COMMISSION STAFF WORKING DOCUMENT Second River Basin Management Plans - Member State: Luxembourg 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 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: Luxembourg, 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) 44 final  COMMISSION STAFF WORKING DOCUMENT Second River Basin Management Plans  - Member State: Luxembourg 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 Floods Directive (2007/60/EC) Second River Basin Management Plans First Flood Risk Management Plans  {COM(2019) 95 final} - {SWD(2019) 30 final} - {SWD(2019) 31 final} - {SWD(2019) 32 final} - {SWD(2019) 33 final} - {SWD(2019) 34 final} - {SWD(2019) 35 final} - {SWD(2019) 36 final} - {SWD(2019) 37 final} - {SWD(2019) 38 final} - {SWD(2019) 39 final} - {SWD(2019) 40 final} - {SWD(2019) 41 final} - {SWD(2019) 42 final} - {SWD(2019) 43 final} - {SWD(2019) 45 final} - {SWD(2019) 46 final} - {SWD(2019) 47 final} - {SWD(2019) 48 final} - {SWD(2019) 49 final} - {SWD(2019) 50 final} - {SWD(2019) 51 final} - {SWD(2019) 52 final} - {SWD(2019) 53 final} - {SWD(2019) 54 final} - {SWD(2019) 55 final} - {SWD(2019) 56 final} - {SWD(2019) 57 final} - {SWD(2019) 58 final} - {SWD(2019) 59 final} - {SWD(2019) 60 final} - {SWD(2019) 61 final} - {SWD(2019) 62 final} - {SWD(2019) 63 final} - {SWD(2019) 64 final} - {SWD(2019) 65 final} - {SWD(2019) 66 final} - {SWD(2019) 67 final} - {SWD(2019) 68 final} - {SWD(2019) 69 final} - {SWD(2019) 70 final} - {SWD(2019) 71 final} - {SWD(2019) 72 final} - {SWD(2019) 73 final} - {SWD(2019) 74 final} - {SWD(2019) 75 final} - {SWD(2019) 76 final} - {SWD(2019) 77 final} - {SWD(2019) 78 final} - {SWD(2019) 79 final} - {SWD(2019) 80 final} - 
 
 
Table of contents 
Acronyms...................................................................................................................................... 5 

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

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

Status of second river basin management plan reporting ........................................................... 9 

Key strengths, improvements and weaknesses of the second River Basin Management Plan(s)
.................................................................................................................................................... 10 

Recommendations ...................................................................................................................... 18 

Topic 1

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

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

1.2  Main changes in implementation and compliance since the 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 WFD requirements in the second 
cycle   ...................................................................................................................................... 24 

2.2  Main changes in implementation and compliance since the first cycle ....................... 32 

2.3  Progress with Commission recommendations .............................................................. 33 

Topic 3
bodies 

  Monitoring, assessment and classification of ecological status in surface water 

 ................................................................................................................................... 35 

3.1  Assessment of implementation and compliance with WFD requirements in the second 
RBMP ..................................................................................................................................... 35 

3.2  Main changes in implementation and compliance since the first RBMP ..................... 53 

3.3  Progress with Commission recommendations .............................................................. 54 

Topic 4

  Monitoring, assessment and classification of chemical status in surface water bodies 
 ................................................................................................................................... 57 

4.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle   ...................................................................................................................................... 57 

4.2  Main changes in implementation and compliance since the first cycle ....................... 70 

4.3  Progress with Commission recommendations .............................................................. 72 

1 

 
 
 
 
 
Topic 5

  Monitoring, assessment and classification of quantitative status of groundwater 

bodies 

 ................................................................................................................................... 75 

5.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle   ...................................................................................................................................... 75 

5.2  Main changes in implementation and compliance since the first cycle ....................... 79 

5.3  Progress with Commission recommendations .............................................................. 79 

Topic 6

  Monitoring, assessment and classification of chemical status of groundwater bodies 
 ................................................................................................................................... 81 

6.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle   ...................................................................................................................................... 81 

6.2  Main changes in implementation and compliance since the first cycle ....................... 88 

6.3  Progress with Commission recommendations .............................................................. 89 

Topic 7
  Designation of Heavily Modified and Artificial Water Bodies and definition of Good 
Ecological Potential................................................................................................................... 90 

7.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle for designation ............................................................................................................... 90 

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

7.3  Progress with Commission recommendations .............................................................. 93 

Topic 8

  Environmental objectives and exemptions ................................................................ 95 

8.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle and main changes in implementation and compliance since the first cycle ...................... 
 ...................................................................................................................................... 95 

8.2  Progress with Commission recommendations ............................................................ 100 

Topic 9

  Programme of measures.......................................................................................... 102 

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

9.2  Main changes in implementation and compliance since the first cycle ..................... 111 

9.3  Progress with Commission recommendations ............................................................ 111 

Topic 10

  Measures related to abstractions and water scarcity .......................................... 114 

10.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle .......................................................................................................................... 114 
2 

 
 
 
 
10.2  Main changes in implementation and compliance since the first cycle .................. 115 

10.3 

Progress with Commission recommendations ........................................................ 115 

Topic 11

  Measures related to pollution from agriculture................................................... 116 

11.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle .......................................................................................................................... 116 

11.2  Main changes in implementation and compliance since the first cycle .................. 118 

11.3 

Progress with Commission recommendations ........................................................ 118 

Topic 12

  Measures related to pollution from sectors other than agriculture ..................... 121 

12.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle .......................................................................................................................... 121 

12.2  Main changes in implementation and compliance since the first cycle .................. 123 

12.3 

Progress with Commission recommendations ........................................................ 123 

Topic 13

  Measures related to hydromorphology ................................................................ 125 

13.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle .......................................................................................................................... 125 

13.2  Main changes in implementation and compliance since the first cycle .................. 126 

13.3 

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

Topic 14

Economic analysis and water pricing policies .................................................... 128 

14.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle and main changes in implementation and compliance .................................... 128 

14.2 

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

  Considerations specific to Protected Areas (identification, monitoring, objectives 

Topic 15
and measures) .......................................................................................................................... 133 

15.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle .......................................................................................................................... 133 

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

15.3 

Progress with Commission recommendations ........................................................ 137 

Topic 16

Adaptation to drought and climate change .......................................................... 138 

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

3 

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

16.3 

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

4 

 
 
Acronyms and definitions 

EQS Directive 

Environmental Quality Standards Directive 

FD 

Km 

km2 

KTM 

PoM 

Floods Directive 

Kilometre 

Kilometre squared 

Key Type of Measure 

Programme of Measures 

QA/QC Directive 

Quality Assurance / Quality Control Directive  

RBD 

RBMP 

WFD 

WISE 

Annex 0 

River Basin District 

River Basin Management Plan 

Water Framework Directive 

Water Information System for Europe 

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

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Foreword 

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

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

2015 and reported to the European Commission in March 2016. 

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

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

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

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

6 

 
 
 
 
 
 
General Information 

Map A  

Map of River Basin Districts 

Source: WISE, Eurostat (country borders) 

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

The Grand Duchy of Luxembourg is surrounded by Belgium, France and Germany. The total 
population  is  0.5  m  and  the  total  surface  area  is  2.597 km2.  Most  of  Luxembourg  (97.3  %2) 
belongs to  the international  Rhine RBD, or Moselle-Saare sub-basin  of the Rhine RBD. The 
remaining 2.7 % (73 km2) are part of the international Meuse RBD. There are seven sub-basins 
(so-called  ‘study  areas’),  six  of  these  belonging  to  the  Rhine  RBD.  There  is  one  national 

7 

LULU000LU001DE2000BEMeuse_RWFRB1FRCBERhin_RWBERhin_RWBESeine_RW01020km 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
RBMP  covering  both  the  Rhine  and  Meuse  RBD.  There  are  no  sub-basin  or  other  sectoral 

plans.  

The information on areas of the national RBDs including sharing countries is provided in the 

following table: 

Table A Overview of Luxembourg’s River Basin Districts  

RBD 

Name 

Size (km2) 

Countries sharing RBD 

LU000 
(also LU 000) 
LU001 
(also LU 001) 

Rhine 

Meuse 

2525 

(AT), BE, CH, DE, FR, (IT), 
(LI), NL 

73 

BE, DE, FR, NL 

Source: RBMPs reported to WISE. 

 Luxembourg subsequently noted that the countries in brackets share the LU000 RBD.  

The  share  of  Luxembourg  in  the  respective  international  RBDs  is  1  %  (Rhine),  and  0.2  % 
(Meuse).  

Table B: Transboundary RBDs by category and % share in Luxembourg 

Co-ordination category 

1 

km² 

% 

1.0 

0.2 

RBD Name 

National RBD 

Countries sharing 
RBD 

Rhine 

Meuse 

LU RB_000 

(AT), BE, CH, DE, 
FR, (IT), (LI), NL 
BE, DE, FR, NL 
Source: WISE electronic reporting.  
Luxembourg subsequently noted that the countries in brackets share the LU000 RBD. 

LU RB_001 

2525 

73 

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. 

8 

 
 
 
 
Status of second river basin management plan reporting 

One RBMP for Luxembourg (Rhine, Meuse) was published on 22 December 2015. Documents 

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

9 

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

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

 

Governance and public consultation 

 

 

Luxembourg involved stakeholders through the establishment of advisory groups. 

Luxembourg has cooperated closely with neighboring Member States and others in the 
international  RBDs it shares via the international  commissions  for water  management 

as well as bilateral agreements.  

 

Characterisation of the RBD 

 

All  the  national  types  for  Luxembourg  appear  to  have  corresponding  intercalibration 

types. 

 

Type  specific  reference  conditions  were  established  for  all  biological  and 

physicochemical quality elements. Type specific reference conditions were not reported 

for  hydromorphological  quality  elements,  but  Luxembourg  reported  that  it  applied  a 
German  methodology  and  related  all  the  national  river  types  to  a  LAWA-type  of  the 

German  typology.  Therefore  each  Luxembourgish  river  type  has  its  correspondent 
reference conditions defined by the German LAWA type. 

 

For  surface  water  and  groundwater  bodies,  significance  of  pressures  is  linked  to  the 
potential  failure  of  objectives  and  defined  in  terms  of  thresholds.  For  the  second 

RBMP, a relatively high number of pressures were not reported (39 for surface waters, 
and  53  for  groundwater)  as  Luxembourg  did  not  use  the  same  level  of  detail  used  in 

WISE reporting and information could not be provided at this more detailed level. The 
significance  of  pressures  affecting  some  surface  water  bodies  (point  sources,  diffuse, 
abstraction  and  other  significant  pressures)  has  been  determined  mainly  by  expert 
judgment and no quantitative tools were used. The same was true for diffuse and point 

source  pressures  in  groundwater,  where  only  expert  judgement  was  used.  This  may 
indicate potential shortcomings in the assessment of these pressure types.  

 

The  reduction  in  pressures  required  to  achieve  environmental  objectives  has  not  been 
adequately  assessed  and  the  measures  to  tackle  Priority  Substances  causing  failure  to 

achieve good status have not been reported. 

10 

 
 
 

Luxembourg reported that all Priority Substances were included in the inventories for 

each RBD. They carried out a simple assessment (tier 1 point source information) for 
substances  not  relevant  at  RBD  level,  and  a  much  more  thorough  assessment  (all  4 

tiers)  for  substances  relevant  at  RBD  level,  as  recommended  by  the  CIS  Guidance 
Document n°28. The quality of the input data is assessed as medium in all cases. 

  Monitoring, assessment and classification of ecological status  

 

 

 

 

 

The  number  of  operational  monitoring  sites  increased  significantly  since  the  first  
RBMP  in  the  Rhine  RBD,  while  the  number  of  surveillance  sites  decreased  slightly. 

There were no changes in numbers in the Meuse RBD. 

According to  the data reported to  WISE, there would  still  be one gap in the elements 
monitored: fish in rivers in Meuse RBD1.  

Of the  five biological  quality elements used for the surveillance monitoring of rivers, 
four were sampled with at least the minimum recommended frequency. However, this 

was the case for only one of the five biological quality elements used in the operational 
monitoring of rivers. 

Information  on  how  the  River  Basin  Specific  Pollutants  were  selected  was  provided, 
and  they  were  monitored  at  least  at  the  minimum  recommended  frequency  at  all 

surveillance  monitoring  sites,  but  they  were  not  monitored  at  the  minimum 
recommended frequency in all of the operational monitoring sites.  

Environmental Quality Standards have been set for 54 River Basin Specific Pollutants 
in  water  for  rivers,  but  none  of  them  was  derived  in  accordance  with  the  Technical 

Guidance Document No 27. For all substances, the analytical methods are in line with 
Article 4(1) or Article 4(2) of the Quality Assurance/Quality Control Directive (QA/QC 

Directive) (2009/90/EC) for the strictest standard applied. 

 

The water bodies used for surveillance monitoring in the Rhine RBD were monitored 
for all required biological quality elements and physicochemical quality elements2. 

1   However, Luxembourg subsequently clarified that this was a reporting error and, in fact, fish were monitored 

in two of the three river water bodies in the Meuse RBD. 

2   Fish were reported not to be monitored in the Meuse RBD but Luxembourg subsequently stated that this was a 

reporting error and that two of the three water bodies in the Meuse RBD are monitored for fish. 

11 

 
 
                                                      
 

None  of  the  water  bodies  included  in  surveillance  monitoring  was  reported  as  having 
been monitored for all required hydromorphological quality elements3.  

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

 

Luxembourg monitors all  41 Priority Substances  in  water and monitoring frequencies 

are  reported  for  each  of  these  at  the  site  level  in  both  Luxembourgish  RBDs.  These 
frequencies  meet  the  frequency  requirements  according  to  the  WFD  for  surveillance 

monitoring in both RBDs but not for operational monitoring in the Rhine RBD.  

 

A very small proportion of the total number of monitoring sites (3 %) are reported to be 

used  for  monitoring  chemical  status  corresponding  to  a  total  of  13  out  of  110  river 

water  bodies  in  the  two  RBDs  in  Luxembourg  (12  in  the  Rhine  RBD  and  one  in  the 
Meuse RBD). Only 12 % of water bodies at poor chemical status were reported to be 

monitored in Luxembourg as a whole as part of the operational monitoring programme. 
Luxembourg  subsequently  clarified  that  it  only  reported  to  WISE  the  sites  where  all 

priority substances have been monitored. Monitoring has been carried out also at other 
sites, either only for some of the priority substances, or at a frequency not in line with 

the provisions of the WFD. These other sites haven’t been reported to WISE, although 
the monitoring results were used to assess chemical status. 

  Monitoring of sediment and biota for status and trend assessment is not reported in the 
second  RBMP.  However,  Luxembourg  uses  alternative  standards  for  mercury, 

hexachlorobenzene  and  hexachlorobutadiene  in  water  for  the  assessment  of  status. 
Luxembourg also  monitors suspended sediment  at  one strategic location  as part of  an 

the 
international  monitoring  programme  for 
Luxembourgish  authorities,  monitoring  of  biota  and  sediment  has  started  and  will  be 

trend  assessment.  According 

to 

reported in the next RBMP. 

 

All river water bodies fail to achieve good chemical status in the second RBMP due to 
the  widespread  occurrence  of  polycyclic  aromatic  hydrocarbons.  The  classification  of 
chemical status is underpinned by monitoring for 11 % and 33 % of river water bodies 

in  the  Rhine  and  Meuse  RBDs,  respectively,  with  the  remainder  classified  by  expert 
judgement. This is reflected in the confidence assigned to the classification: Overall 12 

3   Luxembourg subsequently explained that this was a reporting error and morphological conditions and river 

continuity were monitored and assessed. Hydrological regime was monitored in rivers but was not assessed in 
terms of ecological status/potential. 

12 

 
 
                                                      
% of surface water bodies in Luxembourg were classified for chemical status with high 

confidence and 88 % of surface water bodies were classified with low confidence. 

 

Overall  in  Luxembourg  between  the  two  cycles,  there  was  a  large  decrease  in  the 

proportion  of  surface  water  bodies  with  good  chemical  status  from  70  to  0  %  and  a 
significant increase in the proportion failing to achieve good status from 30 to 100 %. 

The change is largely accounted for by an improvement in the monitoring programmes 
and the extrapolation of those results to all river water bodies. 

 

Environmental objectives and exemptions 

 

Environmental  objectives  for  ecological  and  chemical  status  of  surface  water  bodies 
have  been  reported  for  both  RBDs  and  for  chemical  and  quantitative  status  of 

groundwater in the Rhine RBD. 

 

The number of Article 4(4) exemptions  has increased. Although this can  inter alia be 

explained  by  the  re-classification  of  all  surface  waters  being  in  poor  chemical  status, 

the  number  remains  significant,  particularly  also  with  regard  to  ecological  status  of 
surface water bodies. 

  Monitoring,  assessment  and  classification  of  quantitative  status  of  groundwater 

bodies 

 

There is  still a  gap in monitoring since one out  of the six groundwater bodies has no 

monitoring.  Luxembourg  clarified  however,  that  a  monitoring  site  is  already 
operational and will be integrated in the monitoring network by 2019. 

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

 

Due  to  an  error  in  the  electronic  reporting,  there  is  an  indication  that  there  is  no 
operational  monitoring  even  though  four  out  of  six  groundwater  bodies  are  at  risk  of 

failing  good  chemical  status  and  not  all  WFD  core  parameters  are  monitored. 
Luxembourg subsequently clarified that in fact the number of surveillance monitoring 

sites remained at 31 for the first and second RBMP and also operational monitoring is 
performed at these sites.  

 

It was also clarified that from the WFD core parameters only dissolved oxygen is not 
systematically  monitored  due  to  concerns  of  the  representativity  for  measures, 

especially in springs. 

13 

 
 
 

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

Ecological Potential 

 

The  methodology  for  the  designation  of  heavily  modified  water  bodies  has  not 
been modified since the first cycle, but the designations have been reviewed based 

on  the  availability  of  better  hydromorphological  structural  quality  mapping  of  all 
surface  (river)  waters,  measures  in  progress,  and  results  of  new  investigations 

concerning feasibilities of re-naturalisation actions. In addition, descriptions of the 
assessment  of  significant  adverse  effects  of  restoration  measures  and  of  other 

means  to  deliver  the  benefits  of  the  modifications  are  provided  for  each  heavily 
modified water body, although they remain general and do not use any quantified 

criteria as a basis.  

 

For  the  second  cycle,  a  method  has  been  developed  to  define  good  ecological 

potential.  Efforts  have  also  been  made  do  this  in  biological  terms  (for  fish  and 
benthic  invertebrates),  and  mitigation  measures  are  included  in  the  detailed 

Programme  of  Measures.  However,  no  information  could  be  found  on  the 
ecological  changes  that  the  mitigation  measures  are  designed  to  achieve  in  either 

qualitative or quantitative terms. According to information subsequently provided 
by Luxembourg, the definition of ecological potential and the mitigation measures 

permitting to achieve good ecological potential are under development and will be 
available for the third RBMP.  

 

Programme of Measures 

 

From WISE reporting it is not clear if Key Types of Measures (KTMs) are operational 
for all identified significant pressures. 

 

National basic and supplementary measures have been mapped against a wide range of 

KTMs.  However,  no  information  was  provided  on  the  KTMs  to  address  significant 
pressures and therefore a comparison could not be made. 

 

There  is  no  information  in  WISE,  on  KTMs  used  to  tackle  individual  Priority 
Substances causing failure of objectives.4 

4   Luxembourg clarified subsequently that KTM 21 and KTM 22 have been reported in table “KTM” and these 2 

KTM will help tackling pollution related to RBSP as well as priority substances. 

14 

 
 
                                                      
 

There are no gap indicators or gap analyses for any of the reporting cycles. Therefore, it 

is not possible to measure progress in achieving WFD objectives. 

 

The  objectives  and  requirements  of  the  Floods  Directive  have  been  considered  in  the 

second RBMP and Programme of Measures: The design of new and existing structural 
measures has been adapted to take account of WFD environmental objectives, and clear 

financial  commitments  have  been  secured  for  the  implementation  of  Programme  of 
Measures  in  the  flood  protection  sector.  Although  Luxembourg  indicated  that  natural 

water retention measures have been included in the Programme of Measures, there is no 
evidence  that  such  measures  have  been  made  operational.  WFD  Article  9(4)  has  not 

been applied to impoundments for flood protection. 

  Measures related to abstractions and water scarcity 

  Water abstraction pressures are not reported as relevant for Luxembourg, and the Water 

Exploitation Index + is not calculated. 

 

There  is  a  concession,  authorisation  and/or  permitting  regime  to  control  water 
abstractions  and  impoundments  but  no  register  of  impoundments;  and  small 

abstractions are not exempted from these controls.  

  Measures  promoting  efficient  and  sustainable  water  use  (Basic  Measure  Article 
11(3)(c)) were implemented in the previous cycle, and new measures and/or significant 
changes are planned for the 2016-2021 period. 

  Measures related to pollution from agriculture 

 

 

 

There is a clear link between pressures from agriculture and measures taken. 

A gap assessment for nutrients and pesticides has not been undertaken in all RBDs. 

So  far,  five  drinking  water  protection  zones  have  been  designated  near  groundwater 

bodies and further safeguard zones will be established. 

 

Luxembourg reported that financing of agricultural measures has been secured.   

15 

 
 
 
 
  Measures related to pollution from sectors other than agriculture 

 

KTMs have been reported for the River Basin Specific Pollutants identified as causing 

failure. 

 

Information  is  missing  from  the  RBMP  on  the  number  of  basic  and  supplementary 

measures used to tackle pollution from non-agricultural sources, and links between the 
measures and pressures causing failure are not always presented. 

 

Information on the progress expected in implementing KTMs between 2015 and 2027 

is also missing from the RBMP, and there is no evidence that a gap analysis has been 
undertaken for non-agricultural pollutant pressures. 

  Measures related to hydromorphology 

 

The level of detail provided in the second RBMP on measures is far higher than in the 
first  cycle.  A  catalogue  of  hydromorphological  measures  is  used,  which  includes  a 

semi-quantitative  effectiveness  assessment  for  each  measure  type  on  the  different 
quality elements, as well as an indication of the relevance to the Floods Directive. The 

catalogue  also  includes  the  cost  of  the  measures.  However,  for  the  largest  share  of 
water bodies affected by significant  hydromorphological  pressures,  the specific sector 

linked to these pressures is either unknown or obsolete. 

 

Indicators  on  the  gap  to  be  filled  for  significant  hydromorphological  pressures  and 

KTM value indicators are not reported, as the respective data was not available at the 
time of the WISE reporting. 

 

Ecological flows have not been derived for the relevant water bodies but there are plans 
to do it during the second cycle. A new supplementary measure is planned, namely to 

revise  the  Water  Law  to  set  minimum  ecological  flows.  The  implementation  of 
measures on minimum flow is scheduled to take place by 2021. 

 

Economic analysis and water pricing policies  

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

 

Information on the incentive function of water pricing is rather limited.   

16 

 
 
  A national approach for the calculation of cost recovery rates is used via a harmonised 

calculation method  

 

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

 

A significant reduction in monitoring of water bodies associated with protected areas is 

reported for the second cycle compared to the first cycle, although this was related to an 
error  in  the  information  reported  to  WISE.  The  information  in  WISE  did  not  include 

data on monitoring under the Birds, Habitats and UWWTD, which was reported under 
the obligations of those Directives. 

 

Adaptation to drought and climate change 

 

A  climate  check  of  the  Programme  of  Measures  has  been  made  in  the  second  cycle, 
while such a check was missing in the first cycle.  

 

No national  Climate Change Strategy  had been  developed by  the time the river basin 

management plan was published 

17 

 
 
 
 
Recommendations  

 

Luxembourg  should  focus  on 

international  cooperation, 

including  coordinated 

assessments of the technical aspects of the Water Framework Directive. 

 

 

Luxembourg still needs to continue work on apportionment of pressures among sources, 
so that measures can be adequately targeted. 

Luxembourg  should  reduce  the  dependence  on  expert  judgment  for  assessing  the 
significance of pressures. 

 

The  development  of  assessment  methods  should  be  completed  for  all  quality  elements 

and use them for the assessment of ecological status/potential for next RBMP. 

 

Luxembourg  also  should  ensure  that  Environmental  Quality  Standards  meet  the 
minimum  requirements  for  the  protection  of  freshwater  and  marine  ecosystems  from 
possible adverse effects, as well as of human health.  Luxembourg should complete the 

ongoing work on the establishment of nutrient thresholds that are sufficiently protective 
for good ecological status. 

 

Luxembourg  should  continue  improving  the  confidence  in  the  assessment  of  surface 
water  chemical  status.  Luxembourg  should  also  continue  improving  the  operational 

monitoring  for  status  assessment  to  reach  sufficient  spatial  coverage  and  temporal 
resolution  for  all  the  relevant  Priority  Substances.  If  reduced  frequencies  are  used, 

Luxembourg  should  provide  the  corresponding  explanations,  as  required  by  the 
Directive.  

 

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

provide sufficient data for long-term trend analysis.  

 

The  designation  of  heavily  modified  water  bodies  needs  to  be  further  improved  by 

Luxembourg by developing and applying clear criteria for significant adverse effects of 

restoration  measures  on  the  use  or  the  wider  environment  and  the  lack  of  significantly 
better  environmental  options.  This  will  improve  the  transparency  of  the  designation 

process.  Furthermore,  a  further  refined  methodology  for  the  definition  of  ecological 
potential needs to be applied for the 3rd RBMP. 

18 

 
 
 

A  significant  number  of  Article  4(4)  exemptions  remains  to  be  applied  in  the  second 

cycle. Although the WFD allows for exemptions, a thorough review of the assessment of 
technical feasibility and disproportionate costs is required. Efforts should be continued to 

ensure the implementation  of an  ambitious program  of measures in  order to  ensure the 
timely achievement of the WFD objectives. 

 

It  remains  unclear  whether  there  are  any  new  physical  modifications  planned  in 
Luxembourg. For the potential application of Article 4(7), Luxembourg needs to ensure a 

thorough assessment of possible new modifications in line with the requirements of the 
WFD and as further specified by the Judgment of the Court in case C-461/13. 

 

KTMs should be operational and cover all the pressures causing failure to objectives. In 

addition,  all  individual  Priority  Substances  identified  as  causing  failure  should  be 
associated with KTMs. 

 

 

 

Luxembourg should ensure that the RBMP clearly identifies the gap to good status, and 
that  the  Programme  of  Measures  are  designed  and  implemented  to  close  that  gap  with 

transparent  and  meaningful  information  regarding  the  timing  and  the  funding  of  the 
measures. 

Luxembourg  should  complete  a  comprehensive  gap  assessment  for  diffuse  pollutant 
loads    from  agriculture  (nutrients,  agri-chemicals,  sediment,  organic  matter)  across  all 

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

Luxembourg  should  continue  to  review  and  develop  a  coherent  strategy  encompassing 
WFD  with  all  relevant  policies  and  instruments  (e.g.  RDP,  CAP  Pillar  1,  Nitrates 

Directive, etc.) to  achieve the WFD objectives, and enhance the technical feasibility of 
its  next  RBMPS,  in  cooperation  with  the  farming  community  and  Luxembourg  CAP 

delivery authorities. 

 

A robust methodology should be implemented to identify River Basin Specific Pollutants 

and information on this methodology should be provided. It is strongly recommended to 

use the Technical Guidance for deriving EQSs. 

 

A gap analysis should be carried out as regards pollutants from non-agricultural sources, 

and the impact of the planned measures, such as improved urban waste water treatment, 
should  be  assessed,  so  that  adequate  supplementary  measures  can  be  identified  and 

implemented where necessary. 

19 

 
 
 

Luxembourg  should  ensure  the  implementation  of  ecological  flows  and  all  relevant 

hydromorphological measures during this second cycle. 

 

Luxembourg  should  apply  cost  recovery  for  water  use  activities  having  a  significant 

impact on water bodies or justify any exemptions using Article 9(4). Luxembourg should 
continue  to  transparently  present  how  financial,  environmental  and  resource  costs  have 

been  calculated  and  how  the  adequate  contribution  of  the  different  users  is  ensured.  It 
should  also  continue  to  transparently  present  the  water-pricing  policy  and  provide  a 

transparent overview of estimated investments and investment needs. 

 

Luxembourg  should  continue  the  establishment  of  safeguard  zones  to  protect  drinking 

water sources in designated groundwater bodies until complete coverage of these zones 

is achieved. 

20 

 
 
 
 
Topic 1

  Governance and public participation 

1.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle 

1.1.1

 Administrative arrangements – RBDs 

Luxembourg  belongs 
the  Meuse.  The 
Luxembourgish  part  of  the  international  RBD  Rhine  is  also  called  Moselle  RDB  and  the 

international  RBDs, 

the  Rhine  and 

two 

to 

Luxembourgish part of the international RBD Meuse is also called Chiers RBD.  

1.1.2

 Administrative arrangements – competent authorities 

Luxembourg  has  reported  two  competent  authorities.  The  Department  of  the  Environment, 
Ministry for Sustainable Development and Infrastructure, is responsible for the enforcement of 

regulations  and  the  coordination  of  implementation.  The  Water  Management  Agency  is 
responsible  for  the  monitoring  and  assessment  of  status  of  groundwater  and  surface  water, 

economic analysis, pressure and impact analysis, preparation of the RBMP and Programme of 
Measures,  public  participation,  implementation  of  measures  and  reporting  to  the  European 

Commission. 

1.1.3

 River  Basin  Management  Plans  –  structure  and  Strategic  Environmental 
Assessment. 

Luxembourg  did  not  prepare  sub-plans  for  its  RBMP.  The  RBMP  underwent  a  Strategic 

Environmental Assessment procedure. 

1.1.4

 Public participation and active involvement of stakeholders  

The public and interested parties were informed by direct mailing, over the internet, invitations 
to  stakeholders,  media  (papers,  television  and  radio)  and  through  meetings.  Documents  were 
available for the requisite six months and were available for download and also in paper copies 
at the Water Management Agency. 

The mechanisms for the active involvement of stakeholders were the establishment of advisory 
groups,  and  the  formation  of  alliances.  The  stakeholder  groups  actively  involved  were: 
agriculture/farmers;  local/regional  authorities;  NGOs/nature  protection;  water  supply  and 

sanitation; and municipal associations and river partnerships. 

21 

 
 
The public consultation had the following impacts: addition of new information, adjustment to 

specific measures, changes to the selection of measures, and commitment to action in the next 
RBMP cycle.  

1.1.5

 Integration  with  other  European  Union  legislation:  Floods  Directive5  and  Marine 
Strategy Framework Directive6 

Luxembourg  did  not  carry  out  joint  consultation  of  its  RBMP  and  Flood  Risk  Management 
Plan.  

1.1.6

 International Coordination 

Luxembourg's two RBDs are both part of international RBDs: the Rhine and the Meuse. For 

both,  an  international  agreement  was  in  place  and  a  permanent  co-operation  body;  an 
international RBMP had been produced for the second cycle; and explicit links had been made 

with  national  RBMP  within  the  international  RBMP  (designated  as  category  1  cooperation). 
However,  Luxembourg  reported  that  there  was  no  international  co-ordination  on  public 

participation.  

Luxembourg’s RBMP indicates that international co-operation related to the Rhine RBD takes 
place  via  the  International  Commission  for  the  Protection  of  the  Rhine  (ICPR)  and  the 

International Commissions for the Protection of the Moselle and Saar (ICPMS), which covers 
a  major  sub-basin  of  the  Rhine  IRBD.  The  latter  Commission  is  particularly  important  as  it 

brings together Luxembourg and its three neighbouring Member States, France, Germany and 
Belgium  (Wallonia).  In1984,  moreover,  Germany  and  Luxembourg  signed  a  new  agreement 

for joint water management, including for the rivers Our, Sauer and Moselle, which form the 
border between the two Member States for a length of about 128 km.  A first agreement has 

already  been  signed  in  1816.  In  the  Meuse  international  RBD  co-operation  took  place  under 
the  international  Meuse  Commission  (IMC).  For  further  information  see  the  reports  on 

international coordination on the Water Framework Directive. 

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  

6   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 the first cycle 

The  information  reported  to  WISE  does  not  indicate  any  major  changes  concerning 
Governance topics. 

1.3  Progress with Commission recommendations 

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

  Recommendation: Improve the reporting into the WISE to reflect the information in the 

RBMPs.  

Assessment:  In  comparison  with  the  first  cycle,  when  reporting  to  WISE  was 

incomplete  and  often  duplicated  information  for  the  two  RBDs,  Luxembourg’s 
reporting to WISE for the second cycle appears to be complete: the following chapters 

have  not  identified  gaps  in  reporting  to  WISE.  Moreover,  Luxembourg  has  reported 
separately for its two RBDs.  

Luxembourg has fulfilled this recommendation.  

  Recommendation:  The  RBMPs  should  be  clearly  structured  and  accessible  to  the 
public and relevant stakeholders. It would also be advisable to clearly distinguish the 
information and the measures that are relevant for the Rhine RBD, for the Meuse or for 

both.  This  transparency  within  a  clear  governance  structure  will  encourage  public 
participation  in  both  the  development  and  delivery  of  necessary  measures  to  deliver 

sustainable water management. 

Assessment:  The  RBMP  is  clearly  structured.  The  information  relevant  to  the  Rhine 

and  Meuse  RBDs  is  clearly  distinguished  in  many  cases  where  there  are  differences 
between the two RBDs. Although the PoM (Section 9 of the RBMP) focuses mainly on 
the national level in the RBD, tables list measures against surface water body codes, so 
it is possible to work out whether they belong to the Rhine or Meuse RBDs; moreover, 

Annex  20  of  the  RBMP  provides  details  of  measures  separately  for  the  Rhine  and 
Meuse RBDs. Luxembourg has fulfilled this recommendation. 

23 

 
 
 
 
Topic 2

  Characterisation of the River Basin District 

2.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle  

2.1.1

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

Overall  the  number  of  river  water  bodies  (Table  2.1)  and  groundwater  bodies  (Table  2.2) 

remained  largely  constant  between  the  first  and  second  cycles.  There  was  only  one  extra 
groundwater body and an 8 % increase in river water bodies in the Rhine RBD. Updates to the 

delineation  involved:  changes  in  the  length  and  size  of  the  catchment  for  some  river  water 
bodies; some divisions and some joining of river water bodies; two new surface water bodies; 

and the division of one groundwater body into two (Table 2.3). 

Table  2.1  shows  the  differences  in  size  distribution  of  surface  water  bodies  in  Luxembourg 

between the second and first cycles. However, the lengths of rivers were not reported for the 
first  cycle.  The  minimum  size  criteria  reported  was  0.5  km2  surface  area  for  lakes  but  no 
minimum size was reported for river catchments. 

The  reasons  for  delineation  of  surface  water  bodies  provided  in  the  RBMP  were:  comments 

from  the  European  Commission,  correcting  errors  in  geographical  boundaries,  revision  of 
surface water typology, and the revision of heavily modified water body designations.   

Table 2.1 

Number,  length  and  size  distribution  of  delineated  surface  water  bodies  in 
Luxembourg for the second and first cycles  

River length (km) 

Total length 

Minimum 

Maximum 

Average 

1 191 (1.197) 

2.6 

43.4 (43.26) 

11.13 (11.18) 

23 (22) 

1,214 

4.2 (3.9) 

14.44 (12.85) 

7.77 (7.177) 

Year 

RBD 

2016 

LU000 

2016 

LU001 

2016 

Total 

2010 

LU000 

2010 

LU001 

2010 

Total 

Number of 
river water 
bodies 
107 

3 

110 

99 

3 

102 

Source: WISE electronic reporting. The numbers in brackets were subsequently provided by Luxemburg.  

24 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 2.2 

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

Year 

RBD 

Number 

2016 

2016 

2016 

2010 

2010 

2010 

LU000 

LU001 

Total 

LU000 

LU001 

Total 

6 

0 

6 

5 

0 

5 

Area (km2) 

Minimum  Maximum  Average 

20.59 

912.02 

482.62 

0 

0 

0 

20.59 

912.02 

482.62 

19 

0 

19 

831 

0 

831 

517.2 

0 

517.2 

Source: WISE electronic reporting 

Table 2.3 

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

Luxembourg between the second and first cycles 

Type of water body change for 
second RBMP 

Groundwater 
Body 

River Water Body 

Aggregation 

Splitting 

Aggregation and splitting 

Extended area 

Creation 

Deletion 

Change in code 

No change 

Total water bodies before deletion 

Delineated for second cycle (after 
deletion from first cycle) 

2 

4 

6 

6 

8 

41 

5 

53 

110 

110 

Source: WISE electronic reporting.  

In  the  second  cycle,  93  %  of  identified  surface  water  bodies  were  natural,  while  7  %  were 
designated as “heavily modified”; there were no artificial water bodies. Overall, there was a 4 
%  increase  in  natural  water  bodies,  and  a  4  %  decrease  in  heavily  modified  water  bodies 
between the first and second cycles (Figure 2.1). The RBMP described that this re-delineation 

was in the light of new information, including water structure maps, which indicated that three 
status.  
could 
heavily  modified  water 

ecological 

achieve 

bodies 

good 

25 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
Figure 2.1 

Proportion of surface water bodies in Luxembourg designated as artificial, 

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

category 

Source: WISE electronic reporting 

One of the groundwater bodies was divided into two groundwater bodies  in  the Rhine RBD, 
changing  the  total  number  from  five  to  six,  on  the  basis  of  spatial  and  hydrological 

considerations,  as  well  as  geological  and  land  use  considerations,  and  including  horizontal 
stratification in line with Common Implementation Strategy guidance.   

2.1.2

 Identification of transboundary water bodies  

Transboundary  river  water  bodies  have  been  designated  for  the  Moselle-Saar  sub-unit.  No 

transboundary  groundwater  bodies  have  been  identified.  Delineation  was  coordinated  with 
other Member States. 

2.1.3

 Typology of surface water bodies 

The  number  of  surface  water  body  types  remained  the  same  between  the  first  and  second 
cycles  (Table  2.4).  The  RBMP,  however,  described  that  the  surface  water  typology  was 

changed  from  using  four  different  methods  developed  and  applied  in  the  first  RBMP  to 
focusing  on  one  methodology  adapted  for  Luxembourg  for  the  second  cycle.  The  reason 

provided in the RBMP was that the method allowed for the validation of the typology, to make 
it biologically relevant for aquatic fauna and flora.  

26 

 
 
 
 
All the national types for Luxembourg appear to have corresponding intercalibration types. 

The  Moselle  was  assigned  type  VI,  which  also  coincided  with  the  German  designation.  In 
general,  there  is  good  permanent  cooperation  within  the  relevant  International  Commissions 

for the Protection of the Moselle-Saar, Rhine and Meuse. 

Table 2.4 

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

RBD 

Rivers 

2010 

2016 

LU000 

LU001 

TOTAL 

6 

1 

6 

6 

1 

6 

Source: WISE electronic reporting 

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

2.1.4

 Establishment of reference conditions for surface water bodies 

Table  2.5  shows  the  percentage  of  surface  water  body  types  in  Luxembourg  with  reference 
conditions  established  for  the  second  cycle.  Type  specific  reference  conditions  have  been 

established  for  all  relevant  biological  quality  elements,  and  all  physicochemical  quality 
elements. Type specific reference conditions were not reported for hydromorphological quality 
elements7. 

The  reference  conditions  were  revised  and  clarified  following  the  first  cycle  in  fact  sheets, 

which describe the ideal conditions for good ecological status (the fact sheets are in Annex 2 of 
the RBMP). 

7   Luxembourg subsequently clarified that for the evaluation of morphological quality, Luxembourg applied a 
German methodology and related all the national river types with a LAWA-type of the German typology. 
Luxembourg stated that this is why each Luxembourgish river types has its correspondent reference conditions 
defined by the German LAWA type. Luxembourg subsequently provided a link to the LAWA documents 
describing the hydromorphological reference conditions: 
https://www.umweltbundesamt.de/publikationen/strategien-zur-optimierung-von-fliessgewaesser  

27 

 
 
 
 
 
 
                                                      
Table 2.5 

Percentage of surface water body types in Luxembourg with reference 

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

parenthesis are the number of types in each category 

Biological 
quality 
elements 
100 % 

Hydromorphological 
quality elements 

Physicochemical quality 
elements 

100 %8 

100 % 

Water 
category 

Water 
types 

All 

Rivers (6) 

Some  

None 

Source: WISE electronic reporting 

2.1.5

 Significant pressures and impacts on water bodies 

In 

the  second  cycle,  “diffuse 

-  atmospheric  deposition”,  “physical  alteration  of 

channel/bed/riparian  area/shore”  and  “anthropogenic  pressure”  were  the  most  dominant 
significant pressures affecting about 100 % of river water bodies (Figure 2.2). For groundwater 

bodies, the most significant pressure was “diffuse – agricultural” (83 %), followed by “point - 
contaminated sites” or “abandoned industrial sites” (50 %) (Figure 2.2). No data was available 

for significant pressures on water bodies in Luxembourg in the first cycle.  

For the second  cycle, it was reported that 39 pressures were not  assessed for surface waters. 
For  groundwater  it  was  reported  that  53  significant  pressures  were  not  assessed9.  Many  of 
which were related to surface water specific pressures such as dams and hydrological changes. 

However, there were some pressures that could impact groundwater which were not assessed 
such as “groundwater - alteration of water level or volume”. No explanation for this was found 
in the RBMP10. The RBMP did report that additional pressures have been considered since the 
first RBMP, the relationship between pressures and drivers was clarified. 

In  the  second  cycle,  the  most  significant  impact  on  surface  water  bodies  was  “organic  and 
chemical pollution” and “altered habitats due to morphological changes”, each affecting 100 % 
of river water bodies, followed by nutrient pollution (90 %) (Figure 2.4). For groundwater, the 
most  significant  impacts  were  organic  and  nutrient  pollution  (100  %),  followed  by  chemical 

pollution (83 %) (Figure 2.4). Luxembourg did not report on impacts in the first cycle. 

8   Except, in all cases, for hydrological regime. 
9   Luxembourg subsequently clarified that it couldn’t provide information for some of the pressures as it didn’t 
use the same level of detail as the one used in WISE reporting. Therefore information was reported at a more 
general level. Luxembourg stated that they will try to use the categories from the WISE reporting for the next 
article 5 assessment in order to be able to provide more detailed information in the next reporting exercise. 

10 Luxembourg subsequently highlighted that the interaction between groundwater and surface water will be 

further analysed for the next RBMP. 

28 

 
 
 
 
 
 
 
 
                                                      
Figure 2.2 

The  most  significant  pressures  on  surface  water  bodies  and  groundwater 

bodies in Luxembourg for the second cycle 

Source: WISE electronic reporting  

29 

 
 
 
 
 
 
Figure 2.3 

Significant impacts on surface water and groundwater bodies in Luxembourg 

for the second cycle. Percentages of numbers of water bodies 

Source: WISE electronic reporting  

2.1.6

 Definition and assessment of significant pressures on surface and groundwater 

For  surface  waters,  expert  judgement  was  used  for  defining  significant  pressures  from  point 
sources,  diffuse  sources,  abstraction  and  other  significant  pressures.  Expert  judgement  and 

numerical  tools  were  used  for  defining  water  flow  pressures.  For  surface  water  bodies, 

30 

 
 
 
 
 
 
significance of pressures is reported as being linked to the potential failure of objectives and is 

defined in terms of thresholds. 

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

defining significant pressures from abstractions. For diffuse and point source pressures expert 
judgement was used. Artificial recharge pressures do not appear to have been assessed. 

The  criteria  used  to  set  threshold  values  for  significant  pressures  for  surface  water  and 
groundwater bodies were reviewed following the first RBMP, and some thresholds were made 

more  stringent.  Threshold  values  were  set  for  all  significant  pressures  and  the  relationship 
between  drivers  and  pressures  was  clarified.  The  threshold  values  were  used  along  with  the 

status assessment, monitoring programme results to define significant pressures.  

2.1.7

 Quantification of the gap and apportionment of pressures  

There  are  some  inconsistencies  in  the  pressures  for  which  measures  are  planned  and  the 
significant pressures reported at the water body level.  

Luxembourg  has  characterised  the  drivers  for  the  significant  pressures  and  linked  them  to 
activities/sectors.  The  drivers  at  a  national  level  were  urban,  agriculture  and  forestry, 
navigation,  hydroelectricity,  flood  protection,  and  atmospheric  deposition.  For  groundwater 

bodies,  the  main  drivers  were  agriculture  and  forestry,  linked  to  the  nitrate  and  pesticides 
pressures. 

The Priority Substances causing the failure of good chemical status have been reported, but the 
measures to tackle these substances to achieve good status have not been reported, which is a 

significant  gap.  The  RBMP  reported  that  the  reason  measures  are  not  yet  in  place  was  that 
further  investigations  of  the  sources  are  planned.  This  included  polycyclic  aromatic 

hydrocarbons, which are possibly from old/disused industrial or waste sites, diuron (possibly 
from inappropriate disposal), and isoproturon, which is expected to be reduced to some extent 

as a result of bans on usage in water protection zones (already in place).  

2.1.8

 Groundwater bodies at risk of not meeting good status 

In the Rhine RBD, 67 % of groundwater bodies were reported to be at risk of failing to meet 
good  chemical  status.  The  pollutants  putting  groundwater  bodies  at  risk  of  failing  good 

chemical status have been reported. It was reported that no groundwater bodies were at risk of 
failing to meet good quantitative status. 

31 

 
 
2.1.9

 Inventories of emissions, discharges and losses of chemical substances 

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

and the eight other pollutants listed in Part A of Annex I 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  (resp. 

suppressing) emissions, discharges and losses for priority substances (resp. priority hazardous 
substances). 

Luxembourg  reported  that  all  Priority  Substances  were  included  in  the  inventories  for  each 
RBD. The two step approach from the Common Implementation Strategy Guidance Document 
n°2811 has been followed for all substances considered in  the inventories. They  carried out  a 
simple assessment (tier 1 point source information) for substances not relevant at RBD level as 

recommended by the guidance document, and a much more thorough assessment (all 4 tiers) 
for substances relevant at RBD level. The quality of the input data is assessed as medium in all 
cases. 

2.2  Main changes in implementation and compliance since the first cycle 

Overall, the number of groundwater bodies and river water bodies remained largely the same 

between  the  first  and  second  cycles.  There  was  one  extra  groundwater  body  and  an  8  % 
increase  in  river  water  bodies  in  the  Rhine  RBD.  In  the  second  cycle,  93  %  of  identified 

surface  water  bodies  were  natural  with  7  %  being  designated  as  heavily  modified  and  no 
artificial water bodies.  

The  number  of  surface  water  body  types  remained  the  same  between  the  first  and  second 
cycles, but  the typology  was applied using an updated methodology moving from  using four 

different methods developed and applied in the first RBMP to focusing on one methodology.   

Overall,  there  was  a  4  %  increase  in  natural  water  bodies  and  a  4  %  decrease  in  heavily 

modified water bodies between the first and second cycles because it was realised that some of 
them  could  achieve  good  ecological  status.  The  criteria  used  to  set  threshold  values  for 

significant pressures for surface water bodies and groundwater bodies were reviewed since the 
first RBMP and some thresholds were made more stringent.  

11   CIS Guidance N° 28 - Preparation of Priority Substances Emissions Inventory 

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

32 

 
 
                                                      
2.3  Progress with Commission recommendations 

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

 

inventory  of  chemical  emissions  with  detailed 
Recommendation:  Complete 
information  on  pressures  from  priority  and  priority  hazardous  substances  including 

the 

small  emitters  and  diffuse  sources.  This  improved  inventory  is  expected  to  support  the 
design  of  relevant  and  more  detailed  measures  for  the  reduction  /  phasing  out  of 

emissions of these substances as appropriate.  

Assessment:  Luxembourg  reported  that  all  of  Priority  Substances  were  included  in  the 

inventories  for  each  RBD.  The  two  step  approach  from  the  Common  Implementation 
Strategy Guidance Document n°2812 has been followed for all substances considered in 
the  inventories.  They  carried  out  a  simple  assessment  (tier  1  point  source  information) 
for  substances  not  relevant  at  RBD  level  as  recommended  by  the  guidance  document, 

and a much more thorough assessment (all 4 tiers) for substances relevant at RBD level. 
The  quality  of  the  input  data  is  assessed  as  medium  in  all  cases.  Therefore,  this 

recommendation has been fulfilled. 

 

Recommendation:  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.  

and 

 

Recommendation:  Ensure  that  the  RBMPs  clearly  identify  the  gap  to  good  status,  and 

that  the  Programme  of  Measures  is  designed  and  implemented  to  close  that  gap  with 
transparent and meaningful information regarding the scope, the timing and the funding 
of the measures. 

and 

 

Recommendation: Improve knowledge about the link between pressures and impacts in 

designing and making operational the measures for the second RBMPs cycle in order to: 
Refine the significance of the pressures by quantifying those which are likely to prevent 

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

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

33 

 
 
                                                      
the  achievement  of  environmental  objectives.  Apportion  pressures  by  their  source  and 

identify  the  responsible  sectors/areas.  Assess  the  reduction  in  pressures  required  to 
achieve environmental objectives.  

Assessment: For the second cycle, it was reported that 39 pressures were not assessed for 
surface  waters,  and  53  for  groundwater,  which  was  not  explained  in  the  RBMP13.  The 
criteria used to set threshold values for significant pressures for surface water bodies and 
groundwater bodies were reviewed following the first RBMP and some thresholds were 

made  more  stringent.  Threshold  values  were  set  for  all  significant  pressures  and  the 
relationship between drivers and pressures was clarified. The threshold values were used, 

along with the status assessment and monitoring programme results, to define significant 
pressures. This shows some progress towards fulfilling the part of the recommendations, 

relating to defining significance in relation to the environmental objectives.  

Pressures have been apportioned by their source, and responsible sectors/areas have been 

identified.  However,  expert  judgement  is  still  largely  used  for  defining  significant 
pressures from point sources, diffuse sources, abstraction, and other significant pressures 
for  surface  waters,  which  means  that  this  may  be  less  robust14  compared  to  using  a 
combination of quantitative tools and expert judgement. The Priority Substances causing 

the failure of good chemical status have been reported, but the measures to tackle these 
substances to achieve good status have not been reported.  

Overall,  there  appears  to  be  some  progress  in  implementing  these  recommendations; 
however they have been partially fulfilled. 

13   Luxembourg subsequently explained that the same level of detail used at national level was not the same one 

used in WISE reporting and therefore the information had to be reported at a more general level. 

14   Luxembourg subsequently highlighted that for a small country such as Luxembourg, their experts know the 

water bodies (such as their characteristics, industries implemented in their basin, measures planned, projects to 
be established there in the future etc.) very well. In many cases this knowledge leads to a more detailed 
analysis of pressures as the one done with models as these are often not detailed enough. Luxembourg also 
stated that the delineation of the national water bodies is small scaled and allows to adequately judge the 
pressures on each one of them and they believe that this would not be possible to the same extent with a 
modelling approach. 

34 

 
 
                                                      
Topic 3

  Monitoring,  assessment  and  classification  of  ecological 

status in surface water bodies 

3.1  Assessment of implementation and compliance with WFD requirements 

in the second RBMP 

3.1.1

 Monitoring of ecological status/potential 

Monitoring programmes 

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

assessment of the status of surface water and of groundwater in order to provide a coherent and 
comprehensive overview of water status within each RBD.  

Separate  surveillance  and  operational  monitoring  programmes  were  reported  for  rivers  (the 
only  surface  water  category  delineated)  in  both  RBDs.  There  were  also  other  separate 

monitoring programmes in both RBDs, for example, for eutrophication and river gauging.  

Monitoring sites  

Table  3.1  compares  the  number  of  monitoring  sites  used  for  surveillance  and  operational 
purposes between the first and second RBMPs. 

35 

 
 
 
Table 3.1 

Number of sites used for surveillance and operational monitoring in 

Luxembourg for the second and first RBMPs. Note that for reasons of 
comparability with data reported in the first RBMP, the data for the second 

RBMP does not take into account whether sites are used for ecological and/or 
chemical monitoring 

2nd RBMP 

LU_000 

LU_001 

Total by type of site 

Total number of monitoring sites 
1st RBMP 

LU_000 

LU_001 

Total by type of site 

Rivers 

Surv. 

Op. 

3 

2 

5 

4 

2 

6 

223 

215 

3 

218 

99 

3 

102 

Total number of monitoring sites 

108 

Source: WISE electronic reporting 

There are differences in  the numbers of monitoring sites reported to WISE and that obtained 

from the published first RBMP. Using the most recent data for the first RBMP,  it seems that 
there has been a large increase in the number of operational sites in the Rhine RBD, from 99 in 
the first RBMP to 215 in the second.15 The number of operational sites (3) for the other RBD 
(Meuse) was the same for both RBMPs. In terms of surveillance sites, the only difference from 

the first to the second RBMPs was a decrease in the Rhine RBD, from four for the first RBMP 
to  three  for  the  second.  Table  3.2  gives  the  number  of  sites  used  for  different  monitoring 
purposes  for  the  second  RBMP.  In  addition  to  operational  and  surveillance  monitoring,  a 

number of other monitoring purposes was reported in relation to some types of Protected Areas 
and  international  monitoring  obligations,  and  in  particular  a  large  number  of  sites  used  for 

investigative monitoring. 

15   Luxembourg subsequently stated that for the first RBMP more stations were monitored, however they were 

not reported as some of them were not WFD compliant.   

36 

 
 
  
  
  
  
  
 
 
 
                                                      
Table 3.2 

Number of monitoring sites in relevant water categories used for different 

purposes in Luxembourg 

Monitoring Purpose 

Number of sites 

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

CHE - Chemical status 

ECO - Ecological status 

INT - International network of other international 
convention16 
INV - Investigative monitoring 

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

OPE - Operational monitoring 

RIV - International network of a river convention 
(including bilateral agreements)17 
SUR - Surveillance monitoring 

Total sites irrespective of purpose 

11 

13 

222 

2 

405 

16 

218 

3 

5 

514 

Source: WISE electronic reporting  

Quality elements monitored (excluding River Basin Specific Pollutants) 

Table  3.3  illustrates  the  quality  elements  used  for  the  monitoring  of  rivers  for  the  second 

RBMP: no differentiation is made between purposes of monitoring. 

The  same  biological  quality  elements  monitored  for  the  first  RBMP  were  reported  to  be 

monitored for the second RBMP. This means there is still one gap in the elements monitored: 
fish  in  rivers  in  the  Meuse  RBD18.  Hydromorphological  quality  elements  and  general 
physicochemical  quality  elements  were  only  reported  at  an  aggregated  level  for  the  first 
RBMP.  For  the  second  RBMP,  river  continuity  and  morphological  conditions  were  reported 
not to be monitored.19 All required general physicochemical quality elements were monitored 
in rivers in Luxembourg for the second RBMP.  

16   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 

17   Luxembourg subsequently clarified that the two sites reported for monitoring purpose INT should have been 

reported under RIV, taking the RIV total to five sites. 

18   Luxembourg subsequently clarified that this was a reporting error. Fish were assessed in two of the three water 

bodies in the Meuse RBD but this was not included in the reporting to WISE. 

19   Luxembourg subsequently clarified that morphological conditions and river continuity were monitored and 

evaluated for every water body, but it was not reported in WISE. The evaluation of morphological conditions 

37 

 
 
                                                      
Table 3.3 

Quality elements monitored for the second RBMP in Luxembourg (excluding 

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

Biological quality elements 

s
e
t
y
h
p
o
r
c
a
M

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

c
i
h
t
n
e
B

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

i

h
s
i
F

s
m
r
e
p
s
o
g
n
A

i

e
a
g
l
a
o
r
c
a
M

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

Rivers  Yes  Yes  Yes  Yes  Yes 

s
e
i
c
e
p
s
r
e
h
t
O

c
i
t
a
u
q
a
r
e
h
t
O

a
r
o
l
f

No 

Hydromorphological quality elements7 

l
a
c
i
g
o
o
r
d
y
H

l

i

e
m
g
e
r

l
a
d
i
t

r
o

Yes 

y
t
i
u
n
i
t
n
o
C

s
n
o
i
t
i
d
n
o
c

No 

l

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

s
n
o
i
t
i
d
n
o
c

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

l
a
m
r
e
h
T

s
n
o
i
t
i
d
n
o
c

n
o
i
t
a
n
e
g
y
x
O

s
n
o
i
t
i
d
n
o
c

y
t
i
n

i
l
a
S

s
n
o
i
t
i
d
n
o
c

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

s
u
t
a
t
s

n
e
g
o
r
t
i

N

s
n
o
i
t
i
d
n
o
c

s
u
r
o
h
p
s
o
h
P

s
n
o
i
t
i
d
n
o
C

e
t
a
c
i
l
i

S

r
e
h
t
O

i

d
n
a
n
m
r
e
t
e
d

t
n
e
i
r
t
u
n
r
o
f

s
n
o
i
t
i
d
n
o
c

Rivers 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

No 

No 

Source: WISE electronic reporting  

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

period  of  one  year  during  the  6-year  period  covered  by  a  RBMP.  For  phytoplankton,  this 
should be done twice during the monitoring year and for the other biological quality elements 

once during the year. Operational monitoring should take place at intervals not exceeding once 
every six months for phytoplankton and once every three years during the 6-year cycle for the 

other biological  quality  elements.  Greater intervals  may be justified on the basis of technical 
knowledge and expert judgement. 

In  Luxembourg  as  a  whole,  four  of  the  five  biological  quality  elements  used  for  the 
surveillance  monitoring  of  rivers  were  sampled  at  least  at  the  minimum  recommended 

frequency at all of the sites where they were monitored. The exception was macrophytes, for 
which 75 % of the sites met this frequency. In contrast, only one of the five biological quality 

elements  used  in  the  operational  monitoring  of  rivers  was  sampled  at  least  at  the  minimum 
frequency. For fish only 17 % of sites were sampled at this frequency. 

and river continuity was not done at the level of monitoring stations, but on the basis of a detailed structural 
quality survey. 

38 

 
 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                                                                                                                        
The RBMP specifically mention the following changes from the first to the second RBMP: (i) 

the  quality  element  phytoplankton  was  added  to  the  monitoring  programme  in  all  relevant 
water bodies and the results included in the assessment of ecological status/potential; (ii) other 

aquatic flora has only been monitored since 2007 and has therefore been fully included only in 
the  assessment  for  the  second  RBMP;  20(iii)  the  second  intercalibration  phase  set  new  limit 
values and reference values (2013/480/EU21), and therefore the reference and limit values for 
benthic  invertebrates,  macrophytes  and  diatoms  were  adjusted  accordingly;  (iv)  the  benthic 

invertebrates  have  been  evaluated  using  the  French  “Indice  Biologique  Global  Normalisé” 
(IBGN) since 2007, therefore the calculation continued to be as an “IBGN-equivalent” value to 

allow comparison with earlier results.  

River Basin Specific Pollutants and matrices monitored 

Member  States  were  not  asked  to  report  to  WISE  on  which  River  Basin  Specific  Pollutants 

have  been  identified  or  which  ones  are  specifically  monitored.  However,  information  was 
reported  on  the  individual  chemical  substances  monitored  in  surface  and  groundwater. 
Information  on  monitored  River  Basin  Specific  Pollutants  in  surface  waters  was  derived  by 

removing Priority Substances from the list of monitored chemical substances in surface waters. 

On this basis, 54 River Basin Specific Pollutants are monitored in  Luxembourg, all in water. 
All were monitored at 14 sites22. Member States were also asked to report River Basin Specific 
Pollutants at the generic quality element level for the second RBMP. Luxembourg reported (at 

the generic level) that 400 sites were used for the monitoring of River Basin Specific Pollutants 
for  investigative  purposes.  173  sites  were  reported  to  be  used  for  surveillance  and/or 

operational monitoring.  

Information in the first RBMP was also reported at a generic quality element level. From the 

reported information it appears that there has been a significant increase in the number of sites 
from the first RBMP (Table 3.4). 

20   Luxembourg  subsequently  clarified  that  the  reporting  of  “other  aquatic  flora”  was  a  reporting  error  and  no 

“other aquatic flora” was monitored. 

21   Commission Decision of 20 September 2013 establishing, pursuant to Directive 2000/60/EC of the European 
Parliament and of the Council, the values of the Member State monitoring system classifications as a result of 
the  intercalibration  exercise  and  repealing  Decision  2008/915/EC  (notified  under  document  C(2013)  5915) 
Text with EEA relevance https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32013D0480 
22   Luxembourg subsequently stated that River Basin Specific Pollutants were monitored at other sites also, but at 
some of these monitoring sites only some of the RBSP were monitored (mainly metals) and in some cases the 
frequency was lower than the frequency indicated in the WFD. 

39 

 
 
 
 
                                                      
Table 3.4 

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

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

both cycles may not be fully comparable as different definitions were used and 
also not all Member States reported information at a site level, meaning that 

there were no equivalent data for the first RBMP 

RBMP 

Number of stations  
(River water bodies) 

1st  

 Sites  used  to  monitor  non-priority  specific  pollutants 
and/or other national pollutants – reported at the quality 
element level 

2nd     

Sites used to monitor River Basin Specific Pollutants  – 
reported at the quality element level 

136 

173 

Sources: WISE electronic reporting. Data does not take into account whether sites are used for ecological and/or 
chemical monitoring  

Annex  V  of  the  WFD  provides  guidance  on  the  frequency  of  monitoring  of  the  different 
quality  elements: once every three  months  is recommended for “other pollutants”, which  are 

taken  here  to  equate  to  river  basin  specific  pollutants.  Surveillance  monitoring  should  be 
carried out for each monitoring site for a period of one year during the 6-year period covered 

by a river basin management plan. For river basin specific pollutants this should be done four 
times for the surveillance year, and for operational monitoring four times a year for each year 

of the cycle. 

For all sites and all River Basin Specific Pollutants monitored for surveillance purposes, these 

were  sampled  at  least  at  the  minimum  recommended  frequency.  In  terms  of  operational 
monitoring none of the sites for all River Basin Specific Pollutants was sampled at least at the 

minimum  recommended  frequency.  However,  reported  as  being  sampled  at  least  at  the 
minimum  recommended  frequency.  However  Luxembourg  subsequently  informed  the 

Commission that there were errors in the reporting and that some of the sites were monitored at 
the minimum recommended frequency. 

Surveillance monitoring of surface water bodies 

All  three  river  water  bodies  in  the  Rhine  RBD  used  for  surveillance  monitoring  were 
monitored  for  all  required  biological  quality  elements  and  general  physicochemical  quality 

elements.  All  required  general  physicochemical  quality  elements  were  monitored  in  the  one 
river  water  body  in  the  Meuse  RBD  used  for  surveillance  but  this  was  not  the  case  for  the 

biological  quality  elements.  None  of  the  water  bodies  included  in  surveillance  monitoring  in 

40 

 
 
 
 
both RBDs was reported as having been monitored for all required hydromorphological quality 
elements23.  

Overall in Luxembourg, the number of delineated river water bodies increased from 102 in the 

first  RBMP  to  110  in  the  second.  The  total  number  and  proportion  of  river  water  bodies 
included in surveillance monitoring decreased from five (5 %) for the first RBMP to four (4 %) 

for  the  second.  In  contrast  the  proportion  of  river  water  bodies  included  in  operation 
monitoring increased from  74 % in  the first  RBMP to  85 % in  the second. Overall, 86 % of 

river water bodies were reported to be included in surveillance and/or operational monitoring 
(Figure  3.1).  Luxembourg  subsequently  informed  the  Commission  that  due  to  errors  in  the 

reporting  the  number  of  water  bodies  monitored  might  differ  from  what  was  reported.  The 
proportion of surface  water bodies in  different  status  classes in  which there was surveillance 

monitoring (Figure 3.2) indicates that no surface water bodies in good status are included, and 
therefore not as required by the WFD. 

Figure 3.1 

Percentage of water bodies included in surveillance and operational 
monitoring in Luxembourg for the first RBMP and second RBMP. Note no 
differentiation is made between water bodies included in ecological and/or 

chemical monitoring 

Source: WISE electronic reporting, Luxembourg subsequently noted that wrong water body codes have 

been reported for some monitoring stations. 

23   Luxembourg subsequently indicated that there was an error in their reported data and that all of the water 

bodies included in surveillance monitoring had been monitored for the required hydromorphological quality 
elements. 

41 

 
 
 
 
 
                                                      
Figure 3.2 

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

included in surveillance monitoring in Luxembourg  

Source: WISE electronic reporting 

Operational monitoring of surface water bodies 

The  biological  quality  elements  predominantly  used  for  operational  monitoring  were 
macrophytes,  phytobenthos  and  benthic  invertebrates  (in  94  %  of  water  bodies  included  in 

operational monitoring). 84 % of water bodies in less than good status/potential were included 
in  operational  monitoring:  the  only  three  water  bodies  in  good  or  high  status/potential  were 
included in operational monitoring but not in surveillance monitoring24.  

Transboundary surface water body monitoring  

Six  transboundary  river  water  bodies  were  reported  by  Luxembourg.  Five  river  monitoring 
sites were reported to be part of an international network and/or a river convention network.25  

Use of monitoring results for classification 

Grouping  has  not  been  used  for  the  classification  of  ecological  status/potential  at  the  quality 
element  level.  Around  10  %  of  water  bodies  were  classified  by  expert  judgment  for  general 

24   Luxembourg subsequently clarified that these values are not accurate as some water body codes were 

incorrectly reported for some monitoring stations. 

25   Luxembourg subsequently clarified that all five monitoring sites are included in a river convention network. 

42 

 
 
 
                                                      
physicochemical quality elements and River Basin Specific Pollutants. The biological quality 

elements  were  overwhelmingly  classified  using  monitoring  results.  There  are  often 
discrepancies  between  the  number  of  water  bodies  directly  monitored  for  biological  quality 

elements in the Rhine RBD and those classified using monitoring results. For example, benthic 
invertebrates were monitored in  87 river water bodies and 103 were reported as having been 

classified using monitoring results: grouping was reported not to have been used. Luxembourg 
subsequently informed the Commission that due to errors in the reporting the number of water 

bodies  monitored  might  differ  from  what  was  reported.  A  more  significant  discrepancy  is  in 
terms  of  hydromorphological  quality  elements  where  hydrological  regime  was  directly 
monitored  but  was  not  used  in  the  classification  of  ecological  status/potential26.  Conversely 
river continuity and morphological conditions were reported to be classified using monitoring 

results  even  though  no  water  body  was  reported  to  be  monitored.  However,  Luxembourg 
subsequently clarified that river continuity and morphological conditions were monitored, but 

it was not reported in WISE.  

3.1.2

 Ecological Status/potential of surface water  

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

illustrated in Map 3.1. 

The  total  number  of  river  water  bodies  increased  from  102  in  the  first  RBMP  to  110  in  the 

second. The proportion of river water bodies in good status/potential decreased from 7 % in the 
first RBMP to 3 % in the second. Correspondingly, the proportion of less than good increased 

from  93  %  to  97  %.  There  has  been  an  improvement  in  the  confidence  of  the  classification 
from  the  first  to  the  second  RBMP:  61  %  were  classified  with  high  confidence  in  the  first 

RBMP and 100 % in the second (Figure 3.3). 

The proportion of river water bodies in poor status was reduced from about 10 % in the first 

RBMP to 8 % in the second, and river water bodies in bad status from about 30 % in the first 
RBMP to 23 % in the second. There were increases in the proportion of moderate status, with 

about  53  %  in  the  first  plan  and  66  %  in  the  second  (none  were  classified  as  high  status) 
(Figure 3.4). 

26   Luxembourg subsequently stated that hydrological regime was not evaluated as the methodology was not 

ready, but it will be evaluated for the next RBMP. 

43 

 
 
 
                                                      
Map 3.1 

 Ecological status or potential of surface water bodies in Luxembourg based 

on the most recently assessed status/potential of the surface water bodies 

Note: Standard colours based on WFD Annex V, Article (1)(4)(2)(i).  
Source: WISE, Eurostat (country borders) 

High 

Good 

Moderate 

Poor  

Bad 

Unknown 

River Basin Districts 
Countries  outside 
Union 

the  European 

44 

01020kmLU000LU001LU 
 
 
  
  
  
  
  
  
  
  
 
Figure 3.3  Confidence  in  the  classification  of  ecological  status  or  potential  of  surface 

water  bodies 
status/potential 

in  Luxembourg  based  on 

the  most  recently  assessed 

Source: WISE electronic reporting  

A similar picture emerged for ecological  potential,  where the proportion of heavily modified 
water bodies in good ecological potential was reduced from 9 % to zero from the first  to the 

second  RBMP,  whilst  the  proportion  with  moderate  ecological  potential  remained  about  the 
same, and the proportion in the class of bad potential were significantly reduced, from 45 % to 

25 %, whilst the proportion in the class of poor potential increased from about 18 % to 50 %. 

The  RBMP  indicates  that  the  changes  are  due  in  part  to  changes  in  the  designation  of  water 

bodies (91 natural water bodies in the first RBMP and 102 in the second , 11 heavily modified 
water bodies in the first RBMP and eight in the second), but most importantly due to a more 

complete dataset and more stringent assessment, in particular more biological quality elements 
and a higher number of water bodies monitored, and assessment of the ecological status on the 
basis  of  the  worst  case  results  in  terms  of  biological  and  general  physicochemical  quality 
elements. 

Luxembourg  reports  that  the  majority  of  their  river  water  bodies  will  reach  good 
status/potential for the third RBMP (Figure 3.5). 

45 

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

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

period  of  the  assessment  of  status  for  the  second  RBMP  was  2008  to  2015. 
The year of the assessment of status for first RBMP is not known 

Source: WISE electronic reporting 

46 

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

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

Source: WISE electronic reporting  

Classification of ecological status in terms of each classified quality element 

Over  95  %  of  river  water  bodies  were  classified  for  benthic  invertebrates,  phytobenthos  and 
macrophytes but  for only  41 % for fish (Figure  3.6).  Phytoplankton  is  monitored in  the one 

reported reservoir and four other river water bodies. 

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

status/potential for the second RBMP. 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 between the first and second plans. The same biological quality elements 
were  used  for  the  first  and  second  plans.  Other  aquatic  flora  was  reported  but  Luxembourg 

subsequently  confirmed  that  this  was  a  reporting  error,  and  that  theyreported  “other  aquatic 
flora” in place of the two sub-BQEs diatoms and macrophytes. 

47 

 
 
 
Even  fewer  water  bodies  have  been  classified  using  the  supporting  quality  element 
hydrological regime in the second RBMP than in the first27 (Figure 3.9). 

All river water bodies were classified according to River Basin Specific Pollutants, 97 (88 %) 

using monitoring results, the remainder by expert judgment. 100 water bodies were reported to 
be directly monitored (Figure 3.9). 

Figure 3.6  Ecological  status/potential  of  the  biological  quality  elements  used  in  the 
classification  of  surface  waters  in  Luxembourg.  Note  that  water  bodies  with 

unknown  status/potential,  and  those  that  are  monitored  but  not  classified  or 
not applicable, are not presented. 

Source: WISE electronic reporting.  Luxembourg subsequently noted that there was no 

monitoring for “other aquatic flora” and this was reported by mistake. 

27   Luxembourg  subsequently  clarified  that  hydrological  regime  is  monitored  but  was  not  evaluated  in  the  2nd 

RBMP as the methodology was not ready. It will be evaluated for the next RBMP. 

48 

 
 
 
 
                                                      
Figure 3.7  Comparison  of  ecological  status/potential  in  Luxembourg  according  to 

classified  biological  quality  elements  in  rivers  between  the  first  and  second 
RBMP  

Source: WISE electronic reporting. Luxembourg subsequently noted that there was no monitoring for 
“other aquatic flora” and this was reported by mistake. 

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

of rivers in Luxembourg for the second RBMP. Overall in Luxembourg, the ecological status 
of rivers has been assessed using all four groups of quality elements (Figure 3.8). 

49 

 
 
 
 
Figure 3.8 

The  classification  of 

the  ecological  status  or  potential  of  rivers 

in 

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

Specific Pollutants. 

Source: WISE electronic reporting 

50 

 
 
 
 
 
Figure 3.9 

Basis  of  the  classification  of  ecological  status/potential  in  Luxembourg. 

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

Source: WISE electronic reporting.  Luxembourg subsequently noted that there was no 

monitoring for “other aquatic flora” and this was reported by mistake, “Transparency conditions” and 

“Hydrological regime” were monitored but not used, 

Assessment methods and classification of biological quality elements 

Reference  conditions  were  reported  not  to  have  been  established  for  any  river  type  in 
Luxembourg  for  hydromorphological  quality  elements28.  Reference  conditions  have  been 
established  for  all  general  physicochemical  quality  elements  for  all  river  types.  In  terms  of 
biological quality elements, there are reference conditions for all elements in all six river types, 

and  for  some  elements  for  one  type  that  has  not  been  given  a  national  code.  There  is  also 
double reporting of one type (VI): a common intercalibration type has been reported but also 

"not applicable". 

According  to  the  reporting  in  WISE,  there  is  still  one  gap  in  the  biological  quality  elements 

monitored: fish in rivers in the Meuse RBD. However Luxembourg subsequently clarified that 

28   Luxembourg subsequently explained that the morphological parameters were assessed by applying a German 
methodology  that  compares  the  gap  to  the  reference  conditions  of  each  German  LAWA  type.  As  every 
Luxemburgish  river  type  is  related  to  its  corresponding  LAWA  type,  Luxembourg  did  apply  the  LAWA 
reference conditions for each of its river types. 

51 

 
 
 
                                                      
this was a  reporting  error and that fish are monitored and assessed in  two of the three water 

bodies  of  the  Meuse  RBD.  None  of  the  water  bodies  included  in  surveillance  monitoring  in 
both RBDs was reported to be monitored for all required hydromorphological quality elements. 

Luxembourg subsequently clarified that this was also a reporting error and that all water bodies 
included in surveillance monitoring had been monitored for the required hydromorphological 

quality elements. 

One reported assessment method is relevant for phytoplankton in lakes. This is related to  the 

one  river  water  body  that  is  a  reservoir  and  is  therefore  monitored  and  assessed  as  a  lake. 
Methods for the assessment of all relevant biological quality elements have been reported for 

rivers and are reported to be sensitive to all possible impacts. 

Intercalibration of biological assessment methods  

Only 3 % of river water bodies did not have an equivalent common intercalibration type. The 

river types were intercalibrated against four common intercalibration types. 

Assessment methods for hydromorphological quality elements 

Only two of the three required hydromorphological quality elements were assessed in terms of 
ecological  status  and  potential,  hydrological  regime  was  not.  The  assessment  of  river 

continuity was reported to be related to the class boundaries for the sensitive biological quality 
elements whereas for morphological conditions it was not. 

The  supporting  quality  elements  of  morphology  and  continuity  were  classified  for  all  water 
bodies  on  the  basis  of  a  German  assessment  method  (LAWA-guideline).  The  hydrology  has 

not been classified, as the assessment method did not cover this aspect. 

The  evaluation  of  the  hydromorphological  status  was  based  on  a  detailed  structural  quality 

survey of all water bodies, which was not available for the first RBMP; a comparison with the 
first RBMP is therefore not possible. 

Assessment methods for general physicochemical quality elements 

Luxembourg reported that all the relevant supportive general physicochemical quality elements 
in  rivers  have  been  assessed  in  terms  of  ecological  status/potential  and  the  classification 

boundaries are related to the class boundaries for the sensitive biological quality elements. 
Standards have been set for all relevant general physicochemical quality elements in rivers and 

are reported to be consistent with the good-moderate status boundary of the relevant sensitive 
biological quality elements.  

52 

 
 
 
The  RBMP  indicates  that  Environmental  Quality  Standards  for  the  general  physicochemical 

parameters were used to adjust the specific reference conditions for the second RBMP, and the 
worst case classification for these quality elements was used in combination with the biological 

quality elements to determine ecological status/potential. 

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

The  RBMP  indicates  that  River  Basin  Specific  Pollutants  were  selected  from  the  list  of 

substances  listed  in  Appendix  I  of  the  Grand-Ducal  Regulation  of  28  February  2003, 
depending on their relevance. The environmental quality standards have been set based on an 

analysis of the Directives in force. In case of divergence between the regulatory provisions, it 
is the most stringent quality objectives that have been retained.29  

Environmental Quality Standards have been set for 54 River Basin Specific Pollutants in water 
for rivers: none was derived in accordance with the Technical Guidance Document No 2730 . 
For  35  substances  the  analytical  method  used  meets  the  minimum  performance  criteria  laid 
down in Article 4.1 of the QA/QC Directive (2009/90/EC31) for the strictest standard applied. 
For  the  remaining  19  substances  the  analytical  method  complies  with  the  requirements  laid 

down in Article 4.2 of the same Directive for the strictest standard applied. 

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

Luxembourg  reported  that  the  ‘one‐out,  all‐out’  principle  has  been  applied  in  deriving  the 

overall classification of the ecological status/potential of a water body in both RBDs. 

3.2  Main changes in implementation and compliance since the first RBMP 

There are differences in  the numbers of monitoring sites reported to WISE and that obtained 
from the published first RBMP. Using the most recent data for the first RBMP, it seems that 

there has been a large increase in the number of operational sites in the Rhine RBD, from 99 in 
the first RBMP to 215 in the second.32 The number of operational sites (3) for the other RBD 
(Meuse) was the same for both RBMP. In terms of surveillance sites, the only difference from 

29   Luxembourg subsequently  explained that the  list of River  Basin  Specific Pollutants and the associated limit 
values  were  revised  during  2015.  The  Grand-Ducal  Regulation  which  will  make  this  new  list  binding  was 
published  in  January  2016.  This  revision  is  based  above  all  on  new  knowledge  on  the  presence  of  various 
polluting substances in Luxembourg's rivers. An intense exchange with France has also taken place on the list 
of River Basin Specific Pollutants. The revised list of specific pollutants and associated new quality standards 
will form the basis of the assessment of surface water bodies for the next RBMPs. 

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

WFD%2027%20EC%202011.pdf  

31   http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:201:0036:0038:EN:PDF 
32   Luxembourg subsequently stated that for the first RBMP more stations were monitored, however they were 

not reported as some of them were not WFD compliant.   

53 

 
 
                                                      
the first to the second RBMP was a decrease in the Rhine RBD, from four for the first RBMP 

to three for the second.  

Overall the assessment is based on more complete data sets, i.e. more complete sets of quality 

elements  and  results  for  a  larger  number  of  water  bodies.  For  example,  assessments  for 
phytobenthos and macrophytes were available for 98 % of surface water bodies for the second 

RBMP, whereas for the first RBMP 47 % of surface water bodies were assessed on the basis of 
macrophytes alone and 49 % on the basis of diatoms; fish were reported to be assessed in 41 % 

of surface water bodies for the second RBMP, compared with 14 % for the first RBMP. 

3.3  Progress with Commission recommendations 

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

requested action on the following: 

  Recommendation: The assessment methods for ecological and chemical status need to 
be further developed, in particular for the hydromorphological quality elements. Some 

biological quality elements still need to be adapted to the Decision on Intercalibration. 

Assessment: The biological quality element  “fish” and the supporting quality element 

'hydrological regime' were not classified for the majority of water bodies. A biological 
assessment method for fish is in place; therefore it is unclear why Luxembourg did not 
classify  more  water  bodies  using  this  biological  quality  element33.  An  assessment 
method for the hydrological regime was not available34. No information is available on 
the status of intercalibrated biological quality elements for Luxembourg35. 

Based on this information it is considered that this recommendation has been partially 
fulfilled36. 

  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 

33   Luxembourg subsequently stated that a new method is being developed and will be intercalibrated for 2020. 
The monitoring of fish was extended for the 2nd RBMPs and more monitoring results will be available for the 
next RBMPs. 

34   Luxembourg subsequently stated that a methodology for hydrological regime has been established and will be 

used for the next RBMPs 

35   Luxembourg subsequently stated that all biological quality elements have been intercalibrated.  
36   Luxembourg subsequently stated that all biological quality elements have now been intercalibrated and are 
included in the 2018 Intercalibration Decision. The monitoring of fish was extended for the 2nd RBMP and 
more monitoring results will be available for the next RBMP. 

54 

 
 
                                                      
have been taken into account in the assessment of ecological status. It is important that 

there  is  an  ambitious  approach  to  combatting  chemical  pollution  and  that  adequate 
measures are put in place.  

Assessment:  The  RBMP  provide  information  on  how  River  Basin  Specific  Pollutants 
have been selected.  Environmental Quality Standards have been derived for 54 River 

Basin  Specific  Pollutants  in  water  (only)  for  the  second  RBMP,  but  none  of  the 
standards  was  derived  in  accordance  with  the  Technical  Guidance  Document  No  27.  

For 35 substances the analytical method used meets the minimum performance criteria 
laid down in Article 4.1 of the QA/QC Directive (2009/90/EC) for the strictest standard 

applied  and  for  the  remaining  19  substances  it  complies  with  the  requirements  laid 
down in Article 4.2. 

Detailed  information  has  been  reported  on  the  River  Basin  Specific  Pollutants 
monitored  in  water  with  their  respective  sampling  frequencies.  However,  whereas  all 

pollutants  were  monitored  at  least  at  the  minimum  recommended  frequency  for 
surveillance  monitoring  at  all  sites  where  they  are  monitored,  for  operational 
monitoring none of the sites for all pollutants were reported to be sampled at least at the 

minimum  frequency.  However  Luxembourg  subsequently  informed  the  Commission 
that there were errors in the reporting and that some of the sites were monitored at the 

minimum recommended frequency. In addition, there is conflicting information on the 
number  of  sites  monitoring  River  Basin  Specific  Pollutants  with  far  fewer  being 

reported  at  the  specific  substance  level  than  at  the  generic  quality  element  level: 
Luxembourg subsequently clarified that this is a reporting error. 

Zinc  and  copper  were  reported  to  be  causing  the  failure  to  achieve  good  ecological 
status/potential  in  11  and  six  river  water  bodies,  respectively.  The  one-out,  all-out 

principle  has  been  applied  in  the  classification  based  on  River  Basin  Specific 
Pollutants. 

Based on this information it is considered that this recommendation has been partially 
fulfilled. 

  Recommendation:  Close  the  remaining  gaps  in  monitoring  networks  and  assessment 
methodologies as regards ecological status or surface water, chemical status of surface 

and groundwaters and quantitative status of groundwaters. 

Assessment: In terms of biological quality elements, the same elements monitored for 

the first RBMP were reported to be monitored for the second RBMP. Fish in rivers was 

55 

 
 
still reported as not being monitored in the Meuse RBD, but Luxembourg subsequently 

clarified that  this  was  a  reporting error and two  water bodies had been  monitored for 
fish in the Meuse. 

For the second RBMP, river continuity and morphological conditions were reported not 
to be monitored but Luxembourg subsequently clarified that morphological conditions 

and  river  continuity  were  monitored  and  evaluated  for  every  water  body,  while 
hydrological regime was not evaluated in the second RBMP. 

In conclusion, there has been progress in this aspect and the recommendation has been 
partially fulfilled.  

  Recommendation (partial): Enhance measures to tackle pollution by nutrients (nitrogen 
and  phosphorus)  considering  their  impact  on  ecological  status.  Full  consideration  of 

the  basin-wide  impact  is  needed  in  this  respect  (local  and  downstream  up  to 
transitional  and  coastal  waters).  To  this  extent  Luxembourg  should  check  that  their 

nutrient  standards  are  consistent  with  biological  requirements  for  the  achievement  of 
good status and provide a more coherent strategy encompassing WFD with the Nitrates 

Directive and Common Agricultural Policy in agriculture. 

Assessment: The nutrient threshold defined for nitrate (25 mg/l) may be considered as 

too relaxed to support the achievement of good ecological status/potential. However, it 
this  supposition.  Luxembourg 
would  require  additional  analysis 

to  confirm 

subsequently stated that a study from 2015 relating nitrate, phosphorous and biological 
parameters  found  the  threshold  to  be  accurate  for  good  ecological  status,  but  that  a 

more  substantial  study  taking  into  consideration  other  parameters  will  be  launched  in 
2018. 

In  conclusion,  there  are  still  questions  concerning  the  adequateness  of  the  threshold 
used  by  Luxembourg  and  at  this  stage  it  cannot  be  concluded  whether  or  not  the 

recommendation has been fulfilled. 

56 

 
 
 
 
Topic 4

  Monitoring,  assessment  and  classification  of  chemical 

status in surface water bodies 

4.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle  

4.1.1

 Monitoring of chemical status in surface waters 

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

Member  States  have  to  implement  surveillance  and  operational  monitoring  programmes  in 

accordance with the requirements of the WFD and of the EQS Directive for the assessment of 
ecological status/potential and chemical status.  

Surveillance monitoring programmes should allow Member States to supplement and validate 
the  impact  assessment  procedure,  to  efficiently  and  effectively  review  the  design  of  their 

monitoring programmes, and to  assess the long-term  changes in  natural  conditions  and those 
resulting  from  widespread  anthropogenic  activity.  For  operational  purposes,  monitoring  is 
required to establish the status of waterbodies identified as being at risk of failing to meet their 

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

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

Figure  4.1  summarises  the  proportion  of  sites  used  for  the  monitoring  of  chemical  status  in 
rivers  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  Agency37.    Figure  4.1  shows  that  only  a  very  small 
proportion  of  the  total  number  of  monitoring  sites  (3  %)  are  used  for  monitoring  chemical 
status  whereas  43  %  of  all  monitoring  sites  are  used  for  monitoring  ecological  status. 

Luxembourg subsequently clarified that they only reported to WISE the sites where all priority 
substances have been monitored. Monitoring has been carried out also at other sites, either only 

for  some  of  the  priority  substances,  or  at  a  frequency  not  in  line  with  the  provisions  of  the 
WFD. These other sites haven’t been reported to WISE, although the monitoring results were 

used to assess chemical status. 

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

57 

 
 
                                                      
Figure 4.1 

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

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

their purpose 

Source: WISE electronic reporting 

A  total  of  13  out  of  110  river  water  bodies  are  reported  to  be  monitored  for  chemical  status 
across the two RDBs in Luxembourg (12 in the Rhine RBD and one in the Meuse RBD). 

Figure 4.2 summarises the proportion of water bodies monitored for chemical status rivers for 
the second RBMP. For the purposes of this figure, no distinction is made between sites used 

for  surveillance  and/or  operational  purposes.  The  graph  shows  also  the  proportion  of  water 
bodies monitored for any purpose and those for ecological status.  

58 

 
 
 
Figure 4.2 

Proportion  of  water  bodies  used  for  monitoring  of  chemical  status  and,  for 

comparison,  ecological  status,  in  Luxembourg.  The  number  in  parenthesis 
next  to  the  category  is  the  total  number  of  water  bodies  irrespective  of  their 

purpose 

Source: WISE electronic reporting 

12 % of water bodies failing to achieve good chemical status were reported to be monitored in 

Luxembourg as a whole. More explicit, the percentage of water bodies failing to achieve good 
chemical  status  being  monitored  are  11  %  in  the  Rhine  RBD  and  33  %  in  the  Meuse  RBD 

respectively.  

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

Monitoring for status assessment 

Requirements 

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

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

of sites should be sufficient to obtain a reliable and robust assessment of status. According to 
in  2009),  mercury,  hexachlorobenzene  and 
the  EQS  Directive 

(version 

force 

in 

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.  

59 

 
 
 
Spatial Coverage 

All 41 Priority Substances that are used in the classification of chemical status are all reported 
to be monitored. According to the data reported, 89 % and 67 % of water bodies (all rivers) in 

Luxembourg (the Rhine and Meuse RBDs respectively), were not monitored for the whole list 
of  Priority  Substances  but  the  remainder  were  monitored  for  all  of  the  Priority  Substances.  

Luxembourg  subsequently  clarified  that  metals  and  PAH  were  monitored  in  the  89  %  of 
waterbodies  identified  above,  but  the  information  was  not  reported  because  the  monitoring 

frequencies were not in line with the frequencies in the WFD. 

The initial assessment shows that no information was reported to WISE on the monitoring of 

sediments  or  biota.  The  RBMP  confirms  that  monitoring  has  only  been  carried  out  in  water 
samples (except at one monitoring station where suspended solids are also analysed).  

The  RBMP  indicates  that  Luxembourg  has  derived  alternative  standards  for  mercury, 
hexachlorobenzene  and  hexachlorobutadiene  in  water  for  use  in  the  assessment  of  chemical 

status and monitors for these substances in water. A new analytical method has been applied to 
mercury  from  2014  (for  water  samples)  with  a  much  lower  limit  of  detection  and  therefore 
only a small number of mercury results are considered to be reliable to use in the assessment of 

chemical status.  

Luxembourg subsequently clarified that analysis of biota and sediments started in 2016 and the 

results will be presented in the next RBMP. 

In terms of transnational monitoring, Priority  Substances are monitored at least at one site in 

each international RBD in collaboration with the relevant international body. 

Frequencies 

The WFD indicates that, for the surveillance and operational monitoring of Priority Substances 
in water, the frequency of monitoring should be at least monthly for one year during the RBMP 
cycle and at least monthly every year, respectively. Monitoring in biota for status assessment 
should take place at least once every year according to the EQS Directive. In all cases greater 

intervals can be applied by Member States if justified on the basis of technical knowledge and 
expert judgement. 

Monitoring  frequencies  are  reported  for  41  Priority  Substances  at  the  site  level  in  both 
Luxembourg  RBDs.  All  substances  were  monitored  13  times  per  year  in  both  RBDs  for  a 
period of at least one year which fulfils the minimum requirements for surveillance monitoring. 

60 

 
 
For operational monitoring, the frequencies of monitoring in the Rhine RBD do not meet the 

minimum  recommended  frequency  as  described  in  the  WFD.  For  the  Meuse  RBD,  the 
frequency  of  operational  monitoring  is  in  accordance  with  the  minimum  recommended 

frequency of the WFD. 

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  substances38  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 information was provided via WISE for either RBD on the arrangements for the long-term 
trend analysis of concentrations of those Priority Substances listed in Part A of Annex I of the 

EQS Directive that tend to accumulate in sediment and/or biota (Article 3(3) EQS Directive). 

Some  information  can  however  be  found  in  the  RBMP:  the  RBMP  indicates  that  the 
monitoring  of  suspended  sediment  at  one  location  (Wasserbillig  /  Sûre)  at  the  downstream 

extent  of  the  river  network  in  Luxembourg  is  used  for  trend  assessment.  Monitoring  at  this 
station  is  part  of  a  coordinated  international  programme  as  part  of  the  International 

Commissions for the Protection of Moselle and Saar and the data contributes a long-term data 
series. Luxembourg subsequently clarified that monitoring of sediments commenced in 2016 at 

all  four  surveillance  monitoring  sites  (used  for  the  assessment  of  the  chemical  status)  and 
additionally 13 operational monitoring sites and will be reported in the next RBMP.  

Frequency 

Monitoring of suspended sediment is reported to be undertaken 12 times per year. Luxembourg 

subsequently clarified that for the sediment monitoring that commenced in 2016, the frequency 
for monitoring at surveillance monitoring sites (for status assessment) is every year and that for 

operational monitoring is every three years. 

38   Anthracene,  brominated  diphenylether, 

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

chloroalkanes,  DEHP, 

cadmium,  C10-13 

61 

 
 
                                                      
 
Monitoring of Priority Substances that are discharged in each RBD  

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

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

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

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

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

quantities.” 

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

into the river basin or sub-basin.  

In  Luxembourg,  41  Priority  substances  and  groups  of  priority  substances  are  reported  to  be 
included in the inventories of emissions in both RBDs and all are reported to be monitored.  

Performance of analytical methods used 

For  29  Priority  Substances,  Luxembourg  reported  that  the  analytical  methods  used  meet  the 
minimum  performance  criteria  laid  down  in  Article  4(1)  of  the  Technical  specifications  for 
chemical  analysis and monitoring of water status39, the strictest  standard are applied. For the 
remaining  12  Priority  Substances  reported,  the  analytical  methods  complied  with  the 

requirements  laid  down  in  Article  4(2)  of  the  Technical  specifications  for  chemical  analysis 
and monitoring of water status for the strictest standard applied.  

The  RBMP  indicates  that  some  issues  remain  with  the  analytical  methods  for  mercury, 
hexachlorobenzene  and  hexachlorobutadiene  in  terms  of  achieving  a  suitable  limit  of 

quantification  in  relation  to  the  alternative  environmental  quality  standards  in  water  used  for 
status assessment. 

The  method  of  dealing  with  measurements  of  Priority  Substances  lower  than  the  limit  of 
quantification is as specified in Article 5 of the Technical specifications for chemical analysis 

and monitoring of water status. 

39   Directive 2009/90/EC of 31 July 2009 laying down, pursuant to Directive 2000/60/EC of the European 

Parliament and of the Council, technical specifications for chemical analysis and monitoring of water status 
http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1524565750309&uri=CELEX:32009L0090  

62 

 
 
                                                      
 
4.1.2

 Chemical Status of surface water bodies 

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

this may be the year in which monitoring took place in the surface water bodies within a group 
that  are  used  to  extrapolate  results  to  non-monitored  surface  water  bodies  within  the  same 

group.  In  Luxembourg,  the  chemical  assessments  were  carried  out  in  specified  years  in  the 
period from 2011 to 2014 in the Meuse RBD. However, in the Rhine RBD, 41 % and 6 % of 

chemical  assessments  were  carried  out  in  2014  and  2013,  respectively  with  the  remainder 
being carried between 2011 and 2014. The one-out-all-out principle has been applied. 

The chemical status of surface water bodies in Luxembourg for the second RBMP is illustrated 
in  Map  4.1.  This  is  based  on  the  most  recent  assessment  of  status.  All  water  bodies  are 

classified as “failing to achieve good status”. 

Map 4.1 

Chemical  status  of  surface  water  bodies  in  Luxembourg  based  on  the  most 

recently assessed status of the surface water bodies  

63 

01020kmLU000LU001LUGoodFailing to achieve to goodUnknownRiver Basin DistrictsCountries outside the EU 
 
 
 
 
 
 
The chemical status of rivers in Luxembourg for the first and second RBMP is given in Table 

4.1.  

Overall in Luxembourg between the two cycles, there was a large decrease in the proportion of 

surface water bodies with good chemical status from 70 to 0 % and a significant increase in the 
proportion failing  to  achieve  good status  from  30 to  100 %. With regards to  the basis of the 

classification of chemical status, monitoring underpinned the classifications of 11 and 33 % of 
river water bodies in the Rhine and Meuse RBDs, respectively, with the remainder classified 

by expert judgement. 

Table 4.1 

Chemical  status  of  surface  water  bodies  in  Luxembourg  for  the  second  and 

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

standards  laid  down  in  the  EQS  Directive.  All  water  bodies  are  assessed  as 
failing  to  achieve  good  chemical  status  in  the  second  RBMP,  whether  the 

2008  or  the  2013  environmental  quality  standards  are  used.  Some  Member 
States did not implement the Directive in the first RBMP as the transposition 
deadline was in July 2010, after the adoption of the first RBMP 

Category 

Good 

Number 

2nd RBMP  Rivers (110) 
1st RBMP 
Rivers (102) 

0 

71 

Failing to achieve 
good 

Unknown 

% 

0 

70 % 

Number 

% 

Number 

110 

31 

100 % 

30 % 

0 

0 

% 

0 

0 

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

Overall 12 % of surface water bodies in Luxembourg were classified for chemical status with 
high  confidence  and  88  %  of  surface  water  bodies  were  classified  with  low  confidence. 

Luxembourg subsequently clarified that high confidence was assigned where monitoring for all 
Priority  Substances  was  undertaken  and  low  confidence  where  this  was  not  the  case. 

Confidence in the classification of chemical status for the first RBMP was not reported. 

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

cycle with that for the second RBMP (based on the most recent assessment of status) and that 
expected by 2015. As stated above, a 70 % increase in the proportion of water bodies failing to 

achieve good status was observed, and all water bodies were expected to be classified as such 
in 2015. 

64 

 
 
 
Luxembourg based the assessment of chemical status for the second RBMP on the standards 
laid down in EQS Directive (version in force on 13 January 200940). An assessment using the 
EQS defined in Directive 2013/39/EU was also done in order to be able to identify changes in 

the status assessment which are related to the more stringent EQS fixed by the new Directive.  
Some Member States did not implement the Directive in the first RBMP as the transposition 

deadline  was  in  July  2010,  after  the  adoption  of  the  first  RBMP.  More  information  on  the 
chemical status in each RBD and water category can be found on the website of the European 
Environment Agency.41 

Directive  2013/39/EU  amended  the  EQS  Directive.  In  particular,  it  sets  more  stringent 
environmental  quality  standards  for  seven  substances42.  Member  States  were  required  to 
indicate  if  the  new  standards  caused  the  status  of  the  surface  water  body  to  appear  to 

deteriorate.  In  Luxembourg  as a whole, this was the case  for 100 % of  river water bodies in 
terms of fluoranthene and benzo(a)pyrene.  

Good  chemical  status  should  be  reached  by  2021  in  relation  to  the  revised  environmental 
quality standards, unless Member States apply exemptions under WFD Article 4(4) and/or less 
stringent objectives under WFD Article 4(5).As such, Member States were asked to report the 

expected  date  for  the  achievement  of  good  chemical  status.  Good  chemical  status  of  surface 
water bodies is expected to be achieved by the end of the 3rd cycle for all river water bodies in 
Luxembourg. 

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

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

compounds, Polyaromatic hydrocarbons (PAH) 

65 

 
 
 
                                                      
Figure 4.3 

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

Luxembourg based on the most recently assessed status 

s
B
W
S
f
o
e
g
a
t
n
e
c
r
e
P

120%

100%

80%

60%

40%

20%

0%

No information

High

Medium

Low

Good

Failing to achieve
good

Chemical status 

Unknown

Source: WISE electronic reporting 

Figure 4.4 

Chemical  status  of  surface  water  bodies  in  Luxembourg  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  2011  to  2014. 

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

Source: WISE electronic reporting 

66 

 
 
 
 
 
 
 
 
 
Figure 4.5 

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

Luxembourg. The number in the parenthesis is the number of water bodies  

Source: WISE electronic reporting 

Priority substances causing the failure of good chemical status 

Information reported to WISE indicates that  the substances causing water bodies to fail good 
total 
chemical  status  were: 

isoproturon,  fluoranthene,  benzo(a)pyrene,  mercury  and 

benzo(g,h,i)-perylene  + 
indeno(1,2,3-cd)-pyrene.  However,  Luxembourg  subsequently 
clarified that mercury did not contribute to the failure of good status in any water body for the 

second RBMP (mercury was only monitored in  water and the water EQS was not  exceeded) 
but that they expect the relevant biota environmental quality standard will be exceeded in the 

future and included this in  the WISE reporting to highlight  this. With regard to  fluoranthene 
and benzo(a)pyrene, these two substances are only causing water bodies to fail good status if 

the revised EQS from Directive 2013/39/EU are applied.  

The RBMP confirms that widespread failure to achieve good status in all river water bodies in 

Luxembourg is driven mainly by the presence of Polycyclic Aromatic Hydrocarbons (PAHs). 
The environmental quality standard benzo(g,h,i)-perylene + indeno(1,2,3-cd)-pyrene  as listed 

in Directive 2008/105/EC was exceeded in the headwaters of small rivers in rural areas. Given 
the widespread diffuse inputs of PAHs, the classification of failing to achieve good status was 

extrapolated  by  expert  judgement  to  all  river  water  bodies  in  Luxembourg.  The  RBMP  also 
confirms  that  isoproturon  exceeded  the  environmental  quality  standard  in  Directive 
2008/105/EC  at  two  monitoring  sites  and,  given  the  diffuse  nature  of  the  sources  of  this 

67 

 
 
 
substance,  all  11  river  water  bodies  downstream  of  these  sites  were  classified  as  failing  to 

achieve good status.  

Figure 4.6 summarises the Priority Substances causing failure to achieve good status.  

Figure 4.6 

Priority Substances causing failure to achieve good chemical status in surface 
water  bodies  in  Luxembourg  (according  to  Directive  2008/105/EC  for  total 

benzo(g,h,i)-perylene  +  indeno(1,2,3-cd)-pyrene  and  isoproturon  and  to 
Directive 2013/39/EU for benzo(a)pyrene and fluoranthene ). 

Source: WISE electronic reporting 

For  the  surface  water  bodies  in  the  Luxembourg,  exceedances  were  for  the  annual  average 
Environmental  Quality  Standard  for  fluoranthene  and,  benzo(a)pyrene,  (but  only  when 

applying  the  revised  environmental  quality  standard  from  Directive  2013/39/EU)  and  total 
benzo(g,h,i)-perylene  +  indeno(1,2,3-cd)-pyrene;  all  had  100  %  exceedance.  Exceedances  of 

maximum  allowable  concentration  Environmental  Quality  Standard  were 
isoproturon (10 %).  

largest  for 

Ubiquitous persistent, bioaccumulative and toxic Priority Substances 

According  to  article  8(a)  of  the  EQS  Directive43,  eight  priority  substances  and  groups  of 
priority  substances  are  behaving  like  ubiquitous,  persistent,  bioaccumulative  and  toxic 
substances44.  These  substances  are  generally  expected  to  cause  widespread  exceedances,  and 

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

PFOS, dioxins, hexabromocyclodecane and heptachlor 

68 

 
 
 
 
                                                      
their emissions can be challenging to tackle (e.g. due to long-range atmospheric transport and 

deposition). In order to show the progress made in tackling other priority substances, Member 
States have the possibility to present the information related to chemical status separately for 

these  substances.  In  the  RBMP,  Luxembourg  reports  the  influence  of  ubiquitous,  persistent, 
bioaccumulative and toxic substances on chemical status in two way; when chemical status is 

determined on the basis of the environmental quality standards in Directive 2008/105/EC and 
when  it  is  determined  on  the  basis  of  those  in  Directive  2013/39/EU.    More  details  are 
presented in the 2018 State of Water report of the European Environment Agency45. 

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

All 41 Priority Substances that are used in the classification of chemical status are reported to 

be monitored in both RBDs. 

Monitoring  was  used  for  classification  of  11  %  and  33  %  of  water  bodies  in  the  Rhine  and 

Meuse RBDs respectively, with the remainder classified by expert judgement. A statement is 
also made by Luxembourg that the status of surface water bodies not monitored for chemical 
status has been derived or extrapolated from monitoring available for comparable water bodies. 

This  has  included  assessments  of  results  from  profiles  for  several  pollutants  along  selected 
river stretches or other investigative monitoring programmes. 

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. 

Luxembourg reported that all of the Environmental Quality Standards laid down in Part A of 

Annex  I  of  the  Directive  2008/105/EC  for  assessment  of  the  chemical  status  of  bodies  of 
surface water had been applied. Alternative and/or additional standards for particular Priority 

Substances had not been applied. Moreover, it is clear from the RBMP that both the standards 
in  Directive  2008/105/EC  and  those  in  Directive  2013/39/EU  have  been  used  in  different 

representations of chemical status. 

45   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 

69 

 
 
                                                      
Use of mixing zones  

Article 4 of Directive 2008/105/EC13 provides Member States with  the option of designating 
mixing  zones  adjacent  to  points  of  discharge.  Concentrations  of  substances  may  exceed  the 
relevant  environmental  quality  standard  within  such  mixing  zones  if  they  do  not  affect  the 

compliance of the rest of the body of surface water with those standards. Member States that 
designate  mixing  zones  are  required  to  include  within  their  RBMP  a  description  of:  the 

approaches and methodologies applied to define such zones, and; measures taken with a view 
to reducing the extent of the mixing zones in the future. 

Mixing zones have not been designated in Luxembourg. 

Background Concentrations and Bioavailability 

EC  Directives  2008/105/EU  and  2013/39/EU  stipulate  that  Member  States  may  (i.e.  treat  as 

optional), when assessing the monitoring results against the EQS, take into account: 

(a)  natural  background  concentrations  for  metals  and  their  compounds,  if  they  prevent 

compliance with the EQS value, and; 

(b) hardness, pH or other water quality parameters that affect the bioavailability of metals. 

Luxembourg reported that neither natural background concentration nor parameters that affect 

bioavailability  had  been  taken  into  consideration  in  the  second  RBMP.  Luxembourg 
subsequently clarified that work is underway with regard to these issues and will be reported in 

the next RBMP. 

4.2  Main changes in implementation and compliance since the first cycle 

In  the  second  cycle,  all  110  surface  water  bodies  were  classified  as  “failing  to  achieve  good 
chemical  status”,  compared  to  the  first  cycle  where  70  %  were  classified  as  “good  chemical 

status”  and  30  %  as  “failing  to  achieve  good  status”.  The  reason  for  the  change  has  been 
attributed to the expansion of the monitoring programme leading to more widespread failure of 
the  Environmental  Quality  Standard  for  polycyclic  aromatic  hydrocarbons46  (from  diffuse 
sources, mainly atmospheric deposition) and the extrapolation of this result to all surface water 

bodies.  Without  polycyclic  aromatic  hydrocarbons,  the  second  cycle  chemical  status 
assessment  would  have  resulted  in  90  %  “good  status”  and  10  %  “failing  to  achieve  good 

status” in 2015 based on the environmental quality standards in Directive 2008/105/EC. 

46 Specifically for total benzo(g,h,i)-perylene + indeno(1,2,3-cd)-pyrene. 

70 

 
 
                                                      
Furthermore,  on  the  basis  of  the  amended  EQS  Directive,  all  surface  water  bodies  were 

classified  as  “failing  to  achieve  good  status”  because  the  stricter  Environmental  Quality 
Standard for benzo(a)pyrene (used as a marker for the group of five listed polycyclic aromatic 

hydrocarbons) was widely exceeded, as well as the stricter Environmental Quality Standard for 
fluoranthene. It is also stated that all surface water bodies would still be classified as “failing to 

achieve  good  chemical  status”  without  using  the  benzo(a)pyrene  standard,  because  of  the 
presence of fluoranthene. 

Luxembourg  provided  some  further  clarification  to  corroborate  the  statements  above. 
Investigative monitoring undertaken during the first cycle confirmed the widespread presence 

of polycyclic aromatic hydrocarbons in small tributaries and associated these with “Diffuse  – 
atmospheric deposition” pressures rather than point source discharges.  

In  addition  to  changes  to  the  monitoring  programmes  for  chemical  status  mentioned  above, 
minor changes were made in the selection of monitoring sites to better represent  catchments, 

and  three  additional  Priority  Substances  were  added  to  a  suspended  solids  monitoring 
programme for the Rhine RBD. The RBMP provide details  of Priority Substances, including 
details of monitoring sites and sampling frequencies. Operational monitoring has been revised, 

locating at least one operational monitoring site on each water body with targeted monitoring 
to  gain  more  reliable  profiles  along  river  stretches  and  to  ensure  more  certainty  in  the  risk 

analyses. Investigative monitoring was increased for the second cycle, focusing on polycyclic 
aromatic hydrocarbons and certain metals in order to better understand their sources. 

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, 

examination of the first RBMP showed that diuron (4 %), isoproturon (3 %) and DEHP (3 %) 
in  addition  total  benzo(g,h,i)-perylene  and  indeno(1,2,3-cd)-pyrene  (5  %)  were  causing  the 

greatest failures of Environmental Quality Standards in the two RBDs in Luxembourg at that 
time.  

There  were  no  Priority  Substances  reported  to  have  improved  status  from  failing  to  achieve 
good to good.  

4.3  Progress with Commission recommendations 

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

requested action on the following: 

71 

 
 
  Recommendation: 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.  

Assessment:  While  Luxembourg  monitors  all  Priority  Substances  in  water,  the  spatial 

coverage  of  monitoring  is  limited.  With  regards  to  the  basis  of  the  classification  of 
chemical  status,  monitoring  underpinned  the  classifications  of  11  %  and  33  %  of  river 

water bodies in the Rhine and Meuse RBDs, respectively, with the remainder classified by 
expert judgement. Overall 12 % of surface water bodies in Luxembourg were classified for 

chemical status with high confidence and 88 % of surface water bodies were classified with 
low confidence. Luxembourg subsequently clarified that high confidence was assigned to 

classifications of water bodies where monitoring of all Priority Substances was undertaken 
and  low  confidence  where  this  was  not  the  case.  The  RBMP  indicates  that  further 

monitoring and investigations have also been carried out to gain a better understanding of 
pressures and impacts. This recommendation has therefore been partially addressed. 

  Recommendation: The assessment methods for ecological and chemical status need to be 
further  developed,  in  particular  for  the  hydromorphological  quality  elements.  Some 

biological quality elements still need to be adapted to the Decision on Intercalibration.  

Assessment: Luxembourg monitors all 41 Priority Substances in water but does not report 

monitoring in biota and sediment in the second RBMP. For status assessment, alternative 
standards  for  mercury,  hexachlorobenzene  and  hexachlorobutadiene  in  water  have  been 

derived  and  are  used  in  the  assessment  of  chemical  status.  The  RBMPs  indicates  some 
issues with the analytical methods used to determine concentrations of these substances in 

water  in  relation  to  the  alternative  standards.  For  trend  assessment,  monitoring  of 
suspended  sediment  is  undertaken  at  one  strategic  location  as  part  of  an  international 

programme  and  to  contribute  to  a  long-term  dataset.  Luxembourg  subsequently  clarified 
that  sediment  monitoring  has  commenced  in  2016  and  the  results  will  be  reported  in  the 
next RBMP. With respect to chemical status, all surface water bodies have been classified 
and  a  combination  of  extrapolation  from  monitored  sites  and  expert  judgement  has  been 

used.  Luxembourg  thoroughly  considered  the  environmental  quality  standards  in  both 
versions of the Environmental Quality Standard Directive in their assessment of chemical 

status.  The  RBMP  indicates  that  further  monitoring  and  investigations  have  been  carried 
out  in  an  attempt  to  reduce  uncertainty  and  to  link  pressures  and  impacts.  Progress  has 

therefore been made with addressing this recommendation.  

72 

 
 
  Recommendation:  More information on the monitoring of  Priority Substances, specifying 
for more sites which substances have been monitored and which have caused failure, will 
be expected in the next RBMP.  

Assessment: All 41 Priority Substances that are used in the classification of chemical status 
are monitored in both RBDs. The monitoring programme has been expanded but according 

to WISE, still only a small proportion of monitoring sites are used for assessing chemical 
status (3 % of the total number of monitoring sites and a total of 13 out of 110 river water 

bodies  are  reported  to  be  monitored  for  chemical  status  across  the  two  RDBs  in 
Luxembourg– see figures 4.1 and 4.2).  

Luxembourg  subsequently  clarified  that  they  only  reported  to  WISE  the  sites  where  all 
priority  substances  have  been  monitored.  Monitoring  has  been  carried  out  also  at  other 

sites, either only for some of the priority substances, or at a frequency not in line with the 
provisions  of  the  WFD.  These  other  sites  haven’t  been  reported  to  WISE,  although  the 

monitoring results were used to assess chemical status. However, it is not possible to assess 
the extent of this additional monitoring based on the information available. 

Therefore,  based  on  the  information  available,  this  recommendation  has  been  partially 
addressed. 

  Recommendation:  Close  the  remaining  gaps  in  monitoring  networks  and  assessment 
methodologies  as  regards  ecological  status  or  surface  water,  chemical  status  of  surface 

and groundwaters and quantitative status of groundwaters.  

Assessment:  This  recommendation  is  relevant  to  a  number  of  Topics.  Luxembourg  has 

classified  all  surface  water  bodies  with  respect  to  chemical  status  and  has  used 
extrapolation  and  expert  judgement  as  part  of  the  process.  Monitoring  frequencies  are 

reported for 41 Priority Substances at site level in both Luxembourg RBDs and are shown 
to  be in  accordance with the WFD for both  operational  and surveillance  monitoring only 

for  one  RBD.  For  the  other  RBD,  the  operational  monitoring  is  still  not  in  line  with  the 
WFD.  For  more  details  on  the  spatial  extent  of  monitoring,  see  recommendation  above. 

This recommendation has therefore been partially addressed. 

  Recommendation: The requirement for trend monitoring in sediment or biota as specified 
for several substances in Directive 2008/105/European Commission Article 3(3) will also 
need to be reflected in the next RBMP.  

73 

 
 
Assessment:  Luxembourg  confirms  that,  to  date,  monitoring  has  only  been  carried  out  in 

water samples (except at one monitoring station where suspended solids are also analysed). 
Luxembourg also state that monitoring of sediment or biota has started in 2016 and will be 

reported in the next RBMP. Limited progress has therefore been made towards addressing 
this recommendation. 

  Recommendation: Monitor mercury, hexachlorobenzene and hexachlorobutadiene in biota 
for comparison with the biota standards in the EQS Directive, unless water Environmental 

Quality Standards providing an equivalent level of protection are derived. 

Assessment:  For  mercury,  hexachlorobenzene 

and  hexachlorobutadiene  water 

environmental  quality  standards  have  been  derived  and  monitoring  was  done  in  water 
samples. Although no alternative standards have been reported to WISE, alternative water 

standards  have  been  set  in  the  RBMP  for  each  of  these  substances.  These  alternative 
standards  are  lower  than  the  water  standards  provided  in  the  Directive,  and  the  RBMP 

states  they  were  derived  to  be  as  protective  as  the  biota  standards  (this  could  not  be 
checked  during  this  assessment).  Luxembourg  does  not  report  monitoring  in  biota  in  the 

second RBMP. Luxembourg subsequently clarified that monitoring of biota started already 
in 2016 and will be reported in the next RBMP. Subject to the alternative water standards 

being as protective as the biota standards, this recommendation is fulfilled.  

74 

 
 
 
 
 
Topic 5

  Monitoring, assessment and classification of quantitative 

status of groundwater bodies 

5.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle 

5.1.1

 Monitoring of quantitative status in groundwater 

The  total  number  of  groundwater  bodies  in  Luxembourg  is  six  (Table  2.2);  all  in  the  Rhine 

river basin district. One groundwater body is not subject to monitoring for quantitative status 
(Table  5.1).  This  means  that  17  %  of  groundwater  bodies  are  not  monitored.  RBMP  and 

supporting  document  investigations  found  no  indication  that  grouping  has  been  applied.  It  is 
mentioned  that  this  groundwater  body  has  not  been  monitored  because  of  technical  reasons, 

which  prevented  representative  monitoring,  but  the  quantitative  monitoring  network  is 
expected to be expanded in all groundwater bodies. 

The number of groundwater bodies increased by 20 % from five in the first RBMP to six in the 
second  RBMP,  but  the  total  groundwater  body  area  remained  nearly  the  same.  According  to 
the  RBMP  and  supporting  documents,  one  groundwater  body  was  divided  into  two 

groundwater bodies and the remaining four groundwater bodies remained unchanged since the 
first RBMP.  

The number of monitored groundwater bodies increased from four in the first RBMP to five in 
the second RBMP. The number of monitoring sites for quantitative status is listed in Table 5.3. 
There has been a decrease from 30 in the first RBMP to 1747 in the second RBMP. Two48 of 
six groundwater bodies are identified as drinking water protected areas. 

47   Luxembourg subsequently clarified that due to reporting errors the correct number of monitoring sites is 19 for 
the  first  RBMP  and  18  for  the  second  cycle.  The  quantitative  monitoring  station  LU_COC-118-11  was  not 
reported  anymore  because  measurements  were  considered  less  reliant  than  the  continuous  online 
measurements at monitoring station LU_FCE-118-19 (well), which is located in the same catchment area. 
48   Luxembourg clarified that due to a reporting error five and not two of 6 groundwater bodies are drinking water 

protected areas. 

75 

 
 
 
 
                                                      
Table 5.1 

Number of water bodies in Luxembourg directly monitored and the purpose 
of monitoring 

Monitoring Purpose 

RBD 

Total 
ground-
water 
bodies 
directly 
monitored 

CHE - 
Chemical 
status 

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

OPE - 
Operati
onal 
monitor
-ing 

QUA – 
Quantita-
tive status 

LU000 

6 

6 

6 

5 
Source: WISE electronic reporting 

0 

SOE - 
EIONET 
State of 
Environ-
ment 
monitor-
ing 

SUR - 
Surveilla
nce 
monitor-
ing 

TRE - 
Chemical 
trend 
assess-
ment 

0 

6 

3 

Table 5.2 

Proportion of groundwater bodies in Luxembourg monitored for quantitative 
status 

RBD 

LU000 

Number of groundwater 
bodies with quantitative 
monitoring 

Total number 
groundwater bodies 

Percentage of total groundwater bodies 
monitored for quantitative status 

5 

6 

83.33 % 

Source: WISE electronic reporting 

Table 5.3 

Number of groundwater monitoring sites in Luxembourg and their purpose  

RBD 

Total 
ground
water 
monitor
-ing 
sites 

CHE – 
Chemi-
cal 
status 

DRI - 
Groundwater 
abstraction site 
for human 
consumption 

Monitoring Purpose 

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

OPE – 
Opera-
tional 
monito-
ring 

QUA – 
Quanti-
tative 
status 

SOE - 
EIONE
T State 
of 
Environ
-ment 
monitor
-ing 

SUR – 
Surveil
-lance 
monito
-ring 

TRE – 
Chemi-
cal 
trend 
assess-
ment 

LU000 

31 

31 

0 

31 

0 

17 (18) 

0 

31 

24 

Source: WISE electronic reporting. The numbers in brackets were subsequently provided by Luxembourg and do 
not match the data reported to WISE. 

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  all  six  groundwater  bodies  (100  %)  were  of  good  quantitative  status  (Figure  5.1) 

and  they  were  already  in  good  status  in  the  first  RBMP.  Figure  5.2  shows  the  confidence  in 
status classification, which is of medium and high level. All groundwater bodies had, and still 

have,  a  clear  status,  in  the  first  and  in  the  second  RBMPs.  According  to  the  RBMP  and 
supporting  documents,  in  the  groundwater  body  where  no  quantitative  monitoring  data  were 

available, the quantitative status was based on risk assessment from abstraction data only. 

76 

 
 
 
 
 
 
In  Luxembourg,  water  balance  was  assessed  by  using  reliable  information  on  groundwater 

levels across the groundwater body. 

The  criterion  of  ‘available  groundwater  resource’  has  not  been  applied  in  accordance  with 
WFD  Article  2(27)49.  From  all  environmental  objectives,  only  water  balance  has  been 
considered  in  the  status  assessment.  There  is  no  groundwater  body  at  risk  of  failing  good 

quantitative status.  

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) 

49   Luxembourg  subsequently  clarified  that  for  the  groundwater  bodies  “Unterer  Lias”  (numerical)  and  “Trias 
Nord”  conceptual  models  have  been  established  to  calculate  the  annual  average  rate  of  overall  recharge  of 
groundwater.  Currently,  in  these  two  groundwater  bodies,  where  the  most  significant  relation  to  associated 
surface bodies occurs, studies are ongoing to estimate the long-term annual rate of flow required to achieve the 
ecological quality objectives. 

77 

01020kmLU000LU001LUGoodPoorUnknownRiver Basin DistrictsCountries outside the EU 
 
 
 
 
                                                      
Figure 5.1  Quantitative  status  of  groundwater  bodies  in  Luxembourg  for  the  second 

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

assessment of status for the second RBMP was 2010 to 2014. 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 Luxembourg based on the most recent assessment of status  

Source: WISE electronic reporting 

78 

 
 
 
 
 
5.1.3

 Consideration  of  groundwater  associated  surface  waters  and/or  groundwater 
dependent ecosystems 

In five of six groundwater bodies, groundwater associated surface waters have been  reported, 

they are not related to risk and they have not been considered in status assessment in the RBD. 

In  five  of  six  groundwater  bodies  groundwater  dependent  terrestrial  ecosystems  have  been 

reported, they are not related to risk and they have not been considered in status assessment in 
the  river  basin  district.  The  needs  of  these  ecosystems  have  not  been  considered  in  status 

assessment. 

5.2  Main changes in implementation and compliance since the first cycle 

Four of six groundwater bodies remained unchanged since the first RBMP. 

The  monitoring  situation  has  not  improved  as  the  number  of  monitoring  sites  decreased  and 
there is still one out of the six groundwater bodies without quantitative monitoring. 

The  RBMP  and  supporting  document  assessed  found  that  the  increasing  number  of 
groundwater  bodies  from  five  to  six  was  due  to  dividing  one  groundwater  body  into  two 

groundwater bodies. Reviews and extensions of the existing monitoring network are planned. 
One  groundwater  body  has  not  been  monitored  because  of  technical  reasons,  but  the 

quantitative monitoring network is expected to be expanded in all groundwater bodies by 2019. 

5.3  Progress with Commission recommendations 

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

  Recommendation: Where there are currently high uncertainties in the characterisation 
of  the  RBDs,  identification  of  pressures,  and  assessment  of  status,  these  need  to  be 

addressed in  the current cycle, to  ensure that adequate measures can be  put  in  place 
before the next cycle. 

  Assessment:  Regarding  high  uncertainties  in  status  assessment,  the  confidence  in  the 
status  results  is  reported  to  be  of  medium  and  high  level.  This  recommendation  is 
fulfilled.  

79 

 
 
  Recommendation:  Close  the  remaining  gaps  in  monitoring  networks  and  assessment 
methodologies as regards ecological status or surface water, chemical status of surface 
and groundwaters and quantitative status of groundwaters. 

  Assessment:  Regarding  the  closure  of  monitoring  gaps;  one  out  of  six  groundwater 
bodies  is  without  quantitative  monitoring  and  the  total  number  of  monitoring  sites 

decreased. Therefore, this recommendation is largely fulfilled as the monitoring site in 
the groundwater body without monitoring is announced to be officially included in the 

monitoring network in 2019. 

80 

 
 
 
 
 
Topic 6

  Monitoring,  assessment  and  classification  of  chemical 

status of groundwater bodies 

6.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle 

6.1.1

 Monitoring of chemical status in groundwater 

The  total  number  of  groundwater  bodies  in  Luxembourg  is  six  (Table  2.2);  all  in  the  Rhine 

RBD. All (100 %) groundwater bodies are subject to surveillance monitoring (Table 5.1). Four 
groundwater bodies (67 %) are at risk but there is no operational monitoring. The coverage of 

groundwater  bodies  by  monitoring  is  complete  for  surveillance,  but  not  for  operational 
monitoring. 50  

The  number  of  groundwater  bodies  increased  by  20  %  from  five  in  the  first  River  Basin 
Management Plan to six in the second River Basin Management Plan but the total groundwater 

body  area  remained  nearly  the  same.  According  to  RBMP  and  supporting  document 
assessment, one groundwater body was divided into two groundwater bodies and the remaining 
four groundwater bodies remained unchanged since the first River Basin Management Plan.  

The number of monitoring sites is listed in  Table 5.3 and shows no change between the first 
River  Basin  Management  Plan  and  the  second  River  Basin  Management  Plan  i.e.  31.  In  the 
first River Basin Management Plan 54 operational monitoring sites51 were reported and in the 
second River Basin Management Plan, there is no more operational monitoring.. 

All  substances  causing  risk  of  deterioration  in  chemical  status  are  subject  to  surveillance 
monitoring.  From  the  WFD  core  parameters  nitrate,  ammonium,  electrical  conductivity, 
oxygen and pH only ammonium and nitrate are monitored52. 

50   Luxembourg subsequently clarified, that due to an error of reporting in WISE, in fact operational monitoring is 

done at all 31 monitoring sites. 

51   For  the  first  RBMPs,  there  are  still  31  monitoring  stations.  The  other  stations  are  belonging  to  the 
pesticides 

supplementary 
(http://ec.europa.eu/environment/water/water-framework/pdf/3rd_report/CWD-2012-379_EN-Vol3_LU.pdf) 
52  Luxembourg  subsequently  clarified,  that  also  electrical  conductivity  and  pH  are  monitored  (reporting  error). 
There  are  concerns  about  the  representativeness  of  the  measures  for  dissolved  oxygen,  especially  in  spring 
therefore the parameter is not systematically monitored.  

programmes 

monitoring 

nitrates 

and 

for 

81 

 
 
 
                                                      
6.1.2

 Assessment and classification of chemical status in groundwater 

Map 6.1 and Figure 6.1 display the chemical status of groundwater bodies for the most recently 
assessed status.  It shows that three of six groundwater bodies (50 %) were of good chemical 

status, and the remaining three groundwater bodies (50 %) are failing good status. In terms of 
area,  this  means  that  about  79  %  are  failing  good  chemical  status.  Figure  6.2  shows  the 

confidence in status classifications, all of which are of medium or high level. All groundwater 
bodies had, and still, have a clear status in the first and second River Basin Management Plans.  

The total number of groundwater bodies failing good chemical status increased since the first 
RBMP from two (40 %) to three (50 %) groundwater bodies (Figure 6.1) (from 63 % to 79 % 

of the total groundwater body area). The expected date of achievement of good chemical status 
in Luxembourg is shown in Figure 6.3. 

Map 6.1  Map of chemical status of groundwater bodies in Luxembourg based on the most 

recently assessed status of the groundwater water bodies 

82 

 
 
 
 
Note: Standard colours based on WFD Annex V, Article 2(4)(5).  
Source: WISE, Eurostat (country borders) 

83 

01020kmLU000LU001LUGoodPoorUnknownRiver Basin DistrictsCountries outside the EU 
 
 
 
Figure 6.1 

Chemical  status  of  groundwater  bodies  in  Luxembourg  for  the  second 

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

period of the assessment of status for the second RBMP was 2007 to 2014. 
The year of the assessment of status for first RBMP is not known 

Source: WISE electronic reporting 

Figure 6.2 

Confidence in the classification of chemical status of groundwater  bodies 

in Luxembourg based on the most recent assessment of status 

Source: WISE electronic reporting 

84 

 
 
 
 
Figure 6.3  Expected date of achievement of good quantitative and good chemical status 

of groundwater bodies in Luxembourg. Six groundwater bodies delineated for 
the second RBMP 

Source: WISE electronic reporting 

The reasons for the failure of good chemical status of groundwater bodies are shown in Figure 
6.4, two groundwater bodies failed the chemical status assessment. This assessment considers 

the significant environmental risk from pollutants across a groundwater body and a significant 
impairment  of  the  ability  to  support  human  uses.  Three  groundwater  bodies  are  failing  the 

drinking water test which means that the requirements of drinking water protected areas have 
not been met. One groundwater body is failing the groundwater associated surface water test 

which  means  that  there  is  diminution  of  the  status  of  groundwater  associated  surface  water. 
Figure 6.5 shows the pollutants causing failure of status and those causing a sustained upward 

trend.  

The calculation of the extent of exceedance of a groundwater quality standard or a groundwater 

threshold  value  is  based  on  the  number  of  monitoring  sites  in  the  groundwater  body  in  the 
RBD. 

Groundwater threshold values have been established for all pollutants or indicators of pollution 
causing  a  risk  of  failure  of  good  chemical  status.  The  RBMP  and  supporting  document 

85 

 
 
 
 
assessment  found  an  indication  that  the  Groundwater  Directive53  Annex  II  substances  have 
been  considered.  Natural  background  levels  have  been  considered  in  the  establishment  of 
groundwater threshold values.  

A trend and trend reversal methodology is available and assessments have been performed in 
the RBD. 

Figure 6.4 

Reasons  for  failing  good  chemical  status  in  Luxembourg  for  the  most 
recent assessment of status 

Source: WISE electronic reporting 

Notes: 
‘Surface water’ = Failure to achieve Environmental Objectives (Article 4 WFD) in associated surface water 
bodies or significant diminution of the ecological or chemical status of such surface water bodies. 

‘Groundwater dependent terrestrial ecosystems’ = Significant damage to terrestrial ecosystems which depend 
directly on the groundwater body. 

‘Saline or other intrusion’ = Regional saline or other intrusions resulting from anthropogenically induced 
sustained changes in flow direction. 

‘Drinking Water Protected Area’ = Deterioration in quality of waters for human consumption. 

‘General water quality assessment’ = Significant impairment of human uses; significant environmental risk from 
pollutants across the groundwater body. 

53   Directive 2006/118/EC of the European Parliament and of the Council of 12 December 2006 on the protection 
http://eur-lex.europa.eu/legal-

deterioration 

pollution 

against 

groundwater 

and 
of 
content/EN/TXT/?uri=CELEX:02006L0118-20140711  

86 

 
 
 
 
 
 
                                                      
Figure 6.5 

Top groundwater pollutants causing failure of good chemical status in 

Luxembourg 

Source: WISE electronic reporting.  

Note: only three pollutants reported causing failure. 

Figure 6.6 

Percentage of groundwater bodies in Luxembourg at risk of failing good 

chemical status and good quantitative status for the second RBMP 

Source: WISE electronic reporting 

87 

 
 
 
 
 
 
 
 
 
6.1.3

 Consideration  of  groundwater  associated  surface  waters  and/  or  groundwater 
dependent ecosystems 

In five of six groundwater bodies groundwater associated surface waters  have been reported, 

they  are  not  related  to  risk  and  they  have  been  considered  in  status  assessment  in  all  RBDs. 
Furthermore,  groundwater  dependent  terrestrial  ecosystems  have  been  reported.  The  water 

bodies are not related to risk, and they have not been considered in status assessment.  

Groundwater associated aquatic ecosystems and groundwater dependent terrestrial ecosystems 

have not been considered in the establishment of groundwater threshold values but there is no 
related risk.  

6.2  Main changes in implementation and compliance since the first cycle 

The RBMP and supporting document assessment found a summary of changes and updates for 
this topic in the RBMP. The main changes are: 

 

To  improve  transparency  and  clarity  in  the  second  RBMP,  the  assessment  method  for 

chemical quality in groundwater was carried out according to Common Implementation 
Strategy Guidance document no. 1854.  

 

 

New trend analyses in groundwater bodies were carried out for the second RBMP based 
on a method used and tested in Austria. 

Additional  monitoring  stations  are  envisaged  for  the  second  cycle,  and  the  monitoring 
stations for the Nitrates Directive55 will be integrated more closely with WFD monitoring 
sites  

The  RBMP  and  supporting  document  assessment  found  that  the  increasing  number  of 

groundwater  bodies  from  five  to  six  was  due  to  dividing  one  groundwater  body  into  two 
groundwater bodies. The total groundwater body area remained nearly the same and four of six 

groundwater bodies remained unchanged since the first RBMP. 

The WISE data showed that the monitoring situation deteriorated. All groundwater bodies are 

still subject to surveillance monitoring, but in the second River Basin Management Plan there 
is no more operational monitoring even though four groundwater bodies are at risk of failing 

54    https://circabc.europa.eu/sd/a/ff303ad4-8783-43d3-989a-
55b65ca03afc/Guidance_document_N%C2%B018.pdf  

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

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

88 

 
 
                                                      
good chemical status. However, Luxembourg subsequently clarified that actually the situation 

improved and all groundwater bodies are under operational monitoring. The lack of operational 
monitoring is due to a reporting error in WISE. 

The  status  situation  deteriorated  as  the  groundwater  body  area  failing  good  chemical  status 
increased from 63 % to 79 % of the total groundwater body area. 

6.3  Progress with Commission recommendations 

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

  Recommendation:  Close  the  remaining  gaps  in  monitoring  networks  and  assessment 
methodologies  as  regards  ecological  status  or  surface  water,  chemical  status  of  surface 
and groundwaters and quantitative status of groundwaters. 

Assessment:  The  RBMP  and  supporting  document  investigation  found  that  it  was 
mentioned  that  in  order  to  improve  transparency  and  clarity  in  the  second  River  Basin 

Management Plan, the assessment method for chemical quality in groundwater was carried 
out  according  to  Common  Implementation  Strategy  Guidance  document  no.  18.  All 

groundwater  bodies  are  still  subject  to  surveillance  monitoring  but  there  is  no  more 
operational  monitoring  even  if  four  of  six  groundwater  bodies  are  at  risk  of  failing  good 

chemical status.  

Luxembourg  subsequently  clarified  that  the  operational  monitoring  is  performed  at  all 

monitoring  sites.  This  was  due  to  an  error  of  reporting  in  WISE.  Therefore  despite  the 
WISE reported data, the additional information provided by Luxembourg indicates that the 
recommendation is fulfilled. 

89 

 
 
 
Topic 7

  Designation  of  Heavily  Modified  and  Artificial  Water 

Bodies and definition of Good Ecological Potential 

7.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle for designation  

7.1.1

 Designation of Heavily Modified and Artificial Water Bodies 

Similar  to  the  first  RBMP,  there  are  only  river  water  bodies  designated  as  heavily  modified 

water bodies (6.5 % and 33.3 % of river water bodies respectively in the Rhine RBD and the 
Meuse RBD) (Figure 7.1). No artificial water bodies have been designated. In the Rhine RBD, 

one water body is a reservoir which was originally a river and is designated as a river heavily 
modified  water  body.  The  WFD  requires  a  review  of  designation  every  six  years.  As  noted 

further below in this chapter, only few changes have been noted in the designation of heavily 
modified water bodies since the first RBMP. 

Heavily  modified  water  bodies  are  designated  due  to  urban  development,  hydropower,  flood 
protection  and  transport.  The  main  physical  alterations  of  heavily  modified  water  bodies  are 
channelisation/straightening/bed stabilisation/bank reinforcement and weirs/dams/reservoirs. 

The second RBMP provide specific information on water body level concerning the outcome 
of the assessment of significant adverse effects of restoration measures on the use or the wider 

environment.  Each  heavily  modified  water  body  has  been  assessed  individually  based  on  a 
national  approach  and  a  general  description  of  the  reasons  for  designation  are  given,  e.g. 

maintenance  of  navigation,  provision  of  public  water  supply  (reservoir)  and  hydroelectricity, 
preservation  of  old  city/town  centres.  The  criteria  provided  for  the  assessment  of  significant 

adverse effects are described in general terms without quantitative definitions.  

It has also been checked whether the beneficial objectives can be achieved by “other means” 

and specific information is given on water body level on the outcome of this assessment. There 
is  a  general  statement  that  the  designation  of  eight  heavily  modified  water  bodies  was 

necessary  on  the  basis  that  there  were  no  technically  feasible  alternative  measures,  not 
entailing excessive costs, or an alternative use which would represent  a better environmental 

option.  

90 

 
 
Figure 7.1 

Proportion of total water bodies in each category in Luxembourg that has 

been designated as heavily modified or artificial  

Source: WISE electronic reporting 

7.1.2

 Definition of Good Ecological  Potential for Heavily Modified  and Artificial  Water 
Bodies 

According  to  WISE,  good  ecological  potential  is  reported  as  defined  at  water  body  level  in 
both  RBDs  following  the  Common  Implementation  Strategy  Guidance  approach  (based  on 

biological  quality  elements  as  illustrated  in  Common  Implementation  Strategy  Guidance  No 
4). Information in the RBMP indicates that this new proposed method combines the Common 

Implementation  Strategy  Guidance  approach  and  elements  of  the  Prague  approach  (based  on 
the  identification  of  mitigation  measures).  For  the  second  RBMP,  work  to  define  good 

ecological  potential  started  in  2013  and  a  specific  method  for  defining  good  ecological 
potential  has  been  developed  for  river  water  bodies.  Because  of  the  low  number  of  heavily 

modified water bodies, an individual approach to defining good ecological  potential for each 
water body will be followed. 

Good ecological potential is also reported to have been defined in terms of biology. According 
to  WISE,  the  biological  quality  element  for  which  biological  values  have  been  derived  to 

define  moderate  ecological  potential  and  good  ecological  potential  are  macrophytes, 
phytobenthos,  benthic  invertebrates,  fish,  and  phytoplankton.  It  is  also  reported  that  a 

comparison  between  good  ecological  potential  and  good  ecological  status  has  been  made  in 
both RBDs. 

91 

 
 
 
According  to  information  in  the  RBMP,  benthic  invertebrates  and  fish  have  been  included 

most  commonly 
to 
hydromorphological  alterations.  The  same  method  for  the  evaluation  of  biological  quality 

these  are  considered  as  sensitive 

the  evaluation  because 

in 

elements,  and  the  same  references  and  limits,  has  been  applied  for  heavily  modified  water 
bodies  as  for  natural  surface  water  bodies.  This  has  resulted  in  the  classification  of  the 

ecological  potential  of  all  heavily  modified  water  bodies  as  “moderate  or  worse”.  A  slightly 
different  approach  was  used  for  two  heavily  modified  water  bodies  (both  reservoirs  in  the 

Rhine  RBD)  which  are  characterised  by  significant  water  level  fluctuations  caused  by  the 
water use (impoundment reservoirs used for hydro-electricity production). For the impounded 

sections of these heavily modified water bodies, the classification of ecological potential was 
mainly based on phytoplankton. 

It  is  intended  to  further  improve  and  refine  the  definition  of  good  ecological  potential  in  the 
course of the second planning cycle. 

Biological  quality  element  assessment  methods  sensitive  to  hydrological  and  morphological 
changes in rivers are reported for fish, benthic invertebrates and macrophytes. 

The  estimation  of  values  of  biological  quality  elements  were  based  on  available  monitoring 

data for 2007-2012, and a combination of the use of the “worst monitoring result” (if several 
differing  monitoring  results  are  available  for  one  water  body  and  biological  quality  element) 

and expert judgment (for example, justification in cases where the “worst” result is not used, or 
consideration of hydromorphological and physico-chemical quality elements).  

Mitigation  measures  for  defining  good  ecological  potential  have  not  been  reported,  because 
this  information  cannot  be  provided  by  Luxembourg  to  WISE.  Measures  which  need  to  be 

taken  in  order  to  reach  good  ecological  potential  have  been  identified  for  each  heavily 
modified water body and are included in the detailed Programme of Measures (in annex 20 of 

the second RBMP), which contains technical measures to be implemented for each water body, 
including  heavily  modified  water  bodies,  in  order  to  reach  good  status.  However,  no 

information  could  be  found  on  the  ecological  changes  that  the  mitigation  measures  are 
designed  to  achieve  in  either  qualitative  or  quantitative  terms.  Luxembourg  informed  the 

Commission that the definition of ecological potential and the mitigation measures permitting 
to  achieve good ecological  potential is  under development  and will be available for the third 

RBMP. 

92 

 
 
7.2  Main changes in implementation and compliance since the first cycle 

No changes are noted in the extent of heavily modified water body designation in the Meuse 
RBD (where only one river water body is designated as a heavily modified water body). In the 

Rhine  RBD,  river  heavily  modified  water  bodies  have  decreased  from  10  to  7  water  bodies 
(from 10 % to 6.5 % of total river water bodies).  

The methodology for the designation of heavily modified water bodies has not been modified 
since  the  first  RBMP,  as  the  method  and  criteria  used  for  the  review  of  the  designation  of 
heavily  modified  water  bodies  are  the  same  as  for  the  first  RBMP  (based  on  Common 

Implementation  Strategy  Guidance  no.4).  The  review  of  the  designation  of  heavily  modified 
water bodies has been based on the availability of better hydromorphological structural quality 

mapping of all surface (river)  waters, measures in progress  and results  of new investigations 
concerning feasibilities of re-naturalisation actions. This has led to the de-designation of three 

previously  designated  heavily  modified  water  bodies  (in  the  Rhine  RBD),  changing  these  to 
natural surface water bodies for which good ecological status is expected to be achieved.  

Good  ecological  potential  had  not  been  defined  for  the  first  RBMP,  while  for  the  second 
RBMP a method has been developed to do so following the Common Implementation Strategy 

guidance based approach. Luxembourg informed the Commission that this new method will be 
used in order to define good ecological potential in the third RBMP.  

7.3  Progress with Commission recommendations 

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

requested action on the following: 

  Recommendation  (report  2012):  There  are  significant  gaps  in  the  designation  of  heavily 
modified water bodies. The methodology of this first RBMP does not provide for any driver 
for  restoration  and  improvement  of  the  existing  pressures  from  hydromorphological 

modifications. Furthermore, the methodology to  define good ecological potential was not 
yet  defined  in  this  plan,  and  there  is  therefore  a  significant  gap  in  the  objectives  to  be 

defined for  the heavily  modified water  bodies.  The designation of  heavily modified water 
bodies should be brought in line with all the requirements of Article 4(3). 

Assessment: The methodology for the designation of heavily modified water bodies has not 
been modified since the first RBMP, as the method and criteria used are the same as for the 
first RBMP. However, the designation of heavily modified water bodies has been reviewed 
based  on  the  availability  of  better  hydromorphological  structural  quality  mapping  of  all 

93 

 
 
surface (river) waters, measures in progress, and results of new investigations concerning 

feasibilities  of  re-naturalisation  actions.  In  addition,  descriptions  of  the  assessment  of 
significant  adverse  effects  of  restoration  measures  and  of  other  means  to  deliver  the 

benefits of the modifications are provided for each heavily modified water body, although 
they remain general and do not use any quantified criteria as a basis. 

Overall, based on the information found, this recommendation has been partially fulfilled. 

  Recommendation  (report  2015):  Justify  better  in  the  second  RBMP  the  designation  of 
HMWB and water bodies subject to exemptions in particular as regards the consideration 
of  significant  adverse  effects  and  affordability.  Good  ecological  potential  should  be 

correctly defined for HMWB. 

  Assessment: Concerning issues on the designation of HMWB, details are given under the 
previous recommendation. Concerning good ecological potential, for the second RBMP, a 
method  has  been  developed  to  define  good  ecological  potential,  following  the  Common 

Implementation Strategy guidance based approach. Efforts have also been made do this in 
biological  terms,  and  mitigation  measures  are  included  in  the  detailed  Programme  of 

Measures.  However,  no  information  could  be  found  on  the  ecological  changes  that  the 
mitigation measures are designed to achieve in either qualitative or quantitative terms.  

Luxembourg informed the Commission  that the  definition of ecological  potential and the 
mitigation measures permitting to achieve good ecological potential is under development 

and will be available for the third RBMP. 

Therefore, this recommendation has been partially fulfilled. 

94 

 
 
 
Topic 8

  Environmental objectives and exemptions 

8.1  Assessment of implementation and compliance with WFD requirements 
in  the  second  cycle  and  main  changes  in  implementation  and 
compliance since the first 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,  that  is,  good  status  by  2015.  Within  that  general  objective,  specific  environmental 
objectives are defined for heavily modified water bodies (good ecological potential and good 
chemical status by 201556), groundwaters (good chemical and quantitative status by 2015), and 
for Protected Areas (achievement of the objectives of the associated Directive by 2015, unless 

otherwise specified). 

In Luxembourg, environmental objectives for ecological and chemical status of surface water 

have  been  reported  in  both  RBDs  as  well  as  for  chemical  and  quantitative  status  of 
groundwater in the Rhine RBD. 

Assessments  of  the  current  status  of  surface  and  groundwater  bodies  in  Luxembourg  are 
provided elsewhere in this report: for ecological  status/potential of surface waters (Chapter 3 

Topic  3);  chemical  status  of  surface  waters  (Chapter  4);  quantitative  status  of  groundwater 
bodies (Chapter 5);  chemical  status  of groundwater bodies (Chapter 6);  status  of surface and 
groundwater bodies associated with Protected Areas (Chapter 15). 

For the second RBMP, Member States are required to report the date when they expect each 
surface  and  groundwater  body  to  meet  its  environmental  objective.  This  information  is 

summarised for Luxembourg elsewhere in this report: for ecological status/potential of surface 
waters  in  Chapter  3;  chemical  status  of  surface  waters  in  Chapter  4;  quantitative  status  of 

groundwater bodies in Chapter 5; and chemical status of groundwater bodies in Chapter 6.  

56   For priority substances  newly introduced by Directive  2013/39/EU, good status should  be reached by 2027, 
and for the 2008 priority substances, for which the Environmental Quality Standards were revised by Directive 
2013/39/EU, good status should be reached in 2021. 

95 

 
 
                                                      
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 Luxembourg for the four main sets of environmental 

objectives. 

Figure 8.1 

Water bodies in Luxembourg expected to be in at least good status in 2015 

and use of exemptions. 1 = Surface water body ecological status/potential; 
2  =  Surface  water  body  Chemical  status;  3  =  Groundwater  body 

quantitative status; 4 = Groundwater body chemical status 

Source: WISE electronic reporting 

Article  4  of  the  WFD  allows  under  certain  conditions  for  different  exemptions  to  the 
objectives:  an  extension  of  deadlines  beyond  2015,  less  stringent  objectives,  a  temporary 

deterioration,  or  deterioration  /  non-achievement  of  good  status  /  potential  due  to  new 
modifications, provided a set of conditions is fulfilled. The exemptions under WFD Article 4 

include the provisions in Article 4(4)  - extension of deadline, Article 4(5) - lower objectives, 
Article 4(6) - temporary deterioration, and Article 4(7) - new modifications / new sustainable 

human  development  activities.  Article  4(4)  exemptions  may  be  justified  by:  disproportionate 

96 

 
 
 
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 Luxembourg. 

Figure 8.2 

Type of exemptions applied to surface water and groundwater bodies for the 

second RBMP in Luxembourg. Note: Ecological status and groundwater quantitative status 
exemptions are reported at the water body level. Chemical exemptions for groundwater are 

reported  at  the  level  of  each  pollutant  causing  failure  of  good  chemical  status,  and  for 
surface waters for each Priority Substances that is causing failure of good chemical status 

Source: WISE electronic reporting 

97 

 
 
 
Surface  water  bodies  on  the  national  level  increased  from  102  to  110.  Overall  exemptions 

increased from 72 % to 97 %, i.e. to 107 surface water bodies (from 74 water bodies in the first 
cycle).  The  number  of  groundwater  bodies  on  the  national  level  increased  from  five  to  6, 

exemptions increased from 40 % to 50 % (three water bodies for chemical status). The reasons 
for this increased use of exemptions are explained in chapters 7 and 15 of the RBMP. 

Application of Article 4(4) 

The application of Article 4(4) exemptions has increased, which is inter alia explained by the 

re-classification of all surface waters as poor chemical status (see Chapter 4 of this report for 
further  information).  This  was  mainly  based  on  the  widespread  occurrence  of  polycyclic 
aromatic  hydrocarbons  as  defined  in  the  revised  EQS  Directive57,  as  well  as  on  a  lower 
Environmental  Quality  Standard  for  benzo(a)pyrene  (used  as  marker  for  five  polycyclic 

aromatic  hydrocarbons).  In  addition,  fluoranthene  is  expected  to  exceed  the  lower 
Environmental  Quality  Standards  of  the  Directive  widely  in  the  near  future,  and  there  are 

uncertainties  concerning  mercury,  which  is  also  expected  to  exceed  the  biota  Environmental 
Quality Standards (based on data obtained by Germany, not yet monitored in Luxembourg, but 
planned for the second cycle; mercury was identified to be ubiquitous at EU level in 2013).  

In  the  case  of  groundwater,  the  increase  in  exemptions  from  40  %  to  50  %  of  groundwater 
bodies  merely  reflects  the  re-designation  of  these,  i.e.  splitting  one  groundwater  body  with 

poor  chemical  status  into  two,  one  with  good  and  one  with  poor  chemical  status,  thereby 
increasing  the  total  number  of  groundwater  bodies  from  five  to  6,  with  the  number  of  poor 

quality groundwater bodies remaining the same (three or 50 %, previously three or 40 %). 

All  exemptions  are  due  to  Article  4(4)  for  both  surface  waters  (Table  8.1)  and  groundwater 

(Table  8.2).  The  justification  in  surface  waters  is  related  to  technical  feasibility,  natural 
conditions and disproportional costs. For groundwater, natural conditions are reported. 

For surface waters, natural conditions are justified by natural hydrogeological conditions and 
the  re-establishment  of  flora  and  fauna.  Technical  feasibility  refers  to  no  information  on  the 

cause of the problem, no technical solution is available, and it takes longer to fix the problem. 
Disproportionate  costs  refer  to  affordability,  assessment  of  the  consequences  of  non-action, 

benefits  assessment,  cost-benefit  analysis,  cost-effectiveness  analysis,  distribution  of  costs, 
social and sectoral impacts, and other reasons (not further defined). 

57   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. 

98 

 
 
                                                      
Table 8.1 

Pressures  on  surface  water  bodies  responsible  for  Priority  Substances  in 

Luxembourg failing to achieve good chemical status in 2015 (when applying 
EQS  from  Directive  2008/108/EC)58  and  for  which  exemptions  have  been 
applied 

Significant pressure on surface 
water bodies 

2.2 - Diffuse - Agricultural 

8 - Anthropogenic pressure - 
Unknown 

Failing Priority 
Substances 

Article 4(4) - Technical feasibility 
exemptions 

Number 

1 

4 

Number 

11 

440 

Source: WISE electronic reporting 

Table 8.2 

Pressures  responsible  for  pollutants  in  Luxembourg  failing  to  achieve  good 

chemical status in groundwater in 2015 and for which exemptions have been 
applied  

Significant pressure on groundwater  Number of failing pollutants 

Number of exemptions 

Article 4(4) - Natural conditions 

2.2 – Diffuse - Agricultural 

3 

7 

Source: WISE electronic reporting 

Application of Article 4(5) 

No exemptions according to Article 4(5) have been applied.  

Application of Article 4(6) 

No exemptions according to Article 4(6) have been applied.  

Application of Article 4(7) 

No exemptions according to Article 4(7) have been applied. 

58   Luxembourg subsequently clarified that the EQS for mercury, fluoranthene and benzo(a)pyren in water was 
not exceeded, as defined by Directive 2008/105/EC. However the RBMP (chapter 7.4.2.1) indicated that the 
biota EQS for mercury will most likely be exceeded in the future, once the new EQS is applicable. 

99 

 
 
                                                      
Application of Article 6(3) of the Groundwater Directive 

No exemptions according to Article 6(3) of the Groundwater Directive59 have been applied. 

8.2  Progress with Commission recommendations 

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

  Recommendation: It is unclear whether there are any new physical modifications planned 
in RBMPs. If this is the case, the use of exemptions under Article 4(7) should be based on a 

thorough assessment of all the steps as requested by the WFD, in particular an 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.  

  Recommendation:  A  large  number  of  exemptions  have  been  applied  in  the  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, in 
particular  the  justification  for  technical  infeasibility  and  the  expected  timeline  for  the 

achievement of the objectives.  

  Recommendation: Only little improvement of 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. 

  Recommendation: The high number of exemptions applied in the first RBMPs is expected 
to  be  significantly  decreased  in  the  second  cycle.  Luxembourg  should  take  all  necessary 
measures to bring down the number of exemptions for the next cycle, including the needed 

improvements in the characterisation process, monitoring networks and status assessment 
methods, as well as reducing significantly the degree of uncertainty. 

59   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. 

100 

 
 
                                                      
Assessment  (for  all  recommendations):  Article  4(7)  is  not  used  in  the  second  cycle. 

However,  it  is  not  clear  whether  there  are  any  new  physical  modifications  planned  in  the 
RBMP without employing Article 4(7). 

All  exemptions  are  due  to  Article  4(4).  The  justification  in  surface  waters  is  related  to 
technical feasibility, natural conditions and disproportional costs. For groundwater, natural 

conditions are reported. 

Technical feasibility refers to the fact that more time is required to achieve good chemical 

status  and  good  ecological  status/potential  because  no  technical  solution  was  available. 
Whilst  no  comprehensive  definition  of  technical  feasibility/infeasibility  was  reported,  a 

specification is provided in table 7.1 of the River Basin Management Plan, presenting four 
"levels" of technical feasibility/infeasibility (T1  - there is no technical solution, T2 - more 

time needed to solve the problem, T3 - no information on the cause of the problem, and T4 
–  other).  Much  of  the  ubiquitous  polycyclic  aromatic  hydrocarbons  contamination  is 

thought  to  be due to  atmospheric deposition, and mercury is  also  considered  a long- term 
problem (partly due to atmospheric deposition) and consequently, no short-term solution is 
available  at  present.  Exemptions  due  to  technical  feasibility/infeasibility  have  not  been 

applied to groundwater. 

Natural  conditions  are  justified  by  natural  hydrogeological  conditions  and  the  re-

establishment  of  flora  and  fauna.  No  definition  was  provided,  except  an  explanation  that 
water replenishment  in  groundwater was long-term  (5-15  years and in  some cases longer) 

and therefore the achievement of good chemical status by 2027 was uncertain in two of the 
three groundwater bodies (one expected good by 2021). For surface water bodies, it is noted 

that  biological  recovery  can  take  several  years;  no  details  were  reported  in  relation  to 
exemptions  based  on  hydrological  conditions,  although  a  short  explanation  is  provided  in 

the RBMP (table 7-1). 

No  clear  definition  of  disproportionate  costs  was  provided  but  it  was  stated  that  the 

justification was based on cost-benefit analyses, without giving details of these analyses. 

Time-wise  objective  setting  for  reaching  objectives  has  improved,  although  less  water 

bodies are expected to reach good status/potential in 2021 than initially planned in 2009, or 
even at a later stage (i.e. in 2027).  

Overall,  the  number  of  exemptions  increased,  partly  due  to  justified  reasons,  and  the 
justifications for exemptions improved slightly. Hence, partial progress  has been achieved 

regarding the recommendations. 

101 

 
 
Topic 9

  Programme of measures  

The aim of this chapter is to provide an overview of the Programme of Measures reported by 

Members;  more  specific  information  on  measures  relating  to  specific  pressures  (for  example 
arising from agriculture) is provided in subsequent chapters. 

The  Key  Types  of  Measure  (KTM)  referred  to  in  this  section  are  groups  of  measures 
identified  by  Member  States  in  the  Programme  of  Measures,  which  target  the  same 

pressure  or  purpose.  The  individual  measures  included  in  the  Programme  of  Measure 
(being  part of the RBMP) are  grouped into Key Types of Measure for the purpose of 

reporting.  The  same  individual  measure  can  be  part  of  more  than  one  Key  Types  of 
Measure because it may be multi-purpose, but also because the Key Types of Measure 

are  not  completely  independent  silos.  Key  Types  of  Measure  have  been  introduced  to 
simplify  the  reporting  of  measures  and  to  reduce  the  very  large  number  of 

Supplementary Measures reported by some Member States (WFD Reporting Guidance 
2016).  

A Key Type of Measure may be one national measure but it would typically comprise 

more than one national measure. The 25 predefined Key Types of Measure are listed in 
the WFD Reporting Guidance 2016. 

The Key Types of Measure should be fully implemented and made operational within 
the  RBMP  planning  period  to  address  specific  pressures  or  chemical  substances  and 

achieve the environmental objectives. 

9.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle 

9.1.1

 General issues 

An  indication  as  to  whether  or  not  measures  have  been  fully  implemented  and  made 
operational is when they have been reported as being planned to tackle significant pressures (at 

the  Key  Types  of  Measure  level).  Significant  pressures  are  also  reported  at  the  water  body 
level.  It  would  therefore  be  expected  that  there  would  be  measures  planned  in  the  RBMP  to 

tackle  all  significant  pressures.  Not  all  reported  significant  pressures  seem  to  be  covered  by 
KTMs  which  may  impact  upon  the  achievement  of  WFD  objectives  in  Luxembourg.  For 

102 

 
 
 
 
example  for  groundwater  (Rhine  RBD  only;  there  are  no  groundwater  bodies  in  the  Meuse 

RBD) only diffuse agricultural pressures are covered, but there are no KTMs for point source 
pollution  from  contaminated  sites  or  abandoned  industrial  sites,  or  for  abstraction  for  public 

water  supply  (the  latter  does  not  seem  to  be  an  issue,  as  all  groundwater  bodies  are  in  good 
quantitative status - see Chapter Topic 10 of this report)60.  

For surface water (Rhine RBD), only 9 of 19 significant pressure types are covered: no KTMs 
are  reported  operational  for  point  sources  from  storm  overflows;  Industrial  Emissions 
Directive61  plants;  non-  Industrial  Emissions  Directive  plants;  nor  for  diffuse  sources  from 
agriculture,  contaminated  sites  or  abandoned  industrial  sites,  and  atmospheric  deposition; 

abstraction or flow diversion  for public water supply and  cooling water;  physical  alterations, 
such as dams,  barriers locks for navigation; hydrological  alterations for transport;  introduced 

species and diseases; or other anthropogenic pressures, although six individual substances are 
covered.  In  addition,  significant  pressures  not  covered  by  KTMs  are  navigation,  sediment 

deposition, and recreation. For surface water in the Meuse RBD, two of six reported pressure 
types  are  covered:  no  KTMs  are  reported  for  point  sources  from  Industrial  Emissions 
Directive:  plants;  diffuse  sources  from  contaminated  sites  or  abandoned  industrial  sites,  and 

atmospheric deposition; sediment deposition and other anthropogenic pressures, although four 
individual  substances  are  covered.  The  apparent  lack  of  operational  measures  for  reported 

significant pressures is due to incomplete WISE reporting, for example there is information in 
the RBMP on tackling diffuse agricultural pressures in the Rhine RBD (see Chapter Topic 11 

of this report).  

158  national  basic  measures  and  63  national  supplementary  measures  have  been  mapped 

against  a  wide  range  of  KTMs  for  both  RBDs.  30  %  of  the  national  basic  measures  were 
mapped  to  KTM  2  -  "Reduce  nutrient  pollution  from  agriculture".  28  %  of  the  national 

supplementary  measures  were  mapped  to  the  nationally  defined  KTM  “(Administrative) 
measures which should help achieving the good status or facilitate the implementation of other 

measures  from  the  Programme  of  Measures”.  Links  to  further  information  on  Article 
11(3)(c)(k)  basic  measures  for  both  RBDs  were  provided,  as  was  an  inventory  of  national 

measures, with individual basic measures listed with codes and mapped against measure types, 
including supplementary measures. This includes, for example, national measures for KTM 17 

- "Measures to reduce sediment from soil erosion and surface run-off", but not for KTM 18 – 

60  Luxembourg  clarified  subsequently  that  measures  are  in  place  to  address  point  source  pollution  from 

contaminated sites or abandoned industrial sites, and for abstraction for public water supply.  

61   Directive  2010/75/EU  of  the  European  Parliament  and  of  the  Council  of  24  November  2010  on  industrial 
http://eur-lex.europa.eu/legal-

(integrated 

prevention 

control) 

and 

emissions 
content/EN/TXT/?uri=CELEX:32010L0075  

pollution 

103 

 
 
                                                      
“Measures to prevent or control the adverse impacts of invasive alien species and introduced 

diseases”, although the latter is included in the issues for the Rhine RBD.  

Whilst  KTMs  were  mapped  against  national  measures,  little  information  was  provided  on 

KTMs  tackling  significant  pressures,  although  some  significant  pressures  causing  failure  of 
objectives were listed for groundwater and surface water in the Rhine RBD, and surface water 

(groundwater not relevant) in the Meuse RBD, including some Priority Substances and River 
Basin Specific Pollutants. The percentage of water bodies failing objectives by 2027 is not yet 
known (marked “no information”).62  

No information was reported for River Basin Specific Pollutants or Priority Substances causing 
failure of objectives, nor any KTMs used to tackle these63. This seems to be mainly incomplete 
WISE reporting, as there is information in the RBMP. 

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 qualitative and quantitative cost-effectiveness analysis was 
carried out in both RBDs. Cost-effectiveness analysis was undertaken in the first cycle for all 
Article  11(3)(a)  and  Article  11(3)(b)(l)  type  measures,  but  not  supplementary  measures,  the 

latter being mainly of an administrative nature. In the second RBMP, the information reported 
to WISE indicated that a combination of qualitative and quantitative cost-effectiveness analysis 

was carried out in both RBDs. Therefore, this was examined further in RBMP and background 
documents  of  the  assessment  where  it  was  found  that,  apart  from  satisfying  existing  legal 

requirements  -  Article  11(3)(a)  measures  -  prioritisation  of  measures  was  described  in  detail 
and is broadly based on cost effectiveness in the following order of priority:  

First: Measures which serve to achieve more than one objective, for example, objectives of the 
WFD as well as the Floods Directive and/or protected areas (NATURA 2000);  

Second: Multiple effectiveness in terms of Quality Elements (scoring system zero to ++++ for 
physico-chemical,  biological,  and  hydromorphological  quality  elements,  as  well  as  chemical 

quality) and reduction or elimination of multiple pressures; and 

3rd:  Acceptability  of  a  measure,  which  means  early  implementation  and  therefore  also  early 

effectiveness.  

62 Luxemburg noted that some information related to some indications will be described in the next RBMP, when 

further monitoring results are available 

63 Luxembourg clarified subsequently that KTM 21 and KTM 22 have been reported in table “KTM” and these 2 

KTM will help tackling pollution related to RBSP as well as priority substances. 

104 

 
 
                                                      
The measures  were  grouped as in  the first  cycle  in  terms  of the most important  pressures on 

water  bodies  in  Luxembourg,  that  is,  (i)  Urban  Water  Management  (mainly  wastewater 
collection  and  treatment),  (ii)  Hydromorphological,  (iii)  Agricultural,  and  (iv)  Groundwater 

Protection.  Further  prioritisation  was  described  in  terms  of  these  groups  of  measures,  for 
example,  the  priority  in  “Urban  Water  Management”  was  the  introduction  of  biological 

wastewater  treatment  where  not  already  in  place,  and  the  top  priority  in  “Groundwater 
Protection”  was  the  protection  of  the  quality  of  groundwater  used  for  public  drinking  water 

supply.  

The above information applies nationally (Rhine RBD and Meuse RBD, but the latter has no 

groundwater bodies). 

A  critical  factor  in  the  success  of  the  implementation  of  the  Programme  of  Measures  is  the 

availability  of  funding  to  support  the  investments  required.  Whilst  in  the  first  cycle  costs  of 
basic measures were clearly identified as investment costs and maintenance costs up to 2027 

(except for agriculture), these have not been reported for the  second cycle (Annex 0 explains 
that cost data has not been gathered at river basin district level). Information regarding costs of 
measures at the national level is included in the RBMP. 

A  clear  financial  commitment  has  been  secured  for  the  implementation  of  Programme  of 
Measures in both RBDs. On a sectoral basis, commitments have been secured for agriculture, 

urban,  hydropower  and  flood  protection  in  both  RBDs.  However,  industry,  transport,  energy 
and  aquaculture  are  indicated  as  not  relevant,  although  some  significant  pressures  relate  to 

industry and transport.  

In  relation  to  co-ordination  with  the  Marine  Strategy  Framework  Directive64,  Luxembourg 
reported that as a land-locked country co-ordination is not relevant.  

The RBMP and Floods Directive Flood Risk Management Plan have not been integrated into 

single plans and no joint consultation of RBMP and Flood Risk Management Plan was carried 
out. However, the objectives and requirements of the Floods Directive have been considered in 

the  second  RBMP  and  Programme  of  Measures.  Luxembourg  also  indicated  that  win-win 
measures  in  terms  of  achieving  the  objectives  of  the  WFD  and  Floods  Directive,  drought 

management  and  use  of  Natural  Water  Retention  Measures  have  been  included  in  the 
Programme  of  Measures;  the  design  of  new  and  existing  structural  measures,  such  as  flood 

defences,  and  storage  dams,  has  been  adapted  to  take  account  of  WFD  Environmental 

64   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  

105 

 
 
                                                      
Objectives,  and  clear  financial  commitments  have  been  secured  for  the  implementation  of 

Programme of Measures in the flood protection sector.  

WFD  Article  9(4)  has  not  been  applied  to  impoundment  for  flood  protection  and  as  such  it 

would  be  an  activity/use  which  should  be  subject  to  cost  recovery  under  Article  9,  where 
relevant. 

9.1.2

 Measures related to other significant pressures 

Other significant  pressures were not  reported separately, although some were included in  the 

overall pressures, such as introduced species and diseases, and other anthropogenic pressures 
but no KTMs were reported for these.  

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  KTM.  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 

KTMs  in  Luxembourg.  Also  shown  is  the  number  of  RBDs  for  which  the  KTM  has  been 
reported65. Table 9.2 then summarises the type of basic measures associated with the national 
measures mapped against the Key Type of Measure. 

65   Luxembourg clarified subsequently that an error was made in the reporting and that the same information was 

provided for both RBDs even though some measures are not relevant for the Meuse RBD 

106 

 
 
 
 
                                                      
Table 9.1 

Mapping  of  the  types  of  national  measures  to  Key  Types  of  Measure  in 

Luxembourg  

Key Type of Measure 

KTM1 - Construction or upgrades of wastewater 
treatment plants 

KTM10 - Water pricing policy measures for the 
implementation of the recovery of cost of water 
services from industry 

KTM11 - Water pricing policy measures for the 
implementation of the recovery of cost of water 
services from agriculture 

KTM12 - Advisory services for agriculture 

KTM13 - Drinking water protection measures (e.g. 
establishment of safeguard zones, buffer zones 
etc) 

KTM14 - Research, improvement of knowledge 
base reducing uncertainty 

KTM17 - Measures to reduce sediment from soil 
erosion and surface run-off 

KTM2 - Reduce nutrient pollution from agriculture 

KTM21 - Measures to prevent or control the input 
of pollution from urban areas, transport and built 
infrastructure 

KTM22 - Measures to prevent or control the input 
of pollution from forestry 

KTM23 - Natural water retention measures 

KTM3 - Reduce pesticides pollution from 
agriculture. 

KTM4 - Remediation of contaminated sites 
(historical pollution including sediments, 
groundwater, soil) 

KTM5 - Improving longitudinal continuity (e.g. 
establishing fish passes, demolishing old dams) 

KTM6 - Improving hydromorphological conditions 
of water bodies other than longitudinal continuity 

KTM7 - Improvements in flow regime and/or 
establishment of ecological flows 

KTM8 - Water efficiency, technical measures for 
irrigation, industry, energy and households 

KTM9 - Water pricing policy measures for the 
implementation of the recovery of cost of water 

107 

National 
basic 
measures 

National 
supplementary 
measures 

Number 
of RBDs 
where 
reported 

13 

5 

1 

1 

1 

27 

48 

7 

1 

25 

3 

12 

3 

4 

1 

2 

2 

4 

8 

1 

3 

9 

2 

2 

4 

3 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

2 

 
 
 
 
 
 
 
 
 
 
 
 
Key Type of Measure 

services from households 

KTM99 - Other key type measure reported under 
Programme of Measures - (Administrative) 
measures which should help achieving the good 
status or facilitate the implementation of other 
measures from the Programme of Measures 

KTM99 - Other key type measure reported under 
Programme of Measures - Construction of 
stormwater storage basins, stormwater overflow 
tanks and combined sewer storage tanks 

KTM99 - Other key type measure reported under 
the Programme of Measures - Measures related 
to groundwater 

National 
basic 
measures 

National 
supplementary 
measures 

Number 
of RBDs 
where 
reported 

12 

2 

4 

8 

3 

2 

2 

2 

2 

Total number of Mapped Measures 

158 

63 

Source: WISE electronic reporting  

108 

 
 
 
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Table 9.2 

Type of basic measure mapped to Key Type of Measures in Luxembourg  

Key Type of Measure 

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KTM1 - Construction or upgrades of wastewater treatment plants 
KTM10 - Water pricing policy measures for the implementation of the recovery 
of cost of water services from industry 
KTM11 - Water pricing policy measures for the implementation of the recovery 
of cost of water services from agriculture 
KTM13 - Drinking water protection measures (e.g. establishment of safeguard 
zones, buffer zones etc) 
KTM17 - Measures to reduce sediment from soil erosion and surface run-off 
KTM2 - Reduce nutrient pollution from agriculture 
KTM21 - Measures to prevent or control the input of pollution from urban 
areas, transport and built infrastructure 
KTM22 - Measures to prevent or control the input of pollution from forestry 
KTM3 - Reduce pesticides pollution from agriculture. 
KTM5 - Improving longitudinal continuity (e.g. establishing fish passes, 
demolishing old dams) 
KTM6 - Improving hydromorphological conditions of water bodies other than 
longitudinal continuity 

KTM7 - Improvements in flow regime and/or establishment of ecological flows 
KTM8 - Water efficiency, technical measures for irrigation, industry, energy and 
households 
KTM9 - Water pricing policy measures for the implementation of the recovery 
of cost of water services from households 

KTM99 - Other key type measure reported under PoM 

10 

1 

1 

3 

27 
48 

1 
24 

8 
18 

8 

5 

1 

1 

27 
48 

1 
24 

3 

12 

3 

4 

1 

1 

8 

3 

1 

Key 

Source: WISE electronic reporting 

‘Accidental pollution’ = Article 11(3)(l): Any measures required to prevent significant losses of pollutants from technical installations and to prevent and/or reduce the impact of 
accidental pollution incidents. 
‘Controls water abstraction’ = Article 11(3)(e): Controls over the abstraction of fresh surface water and groundwater and impoundment of fresh surface waters including a register or 

109 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
registers of water abstractions and a requirement for prior authorisation of abstraction and impoundment. 
‘Cost recovery water services’ = Article 11(3)(b): Measures for the recovery of cost of water services (Article 9). 
‘Efficient water use’ = Article 11(3)(c): Measures to promote efficient and sustainable water use. 
‘Hydromorphology’ = Article 11(3)(i): Measures to control any other significant adverse impact on the status of water, and in particular hydromorphological impacts. 
‘Nitrates’ = Nitrates Directive (91/676/EEC). 
‘Point source discharges’ = Article 11(3)(g): Requirement for prior regulation of point source discharges liable to cause pollution. 
‘Pollutants diffuse’ = Article 11(3)(h): Measures to prevent or control the input of pollutants from diffuse sources liable to cause pollution. 
‘Pollutants direct groundwater’ = Article 11(3)(j): Prohibition of direct discharge of pollutants into groundwater. 
‘Protection water abstraction’ = Article 11(3)(d): Measures for the protection of water abstracted for drinking water (Article 7) including those to reduce the level of purification 
required for the production of drinking water. 
‘Recharge augmentation groundwaters’ = Article 11(3)(f): Controls, including a requirement for prior authorisation of artificial recharge or augmentation of groundwater bodies. 
‘Urban Waste Water’ = Urban Waste Water Treatment Directive (91/271/EEC). 

110 

 
 
9.1.4

 Pressures for which gaps to be filled to achieve WFD objectives 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. 

Luxembourg  has  not  defined  indicator  values  for  any  of  the  significant  pressures  identified, 
and  no  gap  analyses  have  been  reported  for  the  different  reporting  cycles.  Luxembourg 

indicated in their Annex 0 that this is due to the relevant data being unavailable.  

9.2  Main changes in implementation and compliance since the first cycle 

The level of implementation of the first cycle of Programme of Measures in the two RBDs in 

Luxembourg  was  reported  as  “some  measures  completed”.  Obstacles  in  terms  of  lack  of 
measures were reported for both RBDs as “Governance”, “Lack of finance”, and “Other” (land 

availability, complex land purchasing procedures, stakeholder engagement/deadlock). Progress 
does seem to have been made in identifying significant pressures and linking at least some of 

these to KTMs and national measures.  

The  catalogue  of  measures  was  reviewed  and  revised  on  the  basis  of:  (i)  the  revised  status 

analysis  made  during  2013-2014,  (ii)  the  pressures  described  in  this  analysis,  and,  (iii) 
additional  requirements,  such  as  the  Floods  Directive,  and  included  a  public  consultation. 

Based on the status of implementation, measures which were not expected to be completed by 
2015 were included in the revised programme of measures, and a considerable number of new 

measures (not included in the 2009 programme of measures) were added.  

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

reported necessary and already adopted. 

9.3  Progress with Commission recommendations 

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

111 

 
 
  Recommendation:  The  RBMPs  should  be  clearly  structured  and  accessible  to  the  public 
and relevant stakeholders. It would also be advisable to clearly distinguish the information 
and  the  measures  that  are  relevant  for  the  Rhine  RBD,  for  the  Meuse  or  for  both.  This 

transparency  within  a  clear  governance  structure  will  encourage  public  participation  in 
both  the  development  and  delivery  of  necessary  measures  to  deliver  sustainable  water 

management. 

Assessment:  Improvements  have  been  made  in  distinguishing  more  clearly  between 

measures  relevant  to  the  Rhine,  Meuse,  or  both  RBDs.  This  recommendation  has  been 
fulfilled. 

  Recommendation: 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. 

Assessment: Progress has been made in identifying significant and other pressures, at least 
at  RBD  level,  and  linking  at  least  some,  but  not  all  of  these  to  measures.  This 

recommendation  has  been  partially  fulfilled  (further  information  may  be  obtained  from 
Chapter 2). 

  Recommendation: Meaningful information regarding the scope, the timing and the funding 
of  the  measures  should  be  included  in  the  PoM  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  increase 

transparency  on  the  planned  actions  for  the  achievement  of  the  environmental  objectives 
set out in the WFD.  

Assessment:  Although  there  is  a  comprehensive  listing  of  basic  and  supplementary 
measures,  not  all  seem  to  be  operational,  although  specific  pressures  were  reported 
(although this may be in part due to a WISE reporting problem). This recommendation has 
been partially fulfilled. 

  Recommendations: Ensure that the RBMPs clearly identify the gap to good status, and that 
the  Programme  of  Measures  are  designed  and  implemented  to  close  that  gap  with 
transparent and meaningful information regarding the scope, the timing and the funding of 
the  measures;  Improve  knowledge  about  the  link  between  pressures  and  impacts  in 

designing and making operational the measures for the second RBMPs in order to: refine 
the  significance  of  the  pressures  by  quantifying  those  which  are  likely  to  prevent  the 

112 

 
 
achievement of environmental objectives; apportion pressures by their source and identify 

the  responsible  sectors/areas;  and  assess  the  reduction  in  pressures  required  to  achieve 
environmental objectives.(cid:157)  

Assessment: It is not possible to judge how and when WFD objectives will be met due to 
the complete absence of gap indicators and gap analyses for the different reporting cycles. 

Although financial commitments have been secured for most relevant sectors, there is not 
for  all  the  measures  an  indication  of  timing  and  funding  of  measures.  (some  information 

regarding funding of measures is provided in chapter 9 of the RBMP). With regard to the 
measures  contained  in  the  detailed  programme  of  measures,  information  regarding  the 

implementation  date  of  each  measures  is  described  in  annex  20  of  the  RBMP.  These 
recommendations have not been fulfilled.  

113 

 
 
 
 
Topic 10

  Measures related to abstractions and water scarcity  

10.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle 

10.1.1

  Water exploitation and trends  

Water  abstraction  pressures  are  not  reported  as  relevant  for  Luxembourg.  The  Water 
Exploitation  Index  +  is  not  calculated,  and  water  quantity  data  have  not  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  RBMP  does  not  include  a 

water resource allocation and management plan.  

10.1.2

  Main uses for water consumption  

No data have been reported for the uses of water consumption, as water quantity pressures are 
not reported as significant.  

10.1.3

  Measures related to abstractions and water scarcity  

Regarding  basic  measures  -  Article  11(3)(e)  -  in  Luxembourg  there  is  a  concession 

authorisation and/or permitting regime to control water abstractions and impoundment, but no 
register of impoundments. Small abstractions are not exempted from these controls. 

Measures promoting efficient and sustainable water use - basic measure Article 11(3)(c) - were 
implemented in the previous cycle, and new measures and/or significant changes are planned 

for the second cycle. 

The  reported  information  indicates  that  measures  for  the  prior  authorisation  of  artificial 

recharge  or  augmentation  of  groundwater  bodies  -  Article  11(3)(f)  had  been  implemented  in 
the previous cycle, and no new measures or significant changes are planned for the next period.  

Complementary measures under KTMs are not reported for addressing abstraction pressures. 

Water reuse is not foreseen as a measure. 

114 

 
 
 
 
10.2 Main changes in implementation and compliance since the first cycle 

There are no significant changes to report. 

10.3 Progress with Commission recommendations 

There  are  no  Commission  recommendations  based  on  the  first  RBMP  and  Programme  of 

Measures. 

115 

 
 
 
 
 
Topic 11

  Measures related to pollution from agriculture  

11.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle 

Luxembourg  has  stated  in  the  RBMP  that  diffuse  pollution  pressures  from  the  agriculture 

sector are assessed in the Rhine and Meuse RBDs. However the reported information to WISE 
states that there are no pollution pressures from agriculture in the Meuse RBD66.  

Measures  matching  the  identified  pressures.  KTM  2  -  Reduce  nutrient  pollution  from 
agriculture,  KTM  3  -  Reduce  pesticides  pollution  from  agriculture,  KTM  12  -  Advisory 

services for agriculture, KTM 13 - Drinking water protection measures (e.g. establishment of 
safeguard zones, buffer zones etc.), KTM 17 - Measures to reduce sediment from soil erosion 

and  surface  run-off,  and  KTM  23  -  Natural  water  retention  measures  are  applied  in  both 
RBDs67.  

In relation  to  KTM 13  -  "Drinking water protection  measures  (for example, establishment of 
safeguard zones, buffer zones etc.)", since the first RBMP five drinking water protection zones 

have been designated near groundwater bodies, with specific Grand-ducal Regulations for each 
protection  zones68.  These  regulations  also  set  out  the  measures/restrictions  that  apply  in  3-4 
different zones around the drinking water abstraction point. Another seven protection zones are 
in  the  process  of  being  designated  through  regulations,  and  a  further  80  are  still  provisional 

designations under technical investigations (it seems that all were provisional designations in 
the  first  cycle).  For  surface  water  bodies,  there  is  only  one  relevant  protection  zone 

(impoundment reservoir Obersauer Stausee) under the law of 27th May 1961 and the Grand-
ducal  Regulation  of  16  December  2011,  which  also  sets  out  the  measures/restrictions  at  and 

around the site. All abstractions for drinking water supply are in the Rhine RBD and therefore 
there are no drinking water protection zones in the Meuse RBD. 

The  implementation  of  basic  measures  related  to  Article  11(3)(h)  for  the  control  of  diffuse 
pollution from agriculture at the source is ensured in all RBDs. According to WISE the rules 

66   Luxembourg subsequently clarified that pressures from agriculture have been assessed at the level of the water 
bodies  (see  annex  5  of  the  RBMP).  However,  the  used  national  category  “agricultural  and  forestry-related 
activity”  didn’t  match  the  “pressure  types”  used  in  WISE,  so  they  have  been  reported  as  “2.10  Diffuse  – 
Other” type. 

67   Luxembourg subsequently clarified that an error was made in the reporting and that the same information was 

provided for both RBDs even though some measures are not relevant for the Meuse RBD. 

68   Luxembourg  subsequently  clarified  that  further  safeguard  zones  have  been  or  will  be  established  but  the 
process takes  several  years.  By  December 2018 78 % of the  groundwater resources  used for drinking  water 
purposes will be protected by safeguard zones. 

116 

 
 
                                                      
applied  are  differentiated  for  different  parts  of  the  RBD.  However,  information  on  what  the 

differences are and how they relate to different scales of pressures/impacts was not available in 
the  RBMP.  Supplementary  measures  are  applied  in  both  RBDs.  General  binding  rules  for 

microbiological/bacteriological  pollution,  nitrates,  organic  pollution,  pesticides  and 
phosphorus  to  control  diffuse  pollution  from  agriculture  are  set  and  applied  in  all  RBDs. 

Sediments are not controlled. 

There  are  a  large  number  of  agricultural  measures  which  apply  on  a  nationwide  basis;  both 

mandatory  and  voluntary.  The  focus  of  these  measures  is  to  tackle  diffuse  pollution  from 
agriculture  (mainly  nutrients  and  pesticides).  Point  source  pollution  is  dealt  with  by  existing 

legislation,  e.g.  discharge  permits,  including  minimum  requirements  according  to  Article 
11(3)(g),  and  measures  include  extending  those  which  are  mandatory  in  drinking  water 

protection zones to apply nationwide, for example the prohibition of pesticide applications near 
water courses. Other relevant measures aim at nutrient control in general or are mainly part of 

voluntary  initiatives,  such  as  the  Rural  Development  Programme.  The  RBMP  states  that 
measures under the Nitrates Directive and other legal requirements are insufficient to reach the 
objective of the good ecological status and other measures are required.  

The  RBMP  does  not  clearly  separate  the  measures  in  terms  of  mandatory  and  voluntary 
measures or their effectiveness.69  The catalogue of agricultural  measures (listed in  Annex 19 
RBMP)  indicates  that  many  individual  measures  types  are  subject  to  regulations  without 
specifying  these.  Some measures  are  listed  as  both  mandatory  (in  the  case  of  drinking  water 

protection zones) and voluntary in other areas. Some measures are clearly indicated as part of 
voluntary initiatives, such as biological/organic farming (linked to compensation schemes and 

governed  by  regulations  once  participation  is  agreed),  but  for  some  measures  there  is  no 
information  whether  they  are  mandatory  or  voluntary.  Many  Measures  are  mainly  related  to 

Article 11(3)(d); there are no technical measures related to agriculture under Article 11(3)(h) 
or  Article  11(3)(g.  The  RBMP  states  that  these  are  administrative  measures,  i.e.  regulations. 

Mandatory measures include prohibition of fertiliser application on strips of land along water 
courses,  conditions  relating  to  fertiliser  application  equipment,  creating  additional  storage 

capacity  for  organic  fertiliser,  restrictions  on  livestock  numbers,  reductions  in  cereal 
production,  restrictions  on  nitrogen  fixing  crops  and  prohibition  of  ploughing  on  permanent 

grassland. 

Supplementary measures are listed separately  (Article 11(4) measures) and include voluntary 

measures relevant to agriculture, such as advice to farmers, and a “No Pesticides Action Plan”. 

69   Luxembourg stated that they have already planned to describe this in more in detail in the next RBMP. 

117 

 
 
                                                      
Some agricultural measures apply nation-wide, and some are targeted specifically to protected 

areas, especially drinking water protection zones or along water courses. 

Luxembourg did not report any indicators to measure the effectiveness of measures. It did not 

report  measures  to  assess  the  scale  of  measure  implementation  needed  and  the  progress  in 
implementation.70  It  reported  that  this  information  is  not  available.  This  indicates  that  the 
European Commission Recommendation was largely not taken up. 

As  regard  to  the  timing  of  the  measures,  the  RBMP  (Annex  18)  lists  agricultural  measures 

completed  or  partially  completed,  and  the  Catalogue  of  agricultural  measures  in  Annex  19 
indicates which measures  are relevant  in  the second cycle, but  there are  no completion dates 

indicated.  

Luxembourg  reported  that  financing  has  been  secured.  It  reports  information  on  investment 

needs  but  does  not  report  on  the  use  of  European  Union  funds  such  as  Rural  Development 
funds. National contributions to funding are provided, but there is no indication of the source. 

The  mechanisms  are  mainly  compensation  payments  linked  to  voluntary  initiatives,  e.g. 
amount  per  ha  per  annum  of  participating  land.  Mandatory  measures  are  carried  by  farmers 
(internalised costs). 

11.2 Main changes in implementation and compliance since the first cycle 

There have been no changes in implementation and compliance since the first cycle.71 

11.3 Progress with Commission recommendations 

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

requested action on the following: 

  Recommendation: Agriculture is indicated as exerting a significant pressure on the water 
resource in Luxembourg RBDs. However, the measures related to agriculture are mainly 
on a voluntary basis, which makes the strategy unlikely to deliver. A right balance between 

voluntary actions and a strong baseline of mandatory measures and rules needs to be set 

70   Luxembourg  has  subsequently  informed  the  Commission  that  the  progress  will  be  reported  in  the  dedicated 

reporting by the end of this year. 

71   Luxembourg  subsequently  clarified  that  especially  the  legal  framework  implementing  Council  Directive 
91/676/CEE  has  been  amended  several  times.  Also  the  delimitation  of  water  protection  areas  has  been 
strengthened  by  the  legal  framework.  Meanwhile  also  the  legislation  on  Greening,  Cross  Compliance  and 
Rural Development Programme have been implemented. 

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up.  This  should  be  developed  with  the  farmers'  community  to  ensure  technical  feasibility 

and acceptance. 

Assessment:  Luxembourg  has  consulted  the  farming  community  when  developing  the 

program of measures. Measures have also been discussed with the Ministry of Agriculture. 
The current Rural Development Program includes several voluntary measures, the Nitrate 

Action  Program  and  the  national  plant  protection  law  mandatory  measures.  Stricter 
mandatory measures are included in the program of measures in relation to zones used for 

drinking  water  abstraction.  Additional  mandatory  measures  are  also  implemented  or 
foreseen in nature protection areas. This recommendation has been implemented. 

  Recommendation: There needs to be a very clear baseline in the agriculture sector so that 
all  farmers  know  the  rules  this  can  be  adequately  advised  and  enforced  and  so  that  the 

authorities  in  charge  of  the  CAP  funds  can  adequately  set  up  Rural  Development 
programmes and cross compliance water requirements.  

Assessment: see above. 

  Recommendation:  Enhance  measures  to  tackle  pollution  by  nutrients  (nitrogen  and 
phosphorus) considering their impact on ecological status. Full consideration of the basin-
wide impact is needed in this respect (local and downstream up to transitional and coastal 

waters).  To  this  extent  Luxembourg  should  check  that  their  nutrient  standards  are 
consistent with biological requirements for the achievement of good status and provide a 

more  coherent  strategy  encompassing  WFD  with:  the  Nitrates  Directive  and  CAP  in 
agriculture  and  the  UWWT  Directive  in  urban  areas  In  particular,  it  is  expected  that 

RBMPs,  based  on  the  necessary  reduction  in  nutrient  load,  clearly  identify  the  extent  to 
which  the  measures  already  taken  under  the  implementation  of  ND  and  UWWTD 

contribute to the achievement of WFD objectives and which additional measures should be 
taken  to  actually  achieve  these  objectives.  A  clear  identification  of  basic  (mandatory) 

measures is expected to be made transparent both to the sectors and to the general public.  

Assessment: For measures see above. According to the RBMP nutrient standards have been 

revised during the Article 5 assessment. A gap assessment for nutrients is still lacking, but 
loads  coming  from  diffuse  sources  are  presented  in  the  RBMP.  The  contribution  of 

different policies towards the achievement of the good ecological  status/potential has not 
been assessed. Therefore the recommendation has been partly fulfilled.  

  Recommendation:  Define  measures  targeted  to  agriculture  with  an  appropriate  level  of 
detail  to  ensure  their  uptake  by  farmers  and  their  inspection  by  relevant  agencies.  The 

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RBMPs  are  expected  to  make  a  clear  distinction  between  mandatory  measures  and 

voluntary ones that will be funded under the EARDF. 

Assessment: It is not fully clear from the RBMP which measures are voluntary and which 
are  mandatory;72  they  have  made  no  progress  on  assessing  the  effectiveness  of  measures 
and  Luxembourg  has  developed  no  indicators  to  measure  what  will  be  achieved  by 
mandatory  measures73  and  the  gaps  being  filled  by  supplementary  measures.  There  is  a 
general statement that the measures taken under the Nitrates Directive and other legislation 

are  not  enough,  but  there  are  no  technical  measures  under  Article  11(3)(h),  although 
regulations under Article 11(3)(h) are mentioned (but not specified). Financing sources of 

measure are provided.  

Recommendation:  Review  the  regulation  of  the  use  of  pesticides  in  order  to  effectively 

reduce  current  levels  of  contamination  of  both  rivers  and  groundwater,  making  clear 
linkages with the implementation of the Directive on the Sustainable Use of Pesticides. 

Assessment:  According  to  the  RBMP  Luxembourg  has  adopted  on  the  of  19  December 
2014  a  law  on  plant  protection  products,  transposing  Directive  2009/128/EC  of  the 
European Parliament and of the Council of 21 October 2009 establishing a framework for 

Community  action  to  achieve  a  use  of  the  pesticides  compatible  with  sustainable 
development;  and  implementing  certain  provisions  of  Regulation  (EC)  No  1107/2009  of 

the European Parliament and of the Council of 21 October 2009 concerning the placing on 
the  market  of  plant  protection  products  and  repealing  Directives  79/117  /  EEC  and 

91/414/EEC of the Council. The recommendation has been implemented. 

72   At  the  stage  of  writing  the  RBMP,  this  could  not  easily  be  done  because  Luxembourg  had  chosen  to  use 
Article 28 as well as Article 30 of EU-Regulation 1305/2013/EC and it depends on the defined zone if article 
28 or 30 has to be applied. In addition, the definition of the zones, especially the water protection areas, is an 
ongoing process. 

73   This statement does not reflect the realty. There are indicators in place, for example the assessment run under 

91/676/CEE or 1305/2013/EC, and a new model is under development. 

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Topic 12

  Measures  related  to  pollution  from  sectors  other  than 

agriculture  

12.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle 

In  the  context  of  this  topic,  pollution  is  considered  in  terms  of  nutrients,  organic  matter, 
sediment,  saline  discharges  and  chemicals  (Priority  Substances,  River  Basin  Specific 

Pollutants,  groundwater  pollutants  and  other  physico-chemical  parameters)  arising  from  all 
sectors  and  sources  apart  from  agriculture.  Key  types  of  measures  (KTM)  are  groups  of 

measures identified by Member States in their Programmes of Measures which target the same 
pressure or purpose. A KTM could be one national measure but would typically comprise more 

than  one  national  measure.  The  same  individual  measure  can  also  be  part  of  more  than  one 
KTM  because  it  may  be  multipurpose,  but  also  because  the  KTMs  are  not  completely 

independent of one another. 

KTMs  relevant  to  non-agricultural  sources  of  pressures  causing  failure  of  WFD  objectives 
have not been reported in the context of those pressures74. 

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). 
Quantitative information on basic and supplementary  measures used to  tackle pollution from 

non-agricultural  sources  (number  of  measures  per  KTM)  is  missing  for  both  RBDs  in 
Luxembourg,  and  quantitative  information  on  basic  measures  to  tackle  pollution  from  non-

agricultural  sources  (number  of  measures  per  KTM)  has  not  been  reported  to  WISE  for  any 
measure types for either RBD in Luxembourg.75 

Luxembourg  has  clarified,  however,  that  there  are  measures  in  place  to  eliminate/reduce 
pollution from Priority Substances and other substances in both RBDs in Luxembourg. 

Basic measures under Article 11(3)(k) are reported to be in place for Priority Substances but 
the links between KTMs and the substances causing failure were not reported in WISE.  

74   Pressures  and  measures  had  been  reported.  However,  Luxembourg  did  not  report  the  link  between  them 

(showing a reporting gap related to KTMs). 

75   Luxembourg  subsequently  highlighted  that  KTMs  have  been  reported  and  these  include  non-agricultural 
measures, and they are also included in annex 19 of the RBMP. Yet, their link to pressures was not reported.  

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The  RBMP  states  that  measures  (other  than  basic  measures  to  control  point  sources 

(permitting) where relevant) are not  yet in place, pending further investigation of the sources 
(polycyclic  aromatic  hydrocarbons  are  probably  mainly  from  old/disused  industrial  or  waste 

sites,  diuron  (detected  but  not  causing  failure)  is  probably  a  result  of  inappropriate  disposal, 
whereas  isoproturon  is  expected  to  be  reduced  to  some  extent  as  a  result  of  a  usage  ban  in 

water protection zones,  already in place.  In addition, the RBMP indicates administrative and 
technical  measures  to  prevent  or  limit  the  discharge/input  of  pollutants  from  point  sources 

under  Article  11(3)(g),  and  diffuse  sources  under  Article  11(3)(h)  (administrative  measures 
only).  

No timescale is given for the completion of investigations and the subsequent introduction of 
appropriate  measures,  but  the  table  of  supplementary  measures  under  Article  11(4)  indicates 

how they should be prioritised. Measures include A30-15 - “Preparation of an Action Plan to 
investigate  and where necessary to  clean-up old/disused industrial or waste sites”, which has 

high priority and is on-going, and measure A33-15 –“investigative monitoring” which refers to 
obtaining further information on pressures, such as polycyclic aromatic hydrocarbons, labelled 
as  “high  priority”,  and  several  measures  to  deal  with  pesticides,  including  A5-15  – 

“Review/revision  of  the  National  Action  Plan  on  pesticides”  and  the  A6-15  -  “Campaign 
without pesticides”, both of which are high priority and on-going.  

As far as  measures for River Basin  Specific Pollutants  causing failure are concerned, copper 
and zinc have been identified as significant pressures on surface water in the Rhine RBD (zinc 

only in the Meuse RBD). The RBMP considers these to be mainly from industrial discharges, 
which  are  subject  to  administrative  measures  (permits)  but  indicates  that,  following  further 

monitoring, there may have to be stricter emission limits in industrial permits in future.  

No non-agricultural pollutants have been reported to WISE as causing failure of objectives in 

groundwater. 

Luxembourg  provided  more  detailed  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  (Basic  measures  Article  11(3)(g))  was  reported  for  both  RBDs  for  surface 

and groundwater. There is no register of waste water discharges in either RBD in Luxembourg. 
There are no thresholds below which waste water discharges do not require permits and are not 

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subject  to  registration76. Some direct  discharges to groundwater are authorised in  accordance 
with Article 11(3)(j) in both RBDs in Luxembourg. 

12.2 Main changes in implementation and compliance since the first cycle  

In the first RBMP, information on substance-specific measures was provided in largely general 
terms.  For  example,  “reductions  in  emissions  of  WFD  Annex  VIII,  IX  and  X  substances, 

including  reduced  application  and  emission  of  pesticides,  and  reductions  in  emissions  of 
Indeno(1,2,3-cd)pyrene and metazachlor in one water body”. Supplementary measures for all 
other substances were related mainly to diffuse agricultural sources, and included, for example, 

reduced application of pesticides and control of fertiliser application (to reduce nutrient input - 
nitrate, phosphorus) on a nationwide, although voluntary, basis. 

For the second RBMP,  basic measures  under  Article 11(3)(k)  are reported to  be in place for 
Priority  Substances  and  KTMs  are  not  linked  to  specific  substances  causing  failure    in  the 

WISE reporting as explained in Annex 0. No information is reported on the progress expected 
in  implementing  KTMs  between  2015  and  2027,  and  no  gap  indicator  is  reported,  as  also 

explained in Annex 0. 

12.3 Progress with Commission recommendations 

The  Commission  recommendations  based  on  the  first  RBMP  and  Programmes  of  Measures 
requested action on the following: 

  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 and adequate measures are put in place. 

Assessment:  In  terms  of  measures  for  pressures  from  non-agricultural  sources,  there  are 

measures  in  place  to  eliminate/reduce  pollution  from  Priority  Substances  and  other 
substances  in  both  RBDs  in  Luxembourg.  However,  they  have  not  been  reported  for  all 

individual  substances.  For  the  second  RBMP,  basic  measures  under  Article  11(3)(k)  are 
reported  to  be  in  place  for  Priority  Substances.  For  Priority  Substances  and  River  Basin 

Specific  Pollutants,  KTMs  were  not  linked  to  specific  substances  causing  failure  in  the 
WISE  reporting.  There  is  however  more  information  detailed  in  an  annex  to  the  RBMP 

76   Luxembourg subsequently clarified that there is an internal register of wastewater treatment plants (communal 
or industrial) according to the UWWTD. Additionally industrial discharges are registered in the E-PRTR.   

123 

 
 
                                                      
which includes measures such as A30-15 - “Preparation of an Action Plan to investigate and 

where necessary to clean-up old/disused industrial or waste sites”.  

Therefore, this recommendation is partially fulfilled in terms of measures for pressures from 

non-agricultural sources. 

  Recommendation:  Enhance  measures  to  tackle  pollution  by  nutrients  (nitrogen  and 
phosphorus) considering their impact on ecological status. Full consideration of the RBD-
wide impact is needed in this respect (local and downstream up to transitional and coastal 

waters). To this extent Luxembourg should check that their nutrient standards are consistent 
with  biological  requirements  for  the  achievement  of  good  status  and  provide  a  more 

coherent  strategy  encompassing  WFD  with  the  Urban  Wastewater  Directive,  in  urban 
areas. In particular, it is expected that RBMPs, based on the necessary reduction in nutrient 

load,  clearly  identify  the  extent  to  which  the  measures  already  taken  under  the 
implementation  of  Nitrates  Directive  and  Urban  Wastewater  Directive  contribute  to  the 

achievement of WFD objectives and which additional measures should be taken to actually 
achieve these objectives. A clear identification of basic (mandatory) measures is expected to 

be made transparent both to the sectors and to the general public. 

  Assessment:  Due  to  incomplete  reporting  to  WISE,  no  data  on  basic  and  supplementary 

measures  or  KTMs  is  available.  The  reported  data  include  KTM  1  –  “Construction  or 
upgrades of wastewater treatment plants", and the Programmes of Measures include several 

projects,  with  reference  to  the  Urban  Wastewater  Directive  and  nutrient  removal,  and 
including an indication of their effect on quality elements  (on a semi quantitative scale of 

zero  to  ++++),  with  the  biggest  effects  being  on  the  physico-chemical  quality  elements 
which  include  nutrients,  but  no  details  are  given  for  specific  substances.  The  annex 

containing  measures  also  includes  supplementary  measures  A21-15  to  extend  and  repair 
local waste water collection networks, listing these as high priority and on-going. However, 

what  is  missing  is  a  gap  analysis  for  nutrients,  which  has  not  been  provided  (nor  for  any 
other  pollutants)  in  the  electronic  reporting,  nor  in  the  RBMP  itself.  Therefore,  this 
recommendation is considered partially fulfilled. 

124 

 
 
 
 
Topic 13

  Measures related to hydromorphology 

13.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle 

Significant hydromorphological pressures are reported in both RBDs. For the largest share of 

water bodies affected by significant hydromorphological pressures, the specific sector linked to 
these  pressures  is  either  unknown  or  obsolete.  In  only  very  few  water  bodies,  significant 

hydromorphological  pressures  are  linked  to  either  hydropower  or  the  transport/navigation 
sector. 

As concerns the WISE reporting,  Luxembourg subsequently informed that information  could 
not  be  reported  on  indicators  concerning  pressure  gaps  and  indicators  on  KTMs  for  tackling 

significant pressures, because the respective data was not available. Although no information is 
available  with  regard  to  whether  measures  are  fully  operational  or  not,  according  to 

information  in  the  second  RBMP,  hydromorphological  measures  are  planned  for  the  second 
cycle. 

The specific hydromorphological measures planned include fish ladders and bypass channels, 
habitat restoration, sediment management, restoration of bank and bed structures, the removal 

of  physical  structures,  setting  ecological  flows,  and  floodplain  inundation.  Supplementary 
measures include revision of the water law of  Luxembourg to  set  minimum  ecological  flows 

and to allow the state to be in charge of hydromorphological measures (high priority, ongoing), 
and simplification of the process of implementing hydromorphological measures.  

In  terms  of  basic  measures  to  tackle  hydromorphological  pressures,  there  is  an  authorisation 
and/or  permitting  regime  in  place  to  control  physical  modifications  in  both  RBDs,  which 

covers  changes  to  the  riparian  area  of  water  bodies  according  to  WFD  Article  11(3)(i). 
However, there is no register of physical modifications of water bodies in place. 

Overall  management  objectives  and  quantitative  objectives  in  terms  of  restoring  river 
continuity have been set. In addition, the design of new and existing structural measures, such 
as flood defences, storage dams and tidal barriers, is reported to have been adapted to take into 

account WFD objectives in both RBDs. 

Win-win  measures  in  terms  of  achieving  the  objectives  of  the  WFD  and  Floods  Directive, 

drought  management  and  use  of  Natural  Water  Retention  Measures  are  included  in  the 

125 

 
 
Programme  of  Measures  of  both  RBDs.  However,  due  to  incomplete  reporting,  KTM  23  - 

"Natural water retention measures" is not reported to tackle any significant pressures. 

Ecological flows have not been derived for the relevant water bodies but there are plans to do it 

during  the  second  cycle.  With  respect  to  ecological  flows,  a  new  supplementary  measure  is 
planned  for  the  second  cycle,  namely  to  revise  the  Water  Law  to  set  minimum  ecological 

flows.    The  second  RBMP  also  notes  that  studies  are  still  ongoing  to  establish  appropriate 
minimum  ecological  flows  and  should  become  available  in  the  second  cycle  to  support  the 

revision of the Water Law. The implementation of measures on minimum flow is scheduled to 
take place by 2021. 

No  conclusion  can  be  drawn  on  the  level  of  ambition  in  terms  of  tackling  significant 
for  significant 
hydromorphological  pressures. 

Indicators  on 

the  gap 

to  be 

filled 

hydromorphological  pressures  and  KTM  value  indicators  are  not  reported,  as  the  respective 
data are not available. 

13.2 Main changes in implementation and compliance since the first cycle 

The  second  RBMP  summarises  progress  on  hydromorphological  measures  compared  to  the 
first  RBMP.  30  of  the  measures  proposed  in  the  first  RBMP  have  been  implemented  (fish 

ladders and re-naturalisation projects). A further 97 measures proposed in the first RBMP are 
in  the  process  of  being  implemented:  these  mainly  comprise  fish  ladders,  re-naturalisation 

projects,  and  one  measure  to  regulate  the  minimum  ecological  flow.  Some  delays  have  been 
occurred for various reasons, including planning procedures, public acceptability of measures, 

property  rights  and  right  of  way,  and  limited  resources  and  finances.  F  measures  on  dams, 
barriers or locks to increase river flow continuity have been completed, and another 30 are in 

progress.  In  addition  to  the  measures  proposed  in  the  first  cycle,  another  48  measures  have 
either been completed or are in progress. However, analyses of the gap that needs to be closed 

are missing. 

All  measures  which  were  not  completed  by  the  end  of  2015  are  included  in  the  second 

Programme  of  Measures.  Furthermore,  the  level  of  detail  provided  in  the  second  RBMP  on 
measures is far higher than in the first RBMP. A catalogue of hydromorphological measures is 

used which includes a semi-quantitative effectiveness assessment for each measure type on the 
different  quality  elements,  as  well  as  an  indication  of  the  relevance  to  the  Floods  Directive. 

The catalogue also includes the cost of the measures. 

126 

 
 
13.3 Progress with Commission recommendations 

There  were  no  Commission  recommendations  based  on  the  first  RBMP  and  Programme  of 
Measures. 

127 

 
 
 
 
Topic 14

  Economic analysis and water pricing policies  

14.1 Assessment of implementation and compliance with WFD requirements 
in  the  second  cycle  and  main  changes  in  implementation  and 
compliance 

As in the first cycle, the only water services that have been defined for Article 9 purposes are 
public drinking water supply (abstraction, treatment and distribution) and waste water services 

(collection and treatment).  

A  national  approach  for  the  calculation  of  cost  recovery  rates  is  used  via  a  harmonised 

calculation  method,  but  so  far  the  method  has  not  been  applied  by  all  municipalities.  Cost 
recovery  figures  have  been  gathered  nationally  (from  the  municipal  authorities)  and  are 

presented  at  national  level  as  total  costs  and  also  as  costs  after  geographical  adjustment  and 
after  economic  adjustments, separately  for public water supply  and waste water services. No 

sectoral disaggregation details were provided for costs and cost recovery. 

The RBMP states that the WFD principle of cost recovery and the "Polluter Pays Principle" are 

incorporated into the Luxembourg Water Law.  

Information on the incentive function of water pricing is rather limited.  The incentive function 

is reflected in the water pricing structure, which includes fixed and variable tariffs. Tarification 
for  households  is  emphasizing  on  the  variable  part  (80  %,  €/m3)  to  encourage  water  saving. 

Industries on the other hand have a higher fixed part to compensate for a higher pollution. 

Resource  costs  are  not  considered  relevant,  since  all  six  groundwater  bodies  are  in  good 
quantitative status. Environmental costs are based on the cost of measures.  

The economic analysis has been redone completely in order to better satisfy the requirements 
of  the  Common  Implementation  Strategy  Guidance  Document77.  In  particular,  the  water 
pricing policy has been presented in more depth, a baseline scenario has been developed and 
the issue of environmental and resource cost recovery has also been addressed in depth. 

14.2 Progress with Commission recommendations 

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

requested action on the following: 

77   https://circabc.europa.eu/sd/a/cffd57cc-8f19-4e39-a79e-20322bf607e1/Guidance%20No%201%20-

%20Economics%20-%20WATECO%20(WG%202.6).pdf  

128 

 
 
                                                      
  Recommendation:  Luxembourg  should  provide  the  calculation  of  contribution  of 
different water uses disaggregated into at least households, agriculture and industry to 
cost  recovery  of  water  services,  in  accordance  with  the  requirements  of  Article  9.  In 

case  Luxembourg  applies  the  flexibility  provisions  of  Article  9(4),  Luxembourg 
authorities should provide required justifications. 

  Recommendation: The cost-recovery should address a broad range of water services, 
including  impoundments,  abstraction,  storage,  treatment  and  distribution  of  surface 

waters,  and  collection,  treatment  and  discharge  of  waste  water,  also  when  they  are 
'self-services', for instance self-abstraction for agriculture. The cost recovery should be 

transparently  presented  for  all  relevant  user  sectors,  and  environment  and  resource 
costs 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. 

  Recommendation:  Provide  information  on  how  the  polluter  pays  principle  has  been 

taken into account in the RBMPs. 

  Recommendation: Provide a more complete definition of water services and a proper 
recovery  of  cost  disaggregated  into  the  different  uses  to  contribute  to  the  objectives, 
especially  when  fully  accounting  for  environmental  and  resource  costs  for  services 

creating a pressure on water bodies. 

Assessment: The only water services that have been defined for Article 9 purposes are 

public drinking water supply (abstraction, treatment and distribution) and waste water 
services  (collection  and  treatment).  The  definition  of  water  services  is  identical  to 

Article  2(38)  of  the  WFD,  i.e.  water  services  mean  all  services  which  provide,  for 
(a)  Abstraction, 
households,  public 

institutions  or  any  economic  activity: 

impoundment, storage, treatment and distribution of surface water or groundwater, and 
(b)  waste-water  and  rainwater  collection  and  treatment  facilities  which  subsequently 
discharge into surface water.  

There is no "broader" definition of water services, such as including self-abstraction by 

farmers.  The  relevant  sectors  causing  the  most  significant  pressures  have  been 
identified as households, industry, and agriculture. 

Although significant pressures were also identified in the baseline scenario from freight 

navigation  and  hydroelectricity  (mainly  hydromorphological  alterations)  and  other 
(airport  as  a  source  of  point  source  pollution),  these  pressures  are  reported  to  affect 

129 

 
 
only a small number of water bodies. This seems to be the reason for not defining these 

other activities as water services.  

Luxembourg did not apply the flexibility provisions of Article 9(4). 

A national approach for the calculation of cost recovery rates is used via a harmonised 
calculation method which has been made available by the National Water Management 

Agency  to  municipalities,  but  so  far  the  method  has  not  been  applied  by  all 
municipalities.  The  harmonised  calculation  method  includes  all  costs  for  planning, 

construction, operation (staff and material) and maintenance of the entire water supply 
and waste water infrastructure, as well as depreciation and geographical and "economic 

adjustments".  

The  RBMP  states  that  the  WFD  principle  of  cost  recovery  and  the  "Polluter  Pays 

Principle"  are  incorporated  into  the  Luxembourg  Water  Law.  On  this  basis,  it  is 
explained  that  Luxembourg  is  working  towards  full  cost  recovery  of  public  water 

supply and waste water services in the sectors: households, industry and agriculture. 

Cost  recovery  figures  have  been  gathered  nationally  (from  the  municipal  authorities) 
and  are  presented  at  national  level  as  total  costs  and  also  as  costs  after  geographical 

adjustment  and  after  economic  adjustments,  separately  for  public  water  supply  and 
waste  water  services.  Whilst  the  aim  is  100  %  cost  recovery,  the  most  recent  data 

shows  overall  cost  recovery  of  about  80  %  for  both  public  water  supply  and  waste 
water services  in  2012, which has been increasing steadily from about  50 % in 2008. 

These figures relate to costs after geographical and economic adjustments; but for the 
total costs the recoveries are lower: 73 % for public water supply and 61 % waste water 

services.  Whilst public water supply and waste water volumes are shown for the years 
2008-2012  for  each  of  the  three  sectors  households,  industry  and  agriculture,  no 

sectoral disaggregation details were provided for costs and cost recovery. 

Information on the incentive function of water pricing is rather limited. Water charges 

are only partially based on volume of water used, that is, there is a fixed charge and a 
variable  usage  charge:  for  households  the  variable  cost  is  high  at  80  %  in  order  to 

encourage water saving. For industry the fixed charge is comparatively high, at 70 %, 
and for agriculture the fixed charge is 60 %. Wastewater charges (in terms of volume) 

are linked to drinking water usage. 

Furthermore,  the  charges  for  water  services  include  national  taxes  imposed  on  water 

abstraction  and  waste  water  production  to  address  environmental  and  resource  costs. 

130 

 
 
Two  water  taxes  are  in  place,  set  at  national  level:  one  is  a  water  abstraction  charge, 
based on volume and fixed by the national Water Law (10 cent per m3), and the other a 
waste  water  tax,  which  is  set  annually  by  a  national  Regulation  (in  2013:  16  %  m3 
discharged  into  surface  waters).  These  charges  are  paid  by  the  water  a  service  sector 
(municipalities), and ultimately by their customers once 100 % cost recovery has been 

achieved, but also by industry where the waste water tax is based on pollutant load. The 
revenues  go  into  a  national  water  management  fund,  which  contributes  to  water 

management projects, for example, contributions to initial investment costs for projects 
in the area of waste water treatment, rain water management, water protection and re-

naturalisation. The funding of projects is governed by the Water Law. Resource costs 
are  not  considered  relevant,  since  all  six  groundwater  bodies  are  in  good  quantitative 

status.  

Environmental costs are based on the cost of measures. These are presented in terms of 

(i)  Hydromorphological  and  Urban  Water  Management  Measures  (separately  for 
investment and operational costs), and (ii) Agricultural Measures. 

Internalised 

environmental 

costs 

are  presented 

separately 

for  measures 

implemented/on-going  and  for  measures  proposed  but  not  yet  implemented  in  the 
second  cycle (2015-21).  Similarly,  externalised  costs are presented for the third cycle 

(2021-27)  for  measures  requiring  to  be  continued  and  potential  additional  measures 
required. It was not considered possible to relate these costs quantitatively to specific 

sectors (households, industry, or agriculture) because there is often overlap of different 
pressures. 

The cost of the hydromorphological and urban water management  measures is largely 
covered  by  municipalities  who  are  responsible  for  the  water  services,  and  to  a  lesser 

extent by industry (both through water charges and the water tax) and includes funding 
of specific projects through the National Water Fund (fed by the water tax), although 

direct state funding may also be obtained for especially important projects. 

Agricultural  measures,  especially  those  involving  compensation  schemes,  are  largely 

funded  through  the  agricultural  development  fund,  additional  state  funding,  and  other 
European Union funding schemes. Thus, the environmental costs are not carried by the 

agricultural  sector,  although  there  are  some  (legal)  restrictions  which  involve 
internalised costs to the agricultural sector. Currently there are no environmental costs 

borne by freight navigation or the hydroelectricity sector, although in future there will 

131 

 
 
be a mandatory requirement for the latter, concerning continuity measures (fish ladders 

or channels) and minimal water flow.  

Compared  to  the  first  cycle  there  are  some  specifications  regarding  water  pricing 

policies  and  environmental  and  resource  costs  in  the  second  RBMP,  in  general  the 
status  since the first cycle has  changed little. Hence, there is  partial progress  towards 

the European Commission’s recommendations. 

132 

 
 
 
 
Topic 15

  Considerations 

specific 

to 

Protected 

Areas 

(identification, monitoring, objectives and measures) 

15.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle 

Protected Areas of all types have been reported except those designated under the Nitrates, and 
Urban Wastewater Directive and those designated for economically significant aquatic species 

(Table  15.1).  A  whole  territory  approach  was  used  to  designation  under  the  Urban  Waste 
Water Treatment Directive and Nitrates Directive in both the first and second cycle, therefore, 

no Protected Areas needed to be reported. Shellfish water areas have not been reported as these 
are  not  relevant  for  Luxembourg.  The  Number  of  Drinking  Water  Protected  Areas  have 
decreased significantly from more than 160 in the first cycle to only six in the second plan78. 

It  should  be  noted  that,  according  to  the  RBMP,  the  register  of  protected  areas  has  been 

reviewed and revised, and is in the process of being implemented.  

Table 15.1 

Number  of  Protected  Areas  in  both  River  Basin  District  of  Luxembourg, 
for surface and groundwater 

Protected Area type 

Number of Protected Areas 
associated with 

Rivers 

Groundwater 

Abstraction of water intended for human consumption under Article 7 

Recreational waters, including areas designated as bathing waters 
under Directive 76/160/EEC79 

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)80 

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) 

1 

11 

15 

28 

5 

2 

11 

Nutrient-sensitive areas, including areas designated as vulnerable 

Whole territory 

Whole territory 

78   Luxembourg  informed  subsequently  the  Commission  that  this  is  incorrect  and  must  be  due  to  an  error  on 

report of the first RBMP. 

79   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  

80   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  

133 

 
 
 
                                                      
Protected Area type 

zones under Directive 91/676/EEC and areas 
designated as sensitive areas under Directive 91/271/EEC81 

Areas designated for the protection of economically significant 
aquatic species82 

Other 

Number of Protected Areas 
associated with 

Rivers 

Groundwater 

Not relevant 

Not relevant 

0 

0 

Source: Member States reporting to WISE 

The  status  assessment  of  water  bodies  associated  with  the  Protected  Areas  is  illustrated  in 
Figure 15.1.  

A small number of groundwater Drinking Water Protected Areas have specific objectives set. 
For the Birds and Habitats Directives, the achievement of good ecological status is thought to 
be sufficient to meet the requirements of these Directives and fulfil the favourable conservation 
status in most of the Protected Areas.  

In Protected Areas where the achievement of good ecological status is sufficient, no additional 
measures are required.  

81   Council Directive 91/271/EEC of 21 May 1991 concerning urban waste-water treatment http://eur-

lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31991L0271 

82   Luxembourg clarified that shellfish areas have not been reported as these are not relevant for the country. As 
for fish areas, these have not been reported as the Grand-Ducal regulations ceased to be in force on 22 
December  2013 and the WFD foresees equivalent objectives for these areas. 

134 

 
 
 
 
                                                      
Ecological

status/potential

Surface water

chemical status

Groundwater

quantitative status

Groundwater

chemical status

0%

20%

40%

60%

80%

100%

0%

20%

40%

60%

80%

100%

0%

20%

40%

60%

80%

100%

0%

20%

40%

60%

80%

100%

Percentage of water bodies with Protected Areas 

Failing to achieve good

High

Good

Poor

Bad

Moderate

Unknown

Good

Unknown

Good

Poor

Unknown

Good

Poor

Unknown

Figure 15.1  Status  of  water  bodies  associated  with  the  Protected  Areas  report  for 

Luxembourg. Note: based on status/potential aggregated for all water bodies 
associated with all Protected Areas 

Source: WISE electronic reporting 

Monitoring sites have only been reported for Protected Areas related to the Bathing Water and 

Nitrates  Directives  in  the  second  cycle,  while  the  first  RBMP  also  included  monitoring  for 
Protected  Areas  linked  to  all  relevant  Directives83.  Exemptions  have  not  been  used  in  the 
second cycle in Luxembourg. 

83   Luxembourg subsequently clarified to the Commission that monitoring is still taking place in Birds, Habitats, 
and Urban Waste Water Treatment Protected Areas but is not reported, due to a lack of clarity in the reporting 
guidance document. Moreover, information regarding monitoring taking place in these protected areas can be 
found in the reporting carried out in the framework of the respective Directives. 

135 

 
 
 
 
 
                                                      
All  six  groundwater  bodies  in  Luxembourg  are  reported  as  being  monitored  as  Nutrient 

Sensitive Areas under the Nitrates Directive, but no other monitoring of groundwater Protected 
Areas is reported84. 

Table 15.2  Number of monitoring sites associated with Protected Areas in Luxembourg 
Number of monitoring sites 
associated with Protected 
Areas in 

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 

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) and 
Directive 92/43/EEC (Habitats) 

Nutrient-sensitive areas, including areas designated as 
vulnerable zones under Directive 91/676/EEC and areas 
designated as sensitive areas under Directive 91/271/EEC 

Areas designated for the protection of economically 
significant aquatic species 

Groundwater 
NR 

Rivers 
NR 

0 

NR 

11 

NR 

31 

16 

Not relevant 

Not relevant 

Other 

NR 

NR 

Source: WISE electronic reporting 
NR – Not reported to WISE 

15.2 Main changes in implementation and compliance since the first cycle 

The main apparent change since the first RBMP was a significant decrease in the number of 

Drinking Water Protected Areas for groundwater, with 82 reported in the first cycle and only 5 
in the second plan. For surface waters, 84 Drinking Water Protected Areas were reported in the 
first  cycle,  and  only  one  in  the  second  cycle85.  The  monitoring  program  reported  in  the  first 
cycle  assessment  covered  Protected  Areas  related  to  all  relevant  Directives:  Drinking  Water 

84   Luxembourg subsequently clarified that information can be found in chapter 6.11 of the RBMP. Moreover, it 
was clarified that monitoring is still taking place in Birds, Habitats, and Urban Waste Water Treatment 
Protected Areas but is not reported, due to a lack of clarity in the reporting guidance document. Moreover, 
information regarding monitoring taking place in these protected areas can be found in the reporting carried 
out in the framework of the respective Directives 

85   Luxembourg subsequently informed the Commission that this is incorrect and must be due to an error on 

report of the first RBMP as only one protected area was in place at that time too. 

136 

 
 
 
                                                      
(both  from  ground  and  surface  water),  Birds,  Habitats,  economically  significant  aquatic 

species, Bathing Waters, Nitrate and Urban Waste Water; whereas the reporting in the second 
cycle only included monitoring sites related to the Bathing Waters and Nitrates Directives86. 

15.3 Progress with Commission recommendations 

There  were  no  Commission  recommendations  based  on  the  first  RBMP  and  Programme  of 

Measures. 

86   Luxembourg subsequently clarified to the Commission that monitoring is still taking place in Birds, Habitats, 
and Urban Waste Water Treatment Protected Areas but is not reported, due to a lack of clarity in the reporting 
guidance document. Moreover, information regarding monitoring taking place in these protected areas can be 
found in the reporting carried out in the framework of the respective Directives. 

137 

 
 
 
 
                                                      
Topic 16

  Adaptation to drought and climate change 

16.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle 

16.1.1

  Climate Change adaptation  

Climate change was considered in both RBDs for checking the effectiveness of measures and 
flood risk management. Projected climate changes have been assessed and taken into account 

in  the  second  RBMP  and  Programme  of  Measures.  A  climate  check  of  the  Programme  of 
Measures has been made in the second cycle, while such a check was missing in the first cycle 
and the Common Implementation Strategy guidance on climate change87 has been used. 

No sub-plans addressing climate change in specific have been 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 RBMPs88, droughts are not relevant for the country in local sub-
RBDs.  No  exemptions  have  been  applied  for  Luxembourg  following  Article  4(6)  due  to 

prolonged droughts. 

Even though there is no legal obligation to prepare Drought Management Plans, many Member 

States have prepared them in order to cope with droughts. No Drought Management Plan has 
been developed in Luxembourg. This situation is similar to that reported in 201289. 

The European Commission made no recommendation regarding drought management. 

16.2 Main changes in implementation and compliance since the first cycle 

A climate check of the Programme of Measures has been made in the second cycle, while such 
a  check  was  missing  in  the  first  cycle.  No  National  Climate  Change  Strategy  had  been 
developed by the time the RBMP was published.  

No  Drought  Management  Plan  has  been  developed  in  Luxembourg  but  droughts  are  not 
considered relevant for this country.  

87   https://circabc.europa.eu/sd/a/a88369ef-df4d-43b1-8c8c-
306ac7c2d6e1/Guidance%20document%20n%2024%20-
%20River%20Basin%20Management%20in%20a%20Changing%20Climate_FINAL.pdf  

88   http://ec.europa.eu/environment/water/quantity/pdf/Assessment%20WSD.pdf  
89   http://ec.europa.eu/environment/water/quantity/pdf/Assessment%20WSD.pdf  

138 

 
 
                                                      
16.3 Progress with Commission recommendations 

There  were  no  Commission  recommendations  based  on  the  first  RBMP  and  Programme  of 
Measures. 

139