectives or whether the objectives will be achieved. Only the annex of the 

West  Aegean  FRMP (BG4000) reports information  about  the expected  results and indicators 
for  tracking  both  implementation  progress  and  progress  towards  achieving  the  objectives  of 
each measure. However, such information is not reported for the other three UoMs42.  

4.5  Geographic coverage/scale of measures 

Information about the geographic scale of the location was reported for all 199 measures in the 
Reporting Sheets. The different types of location given can be grouped in the following general 

categories:  

  APSFRs; 

  Multiple APSFRs: when the measures cover more than one APSFR; 

  UoM/RBD; 

  Other.  

In terms of measure aspect, the location of the measures is relatively evenly spread across the 

different  measure  aspects.  The  majority  of  the  prevention  and  protection  measures  will  be 
implemented  in  multiple  APSFRs,  while  most  of  the  preparedness  and  recovery  and  review 

measures will be implemented at the UoM level. Information about the geographic coverage of 
the  expected  effects  of  measures  was  reported  only  for  the  West  Aegean  UoM  (BG4000), 

where the coverage for all measures is indicated as the UoM (for details see Tables A6 and A7 
in Annex A).  

The  FRMP  annexes  with  PoMs  indicate  the  location  of  each  measure  in  terms  of  different 

geographic  categories  such  as  water  body  (code),  APSFR  (code),  relevant  settlements  (i.e. 
names of cities/towns/villages), municipalities and regions for each measure.  

4.6 

Prioritisation of measures 

The priority was reported for all measures in the Reporting Sheets, following the categories in 

the  Guidance  for  Reporting  under  the  FD  (2007/60/EC).  The  majority  of  the  measures  are 
classified as 'high' priority (107 measures or around 54 % of the total 199 measures) followed 

by  measures  of  'moderate'  priority  (36  measures  or  around  18  %  of  the  total),  'very  high' 
priority (25 measures or around 13 % of the total) and 'critical' priority (21 measures or around 

42   FRMPs: BG1000, Annex 9; BG2000, Annex 18; BG3000, Annex 5; BG4000, Annex 4. 

31 

 
 
                                                           
11 % of the total). The fewest measures are classified as 'low' priority - only 10 (or around 5 
%)  of  the  total.  Most  of  the  prevention,  protection  and  preparedness  measures  are  ranked  as 

'high' priority (32, 28 and 30 measures respectively, representing around 50 % of the measures 
in all three cases) followed by 'moderate' (12, 11 and 12 measures respectively or around 20 % 

of the measures in all three cases) and 'very high' priority (10, 6 and 9 measures respectively).  

Measures of 'critical' priority are found only in the East Aegean UoM (BG3000), while 'low' 

priority  measures  are  found  only  in  the  Black  Sea  UoM  (BG2000).  In  the  Danube  UoM 
(BG1000)  there  are  31  measures  (around  60  %)  of  high,  15  measures  (around  29  %)  of 

moderate and six measures (around 12 %) of very high priority. In the Black Sea UoM, there 
are 25 measures (51 %) of high, 14 measures (29 %) of moderate and 10 measures (20 %) of 

low priority. In the East Aegean UoM, there are 30 measures (45 %) of high, 21 measures (32 
%)  of  critical  and  15  measures  (23  %)  of  very  high  priority.  In  the  West  Aegean  UoM 

(BG4000) there are 21 measures (66 %) of high, seven measures (22 %) of moderate and four 
measures (12.5 %) of very high priority (for details see Tables A8 and A9 in Annex A).  

The prioritisation of the measures in all four FRMPs was based on the same methodology. The 

methodology  was  originally  developed  for  the  Danube  UoM  through  a  call  for  proposals 
financed by the OP 'Environment' in the 2007-2013 period. In this methodology the measures 

are analysed against five criteria: percentage of achieved objectives; urgency of the measure; 
cost of the measure; extent of problem solving (i.e. how effective is the measure in addressing 
the problems and achieving the objectives); and timeline of implementation. Each criterion has 

a  different  weight  (the  highest  weight  of  30  %  is  given  to  the  cost  of  the  measure  while  the 
lowest weight of 5 % is given to the timeline of implementation). To give a priority value of 

each measure in the range one to three, the following steps are taken: 

1.  For each criterion, a value is assigned between one and three to give an overall priority 
value in the range one to three, based on considerations of the objectives and priorities of 

the specific APSFR and a pre-defined scale. 

2.  The  priority  value  assigned  each  criterion  is  multiplied  by  the  criterion’s  weight 

coefficient. 

3.  The  results  of  the  previous  step  are  summed  up  for  all  criteria  providing  an  overall 

priority value of each measure in the range one to three. 

The  overall  priority  values  are  then  translated  into  five  priority  categories:  very  high;  high; 
moderate/medium;  low;  and  very  low  using  a  pre-defined  scale.  The  FRMPs  clarify  that 
identical or similar measures can be assigned different priorities in different UoMs or APSFRs 
as the specificities of each location are also considered. However, the FRMPs do not provide 
further  details  about  the  method  or  explain  how  the  five  national  priority  categories  are 

translated  into  the  five  categories  for  Member  State  reporting  in  the  Guidance  for  Reporting 

32 

 
 
under  the  FD  (2007/60/EC)43  and  it  is  not  clear  how  some  measures  are  categorised  as 
'critical'44. 

Bulgaria did not provide information on the timetable for any of the measures in its reporting 
sheets uploaded to WISE. 

4.7 

Authorities responsible for implementation of measures 

The  FRMP  annexes  with  PoMs  contain  information  about  the  responsible  authority  for  each 

specific measure. In the reporting sheets, Bulgaria provided information also about the level of 
responsibility for these authorities in the categories listed in the Guidance for Reporting under 
the FD (2007/60/EC)45: 

  UoM/RBD authority;  

  Municipal authorities - e.g. mayors;  

  District/regional authorities - e.g. regional governors;  

  National  authorities  -  this  includes  various  ministries  such  as  the  Ministry  of 
Environment  and Water, the Ministry  of Agriculture and  Food, the Ministry of Energy 

etc. and associated national agencies or bodies such as the Directorate General  for Fire 
Safety and Public Protection and the Agency for Road Infrastructure;  

  Other  -  this  includes  various  actors  such  as  the  National  Institute  for  Meteorology  and 
Hydrology,  the  National  Energy  Company,  the  public  irrigation  system  operators  and 

owners of private facilities.  

The  majority  of  the  measures  will  be  implemented  by  municipal  and  national  authorities,  62 
and 53 measures respectively. Most prevention and protection measures will be implemented 

by municipal authorities (22 and 24 measures respectively) while most preparedness measures 
will be implemented by national authorities (29). Most measures in the Danube (BG1000) and 

West  Aegean  (BG4000)  UoMs  will  be  implemented  by  municipal  authorities  (19  and  12 
measures  respectively),  while  most  measures  in  the  East  Aegean  UoM  (BG3000)  will  be 

implemented by national authorities (24). In the Black Sea UoM (BG2000) most measures will 
be implemented by 'other' authorities (16). For details see Tables A10 and A11 in Annex A. 

43  According  to  the  Guidance  for  Reporting  under  the  FD  (2007/60/EC)  (p.56)  Member  States  report  the 
prioritisation of the measures either as a timetable for implementation or using five categories: ‘critical’, ‘high’, 
‘very high’, ‘moderate’ and ‘low’. 

44  FRMPs:  BG1000,  Chapter  5,  pp.76-78;  BG2000,  Chapter  5,  pp.88-90;  BG3000,  Chapter  5,  pp.117-119; 

BG4000, Chapter 5, pp.49-51. 

45  https://circabc.europa.eu/sd/a/acbcd98a-9540-80ea876420b7de64eba/Floods%20Reporting%20guidance%20-

%20final_with%20revised%20paragraph%204.2.3.pdf, p.56 

33 

 
 
                                                           
4.8 

Progress of implementation of measures 

Bulgaria  reported  the  progress  of  all  measures  in  the  reporting  sheets  using  the  categories 
recommended in the Guidance for Reporting under the FD (2007/60/EC). The vast majority of 

the  measures  across  all  aspects  are  reported  as  'not  started'  (179,  90%  of  the  total)  while  no 
measures are reported as 'completed'. A further 19 measures are reported as 'progress ongoing' 

(5%) and only one measure is reported as 'ongoing construction' (a prevention measure). 

In  the  Danube  UoM  (BG1000)  43  measures  are  reported  as  'not  started'  and  9  as  'progress 

ongoing'. In the Black Sea UoM (BG2000) 48 measures are reported as 'not started' and 1 as 
'progress  ongoing'.  In  the  East  Aegean  UoM  (BG3000)  56  measures  are  reported  as  'not 

started', 9 as  'progress ongoing' and 1 as 'ongoing construction'. All 32 measures in the West 
Aegean  UoM  (BG4000)  are  reported  as  'not  started'.  For  details  see  Tables  A12  and  A13  in 

Annex A.  

4.9  Measures taken under other Community Acts 

Member States have been asked to report on other Community Acts under which each measure 
has been implemented: Bulgaria reported this information only for some of the FRMPs in the 

reporting  sheets.  Only  18  of  the  measures  reported  by  Bulgaria  provide  information  about 
other Community Acts of relevance, all of these measures are located in the East Aegean UoM 
(BG3000) and refer to Directive 85/337/EEA46. 

4.10  Specific groups of measures 

Spatial  planning/land  use  measures  are  planned  in  all  four  FRMPs.  Most  often  these 
measures  will,  for  example,  remove  illegal  constructions,  stored  materials,  fences  or  other 

objects  in  the  river  beds  and  banks  or  impeding  the  water  conveyance  in  the  river  beds; 
propose  legislative  measures  for  controlling  construction  in  areas  of  flood  risk  or  ban 

construction in areas of flood risk. There is no information if the overall framework for spatial 
planning has evolved since 200047.  

Natural water retention measures (NWRMs) are included in all four FRMPs. Although not 

exactly  the  same  NWRMs  are  considered  in  each  FRMPs,  the  different  examples  across  the 
four  FRMPs  include:  ‘re-naturalisation’  of  rivers/river  beds;  re-meandering;  cleaning  of  the 
river  beds;  and  afforestation  of  areas  along  river  coasts  or  dams48.  For  example,  in  the  East 

46 

47 

48 

 This Directive and its three amendments have been codified by Directive 2011/92/EU of 13 December 2011 on 
the assessment of the effects of certain public and private projects on the environment. 
 FRMPs:  BG1000,  Chapter  5,  pp.57-65  and  Annex  9;  BG2000,  Chapter  5,  pp.81-87  and  Annex  18;  BG3000, 
Chapter 5, pp.100-106 and Annex 5; BG4000, Chapter 5, pp.47-49 and Annex 4. 
 Considering the NWRM codes provided in Annex B, the NWRMs in the Bulgarian FRMPs can be grouped as: 
cleaning  of  the  river  beds  and  're-naturalisation'  of  rivers/river  beds  (N05);  re-meandering  (N04);  and 
afforestation of areas along river coasts or dams (F03). 

34 

 
 
                                                           
Aegean UoM (BG3000) the planned prevention measures (types M2149 and M2350 as defined 
in Annex B) concern the planting of tree species appropriate for coastlines or flooding terraces, 

while the measures planned in the Black Sea UoM (BG2000) include afforestation and creation 
of a protective forest layer around dams and surface catchment areas. 

Measures that specifically consider nature conservation. Nature conservation is considered 
in  all  FRMPs  as  one  of  the  five  national  priorities  and  corresponding  national  objectives 

concern  environmental  protection.  Examples  of  specific  measures  from  the  four  FRMPs 
include:  protection  of  wetlands  or  protected  territories;  reconstruction  of  wetlands;  're-
naturalisation' of rivers; protection of river coasts from erosion and afforestation51. 

Ports  and  navigation  do  not  seem  to  be  included  in  the  specific  measures  for  any  of  the 
FRMPs.  However,  one  of  the  five  national  priorities  and  corresponding  national  objectives 

concern the protection of critical infrastructure. Hence, it is possible that in some cases ports 
are considered critical  infrastructure and addressed by  general  measures for protection of the 

critical infrastructure.  

Measures for cleaning river beds and ensuring the capacity and ability of the river channel to 

convey  water  are  planned  in  all  four  FRMPs.  Based  on  the  descriptions  provided,  these 
measures  include  the  cleaning  of  domestic  and  construction  waste,  dead  or  fallen  plants  and 

deposits/debris.  However, there is  no indication that any  dredging  measures  with a potential 
negative effect on the environment are planned52. 

4.11  Recovery from and resilience to flooding 

The  role  of  insurance  policies  is  discussed  in  general  in  all  four  FRMPs,  however  only  one 

measure related to insurance (i.e. increasing awareness about insurance schemes for floods) is 
included  in  the  FRMPs  for  the  Danube  (BG1000)  and  the  Black  Sea  (BG2000)  UoMs.  The 

other two FRMPs do not contain any measures related to insurance. 

None  of  the  FRMPs  provide  further  information  or  details  about  different  insurance  options 
that might be available or the insurance conditions for making at risk properties flood resilient. 

There is no information if environmental liability insurance covers restoration costs or whether 
ecosystem  services  are  considered  in  estimating  restoration  costs  in  cases  where  potentially 

polluting sites and installations may be flooded.  

49 

50 

51 

52 

 Prevention, Avoidance, Measure to prevent the location of new or additional receptors in flood prone areas, such 
as land use planning policies or regulation 
 Prevention, Reduction, Measure to adapt receptors to reduce the adverse consequences in the event of a flood 
actions on buildings, public networks, etc... 
 FRMPs:  BG1000,  Chapter  5,  pp.57-65  and  Annex  9;  BG2000,  Chapter  5,  pp.81-87  and  Annex  18;  BG3000, 
Chapter 5, pp.100-106 and Annex 5; BG4000, Chapter 5, pp.47-49 and Annex 4. 
 RMPs:  BG1000,  Chapter  5,  pp.57-65  and  Annex  9;  BG2000,  Chapter  5,  pp.81-87  and  Annex  18;  BG3000, 
Chapter 5, pp.100-106 and Annex 5; BG4000, Chapter 5, pp.47-49 and Annex 4. 

35 

 
 
                                                           
4.12  Monitoring progress in implementing the FRMPS 

The FRMPs report the same national approach for monitoring. The implementation of each of 
the FRMPs will be assessed on two aspects - progress of the implementation of the measures 

and  progress  and  results  for  achieving  the  objectives.  Information  about  the  progress  of 
implementation  of  the  measures  will  be  collected  and  reported  by  the  authorities  responsible 

for  implementing  the  measures  and  through  the  implementation  of  any  monitoring  measures 
resulting from the report on the environmental assessment (i.e. the SEA). The information will 

be reported to the Basin Directorates on a yearly basis, they will in turn prepare reports about 
the progress  of implementation,  monitoring and control of the measures  every two  years. To 

monitor  the  progress  towards  achieving  the  objectives  a  set  of  indicators  for  each  of  the 
national  objectives  is  defined  (examples  of  these  national  indicators  are  listed  in  section  3 

above).  In  addition,  the  FRMPs  for  the  Black  Sea  (BG2000),  the  East  (BG3000)  and  West 
Aegean  (BG4000)  define  also  indicators  for  tracking  the  implementation  of  some  of  the 
planned measures53.  

In  the  Black  Sea  and  West  Aegean  FRMPs  (BG2000,  BG4000)  indicators  are  listed  for  the 
measures for monitoring and control54 and include:  

  quality of the drinking water based on the values for priority substances,  

  number of permits issued (for construction of new flood defence equipment etc.),  

  number and length of dam walls or other equipment inspected etc.  

In the East Aegean FRMP (BG3000) indicators are provided for each measure planned in the 

PoM and include:  

  afforested area,  

  number of trainings,  

  number of participants at the trainings,  

  completed  stages  from  the  construction  of  equipment/  infrastructure,  number  of 

completed clearings of water beds and banks,  

  number of inspections.  

The PoM Annex of the West  Aegean FRMP (BG4000) provides two different  indicators per 

measure:  

53 

54 

 FRMPs:  BG1000,  Chapter  6,  pp.89-97;  BG2000,  Chapter  6,  pp.97-108;  BG3000,  Chapter  6,  pp.198-209; 
BG4000, Chapter 6, pp.63-78 and Annex 4. 
 These  measures  are  not  explicitly  listed  in  the  PoMs,  they  are  just  mentioned  in  the  FRMPs  chapters  and 
include e.g. carrying out monitoring of the water quality after floods, issuing permits for new or reconstruction 
of existing  flood management systems, inspection of dam  walls and other equipment,  keeping a record of the 
implementation of the PoM etc. 

36 

 
 
                                                           
 

 

indicators  for  tracking  implementation  progress  (e.g.  number  of  initiatives,  number  of 
normative documents, number of inspections etc.) and  

indicators for tracking progress towards achieving the objectives (e.g. minimised number 
of  people  impacted  by  floods,  improved  administrative  capacity  for  FRM,  ensured 

protection for the life and health of the population in APSFRs, ensured protection of the 
critical infrastructure or environment etc.). 

Even  though  all  FRMPs  report  indicators  for  tracking  the  progress  towards  achieving  the 

national  objectives,  they  do  not  provide  information  about  baseline  values  against  which  the 
progress  will  be  assessed.  The  Danube  FRMP  (BG1000)  states  that  baseline  values  will  be 

defined for all indicators, however it is not clear if this process has been completed and what 
the outcomes are. Baseline values are not mentioned in the other three FRMPs.  

4.13  Coordination with the WFD 

The  table  below  shows  how  the  development  of  the  FRMP  has  been  coordinated  with  the 

development of the second RBMP of the WFD. 

Table 9 

Coordination  of  the  development  of  the  FRMP  with  the  development  of  the 

second RBMP of the WFD  

All UoMs assessed 

Integration of FRMP and RBMP into a single plan 

Joint consultation of draft FRMP and RBMP  

Coordination between authorities responsible for developing FRMP and RBMP  

Coordination with the environmental objectives in Art. 4 of the WFD  

The objectives of the FD were considered in the preparation of the RBMPs a 

Planning of win-win and no-regret measures in the FRMP 

The RBMP PoM includes win-win measures in terms of achieving the objectives of 
the WFD and FD, drought management and NWRMs a 

Permitting or consenting of flood risk activities (e.g. dredging, flood defence 
maintenance or construction) requires prior consideration of WFD objectives and 
RBMPs  

Natural water retention and green infrastructure measures have been included  

Consistent and compliant application of WFD Article 4(7) and designation of heavily 
modified water bodies with measures taken under the FD e.g. flood defence 
infrastructure  

The design of new and existing structural measures, such as flood defences, storage 
dams and tidal barriers, have been adapted to take into account WFD Environmental 
Objectives a  

37 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

 
 
 
 
 
The use of sustainable drainage systems, such as the construction of wetland and 
porous pavements, have been considered to reduce urban flooding and also to 
contribute to the achievement of WFD Environmental Objectives  
Notes: a based on reporting under the WFD 

The  FRMPs  and  the  RBMPs  in  Bulgaria  are  developed  by  the  same  authorities  -  the  Basin 

Directorates.  In  addition,  the  national  law  requires  the  public  consultations  for  both  types  of 
plans to be run in parallel so the public consultations for each of the draft FRMPs and RBMPs 

for the 2016-2021 period were conducted in parallel. Furthermore, to ensure compatibility and 
synergies between the plans, the analysis of the draft FRM measures included an assessment of 

the impacts of each draft measure on the objectives of the WFD. Measures that were assessed 
to  have  a  positive  or  neutral  impact  were  included  in  the  FRMPs,  while  measures  with 

potentially negative impacts were further assessed to determine if any exception in accordance 
with  Art.4.7  could  be  defined.  The  RBMPs  also  contain  information  about  the  synergies 
between the FRM objectives and measures and the objectives of the WFD55. Moreover, each of 
the FRMPs includes green infrastructure or NWRMs that are compatible with the objectives of 
the WFD56. 

Each  of  the  FRMPs  provides  information  about  the  identified  synergies  of  the  planned 

measures  with  the  objectives  of  the  WFD  and  the  respective  RBMPs.  This  information  is 
presented differently in each of the plans:  

The  FRMPs  for  the  Danube  (BG1000),  the  Black  Sea  (BG2000)  and  the  West  Aegean 

(BG4000) contain annexes with a list of the RBMP measures that have a positive impact on the 
objectives of the FRMPs in the particular UoM/RBD (the measures in  BG1000 and BG2000 

are presented per type of measure based on the national catalogue of RBMP measures, while in 
BG4000 the measures are listed per water body; however, the measures are presented without 

being  related  to  specific  FRM  objectives).  Examples  of  such  measures  include  (but  are  not 
limited  to):  protection  from  erosion;  collection  and  treatment  of  waste  water  in  urban  areas; 

ensuring direct water currents and fish movements; mitigation of the climate change pressures 
and improvement of the hydro-morphological conditions of rivers.  

The  FRMP  for  the  East  Aegean  (BG3000)  presents  the  information  the  other  way  around  - 
with a list of the FRMP measures that are compatible with the objectives of the RBMP of the 

RBD  (the  measures  are  presented  per  water  body).  Examples  of  such  measures  include 

55   RBMPs: BG1000, Chapter 5.1.3 and 5.1.4 (pp.V-13-V-21) and Annexes 5.1.3.1, 5.1.3.2 and 5.1.3.2.A; BG2000, 
Chapter  5.1.3  (pp.12-13);  BG3000,  Chapter  5.1.2.4  and  5.1.3  (pp.23-28)  and  Annexes  05  and  07;  BG4000, 
Chapter 5.1.2 and 5.1.3 (pp.246-255). 
 FRMPs:  BG1000,  Chapter  7,  pp.97-102  and  Chapter  11,  pp.123-134;  BG2000,  Chapter  7,  pp.108-112  and 
Chapter  11,  pp.137-139;  BG3000,  Chapter  7,  pp.210-213  and  Chapter  11,  pp.230-237;  BG4000,  Chapter  7, 
pp.79-80 and Chapter 11, pp.92-97. 

56 

38 

 
 
 
                                                           
afforestation,  limiting  any  new  negative  impacts  on  the  hydrological  conditions  of  water 
bodies, rehabilitation and maintenance of sewage systems57. 

In  its  reporting  sheets  on  the  FRMPs,  Bulgaria  provided  information  in  the  field  “WFD 
Measures”. 

In  its  reporting  under  the  WFD,  Bulgaria  indicated  that  the  objectives  of  the  FD  were 

considered  in  the  preparation  of  its  RBMPs.  Bulgaria  also  reported  that  the  PoMs  included 
win-win  measures  in  terms  of  achieving  the  objectives  of  the  WFD  and  FD,  drought 

management and NWRMs. 

4.14  Good practices and areas for further development with regard to 

measures 

The following good practices were identified: 

  All  FRMPs  provide  information  about  the  location,  cost,  responsible  authority  and 
priority  of  each  planned  measure.  In  addition,  this  information  is  provided  in  a  reader-

friendly tabular format as annexes to the FRMPs.  

  All FRMPs include NWRMs.  

  All FRMPs contain national indicators for tracking the progress towards the achievement 
of the objectives. The FRMPs for the Black Sea (BG2000), the East (BG3000) and West 
Aegean (BG4000) define also indicators for tracking the implementation of some of the 

planned  measures. The  FRMP for the West  Aegean (BG4000)  goes  one  step further to 
define  two  separate  indicators  per  planned  measure  -  one  for  tracking  implementation 

progress and one for tracking progress towards achieving the objectives. 

The following areas for further development were identified:  

  Even though all FRMPs refer to the timely implementation of the measures and explain 
that  the  timelines  will  be  considered  when  monitoring  the  progress  of  implementation, 
they do not include what the timeline for each measure or group of measures is.  

  Although,  indicators  for  tracking  progress  of  the  national  and  UoM-specific  objectives 
have  been  formulated,  there  is  no  information  against  what  baseline  values  these 

indicators will be measured. 

57 

 FRMPs:  BG1000,  Chapter  7,  pp.97-102  and  Annex  13;  BG2000,  Chapter  7,  pp.108-112  and  Annex  18.2; 
BG3000, Chapter 7, pp.210-213 and Annex 7; BG4000, Chapter 7, pp.79-80 and Annex 8. 

39 

 
 
 
 
                                                           
5.   Consideration of climate change 

Measures to mitigate the expected effects of climate change are planned in only one of the four 
FRMPs.  Only  the  Danube  FRMP  (BG1000)  explicitly  identifies  measures  that  address  the 

impacts of climate change. These measures are: increasing awareness and preparedness of the 
population  to  floods;  new  flood  protection  equipment  designed  with  the  possibility  to  be 

adapted in the future; new information about the expected climate change impacts to be taken 
into  account  in  future  versions  of  the  FRMP.  The  FRMPs  of  the  other  three  UoMs  do  not 

identify measures that have been planned to address climate impacts, even though their PoMs 
contain  similar  measures  to  those  in  the  Danube  FRMP  i.e.  increasing  the  awareness  and 

preparedness of the population to floods. In addition, other measures that can be beneficial for 
mitigating the impacts of climate change have been planned across the four FRMPs, namely: 

establishment of an early warning system (all UoMs); issuing of a daily hydrometeorological 
bulletin (all UoMs); ban of wood cutting in catchment areas and increase of the forested area/ 
afforestation (BG2000, BG3000 and BG4000)58. 

None  of  the  FRMPs  refers  to  the  national  Climate  Change  Adaptation  Strategy,  and  the 
Climate-ADAPT website59 indicates that this strategy is still being prepared. Nevertheless, two 
of the four FRMPs – the Black Sea FRMP (BG2000) and the West Aegean FRMP (BG4000) – 
mention  the  Third  National  Climate  Change  Action  Plan  for  the  period  2013-2020  in  the 
chapter  on  coordination  with  other  plans  and  strategies  as  a  plan  relevant  for  the  FRMPs60. 
This  Action Plan provides information  and analysis of the  relevant  climate action policies at 
EU and national level, impacts, mitigation and adaptation measures per economic sector. 

Climate  change  scenarios  were  specifically  considered  in  three  of  the  four  FRMPs.  In  the 

Danube FRMP (BG1000), climate change was one of the significant factors considered during 
the preparation of the PoMs and some forecasts about the expected effects of climate change in 

the Danube UoM were considered. However, the FRMP does not indicate if different scenarios 
were  considered.  In  the  Black  Sea  (BG2000)  and  East  Aegean  (BG3000)  FRMPs,  climate 

change  impacts  were  considered  under  different  scenarios.  In  both  cases  the  scenarios  were 
based on IPCC information and the IPCC scenarios RCP 4.5 (emission reductions post-2050) 
and RCP 8.5 (business as usual). In both cases the timeframes considered were up to 210061. 

In  the  West  Aegean  FRMP  (BG4000),  climate  change  was  not  considered  during  its 

preparation. 

58 

59 

60 

61 

 Reporting  sheets:  Summary  of  Climate  Change;  FRMPs:  BG1000,  Chapter  13,  pp.  136-139  and  Annex  9; 
BG2000, Annex 18; BG3000, Annex 5; BG4000, Annex 4 and Annex 8. 
 http://climate-adapt.eea.europa.eu/countries-regions/countries/bulgaria (visited November 2018) 
 FRMPs: BG2000, Chapter 8, p. 118. 
 Reporting sheets: Summary of Climate  Change; FRMPs: BG1000, Chapter 5, p. 75 and Chapter 13, pp. 136-
139; BG2000, Chapter 3, p.48; BG3000, Chapter 3, pp.71-72; BG4000, Chapter 13, p.106. 

40 

 
 
                                                           
The results of the climate change scenarios are not discussed in the FRMPs. Nevertheless, the 
FRMPs  for  the  Danube  (BG1000)  and  the  East  Aegean  (BG3000)  make  reference  to  the 

expected climate change impacts based on available literature and point out that:  

 

In  the  Danube  UoM:  flash  floods  caused  by  extreme  rainfall  might  occur  more 

frequently; the risk of spring floods would be lower due to a decrease in the snow cover; 
the  frequency  of  winder  floods  might  change  due  to  different  rainfall  intensity,  snow 

cover and extreme events.  

 

In the East Aegean UoM: the probability of winter floods would increase; the frequency 

and  probability  of  formation  of  ‘high  tidal  waves’  would  increase  as  a  result  of  the 
increasing  temperatures  and  earlier  and  faster  snow  melting;  droughts  and  lower  water 
flow would be observed62. 

5.1. Specific measures planned to address climate change 

According to the available information in the reporting sheets and the FRMPs, climate change 
was considered during the preparation of the FRMPs for the Danube (BG1000), the Black Sea 

(BG2000) and the East Aegean (BG3000). Even though there are measures in the PoMs of all 
four UoMs that can (have beneficial impacts and contribute to the mitigation of climate change 

impacts,  it  is not clear whether or which of the planned measures are specifically planned to 
mitigate the climate change impacts as a result of the climate change analyses63. 

5.2. Good practices and areas for further development concerning climate 

change 

The following area for further development was identified: 

  While climate change is considered in the preparation of three of the four FRMPs, and in 
two  of  those  different  scenarios  were  taken  into  account,  the  FRMPs  do  not  explicitly 
relate  the  results  of  the  climate  change  considerations  to  the  measures  planned  e.g.  to 

justify  or  explain  the  choices  made.  Coordination  with  the  national  adaptation  strategy 
should be ensured once the strategy is adopted. Nonetheless, all four FRMPs specify that 
climate change will be considered further in the update of the plans during the 2nd cycle 
of implementation. 

62 

63 

 FRMPs: BG1000, Chapter 13, p.136; BG3000, Chapter 5, pp.194-195. 
 Reporting  sheets:  Summary  of  Climate  Change;  FRMPs:  BG1000,  Chapter  13,  pp.  136-139  and  Annex  9; 
BG2000, Annex 18; BG3000, Annex 5; BG4000, Annex 4. 

41 

 
 
 
 
                                                           
6. Cost-benefit analysis 

A CBA was used for the prioritisation and planning of all measures in all four of the FRMPs. 
A national CBA methodology was applied in all four FRMPs. The national methodology was 

based on the 'Guide to Cost-Benefit Analysis of Investment Projects: Economic Appraisal Tool 
for Cohesion Policy 2014 - 2020': the methodology was prepared under a call for proposals in 

the  West  Aegean  UoM  and  funded  by  OP  Environment  2007-2013.  The  methodology  has 
several components:  

  Financial analysis - in this analysis the direct costs of the measures (e.g. investment and 
operational  costs)  are  estimated  together  with  their  financial  net  present  value.  The 
investment and operational costs for all measures are included in the national catalogue 

of measures and the analyses in each of the FRMPs is based on these national estimates. 
Generally, the national catalogue provides estimates for the costs of all measures except 

those that are an inherent part of the work/services of public institutions and as such are 
part of the institutions' overall costs (e.g. measures for development of plans, monitoring, 

transboundary  coordination  etc.).  In  the  case  of  non-structural  measures,  it  is  assumed 
that they have only operational costs.  

  Economic analysis - here the analysis is expanded to include other costs (if relevant) and 
benefits of the measures. The results of the financial analyses are used as estimates for 

the costs while the value of 'avoided damages' is used as an estimate for the benefits of 
the  measures.  The  value  of  avoided  damages  is  based  on  different  categories  of  assets 

(e.g.  homes,  public  infrastructure  or  land)  and  available  information  about  their  value 
e.g.  from  the  National  Statistical  Institute  or  public  administration.  Once  all  costs  and 

benefits  are  valorised,  the  Economic  Net  Present  Value  (ENPV)  and  the  Economic 
Internal Rate of Return (EIRR) of the measures are estimated together with the benefits-

costs ratio. The costs and benefits of each measure for a certain ASPFR are valorised for 
three scenarios (20-year, 100-year and 1000-year flood occurrence) based on the damage 

information  from  the  FHRMs,  except  for  the  Danube  UoM  (BG1000)  where  the  CBA 
was  performed  only  for  the  100-year  scenario.  The  scenario  that  generates  the  highest 

ENPV,  the  highest  EIRR  and  the  highest  benefits-costs  ratio  for  a  given  ASPFR  is 
chosen (however, results from this analysis are not provided in the FRMPs). Finally, all 

selected  scenarios  are  consolidated  to  define  a  combination  of  measures  for  the  whole 
UoM.  

  Uncertainties and risk analysis - here different uncertainties and risks are considered in 

the CBA (e.g. the different flood risks and scenarios as defined in the FHRMs).  

The FRMPs provide detailed information about all assumptions used in the CBA. Some of the 

key  ones  are:  the  reference  period  is  the  period  for  implementation  of  the  FRMP  i.e.  2016-
2021; the distribution of benefits is even for each remaining year of the reference period after 

42 

 
 
the measure's implementation; the social discount rate is 5% as recommended in the 'Guide to 
Cost-Benefit  Analysis  of  Investment  Projects:  Economic  Appraisal  Tool  for  Cohesion  Policy 
2014 - 2020'64.  

The  available  information  about  the  CBA  methodology  does  not  indicate  if  the  CBA  was 

applied  to  measures  with  transboundary  effects  or  if  multi-benefits  were  considered  in  the 
economic analysis. However, this does not mean that multi-benefits were not considered in the 

qualitative analysis. As  previously mentioned, the synergies between  FRM measures  and the 
WFD objectives  were considered and various measures beneficial for both  the WFD and the 
Flood Directive’s objectives were included in the FRMPs65. 

6.1. Good practices and areas for further development 

The following good practice was identified: 

  All FRMPs provide a description of the CBA methodology either in the main text or in 
Annexes. The methodology seems comprehensive and consistent with the Commission's 

'Guide  to  Cost-Benefit  Analysis  of  Investment  Projects:  Economic  Appraisal  Tool  for 
Cohesion  Policy  2014  -  2020'.  The  applied  CBA  methodology  valorises  the  costs  and 

benefits of all measures.  

The following areas for further development were identified: 

  Presently  the  FRMPs  for  the  Black  Sea  (BG2000,  Annex  20)  and  the  West  Aegean 
(BG4000,  Annex 7) provide annexes  with  the results  of the CBA for all  measures  in  a 

certain APSFR (i.e. the information is presented per APSFR and not per measure). This 
practice should be extended to measures in the other two FRMPs. 

 

It is unclear if and how measures with transboundary effects have been considered in the 

CBA. 

64 

65 

 FRMPs: BG1000, Chapter 5, pp.79-84; BG2000, Chapter 5, p.90 and Annexes 19 and 20; BG3000, Chapter 5, 
pp.119-140; BG4000, Chapter 5, pp.51-54 and Annexes 6 and 7. 
 FRMPs: BG1000, Chapter 5, pp.79-85; BG2000, Chapter 5, p.90-92 and Annexes 19 and 20; BG3000, Chapter 
5, pp.119-150; BG4000, Chapter 5, pp.51-54 and Annexes 6 and 7. Reporting sheets: Summary of Cost/Benefit. 

43 

 
 
                                                           
7.  Governance including administrative arrangements, public 

information and consultation 

7.1. Competent authorities 

The UoMs and the competent authorities for each UoM identified for the FD have not changed 

since they were first reported to WISE in 2012. 

7.2. Public information and consultation 

The table below shows how the public and interested parties were informed in the four UoMs 
assessed concerning the  draft FRMPs.  Information how the consultation  was actually carried 

out and which stakeholders participated is presented in the rest of the section: 

Table 10 

Methods used to inform the public and interested parties of the FRMPs 

Media (papers, TV, radio)  

Internet  

Digital social networking  

Printed material  

Direct mailing  

Invitations to stakeholders  

Local Authorities  

Meetings  

Information centres at the Basin Directorates 

Surveys 

Thematic events/celebrations of environmental days  

Source: FRMPs 

BG1000  BG2000  BG3000  BG4000 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

Each of the draft FRMPs (including their PoMs) were open for six-month public consultations. 
In  all  four  UoMs  the  public  and  the  stakeholders  were  informed  through  publications  on  the 
websites of the Basin  Directorates or local  authorities, announcements in national  media and 
during  stakeholder  meetings.  In  addition,  some  of  the  Basin  Directorates  distributed 

brochures/leaflets  or  other  materials  (BG1000,  BG2000,  BG3000).  Three  of  the  UoMs 
(BG2000,  BG3000,  BG4000)  also  maintain  a  list  of  relevant  stakeholders  and  sent  direct 

invitations  for  meetings  informing  them  of  the  FRMPs  consultations.  Two  of  the  UoMs 
(BG2000  and  BG3000)  also  report  that  they  maintain  information  centres  at  the  Basin 

Directorates  and  use  thematic  events  or  celebrations  of  environmental  days  to  inform  the 

44 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
public  of  ongoing  consultations.  One  of  the  UoMs  (BG3000)  reports  that  the  public  was 
informed also through a social survey66. 

The table below shows how the actual consultation was carried out: 

Table 11 

Methods used for the actual consultation 

Via Internet  

Via Digital social networking 

Direct invitation  

Exhibitions  

Workshops, seminars or conferences  

Telephone surveys  

Direct involvement in drafting FRMP  

Basin Councils  

Surveys or questionnaires (face-to-face or online surveys) 

Source: FRMPs 

In all four UoMs the public consultation of the FRMPs was carried out:  

All UoMs assessed 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

  Through direct involvement in the preparation of the FRMPs. This usually took the form 
of meetings e.g. stakeholder meetings at regional and national levels and meetings of the 
Basin Councils. All four of the UoMs have Basin Councils (as required by national law) 

that consist of different stakeholders and provide feedback during the preparation of the 
FRMPs (for further information see the section on ‘active involvement of stakeholders’ 

below). In addition, the East Aegean FRMP (BG3000) reports also that a social survey 
was  carried  out  during  the  preparation  of  the  Plan  in  order  to  ask  the  public  what  the 

main  issues  and  needs  that  the  Plan  should  address  are.  The  Danube  FRMP  (BG1000) 
reports  that  during  the  preparation  of  the  plan,  a  survey  questionnaire  for  gathering 

opinions  about  the  FRMP  was  available  on  the  Basin  Directorate's  website,  on  the 
websites of the nine regional governors and on the website of the private company that 

carried  out  the  public  consultation  (after  winning  a  public  procurement  call  financed 
through OP Environment 2007-2013). Both FRMPs provide a summary of the surveys’ 
results, the Danube FRMP (BG1000) provides also a weblink67 to the complete analysis 
and results of the survey. 

  Via the internet - the draft FRMPs for consultation were published on the websites of the 

Basin Directorates.  

66 

 FRMPs: BG1000, Chapter 11, pp.118-134; BG2000, Chapter 11, pp.129-139; BG3000, Chapter 11, pp.220-237; 
BG4000, Chapter 11, pp.86-97. 
 Results of the survey carried out in the preparation of the BG1000 FRMP: 

67 
http://www.bd-dunav.org/uploads/content/files/konsultacii-s-obshtestvenostta/Rezult_Anketa_PURN_Web.pdf 

45 

 
 
 
 
 
 
                                                           
  During  stakeholder  meetings  -  stakeholder  meetings  to  discuss  the  draft  FRMPs  were 

organised at regional, UoM/RBD and national levels.  

  Via  surveys  and  questionnaires  -  surveys  or  questionnaires  of  different  length  (in  the 
different UoMs) were published on the websites of the Basin Directorates or distributed 
during stakeholder meetings to collect feedback on the draft FRMPs68.  

Table 12 

Methods used to provide the documents for the consultation 

Downloadable 

Direct mailing (e-mail) 

Direct mailing (post) 

Paper copies distributed at exhibitions 

Paper copies available in municipal buildings (town hall, library etc.) 

Source: FRMPs 

All UoMs 

✔ 

Information  about  how  the  documents  for  the  consultation  were  provided  is  not  explicitly 

reported  within  the  FRMPs.  The  draft  FRMPs  were  published  on  the  websites  of  the  Basin 
Directorates but the FRMPs do not specify in what other formats the drafts were shared with 
the stakeholders69. 

7.3. Active involvement of Stakeholders 

As  part  of  the  overall  consultation,  authorities  should  encourage  the  active  involvement  of 

stakeholders.  The  table  below  shows  the  groups  of  stakeholders  that  have  been  actively 
involved in the development of the four FRMPs assessed: 

Table 13 

Groups of stakeholders  

Civil Protection Authorities such as Government 
Departments responsible for emergency planning and 
coordination of response actions 

Flood Warning / Defence Authorities70  

Drainage Authorities  

Emergency services  

Water supply and sanitation  

BG1000 

BG2000 

BG3000 

BG4000 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

68 

69 

70 

 FRMPs:  BG1000,  Chapter  11,  pp.118-134;  BG2000,  Chapter  11,  pp.129-139;  BG3000,  Chapter  11,  pp.220-
237; BG4000, Chapter 11, pp.86-97. 
 FRMPs:  BG1000,  Chapter  11,  pp.118-134;  BG2000,  Chapter  11,  pp.129-139;  BG3000,  Chapter  11,  pp.220-
237; BG4000, Chapter 11, pp.86-97. 
 The national authorities clarified that these are the same stakeholders as the Civil Protection Authorities. 

46 

 
 
 
 
 
 
 
 
 
 
 
 
                                                           
BG1000 

BG2000 

BG3000 

BG4000 

Agriculture / farmers  

Energy / hydropower  

Navigation / ports  

Fisheries / aquaculture  

Private business (Industry, Commerce, Services) 

NGOs including nature protection, social issues (e.g. 
children, housing) 

Consumer Groups  

Local / Regional authorities  

Academia / Research Institutions  

National authorities, citizens, water users and owners  

Source: FRMPs 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

As previously mentioned, all UoMs have Basin Councils, which are required by the national 

law and whose composition and obligations are defined in the law. According to the examples 
provided  in  the  Danube  FRMP  the  Basin  Councils  consist  of  representatives  of  local  and 

regional administration, national ministries and authorities, the public water supply and sewage 
company,  the  Bulgarian  Academy  of  Science  and  other  academic  institutions,  water  users, 

NGOs and others. According to the website of the Black Sea Basin Directorate, the split of the 
members  of  the  Basin  Council  is  as  follows:  local  administration  (30  %),  water  users  and 

owners (30 %), national administration (20 %) and NGOs and research institutions (20 %). The 
overall role of the Basin  Councils is to  support the Basin  Directorates in the management of 

the UoMs/RBDs. They are consulted during the preparation of the FRMPs and participate in 
meetings during the public consultation of the draft plans71.  

In  addition,  different  stakeholders  provide  feedback  on  the  draft  FRMPs  during  the  public 
consultations.  Although  the  FRMPs  do  not  list  all  stakeholders  that  participated  in  the 
stakeholder  meetings  to  discuss  the  draft  FRMPs,  the  websites  of  the  Basin  Directorates 
provide information  about  all consultation  meetings that took  place together with  lists of the 

participants.  This  information  shows  that  the  draft  FRMPs  were  consulted  with  e.g.  national 
ministries  and  authorities  (e.g.  agencies  for  civil  protection,  nature  protection  etc.),  regional 

and  local  authorities,  citizens,  businesses,  agriculture,  aquaculture  and  port  stakeholders,  the 

71  FRMPs: BG1000, Chapter 11, pp.118-134; BG2000, Chapter 11, pp.129-139; BG3000, Chapter 11, pp.220-237; 
BG4000, Chapter 11, pp.86-97. Website of the Black Sea RBD: https://www.bsbd.org/bg/basin_board.html 

47 

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
National  Energy  Company,  NGOs,  research  institutions  and  the  public  water  supply  and 
sewage company72. 

The table below shows the mechanisms used to ensure the active involvement of stakeholders: 

Table 14 

Mechanisms used to ensure the active involvement of stakeholders 

Regular exhibitions  

Establishment of advisory groups  

Involvement in drafting  

Formation of alliances  

Surveys and questionnaires 

Printed materials  

Interactive online tools 

BG1000  BG2000  BG3000  BG4000 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

✔ 

Source: FRMPs 

In  addition  to  the Basin  Councils, which  can be  considered  as advisory  groups,  and surveys, 
some  FRMPs  report  using  surveys  and  questionnaires.  One  of  the  FRMPs  (BG3000)  also 

mentions the creation of an interactive tool for visualisation and sorting of all draft measures 
that aimed to facilitate the stakeholders' involvement73. 

72 

 FRMPs:  BG1000,  Chapter  11,  pp.118-134;  BG2000,  Chapter  11,  pp.129-139;  BG3000,  Chapter  11,  pp.220-
237; BG4000, Chapter 11, pp.86-97. 
Websites  of  the  Basin  Directorates  with  information  about  the  stakeholder  meetings  (together  with  lists  of 
participants) for each UoM: 

  BG1000:http://www.bd-dunav.org/content/konsultacii-s-obshtestvenostta/konsultacii-pri-izgotviane-na-

purn/konsultacii-v-dunavski-rayon-za-baseynovo-upravlenie/   

  BG2000: https://www.bsbd.org/bg/index_bg_8808391.html   
  BG3000: https://earbd.bg/indexdetails.php?menu_id=603   
  BG4000: https://wabd.bg/index.php/2015-06-25-12-25-12/2016-12-09-14-33-54  
73  FRMPs: BG1000, Chapter 11, pp.118-134; BG2000, Chapter 11, pp.129-139; BG3000, Chapter 11, pp.220-237; 

BG4000, Chapter 11, pp.86-97. 

48 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
7.4. Effects of consultation 

The table below shows the effects of consultation: 

Table 15 

Effects of consultation 

Changes to selection of measures 

Adjustment to specific measures 

Addition of new information 

Changes to the methodology used 

Commitment to further research 

Commitment to action in the next FRMP cycle 

Source: FRMPs 

All UoMs assessed 

✔ 

✔ 

In all four FRMPs the PoMs were revised as a result of the public consultations. All revisions 
to the PoMs are reported in dedicated annexes of the FRMPs. In general, the following changes 

were made:  

  new measures were added to the PoM;  

  details  of  selected  measures  were  modified  e.g.  the  responsible  authority,  location  or 

cost;  

  some measures were reformulated or merged;  

  some  measures  were  removed  usually  due  to  same  or  similar  measures  existing  in  the 

RBMPs74.  

7.5. Strategic Environmental Assessment 

All  four  FRMPs  underwent  a  SEA  procedure.  Moreover,  the  results  of  the  SEA  procedures 
were  open  for  public  consultations  at  the  same  time  as  the  FRMPs  and  both  drafts  were 

discussed together in the process of the public consultations. Overall, all four FRMPs focus on 
providing  information  about  the  conclusions  of  the  SEA  procedures  rather  than  the 

methodology  for  the  SEA.  Two  of  the  FRMPs  (BG2000  and  BG4000)  provide  information 
about the step-by-step process of preparing the SEA, however a methodology is not explicitly 

reported. All four FRMPs contain annexes with a summary of the mitigation measures to take 
during the implementation of the FRMPs according to the SEA, one of the FRMPs (BG4000) 
even annexed the whole SEA document and all its annexes75. 

74 

75 

 FRMPs:  BG1000,  Annex  12;  BG2000,  Annex  18.1; BG3000,  Annex  5.1;  BG4000,  Chapter  11, pp.95-97  and 
Annex 11. 
 FRMPs:  BG1000,  Chapter  12,  pp.134-136  and  Annexes  16  and  17;  BG2000,  Chapter  12,  pp.139-144  and 
Annex 26; BG3000, Chapter 12, pp.237-242 and Annex 5.3; BG4000, Chapter 12, pp.97-106 and Annex 12. 

49 

 
 
 
 
 
 
 
                                                           
7.6. Good practices and areas for further development regarding 

Governance 

The following good practices were identified:  

  All  four  FRMPs  provide  details  about  the  public  consultations  in  dedicated  chapters 
often  summarising  the  general  stakeholder  involvement  strategy  before  describing  the 

actions  for  consultation  for  the  different  steps  of  the  FRMPs  (i.e.  PFRA,  APSFRs, 
FHRMs).  

  The  information  is  detailed  with  references  to  locations  and  dates  of  the  stakeholder 

meetings.  

 

In  addition,  each  of  the  FRMPs  includes  an  annex  that  summarises  the  changes  to  the 

PoMs resulting from the public consultations measure by measure. 

The following area for further development was identified: 

  The  next  FRMPs  should  include  a  list/summary  of  the  types  of  stakeholders  consulted 
during the public consultations. In the current versions, this information is available but 
scattered  across  the  chapters  on  public  consultation.  Links  to  protocols/summaries  of 

public consultation meetings should be provided more consistently in the FRMPs. 

50 

 
 
 
 
Annex A: Supplementary tables and charts on measures 

This Annex gives an overview of the data on measures provided by Bulgaria in the reporting 

sheets. These tables and charts were used for the preparation of section 4 on measures.   

Background & method 

This document was produced as part of the assessment of the Flood Risk Management Plans 
(FRMPs). The tables and charts below are a summary of the data reported on measures by the 

Member States and were used by the Member State assessor to complete the questions on the 
Flood  measures.  The  data  are  extracted  from  the  XMLs  (reporting  sheets)  reported  by 

Member States for each FRMP, and are split into the following sections: 

  Measures overview – Tabulates the number of measures for each UoM; 

  Measure details: cost – Cost & Cost explanation; 

  Measures details: name & location – Location & geographic coverage; 

  Measure  details:  authorities  –  Name  of  responsible  authority  & 

level  of 

responsibility; 

  Measure details: objectives – Objectives, Category of priority & Timetable; 

  Measure details: progress – Progress of implementation & Progress description; 

  Measure details: other – Other Community Acts.  

On the basis of the reporting guidance (which in turn is based on the FD)76, not all fields are 
mandatory, and, as such, not all Member States reported information for all fields.  

Some of the fields in the XMLs could be filled in using standardised answers – for example, 

progress  is  measured via the categories set  out  in the Reporting Guidance. This  means that 
producing comprehensive tables and charts required little effort. For many fields, however, a 

free data format  was used. For some Member States, this resulted in  thousands of different 
answers, or answers given in the national language.  

In such situations, tables and charts were developed using the following steps: 

  A  first  filter  is  applied  to  identify  how  many  different  answers  were  given.  If  a  high 
number of different answers are given, Member States assessors were asked to refer to 
the  raw  data  when  conducting  the  assessment,  and  this  Annex  does  not  reflect  these 

observations. 

76 

 http://icm.eionet.europa.eu/schemas/dir200760ec/resources 

51 

 
 
                                                           
 

If  a  manageable  number  of  answers  are  given,  obvious  categories  are  identified,  and 

raw data sorted. 

  Measures  missing  information  may  be  assigned  categories  based  on  other  fields  (for 
example,  if  the  level  of  Responsibility  Authority  is  missing,  the  information  may  be 
obvious from the field “name of Responsible Authority”). 

  Measures  where  obvious  categories  cannot  be  defined  based  on  other  available 
information (as in the example on the name of the Responsible Authority, above), are 

categorised as “no information”. 

Types of measures used in reporting  

The  following  table77  is  used  in  the  reporting  on  the  types  of  measures.  Each  type  of 
measures is coded as an M-number. Measures are grouped in an ‘aspect’. 

Table A1 

Types of measures used in reporting 

NO ACTION 

M11: No Action 

PREVENTION 

M21: Avoidance 

PREPAREDNESS 

M41: Flood Forecasting & Warning 

M42: Emergency response planning 

M43: Public Awareness 

M44: Other preparedness 

RECOVERY & REVIEW 

M51: Clean-up, restoration & personal recovery 

M22: Removal or relocation 

M52: Environmental recovery 

M23: Reduction 

M24: Other prevention 

PROTECTION 

M31: Natural flood management 

M32: Flow regulation 

M33: Coastal and floodplain works 

M34: Surface Water Management 

M35: other protection 

M53: Other recovery 

OTHER MEASURES 

M61: Other measures 

77  Guidance for Reporting under the FD (2007/60/EC): 
    https://circabc.europa.eu/w/browse/a3c92123-1013-47ff-b832-16e1caaafc9a/ 

52 

 
 
 
 
 
 
 
                                                           
List of Annex A tables and figures 

 Total number of measures (aggregated and individual) per measure type and 

Table A1  Types of measures used in reporting ..................................................................... 53 
Table A2  Number of measures reported in the reporting sheets ........................................... 55 
Table A3  Total number of measures (aggregated and individual) per measure type and 
UoM, including duplicates ....................................................................................................... 55 
Table A4  Number of individual measures per measure type and UoM ................................ 56 
Table A5 
UoM, including duplicates ....................................................................................................... 56 
Table A6  Timetable of implementation by measure aspect .................................................. 59 
Table A7  Geographic location by UoM ................................................................................ 59 
Table A8  Category of priority by measure aspect ................................................................. 61 
Table A9  Category of priority by UoM ................................................................................. 61 
Table A10  Level of responsibility by measure aspect ............................................................. 63 
Table A11  Level of responsibility by UoM ............................................................................. 64 
Table A12  Progress of implementation by measure aspect ..................................................... 66 
Table A13  Progress of implementation by UoM ..................................................................... 66 

Figure A1  Number of total measures (individual and aggregate) by measure aspect ............ 57 
Figure A2  Share of total measures (aggregated and individual) by measure aspect .............. 57 
Figure A3  Visualisation of Table A6: Geographic location by measure aspect ..................... 59 
Figure A4  Visualisation of Table A7: Geographic location by UoM ..................................... 60 
Figure A5  Visualisation of Table A8: Category of priority by measure aspect ..................... 61 
Figure A6  Visualisation of Table A9: Category of priority by UoM ..................................... 62 
Figure A7  Visualisation of Table A10: Level of responsibility by measure aspect ............... 64 
Figure A8  Visualisation of Table A11: Level of responsibility by UoM ............................... 65 
Figure A9  Visualisation of Table A12: Progress of implementation by measure aspect ....... 66 
Figure A10  Visualisation of Table A13: Progress of implementation by UoM ................... 67 

53 

 
 
 
Measures overview 

Table A2 

Number of measures reported in the reporting sheets 

Number of individual measures 

Number of individual measures including measures which have been allocated to more than one measure type 

Number of aggregated measures 

Number of aggregated measures including measures which have been allocated to more than one measure type 

Total number of measures 

Total number of measures including measures which have been allocated to more than one measure type 

Range of number of measures between UoMs including measures which have been allocated to more than one measure type (Min-Max) 

Average number of measures across UoMs including measures which have been allocated to more than one measure type 

133 

133 

61 

66 

194 

199 

32-66 

50 

Table A3 

Total number of measures (aggregated and individual) per measure type and UoM, including duplicates 

Prevention 

Protection 

Preparedness 

Recovery and review 

M21  M22  M24  M31  M32  M34  M35  M41  M42  M43  M44  M51  M52  M53  M61 

BG3000 

Grand Total 

Average per 
UoM 

6 

6 

6 

3 

3 

3 

16 

16 

16 

1 

1 

1 

5 

5 

5 

3 

3 

3 

6 

6 

6 

2 

2 

2 

3 

3 

3 

5 

5 

5 

6 

6 

6 

1 

1 

1 

3 

3 

3 

5 

5 

5 

1 

1 

1 

66 

66 

66 

Note: For the codes, see Types of measures (above), and Annex B. The total includes measures assigned to more than one measure type 

Note also that not all UoMs have aggregated measures, and thus not all UoMs are represented in this table. 

54 

Other  Grand 
Total 

 
 
 
 
 
 
 
Table A4 

Number of individual measures per measure type and UoM 

Prevention 

Protection 

Preparedness 

M21  M22  M24  M31  M32  M33  M34  M35  M41  M42  M43  M44 

Recovery 
& review 
M53 

Other 

M61 

Grand 
Total 

BG1000 

BG2000 

BG4000 

Grand Total 

2 

1 

1 

4 

1 

1 

1 

3 

11 

13 

4 

28 

2 

4 

1 

7 

4 

5 

5 

14 

3 

1 

4 

2 

1 

1 

4 

4 

3 

2 

9 

3 

1 

1 

5 

4 

4 

3 

11 

3 

3 

3 

9 

7 

5 

8 

20 

5 

4 

2 

11 

1 

3 

4 

1 
Average per 
UoM 
Note: For the codes, see Types of measures (above), and Annex B. The total includes measures assigned to more than one measure type. 

7 

3 

2 

5 

1 

2 

1 

1 

9 

4 

3 

4 

1 

52 

49 

32 

133 

44 

Note also that not all UoMs have aggregated measures, and thus not all UoMs are represented in this table. 

Table A5 

 Total number of measures (aggregated and individual) per measure type and UoM, including duplicates 

Prevention 

Aggregate Individual 

Total 

Protection 

Aggregate Individual 

Total 

Preparedness 

Aggregate Individual 

Total 

Recovery and review 

Aggregate Individual 

Total 

Other 

Aggregate Individual 

Total 

Grand 
Total 

BG1000 

BG2000 

BG3000 

25 

BG4000 

Grand 
Total 

25 

14 

15 

6 

35 

14 

15 

25 

6 

60 

15 

15 

15 

14 

9 

38 

15 

14 

15 

9 

53 

16 

16 

17 

13 

15 

45 

17 

13 

16 

15 

61 

9 

9 

5 

4 

2 

5 

4 

9 

2 

11 

20 

1 

1 

1 

3 

1 

3 

1 

52 

49 

66 

32 

4 

5 

199 

Average 
per UoM 
Note: For the codes, see Types of measures (above), and Annex B.  The total includes measures assigned to more than one measure type 

<1 

15 

10 

13 

11 

15 

5 

4 

2 

6 

9 

4 

3 

1 

1 

50 

55 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The information in Tables A3, A4 and A5 is visualised in Figures A1 and A2 below: 

Figure A1  Number of total measures (individual and aggregate) by measure aspect 

Notes: The total includes measures assigned to more than one measure type. 

Figure A2 

Share of total measures (aggregated and individual) by measure aspect 

Notes: The total includes measures assigned to more than one measure type. 

56 

 
 
 
 
 
 
Measure details: cost 

Member States were requested to report information on: 

  Cost (optional field); 

  Cost explanation (optional field). 

Cost was not given for any of the measures in the reporting sheets. (However, as explained in 

section  4  of  this  report,  the  FRMPs  did  provide  some  information  about  the  costs  of  the 
measures planned.)  

In  the  reporting  sheets,  cost  explanation  was  provided  for  101  measures  in  UoMs  BG1000 

and BG2000, no cost explanation was provided for UoMs BG3000 or BG4000.  

The  cost  explanation  for  the  measures  in  BG1000  is  the  same  for  all  measures:  ‘In  the 

Danube RBD, a cost-benefit analysis (CBA) was performed for the selected combinations of 
measures for management of the flood risks for each of the 26 AFSFR defined. In the analysis 

the costs of the planned measures for reducing the flood risk are compared to the economic 
benefits (avoided damage) in case of events with probability of occurring once in 100 years. 

The  impact  of  the  selected  combination  of  measures  on  reducing  the  flood  risk  and  on  the 
common wellbeing were assessed with the results of the CBA.’  

The cost explanation for all measures in BG2000 is: ‘On the basis of the conducted CBA for 

each  APSFR,  for  each  scenario  of  the  programme  of  measures  for  20,  100  and  1000-year 
wave, a programme of measures for each APSFR is chosen and included in the FRMP. The 

methodology for conducting the CBA can be found in Annex 19 of the FRMP’. 

Measure details: name & location 

Member States were requested to report information on the following: 

  Location of implementation of measures (mandatory field); 

  Geographic coverage of the impact of measures (optional field). 

Location of measures 

Bulgaria has reported this information  for all 199 measures. The different types of location 

given can be grouped in the following general categories: 

  APSFR; 

  Multiple APSFRs: when the measures cover more than one APSFR; 

57 

 
 
  UoM; 

  Other. 

Table A6 

Timetable of implementation by measure aspect 

APSFR 

Multiple 
APSFRs 

UoM 

Other 

Grand Total 

Prevention 

Protection 

Preparedness 

Recovery and review 

Other 

Grand Total 

10 

15 

16 

7 

4 

52 

33 

24 

5 

6 

68 

15 

14 

39 

7 

1 

76 

2 

1 

3 

60 

53 

61 

20 

5 

199 

Notes: The total includes measures assigned to more than one measure type. 

Figure A3 

Visualisation of Table A6: Geographic location by measure aspect 

Notes: The total includes measures assigned to more than one measure type. 

Table A7 

Geographic location by UoM 

APSFR 

Multiple APSFRs 

UoM 

Other 

Grand Total 

BG1000 

BG2000 

BG3000 

BG4000 

Grand Total 

Average per 
UoM 

8 

4 

8 

32 

52 

13 

16 

20 

32 

68 

17 

26 

24 

26 

76 

19 

2 

1 

3 

1 

52 

49 

66 

32 

199 

50 

Notes: The total includes measures assigned to more than one measure type. 

58 

 
 
 
 
 
 
 
 
 
 
 
 
 
Figure A4 

Visualisation of Table A7: Geographic location by UoM 

Notes: The total includes measures assigned to more than one measure type. 

Geographic coverage 

Bulgaria has provided information in the reporting sheets about the geographic coverage only 
of the measures in UoM BG4000, where the coverage is indicated as the RBD i.e. UoM.  

Measure details: objectives 

Member States were requested to report information on: 

  Objectives linked to measures (optional field, complementary to the summary provided 

in the textual part of the XML); 

  Category  of  priority  (Conditional,  reporting  on  either  ‘category  of  priority’  or 

‘timetable’ is required); 

  Timetable  (Conditional,  reporting  on  either  ‘category  of  priority’  or  ‘timetable’  is 

required). 

Objectives 

Objectives were reported for all 199 measures. As they vary largely, it has not been possible 
to aggregate the information.  

Category of priority 

The priority is reported for all 199 measures. The following categories are used in reporting: 

59 

 
 
  Critical; 

  Very high; 

  High; 

  Moderate; 

  Low. 

Table A8 

Category of priority by measure aspect 

Critical 

Very high 

High 

Moderate 

Low 

Grand Total 

Prevention 

Protection 

Preparedness 

Recovery and review 

Other 

5 

3 

9 

3 

1 

10 

6 

9 

32 

28 

30 

14 

3 

12 

11 

12 

1 

1 

5 

1 

2 

1 

Grand Total 

10 
Notes: The total includes measures assigned to more than one measure type. 

107 

36 

21 

25 

60 

53 

61 

20 

5 

199 

Figure A5 

Visualisation of Table A8: Category of priority by measure aspect 

Notes: The total includes measures assigned to more than one measure type. 

Table A9 

Category of priority by UoM 

Critical 

Very high 

High 

Moderate 

Low 

Grand Total 

BG1000 

BG2000 

BG3000 

21 

6 

15 

15 

14 

10 

52 

49 

66 

31 

25 

30 

60 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Critical 

Very high 

High 

Moderate 

Low 

Grand Total 

BG4000 

Grand Total 

Average per 
UoM 

21 

5 

4 

25 

6 

21 

107 

27 

7 

36 

9 

10 

3 

32 

199 

50 

Notes: The total includes measures assigned to more than one measure type. 

Figure A6 

Visualisation of Table A9: Category of priority by UoM 

Notes: The total includes measures assigned to more than one measure type. 

Timetable 

Bulgaria did not provide information on the timetable for any of the measures in the reporting 
sheets. 

Measure details: authorities 

Member States were requested to report information on: 

  Name of the responsible authority (optional if ‘level of responsibility’ is reported);   

  Level of responsibility (optional if ‘name of the responsible authority’ is reported).  

Bulgaria reported the level of the responsible authority for all measures except those for UoM 
BG4000. These blanks have been categorised following the examples from the other UoMs 

so that the level of responsible authority can be grouped in the following categories: 

  UoM/RBD authority;  

61 

 
 
 
 
 
 
  Municipal authorities - e.g. mayors;  

  District/regional authorities - e.g. regional governors;  

  National  authorities  -  this  includes  various  ministries  such  as  the  Ministry  of 
Environment and Water, the Ministry of Agriculture and Food, the Ministry of Energy 
etc. and associated national agencies or bodies such as the Directorate General for Fire 

Safety and Public Protection and the Agency for Road Infrastructure;  

  Other - this includes various actors such as the National Institute for Meteorology and 
Hydrology,  the  National  Energy  Company,  the  public  irrigation  system  operators  and 
owners of private facilities. 

Table A10 

Level of responsibility by measure aspect 

UoM/ RBD 
Authority 

District 
Authority 

Municipal 
Authority 

National 
Authority 

Other 

No 
Information 

Grand 
Total 

Prevention 

Protection 

Preparedness 

Recovery and 
review 

Other 

2 

9 

1 

6 

10 

7 

3 

22 

24 

8 

6 

2 

14 

7 

29 

1 

2 

18 

10 

7 

8 

1 

1 

1 

60 

53 

61 

20 

5 

12 

Grand Total 

2 
Notes: The total includes measures assigned to more than one measure type. 
Some of the measures have responsible authorities at different levels, for simplicity all these 

199 

26 

53 

44 

62 

measures have been classified under the first level of authority mentioned.  

62 

 
 
 
 
 
 
 
 
 
 
Figure A7 

Visualisation of Table A10: Level of responsibility by measure aspect 

Notes:  The 

total 

includes  measures  assigned 

to  more 

than  one  measure 

type. 

Some of the measures have responsible authorities at different levels, for simplicity all these 
measures have been classified under the first level of authority mentioned.  

Table A11 

Level of responsibility by UoM 

UoM/RBD 
Authority 

District 
Authority 

Municipal 
Authority 

National 
Authority 

No 
Information 

Other  Grand Total 

BG1000 

BG2000 

BG3000 

BG4000 

Grand Total 

Average per 
UoM 
Notes:  The 

2 

4 

1 

5 

12 

3 

4 

5 

13 

4 

26 

7 

19 

12 

19 

12 

62 

16 

13 

12 

24 

4 

53 

13 

2 

2 

1 

12 

16 

9 

7 

44 

11 

52 

49 

66 

32 

199 

50 

total 

includes  measures  assigned 

to  more 

than  one  measure 

type.  

Some of the measures have responsible authorities at different levels, for simplicity all these 
measures have been classified under the first level of authority mentioned. 

63 

 
 
 
 
 
 
 
Figure A8 

Visualisation of Table A11: Level of responsibility by UoM 

Notes:  The 
type. 
Some of the measures have responsible authorities at different levels, for simplicity all these 

includes  measures  assigned 

than  one  measure 

to  more 

total 

measures have been classified under the first level of authority mentioned. 

Measure details: progress 

Member States were requested to report information on: 

  Progress  of  implementation  of  measures  (mandatory  field)  –  this  is  a  closed  question 

whose responses are analysed below; 

  Progress  description  of  the  implementation  of  measures  (optional  field)  –  this  is  an 
open text question for which not all Member States reported and whose answers are not 

analysed here. 

Bulgaria  reported  information  about  the  progress  of  implementation  of  the  measures  in  the 
reporting sheets. The progress of implementation was reported as78:  

  COM (completed); 

  OGC (ongoing construction); 

  POG (progress ongoing); 

  NS (not started). 

78  Guidance for Reporting under the FD (2007/60/EC): 
    https://circabc.europa.eu/w/browse/a3c92123-1013-47ff-b832-16e1caaafc9a   

64 

 
 
                                                           
A full definition of these terms can be found at the end of this section.  

Table A12 

Progress of implementation by measure aspect 

Ongoing 
construction 

Progress ongoing 

Not started 

Grand Total 

Prevention 

Protection 

Preparedness 

Recovery and review 

Other 

Grand Total 

1 

1 

10 

6 

2 

1 

19 

49 

47 

59 

19 

5 

179 

60 

53 

61 

20 

5 

199 

Notes:  The  total  includes  measures  assigned  to  more  than  one  measure  type.  No  measures 
were reported as completed (COM). 

Figure A9 

Visualisation of Table A12: Progress of implementation by measure aspect 

Notes: The total includes measures assigned to more than one measure type. No measures 
were reported as completed (COM). 

Table A13 

Progress of implementation by UoM 

Ongoing 
construction 

1 

BG1000 

BG2000 

BG3000 

BG4000 

Progress ongoing 

Not started 

Grand Total 

43 

48 

56 

32 

52 

49 

66 

32 

9 

1 

9 

65 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ongoing 
construction 

Progress ongoing 

Not started 

Grand Total 

Grand Total 

Average per UoM 

1 

0 

19 

5 

179 

45 

199 

50 

Note: The total includes measures assigned to more than one measure type.  
No measures were reported as completed (COM). 

Figure A10  Visualisation of Table A13: Progress of implementation by UoM 

Note:  The  total  includes  measures  assigned  to  more  than  one  measure  type.  No  measures 
were reported as completed (COM). 

The categories describing the progress of measures are defined in the EU Reporting Guidance 

Document on the FD: 

For measures involving construction or building works (e.g. a waste water treatment plant, 
a fish pass, a river restoration project, etc.): 

  Not started (NS) means the technical and/or administrative procedures necessary for 

starting the construction or building works have not started. 

  Progress on-going (POG) means that administrative procedures necessary for starting 
the construction or building works have started but are not finalised. The simple 
inclusion in the RBMPs is not considered planning in this context. 

  On-going construction (OGC) means the construction or building works have started 

but are not finalized. 

  Completed (COM) means the works have been finalised and the facilities are 

operational (maybe only in testing period in case e.g. a waste water treatment plant). 

For measures involving advisory services (e.g. training for farmers): 

  Not  started  (NS)  means  the  advisory  services  are  not  yet  operational  and  have  not 

66 

 
 
 
 
 
provided any advisory session yet. 

  Progress  on-going  (POG)  means  the  advisory  services  are  operational  and  are  being 
used. This is expected to be the situation for all multi- annual long/mid-term advisory 
services that are expected to be operational during the whole or most of RBMP cycle. 

  On-going construction (OGC): Not applicable 
  Completed (COM) means an advisory service that has been implemented and has been 
finalised, i.e. is no longer operational. This is expected only for advisory services that 
are relatively short term or one-off, and which duration is time limited in relation to the 
whole RBMP cycle. 

For measures involving research, investigation or studies: 

  Not started (NS) means the research, investigation or study has not started, i.e. contract 

has not been signed or there has not been any progress. 

  Progress  on-going  (POG)  means  the  research,  investigation  or  study  has  been 

contracted or started and is being developed at the moment. 

  On-going construction (OGC): Not applicable 
  Completed  (COM)  means  the  research,  investigation  or  study  has  been  finalised  and 
has been delivered, i.e. the results or deliverables are available (report, model, etc.). 

For  measures 
instructions, etc.): 

involving  administrative  acts  (e.g. 

licenses,  permits,  regulations, 

  Not started (NS) means  the administrative file has not  been opened and  there has not 

been any administrative action as regards the measure. 

  Progress on-going (POG) means an administrative file has been opened and at least a 
first  administrative  action  has  been  taken  (e.g.  requirement  to  an  operator  to  provide 
information  to  renew  the  licensing,  request  of  a  permit  by  an  operator,  internal 
consultation of draft regulations, etc.). If the measure involves more than one file, the 
opening of one would mean already “ongoing”. 

  On-going construction (OGC): Not applicable 
  Completed (COM) means the administrative act has been concluded (e.g. the license or 
permit has been issued; the regulation has been adopted, etc.). If the measure involves 
more than one administrative act, “completed” is achieved only when all of them have 
been concluded. 

Measure details: other 

Member States were requested to report information on: 

  Other Community Acts associated to the measures reported (optional field); 

  Any other information reported (optional field). 

Only 18 of the measures reported by  Bulgaria provide information  about  other Community 

Acts  of  relevance  in  the  reporting  sheets;  all  measures  are  located  in  BG3000  and  refer  to 
Directive 85/337/EEA. 

67 

 
 
 
 
 
Annex B: Definitions of measure types 

Table B1 

Types of flood risk management measures 

M11 

No Action, No measure is proposed to reduce the flood risk in the APSFR or other defined area 

No Action 

Prevention 

M21 

M22 

Prevention, Avoidance, Measure to prevent the location of new or additional receptors in flood prone 
areas, such as land use planning policies or regulation 

Prevention, Removal or relocation, Measure to remove receptors from flood prone areas, or to relocate 
receptors to areas of lower probability of flooding and/or of lower hazard 

M23  Prevention, Reduction, Measure to adapt receptors to reduce the adverse consequences in the event of a 

flood actions on buildings, public networks, etc... 

M24 

Prevention, Other prevention, Other measure to enhance flood risk prevention (may include, flood risk 
modelling and assessment, flood vulnerability assessment, maintenance programmes or policies etc...) 

Protection 

M31  Protection Natural flood management / runoff and catchment management, Measures to reduce the flow 

into natural or artificial drainage systems, such as overland flow interceptors and / or storage, 
enhancement of infiltration, etc and including in-channel, floodplain works and the reforestation of 
banks, that restore natural systems to help slow flow and store water. 

M32 

M33 

M34 

Protection, Water flow regulation, Measures involving physical interventions to regulate flows, such as 
the construction, modification or removal of water retaining structures (e.g., dams or other on-line 
storage areas or development of existing flow regulation rules), and which have a significant impact on 
the hydrological regime. 

Protection, Channel, Coastal and Floodplain Works, Measures involving physical interventions in 
freshwater channels, mountain streams, estuaries, coastal waters and flood-prone areas of land, such as 
the construction, modification or removal of structures or the alteration of channels, sediment dynamics 
management, dykes, etc. 

Protection, Surface Water Management, Measures involving physical interventions to reduce surface 
water flooding, typically, but not exclusively, in an urban environment, such as enhancing artificial 
drainage capacities or though sustainable drainage systems (SuDS). 

M35 

Protection, Other Protection, Other measure to enhance protection against flooding, which may include 
flood defence asset maintenance programmes or policies 

Preparedness 

M41 

M42 

M43 

M44 

Preparedness, Flood Forecasting and Warning, Measure to establish or enhance a flood forecasting or 
warning system 

Preparedness, Emergency Event Response Planning / Contingency planning, Measure to establish or 
enhance flood event institutional emergency response planning 

Preparedness, Public Awareness and Preparedness, Measure to establish or enhance the public 
awareness or preparedness for flood events 

Preparedness, Other preparedness, Other measure to establish or enhance preparedness for flood events 
to reduce adverse consequences 

M51  Recovery and Review (Planning for the recovery and review phase is in principle part of preparedness), 

Individual and societal recovery, Clean-up and restoration activities (buildings, infrastructure, etc), 
Health and mental health supporting actions, incl. managing stress Disaster financial assistance (grants, 

Recovery & Review 

68 

 
 
tax), incl. disaster legal assistance, disaster unemployment assistance, Temporary or permanent 
relocation, Other 

Recovery and Review, Environmental recovery, Clean-up and restoration activities (with several sub-
topics as mould protection, well-water safety and securing hazardous materials containers) 

Recovery and Review, Other, Other recovery and review Lessons learnt from flood events Insurance 
policies 

Other 

Other 

M52 

M53 

M61 

Catalogue of Natural Water Retention Measures (NWRM)  

NWRM cover a wide range of actions and land use types. Many different measures can act as 

NWRM,  by  encouraging  the  retention  of  water  within  a  catchment  and,  through  that, 
enhancing the natural functioning of the catchment. The catalogue developed in the NWRM 

project  represents  a  comprehensive  but  non  prescriptive  wide  range  of  measures,  and  other 
measures,  or  similar  measures  called  by  a  different  name,  that  could  also  be  classified  as 

NWRM.  

To  ease  access  to  measures,  the  catalogue  of  measures  hereunder  is  sorted  by  the  primary 
land use in which it was implemented: Agriculture; Forest; Hydromorphology; Urban. Most 

of the measures however can be applied to more than one land use type. 

Table B2 

List of NWRMs 

Agriculture 

Forest 

Hydro Morphology 

Urban 

A01 Meadows and 

F01 Forest riparian 

N01 Basins and ponds 

U01 Green Roofs 

pastures 

buffers 

A02 Buffer strips and 

F02 Maintenance of 

N02 Wetland restoration 

U02 Rainwater 

hedges 

forest cover in headwater 

and management 

Harvesting 

areas 

A03 Crop rotation 

F03 Afforestation of 

N03 Floodplain 

U03 Permeable surfaces 

reservoir catchments 

restoration and 
management 

A04 Strip cropping 

F04 Targeted planting for 

N04 Re-meandering 

U04 Swales 

along contours 

'catching' precipitation 

A05 Intercropping 

F05 Land use conversion 

N05 Stream bed re-

U05 Channels and rills 

naturalization 

A06 No till agriculture 

F06 Continuous cover 
forestry 

N06 Restoration and 
reconnection of seasonal 

U06 Filter Strips 

streams 

A07 Low till agriculture 

F07 'Water sensitive' 
driving 

N07 Reconnection of 
oxbow lakes and similar 

U07 Soakaways 

features 

69 

 
 
 
Agriculture 

A08 Green cover 

Forest 

Hydro Morphology 

Urban 

F08 Appropriate design 
of roads and stream 

N08 Riverbed material 
renaturalisation 

U08 Infiltration 
Trenches 

crossings 

A09 Early sowing 

F09 Sediment capture 

N09 Removal of dams 

U09 Rain Gardens 

ponds 

and other longitudinal 

barriers 

A10 Traditional 

F10 Coarse woody debris 

N10 Natural bank 

U10 Detention Basins 

terracing 

A11 Controlled traffic 
farming 

F11 Urban forest parks 

stabilisation 

N11 Elimination of 
riverbank protection 

U11 Retention Ponds 

A12 Reduced stocking 

F12 Trees in Urban areas 

N12 Lake restoration 

U12 Infiltration basins 

density 

A13 Mulching 

F13 Peak flow control 

N13 Restoration of 

structures 

natural infiltration to 
groundwater 

F14 Overland flow areas 

N14 Re-naturalisation of 

in peatland forests 

polder areas 

Source: www.nwrm.eu 

70