COMMISSION STAFF WORKING DOCUMENT Second River Basin Management Plans - Member State: Denmark 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: Denmark, 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) 38 final  COMMISSION STAFF WORKING DOCUMENT Second River Basin Management Plans - Member State: Denmark 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) 39 final} - {SWD(2019) 40 final} - {SWD(2019) 41 final} - {SWD(2019) 42 final} - {SWD(2019) 43 final} - {SWD(2019) 44 final} - {SWD(2019) 45 final} - {SWD(2019) 46 final} - {SWD(2019) 47 final} - {SWD(2019) 48 final} - {SWD(2019) 49 final} - {SWD(2019) 50 final} - {SWD(2019) 51 final} - {SWD(2019) 52 final} - {SWD(2019) 53 final} - {SWD(2019) 54 final} - {SWD(2019) 55 final} - {SWD(2019) 56 final} - {SWD(2019) 57 final} - {SWD(2019) 58 final} - {SWD(2019) 59 final} - {SWD(2019) 60 final} - {SWD(2019) 61 final} - {SWD(2019) 62 final} - {SWD(2019) 63 final} - {SWD(2019) 64 final} - {SWD(2019) 65 final} - {SWD(2019) 66 final} - {SWD(2019) 67 final} - {SWD(2019) 68 final} - {SWD(2019) 69 final} - {SWD(2019) 70 final} - {SWD(2019) 71 final} - {SWD(2019) 72 final} - {SWD(2019) 73 final} - {SWD(2019) 74 final} - {SWD(2019) 75 final} - {SWD(2019) 76 final} - {SWD(2019) 77 final} - {SWD(2019) 78 final} - {SWD(2019) 79 final} - {SWD(2019) 80 final} - 
 
 
Table of contents 
Acronyms and definitions ............................................................................................................. 4 

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

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

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

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

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

Topic 1

  Governance and public participation ....................................................................... 21 

1.1  Assessment of implementation and compliance with WFD requirements in second 
cycle   ...................................................................................................................................... 21 

1.2  Main changes in implementation and compliance since first cycle ............................. 23 

1.3  Progress with Commission recommendations .............................................................. 23 

Topic 2 Characterisation of the River Basin District ................................................................ 24 

2.1.  Assessment of implementation and compliance with the WFD requirements in the 
second cycle ............................................................................................................................ 24 

2.2.  Main changes in implementation and compliance since the first cycle ....................... 35 

2.3.  Progress with Commission recommendations .............................................................. 36 

Topic 3 Monitoring, assessment and classification of ecological status in surface water bodies
.................................................................................................................................................... 38 

3.1.  Assessment of implementation and compliance with WFD requirements in second 
RBMPs.................................................................................................................................... 38 

3.2.  Main changes in implementation and compliance since first RBMPs ......................... 61 

3.3.  Progress with Commission recommendations .............................................................. 62 

Topic 4 Monitoring, assessment and classification of chemical status in surface water bodies66 

4.1.  Assessment of implementation and compliance with WFD requirements in second 
cycle   ...................................................................................................................................... 66 

4.2.  Main changes in implementation and compliance since first cycle ............................. 80 

4.3.  Progress with Commission recommendations .............................................................. 81 

Topic 5 Monitoring, assessment and classification of quantitative status of groundwater bodies
.................................................................................................................................................... 83 

5.1.  Assessment of implementation and compliance with the WFD requirements in the 
second cycle ............................................................................................................................ 83 

5.2.  Main changes in implementation and compliance since the first cycle ....................... 89 

5.3.  Progress with Commission recommendations .............................................................. 90 

Topic 6 Monitoring, assessment and classification of chemical status of groundwater bodies 92 

1 

 
 
 
6.1.  Assessment of implementation and compliance with the WFD requirements in the 
second cycle ............................................................................................................................ 92 

6.2.  Main changes in implementation and compliance since the first cycle ....................... 99 

6.3.  Progress with Commission recommendations ............................................................ 100 

Topic7 Designation of Heavily Modified and Artificial Water Bodies and definition of Good 
ecological potential .................................................................................................................. 102 

7.1.  Assessment of implementation and compliance with the WFD requirements in the 
second cycle for designation................................................................................................. 102 

7.2.  Main changes in implementation and compliance since the first cycle ..................... 104 

7.3.  Progress with Commission recommendations ............................................................ 105 

Topic 8 Environmental objectives and exemptions .................................................................. 107 

8.1.  Assessment of implementation and compliance with WFD requirements in second 
cycle   .................................................................................................................................... 107 

8.2.  Main changes in implementation and compliance since first cycle ........................... 111 

8.3.  Progress with Commission recommendations ............................................................ 111 

Topic 9 Programme of measures ............................................................................................. 113 

9.1.  Assessment of implementation and compliance with WFD requirements in second 
cycle   .................................................................................................................................... 113 

9.2.  Main changes in implementation and compliance since first cycle ........................... 119 

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

Topic 10 Measures related to abstractions and water scarcity ............................................... 121 

10.1.  Assessment of implementation and compliance with the WFD requirements in the 
second cycle and main changes in implementation and compliance since the first cycle .... 121 

10.2. 

Progress with Commission recommendations ........................................................ 122 

Topic 11 Measures related to pollution from agriculture ....................................................... 123 

11.1.  Assessment of implementation and compliance with the WFD requirements in the 
second cycle and main changes in implementation and compliance since the first cycle .... 123 

11.2.  Main changes in implementation and compliance since first cycle ........................ 124 

11.3. 

Progress with Commission recommendations ........................................................ 125 

Topic 12 Measures related to pollution from sectors other than agriculture.......................... 126 

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

 ................................................................................................................................. 126 

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

12.3. 

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

Topic 13 Measures related to hydromorphology ..................................................................... 129 

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

 ................................................................................................................................. 129 

2 

 
13.2.  Main changes in implementation and compliance since first cycle ........................ 130 

13.3. 

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

Topic 14 Economic analysis and water pricing policies ......................................................... 132 

14.1.  Assessment of implementation and compliance with the WFD requirements in the 
second cycle and main changes in implementation and compliance since the first cycle .... 132 

14.2. 

Progress with Commission recommendations ........................................................ 133 

Topic 15 Considerations specific to Protected Areas (identification, monitoring, objectives and 
measures) ................................................................................................................................. 135 

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

15.2.  Main changes in implementation and compliance since the first cycle .................. 138 

15.3. 

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

Topic 16 Adaptation to drought and climate change ............................................................... 140 

16.1.  Assessment of implementation and compliance with the WFD requirements in the 
second cycle .......................................................................................................................... 140 

16.2.  Main changes in implementation and compliance since the first cycle .................. 140 

16.3. 

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

3 

 
Acronyms and definitions 

EQS Directive 

Environmental Quality Standards Directive 

FD 

Km 

km2 

KTM 

PoM 

Floods Directive 

Kilometre 

Kilometre squared 

Key Type of Measure 

Programme of Measures 

QA/QC Directive 

Quality Assurance / Quality Control Directive  

RBD 

RBMP 

WFD 

WISE 

Annex 0 

River Basin District 

River Basin Management Plan 

Water Framework Directive 

Water Information System for Europe 

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

4 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Foreword 

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

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

2015 and reported to the European Commission in March 2016. 

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

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

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

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

5 

 
 
 
 
General Information 

The Danish  population  is 5.6 million (the exact number on 1 January 2012 was  5 560 628)1.  
Denmark has a total area of 43 321 km2. Denmark’s RBDs are shown in Map A. 

Map A   Map of RBDs 

Source: 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 

Denmark  has  one  international  RBD  (Vidå-Kruså)  shared  with  Germany.  The  international 
RBD  shared  with  Germany  is  not  jointly  designated.  There  is  more  than  one  transboundary 

river basin in the RBDs. 

1 Eurostat: 

http://epp.eurostat.ec.europa.eu/tgm/table.do?tab=table&language=en&pcode=tps00001&tableSelection=1&f
ootnotes=yes&labeling=labels&plugin=1 

6 

DE9500DE5000SE5DE9610DE9650PL6000NO5103SE4SE5050100kmDK1DK1DK2DK3DK4DKBaltic SeaSkagerrakKattegatNorthSea 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
The  areas  of  the  national  RBDs  including  sharing  countries  is  provided  in  Table  A  and 

Denmark’s share of the international RBD is shown in Table B. 

Table A Overview of Denmark’s RBDs  

RBD 

DK1 

DK2 

DK3 

DK4 

Name 

Jutland and Funen 

Zealand 

Bornholm 

Size (km2) 
(Area including coastal waters 
shown in brackets) 

Countries 
sharing RBD 

32 040 (44 898) 

9 280 (16 364) 

602 (825) 

- 

- 

- 

International (Vidå-Kruså) 

1 100 (1 305) 

DE 

Source: RBMPs reported to WISE  

Table B Transboundary RBDs by category and % share in Denmark 

Name international 
RBD 

National 
RBD 

Krusaa/Krusau 

Vidaa/Wiedau (Rudboel 
Soe/Ruttebüller See) 

DK4 

DK4 

Countries 
sharing 
borders 

DE 

DE 

Co-ordination category 

3 

km² 

15 

1081 

% 

71.4 

80.5 

Source: WISE electronic reports  

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

7 

 
 
 
Status of second river basin management plan reporting 

A  total  of  four  RBMPs  of  Denmark  (Jutland  and  Funen,  Zealand,  Bornholm,  International 

Vidå-Kruså)  were  published  on  27  June  2016.  Documents  are  available  from  the  European 
Environment Agency (EEA) EIONET Central Data Repository https://cdr.eionet.europa.eu/.  

8 

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

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

 

Governance and public consultation 

 

A  broad  range  of  stakeholder  groups  were  actively  involved  in  the  preparation  of 

Denmark’s RBMPs, including via advisory groups. 

 

 

Denmark and Germany have agreed to strengthen coordination in the iRBD. 

Denmark  did  not  adopt  and  publish  the RBMPs in  accordance  with  the  timetable  in 
the Water Framework Directive. 

 

Characterisation of the RBD 

 

Significant changes in the delineation of small water bodies and heavily modified and 

artificial  water  bodies  may  lead  to  issues  with  the  comparability  of  pressures  and 
status between cycles. 

 

 

 

Several of the national types for Denmark in all of the RBDs do not appear to have 
corresponding intercalibration types. 

Type  specific  reference  conditions  have  been  established  for  some  of  the  relevant 
biological  quality elements  in  most  water body types,  and for  all relevant  biological 

quality  elements  in  the  others.  Type  specific  reference  conditions  have  not  been 
established  for  physicochemical  quality  elements  or  hydromorphological  quality 

elements. 

There have been some improvements in the assessment of significant pressures since 
the  first  RBMPs,  with  the  development  of  new  models.  For  both  surface  and 
groundwater,  the  significance  of  pressures  was  reported  to  be  defined  in  terms  of 

thresholds and linked to the potential failure of objectives. 

 

For the second RBMPs, there is no data reported on which significant pressures were 

not assessed for surface waters or groundwater. “Anthropogenic pressure - Unknown” 

was  identified  for  25  %  of  groundwater  bodies,  which  may  indicate  some 
inadequacies in the methodologies used to assess pressures and impacts. Some of the 

9 

 
tools  for  assessing  certain  pressures  could  be  improved  (e.g.  hydromorphological 

pressures and quantitative pressures on groundwater). 

 

Denmark reported inventories for all RBDs, each one including 19 of the 41 Priority 

Substances. According to the RBMPs, the substances not included in the inventories 
are not used in Denmark or screening has shown that they do not occur in significant 

quantities.  The  CIS  Guidance  Document  recommends  providing  basic  estimation  of 
emissions,  including  for  these  substances  of  minor  importance,  which  has  not  been 

done. Tier 1 (point source information) was implemented for substances not relevant 
at  RBD  level,  and  Tier  2  (riverine  load)  was  used  for  other  substances,  while  the 

Guidance Document recommends using at least Tier 1+2 for the relevant substances. 
The data quality was not reported. 

  Monitoring, assessment and classification of ecological status  

 

The number of monitoring sites increased significantly since the first RBMPs, mostly 
due to a large increase in the number of operational monitoring sites in rivers. 

 

There  are  gaps  in  the  monitored  biological  quality  elements:  phytobenthos  are  not 

monitored in rivers and benthic invertebrates are not monitored in lakes. None of the 
water bodies included in surveillance monitoring were monitored for all the required 
biological, hydromorphological and physicochemical quality elements. 

 

15  River  Basin  Specific  Pollutants  were  monitored  in  all  relevant  water  categories 

(three in  coastal waters,  three in lakes and 13 in  rivers), but the percentage of water 
bodies  monitored  is  low.  Monitoring  in  coastal  waters  was  in  biota  only,  while  in 

surface freshwaters it was done in the water column and biota. River Basin Specific 
Pollutants were monitored at the minimum recommended frequency at some sites for 

surveillance monitoring but at no sites for operational monitoring. 

 

New  assessment  methods  have  been  developed  since  the  first  RBMPs  for 

macrophytes  and  fish  in  rivers  and  lakes.  The  remaining  gaps  are  phytobenthos  in 
rivers,  benthic  invertebrates  and  phytobenthos  in  lakes,  and  macroalgae  in  coastal 

waters. 

 

There is no biological quality element method which is sensitive to nutrients in rivers. 

10 

 
  Morphological  conditions  of  rivers  were  assessed 

in 

terms  of  ecological 

status/potential and their classification boundaries are related to the class boundaries 
for the sensitive biological quality elements. 

 

river  continuity  were  not  assessed2.  No 
Hydrological/tidal 
hydromorphological quality elements are used in the classification of status/potential. 

regime  and 

 

Standards  for  assessment  of  general  physicochemical  elements  are  reported  in 

supporting  documents  accompanying  the  RMBPs,  even  if  they  were  not  reported  to 
WISE. 

 

Environmental  Quality  Standards  values  were  reported  for  water  for  all  15  River 
Basin Specific Pollutants: 12 in rivers, three in lakes, as well as two in biota in coastal 

waters. The standards have been derived in accordance with Technical Guidance n. 27 
and the analytical methods used meet the minimum performance criteria laid down in 
Article 4(1) of the QA/QC Directive (2009/90/EC)3 for the strictest standard applied. 

 

River  Basin  Specific  Pollutants  are  used  for  the  classification  of  ecological  status 

where they are monitored in surface waters.  

 

The reported values show an increase in the total number of water bodies in less than 

good ecological status since the first RBMPs. Denmark’s analyse in the RBMPs states 

in  general  minor improvements  in  ecological status  for coastal waters and lakes and 
no changes for watercourses. Comparison between the two cycles should however be 
analysed  with  care,  considering  changes  in  delineation  of  water  bodies  and  in 

methodologies. 

 

The number of natural water bodies with unknown ecological status has significantly 

decreased  since  the  first  RBMP,  which  is  an  improvement.  However,  there  is  still  a 

significant number of water bodies reported with unknown ecological status (20% for 
lakes,  23  %  for  rivers4),  with  the  exception  of  coastal  waters,  which  were  always 
classified for ecological status, while 54% of coastal water bodies had unknown status 
in the first RBMPs. 

2    Denmark  subsequently  stated  that  hydromorphological  elements,  including  tidal  regime,  were  applied  in  the 

definition of typology for coastal waters. 

3   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  

4   Denmark subsequently stated that the correct number is 11 % for rivers. 

11 

 
                                                      
 

The confidence in classification is high for all coastal water bodies and for the large 

majority of rivers and lakes where the overall ecological status/potential is classified. 
There  are  no  water  bodies  classified  with  low  confidence.  This  is  a  major 

improvement  compared  to  the  first  RBMPs,  in  which  there  was  no  information  on 
confidence for more than 95 % of the river and lake water bodies.  

 

The one-out, all-out principle is reported as having been used in all RBDs, but has not 
included the supporting quality elements (except nutrient in lakes). 

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

 

Between  the  two  RBMPs,  the  proportion  of  unknown,  good  and  failing  to  achieve 

good chemical status remained fairly stable, with in particular a very high percentage 
of unknown (almost 99 % of water bodies). There was a change in the delineation of 

water bodies, as well as a reported change in the methods for status assessment. 

 

Chemical status assessment is based on monitoring only, with no use of grouping or 

expert judgement. Classifications have been assigned medium confidence.  

 

Priority substances were not monitored in water in coastal and territorial waters in any 

of the four RBDs, and no monitoring in water was performed in lakes and rivers in the 
Bornholm  and  International  (Vidå-Kruså)  RBDs.  In  the  other  two  RBDs,  only  four 

priority  substances  are  reported  to  be  monitored  in  water  for  status  assessment  in 
lakes, and 13 in rivers. About 95 % of lake water bodies were not monitored for any 

priority substances. Less than 3 % river water bodies were monitored for six or more 
Priority  Substances.  Monitoring  frequencies  were  in  line  with  the  recommended 

minimum  frequencies  for  surveillance  monitoring  but  not  operational  monitoring, 
which  Denmark  said  was  justified  on  the  basis  of  expert  judgment  and  technical 

knowledge, but no further detail was provided. 

 

According  to  WISE,  not  all  discharged  substances  are  monitored.  Denmark 

subsequently  clarified  that  all  substances  discharged  were  actually  monitored, 
however  it  was  not  clear  whether  they  were  monitored  in  a  matrix  for  which  a 

standard  exist,  and  therefore  whether  the  monitoring  could  be  used  for  status 
assessment. 

 

Denmark  mentioned  that  several  priority  substances  were  monitored  for  example  in 

biota  or  sediment,  but  that  the  corresponding  standard  was  not  derived,  despite  the 

12 

 
requirement  of  the  Directive,  and  there  the  monitoring  cannot  be  used  in  the 

assessment of status. 

  Mercury  was  monitored  in  biota  for  status  assessment  in  coastal  and  surface 
freshwaters, and hexachlorobenzene in coastal waters only. Denmark highlighted that 
hexachlorobutadiene  was  not  monitored  because  it  was  not  discharged.  The 

monitoring  frequencies  were  lower  than  the  recommended  minimum  frequencies, 
which  according  to  Denmark  was  justified  on  the  basis  of  expert  judgment  and 

technical knowledge, but no further detail was provided. 

 

Trend  monitoring  was  reported  in  biota  for  four  substances,  all  of  which  were 

monitored  in  coastal  waters,  but  only  one  in  lakes  and  rivers.  Monitoring  for  trends 
was  also  reported  in  water.  The  frequencies  were  not  always  in  line  with  the 

recommended minimum frequency. 

  Monitoring,  assessment  and  classification  of  quantitative  status  of  groundwater 

bodies 

 

The  number  of  monitoring  sites  has  increased  significantly  by  35  %  from  the  first 

cycle. 

 

The total number/total area of groundwater bodies failing good status has significantly 

decreased from the first cycle. 

 

Groundwater  dependent  terrestrial  ecosystems  are  not  considered  in  the  status 

assessment. 

 

Groundwater associated surface waters are considered in the status assessment. 

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

 

The  coverage  of  groundwater  bodies  by  monitoring  is  not  complete,  neither  for 

surveillance monitoring nor for operational monitoring, but grouping of groundwater 
bodies  has  been  applied  in  all  river  basin  districts.  Denmark  informed  that  all  core 

substances  are  being  monitored  and  that  only  those  parameters  and  substances  that 
were included in the status assessment and calculation of trends have been reported. 

13 

 
 

The status situation improved significantly with  a decrease of the groundwater body 

area  failing  good  chemical  status  from  52.7  %  to  19.6  %  of  the  total  groundwater 
body area from the first to the second cycle. 

 

30%  of  the  groundwater  bodies  have  no  clear  status  and  the  confidence  in  status 
results is low or unknown for more than the half of the groundwater bodies. 

 

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

ecological potential 

 

A new guidelines document for the designation of heavily modified water bodies has 

been  developed  since  the  first  RBMPs.  The  reduction  in  the  number  of  designated 

heavily  modified  and  artificial  water  bodies  is  partly  due  to  the  new  guidelines  and 
partly  due  to  the  re-delineation  of  water  bodies.  Further  changes  to  the  extent  of 

designations may take place until the end of 2019. An information gap is related to the 
water uses for which water bodies are designated, namely most heavily modified river 

water bodies are designated due to unknown uses.  

 

The method for defining Good ecological potential is more clearly explained than in 

the first cycle. The approach used is the Common Implementation Strategy Guidance 
approach  and  not  the  Prague  approach  which  was  reported  in  the  first  RBMPs. 

Furthermore, improvements have been made since the first cycle, mainly related to the 
inclusion of more quality elements in the assessment. The mitigation measures for two 

out of four RBDs (Jutland and Funen and Zealand) have been defined, whereas in the 
first RBMPs, mitigation measures were not defined in any RBD. For the International 

(Vidå-Kruså) and Bornholm RBD, no mitigation measures have been used for water 
bodies which have been defined as being at good ecological potential in the districts. 

For the Bornholm RBD, good ecological potential is not defined. Work to designate 
heavily modified water bodies and set environmental goals is still on going in all four 

RBDs, and will continue during 2019,  as part of  the  Food and  Agriculture Package 
(2015).   

 

Environmental objectives and exemptions 

 

Environmental  objectives  for  ecological  status  of  surface  water  bodies  have  been 
reported in all RBDs, whereas for some water bodies the date for the achievement of 

the objectives is unknown.  

14 

 
 

 

Drivers and pressures leading to exemptions were not reported. 

Article 4(4) is used more widely in surface water and groundwater in the second cycle 
than in the first. 

 

Article 4(5) was not applied in the first cycle but is now used in the second cycle for 

surface  waters.  The  information  provided  is  not  sufficient  to  assess  whether  the 
application is compliant. 

 

Programme of Measures 

 

There is  a shortage of meaningful information  so  it is not possible to judge whether 
any progress has been made, other than the indication that “some measures have been 

completed”. 

 

A  clear  financial  commitment  has  been  secured  in  all  four  RBDs  for  the  relevant 

sectors. 

 

All except one significant pressure has been covered by operational KTMs in surface 

water and groundwater in all four RBDs. One significant pressure (Anthropogenic  – 

unknown) is not covered by an operational KTM in one RBD. 

 

A  total  of  18  national  supplementary  measures  have  been  mapped  against  eight 

predefined  KTMs  and  one  KTM  defined  by  Denmark.  No  national  basic  measures 
have been mapped. 

 

The  information  on  measures  on  River  Basin  Specific  Pollutants  and  Priority 
Substances  is  unclear  (but  seems  to  be  covered  under  general  significant  pressures). 

Denmark  has  clarified  that  Priority  Substances  are  covered  by  the  Programmes  of 
Measures,  and  newly  identified  Priority  Substances  will  be  covered  by  preliminary 

Programmes of Measures plan running from 2018-2021. 

 

The objectives and requirements of the Floods Directive5 have not been considered in 
the  second  RBMP  and  Programme  of  Measures.  However,  there  has  been  some  co-
ordination between RBMPs and FRMPs in all four RBDs. 

5   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  

15 

 
 
                                                      
  Measures related to abstractions and water scarcity 

 

A  low  proportion  of  groundwater  bodies  face  water  quantity-related  problems  for 

achieving good quantitative status and water abstraction pressures significantly affect 
only a few surface water bodies.  

  Water  abstraction  pressures  were  reported  as  relevant  for  Denmark.  However,  the 
Water  Exploitation  Index  +  is  not  calculated,  but  water  quantity  data  have  been 

reported to support the European State of the Environment Report in relation to Water 
Quantity. 

 

The RBMPs  include  a  water resource allocation and management  plan  in  all RBDs. 

Measures  on  Article  11(3)(c)  for  efficient  and  sustainable  water  use  have  not  been 
implemented in the previous cycle.  

 

There  is  a  concession,  authorisation  and/or  permitting  regime  to  control  surface  and 
groundwater  abstractions  and  water  impoundment;  and  a  register  of  impoundments 

exists in all RBDs. 

  Measures related to pollution from agriculture 

 

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

surface and groundwater.  

 

An assessment of the gaps to the achievement of WFD environmental objectives for 

nutrients  has  partly  been  undertaken  in  all  RBDs.  In  the  RBMPs  gap  analyses  are 

made for coastal waters (nitrogen) and lakes (phosphorus). 

 

 

Safeguard zones have been established for abstractions.  

The implementation of basic measures according to Article 11(3)(h) for the control of 
diffuse  pollution  from  agriculture  at  source  is  ensured  in  all  RBDs  where  the  same 

rules apply across the whole RBD. 

 

Financing of measures is secured in all RBDs. 

16 

 
 
 
  Measures related to pollution from sectors other than agriculture 

 

Denmark 

is 

implementing  measures  regarding  wastewater  (small  wastewater 

treatment plants, stormwater overflow and wastewater from scattered settlements) in 
order to improve water quality in rivers and lakes. 

  Measures in relation to Priority Substances and River Basin Specific Pollutants were 
described only in a broad manner; i.e. not specific to each substance, and it is not clear 

whether  all  relevant  substances  have  been  identified,  nor  whether  the  non-specific 
measures will be sufficient to achieve the objectives. 

  Measures related to hydromorphology 

 

Overall,  the  second  RBMPs  reflect  a  significant  improvement  in  measures  to  tackle 

hydromorphological pressures. It is expected that efforts will improve the condition of 
up  to  3 575km  of  rivers/streams  (which  amounts  to  approximately  half  of  the  river 

kilometres which are not in good status due to poor physical conditions). 

  Whilst  KTMs  relevant  to  hydromorphological  pressures  have  been  mapped  against 
national  hydromorphological  measures,  information  is  not  available  in  WISE  on  the 
to  specific  significant  pressures.  However,  Denmark 
links  of 

these  KTMs 

subsequently clarified that information is included in the RBMPs. In addition, there is 
to  be  filled  for  significant 
no 

information  available  on 

indicator  gap 

the 

hydromorphological  pressures  by  2021  or  2027.  Nevertheless,  based  on  information 
from  the  published  RBMPs,  it  is  evident  that  hydromorphological  measures  (both 

supplementary and basic) are planned for the second cycle.  

 

Ecological flows have been derived only partly and not implemented yet in any RBD.  

The  work  to  make  operational  the  new  methodology  on  ecological  flow  is  still  on 
going. 

 

Economic analysis and water pricing policies  

 

 

Environmental and resource costs have only partly been included. 

A narrow definition of water services has been used.  

17 

 
 
 
 

Considerations  specific  to  Protected  Areas  (identification,  monitoring,  objectives 

and measures) 

 

Protected Areas for all relevant types have been reported. Compared to the first cycle, 
comparable  numbers  of  Article  7  (groundwater)  and  shellfish  production  areas,  and 

many more Birds and Habitats areas were reported in the second cycle. 

 

Additional  objectives  have  been  set  for  shellfish  production  areas;  some  of  which 

have been met, which reflects significant progress since the first cycle.  

 

The majority of Habitats Directive Protected Areas are also protected under the Birds 

Directive  so  monitoring  of  these  areas  covers  both  directives.  The  extent  of  the 

reported monitoring programmes is reduced in the second cycle compared to the first 
cycle.  

  Monitoring programmes for specific Protected Area types have not been reported for 
all  types.  Monitoring  of  Habitats  areas  does  not  cover  all  water  categories  and  the 

number of monitoring sites is low.  

 

Adaptation to drought and climate change 

 

A  climate  check  of  the  Programme  of  Measures  has  been  carried  out  in  the  second 

cycle.  

18 

 
 
 
 
Recommendations  

 

 

 

The  preparation  of  the  next  RBMPs  should  be  carried  out  in  accordance  with  the 

WFD timetable, so that the third RBMPs are adopted on time. 

Denmark  should  continue  to  improve  cooperation  in  iRBD  and  ensure  transparency 
regarding  coordination  of  the  technical  aspects  of  the  WFD  such  as  ensuring  a 

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

Denmark  needs  to  continue  its  work  on  the  apportionment  of  significant  pressures 
among  different  sectors,  in  order  to  further  improve  the  identification  of  the 

appropriate mitigation measures. 

 

Denmark  should  further  strengthen  monitoring  of  surface  waters  by  covering  all 

relevant biological, physico-chemical and hydromorphological quality elements in all 

water  categories.  The  proportion  of  water  bodies  covered  by  monitoring  for  River 
Basin Specific Pollutants should increase. 

 

 

 

Denmark should complete the development of assessment methods for all biological 
quality  elements  in  all  water  categories,  including  methods  that  are  sensitive  to 

nutrients  in  rivers.  Hydromorphological  quality  elements  should  be  included  in  the 
classification of ecological status. 

The  use  of  grouping  for  the  classification  of  ecological  status  and  the  methodology 
used for grouping needs to be clearly described. 

Denmark should make significant efforts to reduce the number of surface water bodies 
in unknown chemical status. Monitoring should be performed in the relevant matrix in 

a  way  that  ensures  sufficient  spatial  coverage  and  temporal  resolution  to  reach 
sufficient  confidence  in  the  assessment  for  all  water  bodies,  if  necessary  in 

combination with robust grouping/extrapolation methods. If a different matrix is used, 
the corresponding standards need to  be derived to provide at  least  the same level  of 

protection, and the corresponding explanations should be provided, as required by the 
Directives. Explanations should also be provided if reduced frequencies are used. All 

priority substances discharged should be monitored so that monitoring can be used for 
status assessment. 

 

Denmark  should  further  improve  trend  monitoring  for  all  relevant  substances,  in  a 

way that provides sufficient temporal resolution and spatial coverage. 

19 

 
  Monitoring  should  improve  as  well  as  confidence  status  to  address  the  number  of 
groundwater  bodies  with  unknown  chemical  status,  and  grouping  methodologies 
should be further clarified. 

 

Groundwater monitoring and methodologies for  chemical  should  all in  line with  the 
WFD obligations. Measures to ensure good chemical status of groundwater should be 

established considering all WFD aspects. Trend reversals should be carried out. 

 

Denmark  should  continue  progressing  on  the  designation  of  HMWBs  and  definition 

of good ecological potential, and complete the required assessments for all RBDs. 

  Meaningful  information  regarding  the  timing  of  the  measures  should  be  included  in 

the Programmes of Measures. 

 

 

 

Denmark  should  provide  clear  information  on  the  links  of  KTMs  to  specific 
significant pressures. 

All  Priority  Substances  and  River  Specific  Pollutants  identified  as  causing  failure 

should be individually associated with KTMs. 

Denmark  should  ensure  that  its  Programme  of  Measures  as  regards  chemical 

pollutants  from  non-agricultural  sources  is  based  on  reliable  assessment  of  the 
pressures, so  that all relevant  pollutants are addressed.  It  should also  assess whether 

the measures proposed will be sufficient to meet the objectives. 

 

Denmark needs to continue its efforts to ensure that appropriate measures are applied 

in  all  water  bodies  subject  to  hydromorphological  pressures.  Even  if  the  ecological 
flows have been derived, the necessary steps to make it operational in all RBDs need 

still to be taken. 

 

Cost recovery should be applied for water services. Any exemption should be justified 

using  Article  9(4).  Denmark  should  also  present  in  a  transparent  manner  how 
financial,  environmental  and  resource  costs  have  been  calculated  and  how  the 

adequate  contribution  of  the  different  users  is  ensured.  The  water-pricing  policy 
should  be  set  out  in  a  transparent  fashion  and  a  clear  overview  of  estimated 

investments and investment needs should be provided. 

Denmark needs to establish objectives for its relevant Protected Areas for surface and 

groundwater. 

20 

 
 
 
Topic 1

 Governance and public participation 

1.1 

Assessment  of 
requirements in second cycle 

implementation  and  compliance  with  WFD 

1.1.1  Administrative arrangements – RBDs 

Denmark  has  fourRBDs:  Jutland  and  Funen,  Zealand,  Bornholm  and  International  (Vidå-
Kruså).  One  RBD,  International  (Vidå-Kruså),  is  part  of  an  international  RBD  shared  with 

Germany. 

1.1.2  Administrative arrangements – competent authorities 

Denmark  has  reported  one  Competent  Authority  for  the  second  cycle,  the  Danish 
Environmental  Protection  Agency  (EPA),  responsible  for  all  the  main  roles  for  the  RBMPs: 

monitoring  and  assessment  of  status  of  groundwater  and  surface  water,  enforcement  of 
regulations,  pressure  and  impact  analysis,  economic  analysis,  preparation  of  the  RBMPs  and 

Programme  of  Measures,  public  participation,  implementation  of  measures,  coordination  of 
implementation and reporting to the European Commission. Denmark subsequently informed 

that  for  the  second  cycle,  the  Danish  Minister  for  Environment  and  Food  delegated 
administrative powers to the Danish EPA. For the first RBMPs, the administrative powers of 

the Competent Authority, at the time the Minister for the Environment, were delegated to, the 
Danish  Nature  Agency,  which  was  indicated  as  the  main  Competent  Authority  for  the  first 

RBMPs. 

1.1.3  RBMPs – structure and Strategic Environmental Assessment   

Denmark  did  not  report  any  sub-plans  for  its  RBMPs.  In  the  first  cycle,  Denmark  prepared 
individual sub-plans for the 23 main catchments that make up the four River Basin Districts. 

Denmark carried out Strategic Environmental Assessments for all 4 RBMPs. 

1.1.4 

Public consultation 

For all four RBMPs, the public and interested parties were informed by: Internet, invitations to 
stakeholders, local authorities, media (papers, TV and radio), and meetings. Documents were 
available for download for the requisite six months. Public consultation was not coordinated at 

international level (i.e. with Germany) in the International (Vidå-Kruså) RBD. 

The  following  stakeholder  groups  were  actively  involved  in  the  development  of  all  four 

RBMPs: agriculture/farmers, fisheries/aquaculture, local/regional authorities, navigation/ports, 

21 

 
NGOs/nature  protection  and  water  supply  and  sanitation.  The  mechanisms  for  active 

involvement were the establishment of advisory groups and involvement in drafting. 

For  all  four  RBMPs,  public  consultation  had  the  following  impacts:  addition  of  new 

information, adjustment to specific measures, changes to the selection of measures, changes to 
the methodology used and commitment to further research. 

1.1.5 

Integration  with  the  Floods  Directive  and  the  Marine  Strategy  Framework 
Directive 

Denmark carried out a joint consultation of its RBMPs and the Floods Directive6 Flood Risk 
Management Plans.  

Denmark did not carry out joint consultation with the Marine Strategy Framework Directive7.  

1.1.6 

International coordination 

One  of  Denmark's  four  RBMPs  is  part  of  an  international  RBMP  (Vidå-Kruså),  which  is 
shared with Germany. There is an international agreement on water management in place but 

without  a  coordination  body  nor  an  international  RBMP  (designated  as  Category  3 
cooperation). 

According  to  the  RBMP  for  International  (Vidå-Kruså),  Denmark  and  Germany  exchanged 

information  on  the  assessment  of  border  river  catchments.  Nonetheless,  there  were  some 
differences in the classification in waters and the two Member States do not fully follow the 

same  surveillance  monitoring  programme.  Denmark  and  Germany  have  agreed  to  coordinate 
with  regard  to  a  number  of  issues:  transboundary  river  basins,  in  particular  analysis  and 

reviews,  monitoring  programmes,  programmes  of  measures,  river  basin  management  plans, 
timetables and work programmes, interim overviews of significant water management issues, 

measures for consulting and informing the public and reporting to the European Commission.  

Denmark  subsequently  informed  that  the  Competent  Authority  on  the  German  side  was 
consulted in parallel with relevant Danish authorities. 

Further  information  on  international  co-operation  with  respect  to  measures  is  provided  in 

Chapter 9 of this report. 

6   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 

7   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  

22 

 
                                                      
1.2  Main changes in implementation and compliance since first cycle 

For the first cycle, Denmark prepared a sub-plan for each of the 23 main catchments that make 
up  the  four  RBDs.  RBD-wide  RBMPs  were  also  prepared  for  the  Bornholm  RBD  and  the 

International  (Vidå-Kruså)  RBDs.  No  RBD-wide  RBMPs  were  prepared  for  the  Jutland  and 
Funen RBD or the Zealand RBD.  

In  the  second  cycle  Denmark  reports  the  preparation  of  four  RBMPs,  one  for  each  RBD 
covering all main catchments within the RBD, and no sub-plans.  

For  the  first  RBMPs  the  administrative  powers  of  the  Competent  Authority,  at  the  time  the 

Danish Minister for the Environment, were delegated to the Danish Nature Agency, which was 
indicated as the main competent authority (with the Minister of Environment as overall water 

authority); for the second cycle the administrative powers of the Competent Authority, now the 
Danish  Minister  for  Environment  and  Food,  were  delegated  to  the  Danish  Environmental 

Protection Agency. 

1.3 

Progress with Commission recommendations 

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

 

Recommendation: Given the late adoption of the sub-district RBMPs, Denmark needs 
to  take  special  care  to  ensure  that  the  preparation  of  the  next  cycle  of  RBMPs  is 

carried out in accordance with the WFD timetable, to ensure the second RBMPs are 
adopted no later than December 2015.  

Assessment:  According  to  the  information  reported  by  Denmark  the  second  RBMPs  were 
published on 27 June 2016 and thus were 6 months late. Consequently, Denmark did not meet 

the  deadline  set  in  the  recommendation  (nor  the  timetable  set  and  in  the  WFD).  This 
recommendation has not been fulfilled. 

23 

 
 
 
 
Topic 2 Characterisation of the River Basin District 

2.1.  Assessment  of 

implementation  and  compliance  with  the  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 a significant decrease in the number of river water bodies delineated between 

the first and second RBMPs of 49 % (Table 2.1). The same was true for coastal water bodies 
with a decrease of 28 %8. Territorial waters were only reported in the second cycle9. For lake 
water bodies, however there was an increase of 23 % overall, with the largest increase in the 
International (Vidå-Kruså) RBD (83 %). In the second RBMP, 91 % of identified surface water 

bodies were natural with 5 % being designated as heavily modified and 4 % as artificial water 
bodies.  In the  first  RBMP, the situation was  quite different  with  72 % natural,  16 % heavily 

modified and 11 % artificial (Figure 2.1). Table 2.2 shows the differences in size distribution 
of surface water bodies in Denmark between the second and first RBMPs. 

Table 2.1 

Number  and  area/length  of  delineated  surface  water  bodies  in  Denmark  for 
the second and first cycles  

Rivers 

Lakes 

Coastal 

Cycle 

RBD 

Number 
of water 
bodies 

second 

DK1 

6 206 

second 

second 

second 

second 

DK2 

DK3 

DK4 

1 276 

184 

110 

Total 

7 776 

first 

DK1 

first 

DK2 

11 513 
(11 516) 

2 919 
(2 922) 

Total 
length of 
water 
body 
(km) 

15 246 
(15 248) 

2 765 

369 

518 
18 89810 
(18 900) 

15 191 
(15 197) 

Number 
of water 
bodies 

598 

214 

11 

33 

856 

Total 
area 
(km2) of 
water 
bodies 

306 

162 

1 

8 

Number 
of water 
bodies 

83 

33 

2 

1 

Total 
area 
(km2) of 
water 
bodies 

12 803 

7 085 

233 

205 

477 

119 

20 325 

477 

272 (273) 

106 

27 754 

first 

DK3 

431 

370 

11 

1 

2 763 

190 

157 (159) 

56 

3 

11 656 

4 071 

8   Denmark subsequently clarified that this decrease was due to the fact that territorial waters were only reported 

to be delineated as such in the second cycle and were reported as coastal waters in the first cycle.   

9   Denmark further clarified that 28 coastal water bodies reported for the first cycle  were re-delineated/merged 

and reported as territorial waters in the second cycle.  

10   Very  small  rivers  with  a  catchment  area  of  less  than  10  km2  that  are  flat,  narrow  and  dug  will  be  excluded 
from  delineation  in  the  second  RBMP  in  2018  and  2019.  This  falls  under  the  new  Food  and  Agriculture 
Package (2015).  

24 

 
                                                      
Cycle 

RBD 

Rivers 

Lakes 

Coastal 

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 

first 

first 

DK4 

264 

518 

18 

7 

0 

0 

Total 

15 127 
(15 133) 

18 842 

696 

437 (440) 

165 

43 481 

Source: WISE electronic reports.  
Numbers in brackets were provided subsequently by Denmark 

Figure 2.1 

Proportion  of  surface  water  bodies  in  Denmark  designated  as  artificial, 
heavily modified and natural for the second and first cycles. NB - the numbers 

in parenthesis are the numbers of water bodies in each water category   

Table 2.2  Size  distribution  of  surface  water  bodies  in  Denmark  in  the  second  and  first 
cycles  

Source: WISE electronic reports. 

second 

second 

second 

first 

first 

first 

first 

River length (km) 

Cycle 

RBD 

Mini-
mum 

second 

DK1 

0.01 

Maxi-
mum 
37.11 
(37.08) 

Aver-
age 

2.46 

DK2 

0.01 

20.61 

2.17 

0.01 

Mini-
mum 

0.01 

Lake area (km2) 
Maxi-
mum 
16.55 
(17.13) 
39.54 
(35.35) 

Aver-
age 

0.51 

0.76 

Coastal (km2) 
Maxi-
mum 

Average 

Mini-
mum 

0.08 

1 807.01 

154.25 

Territorial (km2) 
Maxi-
mum 

Average 

4 225.79 

1 883.59 

Mini-
mum 

60.08 

5.19 

1 131.35 

214.7 

179.2 

1 863.58 

899.34 

DK3 

0.03 

DK4 

0.04 

10.19 
(10.21) 
16.87 
(16.85) 

2.01 

0.04 

0.13 

0.07 

18.95 

213.69 

116.32 

3 827.22 

3 827.22 

3 827.22 

4.71 

0.01 

2.02 

0.23 

204.99 

204.99 

204.99 

0 

0 

0 

DK1 

DK2 

DK3 

DK4 

21.24 

1.32 

0.01 

9.17 

8.08 

0.95 

0.86 

1.96 

0.02 

0.04 

0.03 

0.04 

10.44 

16.54 
(17,13) 
39.54 
(87) 

0.13 

2.02 

0.57 

0.08 

2 495.79 

261.83 

3.41 

1 166.84 

208.13 

19 

3 837.96 

1 357.08 

0.83 

0.07 

0.39 

Source: WISE electronic reports. Numbers in brackets were provided subsequently by Denmark  

25 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Transitional waters were not delineated in the first or the second cycle. The RBMP reports that 

there are no large river  outlets  to  Danish  coastal waters, but  only  gradual  changes in  salinity 
from the near-shore areas to the open sea. Therefore, the Danish fjords have been defined as 

separate types of coastal waters. 

It was reported in the RBMP that many river water bodies were aggregated where they were 

considered to have similar typology  and status  and were  generally  homogenous in  character. 
Small water bodies for example that were less than 500 metres in length were also aggregated.  

The  aggregation  of  water  bodies,  has  resulted  in  an  increase  of  the  average  length  of  rivers 
from  1.25  km  to  2.43  km  (Table  2.2).  No  changes  in  the  criteria  for  delineation  of  lakes  or 

coastal waters were reported, yet more lakes were included in the second RBMP, mainly lakes 
between one and five hectares.  

Table 2.3 

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

Area (km2) 
Minimum  Maximum  Average 

0.48 

0.92 

0.35 

0.49 

0.35 

6 175.01 

1 315.18 

368.62 

730.42 

6 175.01 

219.44 

109.75 

30.5 

218.36 

173.39 

Year 

RBD 

Number 

second 
second 

second 

second 

second 

first 
first 

first 

first 

first 

DK1 

DK2 

DK3 

DK4 

Total 

DK1 

DK2 

DK3 

DK4 

Total 

241 

136 

19 

6 

402 

271 

101 

6 

7 

385 

Source: WISE electronic reporting  

For groundwater bodies, there was an overall increase of 4 %, however within the Jutland and 

Funen  RBD  there  was  a  significant  decrease  (Table  2.3).  The  boundaries  of  groundwater 
bodies  have  been  updated  based  on  the  proximity  and/  or  connection  to  dependant  surface 
water bodies.  

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

evolved between the two cycles. The changes to the river water bodies and groundwater bodies 
have been reported as “creation” and “deletion” of new water bodies.  

26 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 2.4 

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

Denmark between the second and first cycles 

Type of water body change for second 
cycle (wiseEvolutionType) 

Groundwater 

Rivers 

Lakes 

Coastal 

Territorial 

Aggregation 

Splitting 

Aggregation and splitting 

Creation 

Deletion 

Change in code 

ExtendedArea 

change 

402 

385 

7 776 

15 127 

162 

2 

18 

2858 

694 

36 

Delineated for second cycle (after 
deletion from first cycle) 

402 

7 776 

856 

119 

Source: WISE electronic reports 

814 

6 

14 

2.1.2. Identification of transboundary water bodies  

No transboundary surface or groundwater bodies have been identified by Denmark. However, 
the International (Vidå-Kruså) RBD borders with Germany and is an international RBD. It was 

identified  that  there  are  differences  in  delineation  of  transboundary  water  bodies  between 
Denmark  and  Germany,  indicating  that  the  delineation  may  not  have  been  coordinated,  and 

that joint approaches and methods are not in place. 

2.1.3. Typology of surface water bodies 

The  number  of  water  body  types  per  RBD  and  water  body  categories  remained  largely  the 
same between the first and second RBMPs (Table 2.5). However, there was a decrease in the 
number of lake water body types reported overall, from 17 to 12 types11.  

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 Denmark in all of the RBDs 

do not appear to have corresponding intercalibration types. It is the case for two types of river 
water bodies, nine types of lake water bodies, and 11 types of coastal water bodies12. For the 
national types that have been linked to common intercalibration types, the Danish classification 

11  Denmark subsequently clarified that the number of lake types are the same in first and second cycle; there are 
16  possible  types  of  lakes  in  Denmark,  of  which  only  11  are  actually  found  in  the  second  cycle  RBMP.  In 
addition Denmark stated that for some lakes the type is registered as unknown. 

12  Denmark subsequently highlighted that results from Decision 2013/480/EU have been applied/translated to all 

national coastal water types. 

27 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
system  has  been  successfully  intercalibrated  for  all  the  biological  quality  elements.  This 

indicates  that  the  Danish  typology  is  biologically  relevant  for  those  national  types.  For  the 
other national types that are not linked to any common type, there is no information available 

as to whether those types are biologically relevant. 

Table 2.5 

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

RBD 

DK1 

DK2 

DK3 

DK4 

TOTAL 

Rivers 

Lakes 

Coastal 

first 

second 

first 

second 

6 

6 

6 

6 

6 

5 

5 

2 

5 

5 

17 (11) 

12 (11) 

17 (8) 

17 (2) 

17 (6) 

10 (9) 

4 

8 (7) 

17 (11) 

12 (11) 

17 

first 

15 

8 

1 

1 

second 

17 

9 

1 

1 

19 

Source: WISE electronic reports. Numbers in brackets were provided subsequently by Denmark. Note that the 

total is not the sum of the types in each RBD as some types are shared by RBDs 

2.1.4. Establishment of reference conditions for surface water bodies 

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

conditions established for the first and second cycles. Type specific reference conditions have 
been established for some or all relevant biological quality elements. Type specific reference 

conditions  have  not  been  established 
hydromorphological quality elements.  

for  physicochemical  quality  elements  or 

Table 2.6 

Percentage of surface water body types in Denmark with reference conditions 

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

“water category” are the number of types in each category  

Water category 

Water types 

Biological quality 
elements 

Hydromorphological 
quality elements 

Physicochemical 
quality elements 

Rivers (6) 

Lakes (12 (11)) 

Coastal (20(19)) 

All  

Some 

None 

All  

Some 

None 

All  

Some 

None 

100% 

17% (18%) 

83% (82%) 

95% (100%) 

100% 

100% 

100% 

100% 

5% (0%) 

100% 

100% 

Source: WISE electronic reports.  
Numbers in brackets were provided subsequently by Denmark 

28 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Type-specific  reference  conditions  have  been  intercalibrated  with  other  relevant  Member 

States and is part of the European Commission Decisions on Intercalibration. 

2.1.5. Characteristics of groundwater bodies 

The geological formation of the aquifer types in which groundwater bodies reside along with 
layered  or  not  were  reported.  Further 
details  of  whether  groundwater  bodies  are 

characterisation  work  has  been  reported  since  the  first  cycle  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  on  surface  water  bodies  overall  were 

‘Diffuse - Discharges not connected to sewerage network’ (49 %), followed by ‘Dams, barriers 
and  locks  –  Other’  (26  %),  which  was  mainly  applicable  to  river  water  bodies  (Figure  2.2). 

Diffuse pollution from agriculture is not reported as a significant pressure overall for surface 
water  bodies  (4  %).  However,  when  it  comes  to  coastal  water  bodies  98  %  have  diffuse 
pollution from agriculture and 30 % of lake water bodies but it is not a significant pressure for 

river  water  bodies  (<1  %).  ‘No  significant  pressure’  was  reported  for  22  %  of  surface  water 
bodies overall.  

Figure  2.3  shows  the  comparison  of  pressures  at  an  aggregated  level  between  the  first  and 
second cycle in Demark, which shows an increase in the number of surface water bodies with 

associated diffuse pressures. It appears that this increase relates to ‘discharges not connected to 
the sewerage network.’ However due to important changes in the delineation of water bodies 

between the first and the second RBMPs, changes of pressures between the two RBMPs have 
to be analysed with caution. 

For groundwater bodies “No significant pressure” was reported 75 % of the time and the most 
significant pressures were ‘Anthropogenic pressure – Unknown’ (25 %) and ‘pressures due to 

abstractions’ (Figure 2.2). 

For  the  second  RBMP,  there  is  no  data  reported  on  which  significant  pressures  were  not 

assessed for surface waters or groundwater, and it does not appear that all pressures have been 
apportioned.  For  example,  the  main  pressure  on  groundwater  is  ‘Anthropogenic  pressure  – 

Unknown.’ However, the changes in the significant pressures between the first and the second 
cycle  were  reported.  For  rivers  since  the  first  RBMP,  phosphorus  emissions  from  scattered 

dwellings, have been included whilst acidifying substances and pathogens were removed. For 
coastal  waters  since  the  first  RBMP,  nutrients  from  scattered  dwellings  have  been  added, 

whilst  pathogens  were  removed.  For  coastal  waters,  atmospheric  deposition  of  nutrients  and 
nutrients coming from other countries was added since the first RBMP. It is unclear whether 

29 

 
the  changes  relate  to  exclusion  of  pressures  from  the  assessment  or  to  changes  in  the 

methodologies.  

Figure 2.2 

The  most  significant  pressures  on  surface  water  bodies  and  groundwater 

bodies in Denmark for the second cycle  

Source: WISE electronic reports.  

30 

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

second cycles. Pressures are presented at the aggregated level. NB - there 
were 8 765 identified surface water bodies for the second cycle and 15 988 for 

the first cycle. 

Source: WISE electronic reports. 

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 were used for 

defining point source pressures and pressures from water flow. Numerical tools were used for 
assessing  diffuse  source  pressures.  The  tools  used  to  assess  significant  pressures  are 

Geographical Information System analyses, models, and threshold values linking the pressure 
to the good/moderate status boundary for the sensitive biota. The tools for hydromorphological 

pressures are not well developed and pressures are considered significant if the physical index 
exceeds a certain threshold. 

The RBMPs reported that there have been significant changes in the methodology for assessing 
significant  pressures  from  diffuse  and  point  source  pollution  by  nutrients  and  organic  matter 

since the first RBMP. New models have been developed to estimate nitrogen loads to coastal 
waters, which include the future prediction of nutrient loads. An equivalent methodology has 

been developed for updated calculations of nutrient and organic loads from point sources and 
scattered dwellings.  

For  groundwater,  the  tools  used  for  defining  significant  pressures  were  reported  as  “Not 

Assessed”  for  point  and  diffuse  pollution,  and  numerical  tools  were  used  for  abstraction 
pressures.  For  groundwater,  significance  of  pressures  was  reported  to  be  defined  in  terms  of 

thresholds  and linked to  the potential failure of objectives. Water abstraction for irrigation  is 

31 

 
 
estimated with hydrogeological models. The significance of this pressure has been linked to the 

high probability of deterioration to less than good status of the dependent surface waters (river, 
benthic invertebrate ecological quality ratio values), as well as to a screening criterion of the 

maximum  acceptable  exploitation  of  groundwater.  The  hydrogeological  models  are  also 
reported to be improved since the first cycle.  

2.1.8. Significant impacts on water bodies  

In  the  second  RBMP,  the  most  significant  impact  on  surface  water  bodies  overall  was 

classified  as  ‘Organic  pollution’  (49  %),  followed  by  ‘Altered  habitats  due  to  morphological 
changes’  (33  %)  which  relates  mainly  to  impacts  on  rivers  (Figure  2.4).  For  coastal  water 

bodies the main impact  was reported to  be nutrient  pollution affecting 98 % of water bodies 
and for lakes water bodies it was 62 %. For groundwater, 74 % of water bodies were classified 

as  ‘no  significant  impact’  and  the  most  significant  impact  was  ‘Chemical  pollution’  (25  %). 
Denmark did not report on impacts in the first RBMP. 

32 

 
Figure 2.4 

Significant impacts on surface water and groundwater bodies in Denmark for 

the second cycle. Percentages of numbers of water bodies 

Source: WISE electronic reports 

2.1.9. Groundwater bodies at risk of not meeting good status 

Groundwater bodies were reported to be at risk of failing to meet good chemical status in three 

RBDs,  ranging  from  17  to  27  %  in  the  Jutland  and  Funen,  Zealand  and  International  (Vidå-
Kruså) RBDs. For the Bornholm RBD, no groundwater bodies were reported to be at risk. The 

pollutants  putting  groundwater  bodies  at  risk  of  failing  good  chemical  status  have  been 
reported. 

33 

 
 
 
 
 
In  the  Zealand  RBD  groundwater  bodies  were  reported  to  be  at  risk  of  failing  to  meet  good 

quantitative status (2 % of water bodies) and none were reported to be at risk for the remaining 
water bodies. Further information on the chemical status of groundwater bodies can be found 

in Chapter 6 of this report. 

2.1.10.  Quantification of the gap and apportionment of pressures  

There  was  one  inconsistency  in  the  pressures  for  which  measures  are  planned  and  the 
significant pressures reported at the water body level. In the International (Vidå-Kruså) RBD, 

‘Anthropogenic pressure – Unknown’ has been reported at the groundwater body level but this 
pressure  has  not  been  reported  as  being  tackled  in  the  Programme  of  Measures.  Further 

information on the Programme of Measures can be found in Chapter 9 of this report. 

The Priority Substances and other substances causing the failure of good chemical status have 

been  reported.  However,  the  measures  to  tackle  Priority  Substances  and  other  substances 
causing the failure of good chemical status and the indicator gap to achieving good status have 
not been reported for 2027. Denmark has however clarified that according to the RBMPs and 

Executive  Order  on  programme  of  measures  relevant  environmental  authorities  must,  within 
their  area,  investigate  sources  of  pollutants  that  prevent  the  achievement  of  environmental 

objectives. If necessary, the Authority, if authorised in the sectoral act concerned, shall review 
notified approvals and permits to comply with applicable Environmental Quality Standards.  

Denmark has also stated that projects are also being launched to obtain further knowledge on 
pollutants  in  the  aquatic  environment,  and  substances  added  to  the  EU  list  of  priority 

substances in 2013 are covered by a preliminary program of measures from the end of 2018 to 
the end of 2021. Further information on measures related to pollution from sectors other than 

agriculture can be found in Chapter 12 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)13  requires 
Member  States  to  establish  an  inventory  of  emissions,  discharges  and  losses  of  all  Priority 

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

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

34 

 
                                                      
(respectively  suppressing)  emissions,  discharges  and 

losses  for  priority  substances 

(respectively priority hazardous substances).   

Denmark reported inventories for each RBD. However each of them included only 19 of the 41 

Priority  Substances.  The  RBMP  reported  that  the  Priority  Substances  not  included  on  the 
inventories  are  not  used  in  Denmark  or  that  screening  has  shown  that  they  do  not  occur  in 

significant  quantities.  This  does  not  seem  to  be  entirely  in  line  with  the  Common 
Implementation  Strategy  Guidance  Document  n°28,  which  recommends  that  “For  the 

substances  discarded  (i.e.  for  substances  of  minor  relevance)  Member  States  should  try  to 
provide  a  basic  estimation  of  emissions,  discharges  and  losses  from  available  data.  This  is 

especially  important  for  PHS  [priority  hazardous  substances  –  for  which  emissions  must  be 
phased out]”. 

The  two-step  approach  from  the  Common  Implementation  Strategy  Guidance  Document 
n°2814 has been followed for the substances considered in the inventories. Tier 1 (point source 
information) was implemented for substances not relevant at RBD level, and Tier 2 (riverine 

load) was used for other substances, while the Guidance Document recommends using at least 
Tier 1+2 for the relevant substances. The data quality was not reported. 

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

Overall there was a significant decrease of 49 % in the number of river water bodies delineated 

between  the  first  and  second  RBMPs.  The  same  was  true  for  coastal  water  bodies  with  a 
decrease of 28 %15. For lake water bodies, however there was an increase of 23% overall, with 
the  largest  increase  in  the  International  (Vidå-Kruså)  RBD  (83%).  For  groundwater  bodies, 
there was an overall increase of 4 %.  

In  the  second  RBMPs,  91  %  of  identified  surface  water  bodies  were  natural,  5%  were 
designated as heavily modified and 4 % were artificial water bodies. In the  first RBMPs, the 

situation was somewhat different with 72 % natural, 16 % heavily modified and 11 % artificial.  

The  number  of  water  body  types  per  RBD  and  water  body  categories  remained  largely  the 

same between the first and second RBMPs.  

14  CIS Guidance N° 28 - Preparation of Priority Substances Emissions 

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

15  Denmark subsequently clarified that this decrease was due to the fact that territorial waters were only reported 

to be delineated as such in the second cycle and were reported as coastal waters in the first cycle.   

35 

 
                                                      
There are increases in the number of surface water bodies with diffuse pressures between the 

first  and the second cycle.  It  appears that this increase relates to  discharges not  connected to 
the sewerage network. 

2.3.  Progress with Commission recommendations 

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

requested action on the following: 

  Recommendation: Transitional waters are not designated, and no justification is given 
as  to  why  this  water  category  has  not  been  used.  Denmark  should  review  its 

designation of at least some coastal waters, notably those referred to as inner coastal 
fjords  water,  and  consider  transitional  water  designation,  considering  physical  and 

chemical factors that determine the characteristics of transitional waters and hence the 
biological population structure and composition. 

Assessment: Transitional waters are not delineated in the first or the second cycle. The 
RBMP  reports  that  there  are  no  large  river  outlets  to  Danish  coastal  waters,  but  only 

gradual  changes  in  salinity  from  the  near-shore  areas  to  the  open  sea.  Therefore,  the 
Danish fjords have been defined as separate types of coastal waters. This justification is 

adequate and therefore the recommendation has been fulfilled.  

  Recommendation:  There  are  no  criteria  or  thresholds  given  on  how  to  define 
significant  pressures  from  point  and  diffuse  sources.  Where  there  are  currently  high 

uncertainties  in  the  characterisation  of  the  RBDs,  identification  of  pressures,  and 
assessment  of  status,  these  need  to  be  addressed  in  the  current  cycle,  to  ensure  that 
adequate measures can  be put  in  place before the next  cycle. [Action: Improved and 

clear descriptions of how all pressures and impacts were quantified, in particular on 
how significance was defined] 

Assessment: For surface waters, a combination of both expert judgement and numerical 
tools  were  used  for  defining  point  source  pressures  and  pressures  from  water  flow. 

Numerical  tools  only  were  used  for  assessing  diffuse  source  pressures.  For 
groundwater,  the  tools  used  for  defining  significant  pressures  were  reported  as  “Not 

Assessed” for point and diffuse pollution, and numerical tools were used for abstraction 
pressures.  For  both  surface  water  bodies  and  groundwater,  significance  of  pressures 

was reported to be defined in terms of thresholds and linked to the potential failure of 
objectives  for  all  RBDs.  The  criteria  and  thresholds  are  described  in  the  RBMPs  and 

36 

 
changes  from  the first  cycle are highlighted. Therefore this recommendation has been 

mostly fulfilled.  

  Recommendation:  There 

is  no 

information  on 

tools 

to  assess  significant 

hydromorphological  pressures.  Denmark  needs  to  improve  the  identification  of 
significant  pressures,  describe  the  methodologies,  thresholds  and  tools  better  in  the 

plans  and  report  more  detailed  data  by  water  body.  This  applies  also  to 
hydromorphological pressures and chemical pollution. 

Assessment: The RBMP does not provide information on what pressures were excluded 
from the assessment, but the changes in the significant pressures between the first and 

the second cycle were reported. There is information in the RBMPs regarding the tools 
used  to  assess  the  significance  of  pressures  including  hydromorphological  pressures. 

The  tools  for  hydromorphological  pressures  are  not  well  developed  and  pressures  are 
considered significant if the physical index exceeds a certain threshold. Therefore this 
recommendation has been partially fulfilled.  

  Recommendation: The basis for assessing quantitative status in groundwater bodies is 
weak  and  needs  to  be  improved.  [Action:  Water  abstraction  for  irrigation  is  a  major 

source of this pressure].  

Assessment:  In  terms  of  characterisation,  abstractions  are  only  reported  to  be  a 

significant  pressure  for  2  %  of  water  bodies  and  impacts  were  identified  where 
abstraction  exceeds  available  groundwater  resource  (lowering  water  table).  It  was 

reported that the assessment of abstraction pressures has been improved since the first 
cycle  with  the  use  of  a  new  hydrogeological  model.  All  pressures  including  water 

abstraction  for  irrigation  have  been  considered  for  the  assessment  of  the  quantitative 
status.  However,  only  those  pressures  that  have  led  to  poor  quantitative  status  have 

been  specified  to  be  significant.  Therefore  this  recommendation  has  been  partially 
fulfilled.  

37 

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

3.1.  Assessment of implementation and compliance with WFD requirements 

in second RBMPs 

3.1.1.  Monitoring of ecological status/potential 

Monitoring programmes 

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

comprehensive overview of water status within each RBD.  

A  number  of  different  monitoring  sub-programmes  were  reported  by  Denmark  and  are 

common across the four RBDs. Even though coastal waters were reported for all four RBDs, 
only three of the RBDs have indicated that there is a programme covering coastal waters: the 

Bornholm RBD did not have coastal monitoring, except one monitoring site for macroalgae.  

Denmark subsequently clarified that the sub-programme for coastal waters that was the basis 
of  the  second  RBMPs  did  not  distinguish  between  surveillance  and  operational  monitoring. 

Each  monitoring  site  in  that  programme  was  used  for  both  surveillance  and  operational 
monitoring.  

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

The  first  RBMPs  for  Denmark  were  adopted  on  21  December  2011  and  reported  to  the 
Commission on 22 December 2012. Electronic reporting to WISE was submitted in the spring 

of  2012.  However,  for  legal  reasons  the  first  plans  were  declared  invalid  by  the  Danish 
Authorities in the spring of 2013. The RBMPs were resubmitted to a consultation process and 

the revised RBMPs for the first planning period were adopted in October 2014. Data were also 
resubmitted to  WISE, the latest  in  March 2015. This  assessment is  largely  based on the data 

submitted to WISE in 2012, supplemented by information subsequently provided by Denmark. 

There was a five fold increase in the number of operational sites in rivers in Denmark between 

the first RBMP (2 475) and the second (12 464). There was a smaller increase in the number of 
operational sites in coastal waters (434 to 625) and a decrease in sites in lakes (351 to 262).  

There is no summary of the changes in the RBMPs or referenced background documents. The 
monitoring programme used for the second RBMPs (NOVANA 2011-2015) does not include 

38 

 
any information on the changes made since the first RBMPs. Due to the short time between the 

final  adoption of the first  and second RBMPs, the changes in  the monitoring programme are 
likely to be minor. There are no differences in main monitoring approach between RBDs as the 

monitoring programmes are national. 

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

purposes between the two RBMPs, and Table 3.2 gives the number of sites used for different 
purposes for the second RBMPs.  

There is a significant increase in the total number of monitoring sites in lakes from 35116 for 
the  first  RBMPs  to  1080  for  the  second  RBMPs.  For  the  first  RBMPs,  no  surveillance  sites 

were  reported  for  lakes;  whereas  for  the  second  RBMPs,  818  sites  were  reported.  However 
Denmark  subsequently  clarified  that  there  were  351  surveillance  sites  in  lakes  for  the  first 

RBMPs.  Conversely,  no  surveillance  sites  were  reported  for  coastal  waters  for  the  second 
RBMP and 243 were reported for the first RBMPs. However, Denmark subsequently clarified 
that the total number of monitoring sites for coastal waters has increased from 636 for the first 

RBMPs  to  781  for  the  second,  and  that  no  distinction  was  made  between  surveillance  and 
operational sites for the second RBMPs. Overall, there were only small changes in the numbers 

of surveillance sites in rivers between the two RBMPs. 

There was a five-fold increase in the number of operational sites in rivers in Denmark between 

the first RBMP (2 475) and the second (12 464). There was a smaller increase in the number of 
operational sites in coastal waters (434 to 62517) and a decrease in sites in lakes (351 to 262).  

There is no summary of the changes in the RBMPs or referenced background documents. The 
monitoring programme used for the second RBMPs (NOVANA 2011-2015) does not include 

any information on the changes made since the first RBMPs. Due to the short time between the 
final  adoption of the first  and second RBMPs, the changes in  the monitoring programme are 

likely to be minor. There are no differences in main monitoring approach between RBDs as the 
monitoring programmes are national. 

Table 3.1 

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

data reported for the first RBMPs, the second RBMPs’ data does not take into 
account whether sites are used for ecological and/or chemical monitoring  

second RBMP  

DK_1 

Rivers 

Lakes 

Coastal 

Surv. 

Op 

Surv. 

Op 

Surv. 

Op 

613 

10 269 

553 

194 

(519) 

420 (519) 

16 Denmark subsequently corrected that the number of lakes for the first RBMP is 552. 
17 Denmark subsequently clarified that there were 781operational sites in coastal waters for the second RBMP. 

39 

 
  
  
  
  
  
  
  
                                                      
DK_2 

DK_3 

DK_4 

Total by type of site 

Rivers 

Lakes 

Coastal 

Surv. 

140 

23 

14 

790 

Op 

1766 

203 

226 

12464 

Surv. 

230 

13 

22 

818 

Op 

56 

3 

9 

Surv. 

(257) 

(1) 

(4) 

Op 

202 (257) 

(1) 

3 (4) 

262 

0 (781) 

625 (781) 

Total number of monitoring sites 

13 116(13140) 

1080 

625 (781) 

first RBMP 

DK_1 

DK_2 

DK_3 

DK_4 

Total by type of site 

607 

140 

15 

14 

776 

1 971 

393 

27 

84 

0 (250) 

(89) 0 

(3) 0 

(9) 0 

250 

89 

3 

9 

162 

77 

4 

312 

119 

3 

2 475 

(351) 0 

351 

243 

434 

Total number of monitoring sites 

3 251 

351(552) 

636 

Sources: WISE electronic reports. Numbers in brackets were provided subsequently by Denmark. 

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

Monitoring Purpose 

CHE - Chemical status 

ECO - Ecological status 

HAB - Protection of habitats or species depending on water 

OPE - Operational monitoring 

SOE - EIONET State of Environment monitoring 

SUR - Surveillance monitoring 

Total sites irrespective of purpose 

Rivers 

Lakes  Coastal 

24 

37 

156 

20 (13 136) 

1080 

 (625)  

12 464 

31 

790 

410 

262 

17 

818 

21 

625 (781) 

 (781) 

13 140 

1 080 

783 

Source: WISE electronic reports. Numbers in brackets were provided subsequently by Denmark. 

Quality elements monitored (excluding River Basin Specific Pollutants) 

Table  3.3  illustrates  the  quality  elements  used  for  the  monitoring  of  surface  waters  for  the 
second RBMPs that have been reported in WISE: no differentiation is made between purposes 

of monitoring.  

There are also gaps in the monitored biological quality elements: macroalgae are not reported 

in WISE to be monitored in coastal waters, although the biological quality element is included 
in the NOVANA programme for 2011-2015 with 46 sites, phytobenthos are not monitored in 
rivers18, and benthic invertebrates are not monitored in lakes. Phytobenthos is not reported as 

18 Denmark subsequently stated that a research institution has been requested to provide the scientific basis for the 

preparation of a phytobenthos index in rivers. 

40 

 
  
 
 
 
 
 
 
 
 
  
  
                                                      
being monitored in lakes, but Denmark subsequently clarified that it is monitored but not used 

in the assessment. 

Table 3.3 

Quality  elements  monitored  for  the  second  RBMPs  in  Denmark  (excluding 
River  Basin  Specific  Pollutants).  Note:  quality  element  may  be  used  for 
surveillance  and/or  operational  monitoring.  Note  that  some  Member  States 

reported  “other  aquatic  flora”  rather  than  the  component  sub-quality 
elements, macrophytes, phytobenthos, angiosperms and macroalgae. 

Biological 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

9
1
s

m
r
e
p
s
o
i
g
n
A

Rivers 

Yes  No  Yes  Yes 

Lakes 

Yes  Yes  No  No  Yes 

Coastal 

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 

No 

e
a
g
l
a
o
r
c
a
M

No
20 

Hydromorphological quality 
elements 

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

e
m
i
g
e
r

l
a
d
i
t

No 

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 

General physicochemical quality elements 

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

s
n
o
i
t
i
d
n
o
c

No 

No 

l
a
m
r
e
h
T

s
n
o
i
t
i
d
n
o
c

No 

No 

No 

n
o
i
t
a
n
e
g
y
x
O

s
n
o
i
t
i
d
n
o
c

No 

No 

No 

y
t
i
n
i
l
a
S

s
n
o
i
t
i
d
n
o
c

No 

No 

No 

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

s
u
t
a
t
s

No 

No 

No 

n
e
g
o
r
t
i

N

s
n
o
i
t
i
d
n
o
c

No 

No 

No 

s
u
r
o
h
p
s
o
h
P

s
n
o
i
t
i
d
n
o
C

No 

No 

No 

r
e
h
t
O

r
o
f

t
n
a
n
i
m
r
e
t
e
d

t
n
e
i
r
t
u
n

s
n
o
i
t
i
d
n
o
c

No 

No 

No 

e
t
a
c
i
l
i
S

No 

No 

No 

Rivers 

Lakes 

Coastal 

Source: WISE electronic reports. Denmark subsequently clarified that due to reporting error, more 

elements are monitored than what was reported. In particular, all general physicochemical quality elements are 
monitored in coastal waters (except transparency and acidification), lakes (except silicate and other determinant 

for nutrient conditions) and rivers (except transparency, silicate and other determinant for nutrient conditions).  
All hydromorphological quality elements are monitored in rivers and lakes, while in coastal water freshwater 

flow and composition of sediments are monitored.  

Phytobenthos in rivers and lakes was not monitored for the first RBMPs, it has been monitored 
in lakes but not in rivers for the second RBMPs. All biological quality elements were said to be 

19  Denmark subsequently clarified that for coastal waters, angiosperms and macroalgae are sub-types.  
20  Subsequently its was clarified that, according to NOVANA, macroalgae was monitored in coastal water bodies 

for the second RBMPs 

41 

 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
monitored  in  coastal  waters  for  the  first  RBMPs,  but  macroalgae  were  not  included  in  the 

WISE  reporting  for  the  second  RBMPs  (although  it  was  included  in  the  NOVANA 
programme,  see  above).  It  appears  that  for  the  first  RBMP  some  physicochemical  and 

hydromorphological  quality  elements  were  monitored  in  some  water  categories,  but  for  the 
second  RBMPs  none  were  reported  to  be  monitored.  However,  Denmark  has  subsequently 

clarified that this is a reporting error. All hydromorphological quality elements are monitored 
in  rivers and lakes,  while in  coastal water  freshwater  flow and  composition  of sediments  are 

monitored.  All  general  physicochemical  quality  elements  are  monitored  in  coastal  waters 
(except transparency and acidification), lakes (except silicate and other determinant for nutrient 

conditions)  and  rivers  (except  transparency,  silicate  and  other  determinant  for  nutrient 
conditions). [Note:  Denmark also  reported that reference conditions  had not  been established 

for any type for any hydromorphological or physicochemical quality element.] 

Annex V of the WFD gives a recommended minimum frequency for the sampling of biological 
quality elements unless greater intervals would be justified on the basis of technical knowledge 

and expert judgement. For phytoplankton, the minimum recommended frequency is once every 
six months in all water categories, and once every three years for the other biological quality 

elements.  The  highest  rate  of  alignment  with  these  frequencies  was  for  coastal  sites  where 
benthic  invertebrates,  angiosperms  and  phytoplankton  were  sampled  at  the  minimum 

recommended or higher frequency at 89 %, 88 % and 43 % of sites. The rate of alignment with 
the recommended frequencies was much lower in the other two water categories in Denmark. 

For lakes only 4 %, 1 % and 1 % of sites were sampled at least at the minimum recommended 
frequency  for  macrophytes,  phytoplankton  and  fish,  respectively.  None  of  the  3631  sites 

sampled for fish in rivers were sampled in line with the recommended frequencies. 22 % and 
12  %  of  river  sites  were  sampled  with  at  least  at  the  minimum  recommended  frequency  for 
benthic invertebrates and macrophytes.21  

Monitored River Basin Specific Pollutants  

15 different  River  Basin Specific Pollutants  were reported to be monitored in  Denmark. The 
substance monitored at the most sites (60) was “dioxin-like polychlorinated biphenyls”. Three 

River  Basin  Specific  Pollutants  were  monitored  in  coastal  waters,  three  in  lakes  and  13  in 
rivers.  The  substances  in  coastal  water  were  only  monitored  in  biota  and  those  in  lakes  and 

rivers only in water. 

21  Denmark informed that for rivers, lakes and coastal waters monitoring frequencies and intervals are set on the 
basis  of  technical  knowledge  and  expert  judgement,  from  the  Danish  Centre  for  Environment  and  Energy, 
Aarhus University. 

42 

 
                                                      
River Basin  Specific Pollutants were not  monitored at  the recommended  frequency  at  any of 

the  sites.  The  analytical  methods  used  meet  the  minimum  performance  criteria  laid  down  in 
Article 4(1) of the QA/QC Directive (2009/90/EC)22 for the strictest standard applied. 

Table  3.4  shows  the  number  of  sites  used  to  monitor  River  Basin  Specific  Pollutants  in 
Denmark for the first and second RBMPs. 

Table 3.4 

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

pollutants  for  the  first  RBMPs  in  Denmark.  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 RBMPs 

RBMP 

second 
RBMP 

Sites used to monitor River Basin Specific Pollutants 

first RBMP  Sites used to monitor non-priority specific pollutants and/or 

other national pollutants 

Source: WISE electronic reports  
NR = Not reported to WISE 

Surveillance monitoring of surface water bodies  

Rivers 

Lakes 

Coastal 

21 

NR 

4 

NR 

61 

NR 

None  of  the  water  bodies  included  in  surveillance  monitoring  of  rivers,  lakes  and  coastal 
required  biological,  hydromorphological  and 
waters  were  monitored 

for  all 

the 

physicochemical quality elements, which indicates non-compliance with the WFD. 

Figure  3.1  shows  the  proportion  of  water  bodies  object  of  surveillance  and  operational 
monitoring in each cycle: operational monitoring generally covers a greater proportion of water 

bodies (except for lakes) in the second RBMPs. Surveillance monitoring was reported in WISE 
as occurring for the first time in lakes and not occurring at all in coastal waters in the second 

RBMPs. As explained above, for lakes in the first RBMPs and for coastal waters in the second, 
Denmark  used  the  same  monitoring  programmes  and  the  same  monitoring  sites  for  both 
surveillance  and  operational  monitoring.    Figure  3.2  shows  the  proportion  of  water  bodies 
object of surveillance monitoring. Surveillance monitoring sites are distributed throughout the 

status classes, in water categories where it is reported, including good and high status classes 
as required. 

22  http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:201:0036:0038:EN:PDF 

43 

 
 
                                                      
None  of  the  water  bodies  included  in  surveillance  monitoring  of  rivers,  lakes  and  coastal 

waters  were  monitored 
physicochemical quality elements, which may indicate non-compliance with the WFD. 

required  biological,  hydromorphological  and 

for  all 

the 

Figure 3.1  Percentage of water bodies included in surveillance and operational monitoring 
in  Denmark  for  the  first  RBMPs  and  second  RBMPs.  Note  no  differentiation  is  made 

between water bodies included in ecological and/or chemical monitoring  

Source: WISE electronic reports. Denmark subsequently noted that for the first RBMPs all lake monitoring sites 
served the purposes of both surveillance monitoring and operational monitoring. The same approach was taken 
for all coastal monitoring sites also for the second RBMPs. See Table 3.1 for numbers of surveillance and 
operational monitoring sites in lakes and coastal waters provided by Denmark. 

Figure 3.2 

Proportion  of  water  bodies  included  in  surveillance  monitoring  in 
Denmark shown for each ecological status/potential class. 

Source: WISE electronic reports. Note: Denmark subsequently noted that for the first RBMPs all lake monitoring 
sites served the purposes of both surveillance monitoring and operational monitoring. The same approach was 
taken for all coastal monitoring sites also for the second RBMPs. See Table 3.1 for numbers of surveillance and 
operational monitoring sites in lakes and coastal waters provided by Denmark. 

44 

 
 
 
 
There were significant changes in the delineation of surface water bodies in Denmark from the 

first  to  the  second  RBMPs  with  a  decrease  of  49%  and  28%  in  the  number  of  river  water 
bodies and coastal water bodies respectively. For lake water bodies, there was an increase of 

23% overall. 

For the second RBMPs, coastal water bodies were identified in all 4 RBDs. According to the 

WISE reporting, 91 % were included in operational monitoring, but none of these were in the 
Bornholm  RBD.  For  the  second  RBMPs,  9  %  of  river  water  bodies  were  included  in 

surveillance monitoring and 70 % in operational monitoring. 58 % of lake water bodies were in 
surveillance monitoring and 22 % in operational monitoring. 

Bearing in mind the significant decreases in the numbers of water bodies delineated from the 
first to the second RBMPs 5 % of river water bodies were in surveillance monitoring for the 

first RBMPs compared to 9 % for the second. Overall there was a significant increase in the 
proportion of river water bodies included in operational monitoring (14 % for the first RBMPs, 
70  %  for  the  second),  an  increase  in  coastal  water  bodies  (72  %  for  the  first,  91  %  for  the 

second) and a decrease in lake water bodies (37 % for the first RBMPs, 22 % for the second).  

Operational monitoring of surface water bodies  

The biological quality element predominantly used in Denmark for the operational monitoring 
of coastal waters was phytoplankton (82 % of water bodies included in operational monitoring) 

followed by angiosperms (74 %) and benthic invertebrates (49 %). Phytoplankton was also the 
predominant  biological  quality  element  used  in  the  operational  monitoring  of  lakes  (98  %), 

where macrophytes (38 %) and fish (0.5 %) were also used. In the operational monitoring of 
rivers,  benthic  invertebrates  were  used  in  96  %  of  water  bodies  included  in  operational 

monitoring, fish in 36 % and macrophytes in 2 %. 

In  coastal  water  and  rivers,  a  large  proportion  of  water  bodies  at  less  than  good  ecological 

status/potential are included in operational monitoring, 91 % and 94 %, respectively. For lakes 
this was only 27 %.  

Transboundary surface water body monitoring 

Denmark did not report any transboundary surface or groundwater bodies nor any monitoring 

sites that are part of international monitoring networks.  

3.1.2.  Ecological Status/potential of surface water  

The ecological status/potential of surface water bodies in Denmark for the second RBMPs is 
illustrated in Map 3.1.  

45 

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

RBMPs  with  that  for  the  second  RBMPs  and  that  expected  by  2015.  It  indicates  an  overall 
deterioration  in  ecological  status  from  the  first  to  the  second  RBMPs.  Denmark  has  since 

suggested that this deterioration may be a result of the changes in delineation of waterbodies 
and  the  use  of  more  quality  elements  in  the  classification  of  status  in  the  second  RBMPs. 

Therefore, any comparison between the two RBMPs needs to be taken with care. 

Member States were asked to report the expected date for the achievement of good ecological 

status/potential. The information for Denmark is shown in Figure 3.4. 

Map 3.1 

 Ecological status or potential of surface water bodies in Denmark 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 

46 

 
 
 
  
  
  
  
  
  
  
  
Figure 3.3  Ecological  status  or  potential  of  surface  water  bodies  in  Denmark  for  the 
second RBMPs, for the first RBMPs and expected in 2015. The number in the 

parenthesis  is  the  number  of  surface  water  bodies  in  each  cycle.  Note  the 
period  of  the  assessment  of  status  for  the  second  RBMPs  was  1993  to  2014. 

The year of the assessment of status for first RBMPs is not known  

Source: WISE electronic reports  

47 

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

bodies in Denmark. The number in the parenthesis is the number of water bodies in each 
category23  

Source: WISE electronic reports   

The large majority of water bodies in all water categories are in less than good status/potential, 
and quite a high proportion are in poor or even bad status/potential. There are also still several 

water  bodies  with  unknown  ecological  status/potential,  in  particular  for  artificial  and  heavily 
modified  rivers.  It  should  be  noted,  however,  that  the  big  differences  in  delineation  of  water 

bodies  and  the  changes  in  number  of  quality  elements  used  in  the  classification  make  any 
quantitative comparison very difficult. 

The overall picture indicates a deterioration in  status/potential since the revised first  RBMPs 
(Figure  3.3)  with  5-20  %  more  water  bodies  in  less  than  good  status/potential  in  the  second 

RBMPs,  except  coastal  waters  in  the  Zealand  RBD,  which  has  a  slight  improvement,  while 
rivers  in  the  Zealand  RBD  and  coastal  waters  in  the  Jutland  and  Funen  RBD  and  the 

International  (Vidaa-Krusaa)  RBD  show  no  change.  A  more  detailed  analysis  included  in  the 
RBMPs  estimates  that  there  is  a  general  improvement  for  lakes  and  coastal  waters,  and  no 
change for rivers. 

In the first RBMPs, 19 % of surface water bodies in Denmark were reported to have unknown 

ecological  status/potential  and  this  increased  to  24  %  in  the  second.  Many  heavily  modified 

23  Denmark subsequently clarified that for coastal waters 2 water bodies were reported as expected to be in good 
ecological status by 2015 and 48 water bodies are expected in good status by 2021 unless delayed because of 
natural conditions. For rivers, 55 % of water bodies were reported as expected to be in good ecological status 
by 2015 (which corresponds to 4306 water bodies), further 21 % expected in good status by 2021 and further 
24 % in good status by 2027. 

48 

 
 
                                                      
and  artificial  water  bodies  (30-60  %)  were  reported  with  unknown  ecological  status  in  most 

RBDs.  For  natural  water  bodies,  relatively  few  water  bodies  were  reported  with  unknown 
ecological  status  (15-25%);  this  is  an  improvement  since  the  revised  first  RBMPs,  when  the 

proportion of natural water bodies with unknown ecological status was much higher. 

The ecological status changes from the first to the second RBMPs have been described in the 

second RBMPs. Water bodies that have been re-delineated and those that had unknown status 
in the first RBMPs have not been compared. Results for biological quality elements that have 

only been classified in the second RBMPs could also not be included in the comparisons.  

The comparisons show that the large majority (60-80 %) of all classified water bodies have the 

same status in the first and second RBMPs, which is explained by the short time between the 
publication of the first RBMP and the second RBMP.  

The changes from the first to the second RBMPs for rivers are quite different in the different 
RBDs:  for  the  Jutland  and  Funen  RBD,  the  same  proportion  of  water  bodies  (16  %)  has 
improved or deteriorated; for the Zealand RBD, only 10 % have improved, while 20 % have 

deteriorated;  while  for  the  Vidaa-Krusaa  RBD,  27  %  have  improved  and  13  %  have 
deteriorated.  

The changes for lakes are quite similar in the different RBDs with more water bodies improved 
than  deteriorated:  for  the  Jutland  and  Funen  RBD,  21  %  have  improved,  while  10  %  have 

deteriorated; for the Zealand RBD, 24 % have improved, while 9 % have deteriorated; while 
for the Vidaa-Krusaa RBD, 23 % has improved and 15 % has deteriorated. 

The changes for coastal waters show improvements in all the RBDs: 16 % in the Jutland and 
Funen RBD, 33 % in the Zealand RBD, except in the Vidaa-Krusaa RBD, where there were no 

changes, and in the Jutland and Funen RBD, where 3 % have deteriorated. 

As stated above, any comparison between the two cycles needs to be taken with care, due to 

the significant re-delineation of surface water bodies that took place and to the use of a larger 
number of biological quality elements in the second RBMPs. The supporting quality elements 

are not classified in any water bodies in the two cycles. 

Confidence in ecological status assessment 

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

Overall the confidence in the classification of surface water bodies increased from the first to 
the second RBMPs: 2 % were classified with high confidence in the first RBMPs and 68 % in 

49 

 
the  second.  The  confidence  in  classification  is  high  for  all  coastal  water  bodies  and  for  the 

large  majority  of  rivers  and  lakes  where  the  overall  ecological  status/potential  is  classified. 
There  are  no  water  bodies  classified  with  low  confidence.  This  is  a  major  improvement 

compared to the first RBMPs, in which there was no information on confidence for more than 
95 % of the river and lake water bodies.  

Figure 3.5  Confidence  in  the  classification  of  ecological  status  or  potential  of  surface 
water bodies in Denmark based on the most recently assessed status/potential  

Source: WISE electronic reports  

Classification of ecological status at the quality element level 

Figure  3.6  shows  the  percentage  of  water  bodies  in  terms  of  the  biological  quality  elements 
used for classification. 

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

with caution, as there are differences between the numbers of surface water bodies classified 
for individual elements from the first to the second RBMPs. 

Figure 3.8 illustrates the basis of the classification of ecological status/potential of rivers and 
lakes in Denmark for the second RBMPs. 

50 

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

classification of surface water bodies in Denmark. 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 reports  

51 

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

biological quality elements in surface water bodies from the first to the second 
RBMPs. The number in brackets provides the number of surface water bodies 
with status24 

Source: WISE electronic reports. . 

24  Note  that  comparison  between  the  first  and  the  second  RBMP  should  be  taken  with  care  regarding  the  re-

delineation of water bodies. 

52 

 
 
                                                      
Figure 3.8 

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

coastal  waters  in  Denmark  using  one,  two,  three  or  four  types  of  quality 
element 
Note:  The  four  types  are:  biological;  hydromorphological,  general  physicochemical  and  River 
Basin Specific Pollutants 

Source: WISE electronic reports 

Supporting physicochemical quality elements are not classified 25(Figure 3.8) and classification 
of status relies on biological quality elements (Figure 3.6 and Figure 3.7). This is in particular 

the  case  for  the  nutrients  (phosphorus  and  nitrogen)  in  rivers.  Diffuse  pollution  from 
agriculture  and  nutrient  pollution  (which  includes  both  phosphorus  and  nitrogen)  were  not 
reported as a significant pressure or impact in rivers26.  

The change in status/potential from the first to the second RBMPs at the quality element level 

was  reported  to  be  unknown  for  the  large  majority  of  water  bodies,  but  was  reported  for 
approximately one third of lakes water bodies in all the RBDs for phytoplankton and for a few 

coastal water bodies in  the Jutland and Funen RBD and the Zealand RBD for phytoplankton 
and  angiosperms.  Two  thirds  show  improvement  and  one  third  show  deterioration.  All  these 

changes were reported to be real and not due to changes in delineation or in methodologies. 

Assessment methods and classification of biological quality elements 

Reference conditions and class boundaries are developed for most biological quality elements 
in all national types. New assessment methods have been developed since the first RBMPs, for 

25   Denmark has subsequently informed that physico-chemical elements are being monitored in rivers, lakes and 

coastal waters, but assessment methods for classification have not yet been developed.  

26  Denmark subsequently stated that nitrogen is not considered a pressure for rivers since the residence time is 

short. 

53 

 
 
                                                      
macrophytes  and  fish  in  rivers  and  lakes.  The  remaining  gaps  are  phytobenthos  in  rivers27, 
benthic invertebrates and phytobenthos in lakes 

The  sensitivity  to  impacts  of  the  various  existing  methods  is  consistent  for  all  the  relevant 

impacts  in  Denmark  (nutrients,  organic,  acidification,  hydromorphological)  for  the  various 
biological  quality  elements,  except  for  nutrients  (including  phosphorus)  in  rivers,  for  which 
there is no sensitive biological quality element method developed28. 

Transitional  waters  have  not  been  delineated  in  Denmark,  so  there  are  no  biological  quality 

element methods for that water category. Denmark has provided the Commission in 2009 with 
the technical explanation for not designating transitional waters.  

Examination  of  the  RBMPs  showed  that  reference  conditions  are  missing  for  the  following 
biological quality elements in river types: benthic algae in all river types, benthic invertebrates 

and macrophytes for the soft-bottom river type, macrophytes in small rivers. There are projects 
to  develop  a  new  index  for  benthic  algae  in  all  river  types  and  macrophytes  in  small  rivers. 
There  is  no  explanation  on  the  reason  why  benthic  algae  are  missing.  For  macrophytes,  the 

current  index  is  considered  not  applicable  in  small  rivers  and  for  benthic  invertebrates  the 
current  index  is  not  applicable  in  soft-bottom  rivers,  according  to  experts  from  Aarhus 

University. There is a plan to develop a new index for benthic invertebrates and macrophytes 
in soft-bottom rivers.  

Reference conditions are missing for benthic algae and benthic invertebrates in all lake types. 
A classification system for these biological quality elements in lakes was under development, 

but it has not been used for classification of ecological status in lakes for the second RBMPs. 
Phytoplankton class boundaries are missing for humic lake types29. No justifications are found 
in the plans nor in relevant background documents to explain these gaps30.  

For coastal waters, reference conditions are missing for macroalgae, for which no justification 
was found31.  

27  Denmark subsequently stated that a research institution has been requested to provide the scientific basis for 

the preparation of a phytobenthos index in rivers. 

28    Denmark subsequently stated that nitrogen is  not considered a pressure for rivers  since the residence time is 

short. A research institution has been requested to work on phosphorus pressure for rivers. 

29  Denmark subsequently stated that phytopolankton class boundaries have been developed for five lake types. 
30  Denmark subsequently clarified that for humic lake types chlorophyll class boundaries are used as a proxy for 
phytoplankton class boundaries, except for type five lakes where phytoplankton class boundaries are available. 
31   Denmark subsequently stated that an assessment method which includes both angiosperms and macroalgae is 

under development. It is expected to be ready for the third RBMP. 

54 

 
                                                      
Intercalibration of biological quality element methods 

A minority of national  types  are linked to  common  intercalibration types in  all RBDs. Some 
national  types overlap several  intercalibration types, and it is  unclear which class boundaries 

are  used.  This  is  particularly  difficult  for  river  types,  as  the  Danish  river  typology  does  not 
include  geology  as  a  typology  factor.  Some  national  types  do  not  match  any  common 

intercalibration type, so information on class boundaries has not been reported.  

Phytoplankton,  macrophytes  and  fish  biological  quality  elements  in  lakes  are  intercalibrated 

through two types that are linked to the common intercalibration types L-CB1 and L-CB2. The 
other nine national types have not been intercalibrated.  

Some  biological  quality  elements  in  rivers  (with  the  exception  of  benthic  algae)  have  been 
intercalibrated  in  all  the  three  national  types  that  are  linked  to  the  common  intercalibration 

types  in  the  Central  Baltic  Geographic  Intercalibration  Group.  However,  these  three  national 
types overlap two of these common intercalibration types, which have highly different geology 
and  it  is  not  clear  which  of  the  intercalibrated  class  boundaries  are  used  for  classification  of 

rivers. Two national types with soft-bottom (small and medium sized rivers, type 1 and 2) have 
not been intercalibrated.  

Biological  quality  elements  (with  the  exception  of  macroalgae)  in  coastal  waters  are 
intercalibrated for the six national types that are linked to the common intercalibration types in 

North East Atlantic Geographic Intercalibration Group and Baltic Geographic Intercalibration 
Group.  The  other  11  national  types,  mostly  fjords,  have  not  been  intercalibrated  for  any 

biological quality element.  

No information on particular methods was found in the RBMPs. There was a general statement 

in  the  RBMPs  that  the  results  of  the  intercalibration  must  be  translated  so  that  the  national 
types obtain the same level of protection as the intercalibrated types. This work has been done 
by national experts32.  

Assessment methods for hydromorphological quality elements 

Morphological  conditions  of  rivers  were  reported  to  be  assessed  in  terms  of  ecological 
status/potential reported and their classification boundaries are related to the class boundaries 

for the sensitive biological quality elements. Hydrological/tidal regime in all 3 categories and 
river continuity are not assessed in terms of ecological status/potential. It should be noted that 

32  Denmark  has  later  informed  that  type  or  site  specific  reference  conditions  and  results  from  Decision 
2013/480/EU,  including  high-good  and  good-moderate  class  boundaries,  have  been  applied/translated  to  all 
national types. 

55 

 
                                                      
no hydromorphological quality elements were reported to be monitored and none were used in 
the  classification  of  status/potential  in  Denmark33.  However  Denmark  subsequently  clarified 
that all hydromorphological quality elements are monitored in rivers. 

There  was  no  description 
the  assessment  of 
hydromorphological  quality  elements  from  the  first  to  the  second  RBMPs.  The  only 

the  RBMPs  of  any  changes 

in 

in 

assessment method for the hydromorphological quality elements is a physical index for rivers, 
which was also available in the first RBMPs. This index seems to be used both as a typology 

factor, and as a quality element for classification with a good-moderate status threshold of 0.5. 
For rivers, it is unclear whether the physical index includes all the hydromorphological quality 

elements  required  in  the  WFD,  and  whether  this  is  consistent  with  the  high-good  status  and 
good-moderate  status  thresholds  for  benthic  fauna  or  other  biological  quality  elements.  For 

lakes  and  coastal  waters,  there  are  no  assessment  methods  developed  for  any  of  the 
hydromorphological quality elements34.  

Classification methods for general physicochemical quality elements  

Three  physicochemical  quality  elements  (transparency,  oxygenation  conditions  and  nutrient 
conditions)  were  assessed  in  terms  of  the  ecological  status/potential  of  coastal  waters;  one 

(nutrient  conditions)  was  used  in  lakes  and  one  (salinity  conditions)  also  in  rivers.  The 
classification  boundaries  for  the  assessed  quality  elements  were  reported  to  be  related  to  the 

class boundaries for the sensitive biological quality elements. 

No standards were reported to WISE for any physicochemical quality element, although they 

are included in a background document.  

Information  was  found  in  the  RBMPs  on  the  good-moderate  status  boundaries  for  only  one 

physicochemical  quality  element  in  rivers  which  is  ochre  (ferrous  iron),  where  the  good-
moderate status  boundary  of 0.7 mg/l is  said  to  be correlated with  the benthic fauna at  good 

status  class.  This  quality  element  would  only  be  used  for  classification  in  the  absence  of 
biological data on benthic fauna. 

For lakes, there are good-moderate status boundaries for total phosphorus and total nitrogen for 
shallow and deep lakes. For phosphorus, the good-moderate status boundary for shallow lakes 

is  0.080  milligrams  per  litre  and  for  deep  lakes  0.042  milligrams  per  litre  (summer  mean 
values).  For  nitrogen,  the  good-moderate  status  boundaries  are  0.95  milligrams  per  litre  for 

33  Denmark subsequently informed that limit values for hydromorphological quality elements in rivers are under 

development. 

34  Denmark  subsequently  informed  that  hydromorphological  classification  methods  for  lakes  are  under 

development. 

56 

 
                                                      
shallow  lakes  and  0.90  milligrams  per  litre  for  deep  lakes  (summer  mean  values).  These 

boundaries  are  based  on  dose-response  curves  with  phytoplankton,  using  the  upper  25th 
percentile of lakes  that are in  good status  in  terms  of chlorophyll a to  set  the good-moderate 

status boundary value for the nutrients. This approach provides quite relaxed boundaries.  

For coastal waters, three physicochemical quality elements have recently been developed with 

good-moderate status boundaries that intend to support the biological quality elements. These 
are light conditions (transparency) supporting angiosperms, oxygen conditions in deep waters 

supporting benthic fauna and inorganic nitrogen supporting phytoplankton in nitrogen-limited 
waters. The boundaries appear to be appropriate to support good status, at least for oxygen and 

nitrogen.  The  transparency  conditions  quality  element  is  difficult  to  judge,  due  to  a  special 
model used to set the boundaries. However, none of these have been used for classification in 
any  of  the  coastal  waters  in  the  second  RBMPs35,  according  to  the  information  reported  to 
WISE.  

Large  gaps  remain  for  rivers,  in  particular  for  nutrients  (phosphorus  and  nitrogen),  turbidity, 

temperature and oxygen. For lakes, the most serious gaps are for transparency and oxygen in 
deep waters of deep lakes. Acidification parameters are less relevant in most Danish rivers and 

lakes, as they have moderate or high alkalinity and are not vulnerable to acidification. 

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

The selection of River  Basin Specific Pollutants is  based on monitoring results, screening of 
pollutants in the aquatic environment, and information on the use of substances.  

Environmental  Quality  Standard  values  were  reported  for  water  for  10  River  Basin  Specific 
Pollutants in Denmark as a whole: nine in rivers and three in lakes; as well as two in biota in 
coastal  waters36.  The  standards  have  been  derived  in  accordance  with  the  2011  Technical 
Guidance Document No 27.37  

Use of monitoring results for classification 

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

35    Denmark  informed  that  some  hydromorphological  and  physiochemical  parameters  are  being  monitored,  but 
specific  assessment  methods  for  classification  are  not  operationalised.  Those  parameters  are  included  as 
descriptors  and  drivers  in  the  model  for  coastal  waters  and  for  definition  of  the  reference  condition  for 
biological quality elements and in the derivation of good ecological status. 

36  Denmark informed that the total number and the number for rivers are apparently a reporting error: EQS values 
have  been  established  for  15  River  Basin  Specific  Pollutants,  which  corresponds  to  those  monitored  (see 
section on monitoring above). The correct figure for rivers is 12.  

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

WFD%2027%20EC%202011.pdf 

57 

 
                                                      
Overwhelmingly the results from monitoring have been used in the classification of ecological 

status/potential  of  quality  elements.  Expert  judgment  was  used  for  phytoplankton  for  some 
coastal  water  bodies  in  particular  in  the  Bornholm  RBD  where  the  one  water  body  had  not 

been  directly  monitored.  Benthic  invertebrates  and  phytobenthos  were  not  used  in  the 
classification of lakes, phytobenthos was not used in rivers38, and macroalgae were not used in 
coastal  waters.  Hydromorphological  and  physicochemical  quality  elements  were  not  used  in 
the classification of any  surface water body39. River  Basin  Specific Pollutants were used but 
only in a few river and lake water bodies (<0.5% in each). 

Denmark reported that grouping of water bodies has been used for the classification of water 

bodies with no monitoring sites. However, this is inconsistent with other reported information, 
which indicated that there were no water bodies classified based on grouping.40 

38  Denmark subsequently stated that a research institution has been requested to provide the scientific basis for the 

preparation of a phytobenthos index in rivers. 

39  Denmark  subsequently  stated  that  for  coastal  waters  and  lakes,  some  hydromorphological  and  general 
physiochemical  parameters  are  being  monitored,  but  specific  assessment  methods  for  classification  are  not 
operationalised. Those parameters are included as descriptors and drivers in the model for coastal waters and 
for  definition  of  the  reference  conditions  for  biological  quality  elements,  and  derivation  of  good  ecological 
status. For rivers, limit values for hydromorphological quality elements are under development. 

40    Denmark  have  subsequently  clarified  that  grouping  was  used  for  17  coastal  water  bodies  in  the  Jutland, 

Zealand and Bornholm RBDs, instead of expert judgement as reported by mistake in WISE.  

58 

 
                                                      
Figure 3.9 

Basis of the classification of ecological status/potential in Denmark 

Source: WISE electronic reports. Denmark subsequently clarified that coastal waters that were classified 

based on grouping were reported in WISE as based on expert judgement. 

For rivers, it is reported that some water bodies are classified based on grouping, and therefore 
the number of classified water bodies for biological quality elements is higher than the number 

of  water  bodies  monitored.  But  Denmark  has  indicated  in  Annex  0  that  it  is  not  possible  to 
report  the  surface  water  bodies  which  have  been  monitored  and  used  in  grouping  due  to 

aggregation  of  river  water  bodies  from  first  to  second  RBMPs.  River  water  bodies  grouped 
cannot be individually identified, including those that have been monitored.  

The RBMPs indicate that only monitored water bodies are classified for rivers and lakes. Both 
recent  (2008-2013) and older monitoring data are used if they are considered by the national 

WFD  Authority  (Danish  Environmental  Protection  Agency)  still  to  be  relevant  for 
classification of the current ecological status. Thus, there is no information explaining why the 

number of classified water bodies for different biological quality elements in rivers is reported 

59 

 
 
in WISE to be a bit higher than the number monitored for the same biological quality element.  

For lakes, there is no such discrepancy as the number of water bodies monitored and classified 
is the same for each biological quality element. For coastal waters, a small percentage (around 

15 %) has been reported as being classified based on expert judgement for phytoplankton (but 
were in reality based on grouping, as explained subsequently by Denmark). According to the 

RBMPs,  the  status  classification  is  based  on  data  between  2007  and  2013.  For  the  other 
biological quality elements (angiosperms and benthic invertebrates), the number of monitored 

and classified water bodies is the same.  

For River Basin Specific Pollutants, the number of monitored and classified water bodies is the 

same for rivers and lakes (very low proportion of all water bodies), while for coastal waters, 
some  water  bodies  are  monitored,  but  none  are  classified,  according  to  the  WISE  electronic 

reporting. The reason for the lack of classification of River Basin Specific Pollutants in coastal 
waters  is  that  these  are  monitored  in  sediments,  fish  or  mussels,  while  the  Environmental 
Quality Standards have only been developed for water.   

Overall classification of ecological status 

Figure  3.10  shows  the  percentage  of  river,  lake  and  coastal  water  bodies  where  no  quality 

elements  of  different  types  (biological  and  different  supporting  elements)  were  used  in  the 
classification of ecological status, reflecting the reliance on biological quality elements. 

Figure 3.10 

The percentage of coastal, river and lake water bodies in Denmark where 
no  biological  quality  element  or  no  hydromorphological  (HYMO)  or  no 

general  physicochemical  (PHYSCHEM)  or  no  River  Basin  Specific 
Pollutant (RBSP) has been used in the classification of ecological status or 

potential 

Source: WISE electronic reports 

60 

 
 
The one-out, all-out principle has been used in all RBDs, but has not included the supporting 

quality  elements,  (except  for  lakes  where  it  also  applies  to  nutrient),  which  is  not  compliant 
with Annex V, 1.4.2 of the Water Framework Directive.  

3.2.  Main changes in implementation and compliance since first RBMPs 

The  first  RBMPs  for  Denmark  were  adopted  on  21  December  2011  and  reported  to  the 

Commission on 22 December 2012. For legal reasons the first plans were declared invalid by 
the Danish  Authorities in the spring of 2013, the RBMPs were resubmitted to  a consultation 
process  and  the  revised  RBMPs  for  the  first  planning  period  were  adopted  in  October  2014. 

The terms “original RBMPs” and “revised RBMPs” are used throughout this assessment, when 
referring to the original first RBMPs adopted in 2011 and to the revised first RBMPs adopted 

in 2014 respectively. 

The large majority of water bodies were in less than good ecological status in the first RBMPs 

and  are  still  in  less  than  good  ecological  status  in  the  second  RBMPs,  with  the  exception  of 
rivers  and  lakes  in  the  Bornholm  RBD  where  only  34-40%  are  in  less  than  good  status 

(unknowns excluded).  

However, the change in overall ecological status cannot be reliably compared from the first to 

the  second  RBMPs  due  to  several  reasons:  a)  the  total  number  of  water  bodies  has  changed 
significantly  from  the  first  to  the  second  RBMPs,  primarily  due  to  a  major  re-delineation  of 

river water bodies, with a decrease of 50% in the number of river water bodies, b)  the number 
and  proportion  of  water  bodies  with  unknown  status/potential  has  changed,  c)  the  status  has 

been  assessed  with  more  biological  quality  elements  in  the  second  RBMPs  than  in  the  first. 
Comparison of water bodies which have not been re-delineated and which have been classified 

with the same quality elements in both the first and second RBMPs is more reliable.  

The change in status/potential at the quality element level has been reported as “unknown” for 

almost  all  water  bodies,  but  information  is  given  for  approximately  one  third  of  lake  water 
bodies in all the RBDs for phytoplankton and for a few coastal water bodies in the Jutland and 

Funen RBD and the Zealand RBD for phytoplankton and angiosperms. The changes go in both 
directions,  with  two  thirds  showing  improvement  and  one  third  showing  deterioration.  The 

changes  were  reported  to  be  consistent,  and  not  due  to  changes  in  delineation  or 
methodologies.  

New methods for some biological quality elements since the first RBMPs have been reported 
for macrophytes and fish in rivers. The reference conditions and class boundaries have been set 

61 

 
for more biological quality elements than in the revised first RBMPs, as macrophytes and fish 

in rivers have been included, and for all national types in all water categories.  

The  number  of  surveillance  sites  in  lakes  increased  from  the  first  to  the  second  RBMPs. 

Conversely, no surveillance sites were reported for coastal waters for the second RBMPs and 
243 sites were used for surveillance monitoring for the first.  However, Denmark subsequently 

clarified  that  for  the  second  RBMPs,  no  distinction  is  made  between  operational  and 
surveillance  monitoring  in  coastal  waters,  therefore  monitoring  for  both  purpose  is  based  on 

the  781  sites  that  were  reported.  Overall,  there  were  only  small  changes  in  the  numbers  of 
surveillance sites in rivers from the first to the second RBMPs. 

Phytobenthos was not monitored in rivers and lakes for the first RBMPs and this was still the 
case  for  the  second  RBMPs.  All  biological  quality  elements  were  said  to  be  monitored  in 
coastal waters for the first RBMPs, but macroalgae were not included for the second RBMPs41.  

It  was  reported  that  some  physicochemical  and  hydromorphological  quality  elements  were 
monitored  in  some  water  categories  for  the  first  RBMPs,  while  for  the  second  none  were 

reported to be monitored in any water body. However, this is a reporting mistake, as many of 
these  supporting  quality  elements  are  monitored,  according  to  the  national  monitoring 

programme. 

Bearing in mind the significant decreases in the numbers of river water bodies delineated from 

the first to the second RBMPs, 5 % of river water bodies were in surveillance monitoring for 
the first RBMPs compared to 9 % for the second. Overall there was a significant increase in the 

proportion of river water bodies included in operational monitoring (14 % for the first RBMPs, 
70 % for the second), an increase in coastal water bodies (72 % for the first and 91 % for the 

second) and a decrease in the proportion of lake water bodies (37 % for the first RBMPs and 
22 % for the second). 

3.3.  Progress with Commission recommendations 

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

requested action on the following: 

  Recommendations: 

41  Denmark subsequently informed that macroalgae were monitored in the second RBMPs and that an assessment 
method which includes both angiosperms and macroalgae is under development and is expected to be ready 
for use for the 3rd RBMPs. 

62 

 
                                                      
o  The  ecological  status  classification  system  is  weakly  developed,  and  a  large 
proportion  of  the  biological  quality  elements  are  missing.  The  Danish 
classification  methods  are  only  developed  for  benthic  fauna  in  rivers, 

chlorophyll in lakes, and angiosperm depth limit and benthic fauna (fjords) or 
chlorophyll (open coast). 

o  Denmark needs to extend its classification system for lakes and coastal waters 
to  address  hydromorphological  quality  elements.  For  rivers,  class  boundaries 

given for continuity, flow and morphological variation of river banks need to be 
developed. 

o  The assessment of ecological status was reported with "no info on confidence" 
for 95% of all water bodies. It also seems like fewer methods are available now 

compared to what was reported in 2007. This needs to be clarified. 

Assessment:  New  methods  for  macrophytes  and  fish  in  rivers  and  lakes  have  been 
developed and intercalibrated. The remaining gaps are phytobenthos in rivers, benthic 

invertebrates and phytobenthos in lakes, and macroalgae in coastal waters. Assessment 
methods  for  benthic  invertebrates  in  lakes  and  phytobenthos  in  rivers  and  lakes  are 

under  development.  Hydromorphological  quality  elements  have  not  been  included  in 
the  classification  of  ecological  status  in  the  second  RBMPs42.  Large  gaps  remain  for 
physicochemical  quality  elements,  in  particular  for  nutrients  in  rivers  as  no  standards 
were  reported  and  as  there  is  no  biological  quality  element  sensitive  to  nutrients. 

Demark  has  reported  the  confidence  in  the  second  RBMPs  ecological  status 
assessments.  Overall,  the  confidence  in  the  classification  of  surface  water  bodies 

increased  from  the  first  to  the  second  RBMPs:  2  %  were  classified  with  high 
confidence for the first RBMPs and 68% for the second. 

These recommendations are partially fulfilled. 

  Recommendation:  Denmark  needs  to  further  extend  the  monitoring  programme  to 
include all biological, physical-chemical and hydromorphological quality elements as 
relevant,  for  all  water  categories  (rivers,  lakes,  coastal  waters)  and  ensure  there  is 

adequate  monitoring  of  groundwaters  to  enable  assessment  of  status,  pressures  and 
trends. The reported monitoring system is a new one (NOVANA) and not the one used 

for the first RBMPs. Although it is new, it appears to not yet be WFD compliant.  

42  Denmark informed that for coastal waters, some hydromorphological and physiochemical parameters are being 

monitored but specific assessment methods for classification are not operational.  

63 

 
                                                      
Assessment:  Most  of  the  gaps  in  monitoring  identified  in  the  first  RBMPs  are  still 

present in the second RBMPs, such as phytobenthos in rivers. Denmark also reported 
that  most  of  the  physicochemical  and  hydromorphological  quality  elements  are 

monitored, however, there are still major gaps and potential non-compliance issues, e.g. 
for nutrients in rivers (including both phosphorus and nitrogen). 

In  conclusion:  there  has  been  some  progress43,  but  the  recommendation  is  partially 
fulfilled. 

  Recommendation:  Surveillance  monitoring  stations  for  lakes  need  to  be  established 
and  reported,  and  the  types  of  quality  elements  monitored  per  station  need  to  be 

reported.  

Assessment: Surveillance sites were reported for lakes for the second RBMPs, although 

not all required biological quality elements were monitored (phytobenthos and benthic 
invertebrates are still missing). There are also some gaps in the monitoring of physico-

chemical quality elements. 

In conclusion, there has been some progress on this recommendation, but there are still 

major  shortcomings  in  the  monitoring  of  lakes.  The  recommendation  is  partially 
fulfilled. 

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

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

there  is  an  ambitious  approach  to  combating  chemical  pollution  from  River  Basin 
Specific  Pollutants  and  that  adequate  measures  are  put  in  place.  Denmark  needs  to 

provide clearer reporting on the methodologies used to set the Environmental Quality 
Standards values for national specific pollutants.  

Assessment:  The  selection  of  River  Basin  Specific  Pollutants  is  based  on  monitoring 
results,  screening  of  pollutants  in  the  aquatic  environment,  monitoring  of  emissions 

from  major  sources  and  information  on  the  use  of  substances.  Denmark  has  reported 
information  on  the  monitoring  of  River  Basin  Specific  Pollutants  in  coastal  waters, 

lakes and rivers. Biota is monitored for two substances in coastal waters. However, the 
substances  are  not  monitored  at  the  minimum  frequency  recommended  in  the  WFD, 

43    Denmark  informed  that  regarding  both  quality  elements/parameters  and  numbers  of  monitoring  stations,  the 
monitoring programme in the second RBMPs is more comprehensive than the monitoring programme in the 
first RBMPs. 

64 

 
                                                      
and deviations are not fully explained. The CIS technical guidance has been used to set 

the Environmental Quality Standards for the pollutants and the analytical methods used 
are  in  line  with  Article  4(1)  of  QA/QC  Directive  (2009/90/EC)44.  Exceedances  of 
Environmental  Quality  Standards  have  been  used  in  the  classification  of  single 
pollutants.  However,  very  few  water  bodies  are  monitored  and  classified  for  River 

Basin Specific Pollutants and it is not clear how these results have been combined with 
the  results  for  the  biological  quality  elements  in  assessing  the  overall  ecological 

status/potential of water bodies. 

There has been some progress but the recommendation is partially fulfilled. 

  Recommendation:  Denmark  needs  to  be  more  transparent  on  the  use  of  grouping  of 

water bodies for monitoring and classification.  

Assessment:  It  has  been  reported  that  grouping  of  water  bodies  has  been  used  in 
extrapolating  the  assessment  and  classification  of  ecological  status  from  monitored 

water bodies to those water bodies with no monitoring sites. Although it was reported 
that grouping was not the basis for the classification of any water body in Denmark, it 

has been clarified that this contradictory reporting is due to wrong reporting in WISE, 
with expert judgement having been selected instead of grouping. 

However, there is no information on how the grouping was done, which means that this 
recommendation has not been fulfilled. 

  Recommendation:  Denmark  needs  to  improve  the  certainty  of  its  ecological  status 

assessment. 

Assessment: The confidence in classification is high for all coastal water bodies and for 
the large majority of rivers and lakes where the overall ecological status  is classified. 

There are no water bodies classified with low confidence. This is a major improvement 
compared  to  the  first  RBMPs,  in  which  there  was  no  information  on  confidence  for 

more than 95% of the river and lake water bodies. 

This recommendation is fulfilled. 

44   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  

65 

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

4.1.  Assessment  of 

implementation  and 

compliance  with  WFD 

requirements in second cycle  

4.1.1.  Monitoring of chemical status in surface waters 

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

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

ecological status/potential and chemical status.  

Surveillance monitoring programmes should allow Member States to supplement and validate 

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

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

from the programme of measures. 

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

monitoring programmes in Denmark for the second RBMPs. 

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

surface waters for the second RBMP. In this figure, no distinction is made between sites used 
for  surveillance  and/or  operational  purposes.  More  detailed  information  can  be  found  on  the 
website of the European Environment Agency45. 

Very  small  proportions  of  monitoring  sites  are  monitored  for  chemical  status  compared  to 

those monitored for ecological status.Denmark has assigned the monitoring purpose (chemical 
status) to 217 sites in 134 surface water bodies (1.51 % of total sites monitored in Denmark as 

a whole).  

For  the  second  RBMPs,  for  surface  water  bodies  across  three  RBDs  (Jutland  and  Funen, 

Zealand and International (Vidå-Kruså)) in Denmark, there appears to be a lower proportion of 
sites monitored for Priority Substances under operational monitoring (one site – 0.01% of total 

sites monitored across the whole of Denmark) than under surveillance monitoring (35 sites – 

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

66 

 
                                                      
0.2%  of  total  sites  monitored  across  the  whole  of  Denmark).  In  terms  of  water  bodies 

monitored,  the  percentages  are  0.01  and  0.4  %  for  operational  and  surveillance  monitoring, 
respectively.  The  Bornholm  RBMP  had  no  information  on  monitoring  purpose  for  lakes  and 

rivers and the International (Vidå-Kruså) RBMP had no information for rivers.  

The RBMPs provided no justification for the very low number of sites assigned to operational 

and surveillance monitoring. 

Figure 4.1 

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

comparison,  ecological  status,  in  Denmark.  The  number  in  parenthesis  next 
to  the  category  is  the  total  number  of  monitoring  sites  irrespective  of  their 
purpose. Note no data for territorial waters46. 

Source: WISE electronic reporting 

Figure 4.2 summarises the proportion of water bodies monitored for chemical status in surface 
waters  for  the  second  RBMP.  In  this  figure,  no  distinction  is  made  between  sites  used  for 
surveillance  and/or  operational  purposes.  Also  given  is  the  proportion  of  water  bodies 

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

Very  small  proportions  of  surface  water  bodies  are  monitored  for  chemical  status  with  the 

exception of coastal waters where 60 % were monitored for this purpose (Figure 4.2). 

46   Denmark subsequently identified that there is an error in the reporting of the purpose of monitoring sites and 
that for river water bodies 13136 (just under 100%) of monitoring sites were monitored for ecological status. 
625 (80%) monitoring sites were also monitored for ecological purposes in coastal waters.  

67 

 
 
 
                                                      
Water bodies failing to achieve good chemical status were found in all RBDs except Bornholm 

RBD,  where  all  waterbodies  were  at  good  status.  All  water  bodies  failing  to  achieve  good 
chemical  status  were  reported  to  be  monitored  in  the  Jutland  and  Funen,  Zealand  and 

International  (Vidå-Kruså)  RBDs,  except  for  one  lake  water  body  in  the  Jutland  and  Funen 
RBD.  Denmark  clarified  that  all  water  bodies  failing  to  achieve  good  chemical  status  were 

monitored. 

Figure 4.2 

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

monitored  for  chemical  status  and  monitored  for  ecological  status,  in 
Denmark. The number in parenthesis next to the category is the total number 
of water bodies in that category47  

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

EQS  Directive 

(version 

in 

force 

in  2009),  mercury,  hexachlorobenzene 

and 

47    Denmark  subsequently  clarified  that  in  the  1st  cycle  territorial  waters  were  reported  as  coastal  water  bodies 

whereas in the 2nd cycle they were reported separately. 

68 

 
 
                                                      
hexachlorobutadiene  have  to  be  monitored  in  biota  for  status  assessment,  unless  Member 

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

Spatial coverage 

According  to  WISE,  priority  substances  are  not  monitored  in  water  in  coastal  and  territorial 

water bodies in any of the four RBDs, and no monitoring in water was performed in lakes and 
rivers in the Bornholm and International (Vidå-Kruså) RBDs. In the other two RBDs, only four 

priority substances are reported to be monitored in water for status assessment in lakes, and 13 
in  rivers.  About  95  %  of  lake  water  bodies  were  not  monitored  for  any  priority  substances. 

Less  than  3  %  river  water  bodies  were  monitored  for  six  or  more  Priority  Substances.  The 
spatial coverage of water monitoring therefore appears to be limited.  

Denmark subsequently clarified that overall 19 priority substances were monitored in a matrix 
for which a standard exist.48  

In  coastal  waters,  mercury  and  hexachlorobenzene  are  reported  to  be  monitored  in  biota  for 
status assessment49. Neither of these are monitored in biota in territorial waters and only one 
(mercury)  is  monitored  in  surface  freshwaters.  Benzo(a)pyrene,  and  fluoranthene  are  also 

monitored in biota in coastal and territorial waters. 

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. 

For  water  column  monitoring,  the  four  Priority  Substances  in  lakes  and  the  13  in  rivers  are 
monitored  12  times  per  year  and  at  least  once  per  cycle.  This  is  in  accordance  with  the 

48  Denmark  subsequently  highlighted  that  it  has  monitored  more  priority  substances  in  more  water  bodies  in 
sediment  and  biota  (for  example,  in  lakes,  pollutants  were  primarily  monitored  in  sediments).  However  this 
monitoring was not reported (and so it is not described here), because no standard was established for these 
substances in the corresponding matrix, despite the requirement to do so. Therefore the monitoring performed 
in these matrices could not be used to assess status. 

49  Denmark subsequently highlighted that hexachlorobutadiene is not used in Denmark, hence it is expected to 

not being discharged and therefore not monitored in biota.    

69 

 
                                                      
 
recommended  minimum  frequency  for  surveillance  monitoring  but  not  for  operational 

monitoring. 

Monitoring  of  Priority  Substances  in  biota  is  undertaken  once  per  year  and  at  least  once  per 

cycle  for  status  assessment.  This  is  lower  than  the  recommended  minimum  frequency. 
Denmark  subsequently  clarified  that  greater  intervals  have  been  chosen  on  the  basis  of 

technical knowledge and expert judgement, but no detail was provided. 

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  substances50  that  tend  to  accumulate  in  sediment  and/or  biota,  for  the  purpose  of 
long-term  trend  assessment.  Monitoring  should  take  place  at  least  once  every  three  years, 

unless technical knowledge and expert judgment justify another interval.  

Spatial coverage 

No monitoring of sediments was reported to WISE. Denmark reported monitoring in biota for 

trend  assessment  for  four  priority  substances.  All  four  are  monitored  in  coastal  waters,  and 
only one in lakes and rivers.  

Nine other substances are reported to be monitored in water for trend assessment in rivers only. 

Frequencies 

In water, the reported frequency is 12 times per year and once per cycle. Monitoring of Priority 
Substances in biota in coastal waters was once per year and between once and three times per 

cycle  for  trend  assessment.  The  monitoring  frequencies  are  not  always  in  line  with  the 
recommended minimum frequency. Denmark has subsequently clarified that greater intervals 

have been chosen on the basis of technical knowledge and expert judgment, but no detail was 
provided. 

Monitoring of Priority Substances that are discharged in each RBD. 

50  Anthracene,  brominated  diphenylether, 

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

chloroalkanes,  DEHP, 

cadmium,  C10-13 

70 

 
 
 
                                                      
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.” 

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

into the river basin or sub-basin.  

Denmark  reported  that  19  of  the  41  Priority  Substances  were  included  in  the  inventories  in 
each RBD. The RBMPs reported that the Priority Substances not included on the inventories 

are those that are not used in Denmark or that screening has shown that they do not occur in 
significant quantities. 

Seven of the 19 priority substances in inventories were discharged in each RBD. In the Jutland 
and Funen and Zealand RBDs, all of the priority substances discharged were monitored. In the 

international RBD one Priority Substance (mercury) that was discharged was monitored, and in 
the Bornholm RBD none were monitored. 51 

Performances of analytical methods used  

In Denmark, for the RBDs, for 14, two and four Priority Substances in the Jutland and Funen 

and  Zealand,  Bornholm  and  International  (Vidå-Kruså)  RBDs,  respectively,  the  analytical 
methods used meet the minimum performance criteria laid down in Article 4(1) of the QA/QC 
Directive (2009/90/EC)52 for the strictest standard applied. For the remainder, information has 
not been provided on the analytical method used.  

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

51 Denmark subsequently clarified that all substances discharged were monitored, but it is not clear whether these 
were  monitored in a matrix for which a standard exist, ie whether the monitoring performed can actually be 
used for status assessment. 

52  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  

71 

 
                                                      
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 on which monitoring took place in the surface water bodies within a group 
that is used to extrapolate results to non-monitored surface water bodies within the same group. 

For Denmark, the assessment of chemical status was undertaken between 2007 and 2012. 

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

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

Map 4.1 

Chemical  status  of  surface  water  bodies  in  Denmark  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) 

72 

GoodFailing to achieve to goodUnknownRiver Basin DistrictsCountries outside the EU 
 
 
 
 
 
The chemical status of surface waters in Denmark for the first and second RBMPs is given in 

Table 4.1.  

Table 4.1 

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

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

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

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

Category 

second RBMP 

Rivers (7776) 

Lakes (856) 

Coastal (119) 

Territorial (14) 

Total (8765) 

first RBMP 

Rivers (15127) 

Lakes (696) 

Coastal (165) 

Total (15988) 

Good 

Failing to achieve good 

Unknown 

Number  % 

Number 

% 

Number  % 

7 

3 

58 

4 

72 

0.09% 

0.40% 

49% 

29% 

0.8% 

21 

3.00% 

21 

0.5% 

16 

34 

12 

62 

56 

28 

84 

0% 

4% 

10% 

7753 

819 

49 

10 

99% 

96% 

41% 

71% 

0.7% 

8631 

98.5% 

0.40% 

15071 

99.60% 

675 

137 

97% 

83% 

15883 

99.3% 

17 % 

0.1% 

Source: WISE electronic reporting 

As described in Section 2.1.1 of this report, there has been a significant re-delineation of water 
bodies in Denmark between the two cycles and therefore a comparison of status between the 
two cycles should be treated with some caution.53 

Between the two RBMPs, there was a small increase in the proportion of surface water bodies 
with good chemical status from 0.5 to 0.8 % but also a small increase in the proportion failing 

to  achieve  good  chemical  status  from  0.1  to  0.7  %.  However,  the  proportion  with  unknown 
chemical status decreased a small amount from 99.3 to 98.5 %. This pattern generally occurred 

across all RBDs.  

Chemical  status  assessment  is  based  on  monitoring  with  no  use  of  grouping  or  expert 

judgement. Water bodies without monitoring data are classified as unknown. 

53  Denmark also highlighted that the proportions of water bodies at good status and failing to achieve good status 
in the two RBMPs cannot be compared due to fundamental differences in the approach to the assessment of 
chemical status. 

73 

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

The  water  bodies  classified  are  associated  to  a  medium  level  of  confidence.  The  RBMPs 
included  a  methodology  for  the  assessment  of  confidence  and  precision.  Confidence  in  the 

classification  of  chemical  status  for  the  first  RBMPs  was  not  reported.  The  one-out-all-out 
principle was reported in the RBMPs to have been used. 

Figure 4.3 

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

Source: WISE electronic reporting 

Figure 4.4 presents the chemical status of surface water bodies in Denmark for the first RBMP, 
that for the second RBMP (based on the most recent assessment of status) and that expected by 

2015. Denmark highlighted that the chemical status for the first and second RBMPs cannot be 
compared due to due to fundamental differences in the approach to the assessment of chemical 
status between the two cycles54.  

The  assessment  of  chemical  status  for  the  second  RBMP  was  expected  to  be  based  on  the 

standards  laid  down  in  the  EQS  Directive  2008/105/EC  (version  in  force  on  13  January 
200955).  Some  Member  States  did  not  implement  the  Directive  in  the  first  RBMPs  as  the 
transposition deadline was in July 2010, after the adoption of the first RBMPs.  

54 Cf chapter 4 of the RBMPs. 
55  Please  note  that  following  Directive  2013/39/EU,  which  amended  the  Environmental  Quality  Standards 
Directive,  introduced  a  less  stringent  annual  average  environmental  quality  standard  for  naphthalene  in 

74 

 
 
 
                                                      
Figure 4.4 

Chemical  status  of  surface  water  bodies  in  Denmark  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 2007 to 2012. The year of the 
assessment of status for first RBMP is not known  

Source: WISE electronic reporting 

More information on the chemical status in each RBD and water category can be found on the 
website of the European Environment Agency56. 

Directive  2013/39/EU  amended  the  EQS  Directive.  In  particular,  it  sets  more  stringent 
environmental  quality  standards  for  seven  substances57.  Member  States  were  required  to 
indicate if the new standard caused the status of the surface water body to appear to deteriorate. 

Denmark has stated that the new standard did not cause the status of the surface water body to 
appear  to  deteriorate  for  any  surface  water  body  in  the  four  RBDs.  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  Denmark  is  shown  in  Figure  4.5.  The  numbers  were  reported  as 
cumulative numbers. Good chemical status of surface water bodies is expected to be achieved 

transitional and coastal waters. This less stringent environmental quality standard should be taken into account 
for the determination of surface water chemical status by the 2015 deadline laid down in Article 4 of the WFD.  

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

compounds, Polyaromatic hydrocarbons (PAH) 

75 

 
 
 
                                                                                                                                                        
by the end of the second planning cycle (2021) in all of the RBDs. Given the reported status at 

the beginning of the second cycle, there is significant progress to be made during the second 
cycle. 

Figure 4.5 

Expected  date  of  achievement  of  good  chemical  of  surface  water  bodies  in 
Denmark.  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 for individual substances on the basis of 

the revised, more stringent standards from Directive 2013/39/EU.  

10 individual or groups of Priority Substances were reported to be causing failure to  achieve 

good  chemical  status  in  surface  water  bodies  in  Denmark.  Those  most  commonly  causing 
failure,  in  terms  of  the  proportion  of  water  bodies,  are  shown  in  Figure  4.6.  The  substance 

causing the greatest proportion to fail good chemical status in the second RBMP was mercury 
and its compounds (0.75 % of all surface water bodies) across all surface water categories in 

the Jutland and Funen, Zealand and International (Vidå-Kruså) RBDs. There was no reported 
information for the Bornholm RBD. Brominated diphenylethers is also of note causing 0.11 % 

of  the  failures  to  meet  good  chemical  status.  However,  the  real  extent  of  substances  causing 
failure in Denmark is unknown because 98 % of surface waters have not been monitored and 

assessed for chemical status. 

76 

 
 
 
Figure 4.6 

The  Priority  Substances  most  commonly  causing  failure  to  achieve  good 

chemical status in surface water bodies in Denmark 

Source: WISE electronic reporting 

According  to  WISE,  average  environmental  quality  standards  were  reported  to  have  been 

exceeded  for  a  limited  range  of  Priority  Substances  in  the  Jutland  and  Funen  RBD  (five 
substances),  and  the  Zealand  RBD  (three  substances).  No  exceedance  was  reported  for  the 
Bornholm RBD or International (Vidå-Kruså) RBDs.58 There were no reported exceedances of 
maximum allowable concentration environmental quality standards. 

Ubiquitous persistent, bioaccumulative and toxic Priority Substances 

According  to  article  8(a)  of  the  EQS  Directive59,  eight  priority  substances  and  groups  of 
priority  substances  are  behaving  like  ubiquitous,  persistent,  bioaccumulative  and  toxic 
substances60.  These  substances  are  generally  expected  to  cause  widespread  exceedances,  and 
their emissions can be challenging to tackle (e.g. due to long-range atmospheric transport and 
deposition). In order to show the progress made in tackling other priority substances, Member 

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

58  Denmark subsequently provided the following information : « Annual average environmental quality standards 
were reported to have been exceeded for a limited range of Priority Substances in the Jutland and Funen RBD 
(seven substances), the Zealand RBD (six substances) and the International Zealand RBD (one substance). » 

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

PFOS, dioxins, hexabromocyclodecane and heptachlor 

77 

 
 
                                                      
The influence of ubiquitous, persistent, bioaccumulative and toxic substances on the chemical 

status of monitored surface water bodies in Denmark is limited. While mercury caused failure 
to  achieve  good  status  in  0.75%  of  surface  water  bodies,  it  was  only  solely  responsible  for 

failure in 0.4%; mainly lake water bodies. However, the true extent of the influence of these 
substances is not known because of the very high proportion of water bodies not monitored and 
assigned unknown chemical status61. 

This is illustrated in the 2018 State of Water report of the European Environment Agency62. 

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

Not all of the Priority Substances monitored were used in  the assessment of chemical  status. 

Benzo(a)pyrene  and  fluoranthene  are  used  in  the  status  assessment  and  monitored  in  all  4 
RBDs. In addition the following 11 Priority Substances are used in the status assessment and 

in 

monitored  only 
the  Jutland  and  Funen  and  Zealand  RBDs;  naphthalene,  di(2-
ethylhexyl)phthalate  (DEHP),  hexachlorobenzene,  diuron,  atrazine,  lead  and  its  compounds, 
mercury  and  its  compounds,  nickel  and  its  compounds,  cadmium  and  its  compounds, 

isoproturon, and tributyltin-cation.  

In the Jutland and Funen and Zealand RBDs, 4-nonylphenol, and simazine are monitored, but 
not used in the assessment of chemical status63.  

Lead,  mercury,  nickel,  cadmium  are  monitored  but  not  used  in  the  assessment  of  chemical 
status in the Bornholm and International (Vidå-Kruså) RBDs.64  

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. 

61  Denmark subsequently clarified that in the Jutland and Funen and Zealand RBDs, 4-nonylphenol, and simazine 

are monitored, and used in the assessment of chemical status. 

62 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 

63  Denmark subsequently clarified that this was the case for brominated diphenylethers also. 
64  Denmark subsequently clarified that mercury and its compounds is used in the status assessment and monitored 

in all RBDs but Bornholm 

78 

 
                                                      
In total eight of the 41 standards from the Directive were used in the assessment of chemical 
status in the Jutland and Funen and Zealand RBDs65.  Alternative standards were applied for 6 
Priority  Substances.  For  the  remaining  Priority  Substances,  the  RBMPs  reported  that  the 

Priority Substances are not monitored because they are not used in Denmark or that screening 
has shown that they do not occur in significant quantities.  

For  the  Bornholm  and  International  (Vidå-Kruså)  RBDs,  standards  for  39  and  37  Priority 
Substances66 respectively were not used in the assessment of chemical status and there was no 
available information regarding the standards used. For two substances in the Bornholm RBD 
and four substances in the International (Vidå-Kruså) RBD alternative standards were used67.  

The Jutland and Funen and Zealand RBDs reported that alternative and/or additional standards 
in  biota  for  four  substances 
had  been  applied  for 
(hexachlorobenzene, fluoranthene, benz(a)pyrene and brominated diphenylethers).68  

two  substances 

in  water  and 

There  is  therefore  considerable  uncertainty  about  the  environmental  quality  standards  for  a 
large  number  of  Priority  Substances  used  as  the  basis  for  the  assessment  of  chemical  status. 

Denmark subsequently clarified that the assessment is undertaken on the basis of the Priority 
Substances listed in the table, and for all of which an EQS is laid down in Danish legislation 

(see  Annex  2  to  Bekendtgørelse  (Statutory  Order)  No  1625  of  19/12/2017)  for  the  relevant 
matrix transposing the standards established in the EQS Directive and/or established nationally 

for an alternative matrix. 

Use of mixing zones  

Article 4 of the EQS Directive provides Member States with the option of designating mixing 
zones adjacent to points of discharge in surface waters. Concentrations of priority substances 

may exceed the relevant environmental quality standard within such mixing zones if they do 
not affect the compliance of the rest of the surface water body with those standards. Member 

States that designate mixing zones are required to include within their RBMPs a description of 
the  approaches  and  methodologies  applied  to  define  such  zones,  and  a  description  of  the 

measures taken to reduce the extent of the mixing zones in the future. 

Mixing zones have not been designated in the Bornholm and International (Vidå-Kruså) RBDs 

in  Denmark;  however,  mixing  zones  have  been  designated  in  the  Jutland  and  Funen  and 
Zealand  RBDs.  Information  reported  to  WISE  indicates  that  the  methodology  for  the 

65 Denmark subsequently clarified that this was the case for 19 substances. 
66 Denmark subsequently clarified this was the case for 32 and 35 substances respectively. 
67 Denmark clarified these were biota standards. 
68 Denmark clarified that this must be a reporting error as no alternative standard has been used. 

79 

 
                                                      
designation  of  mixing  zones  follows  the  tiered  approach  as  laid  down  in  the  'Technical 
Background  Document  on  Identification  of  Mixing  Zones'69.  It  is  also  stated  that  measures 
have been implemented with a view to reducing the extent of the mixing zones in the future.  

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. 

Natural  background  concentrations  for  metals  and 

their  compounds  are 

taken 

into 

consideration where such concentrations prevent compliance with  the relevant  environmental 
quality standard in all four RBDs in Denmark. 

Water quality parameters that affect the bioavailability of metals have been taken into account 

when assessing monitoring results against relevant environmental quality standards in all of the 
four RBDs in Denmark. 

4.2.  Main changes in implementation and compliance since first cycle 

The scale and extent of Priority Substance monitoring was not  systematically reported in  the 

first RBMPs. In the second RBMP, the scale and extent of Priority Substance monitoring for 
status assessment remains restricted to a few substances in few water bodies in all categories. 

Denmark subsequently clarified that overall 19 priority substances were monitored in a matrix 
for which a standard exist.    

It is difficult to compare the chemical status between the two cycles due to the re-delineation of 
water bodies and change in assessment methods, nevertheless the changes have been minimal 

with  a  large  majority  of  sites  in  unknown  status  (98.5  %  reduced  from  99.3  %  in  the  first 
cycle). 

Information on Priority Substances causing failure of good chemical status for the first cycle 
was not systematically reported making comparison with the second cycle difficult. However, 

69https://circabc.europa.eu/sd/a/78ce94bb-6f1c-4379-87ac-

88a18967c4c3/Technical%2520Background%2520Document%2520on%2520the%2520Identification%2520o
f%2520Mixing%2520Zones.doc+&cd=1&hl=en&ct=clnk&gl=uk 

80 

 
                                                      
collated  information  in  the  compliance  assessment  of  the  first  RBMPs  indicated  that  ‘heavy 

metals aggregated’ and mercury were responsible for the majority of the environmental quality 
standard failures. No Priority Substances causing improvement in chemical status from failing 

to achieve good chemical status to good were reported for Denmark. 

4.3.  Progress with Commission recommendations 

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

  Recommendation:  Denmark  needs  to  be  more  transparent  on  the  use  of  grouping  of 

water bodies for monitoring and classification.  

Assessment:  With  respect  to  chemical  status,  Denmark  reports  that  all  surface  water 
bodies  classified  have  been  assessed  on  the  basis  of  monitoring  without  the  use  of 

expert judgement or grouping. Surface water bodies not monitored for chemical status 
were reported as unknown status. Very high percentages of surface water bodies are not 

monitored  (97.4  to  99.5  %).  Denmark  has  fulfilled  the  requirements  of  this 
recommendation. 

  Recommendation: Denmark will need to provide data on the chemical status of a much 
higher proportion of its water bodies, if necessary by monitoring more extensively. The 

apparent  omission  of  data  on  hexachlorobutadiene  should  be  addressed.  Denmark 
needs to specify exactly which industrial pollutants are causing failure of the chemical 

status objective. Groundwater monitoring and methodologies should all be made WFD 
compliant.  Measures  to  ensure  good  chemical  status  of  groundwater  should  be 

established  considering  all  WFD  aspects,  not  only  drinking  water  use.  Trend 
assessments and reversals should be carried out in the second RBMP cycle.  

Assessment: With respect to chemical status, the scale and extent of the monitoring of 
Priority  Substances  for  status  assessment  is  very  restricted  in  terms  of  number  of 

Priority  Substances  monitored  and  number  of  monitoring  sites  and  water  bodies 
monitored.  Denmark  subsequently  clarified  that  overall  19  priority  substances  were 
monitored in a matrix for which a standard exist.  

With  respect  to  the  proportion  of  surface  water  bodies  classified,  overall  in  Denmark 

between the two cycles the proportion with unknown chemical status decreased a small 
amount  from  99.3  to  98.5  %.  Denmark  has  reported  the  nine  Priority  Substances 
causing the failure of the small proportion of surface water bodies classified as failing 
to achieve good chemical status.  

81 

 
Denmark  subsequently  clarified  that  hexachlorobutadiene  is  not  discharged  and 

therefore  not  monitored  in  biota.  It  is  however  not  clear  how  status  was  assessed  for 
hexachlorobutadiene, given that no biota monitoring data was available. 

Overall,  almost  no  progress  has  been  made  with  the  recommendation  and  it  is  not 
fulfilled. 

82 

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

5.1.  Assessment  of 

implementation  and  compliance  with  the  WFD 

requirements in the second cycle 

5.1.1. Monitoring of quantitative status in groundwater 

The  total  number  of  groundwater  bodies  in  Denmark  is  402  (Table  2.3).  291  groundwater 

bodies (72 %) are not subject to monitoring for quantitative status (Table 5.1). Grouping was 
applied in all RBDs according to a national approach. The groundwater bodies in Denmark are 

divided by relative depth into three types: shallow groundwater bodies, regional groundwater 
bodies and deep groundwater bodies. The typology does not reflect the physical depth of the 

aquifer, only the relation to surface water: 

1.  The  shallow  groundwater  body  is  in  direct  contact  with  an  ecosystem  (watercourses, 
lakes or wetlands) and a surface area less than 250 km². It consists of sand or limestone. 

2.  The  regional  groundwater  body  is  in  direct  contact  with  an  ecosystem  (watercourses, 
lakes  or  wetlands)  and  a  surface  area  larger  than  250  km².  It  consists  of  sand  or 

limestone. 

3.  Deep  groundwater  bodies  have  no  contact  with  aquatic  or  terrestrial  ecosystems 

(watercourses, lakes or wetlands). 

As reported in  WISE,  all  groundwater bodies  changed since the  first  RBMP. The number of 

groundwater bodies increased by 4 % from 385 in the first RBMP to 402 in the second RBMP 
but the total groundwater body area decreased by about 28 %. 

The  number  of  monitored  groundwater  bodies  increased  slightly  in  absolute  numbers,  from 
120 out  of a total  of 385 groundwater bodies in the first  RBMP to  124  out  of a total  of 402 

groundwater  bodies  in  the  second  RBMP.  However,  the  number  of  monitoring  sites  for 
quantitative status is listed in Table 5.2 and shows a significant increase of almost 50%, from 

634 in the first RBMP to 943 in the second RBMP. The number of monitoring sites and their 
purpose is listed in Table 5.3. 

All 402 groundwater bodies are identified as drinking water protected areas.  

83 

 
 
 
Table 5.1  Number of groundwater bodies in Denmark directly monitored and the purpose 

of monitoring 

Monitoring Purpose 

RBD 

Total 
ground-
water 
bodies 
directly 
monitored 

CHE – 
Chemi-
cal 
status 

DK1 

DK2 

DK3 

DK4 

178 

95 

8 

3 

178 

95 

8 

3 

DRI – 
Ground-
water 
abstracti
on site 
for 
human 
consum-
tion 

153 

83 

8 

2 

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

IND – 
Ground-
water 
abstract-
tion site 
for 
industria
l supply 

153 

83 

8 

2 

16 

7 

0 

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

71 

37 

4 

2 

OPE – 
Operatio
-nal 
monitor-
ing 

QUA – 
Quantita
-tive 
status 

SOE - 
EIONET 
State of 
Environ-
ment 
monitor-
ing 

SUR – 
Surveil-
lance 
monitor-
ing 

TRE - 
Chemica
l trend 
assess-
ment 

30 

17 

1 

1 

81 

37 

4 

2 

76 

40 

4 

2 

76 

40 

4 

2 

148 

81 

5 

1 

Source: WISE electronic reporting70  

Table 5.2 

Proportion of groundwater bodies in Denmark monitored for quantitative 
status 

RBD 

DK1 

DK2 

DK3 

DK4 

No of groundwater bodies 
with quantitative 
monitoring 

Total No. groundwater 
bodies 

% of total groundwater 
bodies monitored for 
quantitative status 

81 

37 

4 

2 

241 

136 

19 

6 

33.60% 

27.21% 

21.05% 

33.33% 

Source: WISE electronic reporting 

Table 5.3 

Number of groundwater monitoring sites in Denmark and their purpose  

RBD 

Total 
ground-
water 
monitor-
ing sites 

CHE – 
Chemi-
cal 
status 

DRI – 
Ground-
water 
abstract-
tion site 
for human 
consump-
tion 

DK1 

DK2 

DK3 

DK4 

6977 

4834 

154 

44 

6977 

4834 

154 

44 

3960 

2993 

110 

21 

Monitoring Purpose 

IND – 
Ground-
water 
abstract-
tion site 
for 
indust-
rial 
supply 

46 

25 

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

726 

238 

16 

11 

DWD – 
Drink-
ing 
water - 
WFD 
Annex 
IV.1.i 

3960 

2993 

110 

21 

OPE – 
Operatio
-nal 
monitor-
ing 

QUA – 
Quanti-
tative 
status 

170 

64 

5 

2 

696 

221 

15 

11 

SOE - 
EIONE
T State 
of 
Environ-
ment 
monito-
ring 

875 

338 

18 

13 

Source: WISE electronic reporting.  

SUR – 
Surveil-
ance 
monitor-
ing 

TRE – 
Chemi-
cal trend 
assess-
ment 

875 

338 

18 

13 

4487 

3131 

112 

28 

70  Denmark  subsequently  clarified  that  no  specific  nutrient  sensitive  areas  have  been  designated.  The  Nitrates 

Action Programme is applied throughout the whole national territory.” 

84 

 
 
 
 
 
                                                      
 
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 399 of 402 groundwater bodies (99 %) were in good quantitative status and three (1 

%)  were  failing  good  status  (Figure  5.1).  In  terms  of  area,  this  means  that  about  2.3%  were 
failing good quantitative status. 

Figure  5.2  shows  that  there  is  overall  medium  confidence  in  status  classification.  All 
groundwater bodies had and still have a known status, in the first and in the second RBMP. 

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) 

85 

GoodPoorUnknownRiver Basin DistrictsCountries outside the EU 
 
  
 
Figure 5.1  Quantitative status of groundwater bodies in Denmark for the second RBMP, 

for  the  first  RBMP  and  expected  in  2015.  The  number  in  the  parenthesis  is 
the  number  of  groundwater  bodies  for  each  cycle.  NB  -  the  period  of  the 

assessment of status for the second RBMP was 2004 to 2010. The year of the 
assessment of status for the first RBMP is not known. 

Source: WISE electronic reporting 

Figure 5.2  Confidence in the classification of quantitative status of groundwater bodies 

in Denmark based on the most recent assessment of status 

Source: WISE electronic reporting 

The total number of groundwater bodies failing good quantitative status decreased significantly 
from 135 (35 %) out of 385 groundwater bodies in the first RBMP to three (1 %) out of 402 

groundwater bodies in the second RBMP. In terms of groundwater body area, this means that 

86 

 
 
 
in  the  first  RBMP  about  42  %  of  the  area  failed  good  status  and  in  the  second  cycle  this  is 

down to 2 %. It has to be considered, however, that the total groundwater body area decreased 
by about 28 % and all groundwater bodies have been re-delineated since the first RBMP. 

In  each  RBD,  water  balance  was  assessed  by  comparing  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.  All  three  groundwater  bodies  are  failing  good  status  due  to  failing  the  water 

balance  test:  this  means that  the  long-term  annual  average  rate  of  groundwater  abstraction  is 
exceeding the available groundwater resource.  

Figure 5.3  Reasons  for  the  failure  of  good  quantitative  status  of  groundwater  in 

Denmark based on the most recent assessment of status  

Source: WISE electronic reporting 

Notes: 
‘Water balance’ = long-term annual average rate of abstraction exceeds the available groundwater resource which 
may result in a decrease of groundwater levels. 

‘Surface water’ = Failure to achieve Environmental Objectives (Article 4 WFD) for associated surface water 
bodies resulting from anthropogenic water level alteration or change in flow conditions; significant diminution of 
the status of surface waters resulting from anthropogenic water level alteration or change in flow conditions. 

‘Groundwater dependent terrestrial ecosystems’ = Significant damage to groundwater dependent terrestrial 
ecosystems resulting from an anthropogenic water level alteration. 

‘Saline or other intrusion’ = Regional saline or other intrusions resulting from anthropogenically induced 
sustained changes in flow direction. 

87 

 
 
 
 
The expected date of achievement of good quantitative status in Denmark is shown in  Figure 

5.4 and it is reported that the groundwater bodies that are currently in poor status, are expected 
to be in good quantitative status by 2027. 

Figure 5.4  Expected date of achievement of good quantitative and good chemical status 
of  groundwater  bodies  in  Denmark.  402  groundwater  bodies  delineated  for 

the second RBMP 

Source: WISE electronic reporting 

In all four RBDs, the criterion of ‘available groundwater resource’ has been partially applied in 
accordance with  WFD Article 2(27)71.  In all RBDs, saline intrusion was considered in  status 
assessment but diminution of the status of groundwater associated surface waters and damage 
to  groundwater  dependent  terrestrial  ecosystems  have  not  been  considered  at  all;  however, 

there is also no risk related to these ecosystems. 

In total, three groundwater bodies (1 %) are at risk of failing good quantitative status, related to 

actual or potential legitimate uses or functions of groundwater. 

71  Denmark  subsequently  clarified  that  the  available  groundwater  resource  has  been  addressed  in  two  different 
ways,  a  balance  approach  and  an  ecological  flow  approach.  According  to  the  water  balance  approach, 
groundwater bodies will fail the criteria of good quantitative status if long-term abstraction exceeds 30% of the 
long-term groundwater recharge. According to the ecological flow approach, groundwater bodies will fail the 
criteria  of  good  quantitative  status  if  the  abstraction  may  lead  to  failure  to  achieve  the  environmental 
objectives  specified  under  WFD  Article  4  for  associated  surface  water  bodies  resulting  from  anthropogenic 
water level alteration or change in flow conditions. Investigations of impacts on associated surface waters have 
been  performed  with  respect  to  surface  water  courses.  The  two  criteria  have  been  considered  for  the 
assessment of quantitative status for all 402 groundwater bodies. 

88 

 
 
                                                      
 
5.1.3. Consideration  of  groundwater  associated  surface  waters  and/or  groundwater 

dependent ecosystems 

In  total  206  out  of  402  groundwater  bodies  were  identified  to  be  associated  with  aquatic 

ecosystems.  Groundwater  associated  surface  waters  have  not  been  considered  in  status 
assessment and there is no risk of failure related to these ecosystems.  

The  impact  of  groundwater  on  surface  water  courses  is  assessed  by  using  a  new  model  that 
establishes  the  relationship  between  a  number  of  water  flow  parameters  and  the  biological 

quality  elements.  Based  on  the  model,  the  impact  of  water  abstractions  on  the  ecological 
condition in the surface waters and then the impact on groundwater status are calculated. The 

model  is  only  used  to  calculate  the  impacts  of  water  abstractions  related  to  aquatic 
macroinvertebrates  and  fish;  the  model  is  not  sufficiently  robust  when  it  comes  to  the 

biological quality element for plants. 

252  out  of  402  groundwater  bodies  are  linked  with  groundwater  dependent  terrestrial 
ecosystems. Groundwater dependent terrestrial ecosystems have not been considered in status 

assessment and there is no risk of failure related to these ecosystems. The needs of terrestrial 
ecosystems have not been considered in status assessment although they exist. 

It is noted that there is no knowledge about the impacts of water abstraction on groundwater 
dependent  terrestrial  ecosystems.  It  is  stated  in  the  RBMPs  that  the  Danish  Environmental 

Protection Agency (previously “styrelsen for vand- og Naturforvalting, now “Miljøstyrelsen”) 
will initiate projects in order to obtain further knowledge in this area. 

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

There is  a summary of changes or updates in  all  RBMPs assessed. As reported in  WISE, all 

groundwater  bodies  have  been  re-delineated  which  makes  direct  comparisons  with  the  first 
RBMP  on  groundwater  body  level  impossible.  In  total,  the  number  of  groundwater  bodies 

increased  by  4  %,  from  385  in  the  first  RBMP  to  402  in  the  second  RBMP,  but  the  total 
groundwater body area decreased by about 28 %. 

The number of monitored groundwater bodies increased slightly, from 120 out of a total of 385 
groundwater  bodies  in  the  first  cycle  to  124  out  of  a  total  of  402  groundwater  bodies  in  the 

second RBMP. The number of monitoring sites for quantitative status increased significantly, 
by almost 50 %, from 634 in the first cycle to 943 in the second RBMP. 

89 

 
All groundwater bodies have been re-delineated which makes direct comparisons at the level 

of groundwater body impossible. The assessment method also changed. The total groundwater 
body area failing good quantitative status decreased significantly from 42 % to 2 %. 

Explanations of the criteria used in the assessments of groundwater quantitative status for the 
first  RBMP  were  quite  simple,  but  not  applied  in  a  uniform  manner  throughout  the  country. 

This  resulted  in  poor  quantitative  status  for  many  groundwater  bodies  indicating  non-
sustainable groundwater abstraction.  

The  quantitative  status  is  now  assessed  on  the  basis  of  1)  groundwater  water  balance,  2) 
groundwater  impacts  on  surface  water  and  3)  intrusion  of  saline  or  other  substances  into  the 

groundwater. The water balance is calculated differently compared to the first RBMP. Water 
balance  in  the  first  RBMP  was  assessed  by  a  screening  criterion  of  the  maximum 

abstraction/exploitation of groundwater, which should not exceed 35 % of the natural recharge 
of groundwater. This criterion was now changed to 30 %. Any aquifer exceeding this criterion 
is subject to an in-depth assessment based on local data and knowledge. 

The impact of groundwater on surface water is assessed by using a new model that establishes 
the  relationship  between  a  number  of  water  flow  parameters  and  the  biological  quality 

elements. 

5.3.  Progress with Commission recommendations 

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

  Recommendations:  

o  The basis for assessing quantitative status in groundwater bodies is weak. 

o  Denmark  needs  to  further  extend  the  monitoring  programme  to  include  all 
biological,  physical-chemical  and  hydromorphological  quality  elements  as 

relevant,  for  all  water  categories  (rivers,  lakes,  coastal  waters)  and  ensure 
there  is  adequate  monitoring  of  groundwater  to  enable  assessment  of  status, 

pressures and trends. The reported monitoring system is a new one (NOVANA) 
and not the one used for developing the 1st RBMPs. Although it is new, it does 
not  yet  appear  to  be  WFD  compliant.  There  is  no  operational  monitoring  of 
drinking water protected areas (groundwater).  

o  Denmark needs to be more transparent on the use of grouping of water bodies 

for monitoring and classification. 

90 

 
Assessment:  The  total  groundwater  body  area  decreased  by  27  %  and  in  parallel,  the 

number of monitoring sites for quantitative status increased significantly, by almost 50 
%, from 634 in the first RBMP to 943 in the second RBMP. The number of monitored 

groundwater  bodies  for  quantitative  status  increased  slightly,  from  120  out  of  385 
groundwater bodies in the first RBMP to 124 out of a total of 402 groundwater bodies 

in the second RBMP. The use of grouping in the monitoring of groundwater status is 
unclear. These recommendations are partially fulfilled.  

91 

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

6.1.  Assessment  of 

implementation  and  compliance  with  the  WFD 

requirements in the second cycle 

6.1.1. Monitoring of chemical status in groundwater 

The  total  number  of  groundwater  bodies  in  Denmark  is  402  (Table  2.3).  In  total,  280 

groundwater bodies (70 %) are not subject to surveillance monitoring (Table 5.1) and only half 
of the 101  groundwater  bodies at  risk (25  %)  (mainly in the Jutland and  Funen  and  Zealand 

RBDs) are subject to operational monitoring. Grouping was applied in all RBDs according to a 
national  approach,  considering  similar  geology  and  hydrogeology  though  not  reported  in 

WISE.  The  groundwater  bodies  in  Denmark  are  divided  by  relative  depth  into  three  types: 
shallow groundwater bodies, regional groundwater bodies and deep groundwater bodies. The 

typology does not reflect the physical depth of the aquifer, only the relation to surface water: 

1.  The  shallow  groundwater  body  is  in  direct  contact  with  an  ecosystem  (watercourses, 
lake or wetlands) and a surface area less than 250 km². It consists of sand or limestone. 

2.  The  regional  groundwater  body  is  in  direct  contact  with  an  ecosystem  (watercourses, 
lake  or  wetlands)  and  a  surface  area  larger  than  250  km².  It  consists  of  sand  or 

limestone. 

3.  Deep  groundwater  bodies  have  no  contact  with  aquatic  or  terrestrial  ecosystems 

(watercourses, lake or wetlands). 

All  groundwater  bodies  changed  since  the  first  RBMP.  The  number  of  groundwater  bodies 

increased  by  4  %  from  385  in  the  first  cycle  to  402  in  the  second  RBMP  but  the  total 
groundwater body area decreased by about 28 %. 

The  number  of  groundwater  bodies  with  surveillance  monitoring  remained  the  same  for  the 
first and second RBMP with 122 groundwater bodies. The number of monitoring sites is listed 

in Table 14 and almost doubled from 636 in the first cycle to 1244 in the second RBMP. The 
number of operational monitoring sites has decreased significantly since the first RBMP, from 

636  (in  122  groundwater  bodies)  to  241  (in  49  groundwater  bodies).  For  chemical  trend 
assessment, 7758 sites in 235 groundwater bodies were used. 

92 

 
Not  all  substances  causing  risk  of  deterioration  in  chemical  status  are  subject  to  monitoring. 

According to the WISE electronic reports, with the exception of nitrate, none of the WFD core 
parameters (ammonium, electrical conductivity, oxygen and pH) are monitored72.  

The  reasons  for  including  substances  in  operational  monitoring  are  that  these  substances  are 
causing  risk  of  failure  or  they  are  Groundwater  Directive73  Annex  II  substances;  BTEX-
substances are also measured. 

6.1.2. Assessment and classification of chemical status in groundwater 

Map  6.1  and  Figure  6.1  display  the  most  recently  assessed  chemical  status  of  groundwater 
bodies. It shows that 178 out of 402 groundwater bodies (44 %) were of good chemical status, 

101 groundwater bodies (25 %) are failing good status and 123 groundwater bodies (31 %) are 
of  unknown  status.  In  terms  of  area,  this  means  that  about  20  %  are  failing  good  chemical 

status.  Figure 6.2  shows the confidence in  status classifications. The number of  groundwater 
bodies  with  unknown  status  increased  from  0  in  the  first  cycle  to  123  in  the  second  RBMP, 
representing about 2 % of the total groundwater body area.  

The total number of groundwater bodies failing good chemical status decreased since the first 
RBMP  from  164  (43  %)  to  101  (25  %)  groundwater  bodies  (see  Figure  6.1)  (from  53  %  to 

approximately 20 % of the total groundwater body area). Due to the significant revision of all 
groundwater  bodies  (splitting,  merging  and  re-delineation)  and  the  reduction  of  the  total 

groundwater body area by about 28 %, it is difficult to compare the results of the first and the 
second RBMP.  

The reasons for the failure of good chemical status of groundwater bodies are shown in Figure 
6.3. For all 101 groundwater bodies, the general assessment was that the chemical status for the 

groundwater  body  as  a  whole  failed  good  chemical  status.  This  assessment  considers  the 
significant  environmental  risk  from  pollutants  across  a  groundwater  body  and  a  significant 

impairment of the ability to support human uses.  

72  Denmark subsequently clarified, that in fact, all WFD core substances are being monitored. 
73  Groundwater Directive (GWD): Directive 2006/118/EC of the European Parliament and of the Council of 12 

December 2006 on the protection of groundwater against pollution and deterioration. 

93 

 
                                                      
Map 6.1 

Map of the most recently assessed chemical status of groundwater bodies in 

Denmark  

Note: Standard colours based on WFD Annex V, Article 2(4)(5). 
Source: WISE, Eurostat (country borders) 

94 

GoodPoorUnknownRiver Basin DistrictsCountries outside the EU 
 
 
 
Figure 6.1 

Chemical status of groundwater bodies in Denmark for the second RBMP, 

for the first cycle and expected in 2015. The number in the parenthesis is 
the number of groundwater bodies for both cycles. NB  - the period of the 

assessment of status for the second cycle was 2000 to 2013. The year of the 
assessment of status for the first RBMP is not known.  

Source: WISE electronic reports 

Figure 6.2 

Confidence in the classification of chemical status of groundwater  bodies 
in Denmark based on the most recent assessment of status  

Source: WISE electronic reports 

95 

 
 
 
Figure 6.3 

Reasons for failing good chemical status in Denmark for the most  recent 

assessment of status  

Source: WISE electronic reports 

Notes: 
‘Surface water’ = Failure to achieve Environmental Objectives (Article 4 WFD) in associated surface water 
bodies or significant diminution of the ecological or chemical status of such surface water bodies. 

‘Groundwater dependent terrestrial ecosystems’ = Significant damage to terrestrial ecosystems which depend 
directly on the groundwater body. 

‘Saline or other intrusion’ = Regional saline or other intrusions resulting from anthropogenically induced 
sustained changes in flow direction. 

‘Drinking Water Protected Area’ = Deterioration in quality of waters for human consumption. 

‘General water quality assessment’ = Significant impairment of human uses; significant environmental risk from 
pollutants across the groundwater body. 

The calculation of the extent of exceedance of a groundwater quality standard or a groundwater 

threshold  value  is  based,  in  all  four  RBDs,  on  the  number  of  monitoring  sites  in  the 
groundwater body.  In all RBDs, the aggregation  method for  assessing  groundwater  chemical 

status is described. There are monitoring points for 375 groundwater bodies (402 groundwater 
bodies altogether). For the period of 2000–2013, monitoring has been performed at least once 

in 284 groundwater bodies. Each monitoring point in each groundwater body is monitored, and 
threshold  values  must  not  be  exceeded  for  any  of  the  substances  in  more  than  20%  of  the 

monitoring points. If data from at least five monitoring points are used, none of the monitoring 
points can contribute to more than 20 % of the status determination74. If data exist from five or 
less  monitoring  points,  the  status  is  considered  as  uncertain.  Trend  analyses  have  been 
performed independently from status assessments. 

74  Denmark  subsequently  clarified  that  status  analyses  have  also  been  performed  for  groundwater  bodies  with 

fewer than 5 monitoring points 

96 

 
 
 
                                                      
In  all  four  RBDs  groundwater  threshold  values  have  been  established  for  all  pollutants  or 

indicators  of  pollution  causing  a  risk  of  failure  of  good  chemical  status.  The  RBMPs  and 
background  documents  did  provide  indication  that  the  Groundwater  Directive75  Annex  II 
substances  have  been  considered.  In  all  four  RBDs,  natural  background  levels  have  been 
considered in the groundwater threshold value establishment.  

A trend methodology is available and assessments have been performed in all RBDs. A trend 
reversal assessment methodology is not available. 

6.1.3. Consideration  of  groundwater  associated  surface  waters  and/or  groundwater 

dependent ecosystems 

In  total,  206  out  of  402 groundwater  bodies  were  identified  as  being  associated  with  aquatic 
ecosystems.  Groundwater  associated  surface  waters  have  not  been  considered  in  the 

assessment  of  chemical  status  assessment,  and  there  is  no  risk  of  failure  of  chemical  status 
related to these ecosystems.  

252  out  of  402  groundwater  bodies  are  linked  with  groundwater  dependent  terrestrial 

ecosystems. Groundwater dependent terrestrial ecosystems have not been considered in status 
assessment and there is no risk assessment performed related to failure for these ecosystems.  

Groundwater associated aquatic ecosystems and groundwater dependent terrestrial ecosystems 
have not been considered in the establishment of groundwater threshold values. Consequently 

they are currently not linked to a risk.  

Figure  6.4  shows  the  pollutants  causing  failure  of  status  and  Figure  6.5  shows  the  five 

pollutants  with  upward  trends  in  groundwater  bodies  in  Denmark.  Figure  6.6  shows  the 
percentage of groundwater bodies at risk of failing good chemical status and good quantitative 

status. 

75   Groundwater Directive (GWD): Directive 2006/118/EC of the European Parliament and of the Council of 12 

December 2006 on the protection of groundwater against pollution and deterioration. 

97 

 
 
 
 
 
                                                      
Figure 6.4 

Top 10 groundwater pollutants causing failure of good chemical status in 

Denmark 

Source: WISE electronic reports 

Figure 6.5 

Top pollutants with upward trends in groundwater bodies in Denmark 

Source: WISE electronic reports  

98 

 
 
 
 
 
 
 
Figure 6.6 

Percentage  of  groundwater  bodies  in  Denmark  at  risk  of  failing  good 

chemical status and good quantitative status for the second RBMP 

Source: WISE electronic reports 

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

No summary of changes or updates were found in any RBMPs assessed for this topic. 

All groundwater bodies had been re-delineated which makes direct comparisons with the first 

RBMP not possible. In total, the number of groundwater bodies increased by 4 % from 385 in 
the first cycle to 402 in  the second RBMP but the total  groundwater body  area decreased by 

about  27  %.  The  re-delineation  has  been  done  due  to  updated  mapping  of  the  groundwater 
location, the boundaries and the proximity/connection to surface water bodies. A groundwater 

body  is  defined  as  an  administrative  unit,  delineated  by  one  or  several  groundwater-
reservoirs/aquifers, based on hydraulic contact and the boundaries of their areal extension. Due 

to the significant revision of all groundwater bodies (splitting, merging and re-delineation) and 
the reduction of the total groundwater body area by about 27 %, it is difficult to compare the 
results of the first and the second RBMP. 

The  monitoring  situation  did  not  improve.  The  total  number  of  groundwater  bodies  with 
surveillance  monitoring  remained  the  same  with  122  groundwater  bodies  and  the  number  of 

monitoring  sites  almost  doubled.  The  number  of  groundwater  bodies  with  operational 
monitoring was significantly reduced from 122 to 49 groundwater bodies, which is half of the 

total number of groundwater bodies at risk, and also the number of monitoring sites decreased 
significantly. Grouping for monitoring purposes was applied but it is not fully clear whether all 

groundwater  bodies  without  monitoring  are  part  of  groups  of  groundwater  bodies  which  are 

99 

 
 
subject  to  monitoring.  The  status  situation  improved  significantly  with  a  decrease  of  the 

groundwater  body  area  failing  good  chemical  status  from  52.7  %  to  19.6  %  of  the  total 
groundwater body area. About 31 % of the groundwater bodies are without a clear status and 

these groundwater bodies are representing about 2 % of the total groundwater body area.  

6.3.  Progress with Commission recommendations 

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

  Recommendation:  Denmark  needs  to  further  extend  the  monitoring  programme  to 
include all biological, physical-chemical and hydromorphological quality elements as 

relevant,  for  all  water  categories  (rivers,  lakes,  coastal  waters)  and  ensure  there  is 
adequate  monitoring  of  groundwater  to  enable  assessment  of  status,  pressures  and 

trends.  

Assessment:  In  total,  7085  monitoring  sites  are  dedicated  to  monitoring  of  drinking 

water  protected  areas  in  284  groundwater  bodies  and  for  chemical  trend  assessment 
7758  sites  in  235  groundwater  bodies  are  established.  The  fact  that  monitoring  of 

groundwater  status  does  not  cover  all  groundwater  bodies  could  be  due  to  their  re-
delineation.  Monitoring is not complete, not all substances causing risk are covered by 

monitoring. Denmark subsequently clarified, that in fact, all WFD core substances are 
being monitored. This recommendation has partially been fulfilled. 

  Recommendation:  Denmark  needs  to  be  more  transparent  on  the  use  of  grouping  of 

water bodies for monitoring and classification. 

Assessment:  This  recommendation  cannot  be  fully  assessed  from  the  information 
available  in  WISE  reporting  and  the  RBMPs,  as  it  does  not  describe  clearly  how 

grouping has been applied. 

  Recommendation: Denmark will need to provide data on the chemical status of a much 
higher proportion of its water bodies, if necessary by monitoring more extensively. The 
apparent  omission  of  data  on  hexachlorobutadiene  should  be  addressed.  Denmark 

needs to specify exactly which industrial pollutants are causing failure of the chemical 
status objective. Groundwater monitoring and methodologies should all be made WFD 

compliant.  Measures  to  ensure  good  chemical  status  of  groundwater  should  be 
established  considering  all  WFD  aspects,  not  only  drinking  water  use.  Trend 

assessments and reversals should be carried out in the second RBMP cycle.  

100 

 
  Assessment: Groundwater dependent/associated aquatic/terrestrial ecosystems have not 
been  considered  in  groundwater  chemical  risk  and  status  assessment  although  they 
exist.  Denmark  noted  that  a  project  is  initiated  to  map  the  chemical  link  between 

groundwater and the associated aquatic and terrestrial ecosystems. A considerable 30% 
share of groundwater bodies has no clear status. A trend methodology is available and 

assessments  have  been  performed  in  all  river  basin  districts.  A  trend  reversal 
assessment  methodology  is  not  available.  Denmark  subsequently  clarified  that 

hexachlorobutadiene  was  not  monitored  because  it  was  not  discharged.  This 
recommendation has been partially fulfilled. 

101 

 
 
 
Topic7  Designation  of  Heavily  Modified  and  Artificial  Water 
Bodies and definition of Good ecological potential 

7.1.  Assessment  of 

implementation  and  compliance  with  the  WFD 

requirements in the second cycle for designation  

7.1.1. Designation of Heavily Modified and Artificial Water Bodies 

In the second RBMPs, 5.1 % of total surface water bodies are designated as heavily modified 

water bodies and 4.1 % as artificial water bodies. The WFD requires a review of designation 
every six years. Only minor reductions are noted in the length of river heavily modified water 

bodies and artificial water bodies between the two cycles and all lake heavily modified water 
bodies designated in the first cycle have been de-designated. Figure 7.1 shows the proportion 

of total water bodies in each category in Denmark that has been designated as heavily modified 
or artificial. Furthermore, no reservoirs were reported. 

Figure 7.1 

Proportion of total water bodies in each category in Denmark that has been 
designated as heavily modified or artificial  

Source: WISE electronic reports  

The  water  uses  for  which  many  river  water  bodies  are  designated  as  heavily  modified  were 
reported as unknown. Some of the river heavily modified water bodies are designated due to 

urban development, wider environment and other uses (not listed in WISE). 

102 

 
 
The  main  physical  alterations  of  river  heavily  modified  water  bodies  are  channelisation/ 

straightening/bed  stabilisation/bank  reinforcement,  weirs/dam/reservoirs,  land  drainage  and 
other alterations (not listed in  WISE). Coastal  heavily modified water bodies are affected by 

dredging/channel maintenance and locks. 

The criteria for the designation of artificial water bodies and heavily modified water bodies are 

given  in  the  guidelines  for  the  preparation  of  the  second  RBMPs,  while  the  specific 
designations  and  the  reasons  are  stated  in  MiljøGIS76.  The  guideline  for  the  designation  of 
artificial  water  bodies  and  heavily  modified  water  bodies  is  based  on  the  Common 
Implementation  Strategy  Guidance  document  No.  477,  while  it  is  noted  that  rules  for 
designating artificial water bodies and heavily modified water bodies are to be found in the law 
1606/2013.  

7.1.2. Definition  of  Good  ecological  potential  for  Heavily  Modified  and  Artificial  Water 

Bodies 

Good ecological potential for rivers was reported as defined at water body level in all 4 RBDs. 

It is not defined in the Bornholm RBD, where only two river heavily modified water bodies are 
designated (<5 km out of total 370 km river stretches). In all four RBMPs it is noted that work 
on the delineation of rivers with catchments of less than 10 km2 and the identification of rivers 
as artificial and heavily  modified were to  be continued  during 2018 and  2019, as part of the 

Food and Agriculture Package (2015). As a result, the environmental goals could change for 
some rivers.  

The approach reported for good ecological potential definition is the Common Implementation 
Strategy  Guidance  approach  (approach  based  on  biological  quality  elements  as  illustrated  in 

Common  Implementation  Strategy  Guidance  No.  4).  Also  good  ecological  potential  is 
reportedly  defined  in  terms  of  biology.  The  biological  quality  element  for  which  biological 

values  have  been  derived  to  define  maximum  ecological  potential  and  good  ecological 
potential  are  phytoplantkton,  angiosperms,  macrophytes,  benthic  invertebrates  and  fish.  A 

comparison between good ecological potential and good ecological status has been made in the 
RBDs where good ecological potential was reported as defined. 

Biological  quality  element  assessment  methods  sensitive  to  altered  habitats  due  to 
morphological  changes  are  only  reported  for  rivers,  and  in  specific  for  macrophytes,  benthic 

invertebrates and fish. 

76 http://miljoegis.mim.dk/cbkort?profile=vandrammedirektiv2-2016 
77https://circabc.europa.eu/sd/a/f9b057f4-4a91-46a3-b69a-e23b4cada8ef/Guidance%20No%204%20-

%20heavily%20modified%20water%20bodies%20-%20HMWB%20(WG%202.2).pdf  

103 

 
                                                      
Good  ecological  potential  is  determined  according  to  the  same  principles  as  good  ecological 

status  and  the  starting  point  are  the  values  of  the  water  body  (watercourse,  lake  or  coastal 
water) to which the heavily modified water bodies are most similar.  

Good  ecological  potential  is  determined  individually  for  the  biological  quality  elements 
depending  on  how  much  the  biological  effect  will  be  due  to  the  physical  change  and  the 

hydromorphological  effect.  After  having  determined  the  closest  comparable  water  body,  the 
hydromorphological conditions/measures needed are determined, which are required to obtain 

the best possible physical and chemical conditions without significantly affecting the water use 
that caused the designation of the heavily modified water bodies. 

The  estimation  of  biological  values  of  biological  quality  elements  for  assessing  status  in 
general (and not only maximum ecological potential and good ecological potential) is based on 

available data, monitoring and, in some cases, modelling.  

Mitigation  measures  for  defining  good  ecological  potential  have  been  reported  in  two  RBDs 
(Jutland  and  Funen  and  Zealand).  These  include:  bypass  channels,  reconnection  of  meander 

bends or side arms, removal of structures, restoration of modified bed structure and retention 
basins.  No  mitigation  measures  can  be  selected  for  the  International  (Vidå-Kruså)  and 

Bornholm RBD, because mitigation measures have not been used for water bodies which have 
been  defined  as  at  good  ecological  potential  in  the  RBD.  It  cannot  be  concluded,  however, 

from the information found whether the existing level of mitigation is sufficient for achieving 
good ecological potential.78 

The ecological changes expected due to the mitigation measures are described in a qualitative 
way and with reference to the effects of physical/hydromorphological measures in general (not 

only for heavily modified water bodies). The associated benefits are described in general terms 
as “improved conditions” of the water courses. 

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

The number of river heavily modified water bodies and artificial water bodies has substantially 

decreased from the first to the second RBMPs but only a minor reduction is noted in the length 
of  river  heavily  modified  water  bodies  and  artificial  water  bodies  between  the  two  cycles. 

Changes are mainly due to the re-delineation of water bodies (adjustment in number of water 
bodies as some have been combined, which has resulted in fewer water bodies in general) as 

78 Danish authorities have clarified that it is expected that good ecological potential/status will be achieved in the 
river  water bodies  where these are implemented. Furthermore, it is expected that  mitigation  measures in the 
form of removal of barriers will result in good ecological status/potential in more river water bodies than the 
one where the mitigation measure has been implemented but the amount has not been quantified.   

104 

 
                                                      
well  as  a  new  guidelines  document  for  the  designation  of  heavily  modified  water  bodies 

developed since the first RBMPs. The guidelines do not explicitly explain modifications in the 
method,  but  it  is  noted  that  in  order  to  clarify  whether  a  water  body  can  be  designated  as 

heavily modified water bodies, the first RBMPs (2009-2015) are to be used as basis. 

All lake heavily modified water bodies designated in the first cycle have been de-designated in 

the  second  cycle.  In  the  RBMP  of  Jutland  and  Funen,  it  is  explained  that  lakes  which  were 
earlier  designated  as  heavily  modified  water  bodies  or  artificial  water  bodies  are  no  longer 

designated,  because  it  is  estimated  that  the  physical  modification  does  not  prevent  the  lakes 
from achieving good ecological status. 

The RBMPs also note that further changes to the extent of designations may take place until 
the end of 2019, as a result of the Food and Agriculture Package (2015).  A qualification of the 

delineation of water courses and a qualification of watercourses to  be designated as artificial 
water  bodies  and  heavily  modified  water  bodies  will  take  place.  The  water  councils  shall  be 
involved in this work. 

Concerning the definition of good ecological potential, the approach reported is the Common 
Implementation Strategy Guidance approach, whereas in the first RBMPs, it was indicated that 

the  Prague  approach  was  used.  Certain  improvements  have  been  made  since  the  first  cycle, 
mainly  related  to  the  inclusion  of  more  quality  elements  in  the  assessment  (e.g.  for  rivers, 

beside  macroinvertebrates,  now  also  macrophytes  and  fish  are  included;  for  lakes,  beside 
chlorophyll  used  in  the  first  cycle,  phytoplankton,  macrophytes  and  fish  have  been  added); 

however,  this  is  an  overall  improvement  in  assessing  status  of  all  water  bodies  (including 
natural ones), not for the definition of good ecological potential in particular. 

Mitigation  measures  for  defining  good  ecological  potential  have  been  reported  in  two  RBDs 
(Jutland  and  Funen  and  Zealand)  in  the  second  RBMPs,  whereas  in  the  first  RBMPs, 

mitigation measures were not defined in any RBD. 

7.3.  Progress with Commission recommendations 

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

  Recommendation:  Denmark  needs  to  ensure  that  the  correct  procedures  to  establish 
good ecological potential are carried out, and are clearly described in the RBMP. The 

mitigation  measures  methodology  has  been  used  to  define  good  ecological  potential, 
but  it  seems  from  the  RBMPs  that  steps  one  and  two  have  not  been  used,  in  spite  of 

national guidance requiring this. 

105 

 
Assessment:  The  method  for  defining  good  ecological  potential  was  more  clearly 

explained  than  in  the  first  cycle.  The  approach  used  is  the  Common  Implementation 
Strategy  Guidance  approach  and  not  the  Prague  approach  which  was  reported  in  the 

first RBMPs. Furthermore, improvements have been made since the first cycle, mainly 
related  to  the  inclusion  of  more  quality  elements  in  the  assessment.  The  mitigation 

measures  for  two  out  of  four  RBDs  (Jutland  and  Funen  and  Zealand)  have  been 
defined,  while  for  the  International  (Vidå-Kruså)  RBD,  no  mitigation  measures  have 

been used for water bodies which have been defined as at good ecological potential in 
the district. It cannot be concluded, however, from the information found whether the 
existing level of mitigation is sufficient for achieving good ecological potential79.  

This recommendation has been partially fulfilled. 

79  However,  the  Danish  authorities  have  clarified  that  it  is  considered  that  the  existing  level  of  mitigation  is 

expected to be sufficient for achieving GEP. 

106 

 
 
 
                                                      
Topic 8 Environmental objectives and exemptions 

8.1.  Assessment  of 

implementation  and 

compliance  with  WFD 

requirements in second cycle 

8.1.1.  Environmental objectives 

The  environmental  objectives  are  defined  in  Article  4  of  the  WFD.  The  aim  is  long-term 
sustainable water management based on a high level of protection of the aquatic environment. 

Article 4(1) defines the WFD general objective to be achieved in all surface and groundwater 
bodies,  i.e.  good  status  by  2015.  Within  that  general  objective,  specific  environmental 

objectives are defined for heavily modified water bodies (good ecological potential and good 
chemical status by 201580), groundwaters (good chemical and quantitative status by 2015) and 
for Protected Areas (achievement of the objectives of the associated Directive by 2015 unless 
otherwise specified).  

Environmental objectives for ecological and chemical status in surface waters and quantitative 
and chemical status in groundwater have been reported in all RBDs, although for some water 
bodies the date for the achievement of the objectives is unknown81. 

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  Denmark  is  provided  in 

Chapter 15 of this report. 

Assessments of the current status of surface and groundwater bodies in Denmark 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)  and  status  of  surface  and  groundwater 
bodies associated with Protected Areas (Chapter 15). 

For the second RBMPs, Member States are required to report the date when they expect each 
surface  and  groundwater  body  to  meet  its  environmental  objective.  This  information  is 
summarised  for  Denmark  elsewhere  in  this  report:  for  ecological  status/potential  of  surface 

80 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. 

81 This  does  not  apply  to  groundwater.  There  are  no  groundwater  bodies  in  any  districts  for  which  the  date  for 
achievement has not been specified. All groundwater bodies with unknown chemical status are expected to be 
in good status in 2015. 

107 

 
                                                      
 
waters  (Chapter  3);  chemical  status  of  surface  waters  (Chapter  4);  quantitative  status  of 

groundwater bodies (Chapter 5) and chemical status of groundwater bodies (Chapter 6).  

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  Denmark  for  the  four  main  sets  of  environmental 

objectives. 

Figure 8.1 

Water bodies in Denmark 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 reports. 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 

108 

 
 
human  development  activities.  Article  4(4)  exemptions  may  be  justified  by:  disproportionate 

cost,  technical  feasibility  or  natural  conditions,  and  Article  4(5)  by  disproportionate  cost  or 
technical feasibility. 

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 Denmark. 

Figure 8.2 

Type  of  exemptions  applied  to  surface  water  and  groundwater  bodies  for 
the  second  RBMP  in  Denmark.  Note:  Ecological  status  and  groundwater 

quantitative  status  exemptions  were  reported  at  the  water  body  level. 
Chemical  exemptions  for  groundwater  were  reported  at  the  level  of  each 

pollutant causing failure of good chemical status  

Source: WISE electronic reports. 

109 

 
 
Table 8.1  Pressure responsible for pollutants in Denmark failing to achieve good chemical 

status in groundwater and for which exemptions have been applied  

Significant pressure on groundwater 

Number 
of failing 
pollutants 

Number of exemptions 

Article 4(4) 
- Natural 
conditions 

Article 4(4) 
- Technical 
feasibility 

Article 4(5) 
- Technical 
feasibility 

1.5 - Point - Contaminated sites or abandoned 
industrial sites 

2.2 - Diffuse - Agricultural 

2.7 - Diffuse - Atmospheric deposition 

8 - Anthropogenic pressure - Unknown 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

NR 

2.NR = Not reported to WISE. No data was provided. 

Application of Article 4(4) 

Article 4(4) was applied in the first cycle and has also been applied in the second cycle. The 

justification in surface water is related, as previously, to technical feasibility, natural conditions 
and  disproportionate  costs.  For  groundwater,  disproportionate  costs  and  natural  conditions 
were reported as being used as justifications. Technical feasibility refers to no information on 

the  cause  of  the  problem  so  the  solution  cannot  be  identified  in  all  RBDs.  Disproportionate 
costs are justified by Cost-Effectiveness Analysis. 

Article 4(4) exemptions in Denmark are not reported to WISE at the pressure and driver level 
(Table  8.1).  Impacts  causing  the  exemptions  are  related  to  altered  habitats  due  to 

morphological  changes  (includes  connectivity)  and  nutrient  pollution  in  all  RBDs.  Chemical 
pollution  as  an  impact  was  reported  in  the  Jutland  and  Funen,  Bornholm  and  International 

(Vidå-Kruså) RBDs. Elevated temperatures are an issue in the Jutland and Funen RBD. 

Application of Article 4(5) 

Article 4(5) was not applied in the first RBMP but has been applied in the second for surface 
water. Article 4(5) was applied for 27 lakes in Jutland and Funen RBD and for eight lakes in 

Zealand  RBD.  There  is  a  lack  of  reported  methodologies  on  exemptions.  Article  4(5) 
exemptions in Denmark are also not reported to WISE at the pressure and driver level (Table 

8.1). The impacts reported are nutrient pollution.  

Application of Article 4(6) 

Article 4(6) has not been applied, though the Jutland and Funen RBMP does describe potential 
future use. 

110 

 
Application of Article 4(7) 

Article 4(7) has not been applied, though the Jutland and Funen RBMP does describe potential 
future use. 

Application of Article 6(3) GWD 

No exemptions according to Article 6(3) of the Groundwater Directive82 have been applied. 

8.2.  Main changes in implementation and compliance since first cycle 

Article  4(5)  was  not  applied  in  the  first  cycle  but  has  been  applied  in  the  second  cycle  for 
surface waters. 

8.3.  Progress with Commission recommendations 

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

requested action on the following: 

  Recommendation: A large number of exemptions have been applied in this first cycle of 
RBMPs.  While  the  WFD  does  provide  for  exemptions,  there  are  specific  criteria  that 
must be fulfilled for their use to be justified. The application of exemptions needs to be 

more transparent and the reasons for the exemptions should be clearly justified in the 
plans.  Denmark  should  take  all  necessary  measures  to  bring  down  the  number  of 

the 
including 
exemptions 
characterisation process, monitoring networks and status assessment methods, as well 

the  next  cycle, 

improvements 

the  needed 

for 

in 

as reducing significantly the degree of uncertainties. 

Assessment:  The  reasons  for  exemptions  were  reported  at  the  water  body  level. 

Justifications for exemptions were reported in WISE. However, whether there are clear 
criteria  that  have  been  developed  for  the  application  of  "technical  unfeasibility", 

"disproportionate costs" and "natural conditions" cannot be assessed due to the lack of 
reported  methodological  documents  for  the  application  of  exemptions  in  surface  and 

groundwater bodies. The number of exemptions applied was reported to decrease.  The 
recommendation is partially fulfilled83. 

82   Directive 2006/118/EC of the European Parliament and of the Council of 12 December 2006 on the protection 

of groundwater against pollution and deterioration  
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02006L0118-20140711  

83  Denmark  subsequently  clarified  that  the  methodologies  for  application  of  exemptions  are  described  in 
“http://mst.dk/media/121345/retningslinjer-vandomraadeplaner-for-anden-planperiode.pdf”,  section  4.8.  The 
document was published together with the RBMPs. Further the process for application of art. 4(7) is described 
in “http://mst.dk/media/133301/bilag-1-vejledning-4-juli-2017.pdf”, section 7 and 8. The guidance document 
for the Program of Measures was published in July 2017. 

111 

 
                                                      
 
  Recommendation: Only little improvement in the water status is expected by 2015 and 
the  objectives  for  subsequent  planning  deadlines  are  not  always  clear.  Objectives 
should be clearly indicated and transparent in order to be able to reach good status of 

waters in a reasonable timeframe.  

Assessment: It has been clearly stated at the water body level when objectives will be 

achieved  (e.g.  2021,  2027,  beyond).  No  information  on  2021  is  provided  for 
groundwater. The recommendation is partially fulfilled84. 

  Recommendation: Denmark has indicated there may be new physical modifications in 
forthcoming RBMPs, falling within the scope of Article 4(7). If this is the case, the use 

of exemptions under Article 4(7) should be based on a thorough assessment of all the 
steps as requested by the WFD, in particular an assessment of whether the project is of 

overriding  public  interest  and  whether  the  benefits  to  society  outweigh  the 
environmental degradation, and regarding the absence of alternatives that would be a 

better environmental option. Furthermore, these projects may only be carried out when 
all  possible  measures  are  taken  to  mitigate  the  adverse  impact  on  the  status  of  the 

water. All conditions for the application of Article 4(7) in individual projects must be 
included and justified in the RBMPs as early in the project planning as possible. 

Assessment:    No  Article  4(7)  exemptions  were  reported  to  be  applied  in  Denmark  - 
only  the  potential  for  future  use  in  the  Jutland  and  Funen  RBMP.  Therefore  the 

fulfilment of this recommendation cannot be assessed. 

84  Denmark  subsequently  clarified  that  all  groundwater  bodies  were  expected  to  be  in  good  chemical  status  in 
2015, except for the ones that are identified to be in poor status, and where status is expected to be achieved 
not later than 2017. 

112 

 
 
 
                                                      
 
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 1 Key Type of Measure 
because  it  may  be  multi-purpose,  but  also  because  the  Key  Types  of  Measure  are  not 

completely independent silos. Key Types of Measure have been introduced to simplify the 
reporting  of  measures  and  to  reduce  the  very  large  number  of  Supplementary  Measures 

reported by some Member States (WFD Reporting Guidance 2016).  

A Key Type of Measure may be 1 national measure but it would typically comprise more 

than 1 national measure. The 25 predefined Key Types of Measure are listed in the WFD 
Reporting Guidance 2016. 

The Key Types of Measure should be fully implemented and made operational within the 
RBMP planning period to  address  specific pressures or chemical  substances and achieve 

the environmental objectives. 

9.1.  Assessment  of 

implementation  and 

compliance  with  WFD 

requirements in second cycle 

9.1.1.  General issues 

An  indication  as  to  whether  or  not  measures  have  been  fully  implemented  and  made 
operational is when they have been reported as being planned to tackle significant pressures (at 

the  Key  Types  of  Measure  level).  Significant  pressures  are  also  reported  at  the  water  body 
level.  It  would  therefore  be  expected  that  there  would  be  measures  planned  in  the  RBMP  to 

tackle all significant pressures. All listed significant pressures causing failure of objectives in 
groundwater  and  surface  water  in  all  four  RBDs  are  covered  by  operational  KTMs,  except 

“Anthropogenic pressure – Unknown” in the International (Vidå-Kruså) RBD. Moreover, in all 
except the Bornholm RBD surface water, additional KTMs have been reported for significant 

pressures  that  have  been  reported  as  causing  failure  of  objectives.  All  are  for  chemical 

113 

 
 
substances  (including  Priority  Substances):  for  groundwater,  a  total  of  11  in  the  Jutland  and 

Funen RBD; 10 in the Zealand RBD, six in the Bornholm RBD and three in the International 
(Vidå-Kruså)  RBD;  and  for  surface  water:  six  in  the  Jutland  and  Funen  RBD,  six  in  the 

Zealand RBD, and one in the International (Vidå-Kruså) RBD. It is not clear therefore if these 
are relevant or will be made operational in the future.  

Examples of substances to be covered by these additional KTMs for groundwater are:  

  Aluminium and its compounds,  

  Lead and its compounds,  

  Nickel and its compounds,  

  Arsenic and its compounds,  

  Cadmium and its compounds,  

  Nitrate,  

  Chloride,  

  Sulphate,  

  Other chemical parameter,  

  BTEX etc. 

Examples of substances to be covered by these additional KTMs for surface water are:  

  Anthracene,  

  Lead and its compounds,  

  Mercury and its compounds,  

  Nickel and its compounds,  

  Brominated diphenylethers  

  Total Benzo(g,h,i)-perylene + Indeno(1,2,3-cd)-pyrene,  

  Benzo(a)pyrene,  

  Di(2-ethylhexyl)phthalate (DEHP) etc. 

No data has been reported on the number of national basic measures associated with reported 

KTMs,  but  a  total  of  18  national  supplementary  measures  have  been  mapped  against  8 
predefined KTMs and one KTM defined by Denmark (Table 9.1).  

114 

 
 
 
Links to documents on Article 11(3)(c-k) basic measures are provided in WISE. The inventory 

of national basic measures provided in WISE lists supplementary measures only. 

Whilst  KTMs are listed as  having been mapped  against national  measures for all four RBDs 

(including one KTM developed by Denmark for the Jutland and Funen RBD) (but no details 
provided to WISE for basic measures – see above), there is no information on KTMs tackling 

significant  pressures.  Denmark  has  subsequently  clarified  that  basic  measures  are  listed  in 
Annex 4 of the RBMP. 

No  data  has  been  reported  for  KTMs  used  to  tackle  River  Basin  Specific  Pollutants  causing 
failure of objectives (although operational KTMs for some chemical substances were reported 

in WISE, and significant pressures causing failure of objectives were listed in WISE). 

No  data  has  been  reported  for  KTMs  used  to  tackle  Priority  Substances  causing  failure  of 

objectives (although operational KTMs for some  Priority Substances were reported in WISE, 
and significant pressures causing failure of objectives were listed in WISE). Some explanation 
of this was provided by Denmark in their WISE reporting. Denmark subsequently clarified that  

Priority Substances are covered by the Programmes of Measures and newly identified Priority 
Substances will be covered by preliminary Programmes of Measures running from 2018-2021.   

The pressures are listed for groundwater and surface water in all RBDs (very similar to those 
listed in WISE and gap analyses have been conducted for all (Table 9.2). In the RBMP specific 

targets  have  been  laid  out  to  specific  measures  (for  instance  wetlands,  afforestation  and 
watercourse restorations) to be executed within the period. Also this programme is specific to 

all surface water bodies in Denmark.  

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. A combination of a qualitative and quantitative cost-effectiveness analysis has 

been carried out in all four RBDs for supporting the selection of measures proposed under the 
second cycle Programme of Measures. Cost-effectiveness analysis seems to have been carried 

out  also  in  the  first  cycle  as  indicated  in  the  Catalogue  of  measures,  which  included 
information on costs and effects of individual measures.  

Links to several documents have been provided for each RBD. 

A  critical  factor  in  the  success  of  the  implementation  of  the  Programme  of  Measures  is  the 
availability  of  funding  to  support  the  investments  required85.  Denmark  has  both  an 

85 Denmark subsequently reported that cost are estimated for all measures in the Programme of Measures in the 

RBMP 

115 

 
                                                      
implementation  plan concerning the second cycle and a finance plan addressing the different 

measures.  For instance a precise funding is planned for the  wetland scheme for all the  years 
ahead in the second cycle.  

Denmark  reported  that  a  clear  financial  commitment  (e.g.  approved  budget  or  financial 
mechanism  by  the  Parliament,  Ministry  of  Finance  or  other  financial  responsible  authority) 

was  secured  for  the  implementation  of  the  Programme  of  Measures  in  all  four  RBDs.  This 
includes  the  sector  Agriculture  in  all  four  RBDs,  and  Aquaculture  in  the  Jutland  and  Funen 

RBD only. Other sectors such as industry, urban, transport, hydropower, energy, recreation and 
flood protection have been reported not relevant in any of the RBDs. Aquaculture was reported 

not to be relevant in the Zealand, Bornholm and International (Vidå-Kruså) RBDs. 

There was no joint consultation carried out on the RBMPs and Marine Strategy in Denmark, 

but  the  preparation  of  RBMP  and  Programme  of  Measures  have  been  co-ordinated  with  the 
implementation of the Marine Strategy Framework Directive86 in all four RBDs. The need for 
additional or more stringent measures beyond those required by the WFD in order to contribute 
to  the achievement of the relevant  Marine Strategy  Framework Directive  objective in  coastal 
and marine environments has been considered in all four RBDs, but it was concluded that no 

additional measures were required.  

National measures relevant to the Marine Strategy Framework Directive have been reported as 

KTM  1  –  “Construction  or  upgrades  of  wastewater  treatment  plants”,  KTM  2  –  “Reduce 
nutrient  pollution  from  agriculture”,  KTM  23  –  “Natural  water  retention  measures”  in  the 

Jutland  and  Funen,  Zealand  and  International  (Vidå-Kruså)  RBDs;  and  KTM  2  -  “Reduce 
nutrient  pollution  from  agriculture”  in  the  Bornholm  RBD  only.  All  are  indicated  as 

“Supplementary measures” but  only KTM 2 seems  to  have measures specifically reported as 
relevant  to  the Marine Strategy Framework Directive (all others indicated as zero number of 

measures). 

Links or references to documents are labelled “not applicable” for all four RBDs. 

Denmark  carried  out  a  joint  consultation  of  its  RBMPs  and  the  Floods  Directive  Flood  Risk 
Management  Plans.  In  the  electronic  reporting  to  WISE  Denmark  has  reported  that  the 

objectives  and  requirements  of  the  Floods  Directive  have  not  been  considered  in  the  second 
RBMP  and  Programme  of  Measures.  However,  Denmark  reported  that  specific  win-win 

measures  in  terms  of  achieving  the  objectives  of  the  WFD  and  Floods  Directive,  drought 
management  and  use  of  Natural  Water  Retention  Measures  have  been  included  in  the 

86   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  

116 

 
                                                      
Programme  of  Measures.  The  design  of  new  and  existing  structural  measures,  such  as  flood 

defences,  storage  dams  and  tidal  barriers,  have  been  adapted  to  take  into  account  WFD 
environmental objectives. Clear financial commitment has been reported as “not applicable” in 

all  RBDs  in  Denmark.  WFD  Article  9(4)  has  not  been  applied  to  impoundment  for  flood 
protection. 

Links to the same document (RBMP for Jutland and Funen) have been provided for all RBDs. 

9.1.2.  Measures related to other significant pressures 

No  information  has  been  reported  electronically  to  WISE  in  relation  to  “other  significant 

pressures”87. 

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 KTMs. KTMs are expected to deliver the 
bulk  of  the  improvements  through  reduction  in  pressures  required  to  achieve  WFD 
environmental  objectives.  A  KTM  may  be  one  national  measure  but  it  would  typically 

comprise more than one national measure. Member States are required to report on the national 
measures  associated  with  the  KTMs,  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 Denmark. Also shown is the number of RBDs for which the KTM 
has been reported. 

Table 9.1 

Mapping of the types of national measures to KTMs in Denmark  

KTM 

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 

KTM13 - Drinking water protection measures (e.g. 
establishment of safeguard zones, buffer zones etc) 

KTM14 - Research, improvement of knowledge base 
reducing uncertainty 

NR 

NR 

NR 

NR 

1 

1 

1 

1 

3 

4 

4 

4 

87  Denmark  subsequently  clarified  that  information  is  available  in  the  RBMPs  on  other  significant  pressures. 

However, these documents have also not been included in the electronic reporting. 

117 

 
                                                      
KTM 

National 
basic 
measures 

National 
supplementary 
measures 

Number of 
RBDs where 
reported 

KTM2 - Reduce nutrient pollution from agriculture 

KTM23 - Natural water retention measures 

KTM5 - Improving longitudinal continuity (e.g. establishing 
fish passes, demolishing old dams) 

KTM6 - Improving hydromorphological conditions of water 
bodies other than longitudinal continuity 

KTM99 - Other KTM reported under Programme of 
Measures - Ocher plant 

Total number of mapped measures 

NR 

NR 

NR 

NR 

NR 

NR 

6 

1 

3 

3 

1 

18 

Source: Member States reports to WISE 
NR = Not reported to WISE. No data was provided. 

4 

3 

4 

4 

2 

4 

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.  Denmark  did  not  report  this  information  in 

WISE; but subsequently clarified that some information is included in the RBMPs. 

Member States were also 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. 

Denmark reported Key Types of Measures, but indicators of the gaps and of the key types of 
measures, and thereby values for the indicators, have not been reported in WISE. Denmark has 

118 

 
not  been  able  to  fill  in  the  used  methodology  in  the  reporting  schema.  However,  the  four 

RBMPs provide apportionment of significant pressures and gap analysis for all media. 

This  information  was  reported  at  sub-unit  level,  or  at  RBDs  level  if  sub-units  have  not  been 

reported by the Member State, as it has been the case in Denmark. 

9.2.  Main changes in implementation and compliance since first cycle 

There  is  a  shortage  of  meaningful  information  so  it  is  not  possible  to  judge  whether  any 
progress has been made, other than the indication that “some measures have been completed”; 
in particular, no gap analyses have been reported.  

No  summary  of  progress  has  been  provided  in  the  RBMPs,  but  major  national  political 
decisions  have  clearly  influenced  the  development  of  the  RBMPs  in  fundamental  ways  as 

described below.  

On 22 December 2015 the Danish  Parliament  signed  an agreement on a Food & Agriculture 

Package which led to a further adjustment of the RBMPs in relation to the proposals that were 
under public consultation. The agreement included limitations on nitrogen regulations, i.e.  the 

abolition of the 10 metre wide buffer zones, cancellation of the planned additional (required) 
60 000  hectares  for  cash  crops,  phasing  out  of  restrictive  fertiliser  standards  (with  respect  to 

nitrogen  usage),  adjustment  of  the  ban  on  tillage,  and  a  future  aquaculture  growth  plan. 
Altogether,  this  necessitated  the  need  to  recalculate  the  measures  required  to  reduce  the 

nitrogen losses in the RBMPs. The Food & Agricultural package, including the consolidation 
of nitrogen calculations, has led to an adjustment of the effort required and the action program 

for coastal waters (a national series of plans overlapping with the RBMPs); as well as revised 
application of exemptions. Overall, the consolidation means that the net reduction of nitrogen 

losses in 2021 has been recalculated to become approx. 13 100 tonnes of nitrogen annually, of 
which  6 200  tonnes  have  been  postponed  to  the  third  planning  cycle,  although  already  a 

provision  in  the  draft  RBMPs.  The  consolidation  of  nitrogen  calculations  was  based  on  the 
work  of  the  inter-ministerial  'Nitrogen  Committee'  set  up  by  the  former  government.  The 

consolidation  is  described  in  more  detail  in  the  technical  note  on  the  nitrogen  committee's 
corrections, which can be found on the website of the Ministry of Environment and Food. The 

agreement will also result in a further adjustment of the delineation of river water bodies and 
the re-designation of the water courses in 2018/2019.  

Denmark  subsequently  clarified  that  the  Food  &  Agricultural  Package  further  presented  a 
number  of  measures  to  reduce  the  leaching  of  nitrogen  from  the  farmland.  This  includes  a 

targeted  catch  crop  scheme  in  2017  and  2018.  The  targeted  catch  crop  scheme  ensures  non-
deterioration,  while  still  implementing  the  Food  &  Agriculture  Package.  In  2019  a  targeted 

119 

 
regulation scheme will be phased in. The scheme will ensure a gradual improvement and will 

by 2021 deliver a reduction of 3.500 tons  nitrogen to  coastal waters  also  meaning  a reduced 
load of nitrogen to groundwater. Further collective measures such as wetlands or afforestation 

will be introduced towards 2021 and is expected to ensure a reduction of 3.500 tons nitrogen to 
coastal waters (also impacting groundwater).     

The measures presented above are also included in the Danish River Basin Management Plans.        

The  prioritisation  of  measures  focuses  on  the  sectors  (i)  contributing  most  to  pressure  and 

impacts, (ii) where legal mechanisms and enforcement are available, (iii) where measures were 
considered as being most cost effective, (iv) where measures are known from past experience 

to  reduce  pressures/improve  status,  and  (v)  on  sectors  that  have  traditionally  been  regulated 
and subject to improvement measures. In practice, this means that the highest priority is given 

to  the  agricultural  sector  and  in  particular  to  nitrogen  reductions  (but  see  changes  outlined 
above).   

9.3.  Progress with Commission recommendations 

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

  Recommendation:  Meaningful  information  regarding  the  scope,  the  timing  and  the 
funding of the measures should be included in the Programme of Measures so that the 
approach to achieve the objectives is clear. All the relevant information on basic and 

supplementary  measures  should  be  included  in  the  summary  of  the  Programme  of 
Measures  to  ensure  transparency  on  the  planned  actions  for  the  achievement  of  the 
environmental objectives set out in the WFD.  

Assessment:  No  information  was  found  initially  to  suggest  this  had  been  done,  in 
particular no gap analyses have been reported. However, the Danish RBMPs were very 

precise with regards to the proposed number of various measures targeting the different 
types of water bodies. As an example, the RBMP for Zeeland (Sjælland) specifies that 

310 km of rivers will be improved through a series of measures, 31 barriers are to be 
removed,  and  96  sand  traps  will  be  established,  for  a  total  cost  of  DKK  73  million. 

Similarly  for  other  types  of  water  bodies  and/or  sectors,  the  scope,  funding  of  the 
measures, and the targeting of measures to achieve WFD objectives was outlined. The 

timing however was not specifically described, except that it will take place during the 
forthcoming 6-year cycle. This recommendation has been partially fulfilled.  

120 

 
 
Topic 10 Measures related to abstractions and water scarcity  

10.1. Assessment  of 

implementation  and  compliance  with  the  WFD 
requirements in the second cycle and main changes in implementation 
and compliance since the first cycle 

10.1.1.  Water exploitation and trends  

Water abstraction pressures were reported as relevant for Denmark; however a low proportion 

of  groundwater  bodies  faces  water  quantity-related  problems  for  achieving  good  quantitative 
status  of  groundwater  bodies  (2.2  %  in  the  Zealand  RBD).  This  is  consistent  with  the 

information  reported in  the first  cycle. The Water Exploitation  Index + is  not  calculated, but 
water  quantity  data  have  been  reported  to  support  the  European  State  of  the  Environment 

Report  in  relation  to  Water  Quantity.  Water  scarcity  is  not  considered  an  issue  at  the 
international level. The RBMPs include a water resource allocation and management plan in all 

RBDs. 

10.1.2.  Main uses for water consumption 

Data have not been reported for the uses of water consumption, except for those groundwater 
bodies where quantitative pressure is significant. Water abstraction information has previously 

been  reported  to  support  the  European  State  of  the  Environment  Report  in  relation  to  Water 
Quantity for the RBDs where water quantitative pressures are significant.  

10.1.3.  Measures related to abstractions and water scarcity  

Regarding basic measures (Article 11(3)(e)), in  Denmark there is  a concession, authorisation 
and/or  permitting  regime  to  control  surface  and  groundwater  abstractions  and  water 

impoundment; and a register of impoundments exists in all RBDs. Small  abstractions require 
permits and are registered.  

Measures  on  Article  11(3)(c)  for  efficient  and  sustainable  water  use  have  not  been 
implemented  in  the  previous  cycle,  and  no  new  measures  and/or  significant  changes  are 

planned for the period of the second cycle.  

Measures  for  the  prior  authorisation  of  artificial  recharge  or  augmentation  of  groundwater 

bodies  (Article  11(3)(f))  have  not  been  implemented  in  the  previous  cycle,  and  no  new 
measures and/or significant changes are planned for the period of the second cycle. 

121 

 
Complementary  measures  under  KTMs  for  addressing  abstraction  pressures  have  not  been 

reported. In general, information is not available in Denmark to report into WISE on the KTMs 
made operational to tackle significant pressures,  

Water reuse is not foreseen as a measure. 

10.2. Progress with Commission recommendations 

There  were  no  Commission  recommendations  based  on  the  first  RBMPs  and  Programme  of 
Measures for this topic. 

122 

 
 
 
Topic 11 Measures related to pollution from agriculture  

11.1. Assessment  of 

implementation  and  compliance  with  the  WFD 
requirements in the second cycle and main changes in implementation 
and compliance since the first cycle 

Pressures  related  to  agriculture  were  clearly  identified  for  surface  water  and  groundwater. 
Nutrient pollution from diffuse sources is impacting water quality in surface water in all RBDs. 

Nitrates are reported as a pressure to groundwater, since when conducting the classification of 
chemical status, nitrates are one of the pressures causing poor chemical status in  groundwater 

bodies. Chemical pollution was reported in the Jutland, Funen and Zealand RBDs. The RBMP 
has estimated the need for reduction of nitrogen to coastal waters and phosphorus to lakes. The 

Programme of Measures has measures to reduce the diffuse load of nitrogen to coastal waters 
and include wetlands, mini wetlands, forestation and targeted nitrogen regulation of agriculture  

An assessment of the gap to the achievement of WFD environmental objectives for nutrients 
has  partly  been  undertaken  in  all  RBDs.  In  the  RBMPs  gap  analyses  are  made  for  coastal 

waters (nitrogen) and lakes (phosphorus). 

KTM  2  –  Reduce  nutrient  pollution  from  agriculture  (supplementary),  KTM  13  –  Drinking 

water  protection  measures  (e.g.  establishment  of  safeguard  zones,  buffer  zones  etc.) 
(supplementary) and KTM 23 – Natural water retention measures (supplementary) are applied 

in all RBDs.  

Mandatory safeguard zones for groundwater have been established and relevant measures have 
been  introduced.  This  is  a  mandatory  requirement  and  follows  from  the  Water  Supply  Act. 

Each  safeguard  zone  is  provided  in  the  MiljøGIS.  The  basic  protection  of  groundwater 
resources  -  and  thus  drinking  water  resources  -  is  based  on  the  general  environmental 

regulation  in  the  form  of  national  nitrates  action  programme    and  pesticide  action  plans, 
national authorisation schemes for the use of pesticides, general harmonised requirements for 

the  spreading  of  manure,  regulation  of  fertilizer  application,  rules  on  establishment  of  catch 
crops etc. In addition, the specific regulation in the form of authorisation and approval schemes 

for a number of activities within each safeguard zone complements this. 

The targeted protection efforts for the protection of groundwater in areas with special drinking 

water  interests  are  carried  out  through  the  municipal  action  plans,  in  line  with  the  Water 
Supply Act. 

123 

 
With  the  parliamentary  agreement  on  Green  Growth,  25  meters  of  protection  zones  are  also 

laid  out  around  all  boreholes  for  general  water  supply  plants  within  which  there  is  no 
cultivation, use of plant protection products or fertiliser. This is implemented by section 21b of 

the Environmental Protection Act. 

Furthermore, the Government and a supporting party in parliament signed an agreement in the 

Parliament  on  a  Food  and  Agriculture  Package  on  22  December  2015.  This  led  to  an 
adjustment  of  the  RBMPs  in  relation  to  the  proposals  that  were  under  consultation.  The 

agreement  included  limitation  of  nitrogen  regulation  in  the  form  of  abolition  of  mandatory 
nine-metre  buffer  zones,  cancellation  of  the  planned  additional  60,000  hectare  catch  crops, 

adjustment of restrictive fertiliser standards to the level of economical optimum and adjustment 
of no-tillage regulation. Instead, the package suggested that several of these (earlier) measures 

enforced  through  regulation,  in  the  future  should  be  addressed  through  voluntary  measures 
generally  with  economic  support  partially  from  the  Rural  Development  Programmes  and 
partially nationally funded. The agreement includes a diverse package of measures, initiating a 

shift  in  the  way  environmental  regulation  of  the  agricultural  sector  is  carried  out:  from  a 
general regulation to a more targeted approach. 

Implementation  of  basic  measures  Article  11(3)(h)  for  the  control  of  diffuse  pollution  from 
agriculture at source are applied with the same rules across the whole RBD. General binding 

rules  to  control  diffuse  pollution  from  agriculture  are  applied  to  nitrates,  pesticides  and 
phosphorus.  

Farmers/Farmers'  Unions  have  been  consulted  under  the  Public  Consultation  process  in  all 
RBDs.  

Financing of agricultural measures is secured in all RBDs.  

11.2.  Main changes in implementation and compliance since first cycle 

The introduction by the Danish Government of the Food and Agriculture Package in 2015 has 
resulted  in  significant  changes  regarding  the  regulation  of  agriculture  with  regard  to  water 

quality protection. The package contains changes to nitrogen regulation including abolition of 
mandatory buffer zones along water courses, cancellation of the planned additional 60.000 ha 

of catch crops, replacement of the previously reduced fertilising limits with new limits that are 
adjusted to the level of economic optimum and consequently less stringent, and changes to the 

no-tillage  regulation.  The  package  seeks  to  replace  many  of  the  mandatory  measures  with 
voluntary  measures  generally  with  economic  support  partially  from  the  Rural  Development 

124 

 
Programmes and partially nationally funded. The overall thrust of the package is to move from 

a general regulation to a more targeted approach. 

11.3.  Progress with Commission recommendations 

There  were  no  Commission  recommendations  based  on  the  first  RBMPs  and  Programme  of 
Measures for this topic. 

125 

 
 
 
Topic  12  Measures  related  to  pollution  from  sectors  other  than 
agriculture  

12.1.  Assessment  of 

implementation  and 

compliance  with  WFD 

requirements in second cycle 

In  the  context  of  this  topic,  pollution  is  considered  in  terms  of  nutrients,  organic  matter, 
sediment,  saline  discharges  and  chemicals  (Priority  Substances,  River  Basin  Specific 

Pollutants,  groundwater  pollutants  and  other  physico-chemical  parameters)  arising  from  all 
sectors  and  sources  apart  from  agriculture.  Key  types  of  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  limited  to  one  national  measure  but  would  typically 

comprise  more  than  one  national  measure.  The  same  individual  measure  can  also  be  part  of 
more  than  one  KTM  because  it  may  be  multipurpose,  but  also  because  the  KTMs  are  not 

completely independent of one another. 

KTMs  relevant  to  non-agricultural  sources  of  pressures  causing  failure  of  WFD  objectives 
have  not  been  reported  in  the  context  of  those  pressures  for  any  RBDs  in  Denmark,  even 

though Denmark states that certain basic measures under WFD Article 11(3) are in place that 
will address chemical pollution.  

The  WFD  specifies  that  Programmes  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).  

Denmark  reported  implementation  of  KTM1  (on  “Construction  or  upgrades  of  wastewater 

treatment plants”) and KTM13 ("Drinking water protection measures), but not specifically in 
relation to tackling non-agricultural sources of pressures. Denmark provided some 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  discharges  (corresponding  to  basic 

measures  under  Article  11(3)(g))  was  reported  for  all  Danish  RBDs  for  surface  and 
groundwater. A register of waste water discharges (also corresponding to basic measures under 

Article 11(3)(g)) is available in all RBDs in Denmark for surface and groundwater. There are 
no thresholds in Denmark below which waste water discharges do not require permits and are 

not subject to registration. Direct discharges to groundwater are prohibited in all RBDs. 

Although Denmark has not reported measures specific to eliminating/reducing pollution from 

Priority Substances and other substances, it expects some of the basic measures it has reported 

126 

 
to  contribute to  this,  including measures  to  limit emissions, discharges and losses from  point 

and diffuse sources. 

In  particular,  the  RBMPs  include  comprehensive  Programmes  of  Measures  addressing  point 

sources  in  order  to  improve  water  quality  in  rivers  and  lakes.  The  Programmes  of  Measures 
include  reduced  discharges  from  dense  settlements,  improvement  of  small  wastewater 

treatment  plants  and  reduced  stormwater  overflow.  The  total  cost  of  the  programme  is  two 
billion  DKK.88  However,  there  is  no  assessment  of  how  effective  these  measures  will  be  at 
improving the chemical status of water bodies. 

12.2.  Main changes in implementation and compliance since first cycle  

In the first RBMPs, Priority Substances and other hazardous substances were mentioned, but 

the  description  was  mainly  general  and  no  inventories  regarding  specific  substances  were 
provided.  The  only  substance-specific  measures  that  were  included  in  the  first  RBMP  were 

further investigations and general permitting regimes.  

In the second RBMP, some Priority Substances are listed as significant pressures, but without 

specific KTMs to address them, although several KTMs are reported as being in place in each 
RBD,  and  some,  in  particular  KTM1  and  KTM13,  are  relevant  to  protection  from  chemical 

pollutants. 

For  three  of  the  four  RBMPs  (Jutland  and  Funen,  Zealand  and  International  (Vidå-Kruså)), 

information  on  Priority  Substances  in  surface  waters  is  provided  in  WISE.  The  RBMPs 
indicate that the measurements have mainly been performed in water; data from sediments and 

biota are few. Measures in relation to Priority Substances and River Basin Specific Pollutants 
are described in a broad manner, they are not substance specific. The RBMPs are written in a 

similar manner, there are no differences between them in structure or content.   

For  groundwater,  information  on  status  is  provided  on  single  pollutants  (pesticides,  nitrate, 

arsenic, lead, cadmium,  chlorine, mercury, nickel, sulphate, chlorinated solvents and BTEX), 
but  no measures relating specifically to  them are mentioned. Measures are listed under basic 

measures for some of these pollutants (e.g. pesticides and nitrates) and others are provided in a 
general manner.   

88  Denmark  provided  additional  information  stating  that  according  to  the  RBMPs  and  Executive  Order  on 
programmes of measures (bekendtgørelse nr. 1521 af 15/12/17/), section 9, relevant environmental authorities 
must,  within  their  area,  investigate  sources  of  pollutants  that  prevent  the  achievement  of  environmental 
objectives.  If  necessary,  the  relevant  authorities,  if  authorised  in  the  sectoral  act  concerned,  must  review 
notified approvals and permits to comply with applicable environmental quality requirements. Projects are also 
being launched to obtain further knowledge of pollutants in the aquatic environment. 

127 

 
                                                      
12.3.  Progress with Commission recommendations 

The  Commission  made  one  recommendation  based  on  the  first  RBMPs  and  Programmes  of 
Measures specific to this topic, as follows: 

  Recommendation:  The  identification  of  river  basin  specific  pollutants  needs  to  be  more 
transparent, with clear information on how pollutants were selected, how and where they 

were monitored, where there are exceedances and how such exceedances have been taken 
into  account  in  the  assessment  of  ecological  status.  It  is  important  that  there  is  an 

ambitious approach to combating chemical pollution from river basin specific pollutants 
and that adequate measures are put in place.  

Assessment:  Although  some  measures  reported  by  Denmark  are  relevant  to  tackling 
chemical  pressures,  no  substance-specific  information  on  measures  is  provided,  and  no 

indication is given of the likely success of the measures. Moreover, Denmark has not  yet 
identified  all  the  relevant  chemical  pressures  in  all  RBDs.  In  that  respect,  the  approach 

presented cannot be considered to fully address the recommendation.  

128 

 
 
 
 
Topic 13 Measures related to hydromorphology  

13.1.  Assessment  of 

implementation  and  compliance  with  WFD 

requirements in second cycle 

Significant  hydromorphological  pressures  are  identified  only  for  rivers  in  the  four  RBDs  of 

Denmark.  None  of  the  significant  hydromorphological  pressures  (physical  alterations  and 
barriers,  locks)  are  assigned  to  any  of  the  specified  sectors  according  to  WISE  (instead  the 

sector  was  reported  as  “other”).  However,  in  the  analysis  for  the  second  RBMPs,  the  most 
significant physical pressures such as pipelines in watercourses/rivers, barriers, ports and locks 

have  been  mapped.  It  is  also  noted  that  there  may  be  barriers  which  have  not  yet  been 
registered. 

Whilst  KTMs  relevant  to  hydromorphological  pressures  (e.g.  KTM5,  KTM6)  are  listed  as 
having been mapped against national measures for all four RBDs, information is not available 
in  Denmark  on  the  KTMs  tackling  specific  significant  pressures.89  In  addition,  there  is  no 
information  available  on  the  indicator  gap  to  be  filled  for  significant  hydromorphological 

pressures by 2021 or 2027. However, it was reported that quantitative management objectives 
in terms of restoring river continuity have been set in all four RBDs. 

Nevertheless,  based  on  information  from  the  published  RBMPs,  it  is  evident  that 
hydromorphological measures (both supplementary and basic) are planned in the second cycle. 

These  measures  focus  on  the  restoration  of  streams,  including  opening  of  pipelines  and 
removing  barriers.  In  addition,  there  are  measures  planned  against  ochre  (ochre  settles  in 

streams as a rusty layer on the bottom and aquatic vegetation).  

On  a  national  level,  it  is  estimated  that  approximately  6 525  km  of  rivers/streams  out  of 

approximately 19 000 km covered by the planning are not in good status due to poor physical 
conditions, including the assumption that physical measures from the first RBMPs (completed 

or  under  realisation)  have  the  expected  effect.  Based  on  this,  it  has  been  decided  that  there 
should be a significant improvement in physical measures in the second RBMPs. The second 
cycle  Programme  of  Measures  is  based  on  the  efforts  that  emerged  from  the  draft  second 

RBMPs and the continuation of a number of unfinished efforts from the first planning period. 
It is expected that efforts will overall improve the condition of up to 3 575 km of rivers/streams 

in this second cycle. 

89 Denmark subsequently informed that,  while this was not reported in WISE, relevant supplementary measures 

and basic measures are reported on in the programme of measures and the RBMP. 

129 

 
                                                      
In  terms  of  basic  measures  to  tackle  hydromorphological  pressures,  there  is  an  authorisation 

and/or permitting regime in place to control physical modifications in all RBDs, which covers 
changes to the riparian area of water bodies according to WFD90 Article 11(3)(i). There is also 
a register of physical modifications of water bodies. 

Win-win  measures  in  terms  of  achieving  the  objectives  of  the  WFD  and  Floods  Directive91, 
drought  management  and  use  of  Natural  Water  Retention  Measures  (NWRM)  have  been 
reported  as  included  in  the  Programme  of  Measures  of  all  RBDs.  The  design  of  new  and 

existing structural measures, such as flood defences, storage dams and tidal barriers, was also 
reported to have been adapted to take into account WFD objectives in all RBDs. 

Ecological flows have been derived partly, i.e. for some relevant water bodies, in the 4 RBDs 
but the work is still on-going. Concerning implementation, ecological flows which have been 

derived have not been implemented but there are plans to do so during the second RBMP. 

Related to the achievement of ecological flows in the RBMPs (section 4.5, on groundwater), a 
brief description on how water abstraction is connected to ecological flows was provided with 

further reference to technical reports. It is noted that environmental objectives for rivers could 
be  assessed  by  using  a  new  approach  provided  in  a  study  (GEUS  report  2014/74)  that  has 

assessed the effects of groundwater abstractions on the ecological state of watercourses using 
modelling  and  links  biological  quality  elements  to  flow.  New  ecological  flow  hydrological 

regime  indicators  for  fish,  macrophytes  and  plants  are  described  in  that  technical  report. 
Overall, work on making the new methodology operational is still on-going. 

13.2.  Main changes in implementation and compliance since first cycle 

The RBMPs do not directly report on progress made in terms of hydromorphological measures 

planned since the first  cycle, but it is stated that measures proposed in the first  cycle will be 
continued into the second cycle and that measures that emerged from the draft second RBMPs 

will be added, as described in the previous section.  

13.3.  Progress with Commission recommendations 

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

90   Directive  2000/60/EC  of  the  European  Parliament  and  of  the  Council  establishing  a  framework  for  the 

Community action in the field of water policy  
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32000L0060  

91   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  

130 

 
                                                      
 
  Recommendation:  Denmark  needs  to  ensure  that  hydromorphological  measures  are 

implemented where relevant, in the first RBMP period.  

Assessment:  The  RBMPs  do  not  directly  report  on  progress  made  in  terms  of 

hydromorphological  measures  planned  since  the  first  cycle,  but  it  is  stated  that 
measures proposed in the first cycle will be continued into the second cycle. Overall, it 

has been decided that there should be a significant improvement in physical measures 
in the second RBMPs. The second cycle of Programme of Measures are based on the 

efforts that emerged from the draft second RBMPs and the continuation of a number of 
unfinished efforts from the first planning period. It is expected that efforts will overall 

improve  the  condition  of  up  to  3 575  km  of  rivers/streams  (which  amounts  to 
approximately half of the river km  which are not  in  good status  due to  poor physical 

conditions). 

At the same time, ecological flows have been derived only partly and not implemented 

yet  in  any  RBD.  Work  on  making  the  new  methodology  on  ecological  flows 
operational is still on-going.  

Therefore, this recommendation is considered to be partially fulfilled.  

131 

 
 
 
Topic 14 Economic analysis and water pricing policies  

14.1. Assessment  of 

implementation  and  compliance  with  the  WFD 
requirements in the second cycle and main changes  in implementation 
and compliance since the first cycle 

As in the first cycle, the definition of water services is a narrow one, covering drinking water 
abstraction, treatment and distribution as well as sewage collection and wastewater treatment. 

Self-services are not included. 

It was reported that Article 9(4) is not used. 

The contributions of different water services to the cost recovery were not described in WISE. 

However, KTM10 - Water pricing policy measures for the implementation of the recovery of 

cost  of  water  services  from  industry  has  been  reported  to  WISE.  However,  information  is 
available in the economic analysis according to article 5 for the first and second RBMP. 

 Agriculture  pays  all  construction  and  operational  cost  for  the  abstraction  of  groundwater 
(primarily  for  irrigation).  Costs  for  irrigation  are  described  in  the  economic  analysis.  Costs 

related to the permit for abstraction are also covered by farmers.  

The  reporting  in  WISE  does  not  describe  how  water-pricing  policies  provide  adequate 

incentives for users to use water resources efficiently, but volumetric charging is in place for 
households,  public  actors  and  economic  enterprises  connected  to  the  public  water  supply. 

However in the economic analysis it is stated that the cost for water services in Denmark are 
among  the  highest  in  Europe,  which  is  a  strong  incentive  for  reduction  of  water  use  and  for 
improved wastewater treatment. Other than that, there is a tax on conductive water and a tax on 

emissions  of  organic  substances  from  wastewater  treatment  plants.  The  tax  on  piped  water 
finances the national groundwater exploration. As part of the tax on piped water there is a tax 

on water loss in the pipes of more than 10 percent. 

No  calculations  of  environmental  and  resource  costs  were  done  for  the  two  identified  water 

services, but in the economic analysis it is stated that revenues exceed the financial costs.  

The economic analysis was updated in 201492.  

92 https://mst.dk/media/118755/bilag-3-oekonomisk-analyse-vandplaner-ifro-20-12-2013-final.pdf 

132 

 
                                                      
14.2. Progress with Commission recommendations 

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

  Recommendation:  Cost-recovery  should  address  a  broad  range  of  water  services, 
including  impoundments,  abstraction,  storage,  treatment  and  distribution  of  surface 

waters,  and  collection,  treatment  and  discharge  of  waste  water,  also  when  they  are 
"self-services",  for  instance  self-abstraction  for  agriculture.  Cost  recovery  should  be 

transparently  presented  for  all  relevant  user  sectors,  and  environment  and  resource 
costs shall be included in the costs recovered. Information should also be provided on 

the incentive function of water pricing for all water services, with the aim of ensuring 
an efficient use of water. Information on how the polluter pays principle has been taken 

into account should be provided in the RBMPs. 

Assessment: As in  the first cycle, the definition of water services is  narrow, covering 

drinking water abstraction, treatment and distribution as well as sewage collection and 
wastewater treatment. Self-services are not included. It was reported that Article 9(4) is 

not used. 

The contributions of different water uses and their adequacy  - at least for households, 

industry  and  agriculture  -  are  not  described,  but  it  was  reported  that  households  and 
industry benefit from both water services and contribute to cost recovery.   

Agricultural contributions to cost recovery are not reported (on WISE, this is indicated 
as  "not  applicable");  But  financial  costs  for  self-abstraction  of  groundwater  for 
irrigation  is  paid  fully  by  the  user  and  there  is  full  cost  recovery  for  farmers  using 

public water supply.   

In the economic analysis it is described how water-pricing policies provide incentives 

for users to use water resources efficiently for water services, and volumetric charging 
is  in  place  for  households,  public  actors  and  economic  enterprises  connected  to  the 

public  water  supply.  User  charges  include  users'  direct  payment  for  the  water 
supply/wastewater  treatment  provided,  and  of  green  taxes  on  water  supply  and 

discharge of wastewater. Regarding the integration of environmental and resource costs 
in the costs recovered, it is mentioned that environmental charges exist; however, it was 

reported in WISE that no calculations of environmental and resource costs were done 
for the two water services defined.  

133 

 
The  Polluter  Pays  Principle  has  been  taken  into  account  as  stated  in  the  economic 

analysis in the recovery of the costs of water services for the two defined water services 
and  with  an  admitted  need  to  perform  further  analysis.  For  both  the  Polluter  Pays 

Principle  and  the  environmental  and  resource  costs,  the  green  tax  is  stated  to  be 
applicable, but without providing details. 

Summarising,  there  is  only  limited  progress  in  terms  of  the  recommendation  (some 
very  limited  additional  information  on  water  users),  but  significant  gaps  remain  (e.g. 

the environmental and resource costs,).  

134 

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

15.1. Assessment  of 

implementation  and  compliance  with  the  WFD 

requirements in the second cycle 

Denmark  identified  Protected  Areas  of  all  types  (except  nitrate  vulnerable  zones  designated 
under  the  Nitrates  Directive  and  sensitive  areas  under  the  Urban  Waste  Water  Treatment 

Directive in line with their whole territory approach to the implementation of these Directives) 
associated with surface and groundwater in the second RBMPs.  

Table 15.1 

Number of Protected Areas of all types in all RBDs in Denmark, associated 
with surface water categories 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/EEC 94 
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) 95 
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) 96 
Areas designated for the protection of 
economically significant aquatic species 

Number of Protected Areas Associated with93 

Rivers 

Lakes 

Transitional 

Coastal 

Groundwater 

402 

106 

933 

91 

77 

14 

66 

173 

98 

39 

107 

13 

95 

Source: Member States reports to WISE 

An  overview  of  the  status  assessment  of  all  water  bodies  associated  with  Protected  Areas  is 
shown in Figure 15.1.  

93   Denmark  subsequently  informed  the  Commission  that  the  reported  information  in  WISE  was  not  accurate. 

This table reflects the updated/corrected data 

94   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  

95   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  

96   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  

135 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
 
Figure 15.1 

Status  of  water  bodies  associated  with  the  Protected  Areas  report  for 

Denmark.  NB  -  based  on  status/potential  aggregated  for  all  water  bodies 
associated with all Protected Areas. 

Source: WISE electronic reporting 

A  high  proportion  of  the  classifications  of  ecological  status  have  been  assigned  high 
confidence with classification based on the monitoring of biological quality elements and with 
some use of  grouping. The status assessment  for chemical  status  in  surface and  groundwater 

states that the assessment is made with either medium or low confidence and, for around 30 % 
of groundwaterbodies and more than 95 % of surface water bodies, no information is available. 

According to the WISE reporting, no additional objectives have been set for Protected Areas 
designated under Article 7 of the WFD for groundwater. In the RBMPs, additional objectives 

for  groundwater  bodies  used  for  public  water  supply  are  described  in  the  form  of  specific 
threshold  values  for  certain  River  Basin  Specific  Pollutants  (chloride,  sulphate,  aluminium, 

arsenic) and Priority Substances (Pb, Cd, Ni, trichloroethylene and tetrachloroethylene) that are 
based on quality criteria in the Drinking Water Directive, that has been transposed to Danish 

law in 2014 (bekendtgørelse nr. 292 af 26. marts 2014). 

To enable the achievement of these additional objectives, there are also additional regulations 

given in action plans and permits for the use of pesticides, as well as harmonised requirements 
for  the  spreading  of  manure.  Additional  regulations  for  permits  for  a  variety  of  human 

activities  are  also  applied  to  prevent  deterioration  of  groundwater  bodies  used  for  drinking 
water. There are also safeguard zones of 25 metres around groundwater wells used for public 

136 

 
 
 
 
water  supply,  where  agriculture,  pesticides  and  fertilization  are  not  allowed,  according  to 

Article  21  in  the  Danish  Environmental  Protection  Act.  If  chloride  thresholds  are  exceeded, 
this  indicates  over-abstraction  and  salt  water  intrusion  and  will  initiate  measures  to  reduce 

abstraction.  The  need  for  supplementary  measures  to  achieve  the  objectives  will  be  further 
investigated  towards  the  3rd  RBMP,  including  improved  mapping  of  the  groundwater  bodies 
and their needs for protection, especially measures that may be needed to prevent deterioration 
of the chemical status of groundwater concerning nitrate, which could potentially be a problem 

after  the  implementation  of  the  Food  and  Agriculture  Package  in  2015,  allowing  more 
fertilization with nitrogen.97  

For  the  surface  water  Protected  Areas  related  to  the  Birds  and  the  Habitat  Directives, 
information  reported  to  WISE  indicated  that  good  ecological  status  is  sufficient  to  fulfil  the 

requirements in the parent directives regarding water quality. Consequently, no information on 
additional  measures  to  meet  such  objectives  was  reported  in  WISE.  However,  the  RBMPs 
indicate that measures to reduce run-off from polluted soils will be implemented, but they will 

only be taken in the third RBMP cycle, because there will be a screening done before 2019 to 
evaluate  where  such  soil  pollution  is  significant  in  terms  of  impacting  flora  and  fauna.  The 

second  RBMPs  include  substantial  measures  on  the  reduction  of  nutrient  loads  and 
improvement  of  physical  conditions,  which  are  expected  to  contribute  substantially  towards 

obtaining  the  favourable  conservation  objective.  This  recognition  for  likely  future  measures 
implies that it is not likely that the achievement of other WFD objectives will be sufficient to 

reach the objectives for Protected Areas subject to the further screening and mapping process 
foreseen before the third RBMPs. 

(shellfish), 
For  Protected  Areas  designated 
microbiological standards have been set to protect shellfish which are different to those in the 
repealed  Shellfish  Directive98.  These  objectives  have  been  met  for  50  %  of  the  shellfish 
Protected Areas in DK1, for 27 % in DK2 and for 50 % in DK4. For DK3 there is no info. 

for  economically 

significant 

species 

For  surface  water  areas,  only  monitoring  sites  related  to  Habitats  Directive  related  Protected 
Areas  have  been  reported;  none  for  those  related  to  the  Birds  Directive,  Bathing  Water 

Directive or to shellfish production.  

Denmark  subsequently  informed  the  Commission  that  the  majority  of  Habitats  Directive 

Protected  Areas  are  also  protected  under  the  Birds  Directive  so  monitoring  of  these  areas 

97   Denmark subsequently informed the Commission that measures have been introduced to compensate for this 
potential  deterioration  of  the  status  of  groundwater  regarding  nitrate  concentration:  particularly  the  targeted 
catch crop scheme in 2017 and 2018 is aiming at securing a non-deterioration of groundwater following the 
decisions in the Food and Agricultural Package. 

98  Directive  2006/113/EC  of  the  European  Parliament  and  of  the  Council  of  12  December  2006  on  the  quality 

required of shellfish waters (codified version)  
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2006.376.01.0014.01.ENG  

137 

 
                                                      
 
covers both directives.  Birds are covered by an extensive monitoring as part of the National 
Natura 2000 monitoring scheme which is not reported in WISE99. 

For  groundwater  bodies,  only  monitoring  sites  related  to  drinking  waters  have  been  reported 

(Table 15.2). For those Protected Area types reported, the monitoring, in terms of the number 
of  monitoring  sites  compared  to  the  number  of  Protected  Areas  looks  adequate  for  Article  7 

areas  in  groundwater.  However,  for  Habitats  related  areas,  monitoring  only  appears  to  cover 
lakes and coastal waters (and not lakes and territorial waters) with low numbers of monitoring 

sites. 

Table 15.2  Number of monitoring sites associated with Protected Areas in Denmark 

Protected Area type 

Abstraction of water intended for human 
consumption under Article 7 

Protection of habitats or species where the 
maintenance or improvement of the status of 
water is an important factor in their protection, 
including relevant Natura 2000 sites designated 
under Directive 92/43/EEC (Habitats) 

Number of monitoring sites associated with Protected Areas 
in 

Rivers 

Lakes 

Coastal 

Territorial  Groundwater 

7084 

410 

21 

Source: WISE electronic reporting 

As expected, no exemptions from additional objectives are applied in the Danish RBMPs for 

either surface water or groundwater areas because no such objectives have been set.  

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

In the first cycle Protected Areas associated with Article 7 (groundwater), Birds, Habitats and 

shellfish  production  were  reported.  In  the  second  cycle,  these  Protected  Areas  are 
supplemented  with  those  associated  with  the  Bathing  Waters  Directive.    In  terms  of  the 

numbers  of  Protected  Areas  reported,  comparable  numbers  of  Article  7  (groundwater)  and 
shellfish production areas and many more Birds and Habitats areas were reported in the second 
cycle. 

In the first cycle, monitoring was reported for all of the reported types of Protected Areas plus 

a  programme  for  Bathing  Waters.  In  the  second  cycle,  the  information  reported  to  WISE  is 

99  Denmark  subsequently  clarified  that  but  this  was  reported  through  the  Reference  portal  for  reporting  under 

Article 12 of the Birds directive and Article 17 of the Habitats Directive. 

138 

 
 
 
 
 
 
 
 
                                                      
 
restricted only to Article 7 (groundwater) and Habitats areas in surface waters100. This leads to 
an apparent significant decrease in the extent of Protected Area monitoring in the second cycle. 

With  regard  to  additional  objectives,  for  Natura  2000  (i.e.  Birds  and  Habitats),  the  high 

ecological status objectives were reported to have been used as the appropriate WFD objective 
for these sites in the first cycle. It is unclear whether the high or good status WFD objective is 

being used. Denmark subsequently clarified that no specific water objectives have been set to 
protect  dependent  habitats  and  species  because  the  achievement  of  WFD  good  status  is 

sufficient to achieve favourable conservation status. 

No  information  is  provided  for  groundwater  dependent  protected  areas.  In  both  cycles,  the 

need for a site-by-site favourable condition assessment is indicated as being required but has 
yet to be implemented. More clarity on the additional objectives for shellfish production areas 

has been provided in the second cycle compared to the first cycle. 

Some additional measures were indicated (though not specified in detail) for Protected Areas 
associated with the Bathing Waters, Habitats and Birds Directive, and for shellfish production 

areas in the first cycle. WISE reporting for the second cycle indicates no additional measures 
though some are referred to in the RBMPs in relation to Habitats areas. 

15.3. Progress with Commission recommendations 

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

requested action on the following: 

 

Recommendation:  Denmark  needs  to  further  extend  the  monitoring  programme  to 

include  all  biological,  physical-chemical  and  hydromorphological  quality  elements  as 
relevant,  for  all  water  categories  (rivers,  lakes,  coastal  waters)  and  ensure  there  is 

adequate  monitoring  of  groundwater  to  enable  assessment  of  status,  pressures  and 
trends. The reported monitoring system is a new one (NOVANA) and not the one used for 

developing the first RBMPs. Although it is new, it appears to not yet be WFD compliant. 
There is no operational monitoring of drinking water protected areas (groundwater). 

Assessment:  With  respect  to  the  monitoring  of  drinking  water  protected  areas 
(groundwater), monitoring sites for this type of Protected Area was reported. This aspect 

of the recommendation has been fulfilled.  

100  Denmark subsequently clarified that other aspects related  to protected areas such as birds and bathing  water 

were monitored under other schemes and are not reported in WISE.   

139 

 
 
                                                      
 
Topic 16 Adaptation to drought and climate change 

16.1. Assessment  of 

implementation  and  compliance  with  the  WFD 

requirements in the second cycle 

16.1.1.  Climate change adaptation 

Climate  change  was  considered  in  all  RBDs  and  the  guidance  on  how  to  adapt  to  climate 
change  (Common  Implementation  Strategy  Guidance  Document  No.  24101)  was  used.  In  the 
first cycle, no climate check of the Programme of Measures was carried out. Such a check has 
now been carried out in the second cycle. Consideration of climate change has taken place for 

the  preferential  selection  of  robust  adaptation  measures.  No  specific  sub-plans  addressing 
climate  change  were  reported  for  Denmark.  No  specific  adaptation  measures  (KTM  24  - 

"Adaptation to climate change") were reported. 

16.1.2.  Effects and impacts of prolonged droughts, as well as related measures 

According to the 2012 Topic report on ‘Assessment of Water Scarcity and Drought aspects in a 
selection  of  European  Union  RBMPs’102,  droughts  were  not  relevant  for  Denmark.  No 
exemptions  have  been  applied  for  the  country  following  Article  4(6)  due  to  prolonged 
droughts. 

Drought  Management  Plans  have  not  been  reported  for  Denmark;  and  also  in  2012  no  such 
plans were in place (Topic report on: Assessment of Water Scarcity and Drought aspects in a 

selection of European Union RBMPs). 

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

In  the  first  cycle,  no  climate  check  of  the  Programme  of  Measures  was  carried  out.  Such  a 

check has now been carried out in the second cycle.  

16.3. Progress with Commission recommendations 

There  were  no  Commission  recommendations  based  on  the  first  RBMPs  and  Programme  of 
Measures for this topic. 

101https://circabc.europa.eu/sd/a/a88369ef-df4d-43b1-8c8c-

306ac7c2d6e1/Guidance%20document%20n%2024%20-
%20River%20Basin%20Management%20in%20a%20Changing%20Climate_FINAL.pdf  

102 http://ec.europa.eu/environment/water/quantity/pdf/Assessment%20WSD.pdf  

140