COMMISSION STAFF WORKING DOCUMENT Second River Basin Management Plans - Member State: Croatia 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: Croatia, adaptation to climate change, application of EU law, environmental risk prevention, flood, risk management, water, water management, water pollution, watercourse

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 26.2.2019  SWD(2019) 43 final  COMMISSION STAFF WORKING DOCUMENT Second River Basin Management Plans - Member State: Croatia 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) 44 final} - {SWD(2019) 45 final} - {SWD(2019) 46 final} - {SWD(2019) 47 final} - {SWD(2019) 48 final} - {SWD(2019) 49 final} - {SWD(2019) 50 final} - {SWD(2019) 51 final} - {SWD(2019) 52 final} - {SWD(2019) 53 final} - {SWD(2019) 54 final} - {SWD(2019) 55 final} - {SWD(2019) 56 final} - {SWD(2019) 57 final} - {SWD(2019) 58 final} - {SWD(2019) 59 final} - {SWD(2019) 60 final} - {SWD(2019) 61 final} - {SWD(2019) 62 final} - {SWD(2019) 63 final} - {SWD(2019) 64 final} - {SWD(2019) 65 final} - {SWD(2019) 66 final} - {SWD(2019) 67 final} - {SWD(2019) 68 final} - {SWD(2019) 69 final} - {SWD(2019) 70 final} - {SWD(2019) 71 final} - {SWD(2019) 72 final} - {SWD(2019) 73 final} - {SWD(2019) 74 final} - {SWD(2019) 75 final} - {SWD(2019) 76 final} - {SWD(2019) 77 final} - {SWD(2019) 78 final} - {SWD(2019) 79 final} - {SWD(2019) 80 final} - 
 
 
Table of contents 
Acronyms...................................................................................................................................... 5 

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

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

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

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

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

Topic 1

  Governance and public participation ....................................................................... 24 

1.1  Assessment of implementation and compliance with WFD requirements in the second 
RBMP ..................................................................................................................................... 24 

1.2  Main changes in implementation and compliance since the first RBMP ..................... 27 

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

Topic 2

  Characterisation of the River Basin District............................................................. 29 

2.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle   ...................................................................................................................................... 29 

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

2.3  Progress with Commission recommendations .............................................................. 40 

Topic 3
bodies 

  Monitoring, assessment and classification of ecological status in surface water 

 ................................................................................................................................... 42 

3.1  Assessment of implementation and compliance with WFD requirements in the second 
RBMP ..................................................................................................................................... 42 

3.2  Main changes in implementation and compliance since the first RBMP ..................... 60 

3.3  Progress with Commission recommendations .............................................................. 61 

Topic 4

  Monitoring, assessment and classification of chemical status in surface water bodies 
 ................................................................................................................................... 63 

4.1  Assessment of implementation and compliance with WFD requirements in the second 
RBMP ..................................................................................................................................... 63 

4.2  Main changes in implementation and compliance since the first RBMP ..................... 76 

4.3  Progress with Commission recommendations .............................................................. 77 

1 

 
 
 
 
 
Topic 5

  Monitoring, assessment and classification of quantitative status of groundwater 

bodies 

 ................................................................................................................................... 80 

5.1  Assessment of implementation and compliance with WFD requirements in the second 
RBMP ..................................................................................................................................... 80 

5.2  Main changes in implementation and compliance since the first RBMP ..................... 87 

5.3  Progress with Commission recommendations .............................................................. 87 

Topic 6

  Monitoring, assessment and classification of chemical status of groundwater bodies 
 ................................................................................................................................... 88 

6.1  Assessment of implementation and compliance with WFD requirements in the second 
RBMP ..................................................................................................................................... 88 

6.2  Main changes in implementation and compliance since the first RBMP ..................... 94 

6.3  Progress with Commission recommendations .............................................................. 95 

Topic 7
  Designation of Heavily Modified and Artificial Water Bodies and definition of Good 
Ecological Potential................................................................................................................... 96 

7.1  Assessment of implementation and compliance with WFD requirements in the second 
RBMP for designation ............................................................................................................ 96 

7.2  Main changes in implementation and compliance since the first RBMP ..................... 98 

7.3  Progress with Commission recommendations .............................................................. 98 

Topic 8

  Environmental objectives and exemptions ................................................................ 99 

8.1  Assessment of implementation and compliance with WFD requirements in the second 
RBMP ..................................................................................................................................... 99 

8.2  Main changes in implementation and compliance since the first RBMP ................... 104 

8.3  Progress with Commission recommendations ............................................................ 104 

Topic 9

  Programme of measures.......................................................................................... 106 

9.1  Assessment of implementation and compliance with WFD requirements in the second 
RBMP ................................................................................................................................... 106 

9.2  Main changes in implementation and compliance since the first RBMP ................... 116 

9.3  Progress with Commission recommendations ............................................................ 117 

Topic 10

  Measures related to abstractions and water scarcity .......................................... 118 

2 

 
 
 
10.1  Assessment of implementation and compliance with WFD requirements in the 
second RBMP ....................................................................................................................... 118 

10.2  Main changes in implementation and compliance since the first RBMP ............... 120 

10.3 

Progress with Commission recommendations ........................................................ 120 

Topic 11

  Measures related to pollution from agriculture................................................... 122 

11.1  Assessment of implementation and compliance with WFD requirements in the 
second RBMP ....................................................................................................................... 122 

11.2  Main changes in implementation and compliance since the first RBMP ............... 124 

11.3 

Progress with Commission recommendations ........................................................ 124 

Topic 12

  Measures related to pollution from sectors other than agriculture ..................... 126 

12.1  Assessment of implementation and compliance with WFD requirements in the 
second RBMP ....................................................................................................................... 126 

12.2  Main changes in implementation and compliance since the first RBMP ............... 127 

12.3 

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

Topic 13

  Measures related to hydromorphology ................................................................ 131 

13.1  Assessment of implementation and compliance with WFD requirements in the 
second RBMP ....................................................................................................................... 131 

13.2  Main changes in implementation and compliance since the first RBMP ............... 132 

13.3 

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

Topic 14

Economic analysis and water pricing policies .................................................... 135 

14.1  Assessment of implementation and compliance with WFD requirements in the 
second RBMP and main changes in implementation and compliance ................................. 135 

14.2 

Progress with Commission recommendations ........................................................ 135 

  Considerations specific to Protected Areas (identification, monitoring, objectives 

Topic 15
and measures) .......................................................................................................................... 139 

15.1  Assessment of implementation and compliance with WFD requirements in the 
second RBMP ....................................................................................................................... 139 

15.2  Main changes in implementation and compliance since the first RBMP ............... 142 

15.3 

Progress with Commission recommendations ........................................................ 143 

Topic 16

Adaptation to drought and climate change .......................................................... 144 

3 

 
 
 
 
16.1  Assessment of implementation and compliance with WFD requirements in the 
second RBMP ....................................................................................................................... 144 

16.2  Main changes in implementation and compliance since the first RBMP ............... 144 

16.3 

Progress with Commission recommendations ........................................................ 144 

4 

 
 
Acronyms and definitions 

EQS Directive 

Environmental Quality Standards Directive 

FD 

Km 

km2 

KTM 

PoM 

Floods Directive 

Kilometre 

Kilometre squared 

Key Type of Measure 

Programme of Measures 

QA/QC Directive 

Quality Assurance / Quality Control Directive  

RBD 

RBMP 

WFD 

WISE 

Annex 0 

River Basin District 

River Basin Management Plan 

Water Framework Directive 

Water Information System for Europe 

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

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Foreword 

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

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

2015 and reported to the European Commission in March 2016. 

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

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

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

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

6 

 
 
 
 
 
 
General Information 

Map A   Map of RBDs 

Source: 2012 assessment reporting WISE, Eurostat (country borders) 

  International RBDs (within European Union) 
  International RBDs (outside European Union) 
  National RBDs (within European Union) 
  Countries (outside European Union) 
  Coastal Waters 

Croatia has a population of 4 million and a surface area of 56 000 km2.1 Its geography ranges 
from the lowlands of the Pannonian basin to the Dinaric Alps and the Dalmatian coastline, over 

1 800 km long. In addition, Croatia has over 1 200 coastal islands. The Dinaric Alps, coastal 
areas and islands have a predominantly karstic geology. 

Croatia has two RBDs: the Danube RBD and the Adriatic RBD (Table A). Croatia’s Danube 
RBD  is  part  of  the  international  Danube  RBD,  which  covers  14  Member  States  and  third 

1 http://europa.eu/about-eu/countries/member-countries/croatia/index_en.htm  

7 

AdriaticSeaHU1000AT1000HRBAHRCHRJMESI_RBD_1SI_RBD_2HU1000AT1000ITA050100km 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
countries.  Among  these,  Croatia’s  Danube  RBD  borders  on  Slovenia,  Hungary,  Serbia  and 

Bosnia and Herzegovina. 

The Adriatic RBD includes Croatia’s coastal islands. Moreover, due to these islands, many of 

them small in size, and Croatia’s long coastline, this RBD also covers extensive coastal waters. 

Table A Overview of Croatia’s RBDs  

Size (km2) 

RBD 

Name 

Mainland 

Islands 

Coastal 
waters 

HRC 

Danube 

HRJ 

Adriatic 

35 101 
(35 117) 

18 185 
(18183) 

3 262 

13 842 
(13 858  ) 

Countries sharing 
borders 

BA, HU, RS and SI 

BA, ME and SI 

Total 

35 101 
(35 117) 

35 289 
(35 303) 

Source: RBMPs reported to WISE. Croatia subsequently provided the values in brackets. 

Croatia is  part of the Danube international  RBD  and the Sava river basin,  a sub-basin  of the 

Danube international RBD. The Sava River is the largest tributary of the Danube by volume of 
water, and about one-quarter of the basin’s total surface area lies in Croatia. 

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

Name 
international 
river basin 

National RBD 

Countries sharing 
borders 

Danube 

Adriatic 

HRC 

HRJ 

BA, HU, RS and SI 

BA, ME and SI 

Co-ordination category 
2 
1 

km² 
35 117 

% 
4.4 % 

km² 

% 

25 370 
(21 445) 

26.0 % 

Source: WISE electronic reporting. Croatia subsequently provided the values in brackets. 

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

In  addition,  Croatia’s  Adriatic  RBD  shares  four  smaller  river  basins  with  Bosnia  and 
Herzegovina: Cetina (the basin’s surface area in Croatia is 1 531 km2 while the entire surface 
area is 2 6142 km2); Neretva (surface area in Croatia is 280 km2 while the basin’s full surface 
area  is  10  520  km2);  Trebišnjica  (in  Croatia  Trebišnjica  appears  as  a  series  of  underwater 
springs and as the Ombla river, which is only 30 m long but with a relatively large discharge, 
24 cubic metres per second); and Krka (the source of the river is located on the border between 

Croatia and Bosnia and Herzegovina). As of 2014, according to the Croatian authorities, joint 

2 Croatia subsequently noted that the correct area of the Cetina RBD is 4145 km2.   

8 

 
 
 
 
 
 
 
 
 
                                                      
management  plans  had  not  been  prepared  for  any  of  these  river  basins.  Cooperation  for  the 

preparation of joint management plans is on the agenda of the Bilateral Commission of Bosnia 
and Herzegovina and Croatia for Water Management Issues. 

Finally, Croatia’s Adriatic RBD shares three small river basins with  Slovenia: Dragonja  (the 
basin  area  in  Croatia  is  55.6  km2);  Mirna  (494  km2  in  Croatia  and  47  km2  in  Slovenia);  and 
Rječina (300 km2 in Croatia and 50 km2 in Slovenia). The coordination of respective national 
plans in these basins is carried out under the framework of the Bilateral Commission of Croatia 
and Slovenia for Water Management Issues. 

9 

 
 
 
 
 
Status of second river basin management plan reporting 

One RBMP covering the two river basin districts in Croatia (Danube, Adriatic) was published 

on  6  July  2016.  Documents  are  available  from  the  European  Environment  Agency  EIONET 
Central Data Repository https://cdr.eionet.europa.eu/.  

10 

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

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

 

Governance and public consultation 

  Croatia cooperates both within international river basin commissions (Danube and Sava) 

as well as bilaterally with several neighbouring countries.  

  A  wide  range  of  stakeholder  groups  were  actively  involved  in  the  preparation  of  the 

RBMP. 

  Croatia  integrated  its  Flood  Risk  Management  Plan  as  a  part  of  its  RBMP,  and  also 

carried out joint consultation with the Marine Strategy Framework Directive. 

  Croatia  did  not  adopt  and  publish  the  RBMP  in  accordance  with  the  timetable  in  the 

Water Framework Directive. 

 

Characterisation of the RBD 

 

There  were  significant  differences  in  the  number  of  delineated  surface  water  bodies 
with  respect  to  the  first  RBMP,  a  significant  number  of  changes  to  water  bodies 

including  changes  to  the  designation  of  heavily  modified  water  bodies.  The  RBMP 
states  that  considering  the  extent  of  changes  in  typology  and  delineation  of  water 

bodies,  it  is  difficult  to  ensure  comparability  with  the  results  described  in  the  first 
RBMP. 

 

Further testing of  abiotic typology with  biological  data has been  carried out  since the 
first cycle RBMP. However, several of the national types for Croatia in all of the RBDs 

do  not  appear  to  have  corresponding  intercalibration  types  (for  21  river  water  bodies 
and  15  lake  water  bodies).  According  to  the  information  subsequently  provided  by 

Croatia,  the  current  analysis  showed  that  appropriate  intercalibration  types  for  most 
national  types  do  exist  and  the  number  of  national  river  types  for  which  appropriate 

intercalibration types are determined will be revised within on-going projects.  

 

Type  specific  reference  conditions  have  not  been  established  for  hydromorphological 

quality  elements  in  any  water  category.  This  may  lead  to  some  weaknesses  in  the 
classification of status/potential according to the hydromorphological biological quality 
elements. According to information subsequently provided by Croatia, the methodology 

11 

 
 
for  monitoring  and  assessment  of  status  according  to  hydromorphological  quality 

elements  is  in  development  and  these  methodologies  will  determine  the  type-specific 
reference conditions for hydromorphological quality elements. 

 

Further characterisation work has been undertaken since the first RBMP, by describing 
the geological formation and whether or not they are layered. Croatia has also included 

an assessment of linkages with surface water bodies and terrestrial ecosystems. 

 

Numerical  tools  were  used  to  help  define  the  significance  of  pressures.  However,  the 

significance of pressures is reported not to be defined in terms of thresholds or linked to 
the  potential  failure  of  objectives  for  both  RBDs.  For  groundwater,  significance  of 

pressures  is  not  linked  to  the  potential  failure  of  objectives.  It  was  reported  that  30 
significant pressures were not assessed for surface waters in  each RBD. According to 

Croatia this is likely to be a reporting error.  

 

Inventories  of  emissions  have  been  established  for  both  RBDs;  however,  they  only 

included 6 of the 41 Priority Substances.  The CIS Guidance Document n°28 identifies 

a  tiered  approach  to  assessing  emissions,  however  Croatia  reported  using  a  different 
methodology. The data quality was assessed as uncertain. 

  Monitoring, assessment and classification of ecological status  

  The second RBMP reports on sites for operational monitoring in coastal and transitional 
waters in the Adriatic RBD, which was not the case in the first RBMP. There were also 

increases in the number of operational sites in rivers and lakes. 

  There  are  significant  gaps  in  the  monitoring  of  quality  elements.  Some  required 
biological  quality  elements  are  not  monitored  in  general,  and  none  of  them  was 
monitored in lakes. Hydromorphological quality elements are not monitored at all. 

  None  of  the  biological  quality  elements  which  were  the  object  of  surveillance  or 
operational  monitoring  in  coastal  and  transitional  waters,  was  sampled  at  least  at  the 

minimum recommended frequency. 

  None of the water bodies in which there was surveillance monitoring was monitored for 

all required biological and hydromorphological quality elements. 

 

28  River  Basin  Specific  Pollutants  were  identified  but  information  on  how  they  were 
selected  is  not  available.  Environmental  Quality  Standards  were  derived  for  seven  of 

12 

 
 
them  in  water  and  none  in  sediment  or  biota,  but  Guidance  Document  No.  27  was  not 

used. 

  River  Basin  Specific  Pollutants  were  monitored  in  all  water  categories  of  water. 
Monitoring in water was done for 23 of them in coastal and transitional waters, for nine 
in rivers and for six in lakes. Monitoring in sediment was done for four, only in rivers. 

  Only  eight  of  the  28  River  Basin  Specific  Pollutants  were  monitored  at  least  at  the 
minimum  recommended  frequency  at  some  of  the  sites.  The  analytical  methods  used 

comply  with  Article  4(1)  or  4(2)  of  Directive  2009/90/EC  for  the  strictest  standard 
applied. 

  An  assessment  method  was  reported  for  macrophytes,  but  none  for  angiosperms  in 
coastal  and  transitional  waters  nor  for  macroalgae  in  transitional  waters.  None  of  the 
assessment  methods  for  biological  quality  elements  was  reported  to  be  sensitive  to 

chemical pollution in rivers, even though this impact was reported to be significant. 

  The assessment and classification systems for biological quality elements in Croatia are 

yet to be intercalibrated. 

  The  expected  hydromorphological  quality  elements  are  assessed  in  rivers  and  lakes. 
However,  the  classification  boundaries  are  not  related  to  the  class  boundaries  of  the 
sensitive  biological  quality  elements  in  rivers.  Only  morphological  conditions  are 

assessed  in  transitional  and  coastal  waters  and,  in  this  case,  the  class  boundaries  are 
related to the sensitive biological quality elements. 

  The  reported  general  physicochemical  quality  elements  are  assessed  in  all  water 
categories.  However,  not  all  the  relevant  elements  are  assessed  and  for  some  of  the 

assessed elements the classification boundaries are not related to the class boundaries of 
the sensitive biological quality elements. 

  The  classification  of  all  hydromorphological  quality  elements  in  all  categories  was 
completely based on expert judgment, which introduces uncertainty and undermines the 
robustness of the classification of ecological status/potential. 

  Grouping  was  used  for  classifying  some  physicochemical  elements  and  River  Basin 
Specific  Pollutants  in  rivers  and  lakes.  River  Basin  Specific  Pollutants  were  only 

classified in lakes and rivers, even though they are monitored in all four water categories, 

13 

 
 
and monitoring results were only reported to be used in the classification of rivers. It is 

therefore not clear what was the basis for grouping for these substances in lakes. 

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

  All  surface  water  bodies  were  classified.  Between  the  two  RBMP,  the  proportion  of 
surface water bodies with good chemical status decreased slightly, from 97 to 92 %. This 
may at least partly result from a more accurate assessment of status, based on improved 

knowledge  since  the  first  RBMP.  In  particular,  the  number  of  monitoring  sites,  the 
number  of  water  bodies  and  priority  substances  monitored  increased  since  the  first 

RBMP. 

  All coastal and almost all transitional water bodies were monitored for chemical status. 
Less than 10  % of inland water bodies were monitored. Grouping was used to  classify 
the  non-monitored  water  bodies,  and  this  may  be  linked  to  the  low  confidence  in  the 

assessment reported for 50 % of surface water bodies. 

  Territorial waters were neither monitored nor classified for chemical status. 

  For Priority Substances, 37 of the 41 were monitored in water for status assessment, and 
this included all substances identified as discharged. The four substances not monitored 
were  not  included  in  the  inventories  so  it  is  unclear  whether  they  are  discharged.  The 

monitoring  frequencies  reported  were  consistent  with  the  recommended  minimum 
frequency for surveillance, but not for operational monitoring. No explanation could be 

found for the reduced frequencies. 

  Mercury,  hexachlorobenzene  and  hexachlorobutadiene  were  not  monitored  in  biota  for 

status assessment. 

  Monitoring for long-term trend occurred in sediments in river water bodies; only for up 
to  five  of  the  14  required  substances.  Monitoring  frequencies  were  above  the 
recommended minimum frequencies. 

  Monitoring,  assessment  and  classification  of  quantitative  status  of  groundwater 

bodies 

 

Grouping of groundwater bodies is applied but still 1/3 of the (groups) of groundwater 
bodies  have  no  quantitative  monitoring.  There  was  no  improvement  since  the  first 

RBMP. 

14 

 
 
 

Although  this  was  not  reported  to  WISE,  Croatia  subsequently  stated  that  the  water 

balance test was considered in all river basin districts. Confidence in status assessment 
is still low for many groundwater bodies.  

 

Groundwater  dependent  terrestrial  ecosystems  and  groundwater  associated  surface 
waters ecosystems have now been considered in status assessment. 

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

 

The  reported  information  shows  that  in  the  second  cycle  not  all  (groups  of) 
groundwater  bodies  are  subject  to  monitoring,  and  there  is  still  no  operational 

monitoring, although five groundwater bodies are at risk. According to the information 
subsequently  provided  by  Croatia  all  groundwater  bodies  are  covered  by  surveillance 

monitoring and by 2015 the establishment of operational monitoring sites started. 

 

 

All WFD core parameters are monitored. 

Croatia subsequently  clarified that  groundwater  dependent  terrestrial  ecosystems  have 

been considered in status assessment in all river basin districts and that no groundwater 
body is at risk due to links to those ecosystems. 

 

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

 

The  information  provided  on  artificial  and  heavily  modified  water  bodies  does  not 

describe  the  methodology  used.  The  RBMP  and  background  documents  available  do 
not give detailed information on criteria to define substantial changes in character due 

to  physical  modifications.  However,  as  part  of  the  pressure  and  impact  analysis,  the 
RBMP describes  that the impact  of physical interventions is  estimated by  means of a 

numerical  model  based  on  recorded  hydromorphological  pressures  and  expert 
judgement.  Concerning  the  designation  process  of  heavily  modified  water  bodies,  no 

information  is  provided  on  how  to  assess  significant  adverse  effects  of  restoration 
measures and other means to achieve the beneficial objectives of the heavily modified 

water bodies. It seems that heavily modified water bodies and artificial water bodies are 
identified  as  candidates  while  further  methodological  development  and 
still 

verifications via monitoring are pending. 

 

No methodology is yet established for defining good ecological potential but there are 

plans  to  do  so  in  the  future.  According  to  information  subsequently  provided  by 

15 

 
 
Croatia,  activities  on  the  establishment  of  a  higher  quality  connection  between 

biological and hydromorphological elements of ecological status of waters are ongoing. 

 

Environmental objectives and exemptions 

 

Improvements  have  been  made  compared  to  the  first  RBMP.  Drivers,  Pressures  and 

pollutants leading to exemptions were reported. 

 

Information on the achievement of objectives has been reported for 2015 and 2016 to 

2021.  Limited  progress  for  the  achievement  of  the  WFD  objectives  is  expected  by 
2021. No indicators for 2027 have been developed yet and the situation is still unknown 

for a number of water bodies. 

 

Compared  to  the  first  RBMP,  Article  4(4)  is  now  applied  in  the  second  RBMP.  A 

number of uncertainties and gaps remain, particularly with regard to the assessment of 
water body status/potential and the thorough justification of Article 4(4) exemptions. 

 

Programme of Measures 

 

Some progress has been made in identifying significant pressures and mapping national 

measures/KTMs, and in performing gap analyses. The level of ambition is still low. 

 

Croatia  has  reported  investment  costs  and  operation  and  maintenance  costs  for  all 

measures,  and  has  reported  that  a  significant  level  of  EU  funding  is  expected.  It  has 
further reported that financial commitment has been secured for the implementation of 

the Programme of Measures in both RBDs. 

 

New  legislation  or  regulations  to  implement  the  Programme  of  Measures  in  the  first 

RBMP was reported necessary and in progress for both RBDs. 

  With a few exceptions, most of the significant pressures in both RBDs are covered by 

KTMs, indicating that these are operational. 

 

 

There a number of significant pressures that have been identified in the Adriatic RBD 
that do not appear to have operational KTMs in place. 

The two nationally derived KTMs have not been properly described. A number of the 
KTMs  against  which  national  measures  have  been  mapped  do  not  appear  to  be 

operational,  including  those  reported  as  relevant  for  the  Marine  Strategy  Framework 

16 

 
 
Directive. This may indicate that more measures, not operational in the first RBMP, are 

planned for the second and third RBMP. 

 

The  KTM  reported  as  addressing  nitrate  in  groundwater  is  inappropriate  -  Croatia 

clarified that the incorrect KTM had been reported. No information has been provided 
on  the  number  of  surface  water  bodies  failing  to  be  of  good  status  as  a  result  of 

pollution from river basin specific pollutants, but KTMs have been reported. 

 

The number of water bodies failing to achieve good status as a result of pollution from 

Priority Substances has been reported, and for some substances KTMs to control them 
have  been  reported.  For  five  Priority  Substances  causing  failure  in  the  Danube  RBD 

and seven in the Adriatic RBD, no KTMs have been reported. 

 

Indicators have been developed and reported for 2015 and 2021. The level of ambition 

is low, with little change expected by 2021. No indicators for 2027 have been reported. 

 

Croatia has reported that the RBMP and FRMPs are integrated. However, whilst it has 
been mapped to national measures, there is no evidence that KTM23 – “Natural water 

retention measures” has been mapped to national measures, has been made operational, 
nor has any information been provided in respect of the pressures it is aimed to address 

in  either  RBD.  Financial  commitments  for  the  implementation  of  a  Programme  of 
Measures in the flood protection sector was marked “not applicable”, and WFD Article 

9(4) has not been applied to impoundment for flood protection. 

  Measures related to abstractions and water scarcity 

 

No  information  was  reported  in  WISE  on  water  exploitation  and  trends,  although  the 

RBMPs include some relevant information.  

 

Information  was  reported  on  the  main  uses  of  water,  but  it  does  not  refer  to  water 

consumption by sectors, only to the number of licences. 

 

In  Croatia,  there  is  a  concession,  authorisation  and/or  permitting  regime  to  control 

water impoundment but no register of impoundments.  

  Measures related to pollution from agriculture 

 

There is  a clear link between agricultural  pressures  and agricultural  measures. Setting 
of  management  objectives  for  nutrient  pollution  and  a  gap  assessment  for  nutrients 
were undertaken in the Adriatic RBD. 

17 

 
 
 

The  implementation  of  basic  measures  Article  11(3)(h)  for  the  control  of  diffuse 

pollution from agriculture at source are given, but only in the Nitrate Vulnerable Zones. 
Pesticides and nutrients are covered by the basic measures in all basins. 

 

 

 

 

Safeguard zones for abstractions have been legally established. 

Supplementary measures for reducing pollution from agriculture are reported 

Financing of measures is not secured. According to information subsequently provided 

by  Croatia,  financing  of  measures  related  to  the  reduction  of  any  negative  project 
impacts falls under the responsibility of the project developer. 

No natural water retention measures and no measures to reduce sedimentation from soil 
erosion and surface runoff are reported.  

 

The  level  of  ambition  is  rather  limited  as  some  measures  are  mandatory  in  the 

designated vulnerable areas, while in all other areas they are voluntary. 

  Measures related to pollution from sectors other than agriculture 

 

Croatia  has  identified  substance  specific  measures  for  all  the  River  Basin  Specific 

Pollutants reported to be causing failure of good status, and for pollutants reported to be 
causing poor chemical status in groundwater bodies. 

 

As  noted  in  the  context  of  Topic  9,  Croatia  has  not  identified  substance-specific 
measures for several Priority Substances. 

 

There is more to do to improve urban waste water treatment, especially as regards more 

stringent treatment in big cities, and as regards diffuse sources. 

 

Croatia  has  not  yet  fully  investigated  the  need  for  supplementary  measures  to  tackle 

pollutants from non-agricultural sources. 

  Measures related to hydromorphology 

 

In  the  first  RBMP,  measures  for  existing  hydromorphological  pressures  were  not 

included. In the second RBMP, hydromorphological pressures are still not addressed by 
specific  technical  measures,  as  the  only  activities  planned  are  related  to  research  and 

monitoring. According to information subsequently provided by Croatia, for determining 
measures  to  reduce  hydromorphological  pressures,  research  is  ongoing  on  the  quality 

18 

 
 
connections  between  biological  and  hydromorphological  water  status  indicators.  Some 

activities related to the review of existing permits and checking their compatibility with 
the WFD would also still be ongoing. 

  Ecological flows have not been derived for the relevant water bodies in any of the RBDs 
but  there  are  plans  to  do  it  during  the  period  of  the  second  RBMP.  The  activities  on 

ecological flows are ongoing and awaiting the completion of relevant research.  

 

In  addition,  none  of  the  RBMP  and  supporting  background  documents  includes 
information on the consideration of Natural Water Retention Measures. 

 

Economic analysis and water pricing policies  

 

 

 

No detailed information on the application of the polluter pays principle was reported.  

A narrow definition of water services has been used.  

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

 

Protected  Areas  of  all  types  have  been  reported  associated  with  both  surface  and 

groundwater. However, the setting of additional objectives is limited to Protected Areas 
designated for economically significant species (shellfish).  

  Monitoring  programmes  for  each  Protected  Area  type  have  not  been  reported  for  all 
types and the number of monitoring sites is low compared to the number of Protected 
Areas. 

 

Adaptation to drought and climate change 

 

Climate change was considered in all river basin districts. However, it is stated that the 
Common  Implementation  Strategy  guidance  document  on  how  to  adapt  to  climate 

change was not used for the preparation of the RBMPs.  

 

KTM 24 - "Adaptation to climate change" is not made operational to address significant 

pressures in the river basin districts. 

 

No information is reported regarding the relevance of droughts in Croatia. No drought 

management  plan  has  been  reported.  According  to  the  information  subsequently 
provided  by  Croatia,  the  Climate  Change  Adaptation  Strategy  is  in  the  process  of 

19 

 
 
preparation and adoption. Following its adoption, a decision will be made as to whether 

the preparation of a drought management plan (in the context of water management) is 
required. 

Recommendations  

  Croatia should carry out the preparation of the next cycle of RBMP in accordance with 

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

  The mechanisms for active involvement of stakeholders should be further developed, for 

example establishing advisory groups that bring together stakeholders. 

  Croatia should further strengthen bilateral  cooperation with  neighbouring  countries and 
continue to improve international cooperation, including coordinated assessments of the 
technical  aspects  of  the  WFD  such  as  ensuring  a  harmonized  approach  for  status 

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

  Croatia  needs  to  do  further  work  on  the  identification  of  pressures,  in  particular  in 

transitional and coastal waters. 

  The  inventories  of  emissions,  discharges  and  losses  of  chemical  substances  need  to  be 

completed. 

  Croatia should continue improving chemical and quantitative groundwater monitoring. 

  Croatia should continue to improve monitoring, in order to increase the confidence in the 
assessment  of  water  body  status,  as  there  are  still  important  gaps.  Monitoring  should 

cover  all 
hydromorphological quality elements, which were reported not to be monitored at all. 

relevant  quality  elements 

in  all  water  categories, 

in  particular 

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

for the classification of ecological status/potential. 

  Hydromorphological  and  biological  monitoring  needs  to  be  reinforced,  to  facilitate 
preparation  of  a  higher  quality  Programme  of  Measures  to  control  and  reduce 

hydromorphological pressures on water bodies. 

20 

 
 
 
  Croatia  should  continue  to  strengthen  its  assessment  methods  for  biological,  general 
physicochemical  and  hydromorphological  quality  elements  by  developing  assessment 
methods  for  all  biological  quality  elements,  and  by  setting  physico-chemical  and 

hydromorphological  classification  boundaries  that  are  sensitive  to  biological  quality 
elements.  

  Croatia  should  continue  improving  the  confidence  in  the  assessment  of  surface  water 
chemical  status  and  make  sure  territorial  waters  are  assessed  for  chemical  status.  In 

particular,  monitoring  should  be  performed  in  a  way  that  provides  sufficient  spatial 
coverage to  reach good  confidence in  the assessment, if necessary in  combination with 

robust  extrapolation/grouping  methods.  All  substances  should  be  considered  in  the 
relevant  matrix.  The  monitoring  frequencies  for  operational  monitoring  should  be  as 

specified  in  the  Directive.  If  a  different  matrix  or  reduced  frequencies  are  used,  please 
provide the corresponding explanations, as required by the Directive. 

  Trend monitoring should be further improved, to ensure that all the relevant substances 
specified  in  Directive  2008/105/EC  are  monitored  in  a  way  that  provides  sufficient 
spatial coverage. 

  Croatia  should  develop  an  appropriate  methodology  for  the  designation  of  Heavily 
Modified  Water  Bodies.  The  designation  of  HMWBs  should  comply  with  all  the 

requirements of Article 4(3), including criteria to define substantial changes in character 
due  to  the  physical  modification,  the  assessment  of  significant  adverse  effects  on  their 

use or the wider environment and the lack of significantly better environmental options. 
This  is  needed  to  ensure  transparency  of  the  designation  process.  In  addition,  a 

methodology needs to be established for defining ecological potential.  

  Progress needs to be continued to further reduce uncertainties regarding the assessment 
of  water  body  status/potential  and  the  timeframe  for  the  achievement  of  the  WFD 
objectives. The application of Article 4(4) exemptions needs to be properly justified. For 

potential  future  application  of  Article  4(7),  Croatia  needs  to  ensure  a  thorough 
assessment of possible new modifications in line with the requirements of the WFD and 

as further specified by the judgment of the Court in case C-461/13. 

  The  RBMP  should  clearly  identify  the  gap  to  good  status,  and  the  Programme  of 

Measures designed and implemented to close that gap. 

  Croatia should carry out cost-effectiveness analysis and provide specific prioritisation of 

measures based on this analysis. 

21 

 
 
  KTMs should be reported to control Priority Substances in both RBDs. 

 

Information  on  the  number  of  the  water  bodies  failing  to  achieve  good  status  due  to 
River Basin Specific Pollutants should be provided. 

  Croatia  should  provide  in  the  next  cycle  all  relevant  information  on  the  level  of 
compliance and the timing to reach compliance of agglomerations, including information 
on  funding,  in  accordance  with  Directive  91/271/EEC  (Article  15  and  following).  It 

should  ensure  compliance  with  Article  5  UWWTD  for  more  stringent  treatment, 
especially in big cities. It should also assess the need to take additional measures on point 

source  pollution  beyond  the  requirements  of  the  UWWTD  and  IED  to  fulfil  the  WFD 
objectives, and complete the identification of KTMs for diffuse sources. 

  Croatia should ensure that abstraction controls are in place and that information on uses, 

water exploitation and trends is collected and reported. 

  The  use  of  natural  water  retention  measures  to  mitigate  risk  to  water  quality  from 
agricultural  pollutants  (nutrients,  agri-chemicals,  sediment,  organic  matter)  should  be 

considered when drawing up the third RBMP. 

 

In the third RBMPs, Croatia should state clearly to what extent, in terms of area covered 

and  pollution  risk  mitigated,  basic  measures  (minimum  requirements  to  be  complied 

with)  or  supplementary  measures  (designed  to  be  implemented  in  addition  to  basic 
measures)  will  contribute  to  achieving  the  WFD  objectives  and  identify  sources  of 
funding (e.g. CAP Pillar 1, RDP), as appropriate, to facilitate successful implementation 

of these measures.  

  Croatia should continue the work on revising existing controls to ensure that agricultural 
practices do not cause hydromorphological pressure and update controls where necessary 

for inclusion in the Programme of Measures of the next RBMP. 

  The  necessary  measures  to  tackle  hydromorphological  pressures  are  still  under 
development. Croatia should ensure that these measures are defined and implemented as 
soon as possible, in particular for river continuity and restoration. Ecological flows need 

to be derived and implemented in all RBDs. 

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

22 

 
 
quality, flood protection, habitat conservation etc.), social and economic benefits which 

can be in many cases more cost-effective than grey infrastructure. 

  Croatia should apply cost recovery for water use activities having a significant impact on 
water  bodies  or  justify  any  exemptions  using  Article  9(4).  Croatia  should  present  in  a 
transparent  way  how  financial,  environmental  and  resource  costs  have  been  calculated 

and  how  the  adequate  contribution  of  the  different  users  is  ensured.  The  water-pricing 
policy, including the use of adequate incentives for users to use water efficiently should 

be  presented  in  a  transparent  way  and  it  should  provide  a  transparent  overview  of 
estimated investments and investment needs. 

  Additional measures have only been set for Shellfish Protected Areas and no monitoring 
programmes are reported for any of the Protected Areas. Croatia needs to ensure that all 

relevant Protected Areas are properly monitored. 

 

Due consideration on the need for a drought management plans is encouraged given the 

vulnerability of Croatia to droughts and the significant pressure on water bodies due to 

abstraction. 

23 

 
 
 
 
 
Topic 1

  Governance and public participation 

1.1  Assessment of implementation and compliance with WFD requirements 

in the second RBMP 

1.1.1 Administrative arrangements – river basin districts 

Croatia has two RBDs: the Danube  and the Adriatic.  Both  are international  RBDs. Croatia’s 
Danube RBD borders on Bosnia and Herzegovina, Hungary, Serbia and Slovenia and is part of 

the international Danube RBD (moreover, just over 2/3 of Croatia’s Danube RBD is part of the 
Sava River basin, a sub-basin of the Danube international RBD).  

Croatia’s  Adriatic  RBD  borders  on  Bosnia  and  Herzegovina,  Montenegro  and  Slovenia. 
Croatia  informed  that  in  the  Adriatic  RBD,  Croatia  shares  five  international  river  basins  of 
larger than 100 km2:  with Bosnia and Herzegovina, the Neretva and Cetina river basins;  and 
with Slovenia, the Rječina, Mirna and Dragonja river basins. 

1.1.2 Administrative arrangements – competent authorities 

Croatia has reported two Competent Authorities for the RBMP.  

Hrvatske vode (Croatian Waters, the national body responsible for water management) has the 
following  main  roles:  the  monitoring  and  assessment  of  groundwater  and  surface  water; 

pressure  and  impact  analysis;  economic  analysis;  preparation  of  RBMP  and  Programme  of 
Measures; reporting to the European Commission; and implementation of measures. Hrvatske 

vode  has  the  following  supplementary  roles:  public  participation  and  co-ordination  of 
implementation.  

Croatia  reported  that  the  main  roles  of  the  Ministry  of  Agriculture  are  enforcement  of 
regulations, public participation and co-ordination of implementation; however, the Directorate 

for Water Management has recently moved from the Ministry of Agriculture to the Ministry of 
Environment and Energy, which should now hold these roles. 

1.1.3 River  Basin  Management  Plans  –  structure  and  Strategic  Environmental 

Assessment  

Croatia has a single RBMP for both its RBDs. Croatia published its RBMP in June 2016, six 

months  after  the  timetable  for  the  second  RBMP  (it  can  be  noted  that  Croatia’s  first  RBMP 
was published in June 2013, just before its accession to the European Union in July 2013).  

24 

 
 
The RBMP has a sub-plan for the construction of infrastructure for municipal water services3. 
Croatia’s reporting references a second sub-plan, for infrastructure investment in irrigation as 
well as flood protection4. 

According to the assessment of Croatia’s Flood Risk Management Plan, that plan is an integral 
part of the country’s RBMP. However, this is not clear from Croatia’s reporting on the RBMP.  

A Strategic Environmental Assessment was carried out for Croatia's RBMP.  

1.1.4 Public Participation and active involvement of stakeholders  

The public and interested parties were informed of the consultation via Internet, via invitations 
to  stakeholders  and  via  meetings.  The  consultation  documents  were  available  via  download 

(only)  for  the  required  six  months.  For  both  Croatia's  RBMP,  there  was  international  co-
ordination of public participation. 

The  following  stakeholder  groups  were  actively  involved  in  the  development  of  the  second 
RBMP  (in  both  RBDs):  agriculture/farmers,  energy/hydropower,  fisheries,  aquaculture, 

industry, local/regional authorities, navigation/ports, NGOs/nature protection and water supply 
and  sanitation.  Active  involvement  took  place  via  two  mechanisms:  involvement  in  drafting 
and regular exhibitions. 

For both RBMPs, public consultation had the following impacts: addition of new information, 
adjustment to specific measures, changes to selection of measures, commitment to action in the 

next  RBMP  and  commitment  to  further  research.  For  the  Adriatic  RBMP,  there  was  joint 
consultation with the Marine Strategy Framework Directive5. 

1.1.5 Integration  with  other  European  Union  legislation:  Floods  Directive  and  Marine 

Strategy Framework Directive 

In  Croatia,  the  RBMP  was  integrated  with  the  corresponding  Flood  Risk  Management  Plan: 
specifically, the Flood  Risk  Management  Plan was  designated an integral part of the RBMP. 
Consequently, there was joint consultation for the RBMP and Flood Risk Management Plan.  

3   Višegodišnji program gradnje komunalnih vodnih građevina planski, November 2015. 
4   VIŠEGODIŠNJI  PROGRAM  GRADNJE  REGULACIJSKIH  I  ZAŠTITNIH  VODNIH  GRAĐEVINA  I 

GRAĐEVINA ZA MELIORACIJE, November 2015. 

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

25 

 
 
                                                      
Croatia  also  reports  that  there  was  joint  consultation  with  the  Marine  Strategy  Framework 

Directive (specifically for the Adriatic RBD). Further information on integration with respect 
to measures is provided in Chapter 9 of this report.  

1.1.6 International Coordination 

Both of Croatia's RBDs are part of international RBDs.  

For  the  Danube  RBD,  there  is  an  international  agreement,  permanent  co-operation  body  and 
international  RBMPs  are  in  place  (designated  as  category  one  cooperation).  Specifically, 

Croatia is a Party to both the Danube River Convention and to the Framework Agreement on 
the Sava River Basin.  Moreover, explicit links have been made with  national  RBMPs within 

the  international  RBMPs.  Both  agreements  have  involved  joint  identification  of  significant 
water  management  issues,  joint  objectives  and  joint  monitoring,  among  other  areas  of 

cooperation.  

For the Adriatic RBD, there is an international agreement and a permanent co-operation body 

are in place (designated as category two cooperation). 

Croatia  has  bilateral  agreements  on  water  management  in  place  with  four  of  its  five 
neighbouring  Member  States  and  third  countries  (Croatia  lacks  a  bilateral  agreement  with 

Serbia):  

  Agreement  on  water  management  between  the  Croatian  government  and  the 

government of the Republic of Hungary; 

  Treaty  between  the  Government  of  the  Republic  of  Croatia  and  the  Government  of 

Bosnia and Herzegovina on the regulation of water management relations; 

  Treaty between the Government of the Republic of Croatia and the Government of the 

Republic of Slovenia on the regulation of water management relations; 

  Treaty between the Government of the Republic of Croatia and the Government of the 
Republic of Montenegro on mutual relations in the field of water management; and, 

All  these  bilateral  agreements  have  set  up  joint  committees  or  commissions  for  water 

management.  Croatia’s  RBMP  refers  to  cooperation  via  the  Danube  and  Sava  international 
commissions  as  well  as  bilaterally  with  neighbouring  countries,  though  it  does  not  provide 

details  on  the  extent  of  cooperation.  On  the  other  hand,  the  report  on  the  Strategic 
Environmental Assessment for the RBMP refers to consultation with neighbouring countries in 

26 

 
 
the context of the Strategic Environmental Assessment (written comments were received from 

Italy and Montenegro and a bilateral meeting was held with Bosnia and Herzegovina). 

Croatia  participated  in  the  extensive  cooperation  activities  under  the  Danube  and  Sava 

Commissions. Work in the Sava IRBD, for example, included coordination on delineation and 
typology of water bodies, significant water management issues, monitoring, water body status, 

identification of pressures as well as the preparation of the international RBMP and PoM (for 
further  information  see  the  reports  on  international  coordination  on  the  Water  Framework 

Directive). 

The timetable of Croatia’s second RBMP was published in June 2016, and six months after the 

international  Danube  RBMP,  published  in  December  2015.  The  Sava  River  RBMP  was 
published  a  year  earlier,  in  December  2014,  and  it  appears  it  was  linked  mainly  to  Croatia’s 

first RBMP (published in June 2013). Both the Danube and Sava international RBMP refer to 
coordination with basin countries including Croatia. 

Croatia  informed  that  the  preparation  of  the  second  RBMP  for  the  Adriatic  RBD  was 
coordinated for shared catchments on a bilateral basis with Bosnia and Herzegovina and with 
Slovenia. 

1.2  Main changes in implementation and compliance since the first RBMP 

The information reported to WISE for governance does not indicate major changes for Croatia. 

1.3  Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMP  and  Programme  of  Measures 

requested action on the following: 

  Recommendation: Coordinate the preparation of the next RBMP with the preparation 
of  the  international  Danube  RBMP  and  the  Sava  RBMP  and  ensure  that cooperation 
with  the  neighbouring  countries  extends  to  all  shared  catchments.  Coordination  of 

measures in internationally shared karstic aquifers should be established.  

Assessment:  The  Commission  recommended  in  its  2015  Commission  Staff  Working 

Document that Croatia improve international coordination, both with international river 
basin  authorities  and  with  neighbouring  countries.  Moreover,  the  2015  Commission 

Staff  Working  Document  noted  that  the  timetable  for  Croatia's  first  RBMP  was  not 
linked to that of the Danube and Sava international RBMP (this concerns the Danube 

27 

 
 
RBD), and also that joint WFD planning with Bosnia-Herzegovina was not carried out 

for shared river basins (this referred mainly to the Adriatic RBD).  

Croatia’s  RBMP  refers  to  cooperation  via  the  Danube  and  Sava  international 

commissions  as  well  as  bilaterally  with  neighbouring  countries,  though  it  does  not 
provide  details  on  the  extent  of  cooperation.  On  the  other  hand,  the  report  on  the 

Strategic  Environmental  Assessment  for  the  RBMP  refers  to  consultation  with 
neighbouring  countries  in  the  context  of  the  Strategic  Environmental  Assessment 

(written  comments  were  received  from  Italy  and  Montenegro  and  a  bilateral  meeting 
was held with Bosnia and Herzegovina). 

The timetable of Croatia’s second RBMP was published in June 2016, and six months 
after  the  international  Danube  RBMP,  published  in  December  2015.  The  Sava  River 

RBMP  was  published  a  year  earlier,  in  December  2014,  and  it  appears  it  was  linked 
mainly to  Croatia’s first  RBMP (published in June 2013). Both  the Danube and Sava 

international RBMP refer to coordination with basin countries including Croatia. 

In  addition,  Croatia  indicated  that  it  co-operated  with  neighbouring  Bosnia  and 
Herzegovina and Slovenia on shared catchments that are part of its Adriatic RBD.  

Based  on  this  information,  it  appears  that  Croatia  has  improved  international 
coordination  within  the  Danube  and  Sava  international  river  basins  and  also  with  at 

least some of its neighbouring countries. It appears that bilateral co-ordination could be 
further strengthened, at least with Serbia and also with Slovenia. Consequently, Croatia 

has partially fulfilled this recommendation. 

28 

 
 
 
 
Topic 2

  Characterisation of the River Basin District 

2.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle  

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

bodies 

Overall  there  was  an  increase  in  the  number  of  water  bodies  delineated  from  the  first  to  the 

second cycles (Table 2.1). 

For river water bodies, there was a 21 % increase overall. For lake water bodies, there was an 

increase of 9 % overall but a decrease of 20 % in the Adriatic RBD. For coastal water bodies, 
there was an 18 % increase in the Adriatic RBD and a decrease in transitional water bodies of 

11 %.  

The typology has been revised since the first cycle RBMP which resulted in the repetition of 

the process of delineation of river water bodies. The revised typology led to merging of water 
bodies that previously were of different types and splitting of water bodies that previously were 

of  the  same  type.  Additional  criteria  for  water  bodies  were  introduced  in  order  to  delineate 
water bodies that  are more appropriate for water  quality management, however these criteria 

were not explained in the second RBMP. The RBMP further states that considering the extent 
of changes in typology and delineation of water bodies, it is difficult to ensure comparability 

with  the  results  obtained  in  the  two  cycles.  The  second  RBMP  did  not  provide  any  specific 
information on the consequences of re-delineation. 

Table 2.2 shows the differences in size distribution of surface water bodies in Croatia between 
the  second  and  first  RBMPs.  The  minimum  size  of  lakes  has  increased  in  the  Adriatic  RBD 
from  0.88  km2  to  1.35  km2.  The  minimum  length  of  rivers  has  slightly  decreased  and  the 
maximum  length  of  rivers  has  decreased  significantly  in  both  RBDs.  The  minimum  size 
criteria reported were 10 km2 catchment area for rivers and 0.5 km2 surface area for lakes6. 

6   Croatia subsequently explained that all the smaller water bodies which not delineated under the RBMP and are 
not a part of a larger water body are subject to the same conditions as those for a water body belonging to the 
same category (river, lake, transitional waters or coastal waters) of the most sensitive ecotype in the associated 
ecoregion. 

29 

 
 
                                                      
Table 2.1 

Number and area/length of delineated surface water bodies in Croatia for the second and the first RBMPs  

RBMP  RBD 

2nd cycle   HRC 
2nd cycle   HRJ 
2nd cycle   Total 

1st cycle  HRC 
1st cycle  HRJ 
1st cycle  Total 

Lakes 

Rivers 

Transitional 

Coastal 

Number of 
water bodies 

Total area 
(km2) of water 
bodies 

Number of 
water bodies 

Total length of 
water body 
(km) 

Number of 
water bodies 

Total area 
(km2) of water 
bodies 

Number of 
water bodies 

Total area 
(km2) of water 
bodies 

33 

4 

37 

29 

5 

34 

125 

41 

166 

127 

42 

169 

1 126 

358 

1 484 

897 

334 

1 231 

14 941 

2 688 

17 629 

10 768 

2 273 

13 041 

25 

25 

28 

28 

150 

150 

145 

145 

26 

26 

22 

22 

13 747 

13 747 

13 752 

13 752 

Table 2.2 

Size distribution of surface water bodies in Croatia in the second and the first RBMPs 

Source: WISE electronic reporting 

RBMP 

RBD 

2nd cycle 
2nd cycle  

1st cycle 
1st cycle 

HRC 

HRJ 

HRC 

HRJ 

Lake area (km2) 

River length (km) 

Transitional (km2) 

Coastal (km2) 

Min 

0.51 

1.35 

0.51 

0.88 

Max 

16.17 

30.48 

17.88 

30.46 

Average 

3.8 

10.15 

4.38 

8.44 

Min 

0.01 

0.02 

0.03 

0.02 

Max 

94.69 

47.66 

Average 

Min 

Max 

Average 

Min 

Max 

Average 

14.26 

8.07 

0.01 

35.72 

5.98 

0.64 

4 238.81 

528.74 

133.69 

109.37 

12 

6.81 

0.01 

34.43 

5.2 

0.63 

4 237.10 

625.11 

Source: WISE electronic reporting 

30 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In  the  first  cycle,  86  %  of  identified  surface  water  bodies  were  natural  with  9  %  being 

designated  as  heavily  modified  and  5  %  as  artificial  water  bodies.  In  the  second  cycle,  the 
situation was  quite different  with  92 % natural, 8 % artificial and no heavily modified water 

bodies (Figure 2.1).  

The  number  of  groundwater  bodies  remained  the  same  in  the  Danube  RBD,  while  for  the 

Adriatic RBD there was an increase of 8 % (Table 2.3).  

Figure 2.1 

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

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

category  

Source: WISE electronic reporting 2016  

Table 2.3 

Number and area of delineated groundwater bodies in Croatia for the second 
and first RBMPs 

RBMP 

RBD 

Number 

2nd cycle  
2nd cycle  
2nd cycle  

1st cycle 
1st cycle 
1st cycle 

HRC 

HRJ 

Total 

HRC 

HRJ 

Total 

20 

13 

33 

20 

12 

32 

Area (km2) 

Minimum  Maximum  Average 

97.32 

143.65 

5 189.02 

1 754.18 

3 754.00 

1 593.73 

1 942 

Source: WISE electronic reporting 2016 

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 2.4 summarises the information provided by Croatia on how water bodies have evolved 

between the two cycles. It is notable that the changes to the river and lake water bodies have 
been recorded as the creation of new water bodies. 

Table 2.4 

Type of change in delineation of groundwater and surface water bodies in 
Croatia between the second and the first RBMPs  

Type of water body change for the 
second cycle RBMP 

Splitting 

Aggregation and splitting 

Change 

Extended area 

Reduced area 

Creation 

Deletion 

Change in code 

Total water bodies before deletion 

Delineated for the second cycle 
RBMP (after deletion from 1st cycle 
RBMP) 

Groundwater 

Rivers 

Lakes 

Transitional 

Coastal  

3 

1 

29 

33 

33 

1 484 

1 232 

2 716 

1 484 

37 

33 

70 

37 

6 

5 

1 

5 

5 

3 

3 

28 

25 

4 

14 

2 

2 

4 

26 

26 

Source: WISE electronic reporting  

2.1.2 Identification of transboundary water bodies  

Transboundary  river  water  bodies  have  been  designated  in  the  Danube  RBD  and  river, 
transitional and coastal transboundary water bodies have been designated in the Adriatic RBD. 

15 transboundary groundwater bodies have been identified in the Danube RBD and six in the 
Adriatic RBD.  

The RBMP explains that the transboundary water management is done under a framework of 

bilateral agreements with neighbouring states. There is no specific information about whether 
delineation or typology of water bodies was specifically covered by these agreements.  

2.1.3 Typology of surface water bodies 

The  number  of  surface  water  body  types  reported  by  Croatia  for  the  first  cycle  and  second 

RBMPs  are  displayed  in  Table  2.5.  In  the  second  cycle  Croatia  reported  five  coastal  water 
body types, 15 (6)7 lake types, 28 river types and four transitional types. The numbers of lake, 

7    Croatia subsequently clarified that there are 6 lake water body types, but this does not match the data reported 

to WISE 

32 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
                                                      
transitional and coastal  water body types  remained largely the same between the two cycles, 

but the number of river water body types has a significant decrease from 52 to 28. The second 
RBMP reported that  the typology had been revised since the  first  RBMP, which allowed for 

the merging of water bodies.  

Table 2.5 

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

second RBMPs 

RBD 

HRC 

HRJ 

TOTAL 

Rivers 

Lakes 

Transitional 

Coastal 

2013 

2016 

2013 

29 

27 

52 

18 

17 

28 

10 

4 

14 

2016 

11 (2) 

4 

15 (6) 

2013 

2016 

2013 

2016 

0 

6 

6 

0 

4 

4 

0 

5 

5 

0 

5 

5 

Source: WISE electronic reporting Note that the total is not the sum of the types in each RBD as some types are 
shared by RBDs. The numbers in brackets were subsequently provided by Croatia and do not match the data 

reported to WISE. 

In  Croatia,  the  typology  system  B  has  been  applied.  The  reasons  provided  where  that  the 
system  is  more  flexible  and  allows  the  definition  of  a  typology  that  better  describes  the 

biological  diversity  of  surface  waters.  Further  testing  of  the  abiotic  typology  with  biological 
data  allowed  for  the  grouping  of  types  with  very  similar  biocenoses.  There  was  work 

undertaken  to  determine  the  extent  to  which  the  layout  and  structure  of  the  biota  can  be 
associated with the abiotic typology of the Croatian hydrographic network8. 

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

natural) have been intercalibrated. Several of the national types for Croatia in all of the RBDs 
do not appear to have corresponding intercalibration types:  21 river water body types and 15 
lake water body types9,10. It is unclear how the intercalibration process has been transferred to 
these national types11.    

8   The Faculty of Natural Sciences of Zagreb has produced a background document "Testing Biological Methods 
for  Evaluation  of  Ecological  Status  (Water  Framework  Directive,  2000/60/EC)  in  representative  basins  of 
Panonic and Dinaric Ecoregion". 

9   Croatia subsequently highlighted that the number of national river types for which appropriate intercalibration 
types are determined will be revised within an on-going projects, in which biological classification systems for 
the  assessment  of  ecological  status  of  rivers  are  intercalibrated.  The  deadlines  for  implementation  of  these 
projects are end of 2018 and March 2019. 

10   Croatia  subsequently clarified that  the typology of the  natural lakes in  the Dinaric ecoregion (six lakes)  has 
been carried out, but they do not have appropriate intercalibration types. Neither typology nor standardisation 
of the natural lakes in the Pannonian ecoregion (three lakes in the Danube floodplain area) have been carried 

33 

 
 
                                                      
2.1.4 Establishment of reference conditions for surface water bodies 

Table  2.6  shows  the  percentage  of  surface  water  body  types  in  Croatia  for  which  reference 
conditions  were  established  for  the  first  and  second  RBMPs.  Type  specific  reference 

conditions have been established for some, all or none relevant biological quality elements (all 
for all river water body types). Type specific reference conditions have been established for all 

physicochemical quality elements in rivers, transitional and coastal waters and for some, all or 
none for lake water body types. Type specific reference conditions have not been established 
for hydromorphological quality elements in any water category12.  

Table 2.6 

Percentage of surface water body types in Croatia with reference conditions 

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

types in each category 

Water category 

Water types 

Biological quality 
elements 

Hydromorphologi
cal quality 
elements 

Physicochemical 
quality elements 

Lakes (15) 

Rivers (28) 

Transitional (4) 

Coastal (5) 

All 

Some 

None 

All 

Some 

None 

All 

Some 

None 

All 

Some 

None 

40 % 

60 % 

100 % 

100 % 

100 % 

100 % 

100 % 

100 % 

100 % 

Source: WISE electronic reporting 

40 % 

53 % 

7 % 

100 % 

100 % 

100 % 

out,  while  other  stagnant  rivers  are  not  of  natural  origin  and  their  typology  has  been  carried  out  within  the 
projects for development of the classification system for ecological potential. 

11   Croatia  subsequently  highlighted  that  the  current  analysis  shows  that  appropriate  intercalibration  types  for 
most  national  types  do  exist,  with  the  exception  of  mountainous  streams  (altitude  larger  than  500  m)  and 
intermittent running rivers in the eastern-continental intercalibration group. 

12   Croatia  subsequently  clarified  that  the  methodology  for  monitoring  and  assessment  of  status  according  to 
hydromorphological quality elements in rivers is in testing and updating stages, whereas the methodology for 
other water categories is under development. These methodologies will determine the type-specific reference 
conditions for hydromorphological quality elements. 

34 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                                                                                                                        
2.1.5 Characteristics of groundwater bodies 

The characteristics of the geological formation and details on layering of groundwater bodies 
were reported in the second RBMP. Further characterisation work has been reported since the 

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

2.1.6 Significant pressures on water bodies 

In the second RBMP, the significant pressures reported most often are ‘Diffuse – Agricultural’ 

(57 % of surface waterbodies) and ‘Diffuse - Discharges not connected to sewerage network’ 
(54 %) (Figure 2.2). Croatia reported on significant pressures in the first cycle at an aggregated 

level. The most significant pressure was found to be diffuse pollution (92 % of surface water 
bodies) followed by hydromorphological  pressures (70 %) which are similar to  the pressures 

reported for the second cycle RBMP.  

35 

 
 
 
Figure 2.2 

The  most  significant  pressures  on  surface  water  and  groundwater  bodies  in 

Croatia for the second RBMP  

Source: WISE electronic reporting 

 ‘No  significant  pressure’  was  reported  for  90  %  of  groundwater  bodies,  and  the  most 

36 

 
 
 
 
significant pressure was ‘Diffuse – Agricultural’ (6 %).  

In  the  second  RBMP,  Croatia  reported  which  significant  pressures  were  not  assessed  for 
surface waters, a total of 30 in each RBD. The RBMP does not give any explanation for the 
excluded  pressures13.  For  groundwater,  only  one  pressure  was  reported  not  to  have  been 
assessed: ‘Groundwater - Recharges.’ 

2.1.7 Definition and assessment of significant pressures on surface and groundwater 

For surface waters, a combination of both expert judgement and numerical tools was used for 

defining  diffuse  and  point  pressures,  and  pressures  from  abstractions  and  flow  diversions  in 
each RBD. The significance of pressures is reported not to be defined in terms of thresholds or 
linked to the potential failure of objectives for both RBDs14. No further information was found 
on this in the RBMP or background documents.  

Some changes to the methodology since the first RBMP were noted in the second RBMP. For 
point sources, estimates of pollutant emissions were made for all known types of point sources 

for the reference year 2012. Data on the abstraction of water for all known uses were collected 
and  analysed.  There  was  no  change  in  the  assessment  of  hydromorphological  pressure  data 
compared to the first RBMP and the completeness and reliability of the data is still limited. 

The  extent  of  diffuse  sources  considered  has  expanded  since  the  first  RBMP.  Some  diffuse 
sources  have  been  considered  in  full  detail,  based  on  reliable  data,  and,  for  some,  only 

estimations  of  the  emissions  have  been  made.  Particular  attention  has  been  given  to  diffuse 
pollution  from  agriculture.  In  the  program  of  supplementary  measures  of  the  first  RBMP, 

activities were undertaken to investigate the impact of agricultural production on surface and 
groundwater status. A model of the spatial distribution of nitrogen and phosphorus applications 

originating  from  mineral  and  organic  fertilisers  was  developed.  Furthermore,  the  spatial 
distribution of pesticides and active substances in pesticides, by pesticide groups and cultures 

has been modelled. 

For groundwater, a combination of expert judgement and numerical tools was used for defining 

diffuse and point source pressures. Numerical tools were used only for abstraction pressures in 
the  Adriatic  RBD  and  a  combination  was  used  in  the  Danube  RBD.  Artificial  recharge 

pressures have not been assessed. For groundwater, significance of pressures is reported to be 
defined in terms of thresholds but not linked to the potential failure of objectives. The second 

13   Croatia subsequently stated that this is likely to be a reporting error.  
14   Croatia  subsequently  highlighted  that  it  is  very  hard  to  define  significance  thresholds  for  different  pressure 

types and especially for small water bodies.  

37 

 
                                                      
RBMP  explains  that  significant  pressures  in  groundwater  are  related  to  the  failure  of 

groundwater quality and quantity thresholds.  

2.1.8 Significant impacts on water bodies  

In  the  second  RBMP,  the  most  significant  impact  on  surface  water  bodies  was  ‘Nutrient 
pollution’  (43  %)  (Figure  2.3),  with  40  %  reported  as  having  “no  significant  impact”.  For 

groundwater, 90 % were reported as “no significant impact”. The most significant impact was 
‘Nutrient pollution’ (6 %). Croatia did not report on impacts in the first RBMP. 

Figure 2.3 

Significant impacts on surface water and groundwater bodies in Croatia for 
the second RBMP. Percentages of numbers of water bodies  

Source: WISE electronic reporting  

38 

 
 
 
 
2.1.9 Groundwater bodies at risk of not meeting good status 

In each RBD, 15 % of groundwater bodies were reported to be at risk of failing to meet good 
chemical status. The pollutants responsible for groundwater bodies being at risk of failing good 

chemical status have been reported. 

In the Adriatic RBD 15 % of groundwater bodies were also reported to be at risk of failing to 

meet  good  quantitative  status,  while  none  were  reported  to  be  at  risk  in  the  Danube  RBD. 
Further information on the quantitative and chemical status of groundwater bodies is provided 

in Chapters 5 and 6 of this report. 

2.1.10  Quantification of the gap and apportionment of pressures  

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

Danube  RBD,  ‘Anthropogenic  pressure  –  Unknown’  has  been  reported  as  a  significant 
pressure at surface water body level but this pressure has not been reported as being tackled in 

the  Programme  of  Measures.  Similarly,  ‘Abstraction  or  flow  diversion  –  Hydropower’  is 
reported as being addressed in the Programme of Measures but is not identified as a significant 
pressure at a surface water body level.  

The  Priority  Substances  and  other  substances  causing  failure  of  good  chemical  status  have 
been reported. The measures to tackle these substances to achieve good status by 2021 and the 

indicator of the gap have been reported. However, there are some substances for which a gap to 
good status will remain (e.g. fluoranthene). Further information on the implementation of the 

Programme of Measures is provided in Chapters 9 to 13 of this report. 

2.1.11  Inventories of emissions, discharges and losses of chemical substances 

Article  5  of  the  Environmental  Quality  Standards  Directive  (EQS  Directive)15  requires 
Member  States  to  establish  an  inventory  of  emissions,  discharges  and  losses  of  all  Priority 

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

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

suppressing) emissions, discharges and losses for priority substances. 

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

Parliament 

Council 

and 

the 

of 

39 

 
                                                      
Croatia reported that only 6 of the 41 Priority Substances were included in the inventories in 

each RBD. The RBMP explained that the inventory will be completed in the future following 
the  Common  Implementation  Strategy  Guidance  Document  No  28  -  Preparation  of  Priority 
Substances Emissions Inventory16. Firstly, the pollutants that are relevant to water pollution in 
Croatia  will  be  identified  and  then  data  will  be  collected  for  the  assessment  of  emissions, 

releases and losses of those pollutants to the aquatic environment. 

The two step approach from the Common Implementation Strategy Guidance Document n°28 

has  been  followed  for  all  substances  considered  in  the  inventories.  The  Guidance  Document 
identifies  a  tiered  approach  to  assessing  emissions,  but  Croatia  reported  using  a  different 

methodology. The data quality was assessed as uncertain. 

2.2  Main changes in implementation and compliance since the first cycle 

Overall  there  was  an  increase  in  the  number  of  water  bodies  delineated  from  the  first  to  the 

second  RBMP.  For  river  water  bodies,  there  was  a  21  %  increase  overall.  For  lake  water 
bodies, there was an increase of 9 % overall but a decrease of 20 % in the Adriatic RBD. For 

coastal  water  bodies,  there  was  an  18  %  increase  in  the  Adriatic  RBD  and  a  decrease  in 
transitional water bodies of 11 %. The number of groundwater bodies remained the same in the 

Danube RBD and there was an increase of 8 % for the Adriatic RBD. In the second RBMP, 86 
%  of  identified  surface  water  bodies  were  natural  with  9  %  being  designated  as  heavily 

modified and 5 % as artificial water bodies. In the first RBMP, the situation was quite different 
with 92 % natural, 8 % artificial and no heavily modified water bodies.  

The number of river water body types had a significant decrease, from 52 to only 28 types. The 
second  RBMP  reported  that  the  typology  had  been  revised  since  the  first  RBMP,  which 

allowed for the merging of water bodies. 

Croatia reported on significant  pressures  in  the first  RBMP at  an aggregated level.  The most 

significant  pressure  was  found  to  be  diffuse  pollution  followed  by  hydromorphological 
pressures, which are similar to the pressures reported for the second RBMP.  

2.3  Progress with Commission recommendations 

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

requested action on the following: 

16   https://circabc.europa.eu/sd/a/6a3fb5a0-4dec-4fde-a69d-5ac93dfbbadd/Guidance%20document%20n28.pdf  

40 

 
                                                      
  Recommendation: Review the pressures and impacts analysis and status assessment in 
the second RBMPs and ensure that the measures are based on the updated pressures 
and impacts analysis and status assessment of water bodies.  

Assessment:  This  recommendation  applies  to  more  than  one  Topic.  In  terms  of 
characterisation, Croatia has reported the pressures and impacts at a water body level. 

Croatia  reported  that  only  6  of  the  41  Priority  Substances  were  included  in  the 
inventories in each RBD.  

For surface waters, a combination of both expert judgement and numerical tools were 
used for defining diffuse and point pressures, and pressures from abstractions and flow 

diversions  in  each  RBD.  For  groundwaters,  a  combination  of  expert  judgement  and 
numerical  tools  was  used  for  defining  diffuse  and  point  source  pressures.  Numerical 

tools were used for abstraction pressures in the Adriatic RBD and a combination was 
used  in  the  Danube  RBD.  Therefore,  there  does  not  appear  to  be  an  overreliance  on 

expert judgement.  

The measures to tackle Priority Substances and other substances causing the failure of 

good chemical status by 2021 and the gap indicator have been reported. However, there 
are some substances for which a gap to good status will remain (e.g. Fluoranthene). 

Overall this recommendation has been partially fulfilled. 

41 

 
 
 
Topic 3

  Monitoring,  assessment  and  classification  of  ecological 

status in surface water bodies 

3.1  Assessment of implementation and compliance with WFD requirements 

in the second RBMP 

3.1.1 Monitoring of ecological status/potential 

Monitoring programmes 

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

comprehensive overview of water status  within each RBD. Territorial waters are not  a water 
body category under WFD. However, it should be noted that under Article 2(1) of the WFD, 

territorial waters are included for the assessment and reporting of chemical status. 

Monitoring programmes were reported for rivers and lakes in both RBDs, and for coastal and 

transitional waters in the Adriatic RBD which had also identified these two water categories. 
The relevant water categories were all included in a surface water monitoring programmes. No 
monitoring was reported for territorial waters. 

Monitoring sites  

Table  3.1  compares  the  number  of  monitoring  sites  used  for  surveillance  and  operational 

purposes from the first to the second RBMP, and Table 3.2 gives the number of sites used for 
different purposes for the second RBMP. 

Table 3.1 

Number of sites used for surveillance and operational monitoring in Croatia 
for the second and first RBMP. Note that for reasons of comparability with 

data reported in 2013, the 2016 data does not take into account whether sites 
are used for ecological and/or chemical monitoring  

Second RBMP  

HR_C 

HR_J 

Total by type of site 

Rivers 

Lakes 

Transitional 

Coastal 

Surv. 

Op 

Surv. 

Op 

Surv. 

Op 

Surv. 

Op 

32 

8 

40 

118 

17 

135 

3 

3 

6 

7 

7 

14 

81 

81 

23 

23 

49 

49 

29 

29 

Total number of monitoring sites 

152 (175) 

19 (20) 

88 

69 

First RBMP 

42 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
HR_C 

HR_J 

Total by type of site 

32 

6 

38 

107 

10 

117 

1 

4 

5 

3 

3 

6 

Total number of monitoring sites 

132 

10 

52 

52 

0 

52 

87 

87 

0 

87 

Sources: Member States electronic reporting to WISE in 2013 and 2016. The numbers in parentheses were 
subsequently communicated by Croatia. 

Table 3.2 

Number of monitoring sites in relevant water categories used for different 
purposes in Croatia  

Monitoring Purpose 

CHE - Chemical status 

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

ECO - Ecological status 

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

INT - International network of other international convention 

MSF - Marine Strategy Framework Directive monitoring network 

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

OPE - Operational monitoring 

REF - Reference network monitoring site 

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

SEA - International network of a sea convention 

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

SOE - EIONET State of Environment monitoring 

SUR - Surveillance monitoring 

Total sites irrespective of purpose 

Lakes  Rivers  Transitional  Coastal 

5 

1 

1 

16 

2 

14 

8 

6 

25 

124 

194 

181 

14 

51 

135 

10 

43 

40 

309 

28 

87 

42 

23 

11 

2 

7 

4 

81 

91 

37 

69 

13 

34 

29 

9 

10 

8 

11 

49 

69 

Source: WISE electronic reporting 

For the first RBMP, there were no sites for operational monitoring in coastal and transitional 
waters  in  the  Adriatic  RBD,  for  the  second  RBMP  29  sites  and  23  sites  were  reported  for 

coastal  and  transitional  waters,  respectively.  There  were  also  increases  in  the  number  of 
operational  sites  in  river  and  lakes  in  both  RBDs  compared  to  the  first  RBMP.  Whilst  there 

was  a  decrease  in  the  number  of  coastal  and  lake  sites  used  for  surveillance  purposes  in  the 
Adriatic RBD for the second RBMP, there was no change in the number of surveillance sites in 

rivers in the Danube RBD and increases in lake sites in the Danube RBD, and in transitional 
waters and rivers in the Adriatic RBD. 

43 

 
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The  number  of  monitoring  sites  in  the  2015  Commission  Staff  Working  Document17  for  the 
first  RBMP are the wrong way around in  terms  of surveillance and operational  monitoring  – 
this has been corrected in Table 3.1. 

Monitored quality elements (excluding RBSPs) 

Table  3.3  illustrates  the  quality  elements  used  for  the  monitoring  of  lakes  and  rivers  for  the 

second RBMP. No differentiation is made between purposes of monitoring. 

Table 3.3 

Quality elements monitored for the second RBMP in Croatia (excluding River 

Basin Specific Pollutants). Note; quality element may be used for surveillance 
and/or operational monitoring  

Biological quality elements 

Hydromorphological quality elements 

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

s
e
t
y
h
p
o
r
c
a
M

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

c
i
h
t
n
e
B

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

h
s
i
F

s

m
r
e
p
s
o
i
g
n
A

e
a
g
l
a
o
r
c
a
M

Lakes 

No  No  No  No  No 

Rivers 

Yes  Yes  Yes  Yes  Yes 

s
e
i
c
e
p
s

r
e
h
t
O

c
i
t
a
u
q
a

r
e
h
t
O

a
r
o
l
f

No 

No 

Transitional  Yes  Yes 

Yes  Yes  No  No  No 

Coastal 

Yes  Yes 

Yes 

No  No  No 

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

e
m
i
g
e
r

l
a
d
i
t

No 

No 

No 

No 

y
t
i
u
n
i
t
n
o
C

s
n
o
i
t
i
d
n
o
c

No 

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

s
n
o
i
t
i
d
n
o
c

No 

No 

No 

No 

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

s
n
o
i
t
i
d
n
o
c

Yes 

Lakes 

Rivers 

Transitional 

Coastal 

Yes 

Yes 

General physicochemical quality elements 

l
a
m
r
e
h
T

s
n
o
i
t
i
d
n
o
c

No 

Yes 

No 

Yes 

n
o
i
t
a
n
e
g
y
x
O

s
n
o
i
t
i
d
n
o
c

Yes 

Yes 

Yes 

Yes 

y
t
i
n
i
l
a
S

s
n
o
i
t
i
d
n
o
c

No 

No 

Yes 

Yes 

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

s
u
t
a
t
s

No 

Yes 

No 

Yes 

n
e
g
o
r
t
i

N

s
n
o
i
t
i
d
n
o
c

Yes 

Yes 

Yes 

Yes 

s
u
r
o
h
p
s
o
h
P

s
n
o
i
t
i
d
n
o
C

Yes 

Yes 

Yes 

Yes 

Source:  WISE electronic reporting18  

r
e
h
t
O

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

t
n
e
i
r
t
u
n

s
n
o
i
t
i
d
n
o
c

No 

No 

No 

No 

e
t
a
c
i
l
i
S

No 

No 

No 

No 

17   http://ec.europa.eu/environment/water/water-framework/pdf/4th_report/MS%20annex%20-%20Croatia.pdf  
18 Croatia subsequently made the following corrections to the table, as there might be reporting errors in WISE. 
For  lakes,  transparency  conditions,  oxygenation  conditions,  nitrogen  and  phosphorus  conditions  are 
monitored.  For  rivers  and  for  coastal  waters  silicates  are  not  monitored.  For  transitional  waters  thermal 
conditions, acidification status and silicates are not monitored. 

44 

 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
There are significant  gaps in the monitoring of required and expected quality elements. Fish, 

macrophytes and phytoplankton are not monitored in lakes. Angiosperms and macroalgae are 
not  monitored  in  coastal  waters  or  transitional  waters,  though  macrophytes  are  reported  for 

both.  Hydromorphological  quality  elements  are  not  reported  to  be  monitored  in  any  water 
category.  A  wide  range  of  physicochemical  quality  elements  are  reported  at  the  specific 

determinand level (e.g. nitrite as part of nutrient conditions), but there still are gaps. 

Morphological conditions were used in the classification of all water categories, hydrological 

regime  was  also  used  in  rivers  and  lakes  and  continuity  in  rivers.  The  classification  of  all 
hydromorphological  quality  elements  in  all  water  categories  was  based  on  expert  judgment: 

none  of  these  elements  were  reported  to  be  monitored.  This  introduces  uncertainty  on  the 
robustness of the classification of ecological status/potential in Croatia. 

Monitoring  sites  in  lakes  in  the  Adriatic  RBD  are  only  used  for  chemical  monitoring:  this 
means  that  biological  quality  elements,  hydromorphological  and  physicochemical  quality 

elements are not monitored, with only River Basin Specific Pollutants and Priority Substances 
being included. 

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

quality elements. Surveillance monitoring should be carried out for each monitoring site for a 
period of one year during the period covered by a RBMP i.e. six years. For phytoplankton, this 

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

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

basis of technical knowledge and expert judgement. 

None of the biological quality elements used for the surveillance or operational monitoring of 

coastal and transitional waters were sampled at, or more than, the WFD minimum frequency. 
In contrast, three of the five biological quality elements used for surveillance, and two of the 

four used for operational monitoring were sampled at, or more than, the minimum frequency at 
all  sites  where  they  were  monitored.  The  one  site  used  for  monitoring  lakes  (including  for 

phytobenthos and benthic invertebrates) was not used for surveillance or operational purposes. 

Monitoring of River Basin Specific Pollutants 

In  total  eight  different  River  Basin  Specific  Pollutants  (mostly  metals)  were  reported  to  be 
monitored  in  Croatia,  according  to  the  WISE  reporting.  These  substances  are:  arsenic, 

chromium,  copper,  cobalt,  zinc,  fluoride,  AOX  and  PCBs.  However,  Croatia  subsequently 

45 

 
clarified  that  cobalt  is  not  considered  as  a  River  Basin  Specific  Pollutant.  Consequently  the 

right number of River Basin Specific Pollutants monitored is seven.  

All  substances  were  monitored  in  water  for  status  assessment  and  four  were  monitored  in 

sediment for trend assessment.  

For  status  assessment  all  seven  river  basin  specific  pollutants  confirmed  by  Croatia  were 

monitored  in  rivers,  two  in  coastal  and  transitional  waters  and  four  in  lakes.  The  number  of 
monitoring sites for each water body type in the second RBMP is shown in Table 3.4.  

Table 3.4 

Number  of  sites  used  to  monitor  River  Basin  Specific  Pollutants  reported  in 
the  second  RBMP  and non-priority  specific  pollutants  and/or  other  national 

pollutants  reported  in  the  first  RBMP  in  Croatia.  Note  the  data  from  both 
cycles may not be fully comparable as different definitions were used and also 

not all Member State reported information at the site level meaning that there 
were no equivalent data for the first RBMP 

RBMP 

second 

first 

Sites used to monitor River Basin 
Specific Pollutants 

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

Lakes 

Rivers  Transitional 

Coastal 

9 

141 

26 

38 

NR 

NR 

NR 

NR 

Sources: WISE electronic reporting. 
NR: Not reported at the site level 

Each of the seven River Basin Specific Pollutants was monitored at a frequency at least as high 

as the WFD recommended minimum frequency in most of the monitoring sites.   

Croatia identified and reported non-priority specific pollutants as part of their first RBMP (to 

be monitored in lakes and rivers), however this information was not reported at the site level. It 
is therefore not possible to make comparison at the site level between the two RBMP.  

Surveillance monitoring of surface water bodies 

None  of  the  water  bodies  used  for  surveillance  monitoring  in  lakes,  rivers,  transitional  and 

coastal  water  was  monitored  for  all  required  biological  and  hydromorphological  quality 
elements.  Around  84  %  of  coastal  and  transitional  water  bodies  included  in  surveillance 

46 

 
 
 
monitoring  were  monitored  for  all  required  physicochemical  quality  elements:  none  of  the 

rivers and lake water bodies was monitored for all required elements. 

Proportionally more surface water bodies in  Croatia were included in  operational  monitoring 

(10  %)  compared  to  surveillance  (6  %).  There  are  discrepancies  in  the  number  of  lakes  and 
transitional water bodies reported in the WISE monitoring schema compared to those reported 

in  the  WISE  surface  water  body  schema.  More  are  reported  in  the  former  compared  to  the 
latter.  

For the first RBMP, there was no operational monitoring in coastal and transitional waters: for 
the  second  RBMP  there  was.  Overall  for  the  first  RBMP,  9  %  of  surface  water  bodies  were 

included in operational  monitoring and 7 % in surveillance monitoring: the respective values 
for the second RBMP were 10 % and 6 %. It should be borne in mind that there was a 20 % 

increase in the number of surface water bodies from 1 315 for the first RBMP to 1 572 for the 
second  RBMP.  Figure  3.1  shows  the  proportion  of  surface  water  bodies  included  in 

surveillance  and  operational  monitoring  in  Croatia  for  the  first  and  second  RBMP  for  each 
water category.  

Figure 3.1 

Percentage  of  water  bodies  included  in  surveillance  and  operational 

monitoring in Croatia for the first RBMP (2013) and second RBMP (2016). 
Note:  no  differentiation  is  made  between  water  bodies  included  in 

ecological and/or chemical monitoring  

Source:  WISE electronic reporting. Note that there are discrepancies in the number of transitional water bodies 

reported in the WISE monitoring schema compared to those reported in the WISE Surface Water Body schema 
resulting in percentages greater than 100. 

47 

 
 
Figure 3.2 shows the  proportion  of water bodies in  each ecological  status/potential class that 

are  included  in  surveillance  monitoring  in  Croatia.  This  shows  the  desired  distribution  of 
surveillance monitoring sites among the ecological status/potential class. 

Figure 3.2 

Proportion of water bodies in each ecological status/potential class that are 
included in surveillance monitoring in Croatia 

Source: WISE electronic reporting  

Operational monitoring of surface water bodies 

No  biological  quality  element  was  used  in  the  operational  monitoring  of  lakes  in  Croatia. 
Predominantly benthic invertebrates and phytobenthos were used for operational monitoring of 

rivers though macrophytes and phytoplankton were also used to a lesser extent: fish were not 
monitored.  Phytoplankton  and  benthic  invertebrates  were  mainly  used  in  coastal  and 

transitional  waters  with  macrophytes  also  used  in  both  categories  and  fish  in  transitional 
waters.  

48 

 
 
Transboundary surface water body monitoring 

Croatia reported transboundary coastal, river, transitional and groundwater bodies. Monitoring 
sites that are part of international network of river or other convention or of a sea convention 

were reported for coastal waters (10 sites), rivers (24 sites) and transitional waters (two sites). 

3.1.2 Assessment and classification of ecological status/potential of surface water 

Ecological Status/potential of surface water  

The  ecological  status/potential  of  surface  water  bodies  in  Croatia  for  the  second  RBMP  is 

illustrated in Map 3.1. This is based on the most recent assessment of status. 

Croatia  delineated  a  high  number  of  river  water  bodies  (1  484).  This  large  number  seems  to 

complicate the ecological status assessment. 

Figure 3.3 compares the ecological status of surface water bodies in Croatia for the first RBMP 

with  that  for  the  second  (based  on  the  most  recent  assessment  of  status/potential)  and  that 
expected by 2015). 

A  detailed  breakdown  of  ecological  status/potential  in  each  RBD  and  water  category  can  be 
viewed in the WISE electronic reports.  

There  was  a  decrease  in  the  proportion  of  surface  water  bodies  at  good  or  better  ecological 

status/potential from 51 % for the first RBMP to 42 % for the second. 

The  significance  of  the  changes  in  status/potential  need  to  be  considered  in  terms  of,  for 

example, changes in the delineation of water bodies. There was a 20 % increase in the number 
of delineated surface water bodies between the two RBMPs with the largest increase being in 

river water bodies (1 231 for the first RBMP to 1 484 for the second). 

Member States were asked to report the expected date for the achievement of good ecological 
status/potential.  The  information  for  Croatia  is  shown  in  Figure  3.4.  The  expected  date  of 
achievement of good ecological status/potential for a large proportion of river and lake water 

bodies remains unknown. 

49 

 
Map 3.1 

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

most recently assessed status/potential of the surface water bodies 

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

Source: WISE, Eurostat (country borders) 

High 

Good 

Moderate 

Poor  

Bad 

Unknown 

RBDs 

Countries outside the European Union 

50 

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

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

period  of  the  assessment  of  status  for  the  second  RBMP  was  2010  to  2015. 
The year of the assessment of status for first RBMP is not known 

 Source: WISE electronic reporting 
Figure 3.4  Expected  date  of  achievement  of  good  ecological  status/potential  of  surface 

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

Source: WISE electronic reporting  

51 

 
 
 
Confidence in Ecological Status assessment 

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

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

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

Source:  WISE electronic reporting 

A  medium  level  of  confidence  was  reported  for  all  surface  water  bodies  classified  for 
ecological status/potential for the first RBMP in Croatia. For the second RBMP, all three levels 

of confidence were reported with 14 % at high, 47 % at medium and 39 % at a low level of 
confidence. 

Classification of ecological status at the quality element level 

Only a very small fraction of water bodies has been classified on the basis of biological quality 

element assessments. The ecological status of most water bodies is based on physicochemical 
or hydromorphological quality elements. The biological elements have only been used in the 

classification  for  about  15  %  of  water  bodies.  Coastal  water  bodies  are  best  covered  by 
biological classification (Figure 3.6).  

52 

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

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

not applicable, are not presented  

Source: WISE electronic reporting 
Figure  3.7  compares  the  classification  of  biological  quality  elements  in  terms  of  ecological 
status/potential for the two RBMPs. It should be noted that this comparison should be treated 

with  some  caution  as  there  are  differences  between  the  numbers  of  surface  water  bodies 
classified  for  individual  elements  from  the  first  to  the  second  RBMP.  Some  additional 

biological  quality  elements  have  been  introduced  in  the  second  RBMP:  macroalgae, 

53 

 
 
phytobenthos,  macrophytes  and  some  indicate  a  deterioration  in  status  in  the  second  RBMP 

(benthic invertebrates and fish). 

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

biological  quality  elements  in  surface  waters  from  the  first  to  the  second 
RBMP. The numbers in parentheses are the number of  surface water bodies 

with a classification for that element. 

Source: WISE electronic reporting.  

Figure 3.8 illustrates the basis of the classification of ecological status/potential of rivers and 
lakes  in  Croatia  for  the  second  RBMP;  confirming  that  only  15  %  of  river  water  bodies  are 

classified  on  the  basis  of  all  four  types  of  quality  element  with  the  remainder  of  rivers  and 
other water categories classified on the basis of just three. 

54 

 
 
Figure 3.8 

The classification of the ecological status or potential of surface water bodies 

in Croatia using 1, 2, 3 or 4 types of quality element. Note: The 4 types are: 
biological;  hydromorphological,  general  physicochemical  and  River  Basin 

Specific Pollutants. 

Source: Extracted from WISE. 

Assessment methods for the biological quality elements 

No  methods  were  reported  for  angiosperms  in  coastal  and  transitional  waters,  and  for 
macroalgae in transitional waters though a method for macrophytes was reported.  

Furthermore,  Croatia  lacks  an  assessment  method  for  fish  in  lakes  that  is  currently  under 
development. The method for assessing the ecological potential of the various water categories 

is also still under development. 

No  biological  quality  element  assessment  method  was  reported  to  be  sensitive  to  chemical 

pollution in rivers even though this impact was reported to be significant in both RBDs. 

The RBMP give some indications on changes since the first RBMP. It says that on the basis of 

the new  findings  emerging  from  the research projects  carried out  in  the  period from  2009 to 
2013, the need for revision of the typology for some surface water categories and for the re-

determination  of  water  bodies  in  accordance  with  the  new  typology  has  been  identified.  The 
collected findings have resulted in substantial modifications and improvements in the surface 

water status assessment system in relation to the first RBMP. This applies in particular to the 
increase in the number of quality elements for which the reference values and class boundaries, 

primarily the biological elements, are set. 

55 

 
 
 
There is limited information in the RBMP on changes between the first and second RBMP in 

the assessment methodologies for the biological  quality elements.  All  changes are given in  a 
common (ecology status and potential, chemical status, ecological status is said to be assessed 

through  biological  and  chemical  status)  summary  on  surface  water  status.  The  elements  of 
changes  can  be  repeated  as  for  the  ecological  and  chemical  status  given  above:  the  biggest 

change  is  use  of  higher  number  of  biological  elements  for  assessment,  but  overall  there  is  a 
lack of spatial and temporal coverage of data. At the national level only 180 river water bodies 

were  assessed,  or  approximately  13  %  of  all  river  water  bodies.  Coverage  of  biological 
monitoring  is  higher  in  the  Danube  RBD  (15  %  of  water  bodies).  Only  5  %  of  river  water 

bodies are rated in the Adriatic RBD. This is to be tackled with measures in this new RBMP 
2016-2021. 

Intercalibration of biological assessment methods and national classification systems 

All  five  coastal  water  and  four  transitional  water  types  were  reported  to  have  an  equivalent 
common intercalibration type. 21 of the 2819 river types do not have a common intercalibration 
type: it will be important that the results of intercalibration are adequately translated to these 
21 national types. None of the 6 lake types have an equivalent common intercalibration type: 

this calls into question the comparability of the classification of the ecological status/potential 
of lakes with other Member States. 

The published RBMPs indicate that Croatia did not participate in the first and second cycles of 
intercalibration  exercises  because  at  that  time  it  was  not  a  member  of  the  European  Union. 

Therefore, the national classification system of biological elements in surface inland waters did 
not  have enough data to  carry out  the intercalibration process.  However,  intercalibration will 

be carried out subsequently as instructed by the European Commission's guide "Procedure to 
fit new or revised national classifications to the completed Intercalibration exercise".20  

Assessment methods for hydromorphological quality elements 

The  expected  hydromorphological  quality  elements  are  assessed  in  terms  of  ecological 

status/potential in rivers and lakes. However the classification boundaries are not related to the 
class  boundaries  of  the  sensitive  biological  quality  elements  in  rivers.  The  classification 

boundaries  for  morphological  conditions  in  lakes  are  related  to  the  class  boundaries  of  the 
sensitive  biological  quality  elements.  Only  morphological  conditions  are  assessed  in 

19   Croatia clarified that 28 river types, not 27, are found in Croatia. 
20   https://circabc.europa.eu/sd/a/5aee6446-276c-4440-a7de-

0d4dec41ed4b/IC_manual_2015_to%20be%20published.pdf  

56 

 
                                                      
transitional and coastal waters and the class boundaries are related to the sensitive biological 

quality elements. 

Classification methods for general physiochemical quality elements 

The  reported  physicochemical  quality  elements  are  assessed  in  terms  of  ecological 
status/potential in all water categories. However, not all the relevant elements are assessed and 

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

In  rivers,  only  oxygenation  and  nutrient  conditions  are  assessed  in  terms  of  ecological 
status/potential  and  their  classification  boundaries  are  related  to  the  class  boundaries  of  the 

sensitive biological quality elements. For lakes, three elements (transparency, oxygenation and 
nutrient conditions) are assessed and again all are related to the classification boundaries of the 

sensitive  biological  quality  elements.  Three  (transparency,  oxygenation  and  nutrient 
conditions) of the five elements assessed in transitional and coastal waters were also classified 

in  relation  to  the  sensitive  biological  quality  elements,  two  (thermal  and  salinity  conditions) 
were not. 

The reported standards for physicochemical quality elements in rivers and lakes have not been 

defined for individual types separately. This holds the risk of inappropriate status classification 
because,  for  instance,  different  river  types  naturally  vary  in  their  national  nutrient 

concentrations.  

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

The RBMP indicates that river basin  specific pollutants have been identified by  a number of 
means  including  from  the  measured  concentrations  in  water  bodies  arising  from  monitoring 

programmes, from estimated concentrations in water bodies derived from modelling exercises 
which  consider  production,  use  and  emission  data  and  on  the  risk  posed  by  releases  of 

substances from both point and diffuse sources in the RBD. 

Environmental Quality Standards are reported for seven River Basin Specific Pollutants, only 

for water. Six of these are set for rivers, six for lakes and two in coastal and transitional waters. 
The standards were not reported to be derived in accordance with the 2011 Technical Guidance 
Document No. 2721 for all substances in all water categories22.  

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

WFD%2027%20EC%202011.pdf 

57 

 
                                                      
It  is  interesting  to  note  that  although  standards  were  reported  for  coastal  and  transitional 

waters,  River  Basin  Specific  Pollutants  were  not  reported  as  classified  in  these  categories  of 
water  (see  Figure  3.9  below).  In  addition,  in  lakes,  River  Basin  Specific  pollutants  are 

classified only on the basis of grouping. 

The analytical methods used meet the minimum performance criteria laid down in Article 4(1) 
of Directive 2009/90/EC23 for the strictest standard applied for six or the seven substances and 
complied with Article 4(2) for the other. 

Use of monitoring results for classification 

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

Morphological conditions were used in the classification of all water categories, hydrological 
regime  were  also  used  in  rivers  and  lakes  and  continuity  in  rivers.  The  classification  of  all 

hydromorphological quality elements in all categories was based on expert judgment and none 
was monitored. This introduces uncertainty and undermines the robustness of the classification 

on ecological status/potential in Croatia.  

The  classification  of  biological  quality  elements  in  all  water  categories  was  based  on 
monitoring results though in some cases (particularly in rivers), the elements were monitored 

in fewer water bodies than were subsequently classified: this raises the question on how some 
water bodies were classified based on monitoring results when they were not monitored. 

Grouping  was used  for  classifying some physicochemical  elements  and  River Basin  Specific 
Pollutants  in  rivers  and  lakes.  Grouping  was  not  used  for  any  biological  quality  element  or 

hydromorphological  quality  element  in  any  of  the  water  categories.  River  Basin  Specific 
Pollutants were only classified in lakes and rivers even though they are monitored in all four 

water categories: monitoring results were only used in the classification of rivers. This raises 
the question as to  how  grouping  was undertaken  when classifying lakes for these substances 

when none had been classified based on monitoring results. 

22   However,  Croatia  subsequently  clarified  that  the  environmental  quality  standards  for  arsenic,  copper,  zinc, 
chromium and their compounds have now been revised according to the Technical Guidance Document. They 
are also planning to revise the standards for fluorides, adsorbable organic halogens (AOX) and polychlorinated 
biphenyls (PCBs) in accordance with the Guidance Document. 

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

58 

 
                                                                                                                                                        
 
Figure 3.9  Basis  of  the  classification  of  ecological  status/potential  in  Croatia.  The 

percentages are in terms of all waterbodies in each category. 

Source: WISE electronic reporting 

59 

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

The  ‘one-out,  all-out’  principle  has  been  applied  in  deriving  the  overall  classification  of  the 
ecological status of a water body. 

Figure 3.10 illustrates the basis of the classification of ecological status/potential of rivers and 
lakes in Croatia for the second RBMP. 

Figure 3.10 

The  percentage  of  surface  water  bodies  in  Croatia  where  no  biological 
quality  element  or  no  hydromorphological  (HYMO)  or  no  general 

physicochemical  (PHYSCHEM)  or  no  river  basin  specific  pollutant 
(RBSP) has been used in the classification of ecological status or potential 

Source: Member State reporting to WISE 

3.2  Main changes in implementation and compliance since the first RBMP 

For the first RBMP, there were no sites for operational  monitoring in coastal and transitional 
waters  in  the  Adriatic  RBD:  for  the  second  RBMP  29  sites  and  23  sites,  respectively  were 
reported. There were also increases in the number of operational sites in river and lakes in both 
RBDs compared to the first RBMP. Whilst there was a decrease in the number of coastal and 

lake sites used for surveillance purposes in the Adriatic RBD for the second RBMP, there was 
no  change  in  the  number  of  surveillance  sites  in  rivers  in  the  Danube  RBD  and  increases  in 

lake sites in the Danube RBD, and in transitional waters and rivers in the Adriatic RBD. 

For the first RBMP there was no operational monitoring in coastal and transitional waters: for 

the  second  RBMP  there  was.  Overall  for  the  first  RBMP,  9  %  of  surface  water  bodies  were 

60 

 
 
included in operational  monitoring and 7 % in surveillance monitoring: the respective values 

for the second RBMP were 10 % and 6 %. It should be borne in mind that there was a 20 % 
increase in the number of surface water bodies from 1315 for the first RBMP to 1572 for the 

second. 

There  was  a  decrease  in  the  proportion  of  surface  water  bodies  at  good  or  better  ecological 

status/potential  from  51  %  for  the  first  RBMP  to  42  %  for  the  second.  However,  the 
significance of the changes in status/potential need to be considered in terms of, for example, 

changes  in  the  delineation  of  water  bodies.  There  was  a  20  %  increase  in  the  number  of 
delineated  surface  water  bodies  from  the  first  to  the  second  RBMP  with  the  largest  increase 

being in river water bodies (1231 for the first RBMP to 1484 for the second). 

3.3  Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMP  and  Programme  of  Measures 

requested action on the following: 

  Recommendation:  Complete  the  development  of  methods  for  the  status  assessment  of 
water  bodies  and  determination  of  reference  conditions  and  apply  them  through  the 

implementation 
(start  monitoring 
hydromorphological parameters in lakes and transitional and coastal waters and fish 

robust  monitoring 

programmes 

of 

in lakes).   

Assessment: Hydromorphological quality elements are not monitored in Croatia. There 

has  been  no  progress  on  this  aspect.  Fish  are  still  not  monitored  in  lakes.  There  has 
been progress on this aspect. 

The assessment methods for most biological  quality  elements  are in  place (except  for 

fish  in  lakes,  angiosperms  in  coastal  and  transitional  waters,  and  for  macroalgae  in 
transitional  waters  and  for  ecological  potential  assessment).  Some  of  these  gaps  are 

currently addressed by ongoing research projects. 

Croatia subsequently indicated that work has been and is underway to further develop 

methods for the status assessment of water bodies. This includes the implementation of 
hydromorphological monitoring and assessment in rivers and a project was initiated for 

the  development  of 
implementation  of  hydromorphological  monitoring  and 
methodologies  for  monitoring  and  assessment  of  hydromorphological  indicators  in 
natural  lakes  and  transitional  and  coastal  waters.  There  is  also  a  project  which  would 
obtain  adequate  information  regarding  the  status  of  fish  populations  in  natural  lakes. 

61 

 
The  methods  for  angiosperms  in  transitional  and  coastal  waters  have  also  been 

developed. 

In conclusion, there has been progress on this recommendation and it has been partially 

fulfilled.  

  Recommendation: An adequate WFD compliant assessment and monitoring framework 
is a necessary pre-requisite to design effective Programme of Measures and ultimately 
to achieve the WFD objectives. 

Assessment:  Croatia  reported  what  determinands  were  included  as  physicochemical 
quality  elements:  however  the  expected  and  required  elements  were  not  monitored  in 

all  water  bodies.  Some  progress  has  been  made  on  this  aspect.  Angiosperms  and 
macroalgae  are  still  not  monitored  in  transitional  waters  but  there  has  been  some 

progress with regards to benthic invertebrates. However, there has been deterioration in 
implementation  of  monitoring  on  coastal  waters  where  angiosperms  and  macroalgae 

were  reported  not  to  be  monitored  for  the  second  RBMP.  No  hydromorphological 
quality elements in any of the four water categories were reported to be monitored.  

In conclusion, there has not been sufficient progress on this recommendation and it is 
not fulfilled. 

 

Recommendation: Review and update the list of river basin specific pollutants 

There was  no information associated with  the first  RBMP on which RBSPs had been 

selected.  Though  information  was  found  in  the  second  RBMP  on  how  RBSPs  were 
selected,  there  was  no  information  on  how  these  had  changed  since  the  first  plan. 

Croatia subsequently clarified that the first and second RBMPs used the same RBSPs. 

This recommendation is not fulfilled. 

62 

 
Topic 4

  Monitoring,  assessment  and  classification  of  chemical 

status in surface water bodies 

4.1  Assessment of implementation and compliance with WFD requirements 

in the second RBMP  

4.1.1 Monitoring of chemical status in surface waters 

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

Member  States  have  to  implement  surveillance  and  operational  monitoring  programmes  in 
accordance  with  the  requirements  of  the  WFD24  for  the  assessment  of  ecological 
status/potential and chemical status.  

Surveillance monitoring programmes should allow Member States to supplement and validate 

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

resulting  from  widespread  anthropogenic  activity.  For  operational  purposes,  monitoring  is 
required to establish the status of waterbodies identified as being at risk of failing to meet their 
environmental objectives, and to assess any changes in the status of such waterbodies resulting 

from the programme of measures. 

Section 3.1.1. of this report summarises the characteristics of the surveillance and operational 

monitoring programmes in Croatia for the second RBMP. 

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

surface  waters  for  the  second  RBMP.  No  distinction  is  made  between  sites  used  for 
surveillance and/or operational purposes.  

More  detailed  information  can  be  found  on  the  website  of  the  European  Environment 
Agency25.  

As shown, 20 %, 40 %, 54 % and 31 % of monitoring sites are used for monitoring of chemical 

status in lakes, rivers, coastal waters and transitional waters respectively. No territorial waters 
are delineated, monitored or assessed for chemical status in Croatia26. 

24   Directive  2000/60/EC  of  the  European  Parliament  and  of  the  Council  establishing  a  framework  for  the 
http://eur-lex.europa.eu/legal-
of 

policy 

water 

field 

Community 
content/EN/TXT/?uri=CELEX:32000L0060 

action 

the 

in 

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

63 

 
                                                      
Figure 4.1 

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

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

purpose 

Source: WISE electronic reporting  

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

freshwaters for the second RBMP. No distinction is made between sites used for surveillance 
and/or  operational  purposes.  Also  given  is  the  proportion  of  water  bodies  monitored  for  any 

purpose  and,  for  comparative  purpose,  those  for  ecological  status.  According  to  the 
information  reported  to  WISE,  all  coastal  water  bodies  and  96  %  transitional  water  bodies27 
(there are 25 of these) are monitored for chemical status whereas only 14 % and 7 % of lake 
and  river  water  bodies  respectively  are  monitored  for  chemical  status.  Croatia  subsequently 
clarified that all transitional water bodies are actually monitored for chemical status.28 

In the Danube RBD, only 17 % of river water bodies that fail to achieve good chemical status 

are monitored as part of the operational monitoring programme for chemical status whereas in 
the Adriatic RBD Croatia clarified that all coastal  and transitional water  bodies and 35 % of 

river water bodies that fail to achieve good chemical status are monitored for chemical status. 

26   Croatia  subsequently  informed  that  the  territorial  water  bodies  with  regard  to  the  RBMP  and  planning 
documents  prepared  according  to  the  requirements  of  Directive  2008/56/EC  (Marine  Strategy  Framework 
Directive) will be analysed in the RBMP 2021 – 2027. 

27   Croatia informed that all 25 transitional water were monitored for chemical status. 
28   Croatia also expressed doubts as regards the value of 14 % for lakes. 

64 

 
 
                                                                                                                                                        
Figure 4.2 

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

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

water bodies in that category 

Source: WISE electronic reporting. 

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

Monitoring for status assessment 

Requirements 

Article 8.1 of the WFD requires Member States to establish monitoring programmes in order to 
provide  inter  alia  a  coherent  and  comprehensive  overview  of  water  status  within  each  RBD. 

The amount of monitoring undertaken in terms of priority substances, frequency and numbers 
of sites should be sufficient to obtain a reliable and robust assessment of status. According to 

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

(version 

force 

in 

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

65 

 
 
 
 
 
Spatial Coverage 

According to  WISE, in  the Danube RBD, 36  groups of Priority Substances are monitored in 
water  and  all  41  groups  of  Priority  Substances  are  monitored  in  water  in  the  Adriatic  RBD. 

However,  Croatia  subsequently  clarified  that  in  each  RBD,  37  substances  are  monitored: 
brominated  diphenylethers,  chloroalkanes,  tributyltin  compounds  and  trifluralin  are  not 

monitored in any of the two RBDs.  

In  the  Adriatic  RBD,  all  coastal  water  bodies  and  92  %  of  transitional  water  bodies  are 

monitored  for  more  than  10  Priority  Substances.  For  the  Danube  RBD  (lake  and  river  water 
bodies  only),  90  %  of  water  bodies  are  not  monitored  for  any  Priority  Substance.  For  river 

water  bodies  and  lake  water  bodies  in  the  Adriatic  RBD,  over  90  %  and  75  %  are  not 
monitored  for  any  Priority  Substances  respectively  but  the  remaining  25  %  of  lake  water 

bodies are monitored for more than 10 Priority Substances. 

Mercury, hexachlorobenzene and hexachlorobutadiene are not monitored for status assessment 
in biota in Croatia.29 

Frequencies 

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

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

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

expert judgement. 

Monitoring frequencies of 12 times per year and at least once per cycle in water were reported 

for 31 groups of Priority Substances at the monitoring site level for a least some sites. This is 
consistent with the minimum recommended frequency of the Directive for surveillance, but not 

for operational, monitoring.  Frequencies of less than 12 times per year and at least once per 
cycle were reported for 41 groups of Priority Substances at some sites30. No explanation could 
be  found  for  these  reduced  frequencies.  However,  Croatia  mentioned  that  a  supplementary 
measure is planned in the Programmes of Measures to improve chemical status monitoring31. 

29   Croatia clarified that the project “Development of the methodology for monitoring elements of chemical status 
in biota in terrestrial surface waters and implementation of preliminary monitoring” is close to finalization. 
30   Croatia indicated that supplementary measures had been identified in the RBMP to address this shortcoming. 
31   Measure called “ Supplementary measures of the harmonization of water status monitoring” 

66 

 
 
                                                      
Monitoring for long-term trend assessment 

Requirements 

Article 3.3 of the EQS Directive (version in force in 2009) requires Member States to monitor 
14  priority  substances32  that  tend  to  accumulate  in  sediment  and/or  biota,  for  the  purpose  of 
long-term trend assessment.  

Spatial Coverage 

Of  the  14  groups  of  Priority  Substances  which  the  environmental  quality  standard  Directive 

requires the monitoring of the long-term trend in biota and/or sediment, both RBDs in Croatia 
monitor in river water bodies only; lead, mercury, nickel and cadmium. In the Adriatic RBD, 

hexachlorobenzene is also monitored in riverine sediment as well as a number of other Priority 
Substances that are not part of the 14 listed specifically in the EQS Directive.  

Frequencies 

Monitoring should take place at least once every three years, unless technical knowledge and 

expert judgment justify another interval.  

All substances are monitored once or twice a year and every year in the cycle which is above 
the minimum recommended frequency.  

Monitoring of Priority Substances that are discharged in each RBD  

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

“Surveillance monitoring shall be carried out for each monitoring site for a period of one year 
during  the  period  covered  by  a  river  basin  management  plan  for  [inter  alia]:  priority  list 

pollutants  which  are  discharged  into  the  river  basin  or  sub-basin.”  Section  1.3.2  (Design  of 
operational  monitoring)  of  the  Directive  states  that  “In  order  to  assess  the  magnitude  of  the 

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

In order to assess the impact of these pressures, Member States shall monitor as relevant [inter 
alia]:  all  priority  substances  discharged,  and  other  pollutants  discharged  in  significant 

quantities.” 

32   Anthracene,  brominated  diphenylether, 

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

chloroalkanes,  DEHP, 

cadmium,  C10-13 

67 

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

into the river basin or sub-basin.  

In both RBDs in Croatia, six groups of Priority Substances are reported to be in an inventory, 

discharged,  and  also  monitored  (i.e.  all  groups  of  Priority  Substances  discharged  are 
monitored).  These  substances  are:  anthracene,  fluoranthene,  lead,  mercury;  nickel  and 

cadmium. As only six substances are considered in the inventories, it is unclear whether others 
(in particular the four non monitored substances) are discharged as well, and in which RBD. 

Performances of analytical methods used  

For 25 groups of Priority Substances in the Danube RBD, the analytical methods used meet the 

minimum  performance  criteria  laid  down  in  Article  4(1)  of  Directive  2009/90/EC  for  the 
strictest  standard  were  applied.  For  12  out  of  the  remaining  16  groups  Priority  Substances 

reported, the analytical  methods complied with the requirements laid down in Article 4(2) of 
Directive 2009/90/EC using best available techniques not entailing excessive costs.  

According to WISE, in the Adriatic RBD, the analytical methods for endosulfan and tributyltin 
comply neither with Article 4(1) nor Article 4(2).  

The  method  of  dealing  with  measurements  of  Priority  Substances  lower  than  the  limit  of 

quantification  is  reported  to  be  as  specified  in  Article  5  of  the  Technical  specifications  for 
chemical analysis and monitoring of water status Directive (2009/90/EC).  

4.1.2 Chemical Status of surface water bodies 

Member States  are  required to  report the  year on which the  assessment of chemical  status  is 

based. This  may be the  year that the surface water body was  monitored. In case of  grouping 
this may be the year in which monitoring took place in the surface water bodies within a group 

that  are  used  to  extrapolate  results  to  non-monitored  surface  water  bodies  within  the  same 
group.  Overall  the  chemical  assessments  were  carried  out  in  the  period  2012-2015  for  the 

Adriatic RBD and 2012 for the Danube RBD. 

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

Map  4.1.  This  is  based  on  the  most  recent  assessment  of  status  and  shows  that  overall  in 
Croatia 92 % of water bodies are at good chemical status and 8 % are failing to achieve good 

chemical status. 

68 

 
Map 4.1 

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

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

Source: WISE, Eurostat (country borders) 

The chemical status of surface water bodies in Croatia for the first and second RBMP is given 

in Table 4.1. Overall between the two cycles, the proportion of surface water bodies with good 
chemical status decreased from 97 to 92 % and the proportion that failed to achieve good status 

increased from 3 to 8 %.  

69 

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

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

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

standards  laid  down  in  EQS  Directive  2008/105/EC  (version  in  force  on  13 
January  2009).  Some  Member  States  did  not  implement  the  Directive  in  the 

first RBMP as the transposition deadline was in July 2010, after the adoption 
of the first RBMP 

Category 

Good 

Failing to achieve good 

Unknown 

Number 

% 

Number 

% 

Number 

% 

second RBMP 

Lakes (37) 

Rivers (1484) 

Transitional (25) 

Coastal (26) 

Total (1572) 

First RBMP 

Lakes (34) 

Rivers (1231) 

Transitional (28) 

Coastal (22) 

Total (1315) 

37 

1366 

18 

22 

1443 

34 

1201 

25 

19 

1279 

100 % 

92 % 

72 % 

85 % 

92 % 

100 % 

98 % 

89 % 

86 % 

97 % 

118 

7 

4 

129 

30 

1 

3 

34 

8 % 

28 % 

15 % 

8 % 

2 % 

4 % 

14 % 

3 % 

Source: WISE electronic reporting 

2 

2 

7 % 

0.2 % 

Figure 4.3 shows the confidence in the classification of chemical status for the second RBMP. 
Overall, 50 % of surface water bodies in Croatia were classified for chemical status with low 

confidence, 39 % with medium confidence and only 11 % with high confidence. Confidence in 
the classification of chemical status for the first RBMP was not reported. 

Grouping  is  used  to  classify  non  monitored  water  bodies  (water  bodies  in  a  same  group  are 
influenced by the same pressure type or the same combination of different pressure types and 

magnitude(s)). The proportion of water bodies classified with low confidence reflects the use 
of grouping in surface freshwaters where the extent of monitoring was more limited than for 

transitional and coastal waters.   

70 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 4.3 

Confidence in the classification of chemical status of surface water bodies in 

Croatia based on the most recently assessed status/potential  

Source: WISE electronic reporting 

The  assessment  of  chemical  status  for  the  second  RBMP  was  expected  to  be  based  on  the 
standards laid down in  EQS Directive 2008/105/EC  (version in  force on 13 January 200933). 
Some Member States did not implement the Directive in the first RBMP as the transposition 

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

More information on the chemical status in each RBD and water category can be found on the 
website of the European Environment Agency34. 

Directive  2013/39/EU  amended  the  EQS  Directive.  In  particular,  it  sets  more  stringent 
environmental  quality  standards  for  seven  substances35.  Member  States  were  asked  to  report 
whether the new standards caused the status of the surface water body to appear to deteriorate. 

Across  the  two  RBDs  in  Croatia,  this  was  the  case  for  23  %  of  surface  water  bodies  for 
fluoranthene  and  for  5  %  of  surface  water  bodies  for  nickel.  Information  for  only  six 

substances was reported (and was not provided for naphthalene). 

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

34   https://www.eea.europa.eu/publications/state-of-water 
35   Anthracene,  Brominated  diphenylether,  Fluoranthene,  Lead  and  its  compounds,  Naphthalene,  Nickel  and  its 

compounds, Polyaromatic hydrocarbons (PAH) 

71 

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

with  that  for  the  second  RBMP  (based  on  the  most  recent  assessment  of  status)  and  that 
expected by 2015. This shows the 5 % decrease in surface water bodies at good status and the 

fact that the expected status in 2015 was very similar to what was given in the second RBMP. 

Figure 4.4   Chemical status of surface water bodies in Croatia for the second RBMP, for 

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

assessment  of  status  for  the  second  RBMP  was  2012-2015.  The  year  of  the 
assessment of status for first RBMP is not known  

Source: WISE electronic reporting 

Good  chemical  status  should  be  reached  by  2021  in  relation  to  the  revised  environmental 
quality  standards,  unless  Member  States  apply  exemptions  under  WFD  Article  4(4)  or  less 

stringent objectives under WFD Article 4(5). 

Member States were asked to report the expected date for the achievement of good chemical 
status.  The  information  for  Croatia  is  shown  in  Figure  4.5.  Lakes  achieved  good  chemical 
status by 2015 and coastal waters and transitional waters are expected to achieve good status 

by the end of the second RBMP (2021). There is some uncertainty for less than 5 % of rivers 
as  to  whether  good  status  will  be  achieved  by  the  end  of  the  third  cycle  (2027)  for  which 

unknown  is  reported.  The  expected  or  actual  improvement  in  the  chemical  status  of  surface 
water bodies at the end of the first RBMP was reported to be less than described in the RBMP. 

72 

 
 
 
 
Figure 4.5  Expected  date  of  achievement  of  good  chemical  of  surface  water  bodies  in 

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

Source: WISE electronic reporting 

Priority substances causing the failure of good chemical status 

Member  States  were  expected  to  report  exceedances  based  on  the  revised,  more  stringent 
Environmental Quality Standards from Directive 2013/39/EU. 

The Priority Substances causing the greatest proportion of water bodies to fail good chemical 
status were mercury (6 % of surface water bodies); fluoranthene (4 %); lead (2 %) and nickel 

(2 %). 

The “top-ten” substance are shown in Figure 4.6.  

73 

 
 
 
Figure 4.6 

The  top-ten  Priority  Substances  causing  failure  to  achieve  good  chemical 

status in surface water bodies in Croatia 

Source: WISE electronic reporting 

The  largest  proportion  of  exceedances  were  for  the  annual  average  environmental  quality 

standard for  fluoranthene (26  % of surface water bodies failing  good status), lead  (7 %) and 
mercury  (6  %).  In  terms  of  exceedance  of  both  types  of  standard  (annual  average  and 

maximum allowable concentration), the largest proportion was for hexachlorocyclohexane (0.3 
%).  

Ubiquitous persistent, bioaccumulative and toxic Priority Substances 

According  to  Article  8(a)  of  the  EQS  Directive36,  eight  priority  substances  and  groups  of 
priority  substances  are  behaving  like  ubiquitous,  persistent,  bioaccumulative  and  toxic 
substances37.  These  substances  are  generally  expected  to  cause  widespread  exceedances,  and 
their emissions can be challenging to tackle (e.g. due to long-range atmospheric transport and 

36   Amended by Directive 2013/39/EU. 
37   Brominated  diphenylether,  Mercury  and  its  compounds,  Polyaromatic  hydrocarbons  (PAH),  Tributyltin,  

PFOS, dioxins, hexabromocyclodecane and heptachlor. 

74 

 
 
                                                      
deposition). In order to show the progress made in tackling other priority substances, Member 

States have the possibility to present the information related to chemical status separately for 
these substances.  

The influence of ubiquitous persistent, bioaccumulative, toxic Priority Substances on chemical 
status was assessed as limited in Croatia. Only 1 % of surface waterbodies would improve for 

failing good status to good status if these substances were not taken into account.  

This is illustrated in the 2018 State of Water report of the European Environment Agency. 38 

The  absence  of  monitoring  in  biota  may  partly  explain  the  limited  exceedances  found  for 
mercury. 

Priority substances used in the assessment of chemical status compared to those monitored 

According to WISE, in the Danube RBD, four groups of Priority Substances are not monitored 

and  not  used  in  the  assessment:  trifluralin;  tributyltin-cation;  chloroalkanes  C10-13,  and 
brominated diphenylethers (congener numbers 28, 47, 99, 100, 153 and 154). Croatia clarified 

that all other substances are used in the assessment of status and monitored. 

According  to  WISE,  in  the  Adriatic  RBD,  brominated  diphenylethers,  endosulfan  and 
tributyltin are monitored and used in the assessment in some water categories but not in others. 

Croatia subsequently clarified that in both the Adriatic RBD and the Danube RBD, brominated 
diphenylethers, chloroalkanes, tributyltin compounds and trifluralin are not monitored in rivers 

and lakes. 

Application of alternative environmental quality standards for water, biota and sediment  

According  to  the  EQS  Directive,  Member  States  may  opt  to  apply  environmental  quality 
standards for  another matrix than the one specified in  the Directive for a given substance.  If 

they do so, they have to ensure the environmental quality standard they set in the other matrix 
(or  matrices)  offers  at  least  the  same  level  of  protection  as  the  standard  established  in  the 

Directive. 

Croatia reported that all of the environmental quality standards laid down in Part A of Annex I 

of the Directive 2008/105/EC from the version in force on 13 January 2009 had been applied 

38   https://www.eea.europa.eu/publications/state-of-water  (p40-41  of  the  report).  Also  available  in  a  more  

interactive format at :  
https://tableau.discomap.eea.europa.eu/t/Wateronline/views/WISE_SOW_SWB_Chemical_Status_Maps/SW
B_Failing_Good_Chemical_Status_RBD?iframeSizedToWindow=true&:embed=y&:showAppBanner=false&
:display_count=no&:showVizHome=no 

75 

 
                                                      
with  the  exception  of  hexachlorobutadiene,  hexachlorobenzene  and  mercury  and  its 

compounds  in  both  RBDs.  The  information  reported  in  WISE  for  these  substances  is  not 
entirely  clear,  however,  Croatia  subsequently  confirmed  that  these  standards  used  actually 

correspond to the standard in water present in the EQS Directive. 

Use of mixing zones  

Article 4 of the EQS Directive provides Member States with the option of designating mixing 
zones adjacent to points of discharge in surface waters. Concentrations of priority substances 

may exceed the relevant environmental quality standard within such mixing zones if they do 
not affect the compliance of the rest of the surface water body with those standards. Member 

States that designate mixing zones are required to include within their RBMP a description of 
the  approaches  and  methodologies  applied  to  define  such  zones,  and  a  description  of  the 

measures taken to reduce the extent of the mixing zones in the future. 

Mixing zones have not been designated in Croatia. 

Background Concentrations and Bioavailability 

The  EQS  Directive  stipulates  that  Member  States  have  the  possibility,  when  assessing  the 
monitoring results against the environmental quality standard, to take into account: 

(a)  natural  background  concentrations  for  metals  and  their  compounds,  if  they  prevent 
compliance with the environmental quality standard, and; 

(b) hardness, pH or other water quality parameters that affect the bioavailability of metals. 

No  information  is  provided  for  Croatia  as  to  whether  natural  background  concentrations  for 

metals  and  their  compounds  are  taken  into  consideration  where  such  concentrations  prevent 
compliance with the relevant environmental quality standard. Also, no information is provided 

as to whether water quality parameters that affect the bioavailability of metals have been taken 
into  account  when  assessing  monitoring  results  against  relevant  environmental  quality 

standards. 

4.2  Main changes in implementation and compliance since the first RBMP 

Between the first and second RBMP, there was a net increase  in monitoring sites and surface 
water bodies monitored for operational purposes for chemical status assessment (an increase of 
76 sites and 43 water bodies) both  due to  a relatively large increase in  river monitoring.  For 
surveillance monitoring,  the number of sites has  increased by eight  and the number of water 

76 

 
bodies has decreased by 14 since the first RBMP. Croatia states in its RBMP that the number 

of  monitoring  sites  has  indeed  increased  as  well  as  the  number  of  monitored  Priority 
Substances.  It  is  also  stated in  the RBMP that more comprehensive and reliable database for 

the assessment of water status is being developed for the forthcoming cycle to develop a better 
understanding of the causes of exceedances and to better assess the effects of measures.  

According to the first RBMP, not all Priority Substances could be analysed since none of the 
approved laboratories were equipped for the determination of certain substances. 

Croatia states in  its second RBMP that the system  of surface water  chemical  assessment has 
been completely “normatively regulated” with the number of monitoring sites, indicators and 

monitoring frequencies increasing. It is reported that recently, Croatian Waters have introduced 
the "Monitoring Alignment Program (2016)" which is concerned with the improvement of all 

monitoring in the jurisdiction of Croatian Waters, including: (i) Monitoring of water status, (ii) 
Hydrological  and  meteorological  monitoring,  (iii)  Monitoring  of  water  pressures  and 

emissions,  (iv)  Monitoring  of  water  structures  (buildings),  and  (v)  Monitoring  established  in 
the  Strategic  Environmental  Assessment  Plans  for  water  management  documents.  The 
monitoring  program  is  the  basis  for  the  adoption  of  annual  monitoring  plans  and  water 

management plans established by the Water Law.  

The other main change is with regard to chemical status of surface water bodies. It should be 

noted that there has been a re-delineation of water bodies between the two cycles and therefore 
a  comparison  of  status  between  the  two  cycles  should  be  treated  with  some  caution  (the 

number of water bodies reported increased from 1315 in the first RBMP to 1572 in the second 
RBMP  and  it  appears  that  unknown  water  bodies  in  the  first  RBMP  were  categorised  as 

Heavily Modified in the second) where, between the two cycles, there has been a decrease in 
the proportion of surface water bodies in Croatia as a whole with  good  chemical  status.  The 

proportion of water bodies at good status has decreased from 97 % to 92 % and the proportion 
that failed to achieve good status has increased from 3 % to 8 %. 

4.3  Croatia provided no information on which substances resulted in an improvement 
of  water  bodies  from  failing  to  achieve  good  status  to  good  statusProgress with 
Commission recommendations 

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

  Recommendation:  Complete  the  development  of  methods  for  the  status  assessment  of 
water  bodies  and  determination  of  reference  conditions  and  apply  them  through  the 

77 

 
implementation 

of 

robust  monitoring 

programmes 

(start  monitoring 

hydromorphological parameters in lakes and transitional and coastal waters and fish 
in  lakes).  An  adequate  WFD  compliant  assessment  and  monitoring  framework  is  a 

necessary pre-requisite to design effective Programmes of Measures and ultimately to 
achieve the WFD objectives.  

Assessment: The monitoring programme for chemical status in Croatia covers up to 54 
%  of  monitoring  sites  across  all  surface  water  categories  (with  the  exception  of 

territorial waters). Monitoring covers all transitional and coastal water bodies but only 
up to 14 % of surface freshwaters (Overall about 10 % of water bodies are monitored 

for  chemical  status).  The  number  of  sites  and  waterbodies  monitored  for  chemical 
status  have  increased,  as  well  as  the  number  of  priority  substances  monitored,  which 

represents a significant  progress since the first RBMP. Grouping is used to assess the 
status of unmonitored waterbodies, but this is associated with a lower confidence in the 

assessment.   

Monitoring for status assessment in water is undertaken for up to 37 groups of Priority 
Substances.  All  discharged  substances  are  monitored,  in  accordance  with  the 

requirement of the Directive (however the inventories contain only six substances, so it 
is  not  entirely  clear  that  all  discharged  substances  have  been  fully  identified).  Four 

substances are still neither monitored nor used in the assessment of status. Monitoring 
is  undertaken  with  a  frequency  that  is  consistent  with  the  minimum  recommended 

frequency  for  surveillance,  but  not  for  operational,  monitoring,  and  no  explanation 
could  be  found  for  the  reduced  frequencies.  Mercury,  hexachlorobenzene  and 
hexachlorobutadiene  are  not  monitored  for  status  assessment  in  biota39  in  Croatia, 
which  is  expected  to  lead  to  the  underestimation  of  the  proportion  of  water  bodies 

failing to achieve good status. 

Croatia monitors some, but not all of the 14 required substances in sediment for trend 

assessment, at a frequency that is above the minimum recommended frequency.  

As  stated  in  Section  1.2,  the  RBMP  imply  that  a  more  comprehensive  and  reliable 

database  for  the  assessment  of  water  status  is  being  developed  for  the  forthcoming 
RBMP  to  develop  a  better  understanding  of  the  causes  of  exceedances  and  to  better 

assess the effects of measures. 

39   Croatia  subsequently  informed  that  the  implementation  of  a  project  “Development  of  the  methodology  for 
monitoring elements of chemical status in biota in terrestrial surface waters and implementation of preliminary 
monitoring” is close to finalisation. 

78 

 
                                                      
While some progress has been made with this recommendation, it is partially fulfilled. 

79 

 
 
 
Topic 5

  Monitoring, assessment and classification of quantitative 

status of groundwater bodies 

5.1  Assessment of implementation and compliance with WFD requirements 

in the second RBMP 

5.1.1 Monitoring of quantitative status in groundwater 

The total  number of groundwater bodies in  Croatia is  33 (Table 2.3). 11 groundwater bodies 

are  not  object  of  monitoring  for  quantitative  status  (Table  5.2).  This  means  that  33  %  of 
groundwater bodies are not monitored.  

The RBMP  and background documents indicate  that in  all river basin  districts grouping was 
applied.  Elements  considered  for  grouping  are  similar  geology,  hydrogeology,  stratigraphy, 

porosity  (inter-granular,  fracture,  fracture-cavernous),  geochemical  composition  (silicate, 
carbonate),  geological  forms  (caves,  pits,  sinks,  sinkhole  zones),  groundwater  directions  and 

flow  rates  (groundwater  tracing  analysis),  groundwater  feed  and  relation  with  surface  flows 
and finally also the groundwater body position within the river basins.  

The groundwater bodies cover 55,802 km² of the mainland territory and 11 larger islands with 

existing groundwater abstraction for public water supply purposes. There are  no groundwater 
bodies on other islands and islets. 

Table 5.1 

Proportion of groundwater bodies in Croatia monitored for quantitative status 

RBD  

HRC 

HRJ 

No of groundwater bodies with 
quantitative monitoring 

13 

9 

Total No. 
groundwater 
bodies 

20 

13 

% of total groundwater bodies 
monitored for quantitative status 

65 % 

69.23 % 

Source: WISE electronic reporting 

80 

 
Table 5.2 

Number of groundwater bodies in Croatia directly monitored and purpose of monitoring 

RBD  

Total 
groundwater 
bodies 
directly 
monitored 

AGR - 
Groundwater 
abstraction 
site for 
irrigation 

CHE – 
Chemical 
status 

DRI – 
Groundwater 
abstraction 
site for human 
consumption 

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

Monitoring Purpose 

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

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

QUA – 
Quantitat
-ive status 

SOE - 
EIONET 
State of 
Environ-
ment 
monitoring 

SUR – 
Surveillance 
monitoring 

TRE - 
Chemical 
trend 
assessment 

HRC 

HRJ 

16 

13 

2 (0) 

15 

13 

11 

11 

16 

11 

15 

13 

4 

2 

13 

9 

15 

8 

15 

13 

15 

13 

Source: WISE electronic reporting. The numbers in brackets were subsequently provided by Croatia and do not match the data reported to WISE. 

Table 5.3  Number of groundwater monitoring sites in Croatia and their purpose  

RBD  

Total 
groundwater 
monitoring 
sites 

AGR - 
Groundwater 
abstraction 
site for 
irrigation 

CHE – 
Chemical 
status 

DRI – 
Groundwater 
abstraction 
site for human 
consumption 

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

Monitoring Purpose 

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

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

QUA – 
Quantitat
-ive status 

SOE - 
EIONET 
State of 
Environ-
ment 
monitoring 

SUR – 
Surveillance 
monitoring 

TRE - 
Chemical 
trend 
assessment 

HRC 

HRJ 

351 

54 

232 (233) 

33 

250 

233 

2 

45 (47) 

35 (37) 

36 (37) 

45 (47) 

115 

11 

119 

24 

24 

8 

233 

46 (48) 

233 

45 (47) 

Source: WISE electronic reporting. The numbers in brackets were subsequently provided by Croatia and do not match the data reported to WISE. 

81 

 
 
 
 
 
The number of groundwater bodies increased slightly from 32 in the first RBMP to 33 in the 

second  RBMP  and  also  the  total  groundwater  body  area  increased  by  about  6  %.  29 
groundwater bodies remained unchanged since the first RBMP. 

The  total  number  of  monitored  groundwater  bodies  remained  the  same;  in  one  river  basin 
district  it  increased  by  two  and,  in  the  other  it  decreased  by  two.  The  total  number  of 

monitoring sites for quantitative status is listed in Table 5.3 and shows a slight decrease from 
144 in the first RBMP to 143 in the second RBMP. In the Danube RBD, the number of sites 

increased by 16 and in the Adriatic RBD the number of sites decreased by 17. 

30 of 33 groundwater bodies are identified as Drinking Water Protected Areas, located in both 

RBDs. 

5.1.2 Assessment and classification of quantitative status for groundwater 

Map  5.1  displays  the  most  recently  assessed  quantitative  status  of  groundwater  bodies.  It 
shows that 32 of 33 groundwater bodies (97 %) were in good quantitative status and one (3 %) 

is  failing  good  status  (Figure  5.1).  In  terms  of  area,  this  means  that  about  0.5  %  of  the  total 
groundwater body area is failing good quantitative status. 

Figure 5.2 shows the confidence in status classifications. In the second RBMP, all groundwater 

bodies  have  a  clear  status.  This  situation  has  improved  since  the  first  RBMPs  where  two 
groundwater bodies had unknown status. 

The total number of groundwater bodies failing good quantitative status decreased significantly 
from  three in  the  first  RBMP to  one in  the second RBMP (from 1.9 % to 0.5 % of the total 

groundwater  body  area).  The  RBMP  and  background  documents  give  no  reasons  for  this 
improvement.  

In  both  river  basin  districts  water  balance  was  assessed  by  a  comparison  of  annual  average 
groundwater  abstraction  against  the  ‘available  groundwater  resource’  for  every  groundwater 

body. 

The  reasons  for  the  failure  of  good  quantitative  status  of  groundwater  bodies  are  shown  in 

Figure 5.3. For the groundwater body that is failing good status, this is due to failing the water 
balance test, which means that the long-term annual average rate of groundwater abstraction is 

exceeding the available groundwater resource therefore causing saline intrusion. The expected 
date of achievement of good quantitative status in this groundwater body is unknown (Figure 

5.4).  

82 

 
Map 5.1 

Map of the most recently assessed quantitative status of groundwater bodies  

Note: Standard colours based on WFD Annex V, Article 2.2.4.  
Source: WISE, Eurostat (country borders) 

83 

GoodPoorUnknownRiver Basin DistrictsCountries outside the EU 
 
  
Figure 5.1  Quantitative  status  of  groundwater  bodies  in  Croatia  for  the  second  RBMP, 

for  the  first  RBMP  and  expected  in  2015.  The  number  in  parenthesis  is  the 
number  of  groundwater  bodies  for  both  cycles.  Note  the  period  of  the 

assessment of status for the second RBMP was 2008 to 2014. The year of the 
assessment of status for the first RBMP is not known 

Expected good status in
2015

Second plan (33)

97% 

97% 

First plan (32)

84% 

0%

20%

40%

60%

80%

100%

Good

Poor

Unknown

Not good

Source: WISE electronic reporting 

Figure 5.2  Confidence in the classification of quantitative status of groundwater bodies 

in Croatia based on the most recent assessment of status  

Source: WISE electronic reporting 

84 

 
 
 
Figure 5.3  Reasons for the failure of good quantitative status of groundwater in Croatia 

based on the most recent assessment of status  

Failing good quantitative status

Groundwater dependent terrestrial ecosystems

0,0% 

Saline or other intrusion

Surface water

0,0% 

Water balance

3,0% 

3,0% 

3,0% 

0,0%

1,0%

2,0%

3,0%

4,0%

Percentage of groundwater bodies 

Source: WISE electronic reporting 

Notes: 
‘Water balance’ = long-term annual average rate of abstraction exceeds the available groundwater resource which 
may result in a decrease of groundwater levels. 

‘Surface water’ = Failure to achieve Environmental Objectives (Article 4 WFD) for associated surface water 
bodies resulting from anthropogenic water level alteration or change in flow conditions; significant diminution of 
the status of surface waters resulting from anthropogenic water level alteration or change in flow conditions. 

‘Groundwater dependent terrestrial ecosystems’ = Significant damage to groundwater dependent terrestrial 
ecosystems resulting from an anthropogenic water level alteration. 

‘Saline or other intrusion’ = Regional saline or other intrusions resulting from anthropogenically induced 
sustained changes in flow direction. 

85 

 
 
 
Figure 5.4  Expected date of achievement of good quantitative and good chemical status 

of groundwater bodies in Croatia. 33 groundwater bodies were delineated for 
second RBMP 

Good quantitative status

32 

Good chemical status

30 

0%

20% 40% 60% 80% 100%

Percentage of groundwater bodies 

Source: WISE electronic reporting 

Less stringent objectives already
achieved

2015

2016--2021

2022--2027

Beyond 2027

Unknown

In  both  river  basin  districts,  the  criterion  of  ‘available  groundwater  resource’  has  been  fully 

applied  in  accordance  with  WFD  Article  2(27).  In  the  Danube  RBD,  all  environmental 
objectives have been considered in status assessment. In the Adriatic RBD, all environmental 
objectives except water balance have been considered in status assessment.40 

In total two groundwater bodies (6 %) (both in the Adriatic RBD) are at risk of failing good 

quantitative status. Both groundwater bodies are at risk of failing good quantitative status due 
to  failing  the  water  balance  test  and  one  also  due  to  saline  intrusion.  In  both  groundwater 

bodies, actual or potential legitimate uses or functions of groundwater are endangered. 

5.1.3 Consideration  of  groundwater  associated  surface  waters  and/or  groundwater 

dependent terrestrial ecosystems 

For  30  groundwater  bodies  groundwater  associated  surface  waters  have  been  reported.  They 

are  not  related  to  risk  and  they  have  been  considered  in  status  assessment  in  all  river  basin 
districts. 

In  total  17  groundwater  bodies  are  linked  to  groundwater  dependent  terrestrial  ecosystems. 
They  are  not  related  to  risk  and  they  have  been  considered  in  status  assessment  in  all  river 

basin districts. The needs of these ecosystems have not been considered in status assessment. 

40   Croatia subsequently clarified that water balance has actually been considered for all groundwater bodies. 

86 

 
 
                                                      
5.2  Main changes in implementation and compliance since the first RBMP 

The RBMP includes a chapter summarising the changes or updates for this topic. Compared to 
the first RBMP progress has been made in the assessment of groundwater quantitative status, 

as methodologies have been developed. One of the major changes was the analysis of surface 
water  status  associated  with  groundwater,  as  well  as  the  status  of  groundwater  dependent 

terrestrial ecosystems. The range of data for assessing the quantitative status of groundwater in 
the present plan has increased. However, due to inadequate availability of spatial and temporal 
data, the reliability of results is rather low. There are still areas which have limited monitoring. 

The number of groundwater bodies increased slightly, from 32 in the first RBMP to 33 in the 
second  RBMP  and  the  total  groundwater  body  area  also  increased  by  about  6  %.  29 

groundwater bodies remained unchanged since the first RBMP. 

The monitoring situation remained unchanged. 

The  status  situation  has  improved.  The  total  number  of  groundwater  bodies  failing  good 
quantitative status  decreased significantly  from  three in the first  RBMP to  one in  the second 

RBMP (from 1.9 % to 0.5 % of the total groundwater body area). The RBMP and supporting 
background documents did not give reasons for this improvement.  

5.3  Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  cycle  RBMP  and  Programme  of 

Measures requested action on the following: 

  Recommendation:  Make  improvements  to  groundwater  monitoring,  investigate  and 

address reasons for saline intrusions. 

Assessment: The total number of monitoring sites was slightly reduced by one site to 

143, with an increase of 16 sites in the Danube RBD and a decrease of 17 sites in the 
Adriatic  RBD.  Still  11  groundwater  bodies  (33  %)  are  without  quantitative 

monitoring.  In  the  second  cycle  both  associated  surface  waters  and  groundwater 
dependent  terrestrial  ecosystems  are  considered.  This  recommendation  is  partially 

fulfilled. 

87 

 
 
 
Topic 6

  Monitoring,  assessment  and  classification  of  chemical 

status of groundwater bodies 

6.1  Assessment of implementation and compliance with WFD requirements 

in the second RBMP 

6.1.1 Monitoring of chemical status in groundwater 

The total number of groundwater bodies in Croatia is 33 (Table 2.3). In total, five groundwater 

bodies (15 %) are not object of surveillance monitoring (Table 5.2) and there is no operational 
monitoring, although five groundwater bodies are reported at risk.  

The RBMP and supporting background documents indicates that in both RBDs grouping was 
applied.  Elements  considered  for  grouping  are  similar  geology,  hydrogeology,  stratigraphy, 

porosity  (inter-granular,  fracture,  fracture-cavernous),  geochemical  composition  (silicate, 
carbonate),  geological  forms  (caves,  pits,  sinks,  sinkhole  zones),  groundwater  directions  and 

flow  rates  (groundwater  tracing  analysis),  groundwater  feed  and  relation  with  surface  flows 
and,  finally  also,  the  groundwater  body  position  within  the  river  basins.  The  groundwater 
bodies  cover  55,082  km²  of  the  mainland  territory  and  11  larger  islands  with  existing 

groundwater abstraction for public water supply purposes. There are no groundwater bodies on 
other islands and islets. 

The number of groundwater bodies increased slightly from 32 in the first RBMP to 33 in the 
second  RBMP  and  also  the  total  groundwater  body  area  increased  by  about  6  %.  29 

groundwater bodies remained unchanged since the first RBMP. 

The number of groundwater bodies with surveillance monitoring increased from 26 in the first 
RBMP to 28 in the second RBMP.41 The number of monitoring sites is listed in Table 5.3 and 
shows that the number of surveillance monitoring sites has increased slightly, from 264 in the 

first RBMP to 279 in the second RBMP. There is still no operational monitoring; this was not 
reported in the first RBMP nor in the second RBMP.42 

All  substances  at  risk  of  causing  deterioration  in  chemical  status  are  subject  to  surveillance 
monitoring. The second RBMP and supporting background documents provide indications that 

at least all substances causing risk and all Annex I and Annex II substances are considered in 
the operational monitoring programme, but operational monitoring sites were still not reported.  

41   Croatia subsequently stated that all 33 groundwater bodies are covered by surveillance monitoring. 
42   Croatia subsequently clarified that the establishment of 65 operational monitoring stations started in 2015. As 
the  available  data  from  this  monitoring  is  very  limited  and  was  not  used  for  the  preparation  of  the  current 
RBMP, these stations were not reported yet. 

88 

 
                                                      
All  WFD  core  parameters  (nitrate,  ammonium,  electrical  conductivity,  oxygen  and  pH)  are 

monitored. 

6.1.2 Assessment and classification of chemical status in groundwater 

Map  6.1  and  Figure  6.1  show  the  most  recently  assessed  chemical  status  of  groundwater 
bodies. It shows that 30 of 33 groundwater bodies (91 %) were in  good chemical status, and 

the remaining three groundwater bodies (9 %) were failing good status. In terms of area, this 
means  that  about  1.5  %  of  the  total  groundwater  body  area  is  failing  good  chemical  status. 

Figure 6.2 shows the confidence in status classifications. All groundwater bodies had, and still 
have, a clear status, in the first and in the second RBMP.  

The  total  number  of  groundwater  bodies  failing  good  status  decreased  since  the  first  RBMP 
from  four  (12  %)  to  three  (9  %)  (see  Figure  6.1).  In  terms  of  groundwater  body  area,  the 

percentage of groundwater bodies in poor status decreased from 2.6 % in the first RBMP to 1.5 
% in the second RBMP. The expected date of achievement of good chemical status in Croatia 

is shown in Figure 5.4. The RBMP and background documents state that the improvement of 
status is due to changes in the pressure situation but also due to implemented measures being 
effective. Changes in the groundwater status only refer to nitrates, because in the first RBMP 

pesticides and other substances were not monitored and not assessed. In the first RBMP, poor 
chemical  status  (for  nitrates)  was  established  in  the  areas  of  Varaždin,  Zagreb  and  Southern 

Istria, while in the second RBMP this is the case in the Varaždin area and in Eastern Slavonia - 
the Drava and Danube basin.43 This could suggest  an improvement in nitrate pollution in the 
area  of  the  group  of  groundwater  bodies  of  Zagreb,  but  a  deterioration  of  the  situation  in 
Eastern  Slavonia  -  the  Drava  and  Danube  basin.  As  stated  in  the  current  RBMP,  monitoring 

will now include at least all substances listed in the Groundwater Directive Annex II Part B. 

The reasons for the failure of good chemical status of groundwater bodies are shown in Figure 

6.3.  For  two  groundwater  bodies,  the  general  assessment  of  the  chemical  status  for  the 
groundwater  body  as  a  whole  was  failed.  This  assessment  considers  the  significant 

environmental risk from pollutants across a groundwater body and a significant impairment of 
the ability to support human uses. One groundwater body is failing good chemical status due to 

saline or other intrusion. Figure 6.4 shows the pollutants causing failure of status.  

In both RBDs, the calculation of the extent of exceedance is based on the groundwater body 

area.  In both  RBDs,  groundwater threshold values have been established for all pollutants or 
indicators of pollution causing a risk of failure of good chemical status and natural background 

43   Croatia subsequently indicated that this is also true for Southern Istria. 

89 

 
                                                      
levels,  as  well  as  all  Annex  II  substances,  have  been  considered  in  the  establishment  of 

groundwater threshold values.  

A  trend  assessment  methodology,  as  well  as  a  trend  reversal  methodology,  is  available  and 

assessments have been performed in both RBDs. 

Map 6.1  Map  of  the  most  recently  assessed  chemical  status  of  groundwater  bodies  in 

Croatia  

Note: Standard colours based on WFD Annex V, Article 2.4.5. 

Source: WISE, Eurostat (country borders) 

90 

GoodPoorUnknownRiver Basin DistrictsCountries outside the EU 
 
 
 
 
 
Figure 6.1 

Chemical  status  of  groundwater  bodies  in  Croatia  for  the  second  RBMP, 

for the first RBMP and expected in 2015. The number in the parenthesis is 
the number  of groundwater bodies for both cycles. Note the period  of the 

assessment of status for the second RBMP was 2009 to 2013. The year of 
the assessment of status for the first RBMP is not known  

Expected good status in 2015

Second plan (33)

First plan (32)

91% 

91% 

88% 

0%

20%

40%

60%

80%

100%

Percentage of groundwater bodies 

Good

Poor

Unknown

Not good

Source: WISE electronic reporting  

Figure 6.2 

Confidence in the classification of chemical status of groundwater  bodies 

in Croatia based on the most recent assessment of status  

i

s
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t
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P

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

No information

High

Medium

Low

Good

Poor

Unknown

Chemical status of groundwater bodies 

Source: WISE electronic reporting 

91 

 
 
 
 
 
 
 
Figure 6.3 

Reasons  for  failing  good  chemical  status  in  Croatia  for  the  most  recent 

assessment of status  

Failing good chemical status

9% 

Surface water

0% 

Saline or other intrusion

3% 

Groundwater dependent terrestrial ecosystems

0% 

General water quality assessment

6% 

Drinking Water Protected Area

0% 

0%

2%

4%

6%

8%

10%

Percentage of groundwater bodies 

Source: WISE electronic reporting  

Notes: 
‘Surface water’ = Failure to achieve Environmental Objectives (Article 4 WFD) in associated surface water 
bodies or significant diminution of the ecological or chemical status of such surface water bodies. 

‘Groundwater dependent terrestrial ecosystems’ = Significant damage to terrestrial ecosystems which depend 
directly on the groundwater body. 

‘Saline or other intrusion’ = Regional saline or other intrusions resulting from anthropogenically induced 
sustained changes in flow direction. 

‘Drinking Water Protected Area’ = Deterioration in quality of waters for human consumption. 

‘General water quality assessment’ = Significant impairment of human uses; significant environmental risk from 
pollutants across the groundwater body. 

92 

 
 
 
Figure 6.4 

Top  groundwater  pollutants  causing  failure  of  good  chemical  status  in 

Croatia 

Source: WISE electronic reporting  

Note: only two pollutants reported as causing failure. 

6.1.3 Consideration  of  groundwater  associated  surface  waters  and/  or  groundwater 

dependent terrestrial ecosystems 

For  30  groundwater  bodies,  groundwater  associated  surface  waters  have  been  reported. 
Groundwater  associated  surface  waters  have  not  been  reported  as  being  considered  in  status 

assessment. 

In total, 17 groundwater bodies are linked with groundwater dependent terrestrial ecosystems. 

Groundwater dependent terrestrial ecosystems have not been considered in status assessment in 
both RBDs.44 

Groundwater associated aquatic ecosystems and groundwater dependent terrestrial ecosystems 
have been considered in the establishment of groundwater threshold values. 

Figure 6.5 shows the percentage of groundwater bodies at risk of failing good chemical status 

and good quantitative status.  

44   Croatia  subsequently clarified that groundwater associated  surface  waters as  well as  groundwater dependent 

terrestrial ecosystems have been considered in status assessment in both RBDs.  

93 

 
 
 
                                                      
Figure 6.5  Percentage of groundwater bodies in Croatia at risk of failing good chemical 

status and good quantitative status for the second RBMP 

i

s
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100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

15% 

Chemical

6% 

Quantitative

Source: WISE electronic reporting 

6.2  Main changes in implementation and compliance since the first RBMP 

Each RBMP consists of a dedicated chapter summarising the changes or updates for this topic. 

Compared  to  the  first  RBMP,  progress  has  been  made  in  the  assessment  of  groundwater 
chemical  status.  Methodologies  have  been  developed.  One  of  the  major  changes  was  the 

analysis  of  surface  water  status  associated  with  groundwater,  as  well  as  the  status  of 
groundwater  dependent  terrestrial  ecosystems.  The  range  of  data  for  assessing  the  chemical 

status  of  groundwater  in  the  second  RBMP  has  increased;  however,  due  to  still  inadequate 
spatial and temporal availability of data, the reliability of results is rather low. 

The number of groundwater bodies increased slightly, from 32 in the first RBMP to 33 in the 
second  RBMP  and  the  total  groundwater  body  area  also  increased  by  about  6  %.  29 

groundwater bodies remained unchanged since the first RBMP. 

The  monitoring  improved  slightly  but  operational  monitoring  was  still  not  in  place  and 

surveillance monitoring was not complete. All WFD core parameters are subject to monitoring. 

Croatia  subsequently  clarified  that  all  groundwater  bodies  are  now  covered  by  surveillance 

monitoring and operational monitoring sites were put in place in the meantime.   

The  status  situation  improved  as  the  number  of  groundwater  bodies  in  poor  status  decreased 

from  four to  three.  The RBMP and background documents explain that the improvement of 

94 

 
 
 
 
 
 
status  is  due  to  changes  in  the  pressure  situation  but  also  to  implemented  measures  being 

effective.  The  status  assessment  of  the  first  RBMP  just  focussed  on  nitrates,  while  in  the 
second RBMP other substances were included. No trend assessment is reported to be applied. 

However, Croatia stated that a study on trend assessment has been published in 2016.  

6.3  Progress with Commission recommendations 

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

  Recommendation:  Make  improvements  to  groundwater  monitoring,  investigate  and 

address reasons for saline intrusions. 

Assessment: Operational monitoring was still not fully in place and not being used for 
the  second  RBMP.  The  number  of  groundwater  bodies  covered  by  surveillance 

monitoring increased slightly from 26 groundwater bodies in the first RBMP to 28 in 
the second RBMP. There is still no consideration of groundwater dependent terrestrial 

ecosystems  in  status  assessment,  although  there  is  one  groundwater  body  where 
damage of such ecosystems is causing risk of failing the environmental objectives.  

  Croatia  subsequently  clarified  that  that  operational  monitoring  sites  have  been 
established  in  2015,  that  associated  surface  waters  and  groundwater  dependent 

terrestrial ecosystems have both been considered in status assessment in both RBDs. 

Therefore this recommendation is partially fulfilled. 

95 

 
 
 
Topic 7

  Designation  of  Heavily  Modified  and  Artificial  Water 

Bodies and definition of Good Ecological Potential 

7.1  Assessment of implementation and compliance with WFD requirements 

in the second RBMP for designation  

7.1.1 Designation of Heavily Modified and Artificial Water Bodies 

In  the  second  RBMP,  135  heavily  modified  water  bodies  have  been  designated  in  the  two 
RBDs.  Artificial  water  bodies  are  identified  in  both  RBDs  (Figure  7.1).  12  heavily  modified 
water  bodies  are  reservoirs  and  were  originally  rivers.  These  are  designated  as  river  heavily 

modified water bodies. 

Figure 7.1 

Proportion of total water bodies in each category in Croatia that has been 

designated as heavily modified or artificial  

Second RBMP

Coastal

Transitional

Lakes

Rivers

First RBMP

Coastal

Transitional

Lakes

Rivers

0% 

0% 

4% 

0% 

0% 

7% 

76% 

69% 

Heavily Modified

Artificial

0%

20%

40%

60%

80%

100%

% of water bodies 

Source: WISE electronic reporting 

The main water uses for which river water bodies are designated as heavily modified are flood 

protection,  agriculture-land  drainage  and  navigation.  For  a  considerable  number  of  river 
heavily modified water bodies (76), the use for designation is not specified in WISE (“other”). 

For some river heavily modified water bodies (20), hydropower is the main water use. For the  

Four  coastal  heavily  modified  water  bodies,  navigation  and  urban  development  are  the  main 

uses.  For  the  transitional  heavily  modified  water  body,  wider  environment  and  urban 
development are the main uses linked to designation, followed by agricultural land drainage.  

96 

 
 
The  main  physical  alterations  of  river  heavily  modified  water  bodies  are  channelisation, 

straightening, bed stabilisation, bank reinforcement and weirs, dams, reservoirs. For the coastal 
heavily modified water bodies, the main alterations are land reclamation, coastal modifications, 

ports. For the transitional heavily modified water body, the main alterations are channelisation, 
straightening, bed stabilisation, bank reinforcement and land reclamation, coastal modifications 

and ports. 

In general, the information provided on artificial water body and heavily modified water bodies 

does not describe the methodology used and is of a general nature. The RBMP and background 
documents  available  do  not  give  any  detailed  information  on  criteria  to  define  substantial 

changes in character due to physical modifications. As part of the pressure and impact analysis, 
the  RBMP  describes  that  the  impact  of  physical  interventions  is  estimated  by  means  of  a 

numerical  model  based  on  recorded  hydromorphological  pressures  and  expert  judgement 
regarding the impact of an individual pressure on hydromorphological indicators. Concerning 

the designation process of heavily modified water bodies, no information is provided on how 
the  significant  adverse  effects  of  restoration  measures  on  the  use  and  the  wider  environment 
have  been  defined  or  how  other  means  to  achieve  the  beneficial  objectives  served  by  the 

modifications of the heavily modified water bodies have been assessed. 

7.1.2 Definition of Good Ecological  Potential for Heavily Modified  and Artificial  Water 

Bodies 

Good ecological potential is reported as not defined. There are ongoing projects to develop a 

good ecological potential methodology. Croatia will build a methodology for the evaluation of 
good ecological potential, in accordance with the WFD and relevant Common Implementation 

Strategy Guidance, including the identification of mitigation measures for each water body. 

For  rivers,  one  methodology  is  reported  to  assess  benthic  invertebrates  and  fish,  which  is 

sensitive  to  altered  habitats  due  to  hydrological  and  morphological  changes.  The  same 
methodology is reported to assess fish in lakes. For coastal waters, two methods are reported as 

sensitive to hydrological and morphological changes for macroalgae and benthic invertebrates. 
For transitional waters, one method is reported as sensitive to hydrological and morphological 
changes for macrophytes.45 

45   Croatian authorities have reported that activities on the establishment of a higher quality connection between 

biological and hydromorphological elements of ecological status of waters are ongoing. 

97 

 
                                                      
7.2  Main changes in implementation and compliance since the first RBMP 

The  first  RBMP  covered  the  period  2013-2015  and  did  not  include  the  number  of  finally 
designated  heavily  modified  water  bodies;  it  only  made  suggestions  for  the  selection  of 
candidate  heavily  modified  water  bodies.  However,  in  the  second  RBMP,  there  is  still 
reference  to  candidate  artificial  water  bodies  and  heavily  modified  water  bodies,  which 

suggests  that  designations  are  not  yet  verified.  Furthermore,  the  RBMP  indicates  that  future 
monitoring will further determine artificial water bodies and heavily modified water bodies. 

In  the  Danube  RBD,  there  are  in  the  second  RBMP  six  more  lake  water  bodies  and  20  less 

river water bodies designated as artificial, compared to the first cycle RBMP. In the  Adriatic 
RBD, there are two additional river artificial water body designations. 

7.3  Progress with Commission recommendations 

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

requested action on the following: 

  Recommendation: Ensure the appropriate designation of heavily modified water bodies 
and  develop  a  methodology  for  establishing  good  ecological  potential.  These 
methodologies should be documented in the RBMPs.  

Assessment: The information provided on artificial water bodies and heavily modified 
water  bodies  does  not  describe  the  methodology  used  and  is  of  a  general  nature.  The 

RBMP  and  background  documents  available  do  not  give  any  detailed  information  on 
criteria  to  define  substantial  changes  in  character  due  to  physical  modifications,  nor 

ways  to  assess  significant  adverse  effects  of  restoration  measures  and  other  means  to 
achieve  the  beneficial  objectives  of  the  heavily  modified  water  bodies.  It  seems  that 

heavily  modified  water  bodies  and  artificial  water  bodies  are  still  identified  as 
candidates while further methodological development and verifications via monitoring 

are  pending.  In  addition,  no  methodology  is  yet  established  for  defining  good 
ecological potential. Therefore, this recommendation has not been fulfilled yet. 

98 

 
 
Topic 8

  Environmental objectives and exemptions 

8.1  Assessment of implementation and compliance with WFD requirements 

in the second RBMP 

8.1.1 Environmental objectives 

The  environmental  objectives  are  defined  in  Article  4  of  the  WFD.  The  aim  is  long-term 
sustainable water management based on a high level of protection of the aquatic environment. 

Article 4(1) defines the WFD general objective to be achieved in all surface and groundwater 
bodies,  i.e.  good  status  by  2015.  Within  that  general  objective,  specific  environmental 

objectives are defined for heavily modified water bodies (good ecological potential and good 
chemical status by 201546), groundwaters (good chemical and quantitative status by 2015), and 
for Protected Areas (achievement of the objectives of the associated Directive by 2015 unless 
otherwise specified).  

Environmental  objectives  for  ecological  and  chemical  status  of  surface  water  and  for 
qualitative  and  quantitative  status  in  groundwater  have  been  reported  in  all  RBD  and  are 

defined on water body level, but there are remaining unknowns. 

Member States are also required to specify additional environmental objectives and standards 

in  Protected  Areas  where  these  are  required  to  ensure  the  requirements  of  the  associated 
Directive  are  met.  An  assessment  of  such  additional  objectives  for  Croatia  is  provided  in 

Chapter 15 of this report. 

Assessments  of the current  status  of surface and groundwater bodies in  Croatia are provided 

elsewhere in this report: for ecological status/potential of surface waters (Chapter 3); chemical 
status  of  surface  waters  (Chapter  4);  quantitative  status  of  groundwater  bodies  (Chapter  5); 

chemical status of  groundwater bodies (Chapter 6); status of surface and groundwater bodies 
associated with Protected Areas (Chapter 15). 

For the second RBMP, Member States are required to report the date when they expect each 
surface  and  groundwater  body  to  meet  its  environmental  objective.  This  information  is 
summarised  for  Croatia  elsewhere  in  this  report:  for  ecological  status/potential  of  surface 

waters  (Chapter  3);  chemical  status  of  surface  waters  (Chapter  4);  quantitative  status  of 
groundwater bodies (Chapter 5); chemical status of groundwater bodies (Chapter 6).  

46 For priority substances newly introduced by Directive 2013/39/EU, good status should be reached by 2027, and 
for  the  2008  priority  substances,  for  which  the  Environmental  Quality  Standards  were  revised  by  Directive 
2013/39/EU, good status should be reached in 2021. 

99 

 
                                                      
8.1.2 Exemptions 

Where  environmental  objectives  are  not  yet  achieved  exemptions  can  be  applied  in  case  the 
respective conditions are met and the required justifications are explained in the RBMP. Figure 

8.1 summarises the percentage of water bodies expected to be at least in good status in 2015 
and  the  use  of  at  least  one  exemption  in  Croatia  for  the  four  main  sets  of  environmental 

objectives. 

Figure 8.1 

Water bodies in Croatia expected to be in at least good status in 2015 and 

use of exemptions. 1 = Surface water body ecological status/potential; 2 = 
Surface  water  body  chemical  status;  3  =  Groundwater  body  quantitative 

status; 4 = Groundwater body chemical status  

Source: WISE electronic reporting. For some water bodies the date for achievement of good status is unknown. 

Article  4  of  the  WFD  allows  under  certain  conditions  for  different  exemptions  to  the 

objectives:  extension  of  deadlines  beyond  2015,  less  stringent  objectives,  a  temporary 
deterioration,  or  deterioration  /  non-achievement  of  good  status  /  potential  due  to  new 

modifications, provided a set of conditions are fulfilled. The exemptions under WFD Article 4 
include the provisions in Article 4(4)  - extension of deadline, Article 4(5) - lower objectives, 

Article 4(6) - temporary deterioration, and Article 4(7) - new modifications / new sustainable 
human  development  activities.  Article  4(4)  exemptions  may  be  justified  by:  disproportionate 

100 

 
 
cost,  technical  feasibility  or  natural  conditions,  and  Article  4(5)  by  disproportionate  cost  or 

technical feasibility. 

Figure 8.2 summarises the percentage of water bodies subject to each type of exemption (and 

reason) in relation to the four types of environmental objective in Croatia. 

Figure 8.2 

Type  of  exemptions  applied  to  surface  water  and  groundwater  bodies  for 

the  second  RBMP  in  Croatia.  Note:  Ecological  status  and  groundwater 
quantitative  status  exemptions  are  reported  at  the  water  body  level. 

Chemical  exemptions  for  groundwater  are  reported  at  the  level  of  each 
pollutant  causing  failure  of  good  chemical  status,  and  for  surface  waters 

for each Priority Substances that is causing failure of good chemical status  

101 

 
 
Source: WISE electronic reporting 

Application of Article 4(4) 

In the first cycle no exemptions were reported to WISE. In the second cycle, Article 4(4) was 

applied to surface water and groundwater. The justifications for surface water and groundwater 
in  relation  to  Article  4(4)  refer  to  technical  feasibility,  disproportionate  costs  and  natural 

conditions.  Disproportionate  costs  are  justified  in  groundwater  by  affordability  and  a  cost-
benefit analysis and in surface water by affordability and distribution of costs.  

For several surface water bodies in both RBDs, the pressure and impact analysis has identified 
to 
that 

to  achieve  good  ecological  status  due 

is  a  possibility  of  failing 

there 

hydromorphological elements. For these, an exemption under Article 4(4) has been indicated, 
but the justification has not been further defined. The required analyses could not be performed 

since  the  relevant  data  was  missing;  this  concerns  primarily  data  related  to  incomplete 
biological  and  hydromorphological  monitoring  and  an  undeveloped  ecological  potential 
classification system47. 

The main impacts relating to exemptions for surface water are organic, chemical and nutrient 

pollution  and  altered  habitats  due  to  hydromorphological  changes.  In  groundwater,  the  main 
impacts  relating  to  the  exemptions  are  nutrient  pollution  and,  in  the  Adriatic  RBD,  lowered 

water tables and saline pollution/intrusion. The main pressures to surface water come from  a 
broad  range  of  activities  including  urbanisation,  industry,  transport,  agriculture,  aquaculture 

and activities causing changes in hydromorphology. For groundwater, the main pressures are 
abstraction for public water supply and agriculture as well diffuse pollution by agriculture. The 
main drivers behind these are, in the case of groundwater, in all RBDs agriculture and urban 

development, and, in the Adriatic RBD, also climate change and tourism. The main drivers for 
pressures  in  surface  water  are  urban  development,  transport,  industry,  flood  protection, 

fisheries and aquaculture, hydropower and agriculture. 

Table 8.1 shows the pressures responsible for Priority Substances in Croatia failing to achieve 

good chemical status for surface water bodies where exemptions have been applied. Table 8.2 
shows  the  pressures  responsible  for  Priority  Substances  in  Croatia  failing  to  achieve  good 

chemical status for groundwater bodies where exemptions have been applied.  

47   Croatia subsequently clarified that the relevant procedure will be conducted and status of water bodies will be 

clarified in the third RBMP. 

102 

 
 
 
                                                      
Table 8.1 

Pressure  responsible  for  Priority  Substances  in  Croatia  failing  to  achieve 

good chemical status and for which exemptions have been applied 

Significant pressure on surface water bodies 

1.1 - Point - Urban waste water 

1.5 - Point - Contaminated sites or abandoned 
industrial sites 

2.1 - Diffuse - Urban run-off 

2.10 - Diffuse - Other 

2.2 - Diffuse - Agricultural 

2.4 - Diffuse - Transport 

2.6 - Diffuse - Discharges not connected to 
sewerage network 

2.7 - Diffuse - Atmospheric deposition 

2.9 - Diffuse - Aquaculture 

Failing 
Priority 
Substances 

Number 

5 

1 

3 

1 

4 

8 

6 

1 

2 

Article 4(4) - 
Technical feasibility 
exemptions 

Article 4(4) – 
Disproportionate 
cost exemptions 

Number 
81(83)48 

Number 
81(83)  

1 

6 

1 

8 

121 

241 

1 

2 

1 

6 

1 

8 

121 

241 

1 

2 

Source: WISE electronic reporting 

Table 8.2 

Pressure  responsible  for  pollutants  in  Croatia  failing  to  achieve  good 

chemical  status  in  groundwater  and  for  which  exemptions  have  been 
applied  

Significant pressure on 
groundwater 

Number of 
failing 
pollutants 

Number of exemptions 

Article 4(4) – 
Disproportionate 
cost 

Article 4(4) - 
Natural 
conditions 

Article 4(4) - 
Technical 
feasibility 

2.2 - Diffuse - Agricultural 

3.1 - Abstraction or flow diversion - 
Agriculture 

3.2 - Abstraction or flow diversion - 
Public water supply 

1 

1 

2 

2 

2 

2 

1 

1 

1 

Source: WISE electronic reporting 

Application of Article 4(5) 

Article 4(5) was not applied. 

Application of Article 4(6) 

No exemptions according to Article 4(6) have been applied.  

48   Croatia subsequently clarified that there are 83 exemptions associated with pressures from point discharges of 

urban waste water. The corrected data are in brackets in this table. 

103 

 
 
 
 
                                                      
Application of Article 4(7) 

No  exemptions  according  to  Article  4(7)  have  been  applied,  although  the  2015  Commission 
Staff Working Document49 indicated that new hydropower projects were under consideration50. 

Application of Article 6(3) of the Groundwater Directive 

No exemptions according to Article 6(3) of the Groundwater Directive51 have been applied. 

8.2  Main changes in implementation and compliance since the first RBMP 

In the first cycle, no exemptions were reported to WISE. In the second cycle, Article 4(4) was 
applied to surface water and groundwater. Article 4(5), Article 4(6) and Article 4(7) were not 

applied in the second cycle. 

8.3  Progress with Commission recommendations 

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

  Recommendation:  Justify  adequately  new  hydromorphological  modifications,  such  as 
navigation projects or new hydropower plants. They should be supported by a proper 
strategic  assessment  of  cumulative  effects,  an  assessment  of  alternative  options,  and 
include all necessary mitigation measures. 

Article  4(7)  has  not  been  applied  in  the  second  cycle  in  Croatia.  Therefore  the 
fulfilment of this recommendation cannot be assessed. 

  Recommendation: Exemptions should be adequately justified at water body level.  

49   http://ec.europa.eu/environment/water/water-framework/pdf/4th_report/MS%20annex%20-%20Croatia.pdf  
50  Croatia  subsequently  clarified  that  since  the  requirement  for  the  implementation  of  Article  4.7  is  prescribed 
under the Water Act, there was no need to specifically emphasize the obligation to implement Article 4.7 for 
each individual facility whose construction is planned under each individual sectoral or physical strategy in the 
RBMP.  The  practice  requires  that,  under  the  SEA  procedure  for  the  Plan’s  environmental  impact  the 
procedure of the assessment of a project’s impact on the status of the environment (water) must be performed. 
If  the  objectives  for  aquatic  environment  cannot  be  achieved,  the  procedure  of  determining  the  overriding 
public  interest  must  be  carried  out.  It  is  further  stated  that  no  preparation  of  any  Feasibility  Study  or 
Environmental  Impact  Assessment  Study  has  been  initiated  to  date  for  any  hydropower  facility,  and  that, 
considering the proscribed length of such procedure, it is estimated that there is no realistic possibility that a 
start of the construction of such facility can be expected in the period until 2021. 

51   Directive 2006/118/EC of the European Parliament and of the Council of 12 December 2006 on the protection 
http://eur-lex.europa.eu/legal-

deterioration 

and 

groundwater 

of 
content/EN/TXT/?uri=CELEX:02006L0118-20140711 

pollution 

against 

104 

 
                                                      
Assessment:  Environmental  objectives  for  ecological  and  chemical  status  of  surface 

water and for qualitative and quantitative status in groundwater have been reported in 
all RBD and are defined on water body level, but there are remaining unknowns. 

  Recommendation:  Establish  an  improved  and  harmonised  approach  to  exemptions  in 
the  second  RBMP.  The  methodology  should  include  calculations  of  disproportionate 

costs, assessment methods for adverse effects and better environmental options.  

Assessment: Several exemptions under WFD Article 4(4) have been indicated, but the 

justification has not been further defined. The required analyses could not be performed 
since the relevant data was missing, primarily data related to incomplete biological and 

hydromorphological monitoring and an undeveloped ecological potential classification 
system. This recommendation has not yet been fulfilled 

  Recommendation: Croatia should set additional objectives for protected areas, monitor 
them  and  assess  what  additional  measures  are  required  to  achieve  those  additional 

objectives (Species and Habitats, Drinking Water, Bathing Water). 

Assessment: Please see Chapter 15 for the assessment of this recommendation. 

105 

 
 
 
Topic 9

  Programme of measures 

The aim of this chapter is to provide an overview of the Programme of Measures reported by 

Member  States;  more  specific  information  on  measures  relating  to  specific  pressures  (for 
example arising from agriculture) is provided in subsequent chapters. 

The  Key  Types  of  Measure  (KTM)  referred  to  in  this  section  are  groups  of  measures 
identified  by  Member  States  in  the  Programme  of  Measures,  which  target  the  same 

pressure  or  purpose.  The  individual  measures  included  in  the  Programme  of  Measure 
(being  part  of  the  RBMP)  are  grouped  into  Key  Types  of  Measure  for  the  purpose  of 

reporting.  The  same  individual  measure  can  be  part  of  more  than  one  Key  Types  of 
Measure because it may be multi-purpose, but also because the Key Types of Measure 

are  not  completely  independent  silos.  Key  Types  of  Measure  have  been  introduced  to 
simplify  the  reporting  of  measures  and  to  reduce  the  very  large  number  of 

Supplementary Measures reported by some Member States (WFD Reporting Guidance 
2016).  

A Key Types of Measure may be one national measure but it would typically comprise 
more than one national measure. The 25 predefined Key Types of Measure are listed in 

the WFD Reporting Guidance 2016. 

The Key  Types  of Measure should be fully implemented and made operational  within 
the  RBMP  planning  period  to  address  specific  pressures  or  chemical  substances  and 

achieve the environmental objectives. 

9.1  Assessment of implementation and compliance with WFD requirements 

in the second RBMP 

9.1.1 General issues 

An  indication  as  to  whether  or  not  measures  have  been  fully  implemented  and  made 
operational is when they have been reported as being planned to tackle significant pressures (at 

the  Key  Types  of  Measure  level).  Significant  pressures  are  also  reported  at  the  water  body 
level.  It  would  therefore  be  expected  that  there  would  be  measures  planned  in  the  RBMP  to 

tackle all significant pressures. With a few exceptions, most of the significant pressures in both 
RBDs  are  covered  by  KTMs,  indicating  that  these  are  operational.  For  the  Danube  RBD, 

KTMs have been reported for all significant pressures in groundwater, and for, all significant 

106 

 
 
 
pressures on surface water except ‘Anthropogenic – unknown’. For the Adriatic RBD, there is 

no KTM for diffuse pollution from agriculture in groundwater, whilst for surface waters, a few 
pressures are not covered by KTMs including point and diffuse pressures from contaminated 

sites,  diffuse  pressures 
run-off,  atmospheric  deposition  and  others, 
hydromorphological alterations - physical loss of part or all of water body hydromorphological 

from  urban 

alterations  -  others,  anthropogenic  pressures  -  unknown  and  anthropogenic  pressures  - 
historical.  

Croatia  has  mapped  589  national  basic  measures  against  22  pre-defined  KTMs  and  two 
national  KTMs.  The  two  national  KTMs  have  only  been  reported  as  KTM991  and  KTM992 

but these titles provide no details of the actual measures they represent - 22 % of the national 
basic measures have been mapped against KTM992 and 9 % against KTM991. A further 9 % 

have  been  mapped  against  KTM6  –  “Improving  hydromorphological  conditions  of  water 
bodies  other  than  longitudinal  continuity”.  Nineteen  national  supplementary  measures  have 

been mapped against seven predefined KTMs and the nationally defined KTM991. Five of the 
national  supplementary  measures  have  been  mapped  against  KTM14  -  “Research, 
improvement of knowledge base reducing uncertainty” and four against KTM991. The national 

basic measures do not include measures for Article 11(3)(f): Controls, including a requirement 
for prior authorisation  of artificial recharge or augmentation of groundwater bodies.  Links  to 

further  information  on  Article  11(3)(c-k)  basic  measures  for  all  RBDs  are  provided  as  is  an 
inventory  of  basic  measures,  including  supplementary  measures,  with  codes  and  mapped 

against types of measure. 

The number of KTMs reported as operational and tackling significant pressures is much lower 

than the number against which national measures have been mapped, i.e. eight KTMs for the 
Danube RBD and 11 KTMs for the Adriatic RBD, compared with 24, including two nationally 

derived  KTMs,  against  which  national  measures  have  been  mapped.  This  may  indicate  that 
more measures, not operational in the first RBMP, are planned for the second and third RBMP. 

For groundwater, nitrate is reported as causing one water body in each RBD to fail to achieve 
good status.  It has been reported that measures under KTM 3  – “Reduce pesticides pollution 

from  agriculture” are in  place to  address  this, but  measures under KTM2  – “Reduce nutrient 
pollution  from  agriculture”  would  seem  more  appropriate52.  In  the  Adriatic  RBD,  electrical 
conductivity  is  listed  as  causing  one  groundwater  body  to  failing  to  be  of  good  status,  and 
measures in KTM 13 – “Drinking water protection measures (e.g. establishment of safeguard 

zones, buffer zones etc.)” are reported to be in place to address this.  

52  Croatia clarified that the incorrect KTM had been reported. 

107 

 
                                                      
No information has been provided on the number of water bodies failing to achieve good status 

due to River Basin Specific Pollutants in either RBD, but KTMs have been reported as in place 
to address them. In the Danube RBD, measures under KTM14 – “Research and improvement 

of knowledge base are reported to be addressing pollution from arsenic and its compounds”. In 
both  RBDs,  KTM15  –  “Measures  for  the  phasing-out  of  emissions,  discharges  and  losses  of 

Priority  Hazardous  Substances  or  for  the  reduction  of  emissions,  discharges  and  losses  of 
Priority Substances” is reported to be in place to address copper and zinc and their compounds. 

In the Danube RBD, this KTM is also reported as addressing pollution from fluoride and AOX. 

The  number  of  surface  water  bodies  to  fail  to  achieve  good  chemical  status  as  a  result  of 

Priority Substances  are reported for both  RBDs.  KTM15  – “Measures for the phasing-out  of 
emissions,  discharges  and  losses  of  Priority  Hazardous  Substances  or  for  the  reduction  of 

emissions,  discharges  and  losses  of  Priority  Substances”  are  reported  as  being  in  place  to 
address 11 of the 16 Priority Substances causing failures in the Danube RBD and seven of the 

14 substances causing failure in the Adriatic RBD. Chlorpyrifos, chlorfenvinphos, DDT(p,p.), 
and  total  benzo(g,h,i)-perylene  +  Indeno(1,2,3-cd)-pyrene  are  reported  as  causing  surface 
waters to fail to be of good status in both RBDs, but no measures are reported as being in place 

to  control  them  in  either  RBD.  In  the  Danube  RBD,  no  measures  are  in  place  to  control 
simazine which is causing one water body to fail to be of good status, and in the Adriatic RBD 

no  measures  are  reported  to  be  in  place  to  control  tributyltin-cation  (causing  failure  in  four 
water  bodies),  hexachlorocyclohexane  or  pentachlorobenzene  (both  causing  failure  in  five 

water bodies). 

Croatia  has  reported  indicators  (most  in  terms  of  water  bodies  failing  environmental  quality 

standard, others for length of waterbody requiring measure) of the gap to achieving good status 
for  significant  pressures  on  groundwater  and  surface  water,  including  individual  River  Basin 

Specific Pollutants and Priority Substances, in both RBDs for 2015 and 2021. No indicators for 
2027  have  been  reported.  Indicators  of  the  level  of  implementation  needed  for  each  KTMs 

have  been  reported  as,  for  example,  the  number  of  new  or  upgraded  treatment  plants,  or  the 
surface area to be covered by measures. The expected improvements between 2015 and 2021 

are  generally  very  modest,  in  some  cases  zero,  and  as  indicated  from  some  higher  indicator 
values  for  KTMs  in  2021,  it  seems  that  some  measures  have  been  delayed  until  the  third 

RBMP. KTM14 – “Research and improvement of knowledge base to reduce uncertainty” has 
been applied to a large number of pressures, mainly related to hydromorhological alterations, 

including  dams  and  barriers,  but  also  to  diffuse  pollution  from  discharges  not  connected  to 
sewer. The situation is similar in both RBDs, but, as discussed above, some pressures are not 
being addressed in the Adriatic RBD. 

108 

 
Cost-effectiveness  analysis  is  an  appraisal  technique  that  provides  a  ranking  of  alternative 

measures  on  the  basis  of  their  costs  and  effectiveness,  where  the  most  cost-effective  has  the 
highest  ranking.  This  methodology  should  be  applied  to  the  prioritisation  of  the  measures 

within  the  Programme  of  Measures;  however,  Croatia  has  reported  that  cost-effectiveness 
analysis  has  not  been  carried  out  in  either  RBD.  The  prioritisation  of  measures  within  the 

Programme of Measures was further investigated in the RBMP and background documents and 
it was found that the RBMP did not make any prioritisation of measures. The RBMP states that 

some  prioritisation  will  be  done  within  the  expected  national  "Climate  Change  Adaptation 
Strategy  and  Action  Plan".  Other  prioritisation  will  be  done  after  2021  using  Cost  Benefit 

Analysis  and  after  all  basic  measures  are  implemented.  Basic  measures  will  be  implemented 
according to available finances and according to prioritisation given by the other national plans 

and programs from which some of the measures are taken (i.e. various sectoral plans). 

A  critical  factor  in  the  success  of  the  implementation  of  the  Programme  of  Measures  is  the 

availability of funding to support the investments required. Croatia reported that €880 m had 
been  invested  in  Article  11(3)(a)  requirements  (measures  required  to  implement  Community 
legislation  for  the  protection  of  water)  for  the  first  Programme  of  Measures  and  €250  m  in 

measures  under  Articles  11(3)(b-l),  Article  11(4)  and  Article 11(5)  (all  other  measures).  For 
the  second  Programme  of  Measures  (2015-2021)  a  capital  investment  of  €5  350  m  will  be 

required for Article 11(3)(a) measures  with  annual  operational  and maintenance costs of €30 
m.  A  capital  investment  of  €708  m  will  be  required  for  measures  under  Articles  11(3)(b-l), 

Article  11(4)  and  Article  11(5)  (all  other  measures)  with  annual  operation  and  maintenance 
costs  of  €50  m.  Depreciation  has  been  included  in  the  costs  for  Articles  11(3)(b-l),  Article 

11(4) and Article 11(5) (all other measures) but not for Article 11(3)(a) measures. For the first 
Programme of Measures €35 m of European Union funding was received and it is anticipated 

that  €1300-1800  m  will  be  received  for  the  second  Programme  of  Measures.  Croatia  has 
reported that a clear overall financial commitment has been secured for the implementation of 

the  Programme  of  Measures  in  both  RBDs.  On  a  sectoral  basis,  commitments  have  been 
secured  in  RBDs  for  Urban,  but  not  for  Agriculture,  Industry  and  Aquaculture,  whereas 

Transport, Hydropower,  Energy, Recreation and  Flood  Protection, were not  considered to  be 
relevant. 

Joint consultation on the RBMP and the Marine Strategy was reported for the Adriatic RBD, 
and co-ordination of the preparation of all RBMP and Programme of Measures with the Marine 
Strategy  Framework  Directive53  for  both  RBDs.  However,  there  was  no  consideration  of  the 

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

109 

 
                                                      
need for additional or more stringent measures beyond those required by the WFD54 in order to 
contribute to the achievement of the relevant Marine Strategy Framework Directive objectives 
in  coastal  and  marine  environments,  hence  no  additional  or  more  stringent  measures  are 

indicated. KTMs that are relevant to the Marine Strategy Framework Directive are listed for all 
RBDs, with an indication of the type of measure and numbers, but not indicating the pressures 

they are addressing. These include a number of KTMs/national measures not reported as being 
applied  to  tackle  significant  pressures  but  which  have  had  national  basic  measures  mapped 

against  them,  e.g.  KTM5  –  “Improving  longitudinal  continuity  (e.g.  establishing  fish  passes, 
demolishing  old  dams)”  and  KTM6  –  “Improving  hydromorphological  conditions  of  water 

bodies  other  than  longitudinal  continuity”,  KTM  9-  "Water  pricing  policy  measures  for  the 
implementation of the recovery of cost of water services from households", KTM 10 - "Water 

pricing policy measures for the implementation of the recovery of cost of water services from 
industry", KTM 11 - "Water pricing policy measures for the implementation of the recovery of 

cost  of water services from  agriculture", KTM 17  – “Measures to  reduce sediment  from soil 
erosion and surface run-off”, KTM 18 – “Measures to prevent or control the adverse impacts of 
invasive alien species and introduced diseases”, KTM 19 – “Measures to prevent or control the 

adverse  impacts  of  recreation  including  angling”,  and  KTM  20  –  “Measures  to  prevent  or 
control the adverse impacts of fishing and other exploitation/removal of animal and plants”. 

Croatia  has  reported  that  the  RBMP  and  Floods  Directive55  Flood  Risk  Management  Plans 
have been integrated in both RBDs. Joint consultation of RBMP and Flood risk Management 

Plans were carried out and the objectives and requirements of the Floods Directive have been 
considered in the second RBMP and Programme of Measures. Win-win measures in terms of 
achieving  the  objectives  of  the  WFD  and  Floods  Directive,  drought  management  and  use  of 
Natural  Water  Retention  Measures  (NWRM)  have  been  included  in  the  Programme  of 

Measures,  and  the  design  of  new  and  existing  structural  measures,  such  as  flood  defences, 
storage  dams  and  tidal  barriers,  has  been  adapted  to  take  account  of  WFD  Environmental 

Objectives in all RBDs.  

However,  whilst  KTM23  –  “Natural  water  retention  measures”  has  been  mapped  to  national 

measures,  there  is  no  evidence  that  this  measure  has  been  made  operational  nor  has  any 
information  been  provided  in  respect  of  the  pressures  it  is  aimed  to  address  in  either  RBD. 

Financial  commitments  for  the  implementation  of  Programme  of  Measures  in  the  flood 
protection sector was marked “not applicable”, and WFD Article 9(4) has not been applied to 

54  Directive  2000/60/EC  of  the  European  Parliament  and  of  the  Council  establishing  a  framework  for  the 
http://eur-lex.europa.eu/legal-
of 

policy 

water 

field 

in 

Community 
content/EN/TXT/?uri=CELEX:32000L0060 

action 

the 

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

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

110 

 
                                                      
impoundment  for  flood  protection  and  as  such  it  would  be  an  activity/use  which  should  be 

subject to cost recovery under Article 9 where relevant. 

9.1.2 Measures related to other significant pressures 

There  is  no  information  in  relation  to  significant  other  pressures  (none  seem  to  have  been 
identified). 

9.1.3 Mapping of national measures to Key Types of Measure 

It was expected that Member States would be able to report their Programme of Measures by 

associating  their  national  measures  with  predefined  Key  Types  of  Measure.  Key  Types  of 
Measure are expected to deliver the bulk of the improvements through reduction  in pressures 

required  to  achieve  WFD  Environmental  Objectives.  A  Key  Type  of  Measure  may  be  one 
national  measure  but  it  would  typically  comprise  more  than  one  national  measure.  Member 

States  are  required  to  report  on  the  national  measures  associated  with  the  Key  Types  of 
Measure, and whether the national measures are basic (Article 11(3)(a) or Article 11(3)(b-l)) or 

supplementary (Article 11(4)).  

Table 9.1 summarises the number of national measures that have been mapped to the relevant 
Key Types of Measure in Croatia. Also shown is the number of RBDs for which the Key Type 

of Measure has been reported. Table 9.2 then summarises the type of basic measures associated 
of  Measure.
with 

national  measures  mapped 

the  Key  Type 

against 

the 

111 

 
Table 9.1 

Mapping of the types of national measures to Key Types of Measure in Croatia  

Key Type of Measure 

National basic 
measures 

National 
supplementary 
measures 

Number of RBDs 
where reported 

KTM1 - Construction or upgrades of wastewater treatment plants 

KTM10 - Water pricing policy measures for the implementation of the recovery of cost of water 
services from industry 

KTM11 - Water pricing policy measures for the implementation of the recovery of cost of water 
services from agriculture 

KTM12 - Advisory services for agriculture 

KTM13 - Drinking water protection measures (e.g. establishment of safeguard zones, buffer 
zones etc.) 

KTM14 - Research, improvement of knowledge base reducing uncertainty 

KTM15 - Measures for the phasing-out of emissions, discharges and losses of Priority Hazardous 
Substances or for the reduction of emissions, discharges and losses of Priority Substances 

KTM16 - Upgrades or improvements of industrial wastewater treatment plants (including farms). 

KTM17 - Measures to reduce sediment from soil erosion and surface run-off 

KTM18 - Measures to prevent or control the adverse impacts of invasive alien species and 
introduced diseases 

KTM19 - Measures to prevent or control the adverse impacts of recreation including angling 

KTM2 - Reduce nutrient pollution from agriculture 

KTM20 - Measures to prevent or control the adverse impacts of fishing and other 
exploitation/removal of animal and plants 

KTM21 - Measures to prevent or control the input of pollution from urban areas, transport and 
built infrastructure 

KTM24 - Adaptation to climate change 

KTM3 - Reduce pesticides pollution from agriculture. 

112 

14 

24 

28 

14 

38 

78 

34 

4 

12 

20 

4 

20 

2 

78 

54 

14 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

10 

6 

4 

2 

4 

2 

 
 
 
 
 
 
 
 
 
 
Key Type of Measure 

National basic 
measures 

National 
supplementary 
measures 

Number of RBDs 
where reported 

KTM4 - Remediation of contaminated sites (historical pollution including sediments, 
groundwater, soil) 

KTM5 - Improving longitudinal continuity (e.g. establishing fish passes, demolishing old dams) 

KTM6 - Improving hydromorphological conditions of water bodies other than longitudinal 
continuity 

KTM7 - Improvements in flow regime and/or establishment of ecological flows 

KTM8 - Water efficiency, technical measures for irrigation, industry, energy and households 

KTM9 - Water pricing policy measures for the implementation of the recovery of cost of water 
services from households 

KTM99 - Other key type measure reported under Programme of Measures - KTM991 

KTM99 - Other key type measure reported under Programme of Measures - KTM992 

Total number of Mapped Measures 

2 

70 

110 

94 

58 

40 

106 

260 

589 

Source: Member States’ reporting to WISE 

2 

2 

2 

2 

2 

2 

2 

2 

2 

8 

19 

113 

 
 
 
 
 
 
 
 
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Table 9.2 

Type of basic measure mapped to Key Type of Measures in Croatia  

Key Type of Measure 

KTM1 - Construction or upgrades of wastewater treatment plants 
KTM10 - Water pricing policy measures for the implementation of the 
recovery of cost of water services from industry 
KTM11 - Water pricing policy measures for the implementation of the 
recovery of cost of water services from agriculture 
KTM12 - Advisory services for agriculture 
KTM13 - Drinking water protection measures (e.g. establishment of 
safeguard zones, buffer zones etc.) 
KTM14 - Research, improvement of knowledge base reducing uncertainty 
KTM15 - Measures for the phasing-out of emissions, discharges and losses 
of Priority Hazardous Substances or for the reduction of emissions, 
discharges and losses of Priority Substances 
KTM16 - Upgrades or improvements of industrial wastewater treatment 
plants (including farms). 
KTM17 - Measures to reduce sediment from soil erosion and surface run-off 
KTM18 - Measures to prevent or control the adverse impacts of invasive 
alien species and introduced diseases 
KTM19 - Measures to prevent or control the adverse impacts of recreation 
including angling 
KTM2 - Reduce nutrient pollution from agriculture 
KTM20 - Measures to prevent or control the adverse impacts of fishing and 
other exploitation/removal of animal and plants 
KTM21 - Measures to prevent or control the input of pollution from urban 
areas, transport and built infrastructure 
KTM24 - Adaptation to climate change 
KTM3 - Reduce pesticides pollution from agriculture. 
KTM4 - Remediation of contaminated sites (historical pollution including 
sediments, groundwater, soil) 
KTM5 - Improving longitudinal continuity (e.g. establishing fish passes, 
demolishing old dams) 
KTM6 - Improving hydromorphological conditions of water bodies other 

n
o
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t
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l
l
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p
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5 

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t
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7 

6 

3 

5 

16 

114 

Basic Measure Type 

e
c
r
u
o
s

t
n
i
o
P

s
e
g
r
a
h
c
s
i
d

6 

6 

9 

2 

17 

2 

e
s
u
f
f
i
d
s
t
n
a
t
u
l
l
o
P

1 

3 

4 

5 

1 

4 

4 

2 
1 

y
g
o
l
o
h
p
r
o
m
o
r
d
y
H

8 

16 

15 

D
E
I
C
P
P
I

s
e
t
a
r
t
i

N

r
e
h
t
O

4 

8 

2 

9 

1 

3 

4 

5 

11 

1 

5 

1 

1 

5 

10 

2 

4 

1 

5 

3 

1 

19 

40 

2 

2 

2 

6 

7 

2 

13 

2 

1 

1 

1 

r
e
t
a
W

e
t
s
a
W
n
a
b
r
U

6 

6 

8 

1 

5 

17 

2 

2 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
than longitudinal continuity 
KTM7 - Improvements in flow regime and/or establishment of ecological 
flows 
KTM8 - Water efficiency, technical measures for irrigation, industry, energy 
and households 
KTM9 - Water pricing policy measures for the implementation of the 
recovery of cost of water services from households 

KTM99 - Other key type measure reported under PoM 

5 

15 

15 

5 

1 

16 

16 

1 

7 

7 

15 

15 

4 

12 

11 

112 

24 

15 

7 

6 

3 

1 

3 

5 

24 

Source: Member States’ reporting to WISE 

Key 

‘Accidental pollution’ = Article 11(3)(l): Any measures required to prevent significant losses of pollutants from technical installations and to prevent and/or reduce the impact of 
accidental pollution incidents. 
‘Controls water abstraction’ = Article 11(3)(e): Controls over the abstraction of fresh surface water and groundwater and impoundment of fresh surface waters including a register or 
registers of water abstractions and a requirement for prior authorisation of abstraction and impoundment. 
‘Cost recovery water services’ = Article 11(3)(b): Measures for the recovery of cost of water services (Article 9). 
‘Efficient water use’ = Article 11(3)(c): Measures to promote efficient and sustainable water use. 
‘Hydromorphology’ = Article 11(3)(i): Measures to control any other significant adverse impact on the status of water, and in particular hydromorphological impacts. 
‘IPPC IED’ = Integrated Pollution Prevention Control Directive (96/61/EC) and the Industrial Emissions Directive (2010/75/EU). 
‘Nitrates’ = Nitrates Directive (91/676/EEC). 
‘Other’ = Other Directives mentioned in Part A of Annex VI of the WFD. 
‘Point source discharges’ = Article 11(3)(g): Requirement for prior regulation of point source discharges liable to cause pollution. 
‘Pollutants diffuse’ = Article 11(3)(h): Measures to prevent or control the input of pollutants from diffuse sources liable to cause pollution. 
‘Pollutants direct groundwater’ = Article 11(3)(j): Prohibition of direct discharge of pollutants into groundwater. 
‘Protection water abstraction’ = Article 11(3)(d): Measures for the protection of water abstracted for drinking water (Article 7) including those to reduce the level of purification 
required for the production of drinking water. 
‘Recharge augmentation groundwaters’ = Article 11(3)(f): Controls, including a requirement for prior authorisation of artificial recharge or augmentation of groundwater bodies. 
‘Surface Priority Substances’ = Article 11(3)(k): Measures to eliminate pollution of surface waters by Priority Substances and to reduce pollution from other substances that would 
otherwise prevent the achievement of the objectives laid down in Article 4. 
‘Urban Waste Water’ = Urban Waste Water Treatment Directive (91/271/EEC). 

115 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
9.1.4 Pressures for which gaps to be filled to achieve WFD objectives have been reported 

and the Key Types of Measure planned to achieve objectives 

Member  States  are  required  to  report  the  gaps  that  need  to  be  filled  to  achieve  WFD 
Environmental  Objectives  in  terms  of  all  significant  pressures  on  surface  waters  and 

groundwaters, in  terms  of Priority Substances causing  failure of  good  chemical  status  and in 
terms  of  River  Basin  Specific  Pollutants  causing  failure  of  good  ecological  status/potential. 

Member  States  were  asked  to  report  predefined  indicators  of  the  gaps  to  be  filled  or  other 
indicators where relevant. Values for the gap indicators were required for 2015 and 2021, and 

were optional for 2027. 

The  information  reported  in  WISE  on  the  gaps  to  fulfil  to  achieve  good  ecological  status 

include detailed data on the significant pressures on surface and groundwaters that may cause 
failure on the environmental objectives. For chemical  status,  the Member States reported the 

specific chemical substances causing failure. 

This information is reported at the sub-unit level. Sub-units are smaller geographic areas within 

particular  RBDs  identified  by  Member  States.  Not  all  Member  States  have  defined  and 
reported sub-units. 

Member States were required to report which KTMs are to be made operational to reduce the 
gaps to levels compatible with the achievement of WFD environmental objectives. A number 

of  indicators  were  predefined  for  each  KTM.  Values  of  the  indicators  for  the  second  and 
subsequent  planning  cycles  were  also  to  be  reported  to  give  an  indication  of  the  expected 

progress and achievements: the values for 2027 could be optionally reported. This means that 
the value of the indicator will be reduced with time as measures are implemented. A value of 

zero is comparable with 100 % good ecological status or potential or good chemical status.  

This  information  was  reported  at  sub-unit  level,  or  at  RBDs  level  if  sub-units  have  not  been 

reported by the Member State. 

9.2  Main changes in implementation and compliance since the first RBMP 

The  level  of  implementation  of  the  first  RBMP  of  Programme  of  Measures  was  reported  in 

WISE by Croatia as “some measures completed” for both RBDs. Obstacles were reported as 
“Governance”, “Lack of finance”, and “Lack of  mechanisms” for both  RBDs.  Improvements 

seem  to  have  been  achieved  in  the  co-operation  with  Member  State  and  non-Member  State 
(both  RBDs  are  international).  Progress  also  seems  to  have  been  made  in  identifying 

significant pressures and mapping national measures/KTMs, and in performing gap analyses. 

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A summary of changes or updates for this Topic could not be found for either of the second 
RBMP. 

9.3  Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMP  and  Programme  of  Measures 

requested action on the following: 

  Recommendation: Review the pressures and impacts analysis and status assessment in 
the  second  RBMP  and  ensure  that  the  measures  are  based  on  the  updated  pressures 
and impacts analysis and status assessment of water bodies. 

Assessment: A large number of significant pressures have been listed as causing failure 
of objectives for both RBDs, and KTMs have been listed and implemented or planned 

to  address  most  of  these  pressures.  With  respect  to  measures,  it  appears  that  this 
recommendation has been addressed. 

  Recommendation:  Ensure that the RBMP  clearly identify the gap to  good status, and 
that the Programme of Measures are designed and implemented to close that gap. 

Assessment: Gap analyses have been reported for both RBDs for 2015 and 2021, none 
for 2027. Gap indicators are reported in many cases as number of water bodies failing 

environmental  quality  standards,  and  also  in  terms  of  KTMs,  e.g.  number  of  new  or 
upgraded  treatment  plants,  or  area  to  be  covered  by  measure.  The  predicted 

achievements for 2021 are generally very modest (or none) and in some cases the gaps 
(in terms of measures) are higher in 2021, indicating that measures were delayed until 

the third RBMP. This recommendation has been partially addressed. 

  Recommendation: Besides basic measures, supplementary measures that are necessary 

to achieve the objectives set should also be included in the second RBMP. 

Assessment:  Nineteen  national  supplementary  measures  have  been  mapped  against 

KTMs.  This  is  a  small  number  of  measures  in  comparison  to  the  number  of  national 
basic  measures  that  have  been  adopted.  This  recommendation  has  been  partially 

addressed. 

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Topic 10

  Measures related to abstractions and water scarcity  

10.1 Assessment of implementation and compliance with WFD requirements 

in the second RBMP 

10.1.1  Water exploitation and trends  

No  information  is  reported  to  WISE  by  Croatia  regarding  water  quantity,  including  water 

abstractions  or  the  Water  Exploitation  Index  +,  nor  has  it  been  reported  to  support  the 
European State of the Environment Report in relation to Water Quantity. However, the RBMP 

2016-2021  includes  that  information.  In  relation  to  the  first  River  Basin  Management  Plan, 
data  on  the  abstraction  of  water  for  all  known  uses  of  water  resources  were  collected  and 

analysed.  Data  are  provided  in  tables  of  abstracted  water  quantity  through  a  controlled 
abstraction  by  usage  and  springs  (sources)  (data  from  2012)  as  well  as  quantities  of 

uncontrolled  water  abstraction  by  usage.  Water  scarcity  issues  are  not  considered  relevant  at 
the international level. Detailed information is provided on the number of water bodies failing 

good status due to abstraction pressures, and the exact area to be considered for implementing 
water  pricing  policies  for  agriculture.  Water  resources  planning  in  relation  to  abstractions  is 

partially included in the RBMP, even if no separate water resource allocation and management 
plans are developed.  

10.1.2  Main uses for water consumption 

Some  information  has  been  reported  for  water  consumption:  approximately  50  %  is  for  the 

public water supply. Public water supply has estimated losses of 42 % (48 % on HRJ and 36 % 
on HRC river basin districts). More significant water abstraction pressures have been identified 

for urban, industrial and agricultural uses.  

In the RBMP, there are data for water consumption that can be considered as given by sectors. 

However, water consumption related data are actually given in terms of the number of licences 
issued  and  by  types  of  purpose  for  which  water  consumption  has  been  used  (those  include: 

public  water  supply,  irrigation,  sale  of  water,  technological  water,  cooling,  aquaculture, 
recreational and health, hydropower). 

10.1.3  Measures related to abstractions and water scarcity  

Regarding  basic  measures  (Article  11(3)(e)),  in  Croatia  there  is  a  permitting  regime  and  a 

register  of  abstractions  for  surface  water  and  groundwater  and  a  concession,  authorisation 
and/or permitting regime to control water impoundment but no register of impoundments; and 

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small abstractions are exempted, even if 6 % of surface water bodies in the Danube RBD and 
10 % in the Adriatic RBD face significant water abstraction pressures56.  

The RBMP explains that water abstraction control (from surface and groundwater) is regulated 
by the national "Water Act", which stipulates that for each use of water exceeding the scope of 

the general or free use, a permit is necessary in the form of: (a) concession agreement for the 
economic use of water, or (b) water-permit for water use (Water Act, Article 157). 

Users which are licensed to abstract water are obliged to keep a record and regularly report to 
Croatian  Waters  (Water  Act,  Article  80,  Ordinance  on  the  Register  of  Abstracted  and  Used 

Amount of Water (Official Gazette 81/10)). 

The RBMP does not provide any information about the fixed or required time period for water 

abstraction permit reviews. Additionally, the Water Law does not have any information about 
“review  of  all  existing  permits  and  assessment  of  their  compatibility  with  the  WFD57”. 
However,  a  table  is  included  in  the  RBMP  (Programme  of  Measures)  on  'Implementing 
measures for water abstraction control' that does foresee measures for stopping the issuing of 

new  water  abstraction  permits  on  water  bodies  with  insufficient  water  flow  quantities, 
reduction of existing permits for surface water abstraction until at least moderate conditions of 

water  flow  quantities  are  achieved,  and  restriction  of  issuing  new  permits  for  surface  water 
abstraction until at least moderate conditions of water flow quantities are achieved. 

Measures under Article 11(3)(c) for sustainable and efficient water use have been implemented 
in the previous cycle but new measures and/or significant changes are planned. These include: 

(1)  Measures  for  improvement  of  water  abstraction  control;  (2)  Implementing  measures  for 
water abstraction control. All measures are similar and relevant for both RBDs. 'Measures for 

improvement  of  water  abstraction  control'  are  mostly  management  measures  for  better 
knowledge  and  transparency  on  issued  water  permits,  as  well  as  water  metering  related 

measures  (use  of  metering  devices  for  all  types  of  water  use/abstraction,  use  of  metering 
devices  on  all  buildings  already  connected  to  municipal  water  structures).  'Implementing 

measures  for  water  abstraction  control'  are  a  set  of  measures  with  very  wide  scope  of 
intervention  including:  water  metering  at  source  of  abstraction,  water  permitting  measures 
(new rights, existing rights regulation according to water body status), abstraction monitoring, 

abstraction pressures monitoring, irrigation issues, better technological water use efficiency. 

56   Croatia  subsequently  explained  that  “register  of  impoundment”  and  “small  abstractions”  are  defined  in  the 
National Water Act (“abstractions not subject to authorisation”). A new authorisation regime is expected in the 
coming new Water Act. 

57   Directive  2000/60/EC  of  the  European  Parliament  and  of  the  Council  establishing  a  framework  for  the 
http://eur-lex.europa.eu/legal-
of 

policy 

water 

field 

in 

Community 
content/EN/TXT/?uri=CELEX:32000L0060 

action 

the 

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Measures  for  the  prior  authorisation  of  artificial  recharge  or  augmentation  of  groundwater 
bodies  (Article  11(3)(f))  are  not  envisaged  in  Croatia  as  no  activities  are  carried  out  which 

would result in pressures on groundwater augmentation.  

Both RBDs (Danube and Adriatic) implement complementary measures associated to KTM7 – 

“Improvements in flow regime and/or establishment of ecological flows”. Measures associated 
to  other  KTMs  are  only  foreseen  for  the  Adriatic  RBD,  for  abstraction  pressures  from 

agriculture, including KTM 11 - "Water pricing policy measures for the implementation of the 
recovery  of  cost  of  water  services  from  agriculture"  and  KTM12  –  “Advisory  services  for 
agriculture” in an area of 59 km2. 

Water reuse is not a measure foreseen, although it is considered to have a lower environmental 

impact than other alternative water supplies in both RBDs. 

10.2 Main changes in implementation and compliance since the first RBMP 

The  assessment  of  the  first  RBMP  indicated  that  it  made  few  references  to  water  scarcity  or 
drought.  The  implementation  described  in  the  previous  section  therefore  represents  the  main 

changes since then. 

10.3 Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMP  and  Programme  of  Measures 

requested action on the following: 

  Recommendation:  Review  all  existing  permits  and  where  necessary,  amend  them  to 

ensure that they are compatible with the WFD objectives. 

Assessment:  Regarding  basic  measures  (Article  11(3)(e)),  in  Croatia  there  is  a 
concession,  authorisation  and/or permitting  regime to  control water impoundment but 

no  register  of  impoundments;  and  small  abstractions  are  exempted,  even  when  in  the 
Danube and Adriatic RBDs, 6 % and 10 % of surface water bodies respectively, face 

significant water abstractions. Measures of this type are planned to be implemented and 
might respond to the recommendation. This recommendation is partially fulfilled. 

  Recommendation:  Ensure  that  abstraction  controls  are  in  place  by  the  time  of  the 

second RBMPs. 

Assessment:  Statistics  on  abstractions  per  sector  are  partially  available  in  the  RBMP, 
but no historic trends on their evolution. The Programme of Measures foresees specific 

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actions such as improving the Water information system, updating the register of water 
rights,  establishing  verification  controls,  imposing  obligatory  installation  of  water 

meters for all abstractions, monitoring abstractions and assessment of data.  
This  recommendation  is  therefore  considered  as  partially  fulfilled  as  the  planned 

measures are yet to be implemented. 

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Topic 11

  Measures related to pollution from agriculture  

11.1 Assessment of implementation and compliance with WFD requirements 

in the second RBMP 

The  types  of  pressures  from  agriculture  have  not  changed  since  the  first  RBMP.  The  main 
pressures are organic, chemical and diffuse pollution as well as altered habitats. While in the 

first  RBMP  only  basic  measures  have  been  applied,  in  the  second  cycle  supplementary 
measures  have  also  been  applied.  A  gap  assessment  was  missing  in  the  first  RBMP  but  has 

been performed now for diffuse nutrient pollution.  

For the Danube RBD, for KTM2 – “Reduce nutrient pollution from agriculture” (groundwater) 

and KTM12 – “Advisory  services for agriculture” (surface water  and groundwater) the  areas 
covered  by  a  measure  are  given.  For  the  Adriatic  RBD,  the  information  is  given  only  for 

surface  water  for  KTM12  –  “Advisory  services  for  agriculture”.  General  binding  rules  have 
been identified by Member States as being in place for nutrients, pesticides and phosphorus.  

Pesticides  and  nutrients  are  addressed  by  the  basic  measures  in  both  RBDs  but  the 
implementation  of  basic  measures  under  Article  11(3)(h)  for  the  control  of  diffuse  pollution 

(i.e., nutrients, especially nitrates) from agriculture at source (11 measures) only covers Nitrate 
Vulnerable Zones.  

There  is  mixed  information  regarding  establishment  of  mandatory  safeguard  zones  around 
drinking  water  protection  areas  in  both  RBDs  in  Croatia.  The  second-  RBMP  provides  a 
summary  of  implementation  of  the  first  cycle  (2013-2015)  stating  that  all  drinking  water 
springs  have  been  identified  but  not  yet  protected  since  there  are  still  no  guidelines  for 

establishment of safeguard zones. Furthermore, it is stated that those guidelines are expected to 
be issued by the end of 2016. However, later in the second RBMP it is written and shown in a 

map of Croatia that there are zones of sanitary protection of water springs intended for human 
consumption  (Sl.A.22.).  This  suggests  that  safeguard  zones  have  been  established.  Then, 

further  in  section  5.2.2.  "Water  protection  measures  intended  for  human  consumption",  an 
explanation that zones of sanitary protection of water sources intended for human consumption 

are regulated by the "Water Act" and the "Law on Water for Human Consumption" (Official 
Gazette  56/13  and  64/15).  It  is  also  stated  that  the  manner  of  establishing  the  sanitary 

protection zone, the mandatory measures and the restrictions imposed therein, the time limits 
for  the  adoption  of  the  decisions  on  protection  and  the  procedure  for  the  adoption  of  those 

decisions,  are  regulated  by  the  "Ordinance  on  Conditions  for  Determination  of  the  Sanitary 
Protection Zone" (Official Gazette, Nos 66/11 and 47 / 13). The conclusion seems to be that 

122 

 
not  all  the  work  regarding  establishment  of  the  mandatory  safeguard  zones  around  drinking 
water protection areas has been finished. 

Furthermore,  the  RBMP  states  that  "When  developing  the  Strategic  Water  Conservation 
Program  for  Human  Consumption  with  the  Implementation  Plan,  it  is  necessary  to  include: 

(among  others)  measures  that  will  limit  the  use  of  mineral  and  organic  fertilizers  and  plant 
protection products in agriculture in the immediate vicinity of the source, but also restrict the 

capacity of livestock production". 

As  regards  drinking  water  protection,  two  basic  measures  have  been  taken  in  the  agriculture 

sector, aiming at “water bodies intended for human consumption”. The first one (S4) aims at 
educating  agricultural  producers,  who  use  agricultural  land  within  the  secondary  sanitary 
protection zone58, about compulsory restrictions for this zone (considering soil and agriculture 
related  activities).  The  second  measure  (S5)  aims  at  strengthening  the  control  over  the 

implementation  of  regulations  related  to  agricultural  production  in  the  second  sanitary 
protection zone around the spring (considering soil and agriculture related activities). 

Additional control measures on land (not just in safeguard zones but in the wider catchment) 
have  been  introduced  in  the  second  RBMP  (2016-2021)  to  prevent  nitrogen,  phosphorus  or 

pesticides  from  entering  drinking  water  sources.  This  RBMP  dedicates  a  specific  section  to 
"Control measures for diffuse sources of contamination” where agriculture (especially nitrates) 

is  recognised  as  one of the most important  sources  of diffuse water contamination.  It  further 
explains that Article 50 of the "Water Act" prescribes the determination of "vulnerable areas" 

for  which  reinforced  measures  to  protect  water  from  nitrate  contamination  coming  from 
agricultural  origin  and  the  adoption  of  an  Action  program  (or  several  programs)  to  reduce 

nitrate  pollution  of  agricultural  origin  would  be  further  enforced.  The  "Decision  on  the 
Determination  of  Vulnerable  Areas  in  the  Republic  of  Croatia"  identified  vulnerable  areas 

covering 9 % of the territory of the Republic of Croatia.  

Based on the above Decision, pursuant to Article 5 of the Nitrates Directive59, Croatia adopted 
an  “Action  program  for  the  protection  of  water  from  pollution  by  nitrates  of  agricultural 

58   Croatia has clarified that sanitary protection zones are established for the purpose of protection of the spring 
and  other  drinking  water  reservoir  areas  against  pollution.  In  Croatia  bodies  of  local  (cities,  municipalities) 
and  regional  (counties)  self-administrating  units  are  responsible  for  protection  of  drinking  water  springs 
according  to  sanitary  protection  zones  rules  and  with  prior  consent  issued  by  Hrvatske  vode  (according  to 
Water  Act,  Article  91).  Sanitary  protection  zones  are  established  according  to  conditions  prescribed  in  the 
Ordinance on the conditions for establishment of sanitary protection zones for springs (Official Gazette 66/11 
and 47/13).  

59   Council  Directive  91/676/EEC  of  12  December  1991  concerning  the  protection  of  waters  against  pollution 
http://eur-lex.europa.eu/legal-
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by 

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nitrates 

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origin" This Action Program will be implemented for a period of four years after accession to 
the European Union. The measures set out in the Action Program are mandatory in vulnerable 

areas, while in other areas they are considered as a recommendation. 

Since accession to the European Union, the "Ordinance on Good Agricultural Practice in the 

Use of Fertilizers" (OG 56/08) has been in force. This Ordinance sets out the general principles 
of good agricultural practice in the use of fertilizers and soil improvers and the conditions of 

use and treatment of fertilizers, especially the use of nitrogen fertilizers. The implementation of 
this Ordinance is mandatory in vulnerable areas and considered as a recommendation in other 

areas. 

The RBMP itself has few measures related to better management and control of diffuse sources 

of pollution coming from agriculture, mostly related to manure and nitrates. 

Farmers/Farmers'  Unions  have  been  consulted  under  the  Public  Consultation  process  in  all 

basins.  

Financing  of  agricultural  measures  is  not  secured  in  both  RBDs.  From  the  second  RBMP,  it 

can  be  concluded  that  sources  of  funding  will  be  national  and  international.  Considering 
national  sources,  the  main  source  of  funding  are  Croatian  Waters’  revenues  coming  from 

various  national  "water  charges"  (water  subsidies  and  compensation  for  water  management) 
with  the  possibility  of  co-financing  from  the  state  budget  and  "other"  domestic  and  foreign 

sources. Other sources of financing include: loans from the Development Bank of the Council 
of Europe (CEB) (mostly  for projects somehow related to flood protection), cross-border co-

operation  programs,  European  Union  funds  (Structural,  Cohesion,  Rural  Development, 
Fisheries, LIFE or RTD), and other available domestic and international sources of funding. 

11.2 Main changes in implementation and compliance since the first RBMP 

The types of pressures from agriculture have not changed. While in the first RBMP only basic 
measures  have  been  applied,  now  also  supplementary  measures  have  been  applied.  A  gap 

assessment was missing in the first RBMP but has been performed for the Adriatic RBD for 
the second RBMP. 

11.3 Progress with Commission recommendations 

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

requested action on the following: 

124 

 
  Recommendation:  Determine  effectiveness  of  basic  measures  and  what  needs  to  be 
done in addition. Based on this gap analysis Croatia should take measures in addition 

to  the  action  programme  for  nitrates  and  on  the  use  of  plant  protection  products,  if 
necessary. Those measures should be part of the next RBMPs. 

Assessment:  Several  parts  of  the  recommendation  have  been  considered.  A  gap 
assessment has been performed, but it is not clear from the data reported to WISE what 

the  contribution  from  the  implementation  of  the  Nitrates  Directive  would  be. 
Implementation of basic measures under Article 11(3)(h) is part of the second RBMP, 
but  the  rules  only  apply  in  a  mandatory  way  in  Nitrate  Vulnerable  Zones60.  Article 
11(3)(g) for measures to reduce point sources is applied in all basins through basic and 

supplementary measures. It is not possible to assess whether measures are voluntary or 
mandatory. 

  Recommendation Review existing controls to ensure that agriculture practices do not 
cause hydromorphological pressure and update controls where necessary for inclusion 
in the PoM of the second RBMPs.  

Assessment:  Article 11(3)(i)  measures  to  reduce  hydromorphological  pressures  from 

agriculture  are  part  of  the  Programme  of  Measures  in  both  RBDs.  Instruments  to 
control hydromorphological pressures are outlined in the Water Act (Article 143.-148.) 

and the Environmental Protection Act. However, the second RBMP states that a lack of 
adequate  hydromorphological  and  biological  monitoring  significantly  hinders  the 

preparation  of  a  higher  quality  Programme  of  Measures  to  control  and  reduce 
hydromorphological pressures on water bodies. 

60   Croatia clarified that a new project is implemented with the aim of determining priority areas for groundwater 
monitoring within intensive agricultural areas. Based on the outcomes of this project vulnerable areas will be 
revised. 

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Topic 12

  Measures  related  to  pollution  from  sectors  other  than 

agriculture  

12.1 Assessment of implementation and compliance with WFD requirements 

in the second RBMP 

In  the  context  of  this  topic,  pollution  is  considered  in  terms  of  nutrients,  organic  matter, 

sediment,  saline  discharges  and  chemicals  (Priority  Substances,  River  Basin  Specific 
Pollutants,  groundwater  pollutants  and  other  physico-chemical  parameters)  arising  from  all 

sectors  and  sources  apart  from  agriculture.  Key  types  of  measures  (KTM)  are  groups  of 
measures identified by Member States in their Programmes of Measures which target the same 

pressure or purpose. A KTM could be one national measure but would typically comprise more 
than  one  national  measure.  The  same  individual  measure  can  also  be  part  of  more  than  one 

KTM  because  it  may  be  multipurpose,  but  also  because  the  KTMs  are  not  completely 
independent of one another. 

KTMs  relevant  to  non-agricultural  sources  of  pressures  causing  failure  of  WFD  objectives 
have been reported in both Croatian RBDs. These KTMs include:  

KTM1 "Construction or upgrades of wastewater treatment plants" 

KTM14 "Research, improvement of knowledge base reducing uncertainty"  

KTM16  –  “Upgrades  or  improvements  of  industrial  wastewater  treatment  plants  (including 
farms)”, and  

KTM21- "Measures to prevent or control the input of pollution from urban areas, transport and 
built infrastructure". 

The  WFD  specifies  that  the  Programme  of  Measures  shall  include,  as  a  minimum,  “basic 
measures” and, where necessary to achieve objectives, “supplementary measures” when basic 

measures are not enough to address specific significant pressures (see Chapter 9 in this report). 
Quantitative information on basic and supplementary  measures used to  tackle pollution from 

non-agricultural sources (number of measures per KTM) has been provided for both Croatian 
RBDs.  Quantitative  information  on  types  of  basic  measures  to  tackle  pollution  from  non-
agricultural  sources (number of measures per KTM) is  provided for seven measure types for 

both Croatian RBDs.  

Croatia provided more targeted information on basic measures required under Article 11(3)(c 

to  k).  Use  of  an  authorisation  and/or  permitting  regime  to  control  waste  water  point  source 

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discharges (Basic measures Article 11(3)(g)) was reported for both Croatian RBDs for surface 
and  groundwater.  A  register  of  waste  water  discharges  (Basic  measures  Article  11(3)(g))  is 

available in both RBDs in Croatia for surface and groundwater. Small waste water discharges 
are exempted from controls in both Croatian RBDs. Some direct discharges to groundwater are 

authorised in accordance with Article 11(3)(j) in both Croatian RBDs. 

Croatia  reported  that  there  are  measures  in  place  to  eliminate/reduce  pollution  from  Priority 

Substances and other substances in both RBDs. 

12.2 Main changes in implementation and compliance since the first RBMP  

The first RBMP cited the following measures to address chemical pollution: 

  water permits for discharge of waste waters; 

  production, placing on the market and use of chemicals requiring prior registration and 
in certain cases approval; many specific substances, including certain pesticides, have 

been prohibited or limited; 

  a water fee for the production and import of plant protection products; and, 

 

limiting  the  use  of  certain  pollutants  on  agricultural  land  in  accordance  with  the 

Ordinance on Protection of Agricultural Land from Pollution. 

As  regards  measures  planned  for  all  Priority  Substances  causing  failure  in  the  second  cycle, 

there  is  no  consistent  information  in  the  WISE  reporting  or  second  RBMP,  i.e.,  no  detailed 
information on substance-specific measures.  

All  River  Basin  Specific  Pollutants  causing  failure  to  achieve  good  status  in  the  two  RBDs 
(Danube and Adriatic) are covered by KTMs. In the Danube RBD, five River Basin Specific 

Pollutants are causing failure (Arsenic and its compounds, copper and its compounds, zinc and 
its compounds, fluoride and AOX); in the Adriatic RBD, two River Basin Specific Pollutants 

(copper and its compounds, zinc and its compounds) are relevant.  

Similarly,  in  both  Croatian  RBDs,  pollutants  which  are  causing  failure  in  groundwater  are 

covered  by  KTMs.  In  the  Danube  RBD,  there  is  one  pollutant  (nitrate)  causing  failure  in 
groundwater. In the Adriatic RBD there are two pollutants (Nitrate, electrical conductivity). 

127 

 
12.3 Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMP  and  Programme  of  Measures 

requested action on the following: 

  Recommendation:  “Provide  in  the  second  RBMP  all  the  information  on  the  level 
compliance and timing to  reach compliance of  agglomerations, including information 
on  funding,  in  accordance  with  Directive  91/271/EEC  (article  15  and  following). 

Prioritize the agglomerations with more than 2 000 PE in terms of the WFD principles 
and of financing in the second RBMP but should also assess the pressures due to waste 

water from small agglomerations (less than 2 000 PE) in the second RBMP cycle.” 

Assessment:  Measures  to  mitigate  pollution  loads  are  planned  until  2027.  For  the 

period  2016  to  2021,  measures  are  to  be  implemented  in  all  water  bodies  where 
pollution loads have been reported (irrespective of the status of water); this includes the 

implementation  of:  (a)  Urban  Waste  Water  Treatment  Directive  (basic  measures),  (b) 
Nitrate  Directives  (basic  measures),  (c)  IED  Directives  (basic  measures).  The  period 

2022-2027  includes  measures  to  be  implemented  in  water  bodies  for  which  it  is 
estimated  that  after  2021  (and  after  the  implementation  of  basic  measures)  the 

minimum  water  status  will  still  not  be  achieved,  and  includes  implementation  of  the 
Urban Waste Water Treatment  Directive (with supplemental  measures for settlements 

<2 000 p.e. where the situation needs improvement).  

According  to  the  Water-Utilities  Directive  Implementation  Plan  (Plan  provedbe 

vodnokomunalnih  direktiva),  basic  pollution  prevention  measures  (from  urban  areas) 
include the construction or upgrading of waste water collection and treatment systems 

at  281  agglomerations  greater  than  2  000  p.e.  at  estimated  current  potential  loads. 
Outside of the basic measures program are 473 agglomerations of less than 2 000 p.e. 

according to  the estimated current  potential burden (data from  2014),  which accounts 
for  about  13  %  of  the  population  of  the  Republic  of  Croatia.  The  "Multi-annual 

Program of Construction of Municipal Water Facilities" includes investments in public 
drainage for 281 agglomerations with more than 2 000 p.e., where improvement of the 

public  drainage  and  waste  water  treatment  system  is  planned  by  2023.  The  Multi-
annual  Program  of  Construction  of  Municipal  Water  Facilities  foresees  investments 

related to: construction  or renovation of  wastewater collection and sewerage systems; 
construction  of  new  or  upgrade  of  existing  wastewater  treatment  plants  to  ensure  the 

required degree of purification for the required projected capacity, with deadlines that 
generally  follow  those  defined  by  the  Water-Utilities  Directive  Implementation  Plan. 

128 

 
The  total  estimated  cost  of  construction  of  the  public  sewerage  system  in  281 
agglomeration  amounts  to  HRK  21  893  m,  of  which  the  cost  of  construction  of 

treatment plants is HRK 6 716 m. The recommendation was partly fulfilled. 

  Recommendation:  “Ensure  the  compliance  of  Article  5  UWWTD  for  more  stringent 

treatment, especially in big cities.” 

Assessment:  Concerning  very  large  urban  agglomerations  (i.e.  more  stringent 

treatment,  especially  in  big  cities),  the  RBMP  does  not  provide  much  information. 
The  highest  urban  agglomerations  mentioned  in  the  Plan  are  those  of  15  000  p.e. 

within  Chapter  5  "Summary  of  PoM",  where  it  is  stated:  The  starting  point  for 
planning supplementary measures is the status of water that can be expected after all 

basic measures have been implemented, regardless of their implementation time.  

The  described  approach  has  been  made  operational  by  analysing  the  two  main 

scenarios  for  controlling/reducing  pollutant  emissions  and  quantifying  the  effects  of 
these  scenarios  on  water  status.  Scenario  1  contains  the  basic  measures  for 

controlling/reducing emissions that will be implemented by 2021. Including:  

(a)  construction  and  upgrading  of  municipal  wastewater  collection  and  purification 

systems  for  all  agglomerations  of  more  than  15  000  p.e.  and  all  agglomerations  of 
more than 10 000 p.e., which discharge waste water into a sensitive area, according to 

the water-utility Directive implementation plan and other current plans and programs 
(i.e.  project  'Inland  water',  'Adriatic  project',  'ISPA'  and  'IPA'  projects  and  other 

national projects);  

(b)  complete  alignment  of  industrial/technological  waste  water  discharge  with  the 

prescribed standards (Ordinance on the limit values for waste water) for all IPPC/IED 
plants  and  other  industrial  and  other  plants  for  which  a  waste  water  discharge  is 

issued;  

(c)  consistent  application  of  the  applicable  regulations  governing  the  production, 

circulation  and  use  of  chemicals,  including  biocidal  products  and  plant  protection 
products, which prescribe a prohibition or restriction for most of the priority and other 

pollutants to assess the chemical status of water;  

(d)  consistent  application  of  the  measures  for  the  implementation  of  the  Nitrates 

Directive.  

129 

 
Scenario  2:  starts  with  the  same  set  of  regulations  as  Scenario  1  and  implies  their 
complete implementation, regardless of allowed adjustment periods. It includes:  

(a)  building  and  upgrading  systems  for  collecting  and  appropriate  treatment  of 
municipal wastewater for all agglomerations covered by the Water-Utilities Directive 

Implementation  Plan  (294  agglomerations  greater  than  2  000  p.e.  according  to  the 
estimated current potential load)  - alignment with the 'Ordinance on the limit values 

for  waste  water'  for  all  existing  waste  water  treatment  plants  (IPPC/IED  and  other 
installations);  

(b) implementation of the Action Program for the reduction of pollution of nutrients 
from agricultural production in vulnerable areas;  

(c)  consistent  alignment  with  European  regulations  regulating  the  production, 
circulation  and  use  of  chemicals,  including  biocides  and  plant  protection  products, 

provided that no forbidden active substances for the assessment of chemical status of 
water will be renewed in the future.  

The measures relate to the control of both point and diffuse sources of pollution and 
their effects on the improvement of physico-chemical and chemical elements of water 

quality.  In conclusion, the RBMP does  not  consider stringent  treatment  for very big 
urban  agglomerations,  probably  because  all  types  of  agglomerations  (regardless  of 

size) will get the same degree of implementation of measures until at least good water 
status is achieved. This recommendation is not considered fulfilled. 

  Recommendation:  “Assess  the  need  to  take  additional  measures  on  point  source 
pollution  beyond  the  requirements  of  the  UWWTD  and  IED  to  fulfil  the  WFD 

objectives.” 

Assessment:  The  RBMP  indicates  in  general  terms  that  for  water  bodies  that  are 

assessed as not achieving good status after the implementation of the basic measures, 
supplementary  measures  will  be  applied.  The  selection  of  supplementary  measures 

and  their  implementation  obligation  will  follow  after  investigative  monitoring.  In 
addition, a detailed water status analysis will check the effects of basic measures for 

all  sources  of  pollution  affecting  the  status  of  these  water  bodies.  Supplementary 
measures  include:  (a)  A  supplementary  measure  of  the  monitoring  of  water  status; 

and, (b) Supplementary Control Measures for Point and Diffuse Sources of Pollution. 
This  recommendation  cannot  be  considered  fulfilled  because  the  assessment 
(additional monitoring) has not yet been carried out. 

130 

 
 
Topic 13

  Measures related to hydromorphology  

13.1 Assessment of implementation and compliance with WFD requirements 

in the second RBMP 

Significant  hydromorphological  pressures  are  reported  for  both  RBDs.  The  significant 
hydromorphological  pressures  are  assigned  to  specific  sectors,  especially  flood  protection, 

agriculture, navigation and hydropower. However, there is also a significant number of water 
bodies  where  the  sector/driver  is  indicated  as  "other",  i.e.  not  specified  as  one  of  the  key 

sectors in the WISE reporting. 

Operational  KTM  to  address  the  significant  hydromorphological  pressures  are  reported  for 

both RBDs, but the only KTM reported in this respect is KTM 14 - "Research, improvement of 
knowledge  base  reducing  uncertainty".  KTM  5  -  "Improving  longitudinal  continuity  (e.g. 
establishing  fish  passes,  demolishing  old  dams61)"  is  not  reported,  quantitative  management 
objectives in terms of river continuity are reported as established in both RBDs.  

According  to  information  in  the RBMP,  hydromorphological  pressures  are  not  addressed  yet 
by  specific  technical  measures.  The  only  measures  planned  are  related  to  monitoring  and 

research.  Almost  half  of  the  hydromorphologically  degraded  surface  water  bodies  have  been 
identified  as  artificial  water  bodies  or  heavily  modified  water  bodies.  Measures  to  partially 

mitigate  hydromorphological  impacts  related  to  artificial  water  bodies  and  heavily  modified 
water  bodies  will  be  planned  after  defining  the  standards  for  assessing  their  ecological 

potential (a process which is still ongoing). For the remaining hydromorphologically degraded 
water bodies, restoration measures will be planned after performing specific biological studies 

to check the impact of the modified hydromorphological elements on status. 

In  terms  of  basic  measures,  there  is  an  authorisation  and/or  permitting  regime  in  place  to 

control physical modifications in all RBDs, which covers changes to the riparian area of water 
bodies according to WFD62 article 11(3)(i) in both RBDs. There is also a register of physical 
modifications of water bodies. 

61 Croatia subsequently clarified that the demolishing of old dams is included in the RBMP, although it was not 

reported in WISE. 

62   Directive  2000/60/EC  of  the  European  Parliament  and  of  the  Council  establishing  a  framework  for  the 
http://eur-lex.europa.eu/legal-
of 

policy 

water 

field 

in 

Community 
content/EN/TXT/?uri=CELEX:32000L0060 

action 

the 

131 

 
                                                      
Win-win  measures  in  terms  of  achieving  the  objectives  of  the  WFD  and  Floods  Directive63, 
drought management and use of Natural Water Retention Measures (NWRM) are reported to 

be  included  in  the  Programme  of  Measures  of  both  RBDs.  The  design  of  new  and  existing 
structural measures, such as flood defences, storage dams and tidal barriers, is also reported to 

have been adapted to take into account WFD objectives in both RBDs. 

Ecological flows have not been derived for the relevant water bodies in any of the RBDs but 
there are plans to do it during the period of the second RBMP. The RBMP mention ecological 
flows  in  the  context  of  future  measures  (under  the  second  RBMP)  but  they  do  not  explicitly 
clarify  the  timeframe  of  these  measures.  The  activities  on  ecological  flows  are  ongoing  and 
awaiting the completion of relevant research. 

Indicators on the gap to be filled for significant hydromorphological pressures are reported for 
2015 and 2021 but not for 2027. From the information available, it can be concluded that there 

will  be  some  minor  reduction 
length  or  number  of  water  bodies  where 
hydromorphological  alterations  are  preventing  the  achievement  of  objectives  until  2021. 

the 

in 

However, it is unclear how this will be achieved, considering that the only measures reported 
to tackle hydromorphology are related to research studies. 

13.2 Main changes in implementation and compliance since the first RBMP 

In the first RBMP, measures for existing hydromorphological pressures were not included. In 

the second RBMP, hydromorphological pressures are still not addressed by specific technical 
measures, as the only activities planned are related to research and monitoring. 

13.3 Progress with Commission recommendations 

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

  Recommendation  (report  2012):  Review  existing  controls  to  ensure  that  agricultural 
practices  do  not  cause  hydromorphological  pressure  and  update  controls  where 
necessary for inclusion in the Programme of Measures of the second RBMP.  

Assessment:  No  specific  information  was  found  in  the  second  RBMP,  specifically 
clarifying  whether  controls  for  impacts  of  agriculture  on  morphology  (controls  on 
drainage,  protecting  the  bank  structure,  etc.)  exist.  The  category  of  "measures  for 

control  and  decrease  of  hydromorphological  impacts  on  waters"  does  not  refer  to 

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

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

132 

 
                                                      
agriculture but it is noted in the description of measures of a generic nature. Most of the 
measures are of research/monitoring/advisory type. Therefore, based on the information 

found, the recommendation is not fulfilled. 

  Recommendation:  Include  hydromorphological  measures  in  the  Programme  of 

Measures of the second RBMP. 

Assessment: In the second RBMP, hydromorphological pressures are still not addressed 
by specific technical measures, as the only activities planned are related to research and 
monitoring.  Croatia  subsequently  informed  that  for  determining  measures  for  the 

reduction  of  hydromorphological  pressures,  it  is  required  to  establish  quality 
connections  between  biological  and  hydromorphological  water  status  indicators. 

Research  projects  in  this  respect  are  ongoing.  Therefore,  this  recommendation  is  not 
fully fulfilled.  

  Recommendation:  Ensure  that  an  ecological  flow  consistent  with  good  status  is 

established and review the existing permits where relevant. 

Assessment: Ecological flows have not been derived yet for relevant water bodies but 
there are plans to do so in the period of the second RBMP. A systematic review of all 

existing  permits  and  checking  their  compatibility  with  the  WFD  was  announced  by 
Croatia for the first half of 2017. The RBMP states that a measure of control and issue 

of water right permits for abstraction and use of water is under implementation as well 
as  a  measure  related  to  the  improvement  of  the  register  of  issued  water  right  permits 

and concessions. As related activities are still ongoing, this recommendation is not fully 
fulfilled. 

  Recommendation:  Consider  and  prioritise  the  use  of  green  infrastructure  and/or 
natural water retention measures that provide a range of environmental (improvements 
in  water  quality,  flood  protection,  habitat  conservation  etc.),  social  and  economic 

benefits which can be in many cases more cost-effective than grey infrastructure. 

Assessment: KTM23 – “Natural Water Retention Measures” has not been applied in the 
second RBMP and none of the RBMP and background documents includes information 
on  Natural  Water  Retention  Measures.  Some  information  on  measures  regarding 
natural  retention  and  flood  areas  can  be  found  in  the  Flood  Risk  Management  Plan 

which, in Croatia, is integrated with the RBMP. Overall, however, as there is no direct 
reference to the consideration of Natural Water Retention Measures in the RBMP, this 
recommendation is not fully fulfilled. 

133 

 
  Recommendation  (report  2015):  Review  all  existing  permits  and  where  necessary, 

amend them to ensure that they are compatible with the WFD objectives. 

Assessment:  As  mentioned  above,  a  systematic  review  of  all  existing  permits  and 
checking their compatibility with the WFD was announced by Croatia for the first half 

of 2017. The RBMP states that a measure of control and issue of water right permits for 
abstraction and use of water is under implementation as well as a measure related to the 

improvement of the register of issued water right permits and concessions. As related 
activities are still ongoing, this recommendation is not yet fulfilled. 

134 

 
 
Topic 14

  Economic analysis and water pricing policies  

14.1 Assessment of implementation and compliance with WFD requirements 
in  the  second  RBMP  and  main  changes  in  implementation  and 
compliance 

There are some changes since the first RBMP in Croatia. Water services are defined 

as "public water supply" and "water collection services". At the moment, Croatia has 
no plans to  apply  a broader definition. The application of Article 9(4) is  reported in 

WISE  for  a  long  list  of  "other"  water  services  (urban  development,  industry, 
agriculture, aquaculture, recreation, flood protection, hydropower, transport, other).  

In both the Danube and the Adriatic RBDs, the cost recovery rate stands at 75 %. For 
each  RBD,  information  is  provided  on  the  percentage  of  cost  recovery  by  sector, 

which in this case includes population/households, industry and agriculture. 

The  rate  is  based  on  volumetric  charging  and  environmental  and  resource  costs  are 

stated to be calculated and internalised.  

The  RBMP  claims  that  the  established  mechanisms  ensure  adequate  contribution  of 

water users to cost recovery for water services, including environmental and resource 
costs, and also taking into account the Polluter Pays Principle.  

For eight water uses, the environmental and resource costs are described in a mostly 
quantitative way;  where  cost  recovery  of environmental  and  resource costs does not 

100  % 

reach 
recreation/transport/others), it is planned to do so for the 3rd RBMP. 

(agriculture, 

irrigation, 

fisheries 

and 

aquaculture, 

Additional incentive pricing measures are foreseen in the updated Water Services Act, 
including generalisation of metering for all uses (amendment planned for adoption by 

the end of 2016).  

The economic analysis is reported as updated. 

14.2 Progress with Commission recommendations 

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

135 

 
  Recommendation:  Develop  fully  the  economic  analysis  of  water  use,  including  the 
calculation of Environmental and Resource Costs and ensure that the water tariff and 

the water fees lead to adequate recovery of the costs of water services. Measures that 
foster introduction of individual metering where shared metering is in place should be 

proposed. 

Assessment: The Water Act defines water services as "public water supply" and "water 

collection services". Article 3(29) of the Water Act defines water supply as abstraction 
(from  surface  and/or  groundwater),  treatment  and  distribution.  Article 3(28)  defines 

water collection as wastewater collection and treatment.  

The  application  of  WFD  Article  9(4)  is  reported  in  WISE  for  a  long  list  of  "other" 

water services (urban development, industry, agriculture, aquaculture, recreation, flood 
protection, hydroenergy, transport, other).  

At the moment, Croatia has no plans to apply a broader definition of water services and 
refers to the outcome of Case C-525/1264 before the European Court of Justice between 
the  European  Commission  and  Germany  on  the  question  of  inadequate  cost  recovery 
from water services. 

In  both  RBDs  the  cost  recovery  rate  stands  at  75  %.  For  each  RBD,  information  is 
provided on cost recovery by sector, which in this case includes population/households, 

industry and agriculture. 

The  rate  is  based  on  volumetric  charging  and  environmental  and  resource  costs  are 

stated to be calculated and internalised.  

The RBMP claims that the established mechanisms are ensuring adequate contribution 

of  water  users  to  cost  recovery  for  water  services,  including  environmental  and 
resource costs, and also taking into account the Polluter Pays Principle. 

The  description  of  the  methodologies  used  is  presented  in  a  background  document 
called "Economic Analysis - The basis for RBMP 2016-2021". The document contains 

an economic analysis of water uses and covers the calculation/estimate of cost recovery 
from  water  services  (including  environmental  and  resource  costs)  as  well  as  the 

calculation/estimate of the contributions of significant water users to environmental and 
resource costs.  

64   https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A62012CJ0525  

136 

 
                                                      
For  eight  water  uses,  the  environmental  and  resource  costs  are  described  in  a  mostly 
quantitative  way;  where  cost  recovery  of  environmental  and  resource  costs  does  not 

100  % 

reach 
and 
recreation/transport/others),65 it is planned so for the third cycle RBMP: 

(agriculture, 

irrigation, 

fisheries 

aquaculture, 

Industry, 

-  Urban development, 
- 
-  Flood protection,  
-  Hydropower,  
-  Agriculture, 
- 
Irrigation,  
-  Fisheries and aquaculture,  
-  Recreation, transport and various others. 

The  methodologies  and  conclusions  are  not  entirely  clear,  but  it  seems  that 
environmental  and  resource  costs  are  calculated  using  a  cost-based  approach  for  the 

defined water services, i.e. considering the costs of measures to reduce impacts on the 
water environment. Environmental and resource costs are considered to have been fully 

internalised via existing policy instruments (e.g. wastewater charges, water abstraction 
charges, licensing regimes, planning processes).  

Additional incentive pricing measures are foreseen in the updated Water Services Act, 
including generalisation of metering for all uses (amendment planned for adoption by 

the end of 2016). 

The recommendation is therefore partially fulfilled. 

  Recommendation:  Ensure  that  abstraction  controls  are  in  place  by  the  time  of  the 

second RBMPs. 

Assessment: In Croatia water pricing in agriculture, including self-abstraction, applies 
volumetric  charges  on  the  basis  of  metering.  Agriculture  users  that  hold  a  water  use 
permit or a concession are required to measure their water consumption. For agriculture 
users that do not measure their water use, the quantities are estimated according to the 

agricultural land area managed by the user.  

65   Croatia  subsequently  clarified  that  the  fact  that  cost  recovery  of  environmental  and  resource  costs  does  not 
reach 100 % (agriculture, irrigation, fisheries and aquaculture, recreation/transport/others) was detected during 
the preparation of River Basin Management Plan, and therefore measures 15, 16, 17, 18 and 19, as given in the 
PoM, were foreseen to address the issue. 

137 

 
                                                      
The  Water  Act  sets  out  that  a  person  may  freely  use  small  water  springs  and 
groundwater on their land provided that these do not breach the rules on general use of 

water issued by local authorities. Only those persons required to obtain a permit (or a 
concession agreement) by the Water Act are required to carry out metering. 

The  RBMP  concludes  that  in  practice  significant  quantities  of  water  are  used  for 
agriculture without any control and that this may have consequences on the local water 

conditions (availability and status).  

Additional incentive pricing measures are foreseen in the updated Water Act, including 

generalisation of metering for all uses (amendment was planned for adoption by the end 
of 2016 and was updated in 2018). 

The  recommendation  was  partially  fulfilled  at  the  time  of  publication  of  the  second 
RBMP.  

138 

 
 
 
Topic 15

  Considerations 

specific 

to 

Protected 

Areas 

(identification, monitoring, objectives and measures) 

15.1 Assessment of implementation and compliance with WFD requirements 

in the second RBMP 

Surface water Protected Area types have been identified for all relevant Directives in Croatia 

for  the  second  cycle  (Table  15.1)  (WFD  Article  7,  Bathing  Water,  Birds,  Habitats,  Nitrates, 
Urban  Waste  Water  and  for  economically  significant  aquatic  species  (fish  and  shellfish). 

Protected Areas associated with groundwater bodies have also been identified for all relevant 
Directives (WFD Article 7, Habitats, Birds and Nitrates). The status of waterbodies associated 

with Protected Areas is also reported (Figure 15.1).  

Table 15.1 

Number of Protected Areas of all types in each RBD of Croatia associated 

with for surface and groundwater 

Protected Area type 

Abstraction of water intended for 
human consumption under Article 7 

Recreational waters, including areas 
designated as bathing waters under 
Directive 76/160/EEC67 

Protection of species where the 
maintenance or improvement of the 
status of water is an important factor 
in their protection, including relevant 
Natura 2000 sites designated under 
Directive 79/409/EEC (Birds)68 

Protection of habitats or species where 
the maintenance or improvement of 
the status of water is an important 
factor in their protection, including 
relevant Natura 2000 sites designated 
under Directive 92/43/EEC 
(Habitats)69 

Nutrient-sensitive areas, including 
areas designated as vulnerable zones 

Number of Protected Areas Associated with66 

Rivers 

Lakes 

Transitional 

Coastal 

Groundwater 

22 

4 

1 

1 

24 (30) 

876 (882) 

227 (240) 

26 

13 

5 

3 

27 

243 

20 

12 (13) 

224 

540 

11 

2 

1 

11 

66   Croatia subsequently informed the Commission that the reported information in WISE was not accurate. The 

data in brackets is the corrected data supplied by Croatia. 

67   Directive  2006/7/EC  of  the  European  Parliament  and  of  the  Council  of  15  February  2006  concerning  the 
management  of  bathing  water  quality  and  repealing  Directive  76/160/EEC  http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32006L0007 

68   Directive 2009/147/EC of the European Parliament and of the Council of 30 November 2009 on the 
conservation of wild birds http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009L0147 
69   Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and 

flora http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31992L0043 

139 

 
 
 
 
 
                                                      
Protected Area type 

under Directive 91/676/EEC (Nitrates 
Directive70) 

Nutrient-sensitive areas designated as 
sensitive areas under Directive 
91/271/EEC (Urban Wastewater 
Treatment Directive71) 

Areas designated for the protection of 
economically significant aquatic 
species 

Other 

Number of Protected Areas Associated with66 

Rivers 

Lakes 

Transitional 

Coastal 

Groundwater 

20 

2 

43 

77 

1 

10 

8 

7 

7 (8) 

57 

15 

15 

131 

Source: Member States reporting to WISE 

A  good  overview  of  the  status  of  water  bodies  associated  with  Protected  Areas  is  reported 
(Figure 15.1) with the status classification reported with mostly low or medium confidence. 

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

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

71   Council Directive 91/271/EEC of 21 May 1991 concerning urban waste-water treatment http://eur-

lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31991L0271 

140 

 
 
 
 
 
 
 
                                                      
Ecological

status/potential

Surface water

chemical status

Groundwater

quantitative status

Groundwater

chemical status

0%

20%

40%

60%

80%

100%

88%

90%

92%

94%

96%

98%

100%

95%

96%

97%

98%

99%

100%

0%

20%

40%

60%

80%

100%

Percentage of water bodies with Protected Areas 

Failing to achieve good

High

Good

Poor

Bad

Moderate

Unknown

Good

Unknown

Good

Poor

Unknown

Good

Poor

Unknown

Figure 15.1  Status  of  water  bodies  associated  with  Protected  Areas  for  Croatia.  Note: 
based  on  status/potential  aggregated  for  all  water  bodies  associated  with  all 

Protected Areas 

Source: WISE electronic reporting 

Regarding  the  setting  of  specific  objectives,  only  the  Protected  Areas  designated  for 
economically  significant  species  (shellfish)  have  had  specific  objectives  set.  For  all  other 

Protected  Area  types,  either  no  objectives  were  set  (WFD  Article  7  Protected  Areas  –  both 
surface  and  groundwater  abstraction)  or  it  is  stated  that  the  achievement  of  good  ecological 
status is also sufficient to meet the objectives of the specified directive (Birds and Habitats).  

Monitoring sites of surface water associated with Protected Areas are only reported for those 

under Article 7 of the WFD, the Nitrates and Habitats Directives and for areas designated for 
shellfish  (Table  15.2).  Similarly,  no  data  are  reported  on  monitoring  sites  of  groundwater 

associated with Protected Areas, except for those under Article 7 of the WFD, the Nitrates and 
Habitats Directives. Further information on the purpose of monitoring sites for surface water 
and groundwater status assessment can be found in Chapters 3 to 6 of this report. 

141 

 
 
 
 
 
There are gaps in the reported monitoring programmes for designated Protected Areas on the 
basis of the monitoring sites associated with them and the number of monitoring sites is low in 

relation to the number of Protected Areas reported.  

Table 15.2  Number of monitoring sites associated with Protected Areas in Croatia. 

Protected Area type 

Abstraction of water intended for 
human consumption under 
Article 7 

Nutrient-sensitive areas, 
including areas designated as 
vulnerable zones under Directive 
91/676/EEC (Nitrates Directive) 

Protection of habitats or species 
where the maintenance or 
improvement of the status of 
water is an important factor in 
their protection, including 
relevant Natura 2000 sites 
designated under Directive 
92/43/EEC (Habitats) 

Areas designated for the 
protection of economically 
significant aquatic species 

Number of monitoring sites associated with Protected Areas in 

Rivers 

Lakes 

Transitional 

Coastal 

Groundwater 

1 

52 

189 

1 

8 

286 

126 

42 

13 

278 

6 

9 

Source: WISE electronic reporting 

Exemptions  under  Article  4(4),  justified  on  the  grounds  of  disproportionate  costs,  have  been 

applied  to  water  bodies  associated  with  nearly  20  %  of  Protected  Areas  and  for  all  types  of 
Protected Areas except Drinking Water areas and Bathing Waters, for which no exemptions are 

applied. 

15.2 Main changes in implementation and compliance since the first RBMP 

Croatia reports fewer Protected Areas in the second RBMP (2464) compared to the first RBMP 
(over 2700): there are fewer Drinking Water Protected Areas but more areas designated under 

the Habitats Directive. All types of Protected Areas were reported in both cycles. Croatia did 
not report information to WISE, nor in the first RBMP, on monitoring programmes for types of 

Protected  Areas.  Such  information  is  reported  in  the  second  RBMP,  although  not  for  all 
Protected Area types. Croatia reported no information on additional objectives and measures in 

the first cycle and there has been little progress in this regard for the second RBMPs.  

142 

 
 
 
 
 
 
 
 
 
 
15.3 Progress with Commission recommendations 

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

requested action on the following: 

  Recommendation: Croatia should set additional objectives for protected areas, monitor 
them  and  assess  what  additional  measures  are  required  to  achieve  those  additional 
objectives (Species and Habitats, Drinking Water, Bathing Water). 

Assessment:  The  reported  data  from  the  second  cycle  RBMP  shows  that  additional 
objectives  have  only  been  set  for  Protected  Areas  designated  for  shellfish.  Moreover, 

for  Drinking  Water  Protected  Areas  (both  surface  and  groundwater)  no  additional 
objectives  have  been  set72  and  for  Birds  and  Habitat  Directives  it  is  stated  that  the 
achievement  of  Good  Ecological  status  is  assumed  to  be  sufficient  to  also  fulfil  the 
objectives  of  the  other  directives.  Monitoring  programmes  for  all  reported  Protected 

Area types have not been reported and the number of monitoring sites reported is low 
in  relation  to  the  number  of  Protected  Areas.  The  information  reported  in  relation  to 
additional measures is unclear73. 

The recommendation has been partially fulfilled. 

73   Croatia subsequently highlighted that the implementation of supplementary measures in Croatia is obligatory, 
i.e. they are implemented just like basic measures. Croatia stated that for the protected areas, it is foreseen to 
implement measures in addition to the basic measures. 

143 

 
 
                                                      
 
 
Topic 16

  Adaptation to drought and climate change 

16.1 Assessment of implementation and compliance with WFD requirements 

in the second RBMP 

Climate  change  was  considered  in  both  RBDs  but  it  is  stated  that  the  guidance  on  how  to 
adapt to climate change (Common Implementation Policy Guidance Document No. 2474) was 
not used. Climate change is also mentioned as a driver for exemptions under Article 4(4) for 
groundwater  in  the  Adriatic  RBD.  Climate  change  was  considered  only  when  detecting 

climate  change  signals  and  for  flood  risk  management.  KTM  24  -  "Adaptation  to  climate 
change" is not made operational to address significant pressures in the RBDs, although some 

national  measures  are  mapped  against  KTM  24  -  "Adaptation  to  climate  change"  in  both 
RBDs. No specific sub-plans addressing climate change are reported.  

No  information  is  reported  regarding  the  relevance  of  droughts  in  Croatia.  No  exemptions 
have been applied following Article 4(6) due to prolonged droughts. 

No Drought Management Plans have been reported for Croatia. 

16.2 Main changes in implementation and compliance since the first RBMP 

Croatia has only considered climate change in  a very limited way in the first RBMP and the 
situation has not changed. For example, climate proofing of measures was not done in either 

the first or second RBMPs. No assessment can be made for droughts, as there is no information 
from the first RBMP. 

16.3 Progress with Commission recommendations 

There was no Commission recommendation based on the first RBMP and first Programme of 

Measures relating to this topic.  

74   https://circabc.europa.eu/sd/a/a88369ef-df4d-43b1-8c8c-
306ac7c2d6e1/Guidance%20document%20n%2024%20-
%20River%20Basin%20Management%20in%20a%20Changing%20Climate_FINAL.pdf  

144