COMMISSION STAFF WORKING DOCUMENT Second River Basin Management Plans – Member State: Poland Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC) Second River Basin Management Plans First Flood Risk Management Plans
Date: 2019-02-26
Institutions: Directorate-General for Environment, European Commission
Subjects: Poland, 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) 53 final  COMMISSION STAFF WORKING DOCUMENT Second River Basin Management Plans – Member State: Poland     Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL  on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC) Second River Basin Management Plans First Flood Risk Management Plans  {COM(2019) 95 final} - {SWD(2019) 30 final} - {SWD(2019) 31 final} - {SWD(2019) 32 final} - {SWD(2019) 33 final} - {SWD(2019) 34 final} - {SWD(2019) 35 final} - {SWD(2019) 36 final} - {SWD(2019) 37 final} - {SWD(2019) 38 final} - {SWD(2019) 39 final} - {SWD(2019) 40 final} - {SWD(2019) 41 final} - {SWD(2019) 42 final} - {SWD(2019) 43 final} - {SWD(2019) 44 final} - {SWD(2019) 45 final} - {SWD(2019) 46 final} - {SWD(2019) 47 final} - {SWD(2019) 48 final} - {SWD(2019) 49 final} - {SWD(2019) 50 final} - {SWD(2019) 51 final} - {SWD(2019) 52 final} - {SWD(2019) 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} - 
 
 
Table of Contents 

Acronyms and definitions ............................................................................................................. 5 

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

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

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

Key strengths, improvements and weaknesses of the second River Basin Management Plans . 11 

Recommendations ...................................................................................................................... 21 

Topic 1

  Governance and public participation ....................................................................... 25 

1.1  Assessment of implementation and compliance with WFD requirements in the second 
RBMPs ................................................................................................................................... 25 

1.2  Main changes in implementation and compliance since the first RBMPs.................... 30 

1.3  Progress with Commission recommendations .............................................................. 30 

Topic 2

  Characterisation of the River Basin District............................................................. 31 

2.1  Assessment of implementation and compliance with WFD requirements in second 
cycle   ...................................................................................................................................... 31 

2.2  Main changes in implementation and compliance since first cycle ............................. 47 

2.3  Progress with Commission recommendations .............................................................. 48 

Topic 3
bodies 

  Monitoring, assessment and classification of ecological status in surface water 

 ................................................................................................................................... 49 

3.1  Assessment of implementation and compliance with WFD requirements in the second 
RBMPs ................................................................................................................................... 49 

3.2  Main changes in implementation and compliance since the first RBMPs ................... 71 

3.3  Progress with Commission recommendations .............................................................. 72 

Topic 4
bodies 

  Topic Monitoring, assessment and classification of chemical status in surface water 
 ................................................................................................................................... 76 

4.1  Assessment of implementation and compliance with WFD requirements in the second 
RBMPs ................................................................................................................................... 76 

4.2  Main changes in implementation and compliance since the first RBMPs ................... 89 

4.3  Progress with Commission recommendations .............................................................. 89 

1 

 
 
 
 
Topic 5
bodies 

  Monitoring, assessment and classification of quantitative status of groundwater 

 ................................................................................................................................... 93 

5.1  Assessment of implementation and compliance with WFD requirements in second 
RBMPs ................................................................................................................................... 93 

5.2  Main changes in implementation and compliance since first RBMPs ....................... 100 

5.3  Progress with Commission recommendations ............................................................ 101 

Topic 6

  Monitoring, assessment and classification of chemical status of groundwater bodies 
 ................................................................................................................................. 103 

6.1  Assessment of implementation and compliance with WFD requirements in second 
RBMPs ................................................................................................................................. 103 

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

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

Topic 7
  Designation of Heavily Modified and Artificial Water Bodies and definition of Good 
Ecological Potential ................................................................................................................. 112 

7.1  Assessment of implementation and compliance with WFD requirements in second 
RBMPs for designation ........................................................................................................ 112 

7.2  Main changes in implementation and compliance since first RBMPs ....................... 114 

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

Topic 8

  Environmental objectives and exemptions .............................................................. 118 

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

8.2  Main changes in implementation and compliance since the first RBMPs ................. 125 

8.3  Progress with Commission recommendations ............................................................ 126 

Topic 9

  Programme of measures .......................................................................................... 129 

9.1  Assessment of implementation and compliance with WFD requirements in the second 
RBMPs ................................................................................................................................. 129 

9.2  Main changes in implementation and compliance since the first RBMPs ................. 138 

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

Topic 10

  Measures related to abstractions and water scarcity .......................................... 144 

2 

 
 
 
10.1  Assessment of implementation and compliance with WFD requirements in second 
RBMPs  ................................................................................................................................. 144 

10.2  Main changes in implementation and compliance since first RBMPs .................... 145 

10.3 

Progress with Commission recommendations ........................................................ 145 

Topic 11

  Measures related to pollution from agriculture................................................... 146 

11.1  Assessment of implementation and compliance with WFD requirements in second 
RBMPs  ................................................................................................................................. 146 

11.2  Main changes in implementation and compliance since first RBMPs .................... 148 

11.3 

Progress with Commission recommendations ........................................................ 148 

Topic 12

  Measures related to pollution from sectors other than agriculture ..................... 151 

12.1  Assessment of implementation and compliance with WFD requirements in the 
second RBMPs ..................................................................................................................... 151 

12.2  Main changes in implementation and compliance since the first RBMPs .............. 152 

12.3 

Progress with Commission recommendations ........................................................ 155 

Topic 13

  Measures related to hydromorphology ................................................................ 158 

13.1  Assessment of implementation and compliance with WFD requirements in the 
second RBMPs ..................................................................................................................... 158 

13.2  Main changes in implementation and compliance since the first RBMPs .............. 159 

13.3 

Progress with Commission recommendations ........................................................ 160 

Topic 14

Economic analysis and water pricing policies .................................................... 161 

14.1  Assessment of implementation and compliance with WFD requirements in the 
second RBMPs ..................................................................................................................... 161 

14.2 

Progress with Commission recommendations ........................................................ 162 

Topic 15

  Considerations specific to Protected Areas ......................................................... 165 

15.1  Assessment of implementation and compliance with WFD requirements in the 
second RBMPs ..................................................................................................................... 165 

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

15.3 

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

Topic 16

Adaptation to drought and climate change .......................................................... 172 

3 

 
 
 
 
16.1  Assessment of implementation and compliance with WFD requirements in the 
second RBMPs ..................................................................................................................... 172 

16.2  Main changes in implementation and compliance since the first RBMPs .............. 172 

16.3 

Progress with Commission recommendations ........................................................ 172 

4 

 
 
Acronyms and definitions  

EQS Directive 

Environmental Quality Standards Directive 

FD 

Km 

km2 

KTM 

PoM 

RBD 

RBMP 

WFD 

WISE 

Annex 0 

Floods Directive 

Kilometre 

Kilometre squared 

Key Type of Measure 

Programme of Measures 

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

Poland joined the European Union in 2004. 

Poland  has  a  population  of  38.1  million1  and  a  total  land  area  of  312 679 km².  Its  territory 
stretches  from  the  Baltic  Sea  in  the  north  to  the  Carpathian  Mountains  in  the  south.  The 
northern part of the country is mainly lowlands with lake districts, whilst the southern part is 

1   European Commission http://europa.eu/about-eu/countries/member-countries/poland/index_en.htm  

7 

0100200kmPL2000PL6000CZ_5000LT1100DE5000SK40000CZ_1000PL7000SE4CZ_6000DE6000DE9650PL8000SK30000DK3CZ_6000PL1000PL9000PL4000PL3000PL5000PL6700PLRUBYUABaltic Sea 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
mountainous. The lowest point in Poland is at 1.8 metres below sea level at Raczki Elblaskie in 
the Vistula delta. The highest part of the Carpathians is the Tatra Mountains with the highest 
peak Rysy at 2 499 metres above sea level.  

Poland  shares  its  borders  with  Germany  (west),  the  Czech  Republic  and  Slovak  Republic 
(south),  Ukraine,  Belarus  and  Lithuania  (east)  and  the  Baltic  Sea  and  the  Russian  region  of 
Kaliningrad Oblast (north). 

Poland  has  10  RBDs  (Table  A).  They  are  all  international.  The  longest  Polish  rivers  are  the 
Vistula and Oder and their RBDs cover almost 97% of the country. Both rivers flow into the 
Baltic Sea.  

Information  on  areas  of  the  international  RBDs,  including  sharing  countries,  is  provided  in 
Table A. Poland’s percentage share of each international RBD is shown in Table B. 

Table A 

Overview of Poland’s RBDs  

RBD 

RBD Name 

Size (km2) 
(% of RBD in Poland) 

PL1000 

Danube 

385 (less than 1%) 

PL2000 

PL3000 

PL4000 

PL5000 

PL6000 

PL 6700 

PL7000 

PL8000 

PL9000 

Vistula 

Swieza 

Jarft 

Elbe 

Oder 

Ucker 

Pregolya 

Nemunas 

Dniester  

183 492 (app. 59%) 

161 (less than 1%) 

210 (less than 1%) 

238 (less than 1%) 

118 365 (app. 38%) 

134 (less than 1%) 

7 522 (app. 2.5%) 

2 515 (less than 1%) 

233 (less than 1%) 

Countries sharing RBD 

DE, SK, UA, AT, BG, CZ, HR, HU, RO, IT, MD, 
ME, RS, SI, BA, AL, CH, MK 

BY, RU, UA, SK 

RU 

RU 

CZ, DE, AT 

CZ, DE 

DE 

RU 

BY, LT (RU) 

UA (MD) 

Source: RBMPs reported to WISE 

8 

 
 
 
Table B 

Transboundary river basins by category and % share in Poland  

Name international 
river basin 

Nati
onal 
RBD 

Countries sharing RBD 

Danube 

Elbe 

Oder 

Dniester / Dnistr/ 
Nistru 

Nemunas/ Nieman/ 
Neman/ Nyoman 

Vistula 

Bug (Sub--basin 
Vistula) 

PL1
000 

PL5
000 
PL6
000 

PL9
000 

PL8
000 
PL2
000 

DE, SK, UA, AT, BG, CZ, HR, HU, RO, IT, 
MD, ME, RS, SI, BA, AL, CH, MK 

CZ, DE, AT 

CZ, DE 

UA (MD) 

BY, LT (RU) 

BY, RU, UA, SK 

Co-ordination category 
3 
2 
1 

km²  % 

<
0.
1 
0.
2 
86
.4 

385 

238 

118 
365 

k
m
² 

%  km²  % 

2
3
3 

0
.
3 

251
5 
183 
492 
192
84 

2.
1 
86
.8 
48
.9 

Source: WISE electronic reports  

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

9 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Status of second river basin management plan reporting 

A total of 10 Polish RBMPs (Danube, Vistula, Swieza, Jarft, Elbe, Oder, Ucker, Pregolya, 
Nemunas, Dniester) were published between 8 November 2016 and 6 December 2016. 
Documents are available from the European Environment Agency EIONET Central Data 
Repository https://cdr.eionet.europa.eu/.  

10 

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

The main strengths and shortcomings of the second RBMPs of Poland are as follows: 

 

Governance and public consultation 

 

 

 

 

Poland has coordinated WFD implementation with neighbouring Member States, both 
through  international  river  basin  committees  and  via  bilateral  agreements.  Moreover, 
Poland  has  carried  out  bilateral  cooperation  with  two  of  its  third  country  neighbours, 
Belarus and Ukraine. As  to  cooperation  between Poland  and Russia,  it appears that it 
has been inactive. 

A  broad  range  of  stakeholder  groups  were  actively  involved  in  the  preparation  of 
Poland’s RBMPs, including via the establishment of advisory groups. 

Joint  consultation  of  Poland’s  RBMPs  and  FRMPs  included  common  meetings, 
regional conferences and a national forum.  

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

 

Characterisation of the RBDs 

 

 

 

 

Not all of the water body types in all water categories had an equivalent intercalibration 
type2.  

In the second cycle Poland reported that reference conditions had been established for 
all  water  body  types  in  each  category  for  all  biological,  hydromorphological  and 
physicochemical quality elements. 

Further  characterisation  work  has  been  undertaken  since  the  first  RBMPs  for 
characterising  groundwaters.  Poland  also  included  an  assessment  of  linkages  with 
surface water bodies and terrestrial ecosystems. 

The significance of pressures was defined in terms of thresholds for the most part and 
linked  to  the  potential  failure  of  objectives.  However,  there  were  still  many  pressure 

2 Poland highlighted that it is usual that intercalibration types do not correspond directly to national types as it is 
virtually  impossible  to  cover  regional  diversity  with  pan-European  typology  and  as  a  result,  the 
correspondence is a trade-off. 

11 

 
 
 
                                                      
 

 

 

 

types  where  expert  judgment  was  used  to  define  the  significance  of  pressures  rather 
than more numerical methods such as modelling3. 

27 pressures were reported not to have been assessed for surface waters. This included 
abstraction  pressures  that  were  not  assessed  in  surface  waters  even  though  they  were 
identified as a pressure in the first RBMPs4.  

Unknown  anthropogenic  pressures  were  also  reported  to  be  significant  in  the  second 
cycle and “Unknown impact” type was reported to affect the largest proportion (36%) 
of surface water bodies in Poland: this implies that the tools used to identify and assess 
significant pressures and impacts were inadequate5. 

Poland  reported  the  gaps  to  be  filled  for  all  significant  pressures  reported  at  the 
groundwater and surface water body level. 

All 10 RBDs in Poland reported inventories of emissions, discharges and losses for all 
Priority Substances except some of the polycyclic aromatic hydrocarbons. Tier 1 of the 
methodology was implemented for all substances included in the inventories (while the 
Guidance  Document  recommends  to  implement  at  least  Tier  1  +  2  for  substances 
relevant at RBD level). The data quality was assessed as medium. 

  Monitoring, assessment and classification of ecological status 

 

 

The number of monitoring sites has decreased substantially since the first RBMPs for 
both  operational  and  surveillance  monitoring  in  all  the  water  categories.  Poland 
subsequently explained that this reduction is due to a better targeting of the monitoring 
efforts. 

The  number  of  quality  elements  monitored  in  lakes  increased,  with  the  inclusion  of 
phytobenthos and benthic invertebrates. 

3  Poland  subsequently  clarified  that  the  diffuse  pressures  assessment  was  based  both  on  expert  judgement  and 
additional  analysis  performed  during  drafting  the  programmes  of  measures.  Poland  further  clarified  that  the 
assessment  of  significance  of  diffuse  pressure  was  based  on  calculated  or  estimated  numbers  presented  as 
nutrient loads originating from those sources, in relation to thresholds defined in the law. 

4 Poland subsequently explained that in the second planning cycle special attention was paid to keeping a clear 
link between status assessment, identified pressures and measures planned. Even if surface water abstraction 
had  not  been  identified  as  a  significant  pressure  it  is  controlled  in  the  frame  of  measures  implemented  at 
country  level  and  those  measures  linked  to:  drafting  or  verification  of  ‘conditions  for  water  use  in  water 
regions  and  river  catchments’,  review  of  water  permits, 
in-depth  pressure  analysis  aimed  at 
hydromorphological modifications and preparation of a national programme for surface water renaturalisation. 
5 Poland subsequently highlighted that information on the methodology for assessment of the unknown pressures 

and planning of dedicated measures is given in the methodology for the PoM. 

12 

 
 
                                                      
  Monitoring of 24 River Basin Specific Pollutants (mainly metals) was carried out in all 
surface water categories, at least at the minimum recommended frequency. Most of the 
monitoring  results  were  used  for  classification  of  status.  The  large  majority  of  lakes, 
however,  were  classified  based  on  expert  judgement  and  the  large  majority  of  rivers 
were classified based on grouping. 

 

 

In general, more water bodies were reported to be classified based on monitoring than 
those that were directly monitored.  

Classification methods have been developed for all the biological quality elements for 
all  types  and  water  categories,  including  definition  of  reference  conditions.  However, 
macroalgae and angiosperms were not classified in transitional and coastal waters. Fish 
were not classified in transitional waters. 

Most  of  the  classification  methods  for  the  biological  quality  elements  had  been 
intercalibrated  by 2013 and most  of  the remaining  ones  were intercalibrated by 2018, 
after the adoption of the second RBMPs. Some biological methods have not yet been 
intercalibrated:  benthic  invertebrates  in  lakes  and  fish  and  benthic  invertebrates  in 
transitional waters. 

 

The classification methods for hydromorphological quality elements were not linked to 
sensitive biological quality elements. 

Classification  methods  have  been  developed  for  all  physicochemical  quality  elements 
and  were  reported  to  be  linked  to  sensitive  biological  quality  elements.  However,  the 
upper part of the ranges for both phosphorus and nitrogen are too high to support the 
nutrient sensitive biological quality elements and the use of the same ranges of nutrient 
standards  for  lakes  and  rivers  raises  concerns  that  these  may  still  represent  the  old 
classification system before the WFD. Poland subsequently stated that the classification 
system for the general physicochemical quality elements changed in 2016, to relate to 
biological elements classification (macrophytes and phytobenthos). 

 

River  Basin  Specific  Pollutants  were  selected  based  on  occurrence  in  water  bodies  at 
risk  of  failing  their  objectives  due  to  emissions  from  wastewater,  industry  and 
agriculture.  Environmental  Quality  Standards  were  set  for  25  substances,  only  for 
water, and none of them were derived in accordance with Technical Guidance n. 27. All 
the  analytical  methods  used  meet  the  minimum  performance  criteria  laid  down  in 

13 

 
Article 4.1 of the Quality Assurance / Quality Control Directive  (2009/90/EC) for the 
strictest standards applied.  

 

 

Ecological status was classified for all water bodies, up from 20% in the first RBMPs.  

70%  of  all  the  water  bodies  were  reported  in  less  than  good  ecological  status  in  the 
second RBMPs and the level of confidence of the classification was low for most water 
bodies. 

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

 

 

 

 

Between  the  two  RBMPs  there  was  a  very  significant  decrease  in  the  proportion  of 
water bodies in unknown status, from 92% to 15%. This resulted in an increase in the 
proportion  of  water  bodies  in  good  status  from  3%  up  to  59%  and  an  increase  in 
proportion of water bodies failing to achieve good status, from 5% to 26%.  

30%  of  water  bodies  are  monitored,  and  grouping  and  expert  judgment  are  used  to 
classify  the  status  of  a  significant  proportion  of  non-monitored  water  bodies.  There 
seem  to  be  some  limitations  in  the  assessment  of  pressures  on  which  the  expert 
judgment is based (in particular, most of the water bodies failing to achieve good status 
are subject to unknown pressures). 

Territorial  waters  were  neither  monitored  nor  classified.  Almost  all  lake,  transitional 
and  coastal  water  bodies  failing  to  achieve  good  status  were  covered  by  operational 
monitoring.  Rivers  failing  to  achieve  good  chemical  status  were  less  well  monitored, 
ranging from between 14% and 40% across RBDs (the exception being the Elbe RBD, 
where the only river water body failing was also monitored). 

No surface water body exists in the Ucker RBD, so no monitoring was reported for this 
RBD. For the nine other RBDs, all priority substances were taken into account in the 
assessment  of  status.  All  substances  (including  those  discharged)  were  monitored  in 
seven RBD. Two RBDs did not identify any discharged substance and did not monitor 
any  substance,  however  seems  that  diffuse  pressures  were  not  considered  when 
assessing  whether  substances  were  discharged.  The  monitoring  frequencies  are 
sometimes below the recommended minimum frequency, which leads to a low level of 
confidence for a significant proportion of the water bodies classified. 

 

No monitoring in biota was performed for status assessment for the second RBMP.  

14 

 
 

No trend monitoring was reported to WISE, however it seems that some monitoring in 
sediment  took  place.  It  is  however  unclear  whether  all  relevant  substances  were 
monitored, and what the spatial coverage and temporal resolution were. 

  Monitoring,  assessment  and  classification  of  quantitative  status  of  groundwater 

bodies 

 

 

 

 

 

Not all groundwater bodies are subject to groundwater quantitative monitoring. 

The groundwater quantitative status has improved. The percentage of the groundwater 
body area failing good quantitative status decreased (from 13% in the first RBMPs to 
4% of the total groundwater body area in the second RBMPs). 

The level of confidence in status results was reported to be high. 

Groundwater dependent terrestrial ecosystems were considered in status assessment. 

There was no consideration of groundwater associated surface waters in two river basin 
districts, although they were associated with a risk to groundwater status. 

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

 

 

 

 

 

The  coverage  of  groundwater  bodies  by  surveillance  monitoring  is  not  complete.  The 
reported data indicate that there is no operational monitoring, although 14 groundwater 
bodies  are  at  risk.  Poland  subsequently  clarified  that  operational  monitoring  is 
continued in the second RBMP covering 39 groundwater bodies at risk. 

According  to  the  information  provided  by  Poland,  all  WFD  core  parameters  are 
monitored, including ammonium, but have not been reported. 

The  status  situation  has  deteriorated.  The  groundwater  body  area  failing  good  status 
increased  from  3.7%  to  7.8%  (from  11  to  14  groundwater  bodies)  of  the  total 
groundwater body area. 

According  to  the  information  provided  by  Poland,  there  is  a  methodology  for  trend 
assessment available, but not yet for the trend reversal assessment. 

Groundwater  dependent  terrestrial  ecosystems  and  associated  surface  waters  were 
related to risk and considered in status assessment and threshold value establishment. 

15 

 
 

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

 

 

 

For  lakes,  transitional  and  coastal  water  bodies,  new  methodologies  have  been 
developed for the designation of heavily modified water bodies in the second RBMPs. 
The methodology for designating river heavily modified water bodies has not changed 
since  the  first  RBMPs,  although  the  information  on  hydromorphology  had  been 
updated.  An  information  gap  is  that  for  the  majority  of  river  heavily  modified  water 
bodies the use for which they were designated is reported as unknown. 

The methodologies for heavily modified water bodies designation include details on the 
criteria  for  the  identification  of  substantial  changes  in  character  as  well  as  general 
guidance (on national level) on the assessment of other means to achieve the benefits of 
the modifications and significant adverse effects of measures on the use and the wider 
environment. However, information was not reported on the details of the outcome of 
the designation tests of significant adverse effects on the use and better environmental 
options (other means) for individual water bodies. 

For the definition of good ecological potential, new methodological developments are 
noted  for  lakes  and  coastal/transitional  water  bodies.  Good  ecological  potential  is 
reported  as  defined  in  terms  of  biology,  following  a  regulation  on  classification. 
Concerning mitigation measures, fish ladders are the only measure reported so far for 
defining  good  ecological  potential,  while  no  description  was  found  of  the  ecological 
changes that these mitigation measures are designed to achieve. 

 

Environmental objectives and exemptions 

 

 

 

Environmental  objectives  for  ecological  and  chemical  status  of  surface  water  bodies 
and chemical and quantitative status of groundwater were reported in all RBDs. 

Drivers, pressures and pollutants leading to exemptions were reported. 

Relevant information  was lacking in the  RBMPs and reported background documents 
to determine whether exemptions related to disproportional costs and natural conditions 
could be justified in terms of meeting WFD requirements. 

16 

 
 

A  significant  number  of  projects  was  reported  by  Poland  to  meet  the  requirements 
under  Article  4(7).  Further  information  is  required  to  fully  assess  whether  this  is 
sufficient. 

 

Programme of Measures 

 

 

 

 

 

 

 

Significant progress has been made, particularly in identifying the gap to good status at 
a  water  body  level,  and  the  level  of  implementation  of  measures  required  to  achieve 
good status by 2027. Clear information on how measures have been prioritised was not 
available.  Poland clarified that the selection was based on efficiency of measures and 
feasibility  of  implementation,  with  details  provided  in  the  background  document  on 
update of the Programme of Measures (PoM). 

The  costs  of  measures  have  been  identified,  and  financing  was  reported  as  being  in 
place. Significant EU funds have been secured for some RBDs. 

The reported significant pressures were well covered with operational KTMs in place to 
reduce the pressures in surface waters in all RBDs and for groundwater in the Oder and 
Vistula.  

Poland  mapped  a total of 1 410 national  basic measures against  15 predefined KTMs 
and nine nationally derived KTMs. 139 national supplementary measures were mapped 
against nine predefined KTMs and 17 nationally derived KTMs 

For River Basin Specific Pollutants, information was only reported for two RBDs. For 
these RBDs no information was provided on the number of surface water bodies failing 
to  be  of  good  status,  although  information  on  KTMs  was  given.  Information  for 
groundwater bodies was provided for these RBDs.  

Information  was  provided  on  the  number  of  surface  waters  failing  good  status  due  to 
Priority Substances for seven RBDs, but KTMs to address them were only reported for 
four RBDs. KTMs were not reported for all the Priority Substances causing failures, but 
these seem to be covered by other measures tackling pollution. 

Poland provided indicators of the gaps to be filled by the KTMs and indicators for the 
scale and progress of the implementation of the measures up to 2027. 

17 

 
 
 
  Measures related to abstractions and water scarcity 

  Water abstraction pressures were not reported to be relevant although a small number 

of groundwater bodies may be at risk of failing good quantitative status. 

 

 

The  Water  Exploitation  Index  +  has  not  been  calculated,  and  no  water  quantity  data 
were  reported to  support the European  State of the  Environment Report in relation to 
Water  Quantity.  The  RBMPs  do  not  include  a  water  resource  allocation  and 
management plan. 

There  is  a  concession,  authorisation  and/or  permitting  regime  to  control  surface  and 
groundwater and a register of surface and groundwater use.  

  Measures on Article 11(3)(c) for sustainable and efficient water are being implemented.  

  Measures related to pollution from agriculture 

 

 

 

 

 

 

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

A gap  assessment for agricultural measures  has  not  been  undertaken in all  RBDs and 
management objectives for nutrient pollution have not been set. 

Safeguard zones have been established for abstractions. 

Implementation  of  basic  measures  under  Article  11(3)(h)  for  the  control  of  diffuse 
pollution from agriculture at source has been ensured in all RBDs. In the Vistula and 
Oder  RBDs,  the  rules  were  applied  only  in  Nitrate  Vulnerable  Zones.  In  all  other 
RBDs, the same rules were applied across the whole RBD. 

Supplementary measures for reducing pollution from agriculture were reported as well 
as measures to reduce sedimentation from soil erosion and surface runoff.   

The  level  of  ambition  is  unclear,  as  the  area  covered  by  measures  to  achieve 
environmental objectives was not reported. In general, it is difficult to identify progress 
with the recommendations that were made6. 

6    Poland  subsequently  stated  that  areas  where  agriculture  significantly  affects  the  status  of  water  have  been 

identified in connection with the implementation of the Nitrates Directive. 

18 

 
 
 
                                                      
 
  Measures related to pollution from sectors other than agriculture 

 

Poland  has  made  progress  on  reducing  emissions  of  non-agricultural  pollutants  by 
improving urban waste water treatment. 

As noted above, KTMs were not reported for all individual Priority Substances causing 
failure, nor for all RBDs, but KTM 15 has been mapped against national measures and 
is reported to be tackling significant pressures in all RBDs. For the Vistula RBMP, no 
measures were reported for two priority substances. 

 

Only  general  measures  were  reported  for  pollutants  causing  failure  of  good  chemical 
status  of  groundwater  (these  include  an  in-depth  analysis  of  the  environmental 
pressures  in  order  to  determine  the causes  of  failure  to  achieve  good  status,  linked to 
KTM14 - Research, improvement of knowledge base reducing uncertainty) 

  Measures related to hydromorphology 

 

 

 

The links between hydromorphological pressures and measures have improved due to 
the  improved  reporting  on  pressures  and  related  KTM  in  WISE.  However,  for 
significant physical alterations and for dams, barriers and locks, the relevant sector or 
water  use  was  indicated  as  unknown  or  obsolete.  The  significant  hydrological  and 
hydromorphological  alterations  were  not  assigned  to  any  of  the  specified  sectors 
according to WISE either (instead the sector was reported as “other’). 

Ecological  flows  were  derived  and  partly  implemented,  i.e.  for  some  relevant  water 
bodies, in eight RBDs, but the work is still on-going. The methodological background 
should  be  finished  within  2018  and  legislative  changes  are  expected  in  the  next  few 
years. 

A  programme  of  flow  retention  in  forests  was  reported  (also  reported  in  the  first 
RBMPs  but  set  to  continue  until  2020)  aimed  at  flow  retention  and  maintenance  of 
streams  and  related  infrastructure  in  good  condition.  Poland  also  informed  that 
measures  related  to  increasing  natural  retention are  an integral  part  of  the  Flood  Risk 
Management Plans. 

 

Economic analysis and water pricing policies  

 

The definition of water services was not clear with inconsistent information presented. 

19 

 
 

 

Environmental and resource costs have been calculated although not comprehensively 
applied to all water services. 

It is not clear whether pricing policies have provided ‘adequate incentives’ to use water 
efficiently. 

 

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

 

 

 

Objectives  have  been  set  for  most  relevant  types  of  Protected  Areas.  However,  for 
nature areas, no information has been provided as to whether the objectives have been 
met, which implies that the monitoring programme may not provide the necessary data 
for assessing the status of the Protected Area. 

The Polish ecological monitoring programme for surface water Protected Areas is fairly 
comprehensive and includes monitoring sites in relation to the relevant Directives.  

However,  for  groundwater  Protected  Areas,  no  specific  monitoring  programme  has 
been reported, although monitoring schemes have been developed in the framework of 
the national programme for environmental monitoring. 

 

Adaptation to drought and climate change 

 

 

 

 

Climate  change  was  considered  in  all  river  basin  districts  and  the  Common 
Implementation  Strategy  guidance  document  on  how  to  adapt  to  climate  change  was 
used. 

A  climate  change  check  of  the  PoM  has  been  carried  out  in  the  second  river  basin 
management plans.  

Adaptation measures (KTM24) were not reported as operational to address any of the 
significant pressures. 

Drought management plans were not reported for Poland. According to the information 
provided by Poland, plans for action against effects of drought have been prepared by 
different regional water management boards 

20 

 
 
 
Recommendations 

 

 

 

 

 

 

 

 

 

Poland needs to ensure that the preparation of the next cycle of RBMPs is carried out in 
accordance with the WFD timetable, to ensure the third RBMPs are adopted on time. 

Clear  information  should  be  included  in  national  RBMPs  on  international  coordination 
efforts.  

Poland  should  continue  to  improve  international  cooperation,  including  coordinated 
assessments of the technical aspects of the WFD such as ensuring a harmonized approach 
for status assessment and a coordinated PoM in order to ensure the timely achievement 
of the WFD objectives. 

Poland has made significant progress in the characterisation of water bodies. However, 
further  work  is  still  needed  on  the  significance  of  pressures  and  on  clarifying  impacts 
which are currently reported as unknown. 

Further  work  is  required  to  make  the  monitoring,  assessment  and  classification  of 
groundwater status fully compliant with the requirements of the Groundwater Directive. 
The work on aligning national types with those intercalibrated at the EU level should be 
completed. 

Poland  should  strengthen  monitoring  of  surface  waters  by  covering  all  relevant  quality 
elements in all water categories 

An increased level of monitoring should lead to a lower dependence on expert judgment 
and on grouping for the classification of ecological status/potential, and consequently to 
an increased confidence in the assessment of ecological status. 

Poland  should  make  sure  that  the  method  used  for  the  derivation  of  Environmental 
Quality Standards meets the minimum requirements for the protection of freshwater and 
marine ecosystems from possible adverse effects, as well as of human health. 

Poland  should  provide  a  complete  assessment  of  ecological  status  for  all  categories  of 
water, including assessments of all relevant quality elements. The methods developed for 
classification  of  ecological  status  for  hydromorphological  and  physicochemical  quality 
elements  should  be  WFD  compliant,  in  particular  concerning  their  links  to  good  status 
for the relevant biological quality elements. 

21 

 
 

 

 

 

 

 

 

Poland should continue to progress in the transfer of the results of intercalibration into all 
national types, and provide clear information on the class boundaries that are used for the 
status classification of different national types. 

Confidence  in  the  assessment  of  status  for  all  water  categories  should  continue  to  be 
improved  (including  territorial  waters,  whose  status  should  be  assessed),  and  the 
proportion  of  unknown  status  further  reduced.  In  particular,  monitoring  should  be 
performed in a way that provides sufficient temporal resolution and spatial coverage to 
robust 
classify 
grouping/extrapolation methods), in the relevant matrix. If a different matrix or reduced 
frequencies are used, the corresponding explanations should be provided, as required by 
the Directive. 

necessary,  with 

combination, 

all  water 

bodies 

(in 

if 

Poland should further improve trend monitoring to ensure that all the relevant substances 
specified  in  Directive  2008/105/EC  are  monitored  in  a  way  that  provides  sufficient 
spatial coverage and temporal resolution. 

On groundwater, a methodology for trend reversal should be in place. 

Further  efforts  are  needed  to  develop  a  consistent  methodology  for  the  designation  of 
heavily modified water bodies for all relevant water categories based on WFD compliant 
monitoring.  The  assessment  of  significant  adverse  effects  of  a  comprehensive  set  of 
mitigation measures on their use or the wider environment and the lack of significantly 
better  environmental  options  at  water  body  level  needs  to  be  specifically  mentioned  in 
the RBMPs. This will ensure the transparency of the designation process. Further efforts 
are needed to define ecological potential in terms of relevant biological quality elements 
for all water categories. 

Poland  should  continue  to  further  improve  the  methodology  and  justifications  for  the 
assessment  and  application  of  Article  4(4)  and  4(5)  exemptions.  The  approach  for  the 
application  of  these  exemptions  needs  to  be  described  in  more  detail  and  made 
transparent in the RBMPs. Criteria for the application of Article 4(4) need to be clearly 
distinguished from the criteria applied for Article 4(5) in relation to technical feasibility 
and disproportionate costs. 

A significant number of projects was reported to meet all the requirements as outlined in 
WFD Article 4(7).  Poland needs to ensure that the use of exemptions under Article 4(7) 
is based on a thorough assessment of all the steps as required by the WFD, in particular 

22 

 
an  assessment  of  whether  the  project  is  of  overriding  public  interest  and  whether  the 
benefits  to  society  outweigh  the  environmental  degradation,  and  the  absence  of  real 
alternatives that would be a better environmental option. Furthermore, these projects may 
only  be  carried  out  when  all  practicable  measures  are  taken  to  mitigate  the  adverse 
impact on the status/potential of the water bodies. 

Poland  should  ensure  that  KTMs  are  reported  to  address  identified  Priority  Substances 
causing failure of objectives.  

Poland  should  consider  how  supplementary  measures  (designed  to  be  implemented  in 
addition  to  basic  measures)  can  contribute  more  effectively  to  achieving  the  WFD 
objectives and quantify the total area to be covered by each measure. 

Poland  should  complete  a  comprehensive  gap  assessment  for  diffuse  pollutant  loads  
from agriculture (nutrients, agri-chemicals, sediment, organic matter) across all waters in 
all RBDs and link it directly to mitigation measures  in the third RBMPs (as per WFD 
Article 11(3)(h)), to facilitate the achievement of WFD objectives. 

Poland  should  complete  the  designation  of  a  sufficient  number  of  Nitrate  Vulnerable 
Zones  in  the  third  RBMP  cycle  and  adopt  measures  to  effectively  combat  nitrate 
pollution in these zones as required by the Nitrates Directive and Article 11.(3)(a) of the 
WFD.   

Poland  should  complete  the  adoption  of  measures  to  improve  manure  handling  and 
recycling  on  farms,  decrease  nutrient  discharges  (fertiliser  and  pesticide  applications), 
perform more controls and monitoring, etc, and identify financing sources to fund these 
measures. 

Poland  should  continue  to  review  and  develop  the  strategy  for  the  delivery  of  WFD 
objectives, in cooperation with the farming community and the authorities in charge of 
CAP  in  Poland  to  ensure  the  third  RBMP  is  technically  feasible  and  that  all  relevant 
policies  and  instruments  (e.g.  RDP,  CAP  Pillar  1,  ND,  etc.)  contribute  significantly  to 
RBMPs.  

Poland  should provide more information  on how it has  selected measures, including in 
relation  to  combatting  pollution  by  Priority  Substances  and  other  chemical  pollutants. 
More  consideration  should  be  given  to  pollutants  arriving  via  the  atmosphere,  which 
could  be  relevant  in  all  RBDs,  and  to  identifying  measures  specific  to  individual 
Groundwater pollutants. 

 

 

 

 

 

 

 

23 

 
 

 

 

 

 

 

should 

implement 

Poland 
the 
hydromorphological  impacts  from  agriculture,  in  line  with  the  requirement  of  Article 
11(3) WFD. 

specific  measures 

address 

report 

and 

to 

Ecological flows also need to be derived and implemented during the second cycle. 

Poland  should  continue  prioritising  the  use  of  green  infrastructure  and/or  natural  water 
retention  measures  that  provide  a  range  of  environmental  (improvements  in  water 
quality, flood protection, habitat conservation etc.), social and economic benefits which 
can be in many cases more cost-effective than grey infrastructure. 

Poland should apply cost recovery for water use activities having a significant impact on 
water  bodies  or  justify  any  exemptions  using  Article  9(4).  Poland  should  continue  to 
transparently  present  how  financial,  environmental  and  resource  costs  have  been 
calculated  and  how  the  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. 

Poland has reported additional objectives only for surface waters Protected Areas related 
to  Birds  and  Habitats  Directives.  Therefore,  Poland  should  work  on  the  additional 
objectives  for  groundwater  related  Protected  Areas.  Finally,  Poland  should  also  ensure 
that all relevant Protected Areas are properly monitored during the second RBMPs.  

Poland should consider ensuring that all its areas susceptible to drought are covered with 
appropriate drought management plans and measures. 

24 

 
 
 
 
Topic 1

  Governance and public participation 

1.1 

Assessment  of  implementation  and  compliance  with  WFD 
requirements in the second RBMPs 

1.1.1  Administrative arrangements – RBDs 

Poland  has  10  RBDs,  and  all  are  international.  The  longest  Polish  rivers  are  the  Vistula  and 
Oder; their RBDs cover almost 97% of the country. 

1.1.2  Administrative arrangements – competent authorities 

Poland has reported a broad range of Competent Authorities, a number of which have roles in 
enforcement of regulations and implementation of measures. The following national ministries 
are identified7: 

  The  Ministry  of  Environment  has  main  roles  in  enforcement  of  regulations, 

implementation of measures and coordination of implementation;  

  The  Ministry  of  Agriculture  and  Rural  Development  and  the  Ministry  of  Maritime 
Economy  and  Inland  Navigation  have  main  roles  in  enforcement  of  regulations  and 
implementation of measures; 

  The Ministry of Development has a main role in the enforcement of regulations.  

National environmental and health authorities are identified as Competent Authorities: 

  The  General  Director  for  Environmental  Protection  has  main  roles  in  enforcement  of 

regulations and the implementation of measures.  

  The  Chief  Inspector  of  Environmental  Protection  has  main  roles  in  monitoring  and 
assessment of status of groundwater and surface water, along with the enforcement of 
regulations and the implementation of measures.  

  The Chief Sanitary Inspectorate  has  main roles  in  enforcement  of regulations and the 

implementation of measures.  

Authorities for water management and maritime issues are identified: 

7   This section presents information reported for the RBMP. Poland passed a new Water Law in July 2017 that 

may change the set of Competent Authorities, among other elements. 

25 

 
                                                      
  The  National  Water  Management  Authority  has  main  roles  in  enforcement  of 
regulations,  pressure  and  impact  analysis,  economic  analysis,  preparation  of  the 
RBMPs  and  PoM,  public  participation,  implementation  of  measures,  coordination  of 
implementation and reporting to the European Commission.  

  The Directors of the Regional Water Management Boards (seven are listed) each have 
main  roles  in  enforcement  of  regulations,  pressure  and  impact  analysis,  economic 
analysis, public participation and implementation of measures.  

  The Directors of Amelioration and Water Structures Authorities (formerly, Directors of 
the  Authorities  for  Land  Improvement  and  Water  Facilities)  have  main  roles  in 
enforcement of regulations and implementation of measures.  

  The Directors of Inland Waters Navigation Offices (eight are listed) have main roles in 

enforcement of regulations.  

  The Directors of Maritime Offices (three are listed) have main roles in enforcement of 
regulations and in implementation of measures (except for the Director of the Maritime 
Office in Slupsk, who does not have a main role in the enforcement of regulations).  

Competent Authorities at regional level are identified: 

  The Marshals of the Voivodships, the Voivodes and the Governors of the districts all 

have main roles in enforcement of regulations and implementation of measures.  

  The  Voivodship  Inspectorates  for  Environment  Protection  and  Voivodship  Sanitary 
Inspectorates have main roles in enforcement of regulations and the implementation of 
measures.  

Finally, the the municipalities also have main roles in the implementation of measures. 

1.1.3  RBMPs – structure and Strategic Environmental Assessment 

Poland's RBMPs do not have sub-plans. 

Poland carried out Strategic Environmental Assessments for all of its RBMPs. 

26 

 
1.1.4 

Public consultation 

Public  consultation  was  carried  out  via  direct  invitation,  telephone  surveys  and  the  Internet. 
For  all  10  RBMPs,  consultation  documents  were  available  for  the  required  six  months8; 
documents  were  available  for  download,  paper  copies  were  available  in  municipal  buildings 
and paper copies were distributed at exhibitions. 

the 

For all 10 RBDs, the following stakeholder groups were actively involved in the development 
of 
energy/hydropower, 
RBMPs: 
local/regional  authorities,  navigation/ports,  NGOs/nature 
fisheries/aquaculture, 
protection  and  water  supply  and  sanitation.  Active  involvement  took  place  via  the 
establishment of advisory groups and their involvement in drafting the RBMPs. 

agriculture/farmers, 

consumer 

industry, 

groups, 

For all 10 RBDs, consultation resulted in the following impacts: addition of new information, 
adjustment of specific measures, commitment to action in the next RBMPs and commitment to 
further research. 

1.1.5 

Integration with the Floods Directive and the Marine Strategy Framework 
Directive 

Poland carried out joint consultations with the Flood Risk Management Plans under the Floods 
Directive9;  joint  consultations  were  not  carried  out  for  the  Marine  Strategy  Framework 
Directive10. 

Poland  informed  that  in  the  joint  consultation  of  RBMPs  and  FRMPs,  there  were  common 
communication  and  consultation  mechanisms  dedicated  to  both  types  of  plans,  including: 
consultation meetings, regional conferences and a National Water Forum. A common slogan, 
‘Niezawodne plany’ (‘Reliable Plans’), and logo were used. The websites for the RBMPs and 
FRMPs were linked and in public surveys, questions on both plans were asked.  

1.1.6 

International coordination 

All 10 of Poland's RBDs are part of international RBDs. This includes Poland's sections of the 
Danube, Elbe and Oder RBDs: for these three international RBDs, an international agreement, 
permanent cooperation body and international RBMP are in place (designated as category one 

8   Poland noted that public consultations on the RBMPs took place from November 2014 to June 2015, a period 

of seven months.  

9   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 

10   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 

27 

 
                                                      
cooperation).  Poland  also  reports  that  explicit  links  have  been  made  with  national  RBMPs 
within  the  international  RBMPs  for  the  Elbe  and  Oder  and  has  explicitly  informed  the 
Commission  that  an  international  RBMP  and  PoM  were  prepared  commonly  with  Germany 
and the Czech republic for the Oder RBD.  

Poland has informed the Commission that there has not been an international RBMP and PoM 
prepared for the Vistula RBD due to the characterisation and location of this RBD. Poland has 
in this context informed that nearly 90% of the RBD is located on Poland’s territory and that 
the  RBD  is  shared  with  Slovakia.  Under  the  framework  of  the  bilateral  commission  with 
Slovakia (see below), working groups have shared information on the characteristics of water 
bodies (e.g. typology, status assessment, identification of HMWBs). Joint monitoring is carried 
out and there is coordination of measures (Poland’s Vistula RBMP notes that recently agreed 
transboundary  cooperation  between  Slovakia  and  Poland  includes  joint  monitoring,  data 
harmonisation,  data  exchange  and  joint  projects).  In  addition,  Poland  has  signed  a  range  of 
bilateral agreements with neighbouring Member States and third countries. These include the 
following11: 

  Poland-Belarus:  Agreement  on  Cooperation  between 

the  Hydrometeorology 
Department of the Ministry of Natural Resources and Environmental Protection of the 
Republic  of  Belarus  and  the  Institute  of  Hydrometeorology  and  Water  Resources  of 
Poland, 2003; 

  Poland-Belarus:  Agreement  between  the  Government  of  the  Republic  of  Poland  the 
Government  of  the  Republic  of  Belarus  on  cooperation  in  the  field  of  environmental 
protection, 2009; 

  Poland-Russia:  Agreement  on  cooperation  in  the  north-eastern  provinces  of  the 
Republic  of  Poland  and  Kaliningrad  oblast  (region)  of  the  Russian  federation  (only 
relating to  environmental protection and  monitoring of transboundary coastal  waters), 
1992; 

  Poland-Slovakia: Agreement between the Government of Slovakia and the Government 
of  Poland  on  the  Management  of  Transboundary  Waters,  1997  (implemented  through 
the Polish-Slovakian Transboundary Waters Commission);  

11   According 

to 

the  Vistula  RBMP  and 

the  2012  Pressures  &  Measures  study  available  at: 

http://ec.europa.eu/environment/archives/water/implrep2007/pdf/Governance-
Transboundary%20Fact%20Sheets.pdf)  

28 

 
                                                      
  Poland-Ukraine: Agreement between the Government of Ukraine and the Government 
of Poland on Cooperation in the Field of Water Management in Frontier Waters, 1996 
(a Ukrainian-Polish Commission works under this Agreement); 

  Poland-Ukraine: Agreement on Cooperation between the State Department of Ecology 
and  Natural  Resources  in  the  Lviv  region,  Ukraine,  and  the  Podkarpatskiy  Provincial 
Water Inspectorate for Environmental Protection, 2004; 

  Poland-Ukraine:  Agreement on Cooperation between  the Bug Basin  Water Resources 
Management Authority of Ukraine and the Regional Water Management Authority of 
Warsaw in Poland, 2006, and; 

  Poland-Former  USSR:  Agreement  between  the  Government  of  the  Polish  People’s 
Republic  and  the  Government  of  the  Union  of Soviet  Socialist  Republics  Concerning 
the Use of Water Resources in Frontier Waters, 1964. 

Working  groups  were  set  up  as  part  of  the  Polish-Slovak  Commission  for  Border  Waters 
covering: 

 

flood  control,  regulation  of  border  watercourses,  water  supply,  land  rehabilitation, 
planning and hydrogeology; 

  hydrology and flood protection in border waters;  

  protection of border waters against pollution, and;  

 

implementation of tasks under the WFD.  

Recently agreed transboundary actions between Slovakia and Poland include joint monitoring, 
data harmonisation, data exchange and experience exchange, and joint projects. 

Poland and Ukraine have set up the following working groups covering: 

  planning on transboundary waters;  

  protection of border waters against pollution;  

 

flood control regulation and drainage; combating extraordinary pollution, and;  

  hydrometeorology and hydrogeology. 

29 

 
Poland and Ukraine have established a coordinated monitoring programme. Coordination takes 
place  with  regard  to  bilaterally  agreed  indicators  and  information  exchange  as  a  part  of  the 
meetings of the Polish-Ukrainian transboundary water commission. 

The RBMP notes that cooperation with Belarus on border waters is carried out via the Polish-
Belarusian  Subcommittee  on  Cross-Border  Co-operation,  under  the  Polish-Belarusian 
Intergovernmental Coordination Committee for in Cross-Border Cooperation.  

Cooperation with the Russian Federation on water management is carried out under the 1964 
agreement between Poland the USSR;  however, it appears that joint activities have currently 
been suspended. 

Further  information  is  included  in  the  reports  on  international  coordination  on  the  Water 
Framework Directive.  

1.2  Main  changes  in  implementation  and  compliance  since  the 

first RBMPs 

Poland  has  strengthened  international  coordination  on  water  management,  including  with 
Slovakia (in the Vistula RBD).  

1.3 

Progress with Commission recommendations 

There were no recommendations on this topic.  

30 

 
 
Topic 2

  Characterisation of the River Basin District 

2.1 

Assessment  of 
requirements in second cycle  

implementation  and  compliance  with  WFD 

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

water bodies 

There was only a change in the number of lake water bodies between the two cycles in Poland 
as  a  whole  -  an  increase  of  six  from  1,038  in  the  first  RBMP  to  1,044  in  the  second  RBMP 
(Table  2.1).  Three  of  these  were  in  the  Vistula  RBD,  (with  an  area  exceeding  50  hectares), 
which were not included in the first RBMPs (PLLW 20061 Likieckie, PLLW 20624 Kuchnia, 
PLLW  20775  Motława  Wielka)12.  The  same  number  of  coastal,  river  and  transitional  water 
bodies  were  reported  for  both  cycles  of  RBMPs.  The  reasons  and  consequences  of  the  re-
delineation were not directly described in the RBMPs. There was an apparent increase in the 
number  of  groundwater  bodies  in  Poland  from  161  in  the  first  RBMPs  to  178  (172)13  in  the 
second RBMPs (Table 2.2).  

There was a 25% reduction in the number of heavily modified water bodies in Poland for the 
second  RBMPs  compared  to  the  first  (Figure  2.1).  The  largest  decrease  was  in  heavily 
modified river water bodies in two RBDs: in the first cycle there were 904 in the Vistula RBD 
and  594  in  the  Oder  RBD  which  were  reduced  to  491  and  559,  respectively,  in  the  second 
cycle. This was accompanied by an almost equivalent number of identified natural river bodies 
between the two RBMPs14. In contrast there was an increase in the number of heavily modified 
lake  water  bodies  between  the  two  RBMPs  from  75  in  the  first  cycle  to  123  in  the  second 
cycle15. 

Table 2.3 shows the differences in size distribution of surface water bodies in Poland between 
the  second  and  first  RBMPs.  There  were  no  significant  changes.  The  minimum  size  criteria 
reported  were  10  km2  catchment  area  for  rivers  and  0.5  km2  surface  area  for  lakes,  which  is 
system B in Annex II of the WFD. 

12  Poland  subsequently  clarified  that  there were  six  new  lake  water bodies  established in  the  2nd  RBMP,  which 

were lakes bigger than 50 ha, important for water management, mistakenly missed in the 1st RBMPs. 

13 Poland clarified that the real number of groundwater bodies is 172. A few of them spread over more than one 
RBD and were there reported as separate water bodies within each RBD, leading to double counting, which 
explains the bigger number in WISE.  

14 Poland subsequently confirmed that the number of riverine HMWBs decreased and the number of natural river 
water bodies grew proportionally. They highlighted that this was because of more detailed analysis and better 
availability of monitoring data in the 2nd cycle. 

15 Poland clarified that for heavily modified lakes there was an update of methodology for identification of them 

which resulted in higher number of such water bodies in the 2nd RBMPs. 

31 

 
                                                      
Table 2.4 summarises the information provided by Poland on how water bodies have evolved 
between the two RBMPs. The changes noted above do not appear to be identified which may 
be an error in the reporting.  

32 

 
Table 2.1 

Number and area/length of delineated surface water bodies in Poland for the secondand first RBMPs 

Lakes 

Rivers 

Transitional waters 

Coastal waters 

Year 

RBD 

Number of 
water bodies 

Total area 
(km2) of 
water bodies 

Number of 
water bodies 

Total length of 
water body (km) 

Number of 
water bodies 

Total area 
(km2) of water 
bodies 

Number of 
water bodies 

Total area 
(km2) of water 
bodies 

2016 

2016 

2016 

2016 

2016 

2016 

2016 

2016 

2016 

2016 

2010 

2010 

2010 

2010 

2010 

2010 

2010 

2010 

2010 

2010 

PL1000  

PL2000  

PL3000  

PL4000  

PL5000  

PL6000 

PL7000  

PL8000  

PL9000  

Total 

PL1000  

PL2000  

PL3000  

PL4000  

PL5000  

PL6000 

PL7000  

PL8000  

PL9000  

Total 

484 

1 

422 

101 

36 

1 153 

1 

793 

281 

70 

11 

2 660 

4 

6 

8 

1 735 

120 

39 

3 

226 

65 485 

65 

107 

147 

41 577 

2 940 

833 

130 

1 044 

2 297 

4 586 

111 510 

481 

1 

420 

101 

35 

1 150 

1 

792 

281 

70 

11 

2 660 

4 

6 

8 

1 735 

120 

39 

3 

226 

65 473 

65 

107 

147 

41 565 

2 938 

834 

130 

1 038 

2 293 

4 586 

111 483 

Source: WISE electronic reports. 

5 

4 

9 

5 

4 

9 

33 

1 475 

462 

6 

4 

316 

350 

1 937 

10 

666 

1 473 

462 

6 

4 

316 

350 

1 936 

10 

666 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 2.2 

Number and area of delineated groundwater bodies in Poland for the secondand first RBMPs  

Year 

RBD 

Number 

2016 

2016 

2016 

2016 

2016 

2016 

2016 

2016 

2016 

2016 

2016 

2010 

2010 

2010 

2010 

2010 

2010 

2010 

2010 

2010 

2010 

PL1000  

PL2000  

PL3000  

PL4000  

PL5000  

PL6000 

PL6700  

PL7000  

PL8000  

PL9000  

Total 

PL1000  

PL2000  

PL3000  

PL4000  

PL5000  

PL6000 

PL6700  

PL7000  

PL8000  

Total 

3 

94 

1 

1 

7 

66 

1 

2 

2 

1 
178 (17216 

2 

89 

1 

63 

3 

2 

1 

161 

Minimum 

0.71 

31.36 

161.6 

210.34 

0.29 

23.67 

14.69 

1 804.53 

504.8 

232.98 

24.59 

31.02 

214.15 

42.24 

1 152.23 

505.61 

233.06 

24.59 

Area (km2) 

Maximum 

360.16 

9 396.67 

161.6 

210.34 

92.76 

4 947.88 

14.69 

5 723.66 

2,008.85 

232.98 

359.66 

8 933.04 

214.15 

5 271.97 

6 089.30 

1 965.23 

233.06 

8 933.04 

Average 

128.49 

1 946.72 

161.6 

210.34 

34.05 

1 783.34 

14.69 

3 764.09 

1,256.82 

232.98 

192.12 

2 049.42 

214.15 

1 873.88 

2 805.93 

1 235.42 

233.06 

1 938.96 

16 Poland clarified that the real number of groundwater bodies is 172. A few of them spread over more than one RBD and were there reported as separate water 

bodies within each RBD, leading to double counting, which explains the bigger number in WISE. 

34 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
Source: WISE electronic reports. Values in brackets provided by Poland as value from WISE is number of subunits. 

Table 2.3 

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

Lake area (km2) 

River length (km) 

Transitional (km2) 

Coastal (km2) 

Year 

RBD 

2016  PL1000  

2016  PL2000  

2016  PL3000  

2016  PL4000  

2016  PL5000  

Min 

Max 

Average 

0.31 

0.81 

102.43 

0.81 

2.38 

0.81 

2016  PL6000 

0.35 

54.18 

1.88 

2016  PL6700  

2016  PL7000  

2016  PL8000  

2016  PL9000  

2010  PL1000  

2010  PL2000  

2010  PL3000  

2010  PL4000  

2010  PL5000  

2010  PL6000 

2010  PL6700  

2010  PL7000  

2010  PL8000  

0.34 

0.49 

29.04 

21.69 

2.78 

1.95 

0.31 

0.81 

102.36 

0.81 

2.39 

0.81 

0.35 

0.34 

0.49 

54.22 

29.02 

21.7 

1.88 

2.78 

1.99 

Min 

1.29 

0.15 

3.23 

2.65 

5.19 

0.43 

1.24 

0.21 

11.71 

1.29 

0.15 

3.23 

2.65 

5.19 

0.43 

1.24 

0.21 

11.72 

Max 

47.32 

234.41 

40.31 

65.27 

34.33 

256.05 

174.58 

81.82 

93.79 

47.29 

234.24 

40.28 

65.22 

34.32 

255.98 

174.55 

81.8 

93.83 

Average 

Min 

Max 

Average 

Min 

Max 

Average 

64.33 

711.21 

295.06 

0.12 

141.17 

52.74 

2.39 

406.95 

115.46 

38.81 

153.67 

87.48 

64.24 

710.28 

294.66 

0.12 

141 

52.68 

2.39 

407.28 

115.55 

38.78 

153.67 

87.47 

20.58 

24.62 

16.2 

17.78 

18.32 

23.96 

24.5 

21.37 

43.23 

20.57 

24.61 

16.19 

17.77 

18.32 

23.96 

24.48 

21.37 

43.24 

Source: WISE electronic reports 

35 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 2.1 
Proportion of surface water bodies in Poland designated as artificial, heavily 
modified or natural for the second and first RBMPs. Note that the numbers in parenthesis 
are the numbers of water bodies in each water category 

Source: WISE electronic reports. 

Table 2.4 

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

Groundwater 

Rivers 

Lakes 

Transitional  Coastal 

Type of water body change for second 
RBMPs 

Aggregation 

Splitting 

Aggregation and splitting 

Extended area 

Creation 

Deletion 

Change in code 

No change 

178 (172) 

161 

1 

1 

6 

4585 

1038 

9 

9 

9 

10 

10 

10 

Total water bodies before deletion 

339 

Delineated for second RBMPs (after 
deletion from first RBMPs) 

178 (172) 

4587 

4586 

1044 

1044 

Source: WISE electronic reports. Values in brackets were provided by Poland as explained above. 

36 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Poland  reported  147  transboundary  surface  water  bodies  in  eight  of  the  ten  RBDs;  the  most 
(67) were in the Oder RBD17. Transboundary coastal lake and transitional water bodies were 
also reported. No transboundary groundwater bodies were reported. 

2.1.2  Typology of surface water bodies 

Table 2.5 shows the number of surface water body types at RBD level in Poland for the first 
and second RBMPs. 25 river types were reported for Poland in the second cycle; one type was 
common to six RBDs and five types to four RBDs. Three coastal, four transitional and thirteen 
lake types were reported. There were only small changes in the number of types reported for 
each  water  category  in  each  RBD  between  the  two  RBMPs.  All  differences  were  for  lakes, 
where there was a decrease of two types in the Oder RBD, a decrease of one in the Pregolya 
RBD and an increase of one in the Nemunas RBD.  

Table 2.5 

Number of surface water body types at RBD level in Poland for the first 
and second RBMPs  

RBD 

Rivers 

Lakes 

Transitional 

Coastal 

2010 

2016 

2010 

2016 

2010 

2016 

2010 

2016 

PL1000  

PL2000  

PL3000  

PL4000  

PL5000  

PL6000 

PL6700  

PL7000  

PL8000  

PL9000  

TOTAL 

2 

24 

1 

1 

2 

21 

0 

5 

6 

1 

25 

2 

24 

1 

1 

2 

21 

5 

6 

1 

25 

0 

13 

1 

0 

0 

9 

0 

5 

3 

0 

0 

13 

1 

0 

0 

7 

4 

4 

0 

13 

13 

0 

4 

0 

0 

0 

2 

0 

0 

0 

0 

4 

0 

4 

0 

0 

0 

2 

0 

0 

0 

4 

0 

3 

0 

0 

0 

2 

0 

0 

0 

0 

3 

0 

3 

0 

0 

0 

2 

0 

0 

0 

3 

Source: WISE electronic reports  
Note that the total is not the sum of the types in each RBD as some types are shared by RBDs 

It  was  stated  in  the  RBMP  that  in  Poland,  surface  water  types  were  determined  based  on 
system A supplemented with selected parameters of system B. It was stated in the RBMP for 
Vistula  that  reference  conditions  for  benthic  invertebrates  were  under  development.  Other 
biological parameters were reported against other types of water bodies. However, it appears 

17  Poland  subsequently  highlighted  that the coordination  of  characteristics  of water  bodies  was  provided  by  the 

Oder Commission (PL/DE/CZ). 

37 

 
 
 
 
 
 
 
                                                      
that  not  every  biological  parameter  was  considered  for  each  water  type  e.g.  fish  were  not 
considered for type 26 for rivers, macrophytes were only considered for types:  4, 5, 6, 7, 12, 
17,  18,  24;  phytobenthos  for  types  4,  5,  17,  18,  19,  20,  24,  25  etc.  In  terms  of  lake  water 
bodies,  transitional  water  bodies  and  coastal  water  bodies  there  was  no  detailed  information 
regarding the types and biological parameters considered but all required biological parameters 
were listed. 

All national lake types were intercalibrated against three common intercalibration types.  

10 lake types also had two equivalent intercalibration types. This seems to be a reporting error. 
14  national  river  types  were  intercalibrated  against  four  common  intercalibration  types. 
However, four river types were reported to have two different intercalibration types. The other 
national river types did not have equivalent common intercalibration types: this equates to 37% 
of  river  water  bodies  without  an  equivalent  intercalibration  type18.  The  translation  of 
intercalibration  types  to  non-calibrated  national  types  is  therefore  an  important  aspect  for 
consideration.  Only  one  of  the  four  transitional  water  types  had  equivalent  intercalibration 
types equating to three out of the total nine transitional water bodies. All coastal water body 
types had equivalent intercalibration types though one type had two equivalent intercalibration 
types: this could again be a reporting error.  

No  information  was  found  in  the  RBMPs  on  whether  the  typology  was  coordinated  with 
Member  States19.  A  typology  background  document  was  provided  which  was  dated  2004. 
However,  it  was  indicated  in  the  background  documents20  (there  are  three  reports  published, 
each for a separate phase) that the typology of member state sharing borders was considered 
and researched as there is a short section written about some of the Member States. There was 
more  information  on  Germany  (sharing  Oder  RBD)  and  its  similarities  to  the  Polish  system 
(ecoregions considered, similar to Poland, system A used with some aspects of system B). 

18 Poland highlighted that it is usual that intercalibration types do not correspond directly to national types as it is 
virtually  impossible  to  cover  regional  diversity  with  pan-European  typology  and  as  a  result,  the 
correspondence is a trade-off. 

19 Poland subsequently highlighted that in the frame of bilateral PL-CZ Commission on Transboundary Waters, a 
working group ‘WFD’ acts. Poland stated that the group shares information on typology. Also in the frame of 
bilateral  PL-DE  Commission  on  Transboundary  Waters  working  group  W2  acts  and  shares  information  on 
water typology.  

20   http://cdr.eionet.europa.eu/pl/eu/wfd2016/documents/national/envwbtrxw/  -  link  to  a  report  on  Typology: 

13Typologia.zip 

38 

 
 
                                                      
2.1.3  Establishment of reference conditions for surface water bodies 

Table  2.6  shows  the  percentage  of  surface  water  body  types  in  Poland  with  reference 
conditions  established  for  the  first  and  second  RBMPs.  In  the  second  cycle  Poland  reported 
that reference conditions had been established for all water body types in each category for all 
biological,  hydromorphological  and  physicochemical  quality  elements.  In  the  first  cycle,  by 
comparison,  only  8  out  of  26  river  types  had  a  reference  condition  established,  and  only 
preliminary  reference  conditions  were  determined  for  the  remainder.  Therefore  there  was  a 
significant improvement in the establishment of reference conditions for surface water bodies 
between the two RBMPs.  

Table 2.6 

Percentage of surface water body types in Poland with reference conditions 
established for all, some and none of the biological, hydromorphological and 
physicochemical quality elements. Numbers in parenthesis are the number of 
types in each category  

Water 
category 

Water types 

Biological quality 
elements 

Hydromorphological 
quality elements 

Physicochemical 
quality elements 

All  

100% 

100% 

100% 

Lakes (13) 

Some 

None 

All  

Rivers (25) 

Some 

Transitional 
(4) 

None 

All  

Some 

None 

All  

Coastal (3) 

Some 

None 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

Source: WISE electronic reports 

No information was found in the RBMPs in terms of coordination of the identification of type-
specific reference conditions with other Member States or non-European Union countries. A 
typology background document was provided which was dated 2004. No new information has 
been reported.  

39 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
2.1.4  Characteristics of groundwater bodies 

All RBDs with surface water bodies (9) had reported links with groundwater bodies, and all 10 
RBDs had groundwater bodies with links to  terrestrial ecosystems. The characteristics  of the 
geological formation and layering of groundwater bodies were also reported. 

2.1.5 

Significant pressures on water bodies 

In  the  second  cycle  Poland  identified  13  defined  significant  pressures  on  surface  waters  and 
also  unknown  and  historical  pressures  and  pressures  from  tourism  and  recreation.  No 
abstraction  pressures  were  reported21.  Diffuse  pollution  from  discharges  not  connected  to 
sewerage network were reported in six RBDs, diffuse agricultural and atmospheric deposition 
pressures  in  five  RBDs  and  point  source  pressures  from  urban  waste  water  in  four  RBDs. 
‘Hydromorphological alteration - Other’ was the most reported significant pressure on coastal 
and transitional waters in Poland in the second cycle: significant diffuse agricultural pressures 
were also reported for coastal waters but not for transitional waters (Figure 2.2). 

Diffuse  agricultural  pressures  affected  the  largest  proportion  of  lakes  (62%)  in  Poland  but 
affected only 8% of river water bodies. The most significant pressure on rivers (50% of river 
water bodies) was unknown anthropogenic pressures.  

The comparison of pressures between the two RBMPs may have been confounded by changes 
in  delineation  of  water  bodies  and  also  changes  in  definition  of  pressures.  There  were  only 
minor changes in the delineation of surface water bodies in Poland between the two RBMPs. 
There  were,  however,  some  noticeable  differences  between  the  pressure  types  and  extent  of 
pressures  between  the  two  RBMPs  (Figure  2.3).  The  proportion  of  water  bodies  affected  by 
diffuse agriculture also increased for the second RBMPs: 2% of lakes in the first cycle, 62% in 
the  second  cycle22;  3%  of  rivers  in  in  the  first  cycle,  8%  in  the  second  cycle.  Abstraction 
pressures were reported to affect 12% of surface water bodies in 2010 but were not reported at 
all in the second cycle. Unknown anthropogenic pressures were also reported to be significant 
in the second cycle23. 

21  Poland  subsequently  clarified  that  even  if  surface  water  abstraction  has  not  been  identified  as  a  significant 

pressure it is controlled in the frame of measures implemented at national level. 

22  Poland  highlighted  that  the  higher  number  of  lakes  under  pressure  from  agriculture  is  a  result  of  new 
methodology  used  for  pressure  identification:  nitrogen  and  phosphorus  loads  were  calculated  as  those 
produced in a whole catchment of the lake and a 1000-metre buffer around the lake, with morphological and 
hydrographic variability of the lake taken into account. Poland stated that in the 1st cycle mainly lakes located 
on nitrate vulnerable zones were reported as being under pressure from agriculture. 

23  Poland  subsequently  stated  that  “Anthropogenic  pressure  –  unknown”  was  reported  when  identification  of 
pressure was not possible, which included all those water bodies with status assessed upon expert judgement 

40 

 
                                                      
27  pressures  were  reported  to  not  have  been  included  for  surface  waters  in  the  second  cycle 
including  abstractions  and  industrial  point  sources24.  No  information  was  reported  in  the 
RBMP  on  why  the  pressures  reported  to  WISE  were  not  considered  at  the  risk  assessment 
stage. 

7 different pressures types were reported to be significant for groundwater in the second cycle. 
The most significant in terms of affected water bodies was diffuse pollution from mining (8% 
of groundwater bodies) followed by alteration of groundwater level (7%) (Figure 2.3).  

There was a significant increase in the number of delineated groundwater bodies between the 
two RBMPs (from 161 to 172). This increase in numbers of water bodies does not explain the 
large differences between the type and extent of pressures reported for groundwater for the two 
RBMPs.  In  2010,  abstractions  for  public  water  supply  were  affecting  92%  of  groundwater 
bodies; in the second cycle none were reported to be affected25. Diffuse mining pressures were 
reported to be most significant in the second cycle but had not been in 2010. 

and which reliable assessment of pressure impact on water status was impossible to be done for, were reported 
as  water  bodies  with  unknown  pressure.  Poland  also  stated  that  water  bodies  assessed  based  on  monitoring 
results  but  with  no  significant  wastewater  discharge  from  industry  or  communal  WWTPs  in  its  catchment 
were  reported  as  water  bodies  with  unknown  pressure  as  well.  Poland  indicated  that  for  such  water  bodies 
implementation of an approach aiming at confirmation if the identified pressure is significant or not and if it 
has impact on water status was planned in the PoM. 

24  Poland  subsequently  highlighted  that  pressures  from  industry  sector  were  reported  mainly  as  ‘Point  -  Urban 
waste  water’,  ‘Diffuse  –  Mining’  (because  of  mining  industry)  and  ‘Point  –  Other’.  A  large  number  of 
measures  targeting  wastewater  management  (i.e.  construction,  modernisation,  renovation,  development  of 
WWTPs) implemented in the frame of the National Municipal Wastewater Treatment Programme target, at the 
same time, point-pressures from industry. 

25 Poland subsequently stated that in the frame of standard procedure defined in the regulation of the Minister of 
Environment of 6.11.2008 r. information on registered abstraction of groundwaters (annual sum and average 
daily  abstraction)  is  gathered.  They  also  highlighted  that  in  2011  information  on  scale  of  abstraction  was 
collected from 18 731 groundwater intakes (together summed up to 1 584,7 mln m3). 

41 

 
 
 
                                                                                                                                                        
Figure 2.2 

The  most  significant  pressures  on  surface  water  bodies  and  groundwater 
bodies in Poland for the second RBMPs  

Source: WISE electronic reports 

42 

 
 
 
 
 
Figure 2.3  Comparison of pressures on surface water bodies in Poland in the first and 
second RBMPs. Pressures presented at the aggregated level.  

Source: WISE electronic reports. Not all pressures are shown. 

2.1.6  Definition and assessment of significant pressures on surface and groundwater 

The only pressure on surface waters where potentially quantitative numerical tools were used 
to assess significance in the second cycle was for point source pressures where they were used 
in combination with expert judgement. Expert judgment was reported to be used to assess the 
significance of diffuse source pressures and pressure arising from water flow modifications26. 
Water abstraction pressures were not assessed27.  

For  the  first  RBMPs  numerical  methods  were  mainly  used  to  assess  the  significance  of  the 
identified  pressures  arising  from  point  source,  diffuse  source  and  abstraction  pressures  on 
surface waters. In the first RBMPs, numerical tools were used to assess the significance, which 
also  appears  to  have  been  the  case  for  the  second  RBMPs.  The  RBMPs  describe  how  point, 
diffuse  and  hydromorphological  significant  pressures  were  assessed  separately  and  then  how 
the cumulative effects of these pressures were considered.  

It  was  stated  in  Vistula  RBMP  that  exceedances  of  physicochemical  indicators  (including 
biogenic  substances)  based  on  2010-2013  monitoring  and  significant  municipal  sewage 

26  Poland  subsequently  clarified  that  diffuse  pressures  assessment  was  based  both  on  expert  judgement  and 
additional  analysis  performed  during  drafting  the  programmes  of  measures.  Poland  further  clarified  that  the 
assessment  of  significance  of  diffuse  pressure  was  based  on  calculated  or  estimated  numbers  presented  as 
nutrient loads originating from those sources, in relations to thresholds defined in the law. 

27  Poland  highlighted  that  in  2nd  cycle  special  attention  was  paid  to  keeping  a  clear  link  between  water  body 

status assessment, identified pressures and measures planned as well as expertises prepared. 

43 

 
 
                                                      
discharges were identified. In the RBMP, thresholds of significant pressure were mentioned in 
relation to nitrogen and phosphorus loads in the catchment and in a 1 000 m wide strip around 
each lake, taking into account the adopted abiotic types of lakes. The thresholds of significant 
pressure  were  determined  based  on  the  analysis  of  the  relationship  between  the  condition  of 
monitored lakes and the intensification of pressure affecting those lakes. Identification of this 
relationship made it possible to determine the risk of not reaching the environmental objective 
by lakes for which monitoring was not carried out and data on the status of their waters was not 
available, while data on the pressure affecting them were available. Those unmonitored lakes 
were  indicated  to  be  at  risk  if  the  threshold  values  were  exceeded  for  both  parameters 
(phosphorus and nitrogen loads) or one of them.  

The  threshold  values  were  also  given  for  point  sources  in  a  table  in  the  RBMP  which  were 
limit concentration values used to calculate the permissible load of different parameters such as 
biological  oxygen  demand,  chemical  oxygen  demand,  nitrogen,  phosphorus  and  nickel.  This 
implies that some threshold values were used for both point and diffuse source pressures, and it 
was reported that significance was not defined in terms of thresholds in the WISE data but that 
they were linked to the failure of objectives.  

to  WISE 

that  no  numerical 

It  was  reported 
threshold  values  were  provided  for 
hydromorphological  pressures28.  The  identification  of  hydromorphological  pressures  was 
carried out on the basis of data from the survey of water administrators and information on the 
current  flood  protection  system  and  studies  carried  out  in  the  field  of  verification  of  the 
determination of heavily  modified water bodies. Maps of different significant pressures were 
also  presented  in  the  RBMP.  The  hydromorphological  pressure  was  considered  significant, 
based  on  monitoring  data  from  2010-2013,  where  only  biological  indicators  were  exceeded, 
and  at  the  state  of  preliminary  determination  of  surface  water  bodies  were  designated  as 
heavily modified water bodies. Such surface water bodies were also considered to be at risk of 
failing to achieve environmental objectives due to hydromorphological pressure affecting the 
state of biological elements.  

Hydromorphological  pressure  was  identified  and  reported  also  for  particularly  important  or 
important rivers where transverse buildings with need of patency restoration existed. The tools 
used to assess the significance of pressures on groundwater were all based on a combination of 
numerical tools and expert judgment in all RBDs and for all assessed pressures. Significance 
was defined in terms of thresholds and linked to the potential failure of objectives. 

28  Poland  subsequently  clarified  that  for  the  hydromorphological  pressure  assessment,  the  threshold  values  of 
indicators for preliminary identification of heavily modified water bodies were  used (if biological indicators 
had been exceeded).  

44 

 
                                                      
2.1.7 

Significant impacts on water bodies  

“Unknown impact’ type was reported to  affect the largest proportion (36%) of surface water 
bodies  in  Poland,  followed  by  nutrient  pollution  (22%)  and  altered  habitats  due  to 
morphological changes (8%) (Figure 2.4).  

Figure 2.4 

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

Source: WISE electronic reports 

45 

 
 
 
 
The  three  most  significant  reported  impacts  on  groundwater  bodies  in  Poland  (Figure  2.4) 
were: 

  abstraction  exceeding  available  groundwater  resource  (lowering  water  table)  (7%  of 

groundwater bodies); 

  diminution of quality of associated surface waters for chemical or quantitative reasons 

(7%), and; 

  damage  to  groundwater-dependent  terrestrial  ecosystems  for  chemical  or  quantitative 

reasons (4.5%).  

2.1.8  Groundwater bodies at risk of not meeting good status 

Two  RBDs  reported  that  groundwater  bodies  were  at  risk  of  not  achieving  good  chemical 
status:  around  8%  of  groundwater  bodies  were  at  risk in  Poland  as  a  whole.  13  groundwater 
pollutants  were  reported  as  causing  a  risk  to  the  achievement  of  good  chemical  status  in 
groundwater bodies in two of the ten RBDs in Poland. Nitrate affected the most groundwater 
bodies (six) in the two RBDs. 

7%  of  groundwater  bodies  in  Poland  were  reported  to  be  at  risk  of  not  achieving  good 
quantitative status with saline or other intrusion and effects on water balance to be the cause of 
the risk. The groundwater bodies at risk of not achieving good quantitative status were only in 
the Vistula and Oder RBDs. 

2.1.9  Quantification of the gap and apportionment of pressures  

Poland reported the gaps to be filled for all significant pressures reported at the groundwater 
and  surface  water  body  level.  36  different  chemical  substances  causing  failure  of  objectives 
were reported by Poland: 12 chemical substances in groundwater and 25 chemical substances 
in surface water. The chemical substances include Priority Substances and polluting substances 
in  groundwater.  Gaps  were  reported  for  each  in  terms  of  the  number  of  water  bodies  where 
chemical  pressures  were  preventing  the  achievement  of  objectives  and  the  number  of  water 
bodies  where  diffuse  atmospheric  deposition  pressures  were  preventing  the  achievement  of 
objectives. 

2.1.10  Inventories of emissions, discharges and losses of chemical substances 

Article  5  of  the  Environmental  Quality  Standards  Directive  (EQS  Directive)29  requires 
Member  States  to  establish  an  inventory  of  emissions,  discharges  and  losses  of  all  Priority 

29   Directive 2008/105/EC of the European Parliament and of the Council of 16 December 2008 on environmental 
quality  standards  in  the  field  of  water  policy,  amending  and  subsequently  repealing  Council  Directives 

46 

 
                                                      
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). 

All 10 RBDs in Poland reported inventories of emissions, discharges and losses and all Priority 
Substances  and  groups  of  Priority  Substances  are  included,  apart  from  benzo(g,h,i)perylene 
and indeno(1,2,3-cd) pyrene (these belong to the group of polycyclic aromatic hydrocarbons).  

The two step approach from the Common Implementation Strategy Guidance Document n°2830 
has  not  been  followed  for  any  of  substances  included  in  the  inventories.  Tier  1  of  the 
methodology  was  implemented  for  all  substances  included  in  the  inventories  (while  the 
Guidance  Document recommends  to  implement at least Tier 1 + 2 for substances relevant at 
RBD level). The data quality was assessed as medium. 

2.2  Main changes in implementation and compliance since first cycle 

There was a 25% reduction in the number of heavily modified water bodies in Poland for the 
second RBMPs compared to the first. The largest decrease was in heavily modified river water 
bodies in two RBDs: the Vistula and the Oder. This was accompanied by an almost equivalent 
number  of  identified  natural  river  bodies  between  the  two  RBMPs.  In  contrast  there  was  an 
increase in the number of heavily modified lake water bodies between the two RBMPs from 75 
in the first RBMP to 123 in the second cycle. There were only small changes in the number of 
types  reported  for  each  water  category  in  each  RBD  between  the  two  RBMPs,  with  all 
differences being for lakes. 

There  were,  however,  some  noticeable  differences  between  the  pressure  types  and  extent  of 
pressures  between  the  two  RBMPs.  Abstraction  pressures  were  reported  to  affect  12%  of 
surface  water  bodies  in  the  first  cycle  but  were  not  assessed  in  the  second  cycle31.  The 
proportion  of  water  bodies  affected  by  diffuse  agriculture  also  increased  for  the  second 
RBMPs: 2% of lakes in the first cycle, 62% in the second cycle; 3% of rivers in the first cycle, 

82/176/EEC, 83/513/EEC, 84/156/EEC, 84/491/EEC, 86/280/EEC and amending Directive 2000/60/EC of the 
European Parliament and of the Council   
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008L0105-20130913 

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

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

31  Poland  subsequently  clarified  that  even  if  surface  water  abstraction  has  not  been  identified  as  a  significant 

pressure it is controlled in the frame of measures implemented at national level. 

47 

 
                                                                                                                                                        
and 8% in the second cycle. This appears to have been from improved methodology that used 
loading  data  as  well  as  expert  judgement.  Unknown  anthropogenic  pressures  were  also 
reported to be significant in the second cycle: this pressure type was not used in the first cycle 
reports.  

There was a significant increase in the number of delineated groundwater bodies between the 
two RBMPs (from 161 to 172). This increase in numbers of water bodies does not explain the 
large differences between the type and extent of pressures reported for groundwater for the two 
RBMPs. In 2010, abstractions for public water supply affected 92% of groundwater bodies, in 
the  second  cycle  none  were  reported  to  be  affected.  Groundwater  abstractions  were  assessed 
using a combination of numerical tools and expert judgement and no changes in methodology 
were  identified  so  the  reasons  for  this  change  are  unclear.  Diffuse  mining  pressures  were 
reported to be most significant in the second cycle but had not been in the first cycle. 

2.3 

Progress with Commission recommendations 

The Commission recommendations based on the first RBMPs and first PoM 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 RBMPs, to ensure that adequate measures can be put in place 
before the next RBMPs. 

types 

in  each  category 

for  all  water  body 

Assessment:  In  the  second  cycle  Poland  reported  that  reference  conditions  have  been 
established 
for  all  biological, 
hydromorphological  and  physicochemical  quality  elements  which  is  a  significant 
improvement since the first RBMPs. Pressures have been assessed using a combination 
of  expert  judgement  and  quantitative  analysis.    There  was  significant  reporting  of 
“unknown impacts’ which could imply that methods were not discriminative enough for 
use for WFD purposes32. Overall there has been progress and this recommendation has 
been partially fulfilled. 

32  Poland  subsequently  stated  that  “Anthropogenic  pressure  –  unknown”  was  reported  when  identification  of 
pressure was not possible, which included all those water bodies with status assessed upon expert judgement 
and which reliable assessment of pressure impact on water status was impossible to be done for, were reported 
as  water  bodies  with  unknown  pressure.  Poland  also  stated  that  water  bodies  assessed  based  on  monitoring 
results  but  with  no  significant  wastewater  discharge  from  industry  or  communal  WWTPs  in  its  catchment 
were  reported  as  water  bodies  with  unknown  pressure  as  well.  Poland  indicated  that  for  such  water  bodies 

48 

 
 
                                                      
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 RBMPs 

3.1.1  Monitoring of ecological status/potential 

Monitoring programmes 

Article  8.1  of  the  WFD  requires  Member  States  to  establish  monitoring  programmes  for  the 
assessment of the status of surface water and of groundwater in order to provide a coherent and 
comprehensive overview of water status within each RBD. Territorial waters are not  a water 
body category under WFD. However, it should be noted that under Article 2(1) of the WFD, 
territorial waters are included for the assessment and reporting of chemical status. 

There were several gaps in the reported monitoring programmes in relation to water categories 
identified in Poland. There were no programmes for the surveillance monitoring of rivers in the 
Danube, Jarft, Elbe or Dniester RBDs. There was no WFD surveillance monitoring programme 
for  coastal  waters  and  transitional  waters  in  the  Vistula  or  Oder  RBDs.  There  was  no  lake 
monitoring programme in the Swieza RBD, although there is one lake water body. In addition, 
no  monitoring  programme  was  reported  for  territorial  waters  even  though  two  RBDs  have 
delineated coastal water bodies. 

Poland  subsequently  stated  that  a  surveillance  monitoring  programme  was  implemented  for 
river basins Jarf, Dniester, Danube and Łaba as well as in all transitional and coastal areas in 
the period 2010-2012. The non-reporting of these programmes was probably an error. 

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

Table  3.1  compares  the  number  of  monitoring  sites  used  for  surveillance  and  operational 
purposes between the two RBMPs, and Table 3.2 gives the number of sites used for different 
purposes  for  the  second  RBMPs.  Note  that  no  information  has  been  provided  for  the  Ucker 
RBD as no surface water body was delineated in this RBD. 

For rivers, there were five times more monitoring sites used for operational purposes than for 
surveillance  monitoring  in  the  second  RBMPs,  while  for  lakes  there  were  almost  equal 
numbers of monitoring sites for operational and for surveillance monitoring.  

implementation of an approach aiming at confirmation if the identified pressure is significant or not and if it 
has impact on water status was planned in the PoM. 

49 

 
                                                                                                                                                        
There was a significant reduction in the number of operational monitoring sites from the first 
to the second RBMPs in all four water categories. Proportionally the largest decrease was in 
transitional waters (71%), followed by lakes (46%), coastal waters (33%) and rivers (14%).  

Table 3.1 

Number of sites used for surveillance and operational monitoring in Poland 
for the second and first RBMPs. Note that for reasons of comparability with 
data reported in the first RBMPs, the data for the second RBMPs does not 
take into account whether sites are used for ecological and/or chemical 
monitoring  

Rivers 

Lakes 

Transitional 

Coastal 

Surv. 

Op 

Surv. 

Op 

Surv. 

Op 

Surv. 

Op 

second RBMP 

PL_1000 

PL_2000 

PL_3000 

PL_4000 

PL_5000 

PL_6000 

PL_7000 

PL_8000 

PL_9000 

Total by type of site 

Total number of 
monitoring sites 

first RBMP 

PL_1000 

PL_2000 

PL_3000 

PL_4000 

PL_5000 

PL_6000 

PL_7000 

PL_8000 

PL_9000 

0 

192 

1 

0 

0 

133 

8 

4 

0 

338 
(494) 

5 

1031 

1 

1 

3 

734 

31 

6 

1 

0 

151 

0 

0 

0 

133 

30 

8 

0 

0 

169 

0 

0 

0 

166 

30 

8 

0 

5 

4 

6 

4 

1813 

322 

373 

0 

9 

0 

10 

1879 

451 

9 

10 

2 

304 

0 

1 

2 

6 

1134 

1 

1 

4 

0 

303 

0 

0 

0 

0 

315 

0 

0 

0 

193 

913 

229 

324 

5 

15 

1 

41 

14 

1 

32 

17 

0 

32 

18 

0 

0 

8 

0 

0 

0 

8 

0 

0 

0 

0 

19 

0 

0 

0 

12 

0 

0 

0 

31 

0 

8 

0 

0 

0 

6 

0 

0 

0 

0 

9 

0 

0 

0 

6 

0 

0 

0 

14 

15 

Total by type of site 

523 

2115 

581 

689 

16 

Total number of 
monitoring sites 

2194 

707 

31 

15 

Sources: Member States electronic reports to WISE. The number in parentheses was subsequently provided by 
Poland, to correct what seems to have been a reporting error 

50 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
Subsequently  Poland  indicated  that  the  seeming  reduction  of  representative  monitoring  sites 
from  the  first  to  the  second  RBMPs  was  the  result  of  redefinition  of  the  role  of  monitoring 
sites.  Changes  in  the  legal  acts  concerning  monitoring  improved  the  management  of 
monitoring data, making the assessment of water bodies more representative and facilitated the 
quality  of  the  analysis  of  the  status  of  waterbodies.  Monitoring  sites  are  designed  for  the 
representative  assessment  of  a  whole  water  body,  and  are  composed  of  many  subsites.  In 
surveillance monitoring there are up to eight different functional types of monitoring subsites. 

Poland also indicated that some of reported changes from the first to the second RBMPs may 
be  due  to  how  the  information  has  been  reported  to  WISE  -  there  have  been  unintended 
reporting errors. 

Table 3.2 

Number of monitoring sites in relevant water categories used for different 
purposes for the second RBMP in Poland. Note that no differentiation is made 
between sites used for ecological monitoring and/or chemical monitoring 

Monitoring Purpose 

Lakes 

Rivers  Transitional  Coastal 

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

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

ECO - Ecological status 

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

INV - Investigative monitoring 

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

OPE - Operational monitoring 

SUR - Surveillance monitoring 

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

Total sites irrespective of purpose 

52 

1 

22 

193 

10 

7 

373 

322 

159 

464 

47 

121 

12 

582 

94 

167 

1813 

338 

1460 

2108 

Source: WISE electronic reporting 

7 

6 

9 

9 

9 

9 

9 

8 

10 

10 

10 

10 

There were also significant reductions in the number of surveillance monitoring sites from the 
first  to  the  second  RBMPs,  with  no  sites  in  coastal  and  transitional  waters  in  the  second 
RBMPs.  

There  were  reductions  in  lake  and  river  surveillance  sites,  respectively,  from  the  first  to  the 
second  RBMPs  corresponding  to  45%  for  lakes  (from  581  to  322  sites)  and  35%  for  rivers 
(from 523 to 338 sites),  

51 

 
 
 
 
 
 
 
 
 
Table 3.2 gives the number of sites reported to be used for different purposes for the second 
RBMP.  Differences  between  the  numbers  of  sites  reported to  be  used  for  “ecological  status” 
and  for  surveillance/operational  monitoring  probably  indicate  some  uncertainty  on  what  was 
expected  to  be  reported  by  Member  States  for  these  elements  leading  to  some  unintended 
reporting errors. 

Figure  3.1  shows  the  percentage  of  water  bodies  included  in  surveillance  and  operational 
monitoring for the second plans (no data at water body level was provided for the first plans). 
Around  a  third  of  lake  water  bodies  were  monitored  for  both  operational  purposes  and 
surveillance  purposes  in  the  second  RBMPs  with  around  a  third  of  river  water  bodies  being 
monitored  for  operational  purposes  and  only  7%  being  monitored  for  surveillance  purposes. 
No transitional and coastal water bodies were monitored for surveillance purposes but all were 
monitored for operational purposes. 

Figure 3.1 

Percentage  of  water  bodies  included  in  surveillance  and  operational 
monitoring in Poland for second RBMPs (2016). Note no differentiation is 
made  between  water  bodies  included  in  ecological  and/or  chemical 
monitoring 

Source: WISE electronic reporting 

52 

 
 
Monitoring sites and monitored water bodies used for ecological status/potential 

Figure 3.2  shows the proportion of water bodies in each ecological status/potential class that 
are  included  in  surveillance  monitoring  in  Poland.  As  stated  above,  there  is  no  longer  any 
surveillance monitoring of transitional and coastal waters reported for Poland33. 

Figure 3.2  

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

Source: WISE electronic reports 

Transboundary surface water body monitoring 

Poland  reported  transboundary  river  water  bodies  in  eight  of  its  10  RBDs.  Most  were  in  the 
Oder  (67)  and  Vistula  (49)  RBDs.  Transboundary  coastal,  lake  and  transitional  water  bodies 
were  also  reported.  No  monitoring  sites  were  reported  to  be  part  of  international  monitoring 
networks.  

Poland subsequently clarified that the monitoring of transboundary waterbodies was continued 
during  the  2010-2015  monitoring  cycle.  All  of  the  waterbodies  subject  to  international 
cooperation  were  covered  by  investigational  monitoring  according  to  these  agreements.  The 
transboundary  waterbodies  that  are  most  important  to  water  management  were  additionally 
covered  by  surveillance  monitoring  and,  if  the  pressure  and  impact  assessment  indicate  it 

33  Poland  subsequently  stated  that  this  lack  of  reporting  of  surveillance  monitoring  in  transitional  and  coastal 

waters was probably an unintended reporting error. 

53 

 
 
                                                      
necessary, by operational monitoring. The gaps in the electronic reports to WISE are probably 
due to reporting errors. 

Quality elements monitored (excluding River Basin Specific Pollutants) 

Table  3.3  illustrates  the  quality  elements  used  for  the  monitoring  of  lakes  and  rivers  for  the 
second RBMPs: no differentiation is made between the purposes of monitoring. 

Table 3.3 

Quality  elements  monitored  for  the  second  RBMPs  in  Poland  (excluding 
River  Basin  Specific  Pollutants).34  Note:  quality  element  may  be  used  for 
surveillance  and/or  operational  monitoring.  “Other  aquatic  flora”  may  be 
reported  separately  for  its  component  sub-quality  elements,  for  example, 
macrophytes and phytobenthos in rivers, by some Member States. 

Biological quality elements 

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

s
e
t
y
h
p
o
r
c
a
M

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

c
i
h
t
n
e
B

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

h
s
i
F

s

m
r
e
p
s
o
i
g
n
A

e
a
g
l
a
o
r
c
a
M

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

a
r
o
l
f

s
e
i
c
e
p
s

r
e
h
t
O

Rivers 

Lakes 

Yes  Yes  Yes  Yes  No  

Yes  Yes  Yes  Yes  No  

No  Yes 

No  Yes 

Transitional 

Coastal 

Yes 

Yes 

No   No   No   No  No  Yes 

No  

No   No   No  Yes 

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

s
n
o
i
t
i
d
n
o
c

Yes 

Yes 

Yes 

Yes 

General physicochemical quality elements 

l
a
m
r
e
h
T

s
n
o
i
t
i
d
n
o
c

Yes 

Yes 

Yes 

Yes 

n
o
i
t
a
n
e
g
y
x
O

s
n
o
i
t
i
d
n
o
c

Yes 

Yes 

Yes 

Yes 

y
t
i
n
i
l
a
S

s
n
o
i
t
i
d
n
o
c

Yes 

Yes 

Yes 

Yes 

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

s
u
t
a
t
s

Yes 

Yes 

Yes 

Yes 

n
e
g
o
r
t
i

N

s
n
o
i
t
i
d
n
o
c

Yes 

Yes 

Yes 

Yes 

Source: WISE electronic reporting 

Rivers 

Lakes 

Transitional 

Coastal 

Hydromorphological quality 
elements 

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

e
m
i
g
e
r

l
a
d
i
t

No 

No 

No 

No 

s
u
r
o
h
p
s
o
h
P

s
n
o
i
t
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34  Poland  subsequently  clarified  that  the  following  quality  elements  are  monitored:  benthic  invertebrates  in 
transitional  and  coastal  waters;  fish  in  rivers,  lakes  and  transitional  waters;  angiosperms  in  transitional  and 
coastal  waters;  macroalgae  in  transitional  and  coastal  waters  (where  it  occurs  naturally);  and  the  three 
hydromorphological quality elements in lakes. 

54 

 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
There were major gaps in the quality elements monitored in Poland. Fish were not monitored 
in rivers, lakes and transitional waters; the only biological quality element monitored in coastal 
and  transitional  waters  was  phytoplankton  (though  chlorophyll  a  was  reported  as  an  ‘other’ 
quality  element);  macrophytes  and  phytobenthos  are  not  monitored  in  rivers  in  two  RBDs 
(Swieza  and  Jarft);  hydromorphological  quality  elements  are  not  monitored  in  any  water 
category.  There  was  no  detail  on  what  specific  quality  elements  were  monitored  in  the  first 
RBMPs, though an alternative source indicated that some quality elements were monitored in 
rivers  and  coastal  waters.  Comparison  with  this  alternative  source  shows  that  there  has  been 
some progress in that phytobenthos and benthic invertebrates are now monitored in lakes, but 
most of the  shortcomings  in  the first RBMPs were still present  in  the second. In  coastal  and 
transitional  waters 
than 
phytoplankton  chlorophyll.  The  emphasis  in  Polish  monitoring  therefore  remained  on  the 
general physicochemical quality elements.35  

there  was  no  biological  quality  elements  monitored  other 

None of the water bodies included in surveillance monitoring in Poland was reported as being 
monitored for all the required biological and hydromorphological quality elements. However, 
Poland subsequently clarified that all the required biological and hydromorphological quality 
elements were monitored in many water bodies. 

Concerning  the  general  physicochemical  quality  elements,  all  the  required  elements  were 
monitored in every water body included in surveillance monitoring.. 

Three of the required biological quality elements were reported to be used in the operational 
monitoring  of  rivers.  The  predominant  element  was  phytobenthos  (25%  of  water  bodies  in 
operational monitoring), followed by benthic invertebrates (18%) and macrophytes (17%). Fish 
were not monitored in rivers, lakes and transitional waters, but were nevertheless reported to be 
classified based on monitoring for a small proportion of river and lake water bodies. 

River Basin Specific Pollutants and matrices monitored 

Poland  reported  that  30  substances  that  are  not  Priority  Substances  were  being  monitored. 
According to the Reporting Guidance for the second RBMPs it was expected that these would 
be River Basin Specific Pollutants.  However, Poland subsequently clarified that the register of 

35  Poland  subsequently  clarified  that  the  data  reported  to  WISE  do  not  reflect  all  the  situation  in  Poland.  Fish 
monitoring  was  undertaken  in  rivers,  lakes  and  transitional  water  bodies  in  the  period  2010-2015.  For 
example, fish were monitored in 763 river water bodies, and only a small fraction of results was excluded from 
ecological  status  assessment.  The  hydrologic  regime  is  monitored  continuously  by  Poland’s  Institute  of 
Meteorology  and  Water  Management.  However,  hydromorphological  elements  of  rivers  were  monitored  in 
Polish State Environmental  Monitoring in 2011 and 2012 as a pilot programme by Institute of Meteorology 
and Water Management, and since 2013 it has been introduced in routine monitoring. 

55 

 
                                                      
River  Basin  Specific  Pollutants  includes  24  synthetic  and  non-synthetic  river  basin  specific 
pollutants.  

Among the substances for which an Environmental Quality Standard was reported (which are 
assumed to be the substances identified as the 24 River Basin Specific Pollutants), copper was 
monitored at the largest number of sites (1 688 within seven RBDs). Phenol was reported to be 
monitored in nine of the 10 RBDs at 1 031 sites. 

The  WFD  indicates  that,  for  the  surveillance  and  operational  monitoring  of  River  Basin 
Specific Pollutants, the frequency of monitoring should be at least once every three months for 
one year during the RBMP cycle and at least once every three months every year, respectively 
(this frequency is to be understood for monitoring in water). Greater intervals can be applied 
provided they are justified on the basis of expert judgment or technical knowledge. Overall in 
Poland, River Basin Specific Pollutants were monitored at a frequency equal to or above the 
intra-annual minimum frequency (4 times per year) at most of sites. No explanation could be 
found for the reduced frequencies implemented at some of the sites. 

It was reported that River Basin Specific Pollutants were only monitored in water.  

Table  3.4  indicates  that  the  30  substances  reported  in  WISE  as  being  monitored  were 
monitored  at  391  lake  sites  and  1  348  river  sites.  Despite  some  minor  inconsistencies  in  the 
number  of  monitoring  sites  between  different  sources  of  information,  and  despite  the 
inconsistencies  between  the  number  of  substances  reported  to  be  monitored  as  River  Basin 
Specific  Pollutants  in  WISE  and  the  River  Basin  Specific  Pollutants  actually  identified  by 
Poland,  it  is  clear  that  the  monitoring  of  River  Basin  Specific  Pollutants  was  a  major 
improvement  compared  to  the  first  RBMPs,  where  these  pollutants  were  not  reported  to  be 
monitored.  

Table 3.4 

Number  of  sites  used  to  monitor  River  Basin  Specific  Pollutants  for  the 
second  RBMPs  and  non-priority  Specific  Pollutants  and/or  other  national 
pollutants  in  the  first  RBMPs  in  Poland.  Note  the  data  from  the  first  and 
second RBMPs may not be fully comparable as different definitions were used 
and also not all Member States reported information at the site level meaning 
that there were no equivalent data for the first RBMPs. 

RBMP 

Second 

Sites used to monitor River Basin Specific 
Pollutants  

First  

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

Lakes 

Rivers 

Transitional 

Coastal 

391 

1348 

0 

0 

9 

0 

3 

0 

Sources: WISE electronic reports 

56 

 
 
Use of monitoring results for classification 

There were a number of mismatches between the water bodies classified based on monitoring 
and  those  directly  monitored  for  most  biological  quality  elements  and  supporting  physico-
chemical  quality  elements.  Fish  were  not  reported  to  be  monitored  in  any  water  category. 
However, fish were also reported to be used to classify some lake and river water bodies using 
monitoring  results:  this  is  again  not  consistent  with  the  reported  monitoring  data.  The 
hydromorphological quality elements were not directly monitored, but were still claimed to be 
classified partly based on monitoring in coastal, rivers and transitional waters. In lakes, expert 
judgement was solely used to classify the hydromorphological quality elements.  

Expert judgment was used to classify proportionally more lake water bodies in terms of each 
quality  element  than  by  using  monitoring  results:  grouping  was  not  used  at  all.  The 
classification of all quality elements in transitional waters was solely based on monitoring data. 
In  rivers  grouping  was  used  to  classify  proportionally  more  water  bodies  than  monitoring 
results for all classified quality elements: expert judgement was not used at all. There were also 
inconsistencies  between  classified  and  monitored  biological  quality  elements  in  coastal  and 
transitional  waters.  The  only  reported  monitored  biological  quality  element  in  both  was 
phytoplankton, but benthic invertebrates were used in the classification of transitional waters 
and  macroalgae  and  benthic  invertebrates  in  coastal  waters.  For  benthic  invertebrates  in  the 
two saline water categories, the classification was reported to be based on monitoring results, 
although no monitoring was reported for this biological quality element.  

For  the  River  Basin  Specific  Pollutants,  the  proportion  of  classified  water  bodies  based  on 
monitoring varied considerably between RBDs and water categories, with a large majority of 
water bodies classified based on grouping for rivers and on expert judgement for lakes.  

3.1.2  Ecological Status/potential of surface water  

The  ecological  status/potential  of  surface  water  bodies  in  Poland  for  the  second  RBMPs  is 
illustrated in Map 3.1. This is based on the most recent assessment of status. 

57 

 
Map 3.1 

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

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

Source: WISE, Eurostat (country borders) 

High 

Good 

Moderate 

Poor  

Bad 

Unknown 

RBDs 

Countries outside the European Union 

All but two water bodies were classified. The proportion of unknowns decreased from 80% in 
the first RBMPs to less than 1% in the second, which is a major improvement. However, the 
proportion of water bodies in less than good ecological status was 70%. Most of these were at 
moderate status. 

Figure  3.3  shows  the  confidence  in  the  classification  of  ecological  status/potential.  The 
majority (60%) of river and lake water bodies were classified with low confidence, while all 
the  coastal  and  transitional  water  bodies  were  classified  with  high  confidence  (which  is 

58 

 
 
  
  
  
  
  
  
  
  
 
difficult  to  reconcile,  given  the  fact  that  very  few  biological  quality  elements  were  used  for 
classifying  the  two  saline  water  categories).  The  remaining  river  and  lake  water  bodies  were 
classified with high confidence.  

Poland subsequently explained that all transitional and coastal waters were assessed based on 
data  of  all  biological  quality  elements  required  for  these  water  body  categories  under  WFD. 
This  information  was  not  in  the  electronic  report  to  WISE  because  of  reporting  errors. 
Phytoplankton  (chlorophyll-a),  macroalgae,  angiosperms  and  benthic  invertebrates  were 
assessed in coastal water bodies, and also fish in transitional waters; hence the confidence level 
of  the  assessment  is  high  for  these  water  body  categories.  Furthermore,  river  and  lake  water 
bodies that were assessed based on ‘expert judgement’ with low confidence due to the fact that 
were not assessed based on the monitoring data. 

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

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

Source: WISE electronic reporting 

Figure  3.4  compares  the  ecological  status  of  surface  water  bodies  in  Poland  for  the  first 
RBMPs with that for the second (based on the most recent assessment of status/potential) and 
that  expected  by  2015).  The  results  mainly  show  the  huge  reduction  in  the  proportion  of 
unknowns since the first RBMPs, but that the proportion at good status/potential was less than 
good  for  70%  of  all  the  water  bodies.  The  expectation  for  2015  was  that  64%  of  all  water 
bodies would be in less than good ecological status.  

59 

 
 
Figure 3.4   Ecological status or potential of surface water bodies in Poland for the second 
RBMPs,  for  the  first  RBMPs  and  expected  in  2015.  The  number  in  the 
parenthesis  is  the  number  of  surface  water  bodies  for  each  cycle.  Note  the 
period  of  the  assessment  of  status  for  the  second  RBMPs  was  2007  to  2012. 
The year of the assessment of status for first RBMPs is not known 

Source: WISE electronic reporting 

Member States were asked to report the expected date for the achievement of good ecological 
status/potential. The information for Poland is shown in Figure 3.5. 37% of river water bodies 
are  expected  to  achieve  their  objectives  by  2015,  which  is  consistent  with  the  information 
given  in  Figure  3.4,  in  which  36%  of  all  surface  water  bodies  are  expected  to  be  in  good 
ecological status by 2015 (and rivers are the water category with most of the total number of 
water bodies in Poland).  

For lakes, 1/3 was expected to achieve the objectives by 2015, approximately another 50% by 
2016-2021,  and  the  rest  by  2022-2027.  For  coastal  waters,  the  majority  was  expected  to 
achieve  the  objectives  in  the  second  RBMPs  (2016-2021),  while  the  more  than  80%  of  the 
transitional waters were only expected to achieve their objectives during the period 2022-2027. 
No water bodies were reported to have already achieved less stringent objectives.  

60 

 
  
Figure 3.5  Expected  date  of  achievement  of  good  ecological  status/potential  of  surface 
water bodies in Poland. The number in the parenthesis is the number of water 
bodies in each category  

Classification of ecological status in terms of each classified quality element 

Source: WISE electronic reporting 

Figure  3.6  shows  that  the  proportion  of  water  bodies  in  good  or  high  ecological  status  was 
much higher for the single biological quality elements than for total ecological status for rivers 
(compare Figure 3.6 with Map 3.1, which is dominated by river water bodies). For rivers, most 
of  the  biological  quality  elements  were  classified  in  almost  80%  of  water  bodies,  and  the 
proportion at good or better status was 40-50%, while for lakes, the proportion of water bodies 
classified  was  almost  90%  for  phytoplankton,  phytobenthos  and  macrophytes,  while  benthic 
invertebrates and fish were classified for 60-70%.  

The proportion of classified water lakes at good or better status was 20-40%, which was less 
than for rivers. Transitional and coastal water bodies were classified with only phytoplankton 
and  benthic  invertebrates,  except  for  a  few  coastal  water  bodies  where  macroalgae  was 
classified (10% of all water bodies, which means one water body only). The ecological status 
was less than good in 80% or more of the total coastal or transitional water bodies. 

61 

 
 
A large proportion of the water bodies were classified based on expert judgement or grouping. 
For fish, no direct monitoring was reported, but a small proportion was reported to be based on 
monitoring36.  

Figure 3.6  Ecological  status/potential  of  the  biological  quality  elements  used  in  the 
classification  of  surface  waters  in  Poland.  Note  that  water  bodies  with 
unknown  status/potential  at  the  quality  element  level  and  those  that  are 
monitored but not classified or not applicable, are not presented.  

 Source: WISE electronic reporting 

Figure  3.7  compares  the  classification  of  biological  quality  elements  in  terms  of  ecological 
status/potential for the first and second RBMPs. It should be noted that this comparison should 

36 Poland subsequently stated that fish were monitored during the whole cycle. This had not been reported because 

of unintended reporting errors. 

62 

 
 
                                                      
be  treated  with  some  caution  as  there  are  differences  between  the  numbers  of  surface  water 
bodies classified for individual elements from the first to the second RBMPs. Changes in the 
ecological status of the biological quality elements cannot be assessed due to the very different 
proportion  of  unknowns  in  the  first and  second  RBMPs  (80%  unknowns  in  the  first  RBMPs 
and no unknowns in the second).  

Figure 3.7  Comparison  of  ecological  status/potential  in  Poland  according  to  classified 
biological  quality  elements  in  surface  water  bodies  between  the  first  and 
second RBMPs. The numbers in parenthesis show the number of water bodies 
with a classification for that element 

Source: WISE electronic reporting 

Figure 3.8 and Figure 3.9 illustrate the basis of the classification of ecological status/potential 
of rivers and lakes in Poland for the second RBMPs. The figures show that all the four groups 
(types)  of  quality  elements  were  used  to  classify  the  large  majority  (80%)  of  the  river  water 
bodies,  while  20%  were  classified  using  three  groups  of  quality  elements.  For  lakes,  the 
proportion  of  water  bodies  classified  with  all  the  four  groups  of  quality  elements  was  only 
61%, while 24% were classified with three types of quality elements and 14% using only two 
types. For coastal and transitional waters, 90% and 100% respectively were classified using all 
the  four  groups  of  quality  elements.  However,  the  majority  of  water  bodies  were  classified 
using  grouping  or  expert  judgement,  especially  for  hydromorphological  quality  elements, 
which have not been directly monitored in the second RBMPs. 

63 

 
Figure 3.8 

The  classification  of  the  ecological  status  or  potential  of  rivers  and  lakes  in 
Poland using 1, 2, 3 or 4 types of quality element 
Note:  The  four  types  are:  biological;  hydromorphological,  general  physicochemical  and  River 
Basin Specific Pollutants 

Source: Member State reports to WISE 

Figure 3.9 

The  percentage  of  river  and  lake  water  bodies  in  Poland  where  no 
biological  quality  element  or  no  hydromorphological  (HYMO)  or  no 
general physicochemical (PHYSCHEM) or no river basin specific pollutant 
(RBSP) has been used in the classification of ecological status or potential 

Source: Member State reports to WISE 

The  hydromorphological  quality  elements  were  not  classified  in  39%  of  lake  water  bodies 
(Figure 3.9). River Basin Specific Pollutants were not used in the classification of 15, 21, 10 
and  33%  of  lakes,  rivers,  coastal  and  transitional  waters respectively.  At  least  one  biological 

64 

1%1%0%33%39%0%0%33%0%1%0%33%15%21%10%33%0%5%10%15%20%25%30%35%40%45%LakesRiversCoastalTransitionalPercentage of WBsNo BQENo HYMONo PHYSCHEMNo RBSP 
 
 
quality element and also physicochemical quality elements were monitored in almost all water 
bodies in all water categories. 

The classification of the individual quality elements is illustrated in Figure 3.10. In transitional 
waters, the classification of all quality elements was based on monitoring, while for rivers and 
lakes 60% were classified based on grouping (rivers) or expert judgement (lakes). Monitoring 
results were primarily used in coastal waters with grouping also being used for some quality 
elements. 

65 

 
Figure 3.10 

Basis of the classification of ecological status/potential in Poland. The 
percentages are in terms of all waterbodies in each category 

Source: WISE electronic reporting 

66 

 
 
Assessment methods and classification of biological quality elements 

Assessment methods were complete for all biological quality elements in all water categories 
and  RBDs  (Legal  Ordinance  from  the  Ministry  of  Environment  in  2011,  included  in  the 
classification  guidance  of  the  Chief  Inspectorate  for  Environmental  Protection,  and 
intercalibrated in 2013). All the biological quality elements with methods developed were used 
for classification in all water categories and RBDs (however, a large proportion of rivers and 
lakes were assessed based on grouping or expert judgement, see above). The fish methods for 
rivers and lakes were not intercalibrated in 2013 (ex-ante information). Further information on 
the single indices used to classify the different biological quality elements in rivers are given in 
section five of the RBMP. Section five explains how the objectives have been set for different 
types of water body. 

A check of the Intercalibration Official Decision from 201337 revealed further gaps for coastal 
waters,  as  only  the  phytoplankton  method  was  intercalibrated,  while  for  transitional  waters 
none of the biological quality elements were intercalibrated.  

In the 2018 Intercalibration Decision38, most of the gaps were closed, but there were still some 
biological  methods  that  had  not  been  intercalibrated:  macroalgae  and  angiosperms  in  coastal 
waters, benthic invertebrates in lakes and fish and benthic invertebrates in transitional waters39.  

These gaps mainly correspond to the gaps in the reported quality element classification, where 
coastal water macroalgae were unknown in most water bodies, angiosperms were listed as not 
applicable,  transitional  waters  aquatic  flora  were  missing  or  not  applicable  (in  spite  of  a 
recently  intercalibrated  method  for  macrophytes)  and  transitional  waters,  where  fish  was 
unknown in all water bodies.  

Poland subsequently stated that macrophytes and angiosperms are assessed in the water bodies 
where they exist in natural conditions, i.e. in two transitional and one coastal water body. The 
Review Panel of the Common Implementation Strategy Working Group on Ecological Status 
accepted  in  2014  the  Polish  justification  not  to  perform  intercalibration  for  macrophytes  and 
angiosperms for type BC7.  

37   2013/480/EU: 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  
38 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32018D0229&rid=2 
39  Poland  subsequently  stated  that the  method  for benthic  invertebrates  in  lakes  would  be  autointercalibrated  in 

2018. 

67 

 
                                                      
The  recently  intercalibrated  class  boundaries  for  phytoplankton  chlorophyll  in  the  Vistula 
lagoon are in the hypereutrophic range with a High-Good boundary of 33 micrograms per litre 
and  a  Good-Moderate  boundary  of  42  micrograms  per  liter.  The  scientific  basis  for  those 
boundaries should be explained. 

Poland  subsequently  stated  that  though  the  intercalibrated  values  of  chlorophyll-a  are  high, 
they are the same as used in Lithuania and have been incorporated in the Commission Decision 
on intercalibration.  

Intercalibration of biological assessment methods and national classification systems 

A  large  proportion  of  national  river  types  were  not  linked  to  any  intercalibration  type,  and 
many lake types were linked to two different intercalibration types (shallow and very shallow 
lakes), which have very different class boundaries for several biological quality elements (e.g. 
phytoplankton). Thus, it is unclear which class boundaries were used for these national types. 
From the ex-ante documents, fish methods for rivers and lakes were not intercalibrated in time 
for the second RBMPs, but have since been successfully intercalibrated (2018 intercalibration 
Official Decision40). For other non-intercalibrated biological assessment methods, see above.  

Poland subsequently stated that the methodologies were intercalibrated as a whole, not just in a 
section  corresponding  to  the  intercalibration  types:  so  if  a  given  national  type  does  not 
correspond  to  any  of  the  intercalibration  types,  the  methodology  of  its  classification  using  a 
given  biological  element  is  developed  in  the  same  way  as  for  types  corresponding  to 
intercalibration types. 

Assessment methods for hydromorphological quality elements 

Hydromorphological methods were developed for all quality elements in all water categories. 
There was no information on the water bodies directly monitored for these quality elements41, 
although approximately 40% of the rivers were reported to be classified based on monitoring 
and the rest based on grouping. Thus, it is not clear how the hydromorphological assessment in 
rivers was done. For lakes, all the hydromorphological quality element assessments were based 
on  expert  judgement  and  none  on  monitoring.  For  the  two  saline  water  categories,  the 

40   Commission Decision (EU) 2018/229 of 12 February 2018 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  Commission  Decision  2013/480/EU (notified under 
document C(2018) 696)Text with EEA relevance.  
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32018D0229  

41 Poland subsequently stated that hydromorphological quality elements are monitored and the fact they were not 

reported in the electronic reports to WISE as being monitored was a probable error. 

68 

 
                                                      
 
hydromorphological  quality  elements  were  not  directly  monitored,  but  were  nevertheless 
reported to be classified mainly based on monitoring. 

The  weaknesses  in  assessing  hydromorphological  quality  elements  and  fish  in  rivers  are  a 
cause  for  concern  given  the  existing  plans  for  changes  to  river  morphology  to  improve 
navigation conditions. 

Assessment methods for general physicochemical quality elements 

Physicochemical  standards  were  set  for  all  general  physicochemical  quality  elements  for  all 
water categories required by the WFD. These were, however, reported as quite wide ranges of 
values for each parameter, which may reflect the need to apply different boundary values for 
different  types  of  water  bodies.  The  RBMP  states  that  threshold  values  for  the  general 
physicochemical  parameters  were  changed  by  the  Ordinance  of  the  Minister  of  the 
Environment of 22 October 2014 on the method of classification of the surface water bodies. 
The general physicochemical standards for nutrients were reported to be related to the sensitive 
biological quality elements, but the upper part of the ranges for both phosphorus and nitrogen 
are too high to support the nutrient sensitive biological quality elements (up to 0.5 milligrams 
per litre for Total-phosphorus and up to 5 milligrams per litre for nitrate). The use of the same 
ranges of nutrient standards for all water categories (total nitrogen range 0.27-8.2 milligrams 
per litre and total phosphorus range 0.03-0.51 milligrams per litre) raises concerns that these 
may still represent the old classification system before the WFD. 

Poland  subsequently  stated  that  the  classification  system  for  the  general  physicochemical 
quality elements changed in 2016. Since then physicochemical quality elements are related to 
biological  elements  classification  (macrophytes  and  phytobenthos).  The  new  standards  were 
adopted in the RMBP for 2016-2021 as environmental objectives. The new standards are being 
developed  according  to  the  new  CIS  guidance  document  and  with  the  use  of  the  toolkit 
prepared in 2017. 

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

River  Basin  Specific  Pollutants  were  selected  based  on  occurrence  in water  bodies  at  risk  of 
failing  their  objectives  due  to  emissions  from  wastewater,  industry  and  agriculture  (Nitrate 

69 

 
Vulnerable  Zones  under  the  Nitrates  Directive42  and  sensitive  areas  under  the  Urban  Waste 
Water Treatment Directive43). 

Environmental Quality Standards were reported in WISE for 25 substances (mostly metals and 
a few organic pollutants), all only for water.  Poland mentioned however that 24 River Basin 
Specific Pollutants have been identified. The difference may result from a reporting mistake: 
phenols have been reported with two different CAS numbers, but with the same Environmental 
Quality Standards. None of the Environmental Quality Standards were derived in accordance 
with the 2011 Technical Guidance Document No 2744.  

River Basin Specific Pollutants were classified in approximately 80% of all water bodies in all 
the  relevant  water  categories  in  all  the  RBDs.  Some  20-30%  were  based  on  monitoring  in 
rivers  and  lakes  and  70-100%  based  on  monitoring  in  transitional  or  coastal  waters. 
Exceedances  were  given  for  some  substances  (5  metals,  fluorine  and  two  organic  pollutants, 
phenols  and  oil  fractions)  in  the  Vistula  and  Oder  RBDs,  but  not  in  the  other  RBDs.  It  is 
unclear why so few organic pollutants were identified, and also why there was no information 
about exceedances in the other RBDs.  

The  analytical  methods  used  for  all  of  the  25  substances  for  which  standards  have  been  set 
meet  the  minimum  performance  criteria  laid  down  in  Article  4.1  of  the  Quality  Assurance  / 
Quality Control Directive (2009/90/EC) for the strictest standards applied45.  

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

Poland  reported  that  the  one-out,  all-out  principle  was  used.  However,  the  details  of  the 
combination rules for the different groups of quality elements were not reported. 

42   Council  Directive  91/676/EEC  of  12  December  1991  concerning  the  protection  of  waters  against  pollution 
http://eur-lex.europa.eu/legal-
agricultural 

sources 

by 

caused 
from 
content/EN/TXT/?uri=celex:31991L0676  

nitrates 

43  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 

44https://circabc.europa.eu/sd/a/0cc3581b-5f65-4b6f-91c6-433a1e947838/TGD-EQS%20CIS-

WFD%2027%20EC%202011.pdf 

45   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 

70 

 
                                                      
3.2  Main  changes  in  implementation  and  compliance  since  the 

first RBMPs 

There  was  a  significant  reduction  in  the  number  of  operational  monitoring  sites  between  the 
first and second RBMPs in all four water categories. Proportionally the largest decrease was in 
transitional waters (71%), followed by lakes (46%), coastal waters (33%) and rivers (14%).  

There were also significant reductions in the number of surveillance monitoring sites from the 
first  to  the  second  RBMPs,  with  no  sites  in  transitional  and  coastal  waters  in  the  second 
RBMPs, in contrast to the first RBMPs when 16 sites and 14 sites were monitored respectively. 
There were major reductions in the number of lake and river surveillance monitoring sites from 
the  first  to  the  second  RBMPs,  corresponding  to  45%  (from  581  to  322  sites)  for  lakes  and 
35% (from 523 to 338 sites) for rivers. 

The decrease in the number of monitoring sites in all the water categories should be explained 
by  the  Polish  WFD  authorities,  also  taking  into  consideration  that  the  mean  size  of  Polish 
rivers (16-43 km in the different RBDs) and especially transitional waters (115-295 km2) (table 
two in chapter two above) are much higher than the European Union average being 13 km for 
rivers and 19 km2 for transitional waters (European Environment Agency State of Environment 
report,  table  1.1).  For  transitional  waters,  the  number  of  operational  monitoring  sites  is  the 
same as the number of water bodies, indicating that the very large water bodies may only have 
one  monitoring  site  in  each  water  body.  Also  for  rivers,  the  representativeness  of  the 
monitoring sites relative to the large mean size of the river water bodies should be clarified.  

There  has  been  some  progress  since  the  first  RBMPs  concerning  the  biological  quality 
elements  that  have  been  included  in  the  monitoring  programmes:  phytobenthos  and  benthic 
invertebrates  are  now  monitored  in  lakes.  Otherwise,  most  of  the  shortcomings  in  the  first 
RBMPs are still present in the second RBMPs: no monitoring of fish was reported in any water 
category46 and no monitoring of macroalgae, angiosperms and benthic fauna in transitional and 
coastal  waters.  There  was  also  no  monitoring  of  the  hydromorphological  quality  elements  in 
any water category.  

The monitoring of River Basin Specific Pollutants was a major improvement compared to the 
first RBMPs, where these pollutants were not reported to be monitored. 

There was a considerable improvement in the number and proportion of water bodies classified 
for ecological status, decreasing the proportion of unknowns from 80% to almost 0% from the 

46  Poland  subsequently  clarified  that  fish  are  monitored  in  transitional  and  coastal  waters,  although  this  is  not 

required for the latter 

71 

 
                                                      
first to the second RBMPs. At least one biological quality element and also physicochemical 
quality elements were monitored in almost all water bodies in all water categories. However, 
the confidence in classification was low for the large majority of water bodies, because it was 
based on grouping or expert judgment and only to a small extent on monitoring for most of the 
biological  quality  elements  and  all  the  hydromorphological  quality  elements  in  most  of  the 
water bodies (60%) in rivers and lakes.  

It  is  not  meaningful  to  assess  the  change  in  ecological  status  from  the  first  to  the  second 
RBMPs,  as  80%  of  the  water  bodies  have  been  classified  for  the  first  time  in  the  second 
RBMPs.  

The  RBMPs  explain  that  classification  methods  have  been  developed  for  all  the  biological 
quality  elements  in  all  types  and  all  the  water  categories.  Most  of  the  biological  assessment 
methods  have  been  successfully  intercalibrated  since  the  first  RBMPs.  The  sensitivity  to 
different  impacts  was  reported  with  logical  combinations  of  different  biological  indices  and 
impacts.  A  large  proportion  of  water  bodies  were  classified  with  more  biological  quality 
elements  than  in  the  first  RBMPs,  and  at  least  some  River  Basin  Specific  Pollutants  were 
included in the classification. These are major improvements since the first RBMPs. 

Hydromorphological  and  general  physicochemical  assessment  methods  have  been  developed 
for all the quality elements in all water categories, but it is unclear if they are in line with the 
WFD  requirements.  For  the  River  Basin  Specific  Pollutants,  environmental  quality  standard 
values were set for 25 substances, but the methodology is unclear, see below. 

3.3 

Progress with Commission recommendations 

The Commission recommendations based on the first RBMPs and first PoM requested action 
on the following: 

 

Recommendation 2: 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 RBMPs, to ensure that adequate measures can be put in place 
before the next RBMPs.  

Assessment:  Initial  assessment of the  RBMPs showed that  there are still major  gaps  in 
Poland’s  monitoring  programmes  with  fish  not  being  monitored  in  the  expected  water 
categories;  phytoplankton  was  the  only  biological  quality  element  monitored  in 
transitional and coastal waters; hydromorphological quality elements were not monitored 

72 

 
in any water category. However, there has been some progress in that phytobenthos and 
benthic invertebrates were monitored in lakes.  

The quality elements monitored at each site were reported, but there are some apparent 
inconsistencies in the reported electronic data, especially concerning the monitoring sites 
in lakes, transitional and coastal waters in the first RBMPs. 

Monitoring is not carried out in the Ucker RBD for surface waters as no surface water 
body has been delineated in this RBD. 

However,  after  clarifications  by  Poland,  many  of  these  gaps  were  closed.  The 
recommendation is partially fulfilled.  

 

Recommendation  3:  River  Basin  Specific  Pollutants  need  to  be  identified,  with  clear 
information on how they have been selected, how and where they are being monitored, 
where there are exceedances and how such exceedances will be 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. Apparently, 
there has been no monitoring of River Basin Specific Pollutants, at least none taken into 
account in the ecological status assessment. 

Assessment:  River  Basin  Specific  Pollutants  (mainly  metals)  have  now  been  identified 
which  represents  a  major  improvement  compared  with  the  first  RBMP.  There  is  also 
information explaining how the River Basin Specific Pollutants have been selected, using 
emissions  and  risk  assessment  (it  should  be  noted  however  that  Environmental  Quality 
Standard  values  have  not  been  set  according  to  the  Technical  Guidance  no.  27). 
Information  on  monitoring  and  exceedances  have  been  reported.  However  the 
information  in  WISE  on  the  River  Basin  Specific  Pollutants  monitored  don’t  seem 
entirely consistent with the information reported on the Environmental Quality Standards 
set for River Basin Specific Pollutants. Information on exceedances seems to be missing 
in  WISE  for  certain  RBDs.  The  one-out-all-out  principle  has  been  applied  to  assess 
ecological status. 

Significant progress has been made, the recommendation has partly been fulfilled. 

 

Recommendation:  Ensure  that  monitoring  and  subsequent  assessments  of  the  status  of 
water  bodies  are  carried  out  in  compliance  with  the  requirements  prescribed  by  the 
WFD.  In  particular  Poland  should  develop  a  coherent  and  comprehensive  monitoring 
network  under  Article  8  WFD  which  enables  the  correct  classification  of  all  water 

73 

 
bodies, monitor water bodies in line with the requirements of Annex V to the WFD and 
with  adequate  frequencies,  and  set  reference  conditions  for  all  quality  elements  for  all 
water bodies. 

 

Recommendation:  Further  work  is  required  to  make  the  monitoring,  assessment  and 

classification  of  surface  water  and  groundwater  status  fully  compliant  with  the 
requirements  of  the  WFD,  Environmental  Quality  Standards  and  Groundwater 
Directives. 

Assessment:  Almost  all  water  bodies  in  Poland  were  classified  in  the  second  RBMPs, 
which  is  a  major  improvement  compared  to  the  first  RBMPs,  when  only  20%  were 
classified. A large proportion of water bodies were classified for more biological quality 
elements than in the first RBMPs.  The classification was reported with low confidence 
for most water bodies, probably due to the extensive use of expert judgement or grouping 
for classifying these quality elements in most lakes and river water bodies.  

Assessment  methods  are  complete  for  all  biological  quality  elements  in  all  water 
categories  and  RBDs  (Legal  Ordinance  from  the  Ministry  of  Environment  in  2011, 
included  in  the  classification  guidance  of  the  Chief  Inspectorate  for  Environmental 
Protection,  and  intercalibrated  in  2013).  The  sensitivity  of  several  of  the  biological 
quality element methods to different impacts were reported with logical combinations of 
biological  quality  elements  and  impacts.  All  the  biological  quality  elements  with 
methods  developed  were  used  for  classification  in  all  water  categories  and  RBDs 
(however,  a  large  proportion  of  rivers  and  lakes  were  assessed  based  on  grouping  or 
expert judgement, see above).  

Further information on the single indices used to classify the different biological quality 
elements in rivers is given in section 5 of the RBMP. Section 5 explains how objectives 
were set for different types of water body. 

A  check  of  the  Intercalibration  Official  Decision  from  2013  revealed  further  gaps  for 
coastal waters, as only the phytoplankton method was intercalibrated, and for transitional 
waters, none of the biological quality elements were intercalibrated.  

From the ex-ante documents, fish methods for rivers and lakes were not intercalibrated in 
time  for  the  second  RBMPs,  but  have  since  been  successfully  intercalibrated  (2018 

74 

 
intercalibration Decision47). In the 2018 Decision, most of the other gaps have also been 
closed, but there are still some biological methods that have not been intercalibrated.  

Hydromorphological  methods  were  developed  for  all  quality  elements  in  all  water 
categories  but  not  in  all  cases  consistent  with  WFD  and  with  shortcoming  in  their 
application.  

Physicochemical standards were set for all the physicochemical quality elements for all 
water  category  required  by  the  WFD.  These  were,  however,  reported  as  quite  wide 
ranges  of  values  for  each  parameter  which  may  reflect  the  need  to  apply  different 
boundary values for different types of water bodies.  

In conclusion, the recommendations have been partly fulfilled. 

47   Commission Decision (EU) 2018/229 of 12 February 2018 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  Commission  Decision  2013/480/EU (notified under 
document C(2018) 696)Text with EEA relevance.  
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32018D0229  

75 

 
 
 
                                                      
 
Topic 4

  Topic  Monitoring,  assessment  and  classification  of 

chemical status in surface water bodies 

4.1 

Assessment  of  implementation  and  compliance  with  WFD 
requirements in the second RBMPs  

4.1.1  Monitoring of chemical status in surface waters 

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

Member States 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 PoM. 

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

Figure  4.1  summarises  the  proportion  of  sites  used  for  the  monitoring  of  chemical  status  in 
lakes  and  rivers  for  the  second  RBMPs.  In  this  figure,  no  distinction  is  made  between  sites 
used for surveillance and/or operational purposes.  

76 

 
 
Figure 4.1 

Proportion  of  sites  used  for  monitoring  of  chemical  status  and,  for 
comparison, ecological status, in Poland. The number in parenthesis next to 
the  category  is  the  total  number  of  monitoring  sites  irrespective  of  their 
purpose 

Source: WISE electronic reporting 

Figure 4.1 shows that a high proportion of the lake monitoring sites (85%) and two-thirds of 
the  river  and  transitional  water  monitoring  sites  were  used  for  monitoring  chemical  status. 
Only 30%  of coastal water  monitoring sites (three  sites) were monitored for chemical status. 
Territorial  waters  were  neither  monitored  nor  classified  for  chemical  status.  More  detailed 
information can be found on the website of the European Environment Agency48. 

Figure  4.2  summarises  the  proportion  of  water  bodies  monitored  for  chemical  status  for  the 
second RBMPs. In this figure, no distinction is made between sites used for surveillance and/or 
operational purposes. Also given is the proportion of water bodies monitored for any purpose 
and,  for  comparison,  those  for  ecological  status.  Figure  4.2  shows  that  according  to  the 
information  reported  to  WISE,  30%  of  coastal  water  bodies  were  monitored  for  chemical 
status.  However,  Poland  subsequently  clarified  that  50%  of  coastal  water  bodies  were 
monitored for chemical status (the lower proportion identified here is likely to be the result of a 
reporting mistake).  

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

77 

 
 
 
 
                                                      
Figure 4.2 

Proportion  of  total  water  bodies  in  each  category  which  are  monitored, 
monitored for chemical status and monitored for ecological status, in Poland. 
The number in parenthesis next to the category is the total number of water 
bodies in that category 

Source: WISE electronic reporting 

Almost all lake, transitional and coastal water bodies failing to achieve good chemical status 
were  reported  to  be  monitored  across  Poland.  Rivers  failing  to  achieve  good  chemical  status 
were  less  well  monitored,  ranging  from  14%  to  40%  across  RBDs  with  the  exception  of  the 
Elbe  RBD,  where  the  only  river  water  body  failing  to  achieve  good  chemical  status  was 
monitored.  

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

Monitoring for status assessment 

Requirements 

Article 8.1 of the WFD requires Member States to establish monitoring programmes in order to 
provide  inter  alia  a  coherent  and  comprehensive  overview  of  water  status  within  each  RBD. 
The amount of monitoring undertaken in terms of priority substances, frequency and numbers 
of sites should be sufficient to obtain a reliable and robust assessment of status. According to 
the  EQS  Directive  (version 
in  2009),  mercury,  hexachlorobenzene  and 
hexachlorobutadiene  have  to  be  monitored  in  biota  for  status  assessment,  unless  Member 

in  force 

78 

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

Spatial coverage 

The Swieza, Jarft and Ucker RBDs did not report any monitoring of priority substance at site 
level. No surface water body was identified in the Ucker RBD, which explains that no priority 
substances were monitored in this RBD. This RBD will consequently not be referred to in the 
rest of this chapter. In the other two RBDs, it seems that no monitoring of priority substances 
was performed49.  

All  the  other  RBDs  reported  having  monitored  all  41  priority  substances.  However,  coastal 
waters were not monitored at all in the Vistula RBD. 

Poland  have  not  reported  monitoring  of  mercury,  hexachlorobenzene  or  hexachlorobutadiene 
in biota for status assessment.50  

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 were reported for 37 Priority Substances at site level in all the RBDs 
apart from the Swieza and Jarft RBD51. Monitoring frequencies ranged from one to 12 times 
per  year,  and  from  once  per  cycle  to  every  year.  The  sampling  frequencies  meet  the 
recommended minimum frequencies  for operational  and surveillance monitoring in some but 
not all sites52.  

49 Poland subsequently confirmed that priority substances were not monitored in 2010-2013 in the Swieza RBD.  
50 Poland subsequently stated that monitoring in biota is in place from 2016 so there was no data available for the 
second  RBMPs.  This  monitoring  will  be  performed  for  11  substances,  in  accordance  with  Directive 
2013/39/EU. 

51 Poland did not report to WISE the monitoring frequencies for all the priority substances monitored. 
52  Poland  subsequently  clarified  that  this  was  due  to  limitations  of  analytical  research  methodologies,  weather 
conditions that prevented sampling (e.g. floods, droughts, ice cover), and limitations in achieving the correct 
analytical measurement quality. 

79 

 
 
 
                                                      
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  substances53  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  

According  to  the  RBMPs,  monitoring  was  planned  in  sediments  in  lakes  and  rivers,  at 
frequencies  at  or  below  the  recommended  minimum  frequency.  Poland  subsequently 
mentioned  that  some  priority  substances  have  been  monitored  in  sediment  (some,  such  as 
PAH, mercury, lead and cadmium, have been monitored since 1998) but the results were not 
reported. It is not clear whether all relevant priority substances have been monitored, and what 
the spatial coverage and temporal resolution are. 

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 the Swieza and Jarft RBDs, no substance was identified as discharged, and no substance was 
monitored.  In  the  other  seven  RBDs,  all  priority  substances  were  monitored,  including  those 

53  Anthracene,  brominated  diphenylether,  cadmium,  C10-13  chloroalkanes,  DEHP, 

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

80 

 
                                                      
assessed as discharged (the Ucker RBD is not considered in this part of the assessment as no 
surface water body has been designated in this RBD). 

Performance of analytical method used 

Poland  reported  that  for  all  41  Priority  Substances,  the  analytical  methods  used  meet  the 
minimum  performance  criteria  laid  down  in  Article  4(1)  of  Directive  2009/90/EC  for  the 
strictest standard applied.  

The  method  of  dealing  with  measurements  of  Priority  Substances  lower  than  the  limit  of 
quantification is stated to be as specified in Article 5 of Directive 2009/90/EC. 

4.1.2  Chemical Status of surface water bodies 

Member States  are required to  report the year on which the assessment of chemical  status is 
based. This may be the year that the surface water body was monitored. In case of grouping 
this may be the year in which monitoring took place in the surface water bodies within a group 
that  are  used  to  extrapolate  results  to  non-monitored  surface  water  bodies  within  the  same 
group. All assessments across Poland were conducted between 2010 and 2013. 

The chemical status of surface water bodies in Poland for the second RBMPs is illustrated in 
Map  4.1..  This  is  based  on  the  most  recent  assessment  of  status.  In  Poland  overall,  59%  of 
surface water bodies were at Good chemical status, 26% were failing to achieve Good status 
and 15% were classified as Unknown.  

Map 4.1 

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

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

Source: WISE, Eurostat (country borders) 

81 

GoodFailing to achieve to goodUnknownRiver Basin DistrictsCountries outside the EU 
 
 
 
 
 
 
The chemical status of lakes and rivers in Poland for the first and second RBMPs is given in 
Table  4.1.  More  information  on  the  chemical  status  in  each  RBD  and  water  category  can  be 
found on the website of the European Environment Agency54.  

Table 4.1 

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

RBMPs.  Note:  the  number  in  parenthesis  next  to  the  water  category  is  the 
number  of  water  bodies.  Note:  Chemical  status  assessment  is  based  on  the 
standards  laid  down  in  EQS  Directive  2008/105/EC  (version  in  force  on  13 
January  2009).  Some  Member  States  did  not  implement  the  Directive  in  the 
first RBMPs as the transposition deadline was in July 2010, after the adoption 
of the first RBMPs 

Good 

Failing to achieve good 

Unknown 

Number 

% 

Number 

% 

Number 

% 

3134 

192 

2 

3 

3331 

88 

64 

68% 

18% 

22% 

30% 

59% 

2% 

6% 

1447 

35 

4 

3 

1489 

272 

7 

32% 

3% 

44% 

30% 

26% 

6% 

1% 

5 

817 

3 

4 

829 

4226 

967 

9 

10 

152 

3% 

279  

5% 

5212 

0% 

78% 

33% 

40% 

15% 

92% 

93% 

100% 

100% 

92% 

Category 

second RBMP 

Rivers (4586) 

Lakes (1044) 

Transitional (9) 

Coastal (10) 

Total (5649) 

first RBMP 

Rivers (4568) 

Lakes (1038) 

Transitional (9) 

Coastal (10) 

Total (5643) 

Overall, between the two cycles of RBMPs there was an increase in the proportion of surface 

water bodies with good chemical status from 3% to 59%. Similar increases occurred across all 

water body types (artificial, heavily modified and natural). There was also an overall increase 

in the proportion of surface water bodies failing to achieve good chemical status between the 

two  cycles  of  RBMPs,  from  5%  to  26%.  The  increases  in  the  proportions  of  surface  water 

bodies with good or failing to achieve good chemical status can be explained by the significant 

reduction in the proportion of surface water bodies with unknown chemical status, from 92% 

in the first RBMPs down to 15% in the second RBMPs. 

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

82 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
Grouping  was  used  to  classify  a  significant  proportion  of  the  water  bodies,  in  particular  for 

rivers (grouping was used for 67% to 96% of river water bodies depending on the RBD). In the 

Swieza RBD all classifications were based on grouping and expert judgment, as no monitoring 

was performed. Monitoring was used to classify all lakes in the Vistula, Oder, Pregolya, and 

Nemunas RBD, all transitional waters in the Vistula and Oder RBDs and all coastal waters in 

the Vistula RBD. 

The RBMPs provided explanations on the grouping methodology, however it was not entirely 

clear whether these concerned chemical status or ecological status or both. For rivers, the status 

of water bodies classified on the basis of monitoring results was transferred to non-monitored 

water  bodies,  provided  those  waterbodies  presented  similar  characteristics.  For  lakes,  expert 

judgement was used and was based on the analysis of pressures.  

However,  there  seem  to  be  some  limitations  in  the  assessment  of  pressures,  as  “unknown 

pressures”  and  “no  significant  pressure”  are  reported  for  respectively  58%  and  27%  of  the 

water  bodies  failing  to  achieve  good  chemical  status.  Poland  highlighted  that  measures  are 

planned  in  the  Programmes  of  measures  aiming  at  a  more  thorough  identification  of  the 

pressures and their impacts on status. 

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

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

of the water bodies classified were associated with a low level of confidence, and the rest with 

a high level of confidence. All lakes, transitional and coastal waters were classified with high 

confidence but that was the case for only about 30% of rivers. 

83 

 
 
 
Figure 4.3 

Confidence in the classification of chemical status of surface water bodies in 
Poland based on the most recently assessed status/potential  

Source: WISE electronic reporting 

The  Polish  Chief  Inspectorate  for  Environmental  Protection  (CIEP)  adopted  the  following 
guidelines  for  the  determination  of  the  level  of  confidence:  1)  status  based  on  12  or  more 
monitoring results have been assigned a high level of confidence; 2) status based on 11 or 10 
monitoring results were assigned a medium confidence level; 3) status based on less than 10, 
but at least four results were assigned a low confidence level (when less than four monitoring 
results were available for one substance, these results were not considered in the assessment of 
status). 

Figure 4.4 compares the chemical status of surface water bodies in Poland for the first RBMPs 
with  that  for  the  second  RBMPs  (based  on  the  most  recent  assessment  of  status)  and  that 
expected by 2015. There is a substantial difference in the proportion of water bodies in good 
status in the second RBMP, and that expected by 2015. 

The  assessment  of  chemical  status  for  the  second  RBMPs  was  expected  to  be  based  on  the 
standards  laid  down  in  EQS  Directive  2008/105/EC  (version  in  force  on  13  January  2009). 
Some Member States did not implement the Directive in the first RBMPs as the transposition 
deadline was in July 2010, after the adoption of the first RBMPs. 

84 

 
 
 
Figure 4.4 

Chemical status of surface water bodies in Poland for the second RBMPs, for 
the first RBMPs and expected in 2015. The number in the parenthesis is the 
number  of  surface  water  bodies  for  both  RBMPs.  Note  the  period  of  the 
assessment of status for the second RBMPs was 2010 to 2013. The year of the 
assessment of status for first RBMPs is not known 

Source: WISE electronic reporting 

Directive  2013/39/EU  amended  the  EQS  Directive.  In  particular,  it  sets  more  stringent 
environmental  quality  standards  for  seven  substances55.  Poland  reported  that  no  deterioration 
was caused by the new standards. 

Good  chemical  status  should  be  reached  by  2021  in  relation  to  the  revised  environmental 
quality  standards,  unless  Member  States  apply  exemptions  under  WFD  article  4(4)  or  less 
stringent objectives under WFD article 4(5). 

The expected date for the achievement of good chemical status is shown in Figure 4.5. Good 
chemical  status  of  surface  water  bodies  was  expected  to  be  achieved  by  the  end  of  the  third 
cycle in all of the RBDs. No data on the expected achievement of good status was provided in 
the first RBMPs. 

55  Anthracene,  Brominated  diphenylether,  Fluoranthene,  Lead  and  its  compounds,  Naphthalene,  Nickel  and  its 

compounds, Polyaromatic hydrocarbons (PAH) 

85 

 
 
 
                                                      
Figure 4.5 

Expected date of achievement of good chemical status of surface water bodies 
in  Poland.  The  numbers  in  parentheses  are  the  numbers  of  water  bodies  in 
each category. Percentage of water bodies is represented cumulatively 

Priority substances causing the failure of good chemical status 

Source: WISE electronic reporting 

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

The substances causing the greatest number of water bodies to fail good chemical status were 
benzo(g,h,i)-perylene + indeno(1,2,3-cd)-pyrene, mercury, and cadmium. No information was 
provided for the Danube56, Swieza or Jarft RBDs.  

The “top-ten’ substances are shown in Figure 4.6. 

Overall for surface water bodies in Poland, the largest proportion of exceedances were for the 
annual average-Environmental Quality Standard for benzo(g,h,i)-perylene + indeno(1,2,3-cd)-
pyrene. Exceedances of maximum acceptable concentration Environmental  Quality Standards 

56 Poland subsequently clarified that surveillance monitoring was performed in the Danube RBD which included 

Priority Substances and therefore this may be an unitended  reporting error.  

86 

 
 
 
                                                      
were the greatest for mercury and its compounds. In terms of exceedance of both standards, the 
largest proportion was for benzo(g,h,i)-perylene + indeno(1,2,3-cd)-pyrene.  

Figure 4.6 

The  top-10  Priority  Substances  causing  failure  to  achieve  good 
chemical status in surface water bodies in Poland 

Ubiquitous persistent, bioaccumulative and toxic Priority Substances 

Source: WISE electronic reporting 

According  to  article  8(a)  of  the  EQS  Directive57,  eight  priority  substances  and  groups  of 
priority  substances  are  behaving  like  ubiquitous,  persistent,  bioaccumulive  and  toxic 
substances58.  These  substances  are  generally  expected  to  cause  widespread  exceedances,  and 
their emissions can be challenging to tackle (e.g. due to long-range atmospheric transport and 
deposition). In order to show the progress made in tackling other priority substances, Member 
States have the possibility to present the information related to chemical status separately for 
these  substances.  When  all  41  priority  substances  are  taken  into  account,  about  a  quarter  of 
water  bodies  are  failing  to  achieve good  chemical  status,  however  this  falls  to  a  few  percent 
when  the  ubiquitous,  persistent,  bioaccumulative  and  toxic  substances  are  omitted.  This  is 

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

dioxins, hexabromocyclodecane and heptachlor 

87 

 
 
                                                      
illustrated  in  the  2018  State  of  Water  report  of  the  European  Environment  Agency59.  The 
absence of monitoring in biota may underestimate the impact of this substance on the chemical 
status. 

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

For all RBDs except the Swieza and the Jarft RBDs, 41 Priority Substances were reported to be 
monitored and used in the status assessment. For these RBD, all 41 substances were reported to 
be used in the status assessment but not monitored.  

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. 

Poland have applied all of the Environmental Quality Standards laid down in Annex I of the 
EQS  Directive.  No  alternative  and/or  additional  standards  for  particular  Priority  Substances 
have been applied.  

Use of mixing zones  

Article 4 of the EQS Directive provides Member States with the option of designating mixing 
zones adjacent to points of discharge in surface waters. Concentrations of priority substances 
may exceed the relevant environmental quality standard within such mixing zones if they do 
not affect the compliance of the rest of the surface water body with those standards. Member 
States that designate mixing zones are required to include within their RBMPs a description of 
the  approaches  and  methodologies  applied  to  define  such  zones,  and  a  description  of  the 
measures taken to reduce the extent of the mixing zones in the future. Mixing zones have not 
been designated in Poland.  

59https://www.eea.europa.eu/publications/state-of-water  (p40-41  of  the  report).  Also  available  in  a  more 

interactive format at :  

https://tableau.discomap.eea.europa.eu/t/Wateronline/views/WISE_SOW_SWB_Chemical_Status_Maps/SWB_F
ailing_Good_Chemical_Status_RBD?iframeSizedToWindow=true&:embed=y&:showAppBanner=false&:dis
play_count=no&:showVizHome=no 

88 

 
                                                      
Background Concentrations and Bioavailability 

The  EQS  Directive  stipulates  that  Member  States  have  the  possibility,  when  assessing  the 
monitoring results against the environmental quality standard, to take into account: 

(a) natural background concentrations for metals and their compounds, if they prevent 
compliance with the environmental quality standard, and; 

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

Seven of the ten RBDs have taken into account natural background concentrations for metals 
where such concentrations prevented compliance.  

Nine of the ten RBDs took into account bioavailability when assessing compliance for metals. 

4.2  Main  changes  in  implementation  and  compliance  since  the 

first RBMPs 

Between  the  two  RBMPs,  there  has  been  a  net  decrease  in  sites  and  surface  water  bodies 
monitored for operational purposes (a decrease of 592 monitoring sites and 24 water bodies). 
For surveillance monitoring the number of sites has decreased by 447 and the number of water 
bodies has decreased by 179. However, no specific information could be found in the RBMPs 
on the changes in the monitoring programmes since the first RBMP.  

Between the two RBMPs, there was an increase in the proportion of surface water bodies with 
good chemical status from 3% up to 59%, and similar increases occurred across all water body 
types  (artificial,  heavily  modified  and  natural).  There  has  also  been  an  overall  increase  in 
proportion of surface water bodies failing to achieve good chemical status, from 5% to 26%.  

These  changes  result  from  a  significant  reduction  in  the  proportion  of  surface  water  bodies 
with  unknown  chemical  status,  from  92%  in  the  first  RBMPs  down  to  15%  in  the  second 
RBMPs. The RBMP provided no specific information on the reasons for these changes. 

Poland reported no improvement in status for any Priority Substance in any water body since 
the first RBMPs. 

4.3 

Progress with Commission recommendations 

The Commission recommendations based on the first RBMPs and first PoM requested action 
on the following:  

89 

 
  Recommendation:  The  monitoring  of  Priority  Substances  should  be  sufficient  to  allow 
chemical  status  to  be  determined  for  a  much  higher  proportion  of  water  bodies.  The 
correct  statistical  calculations  should  be  done  when  assessing  compliance  with  the 
maximum annual concentrations. The plans should make clear which Priority Substances 
are  being  monitored  where,  and  in  which  matrix.  Mercury,  hexachlorobenzene  and 
hexachlorobutadiene  should  be  monitored  in  biota  unless  an  equally  protective 
Environmental  Quality  Standard  has  been  established  in  water.  The  trend  monitoring 
apparently  being  carried  out  in  sediment  or  biota  should  include  the  substances  in  EQS 
Directive Article 3(3) and will need to be reflected in the next RBMP.  

Assessment:  Between  the  two  RBMPs  there  was  a  very  significant  reduction  in  the 
proportion of surface water bodies with unknown chemical status, from 92% down to 15%. 
A significant proportion of water bodies are however still classified with a low confidence. 
This  results  from  the  reduced  sampling  frequencies  sometimes  implemented  (frequencies 
lower  than  the  recommended  minimum  frequency),  leading  to  more  uncertainty  in  the 
assessment.  This  low  level  of  confidence  may  also  result  from  the  use  of  grouping  and 
expert  judgment,  based  on  the  assessment  of  pressures,  to  classify  non  monitor  water 
bodies (70% of all water  bodies are not monitored).  All  priority substances (so  including 
those discharged) are monitored in seven RBDs. On the contrary two RBDs didn’t monitor 
any priority substance60.  

No  information  could  be  found  on  the  statistical  calculations  performed  when  assessing 
compliance  with  the  maximum  annual  concentrations.  However,  Poland  subsequently 
clarified  that  the  90th  percentile  of  the  measured  concentrations  was  compared  with  the 
environmental quality standard when twelve monitoring results were available. When there 
were  less  than  twelve  monitoring  results,  the  highest  measured  concentration  was 
compared with the standard. Poland clarified that this aimed at avoiding the high statistical 
uncertainty that would occur when calculating a percentile on a small dataset.  

Seven of the ten RBDs provided information on which priority substances were monitored 
where,  and  in  which  matrix,  for  status  assessment.  Three  RBD  did  not  provide  such 
information  –  one  doesn’t  have  any  surface  water  bodies,  and  it  seems  that  no  priority 
substance  was  monitored  in  any  of  the  other  two.  The  information  reported  on  trend 
monitoring was unclear. 

No monitoring in biota was performed for status assessment for the second RBMP. 

60 As mentioned above, the Ucker RBD doesn’t have any surface water body and therefore is not included in the 

analysis. 

90 

 
                                                      
No  trend  monitoring  was  reported  to  WISE,  however  it  seems  that  some  monitoring  in 
sediment took place. It is however unclear whether all relevant substances were monitored, 
and what the spatial coverage and temporal resolution were.  

This recommendation has been partially 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: See assessment for the recommendation above. In addition, there seem to be 
some limitations in the assessment of pressures, as a majority of the water bodies failing to 
achieve  good  status  are  subject  to  unknown  pressures,  and  more  than  a  quarter  are 
identified as subject to no pressure. 

This recommendation has been partially addressed. 

  Ensure  that  monitoring  and  subsequent  assessments  of  the  status  of  water  bodies  are 
carried  out  in  compliance  with  the  requirements  prescribed  by  the  WFD.  In  particular 
Poland should develop a coherent and comprehensive monitoring network under Article 8 
WFD which enables the correct classification of all water bodies, monitor water bodies in 
line with the requirements of Annex V to the WFD and with adequate frequencies, and set 
reference conditions for all quality elements for all water bodies.  

Assessment:  Addressed  in  the  assessment  of  the  two  recommendations  above.  The 
recommendation has therefore been partially fulfilled. 

  Recommendation:  Further  work  is  required  to  make  the  monitoring,  assessment  and 
classification  of  surface  water  and  groundwater  status  fully  compliant  with  the 
requirements of  the WFD, Environmental  Quality Standard and Groundwater  Directives. 
The biological quality elements should be fully intercalibrated at the EU level.  

Assessment: Significant efforts have been made since the first RBMPs to classify a much 
larger proportion of water bodies. However there are still some limitations (low confidence 
in the assessment linked to reduce monitoring frequencies, limitations in the assessment of 
pressures  which  feeds  into  the  expert  judgment,  absence  of  biota  monitoring).  This 
recommendation is partially fulfilled. 

91 

 
  Recommendation:  Put in place in  the second cycle  of  RBMPs  concrete actions to reduce 
the number of unknowns and to increase the percentage of water bodies in good chemical 
status. 

Assessment: As stated above, there was a significant reduction in the proportion of surface 
water bodies with unknown chemical status, from 92% in the first RBMPs down to 15% in 
the second RBMPs. There was also a substantial increase in the proportion of water bodies 
in  good  chemical  status,  resulting  from  the  classification  of  water  bodies  previously  in 
unknown status (no improvement in status has been reported for any priority substance in 
any  water  body).  Progress  has  therefore  been  made  towards  meeting  the  requirements  of 
the recommendation. It is partially fulfilled. 

92 

 
 
 
 
  Monitoring, assessment and classification of 

Topic 5
quantitative status of groundwater bodies 

5.1 

Assessment  of 
requirements in second RBMPs 

implementation  and  compliance  with  WFD 

5.1.1  Monitoring of quantitative status in groundwater 

The total number of groundwater bodies in Poland is 178 (Table 2.2)61. 15 groundwater bodies 
were  not  subject  to  monitoring  for  quantitative  status  (Table  5.1).  This  means  that  8%  of 
groundwater bodies were not monitored. From a review of the Vistula RBMP information on 
whether grouping was applied was not found. 

Table 5.1 

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

RBD 

PL1000 

PL2000 

PL4000  

PL5000  

PL6000 

PL7000 

PL8000 

PL9000 

Total groundwater 
bodies directly 
monitored 

Monitoring Purpose 

CHE - Chemical status 

QUA - Quantitative status 

SUR – Surveillance 
monitoring 

2 

94 

1 

1 

65 

2 

2 

1 

2 

1 

1 

2 

2 

1 

2 

92 

1 

1 

62 

2 

2 

1 

94 

65 

1 

Source: WISE electronic reporting  

The number of groundwater bodies increased by 7% from 161 in the first RBMP to 178 in the 
second  RBMPs  but  the  total  groundwater  body  area  remained  nearly  the  same.  In  fact,  no 
groundwater body remained unchanged and all groundwater bodies had been re-delineated. 

The number of groundwater bodies monitored for quantitative status increased from 145 of 161 
(90%)  in  the  first  RBMPs  to  163  of  178  (97%)  in  the  second  RBMPs62.  The  number  of 
monitoring sites slightly increased from 828 in the first RBMPs to 836 in the second RBMPs 

61 Poland subsequently clarified that the number of groundwater bodies was 172. Poland stated the number 178 
was reported as such due to the fact of counting subunits as groundwater-bodies (groundwater bodies shared 
by more than one River Basin District) 

62 Poland subsequently clarified that only five GWBs in Poland are not monitored – 106, 122, 123, 138, 139. 

93 

 
 
 
 
 
 
 
 
                                                      
 
(Table  5.2,  Table  5.3)  .The  single  groundwater  body  in  the  Jarft  RBD  is  now  covered  by 
quantitative monitoring (by one monitoring site). 

Table 5.2 

Proportion of groundwater bodies in Poland monitored for quantitative status 

RBD 

PL1000 

PL2000 

PL4000 

PL5000 

PL6000 

PL7000 

PL8000 

PL9000 

No of groundwater 
bodies with quantitative 
monitoring 

Total No. groundwater 
bodies 

% of total groundwater 
bodies monitored for 
quantitative status 

2 

92 

1 

1 

62 

2 

2 

1 

3 

94 

1 

7 

66 

2 

2 

1 

66.67% 

97.87% 

100.00% 

14.29% 

93.94% 

100.00% 

100.00% 

100.00% 

Table 5.3 

Number of groundwater monitoring sites in Poland and their purpose  

Source: WISE electronic reporting 

RBD  

PL1000 

PL2000 

PL3000 

PL4000 

PL5000 

PL6000 

PL6700 

PL7000 

PL8000 

PL9000 

Total 
groundwater 
monitoring 
sites 

Monitoring Purpose 

CHE - Chemical status 

QUA - Quantitative 
status 

SUR - Surveillance 
monitoring 

5 

678 

0 

1 

1 

492 

0 

20 

20 

2 

5 

1 

1 

19 

18 

5 

488 

1 

1 

307 

15 

18 

1 

1 
Source: WISE electronic reporting 

679 

492 

1 

174 of 178 groundwater bodies were identified as Drinking Water Protected Areas, allocated in 
all RBDs where groundwater bodies were present63. 

63 Poland subsequently clarified that 168 of 172 groundwater bodies were identified as Drinking Water Protected 

Areas. 

94 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
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 165 of 178 groundwater bodies (93%) are of good quantitative status and 13 (7%) 
are failing good status (Figure 5.1)64. In terms of area this means that about 4% were failing 
good quantitative status. All groundwater bodies had and still have a clear 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) 

64  Poland  subsequently  clarified  that  159  of  172  (92%)  groundwater  bodies  were  of  good  quantitative  status. 

Consequently, 13 (8%) were failing to achieve good status.  

95 

GoodPoorUnknownRiver Basin DistrictsCountries outside the EU 
 
  
 
 
                                                      
Figure 5.1  Quantitative status of groundwater bodies in Poland for the second RBMPs, 
for the first RBMPs and expected in 2015. The number in parenthesis is the 
number of groundwater bodies for both cycles of RBMPs. Note the period of 
the assessment of status for the second RBMPs was 2010 to 2012. The year of 
the assessment of status for the first RBMPs is not known 

Source: WISE electronic reporting 

Figure  5.2  shows  that  confidence  in  status  classification  for  all  groundwater  bodies  was  at  a 
high level but the RBMPs revealed some discrepancies. For 50 of the 172 groundwater bodies 
there was no data available. The confidence levels were given as sufficient and low. 12 of 122 
were  found  to  be  indicative  of  a  poor  quantitative  status  (13  were  reported,  7  in  the  Vistula 
RBD  and  6  in  the  Oder  RBD),  but  only  for  5  with  sufficient  confidence,  while  for  the 
remaining  7  the  assessment  was  based  on  the  recognition  with  low  confidence.  In  110 
groundwater  bodies  indications  for  good  quantitative  status  were  found,  including  sufficient 
confidence level in 76 groundwater bodies. The results from the Vistula RBMP assessment are 
therefore  not  consistent  with  the  data  reported  (Figure  5.2),  where  confidence  is  high  for  all 
groundwater bodies.65. 

65 Poland subsequently clarified that the level of confidence in the status assessment was considered sufficient in 
all 13 groundwater bodies at poor status. For 5 of 159 groundwater bodies at good status, the confidence of the 
status  assessment  was  defined  as  low.  This  concerned  three  groundwater  bodies  in  the  Odra  RBD  and  two 
groundwater bodies in the Elbe RBD. 

96 

 
 
 
                                                      
Figure 5.2  Confidence  in  the  classification  of  quantitative  status  of  groundwater  bodies 

in Poland based on the most recent assessment of status  

Source: WISE electronic reporting 

The total number of groundwater bodies failing good quantitative status decreased significantly 
from 29 of 161 (18%) groundwater bodies in the first RBMP to 13 of 178 (7%) in the second 
RBMPs  (from  13%  to  4%  of  the  total  groundwater  body  area).  The  RBMP  revealed  a 
discrepancy  in  the  WISE  electronic  reports  regarding  the  Pregolya  river  basin  district  where 
there was no groundwater body of poor status, but it was reported that one groundwater body 
in the Pregolya river basin district was failing good status due to saline intrusion66.  

In  all  river  basin  districts  water  balance  was  assessed  by  a  comparison  of  annual  average 
groundwater  abstraction  against  the  ‘available  groundwater  resource’  for  every  groundwater 
body. 

The  reasons  for  the  failure  of  good  quantitative  status  of  groundwater  bodies  are  shown  in 
Figure  5.3. Nine  groundwater  bodies  failed  good  status  due  to  failing  the  water  balance  test, 
which  means  that  the  long-term  annual  average  rate  of  groundwater  abstraction  is  exceeding 
the  available  groundwater  resource.  Five  groundwater  bodies  failed  due  to  damage  to 
groundwater dependent terrestrial ecosystems and five groundwater bodies failed due to saline 
intrusion. The expected date of achievement of good quantitative status in Poland is shown in 
Figure 5.4.  

66 Poland subsequently clarified that there is an error in the report and reasons for failing good status should not 
have  been  indicated  for  this  groundwater  body  in  the  Pregolya  RBD.  In  the  Pregolya  RBD  all  groundwater 
bodies are at good quantitative status. 

97 

 
 
                                                      
In all 10 river basin districts the criterion of ‘available groundwater resource’ was fully applied 
in accordance with WFD Article 2(27). 

The  environmental  objectives  were  partially  considered  in  status  assessment.  With  the 
exception  of  the  Ucker  river  basin  district,  surface  water  objectives  and  the  diminution  of 
surface  water  status  were  not  considered67.  Water  balance,  groundwater  dependent  terrestrial 
ecosystems and saline intrusion were considered in all RBDs. 

In  total,  13  groundwater  bodies  (7%)  were  at  risk  of  failing  good  quantitative  status  (Figure 
5.5) and they are located in the Vistula RBD and the Oder RBD. Ten groundwater bodies were 
at risk of failing good quantitative status due to failing the water balance test and five due to 
saline intrusions. 

Figure 5.3  Reasons for the failure of good quantitative status of groundwater in Poland 

based on the most recent assessment of status  

Source: WISE electronic reporting 

67  Poland  subsequently  clarified  that  in  the Ucker  RBD no  surface  water bodies had been  identified,  as  already 
reported in the 1st RBMPs, hence there is no association between surface and groundwater in this river basin 
district. 

98 

 
 
 
 
                                                      
Figure 5.4  Expected date of achievement of good quantitative and good chemical status 
of groundwater bodies in Poland. 178 groundwater bodies were delineated for 
the second RBMPs 

Source: WISE electronic reporting 

Figure 5.5 

Percentage of groundwater bodies in Poland at risk of failing good chemical 
status and good quantitative status for the second RBMPs 

Source: WISE electronic reporting 

99 

 
 
 
 
 
 
5.1.3  Consideration  of  groundwater  associated  surface  waters  and/or  groundwater 

dependent ecosystems 

Groundwater associated surface waters were reported for 172 of 178 groundwater bodies68. In 
13  groundwater  bodies  (in  the  Vistula  and  Oder  RBDs)  there  was  a  related  risk  but 
groundwater associated surface waters were only considered in status assessment in the Ucker 
RBD69. 

Groundwater  dependent  terrestrial  ecosystems  were  reported  for  165  of  178  groundwater 
bodies70. In 13 groundwater bodies (in the Vistula RBD and the Oder RBD) there was a related 
risk. Groundwater dependent terrestrial ecosystems were considered in status assessment in all 
RBDs  and  also  the  needs  of  these  ecosystems  were  considered  in  status  assessment  in  all 
RBDs. 

5.2  Main changes in implementation and compliance since first RBMPs 

All groundwater bodies have had changes since the first RBMP. 

The RBMP for the Vistula RBD contains a very short summary of changes. It mentions that 
the water monitoring programme has been fully adapted to the requirements of EU law, and on 
the  basis  of  its  results,  the  current  assessment  of  water  status  has  been  carried  out.  Water 
monitoring carried out in the second RBMPs was much more comprehensive, but there was no 
specific conclusion or mention of quantitative monitoring in groundwater bodies. 

The  groundwater  bodies  have  all  been  re-delineated.  The  RBMP  of  the  Vistula  river  basin 
district explains that for the first RBMP 161 groundwater bodies were delineated and based on 
the needs of the second RBMPs, a new division into 172 groundwater bodies was developed. 
This change was needed due to the definition (adopted according to Polish Geological Institute 
-  National  Research  Institute)  of  the  conceptual  model  of  the  hydrogeological  system. 
According  to  this  definition,  the  conceptual  model  describes  the  structure  of  the  system  and 
indicates  the  dependencies  existing  within  it  (impact  -  process)  and  occurring  between 
individual components of the system and the interaction of the system with the environment. In 
this  approach,  the  conceptual  model  is  built  from  data  as:  1)  geological  structure;  2) 
lithological information, distribution and dissemination as well as hydrogeological parameters 

68 Poland subsequently clarified that 168 of 172 groundwater bodies had groundwater associated surface waters.  
69 As previously indicated, Poland subsequently clarified that in the Ucker RBD no surface water bodies had been 
identified, so there is no association between surface and groundwater in this river basin district. Poland also 
clarified that the consideration of surface waters was not possible due to a lack of the necessary data. 

70  Poland  subsequently  clarified  that  160  of  172  groundwater  bodies  had  groundwater  dependant  terrestrial 

ecosystems.  

100 

 
                                                      
of  aquifers;  3)  environmental  elements  -  anthropogenic  pressures;  4)  factors  affecting  the 
course of individual processes within the system. The new delineation methodology comprises 
a  general  rule  to  limit  the  number  of  aquifers  included  in  the  model  (by  combining)  up  to  a 
maximum of three levels. This is in line with the groundwater body monitoring system adopted 
in Poland, and the following levels or complexes of aquifers are observed in the monitoring: 1) 
the first aquifer with a free-standing groundwater level, the most exposed to pressure from the 
surface area; 2) usable aquifers with a confined groundwater level, constituting the main source 
of water supply for human consumption; 3) deep water level, exposed to salt water intrusion. 

The  monitoring  situation  has  slightly  improved.  The  percentage  of  monitored  groundwater 
bodies increased from 90% to 92% and also the number of monitoring sites slightly increased. 
The groundwater body in the Jarft RBD was subject to monitoring. Monitoring in the second 
RBMPs  was  carried  out  in  accordance  with  the  quality  requirements  given  in  the  2011 
Monitoring Regulation, but it is not clear if and how the quantitative monitoring requirements 
changed  between  the  two  cycles.  Yet,  the  results  could  have  had  an  impact  on  the  status 
assessment. 

The status  situation improved substantially. Since  the first RBMP the  percentage of the total 
groundwater area in poor status declined from 7% to 4%. Comparison between the numbers of 
groundwater bodies is difficult as all groundwater bodies have been re-delineated. The RBMP 
states  that  the  methodology  for  the  status  assessment  is  from  2008.  It  is  later  stated  that  the 
methodology adopted in 2012 for the assessment of groundwater body status incorporated the 
nine classification tests to assess the quantitative and chemical status, and finally the status of 
groundwater bodies. 

5.3 

Progress with Commission recommendations 

The Commission recommendations based on the first RBMPs and first PoM requested action 
on the following: 

  Recommendation: “Ensure that monitoring and subsequent assessments of the status of 
water  bodies  are  carried  out  in  compliance  with  the  requirements  prescribed  by  the 
WFD. In particular, Poland should develop a coherent and comprehensive monitoring 
network  under  Article  8  WFD  which  enables  the  correct  classification  of  all  water 
bodies, monitor water bodies in line with the requirements of Annex V to the WFD and 
with adequate frequencies, and set reference conditions for all quality elements for all 
water bodies.” 

101 

 
“Further  work  is  required  to  make  the  monitoring,  assessment  and  classification  of 
surface  water  and  groundwater  status  fully  compliant  with  the  requirements  of  the 
WFD,  Environmental  Quality  Standards  and  Groundwater  Directives  should  be  fully 
intercalibrated at the European Union level.” 

Assessment: The recommendations were partially fulfilled. The number of monitoring 
sites slightly increased from 828 to 836 and the percentage of monitored groundwater 
bodies  increased  from  90%  to  92%.  There  is  one  groundwater  body  in  the  Jarft  RBD 
that was subject to monitoring for the first time. 

  Recommendation: “Provide information on drinking water protected areas associated 
with  groundwater  bodies  and  on  the  number  of  drinking  water  protected  areas  - 
including whether they are in good status or not.” 

Assessment:  based  on  the  reported  information,  this  recommendation  is  considered  is 
fulfilled.  

102 

 
 
 
  Monitoring, assessment and classification of chemical 

Topic 6
status of groundwater bodies 
6.1 

Assessment  of 
requirements in second RBMPs 

implementation  and  compliance  with  WFD 

6.1.1  Monitoring of chemical status in groundwater 
The  total  number  of  groundwater  bodies  in  Poland  is  17871.  In  total  18  (10%)  groundwater 
bodies  which  are  mainly  located  in  the  smaller  RBDs  were  not  subject  to  surveillance 
monitoring.  The  review  of  the  Vistula  RBMP  revealed  that  no  reference  to  grouping  of 
groundwater bodies for monitoring and assessment of chemical status was found72. 
The  WISE  electronic  reports  indicate  that  there  is  no  operational  monitoring  any  more, 
although 14 groundwater bodies (8%) were reported to be at risk (in the Vistula RBD and the 
Oder RBD)73. In the first RBMPs 369 operational monitoring sites in 55 groundwater bodies 
were  reported.  The  Vistula  RBMP  indicates  that  operational  monitoring  was  carried  out  for 
those groundwater bodies for which threshold values were exceeded but this was not reflected 
in the reporting of monitoring points dedicated to operational monitoring. 
According to the data reported in WISE, the number of groundwater bodies increased by 11% 
from  161  in  the  first  RBMP  to  178  in  the  second  RBMPs  but  after  additional  explanation 
provided  by  Poland  the  increase  turned  out  to  be  approximately  7%.  The  total  groundwater 
body  area  remained  nearly  the  same  (slight  decrease  in  total  area  covered).  In  fact,  no 
groundwater body remained unchanged and all groundwater bodies had been re-delineated. 
Not  all  groundwater  bodies  were  covered  by  chemical  monitoring.  There  was  no  chemical 
monitoring  in  the  Swieza  or  Ucker  RBDs74.  The  number  of  groundwater  bodies  with 
surveillance  monitoring  increased  from  148  (86%)  in  six  RBDs  in  the  first  RBMP  to  160 
(90%) in three RBDs in the second RBMPs. The number of monitoring sites is listed in Table 
14 (see Chapter 5) and shows a significant increase from 789 in the first RBMP to 1172 in the 

71  Poland  clarified  that  the  number  of  groundwater  bodies  is  in  fact  172.  Poland  stated  the  number  178  was 

reported wrongly and comes from calculation subunits as groundwater-bodies. 

72  Poland  clarified  that  unless  there  was  evidence  that  the  water  bodies  without  monitoring  had  anthropogenic 

pressures then the chemical status was classified as good and generally had low confidence.  

73  Poland  subsequently  clarified  that  operational  monitoring  has  been  continued  in  the  second    of  river  basin 
management  plans  and  covers  39  GWBs  threatened  by  failure  to  achieve  environmental  objectives  and  is 
conducted annually outside the year in which surveillance monitoring is carried out. 

74 Poland subsequently clarified that  due to the small area of the Świeża river basin district, the inclusion of the 
groundwater monitoring station in its area was planned at a later stage of monitoring works. The assessment of 
the  basin  was  carried  out  as  part  of  the  status  assessment  GWB  no.  20  (PLGW700020).  In  the  area  of  the 
Ucker river basin district, there is a fragment of one groundwater, PLGW60003 that is located on the territory 
of two river basin districts: the vast majority (97.66%) of the groundwater body's area is within the Odra river 
basin district, and 2.34% within the Ucker river basin district. Due to the small area of the Ucker river basin 
district, consideration of the groundwater monitoring station in its area was planned in subsequent stages of 
monitoring works. The chemical status assessment of this groundwater body was carried out on the basis of 
monitoring stations located in the Odra river basin districts. 

103 

 
                                                      
 
second  RBMPs.  The  number  of  operational  monitoring  sites  declined  significantly  from  the 
first RBMP, from 369 to 075. 
In the Vistula RBD and the Oder RBD, all substances causing risk, except for ammonium (the 
Vistula  RBD  and  the  Oder  RBD)  and  total  nitrogen  (the  Vistula  RBD),  were  subject  to 
surveillance monitoring. No groundwater bodies in other RBDs were considered to be at risk. 
Except  for  ammonium,  all  remaining  WFD  core  parameters  nitrate,  electrical  conductivity, 
oxygen and pH were monitored.75 

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 164 of 17876 groundwater bodies (92%) were of good chemical 
status, and the remaining 14 groundwater bodies (8%) failed good status. In terms of area this 
means  that  about  8%  failed  good  chemical  status.  Figure  6.2  shows  that  the  confidence  in 
status classification was high77. All groundwater bodies had a clear status in both the first and 
in the second RBMPs.  

Map 6.1  Map  of  chemical  status  of  groundwater  bodies  in  Poland  based  on  the  most 

recently assessed status of the groundwater water bodies 

Note: Standard colours based on WFD Annex V, Article 2.4.5. Source: WISE, Eurostat (country borders) 

75 Poland subsequently clarified, that in 2012 ammonium was part of the status assessment report  and therefore 

monitored. 

76  Poland clarified that 158 out of 172 groundwater bodies are in good chemical status.  
77 Poland subsequently clarified that the confidence of the chemical status assessment has been determined to be 
sufficient for 148 GWB and low for 24 GWB. All groundwater bodies with low confidence of the assessment 
were characterized by good chemical status. In the case of five groundwater bodies, in which no surveillance 
monitoring was carried out due to the lack of monitoring points, the chemical status was assessed good and 
with low confidence of the assessment. 

104 

GoodPoorUnknownRiver Basin DistrictsCountries outside the EU 
 
                                                      
Figure 6.1 

Chemical status of groundwater bodies in Poland for the second RBMPs, 
for the first RBMPs and expected in 2015. The number in the parenthesis 
is  the  number  of  groundwater bodies  for both cycles of  RBMPs.  Note the 
period of the assessment of status for the second RBMPs was 2010 to 2012. 
The year of the assessment of status for the first RBMPs is not known 

Source: WISE electronic reporting 

Figure 6.2 

Confidence  in  the  classification  of chemical  status  of  groundwater  bodies 
in Poland based on the most recent assessment of status 

Source: WISE electronic reporting 

105 

 
 
 
 
The total number of groundwater bodies failing good chemical status has increased since the 
first  RBMP  from  11  (7%)  to  14  (8%)  groundwater  bodies  (from  3.7%  to  7.8%  of  the  total 
groundwater body area). The expected date of achievement of good chemical status in Poland 
is shown in Figure 6.1. 

The reasons for the failure of good chemical status of groundwater bodies are shown in Figure 
6.2 The drinking water test, the tests concerning the groundwater associated surface water and 
groundwater dependent terrestrial ecosystems and the test concerning saline or other intrusion 
have  been  carried  out.  The  general  water  quality  assessment  is  the  main  reason,  causing  six 
groundwater bodies to be in poor status. 

Figure 6.3 

Reasons  for  failing  good  chemical  status  in  Poland  for  the  most  recent 
assessment of status  

Source: WISE electronic reports 

Figure 6.4 shows the top ten pollutants causing failure of status and Figure 6.5 shows the two 
pollutants causing a sustained upward trend.  

106 

 
 
 
Figure 6.4 

Top 10 groundwater pollutants causing failure of good chemical status in 
Poland  

Source: WISE electronic reporting 

Figure 6.5 

Pollutants with upward trends in groundwater bodies in Poland  

Source: WISE electronic reporting 

The calculation of the extent of exceedance of a groundwater quality standard or a groundwater 
threshold value was based on the groundwater body area.  

Groundwater  threshold  values  were  established  for  all  pollutants  or  indicators  of  pollution 
causing  a  risk  of  failure  of  good  chemical  status.  There  was  no  explicit  indication  that  all 

107 

 
 
 
 
 
 
Groundwater Directive78 Annex II substances had been considered. Natural background levels 
were considered in the establishment of threshold values in all RBDs except the Vistula which 
mentions that they were considered in a ‘different way’. There was no further explanation of 
this ‘different way’. 

Trend  assessments  were  reported  for  all  RBDs  but  a  methodology  for  identifying  significant 
upward trends in any pollutants concentration had not been applied. A methodology for trend 
reversal assessment is not available.79 

6.1.3  Consideration  of  groundwater  associated  surface  waters  and/  or 

groundwater dependent ecosystems 

In 172 of 178 groundwater bodies, groundwater associated surface waters were reported and in 
14  groundwater  bodies a  related risk  was  indicated.  Diminution  of the  status  of  groundwater 
associated surface waters was considered in status assessment for all RBDs. 

Groundwater  dependent  terrestrial  ecosystems  were  reported  for  165  of  17880  groundwater 
bodies  and  in  14  groundwater  bodies  a  related  risk  was  indicated.  Groundwater  dependent 
terrestrial ecosystems were considered in status assessment. 

Groundwater associated aquatic ecosystems and groundwater dependent terrestrial ecosystems 
were  considered  in  the  establishment  of  groundwater  threshold  values  in  both  RBDs  where 
groundwater bodies were at risk.  

6.2  Main changes in implementation and compliance since first RBMPs 

The number of groundwater bodies increased by approximately 7% but the total groundwater 
body  area  remained  nearly  the  same  (slight  decrease  in  total  area  covered).  In  fact,  all 
groundwater  body  changed  and  all  groundwater  bodies  had  been  re-delineated.  This  change 
was needed due to the definition (adopted according to Polish Geological Institute  - National 
Research Institute) of the conceptual model of the hydrogeological system (see Section 5.2 for 
further details). 

78   Directive 2006/118/EC of the European Parliament and of the Council of 12 December 2006 on the protection 

of groundwater against pollution and deterioration  
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02006L0118-20140711 

79 Poland subsequently clarified, that the methodology for identifying significant upward trend is described in the 
report  on  the  chemical  and  quantitative  status  of  groundwater  bodies  in  2012,  which  was  submitted  as  text 
report.  A  methodology  for  trend  reversal  assessment  was  not  developed  at  this  stage  as  the  length  of  the 
available time series is not sufficient to perform assessments in 2012. 

80 Poland clarified that there are 158 (out of 172) groundwater dependent terrestrial ecosystems. 

108 

 
                                                      
 
The  surveillance  monitoring  network  improved  slightly  in  Poland,  in  terms  of  number  of 
groundwater  bodies  covered  (from  92%  to  93%  coverage)  and  in  terms  of  the  number  of 
monitoring  sites.  However,  there  was  no  surveillance  monitoring  in  seven  RBDs  (with  only 
very  few  groundwater  bodies).  For  operational  monitoring  the  situation  deteriorated 
significantly as there was no more monitoring even though 14 groundwater bodies were at risk, 
located  in  the  Vistula  and  Oder  RBDs.    Poland  clarified  however  that  in  fact  operational 
monitoring is continued in the second RBMP covering 39 groundwater bodies at risk. 

For Vistula RBD for example, a short summary of changes was provided. It mentioned that the 
water  monitoring  programme  has  been  fully  adapted  to  the  requirements  of  European 
legislation.  On  this  basis,  the  current  assessment  of  water  status  has  been  carried  out.  No 
further information was given with regard to the monitoring, assessment and classification of 
the chemical status of groundwater bodies.  

Poland  however  clarified  that  a  summary  is  to  be  found  in  all  RBMPs  about  all  changes 
introduced or the updates done after the adoption of the first RBMP together with monitoring 
results. 

The  status  situation  has  deteriorated  as  described  above.  The  groundwater  body  area  failing 
good status increased from 3.7% to 7.8% of the total groundwater body area, which could be 
the result of delineation. 

6.3 

Progress with Commission recommendations 

The Commission recommendations based on the first RBMPs and first PoM requested action 
on the following: 

  Recommendation: Ensure that monitoring and subsequent assessments of the status of 
water  bodies  are  carried  out  in  compliance  with  the  requirements  prescribed  by  the 
WFD. In particular, Poland should develop a coherent and comprehensive monitoring 
network  under  Article  8  WFD  which  enables  the  correct  classification  of  all  water 
bodies, monitor water bodies in line with the requirements of Annex V to the WFD and 
with adequate frequencies, and set reference conditions for all quality elements for all 
water bodies. 

  Recommendation:  Further  work  is  required  to  make  the  monitoring,  assessment  and 
classification  of  surface  water  and  groundwater  status  fully  compliant  with  the 
requirements  of  the  WFD,  EQS  and  Groundwater  Directives.  should  be  fully 
intercalibrated at the EU level. 

109 

 
Assessment: The monitoring situation improved for surveillance monitoring in terms of 
number of groundwater bodies covered and in terms of the number of monitoring sites. 
Conversely,  there  was  no  surveillance  monitoring  in  approximately  10%  of  the 
groundwater  bodies  (i.e.  18  groundwater  bodies)  in  seven  RBDs  (with  only  very  few 
groundwater  bodies).  Initial  assessment  showed  that  for  operational  monitoring  the 
situation  deteriorated  significantly  as  there  was  no  more  monitoring  despite  some 
groundwater  bodies  being  at  risk  (Vistula  and  Oder  RBDs).  Poland  however  clarified 
that operational monitoring is continued in the second RBMPs covering 39 groundwater 
bodies at risk.  

The recommendation is partly fulfilled.  

  Recommendation: Put in place in the second RBMPs cycle concrete actions to reduce 
the number of unknowns and to increase the percentage of WB in good chemical status. 

The  recommendation  concerning  reduction  of  the  unknowns  is  not  relevant  as  all 
groundwater bodies had and still have a clear status classification, in the first and in the 
second RBMPs.  

The recommendation concerning the increase of the percentage of groundwater bodies 
in  good  chemical  status  was  not  fulfilled.  The  number  of  groundwater  bodies  failing 
good status increased (from 7% to 8% groundwater bodies) and the groundwater body 
area  failing  good  status  increased  from  3.7%  to  7.8%  of  the  total  groundwater  body 
area.  However  this  could  be  as  a  result  of  redelineation  of  water  bodies.  There  is  no 
evidence however that this recommendation has been fulfilled.  

  Recommendation: On groundwater, it is important to have a clear methodology on how 
exceedances  of  threshold  values  are  handled  in  the  assessment  of  groundwater 
chemical  status.  Furthermore,  a  methodology  for  trend  analysis  should  be  in  place, 
even if it was not possible yet to carry out such an analysis during the first RBMP, in 
order to be sure that this will be done in the second RBMP, and to link groundwater 
protection measures with the relevant pressures. 

The recommendation concerning a clear methodology on how exceedances of threshold 
values are handled in the assessment of groundwater chemical status was fulfilled as all 
RBDs reported that the calculation of the extent of exceedance of a groundwater quality 
standard or a groundwater threshold value was based on the groundwater body area. 

110 

 
Initial assessment showed that the recommendation concerning a methodology for trend 
analysis was not fulfilled. It was reported that trend assessments were performed in all 
RBDs, but it was in parallel reported that a methodology was not available. In addition 
to that, a methodology for trend reversal assessment was also not available. 

  Poland  subsequently  clarified  that  the  methodology  for  identifying  significant  upward 
trend is described in the report on the chemical and quantitative status of groundwater 
bodies in 2012, which was submitted as a report. 

  Therefore, the recommendation is partly fulfilled. 

111 

 
 
  Designation of Heavily Modified and Artificial Water 

Topic 7
Bodies and definition of Good Ecological Potential 

7.1 

Assessment  of 
requirements in second RBMPs for designation  

implementation  and  compliance  with  WFD 

7.1.1  Designation of Heavily Modified and Artificial Water Bodies  

Heavily  modified  water  bodies  or  artificial  water  bodies  were  designated  in  five  out  of  ten 
RBDs, similar to the first RBMPs (Figure 7.1). In two RBDs (the Vistula RBD and the Oder 
RBD),  there  were  38  river  heavily  modified  water  bodies  which  are  now  designated  as 
reservoirs, having previously been designated as rivers. 

Figure 7.1 

Proportion of total water bodies in each category in Poland that has been 
designated as heavily modified or artificial  

Source: WISE electronic reports 

The  water  uses  for  which  river  heavily  modified  water  bodies  were  designated  as  heavily 
for 
modified  were  mainly 

irrigation,  urban  development, 

agricultural 

storage 

112 

 
 
fisheries/aquaculture/fish  farms,  flood  protection,  land  drainage  for  agriculture,  hydropower, 
tourism and recreation, transport and the wider environment. In the RBD Oder and the RBD 
Vistula, for 23.4% and 9.1% respectively of river heavily modified water bodies, the uses are 
reported as unknown. For the two river heavily modified water bodies in the RBD Danube, the 
uses for which they are designated were reported as unknown. The water uses for which lake 
water  bodies  were  designated  as  heavily  modified  were  mainly  urban  development,  tourism-
recreation and other uses which were not specified according to the uses listed in WISE. One 
coastal  heavily  modified  water  body  in 
the  Vistula  RBD  was  designated  due  to 
navigation/ports and transitional heavily  modified  water bodies were designated due to  flood 
protection, navigation/ports and other uses. 

river  heavily  modified  water  bodies  were 
The  main  physical  alterations  of 
channelisation/straightening/bed  stabilisation/bank  reinforcement  and  weirs/dams/reservoirs. 
Lake  heavily  modified  water  bodies  were  affected  by  channelisation/straightening/bed 
stabilisation/bank reinforcement and other alterations (not specified in WISE). Also for coastal 
and  transitional  heavily  modified  water  bodies,  the  physical  alterations  are  not  specified  in 
WISE (reported as “other”). 

The methodologies for heavily modified water bodies designation include details on the criteria 
for  the  identification  of  substantial  changes  in  character  as  well  as  general  guidance  (on 
national level) on the assessment of other  means to achieve the benefits of the modifications 
and significant adverse effects of measures on the use and the wider environment. 

7.1.2  Definition of good ecological potential for Heavily Modified and Artificial Water 

Bodies 

Good  ecological  potential  was  reported  as  having  been  defined  with  reference  made  to  the 
approach used as detailed in the Common Implementation Strategy Guidance (approach based 
on  biological  quality  elements  as  illustrated  in  Common  Implementation  Strategy  Guidance 
Document No 481). 

In practice, in Poland, good ecological potential has been defined at different levels, depending 
on the category of the water body:  

  Rivers: good ecological potential has been defined for groups of heavily modified water 

bodies/artificial water bodies of the same purpose/physical modification; 

81 

https://circabc.europa.eu/sd/a/f9b057f4-4a91-46a3-b69a-e23b4cada8ef/Guidance%20No%204%20-

%20heavily%20modified%20water%20bodies%20-%20HMWB%20(WG%202.2).pdf  

113 

 
                                                      
 
  Lakes: good ecological potential has been defined at national level; 

  Transitional and coastal waters: good ecological potential has been defined at the water 

body level. 

Good ecological potential has also been reported as defined in terms of biology. The biological 
quality  elements  for  which  biological  values  were  derived  to  define  maximum  ecological 
potential and good ecological potential are phytoplankton, macrophytes, phytobenthos, benthic 
invertebrates, and fish. In two RBDs (the Vistula and the Oder), values for biological quality 
elements to define maximum ecological potential and good ecological potential were derived 
in addition for macroalgae and angiosperms. According to information in the second RBMPs, 
the assessment of ecological potential was based on monitoring data from previous years. The 
classification  of  heavily  modified  water  bodies/artificial  water  bodies  in  terms  of  biological 
elements followed the 2011 classification regulation for ecological status, chemical status and 
ecological  potential.  This  regulation  does  not  however  provide  values  for  biological  quality 
elements but more general definitions of ecological potential.  

According  to  the  reporting,  a  comparison  between  good  ecological  potential  and  good 
ecological status was made. 

For  rivers, methods  for  assessing  fish  and  benthic invertebrates  were  reported  as  sensitive to 
altered habitats due to morphological changes. For coastal waters, only methods for assessing 
benthic invertebrates were reported as sensitive to hydromorphology. For lakes and transitional 
waters,  the  methods  reported  for  assessing  biological  quality  elements  are  not  sensitive  to 
hydromorphological  changes.  For  coastal  waters,  two  methods  for  assessing  benthic 
invertebrates were reported as sensitive to altered habitats due to morphological changes. 

Fish ladders were reported as the only mitigation measure identified to define good ecological 
potential.  However,  no  description  was  found  on  the  ecological  changes  that  the  mitigation 
measures were designed to achieve. 

7.2  Main changes in implementation and compliance since first RBMPs 

Major changes in designated river heavily modified water bodies were noted, especially in the 
Vistula RBD where their number decreased from 904 to 491 from the first to second RBMPs.  

For lake heavily modified water bodies, some changes were noted. In the Vistula RBD and the 
Pregolya RBD, the number of lake heavily modified water bodies decreased slightly, while in 

114 

 
the Oder RBD the number increased (from 34 to 102 lake water bodies although the increase in 
area is not as high from 201 to 297 km²). 

In the Vistula RBD, no transitional heavily modified water bodies were designated in the first 
RBMPs, while two heavily modified water bodies were designated in the second RBMPs. In 
the  Oder  RBD,  two  coastal  heavily  modified  water  bodies  from  the  first  cycle  were  de-
designated in the second cycle. 

Heavily  modified  water  bodies/artificial  water  bodies  were  designated  in  Poland  for  the  first 
time  in  2007.  In  the  first  RBMPs,  the  methodologies  used  for  the  designation  included  the 
assessment  of  hydromorpholgical  status  and  refinement  of  threshold  values  to  finalise  the 
initial  identification  of  heavily  modified  water  bodies/artificial  water  bodies.  For  the  second 
cycle,  the  verification  of  the  identification  of  heavily  modified  water  bodies/artificial  water 
bodies  was  carried  out  in  2012-2013,  and  involved  the  update  of  information  on 
river  heavily  modified  water 
hydromorphology.  The  methodology 
bodies/artificial  water  bodies  is  still  valid,  as  established  in  the  first  RBMPs.  Although  it  is 
stated that the information on hydromorphology has been updated, no further explanation was 
provided explaining the changes in numbers of designated river heavily modified water bodies 
since the first RBMPs.  

identifying 

for 

A  methodology  for  the  designation  of  lake  heavily  modified  water  bodies/artificial  water 
bodies  was  developed  for  the  second  RBMPs,  while  in  the  first  RBMPs  there  was  no 
methodology  available  and  the  identification  was  based  on  expert  judgement.  For  the 
designation of transitional and coastal heavily modified water bodies/artificial water bodies, a 
methodology document of 2011 was reported, but it is not clear if the same methodology was 
also  used  in  the  first  RBMPs  or  whether  this  methodology  was  developed  for  the  second 
RBMPs.  Poland  has  informed  the  Commission  that  the  methodology  document  of  2011  was 
prepared for the second cycle. In the first cycle, the methodological approach was developed 
by  regional  water  management  authorities  in  Gdańsk  and  Szczecin  (covering  the  whole 
coastline  in  Poland).  In  the  second  cycle,  these  approaches  were  revised  and  updated  on  the 
national level. 

It was reported that the approach used for the definition of good ecological potential followed 
the Common Implementation Strategy Guidance approach. This was not entirely clear from the 
reporting  in  the  first  RBMPs.  The  methodological  document  for  good  ecological  potential 
definition in river water bodies has not changed since the first RBMPs and is dated 2007. The 
methodological  documents 
lakes  and 
coastal/transitional water bodies are more recent, dated 2011. 

for  good  ecological  potential  definition 

in 

115 

 
7.3 

Progress with Commission recommendations 

The Commission recommendations based on the first RBMPs and first PoM requested action 
on the following: 

  Recommendation (report 2012): Designate artificial and heavily modified water bodies 
and  justify  their  designation;  develop  a  system  for  classifying  them  and  establish  a 
coherent  and  comprehensive  monitoring  network  to  enable  their  classification;  duly 
justify exemptions at the water-body level. 

  Recommendation (report 2012): The designation of HMWBs should comply with all the 
requirements  of  Article  4(3).  The  assessment  of  "significant  adverse  effects"  on  their 
use  or  the  environment  and  the  lack  of  "significantly  better  environmental  options" 
should  be  specifically  mentioned  in  the  RBMPs.  This  is  needed  to  ensure  the 
transparency of the designation process. 

Assessment: The methodology for designating river heavily modified water bodies has 
not  changed  since  the  first  RBMPs.  Although  it  was  stated  that  the  information  on 
hydromorphology was updated, no further explanation was provided on the changes in 
numbers  of  designated  river  heavily  modified  water  bodies  since  the  first  RBMPs 
RBMPs.  For  lakes  and  also  for  transitional  and  coastal  water  bodies,  new 
methodologies  have  been  developed  for  the  designation  of  heavily  modified  water 
bodies for the second RBMPs. 

The methodologies for heavily modified water bodies designation include details on the 
criteria  for  the  identification  of  substantial  changes  in  character  as  well  as  general 
guidance (on national level) on the assessment of other means to achieve the benefits of 
the modifications and significant adverse effects of measures on the use and the wider 
environment. However, information was not reported on the details of the outcome of 
the designation tests of significant adverse effects on the use and better environmental 
options (other means) for individual water bodies. 

To  fulfil  this  recommendation  in  terms  of  classification,  WFD  compliant  monitoring 
and assessment methods for fish in rivers, lakes and transitional water bodies should be 
in place; for macrophytes in rivers; and angiosperms and macroalgae in transitional and 
coastal waters. These elements would need to be monitored in water bodies affected by 
hydromorphological  pressures.  Biological  quality  element  assessment  methods  were 
reported  for  fish  in  rivers,  lakes  and  transitional  water  bodies  as  well  as  for 

116 

 
macrophytes  in  rivers  and  lakes.  However,  assessment  methods  for  angiosperms  and 
macroalgae  were  only  reported for coastal  but not  for transitional waters. Concerning 
monitoring,  it  appears  from  information  given  in  the  RBMP  that  the  assessment  of 
ecological potential was based on monitoring data from previous years. Concerning the 
justification of exemptions, please refer to the chapter on exemptions in this report. 

Overall, based on the information found, this recommendation was partially fulfilled. 

  Recommendation (report 2012):  The method for the determination of good ecological 
potential  in  heavily  modified  and  artificial  water  bodies  should  be  transparent  and 
clearly reported. There seems to be no understanding of how the methodology should 
be applied. 

Assessment:  It  was  clearly  reported  that  good  ecological  potential  was  defined 
according  to  the  Common  Implementation  Strategy  Guidance  approach  (based  on 
biological  quality  elements  as  illustrated  in  Common  Implementation  Strategy 
Guidance No 4). The methodological document for good ecological potential definition 
in  river  water  bodies  has  not  changed  since  the  first  RBMPs  and  is  dated  2007.  The 
methodological  documents  for  good  ecological  potential  definition  in  lakes  and 
coastal/transitional  water  bodies  are  more  recent,  dated  2011,  indicating  new 
methodological developments for these categories. 

Good  ecological  potential  was  also reported  as  defined  in  terms  of  biology  following 
the  2011  regulation  on  the  classification  of  ecological  status,  ecological  potential  and 
chemical status of surface water bodies. This regulation though does not provide values 
for  biological  quality  elements  but  more  general  definitions  of  ecological  potential. 
Mitigation measures were reported for defining good ecological potential (though only 
fish ladders) but no description was found on the ecological changes that the mitigation 
measures are designed to achieve. 

Overall, this recommendation was partially fulfilled. 

117 

 
 
Topic 8

  Environmental objectives and exemptions 

8.1 

Assessment  of  implementation  and  compliance  with  WFD 
requirements in the second RBMPs 

8.1.1  Environmental objectives 

The  environmental  objectives  are  defined  in  Article  4  of  the  WFD.  The  aim  is  long-term 
sustainable water management based on a high level of protection of the aquatic environment. 
Article 4(1) defines the WFD general objective to be achieved in all surface and groundwater 
bodies,  i.e.  good  status  by  2015.  Within  that  general  objective,  specific  environmental 
objectives are defined for heavily modified water bodies (good ecological potential and good 
chemical status by 201582), groundwaters (good chemical and quantitative status by 2015) and 
for Protected Areas (achievement of the objectives of the associated Directive by 2015 unless 
otherwise specified).  

Environmental objectives are reported for surface and groundwater bodies. 

Member States are also required to specify additional environmental objectives and standards 
in  Protected  Areas  where  these  are  required  to  ensure  the  requirements  of  the  associated 
Directive  are  met.  An  assessment  of  such  additional  objectives  for  Poland  is  provided  in 
Chapter 15 of this report. 

Assessments  of  the  current  status  of  surface  and  groundwater  bodies  in  Poland  are  provided 
elsewhere in this report: for ecological status/potential of surface waters (Chapter 3); chemical 
status  of  surface  waters  (Chapter  4);  quantitative  status  of  groundwater  bodies  (Chapter  5); 
chemical status of groundwater bodies (Chapter 6); status of surface and groundwater bodies 
associated with Protected Areas (Chapter 15). 

For the second RBMPs, Member States are required to report the date when they expect each 
surface  and  groundwater  body  to  meet  its  environmental  objective.  This  information  is 
summarised  for  Poland  elsewhere  in  this  report:  for  ecological  status/potential  of  surface 
waters  (Chapter  3);  chemical  status  of  surface  waters  (Chapter  4);  quantitative  status  of 
groundwater bodies (Chapter 5); chemical status of groundwater bodies (Chapter 6).  

82 For priority substances newly introduced by Directive 2013/39/EU, good status should be reached by 2027, and 
for  the  2008  priority  substances,  for  which  the  Environmental  Quality  Standards  were  revised  by  Directive 
2013/39/EU, good status should be reached in 2021. 

118 

 
                                                      
8.1.2  Exemptions 

Where  environmental  objectives  are  not  yet  achieved  exemptions  can  be  applied  in  case  the 
respective conditions are met and the required justifications are explained in the RBMP. 

Figure 8.1 summarises the percentage of water bodies expected to be at least in good status in 
2015 and the use of at least one exemption in Poland for the four main sets of environmental 
objectives.  Exemptions  are  most  widely  applied  in  relation  to  ecological  status/potential 
objectives. 

Figure 8.1 

Water bodies in Poland expected to be in at least good status in 2015 and 
use of exemptions. 1 = Surface water body ecological status/potential; 2 = 
Surface  water  body  chemical  status;  3  =  Groundwater  body  quantitative 
status; 4 = Groundwater body chemical status 

Source: WISE electronic reports  

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 

119 

 
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 Poland. 

Figure 8.2   Type of exemptions applied to surface water and groundwater bodies for the 

second RBMPs in Poland. Note: Ecological status and groundwater 
quantitative status exemptions were reported at the water body level. Chemical 
exemptions for groundwater were reported at the level of each pollutant 
causing failure of good chemical status, and for surface waters for each 
Priority Substances that is causing failure of good chemical status 

Source: WISE electronic reports  

120 

 
Application of Article 4(4) 

Article  4(4)  was  not  applied  in  surface  waters  in  the  first  RBMPs  in  the  Danube  RBD,  Jarft 
RBD, Elbe RBD or Dniester RBDs. This has changed in the second cycle and Article 4(4) was 
applied  in  all  RBDs83.  Good  ecological  status  is  only  achieved  in  all  water  bodies  in  the 
Dniester  RBD.  Exemptions  reported  in  terms  of  achievement  of  good  chemical  status  in 
surface waters were applied in all RBDs except for the Danube and Swieza RBDs.  

The  reasons  for  exemptions  to  surface  water  bodies’  objectives  included  natural  conditions, 
disproportionate costs and technical feasibility. 

In the first cycle, Article 4(4) exemptions on chemical status for groundwater were applied in 
the Elbe RBD. In the second cycle, exemptions to the achievement of good chemical status and 
quantitative status by 2015 were applied in the Oder and Vistula RBD. The reason reported for 
exemptions to groundwater objectives was technical feasibility.  

Justifications for technical feasibility were given in relation to Article 4(4) at water body level. 
Information on when environmental objectives are expected to be met was also given. A more 
also  provided.  However, 
in-depth 
PLRW200002111569  was  assessed  in  more  detail  and  as  justification  for  the  exemption 
information was provided that no pressure was identified in this water body that could cause 
the exceedance of the quality element.  

justification  of 

feasibility 

technical 

the 

is 

Disproportionate costs were only used for surface waters in the Vistula and Oder RBD. Costs 
of basic measures listed in Article 11(3) (a) of the WFD have been explicitly excluded from the 
assessment of disproportionate cost in surface water bodies. The justification provided in the 
plans  however  was  not  fully  clear  and  also  mixed  elements  from  justifications  of  technical 
feasibility  and  natural  conditions.  There  was  also  no  differentiation  between  justifications 
related to Articles 4(4) and 4(5).  

The  use  of  natural  conditions  as  a  justification  was  not  fully  justified  as  details  are  lacking. 
Application  of  Article  4(4)  was  reported  in  WISE  and  mentioned  in  relation  to  lakes  in  the 
RBMP, but only general text is provided without details.  

For surface waters the drivers behind Article 4(4) were: 

83  Poland  subsequently  clarified  that  the  analysis  was  more  thorough  as  data  available  for  waterbodies 
characterisation was updated and refined. Moreover, some changes in the approach on setting exemptions for 
example in the SWBs with no direct monitoring have taken place. 

121 

 
                                                      
  agriculture (Vistula, Oder, Pregolya and Nemunas RBDs); 

 

industry (Vistula, Oder and Pregolya RBDs); 

 

tourism and recreation (Vistula, Oder, Pregolya and Nemunas RBDs); and 

  urban development (Danube, Vistula, Oder, Pregolya and Nemunas RBDs).  

The impacts causing exemptions in surface waters were: 

  acidification (Vistula, Oder and Pregolya RBDs); 

  chemical pollution (Vistula, Jarft, Elbe, Oder, Pregolya, Nemunas and Dniester RBDs); 

  altered  habitats  due  to  morphological  changes  (Vistula,  Elbe,  Oder,  Pregolya  and 

Nemunas RBDs); 

  nutrient  pollution  (Danube,  Vistula,  Swieza,  Jarft,  Oder,  Pregolya,  and  Nemunas 

RBDs),  

  organic pollution (Vistula, Swieza and Pregolya RBDs).  

For groundwater the drivers behind Article 4(4) were: 

  Agriculture Urban development and industry (Vistula, Oder) 

  Transport (Oder) 

The impacts causing exemptions to groundwater were: 

  damage  to  groundwater-dependent  terrestrial  ecosystems  for  chemical  /  quantitative 

reasons (Vistula RBD); 

  alterations in flow directions resulting in saltwater intrusion (Vistula RBD),  

  Microbiological pollution (Vistula and Oder RBDs),  

  Diminution of quality of associated surface  waters for chemical / quantitative reasons 

(Vistula and Oder RBDs),  

  Saline pollution/intrusion (Oder RBD). 

The  drivers  for  exemptions  related  to  Article  4(4)  in  groundwater  were  agriculture,  industry, 
transport and urban development in the Vistula and Oder RBDs. In other RBDs, Article 4(4) 
was not applied to groundwater.  

122 

 
The pressures to surface waters caused by the drivers mentioned above were point and diffuse 
pollution  (Danube,  Vistula,  Oder,  Pregolya  and  Nemunas  RBDs).  For  the  Swieza  and  Jarft 
RBDs only diffuse pollution was reported and for the Elbe RBD the pressures were reported as 
unknown. No information on pressures was reported for the Dniester RBD84.  
For groundwater alteration of water level or volume, diffuse and point pollution were reported 
for the Vistula and Oder RBDs.  
Pressures  responsible  for  Priority  Substances  failing  to  achieve  good  chemical  status  and  for 
which  exemptions  have  been  applied  are  summarised  in  Table  8.1  and  pressures  responsible 
for pollutants failing to achieve good chemical status in groundwater and for which exemptions 
have been applied are summarised in Table 8.2. 

Table 8.1 

Pressures responsible for Priority Substances  in Poland failing to achieve 
good chemical status and for which exemptions have been applied 

Significant pressure on surface 
water bodies 

Failing Priority 
Substances 

Article 4(4) - 
Technical feasibility 
exemptions 

Number 

Number 

1.1 - Point - Urban waste water 

1.9 - Point - Other 

2.7 - Diffuse - Atmospheric deposition 

8 - Anthropogenic pressure - Unknown 

5 

7 

1 

18 

9 

12 

109 

177 

Source: WISE electronic reports  

Table 8.2 

Pressure  reported  being  responsible  for  pollutants  in  Poland  failing  to 
achieve  good  chemical  status  in  groundwater  and  for  which  exemptions 
have been applied  

Significant pressure on groundwater 

1.6 - Point - Waste disposal sites 

1.7 - Point - Mine waters 

2.2 - Diffuse - Agricultural 

2.8 - Diffuse - Mining 

4.3.4 - Hydrological alteration - Public water supply 

7 - Anthropogenic pressure - Other 

Number of 
failing 
pollutants 

6 

5 

6 

5 

1 

9 

Number of exemptions 

Article 4(4) - 
Technical 
feasibility 
6 

Article 4(5) - 
Technical 
feasibility 

4 

8 

4 

9 

3 

2 

5 

1 

3 

Source: WISE electronic reports  

84 Poland subsequently clarified that there was only one significant pressure identified in the Dniester RBD which 
is diffuse atmospheric deposition’ in the water body coded PLRW9000127691. The other two WBs are in bad 
status (upon the expert judgment based on monitoring results from 2010-2012) and there is no data from 2013 
chemical monitoring. In such a case no significant pressure was reported. 

123 

 
 
 
 
                                                      
Application of Article 4(5) 

Article 4(5) was only used in the Vistula RBD in surface waters and groundwater in the first 
RBMPs. This has not changed, but in the second RBMPs, Article 4(5) was also applied in the 
Pregolya RBD (surface waters) and the Oder RBD (surface waters and groundwater).  

The  reasons  for  exemptions  under  Article  4(5)  to  surface  waters  are  justified  on  water  body 
level by technical feasibility and disproportionate costs. 

The drivers behind Article 4(5) exemptions in surface waters were: 

  agriculture (Vistula, Oder and Pregolya RBDs); 

  urban development (Vistula RBD, PL6000); 

  Tourism and recreation (Vistula, Oder and Pregolya RBDs); and  

  Urban development (Vistula RBD).  

The drivers behind Article 4(5) exemptions in groundwater were: 

  agriculture (Vistula and Oder RBDs); 

  urban development (Vistula and Oder RBDs); 

 

industry (the Oder RBD); 

  energy (the Vistula RBD, the Oder RBD); and 

 

transport (the Vistula RBD).  

Application of Article 4(6) 

No exemptions according to Article 4(6) were applied. 

Application of Article 4(7) 

Article  4(7)  was  applied  in  the  first  RBMPs  and  is  also  applied  in  the  second  RBMPs.  The 
justification  for  using  Article  4(7)  in  the  Vistula  RBMP  refers  to  master  plans  under  which 
Article 4(7) was considered/assessed. The RBMP gives a summary of the master plans for the 
Vistula  RBD  and  states  that  among  all  the  investments  analysed,  it  was  reported  that 
Article 4(7) was assessed for 252 potential investments. 155 investments were reported to meet 
all the conditions allowing for derogation from the set environmental objectives. Investments 

124 

 
which entered into the masterplan for the Vistula RBD are planned until 2021. The Annexes to 
the Vistula, Oder and Pregolya RBMPs present the final list of investments with justifications 
for meeting the requirements set out in the Article 4(7) WFD85.  

Application of Article 6(3) of the Groundwater Directive 

No exemptions according to Article 6(3) of the Groundwater Directive86 were applied. 

8.2  Main  changes  in  implementation  and  compliance  since  the 

first RBMPs 

The  RBMPs  contain  a  short  summary  of  changes  and  references  to  the  articles  in  the  Polish 
Water Law 2011 that has now been superseded by the Water Law 2017. The RBMP stated that 
the most important change to the Water Law Act is the definition of environmental objectives 
and  exemptions  and  the  provisions  of  articles  to  fully  transpose  Article  4(5)  of  the  WFD 
(Article 114a of Poland’s Water Law) and Article 4(7) of WFD (Article 38j of Poland’s Water 
Law).  The  provisions  of  Article  38  and  Article  114a  of  the  Water  Law  Act  define 
environmental  objectives  for  water  bodies  and  Protected  Areas  and  set  the  rules  for  the 
application of deviations from their implementation, which was stated to be a full transposition 
of the WFD Articles.  

Article 4(4) was not applied in surface waters in the first RBMPs in the Danube, Jarft, Elbe or 
Dniester  RBDs.  This  changed  in  the  second  RBMPs  where  Article  4(4)  was  applied  in  all 
RBDs. Article 4(5) was only used in the Vistula RBD in surface waters and groundwater in the 
first RBMPs. This did not change in the second RBMPs, but Article 4(5) was also applied in 
the  Pregolya  (surface  waters)  and  Oder  RBDs  (surface  waters  and  groundwater).  For 
groundwater exemptions under Article 4(4) and Article 4(5) on chemical status were applied in 
the  Vistula  and  Elbe  RBDs  in  the  first  RBMPs.  In  the  second  cycle  exemptions  to  the 

85 Poland further informed that the review of RBMPs had been in place since May 2014. One of the tasks was a 
detailed  in-depth  analysis  of  planned  investments  against  requirements  of  the  WFD  and  its  Article  4(7). 
During  those  analyses  the  list  of  investments  which  could  negatively  affect  the  ability  to  achieve 
environmental  objectives  and  for  which derogation 4(7)  could  be  applied  was updated (also  in  the  frame  of 
public consultation)  and verified. Those  analysis included impact  assessment  related  to  the quality elements 
used  for  water  body  status  assessment  (biological,  physico-chemical  and  hydromorphological)  and  also  on 
every stage of project implementation. The Masterplans have been included in the second RBMPs by inclusion 
of  chosen  investments  from  the  list  No  2  of  Masterplans  (i.e.  those  investments  that  may  cause  failure  to 
achieve  good  status  of  WBs  or  deterioration  of  status),  meeting  (after  additional  thorough  verification)  the 
requirements of the Article 4(7). Further investments related to flood protection have also been assed in-depth. 
Cases where not all the requirements of the Article 4(7) have been met were finally not included in the second 
RBMPs even being in the territory of the PFRA and analysed in the FRMPs. 

86   Directive 2006/118/EC of the European Parliament and of the Council of 12 December 2006 on the protection 

of groundwater against pollution and deterioration  
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02006L0118-20140711 

125 

 
                                                      
 
achievement  of  good  chemical  status  by  2015  have  been  applied  in  the  Vistula  and  Oder 
RBDs.   

8.3 

Progress with Commission recommendations 

The Commission recommendations based on the first RBMPs and first PoM reports requested 
action on the following: 

  Recommendation: Only little improvement of the water status is expected by 2015 and 
the objectives for subsequent plans are not always clear. Objectives should be clearly 
indicated  and  transparent  in  order  to  be  able  to  reach  good  status  of  waters  in  a 
reasonable timeframe. 

Assessment:  Environmental  objectives  for  chemical  and  ecological  status  of  surface 
water  and  chemical  and  quantitative  status  of  groundwater were  reported  in  all  RBDs 
and  deadlines  when  objectives  will  be  met  are  set.  Overall  the  RBDs  under  which 
exemptions  are  applied  have  been  increased.  In  terms  of  improvements  in  the 
characterisation  process,  monitoring  networks,  status  assessments  and  reducing 
uncertainty,  various  levels  of  progress  have  been  made  as  reported  in  the  preceding 
chapters. This recommendation has been partially fulfilled. 

  Recommendation: Exemptions from the achievement of good ecological status by 2015 
have  been  widely  applied  in  Poland,  and  mostly  under  Article  4(4).  While  the  WFD 
does  provide  for  exemptions,  specific  criteria  must  be  fulfilled  for  their  use  to  be 
justified. The application of exemptions needs to be more transparent and the reasons 
for the exemptions should be clearly justified in the plans.   

Assessment:  The  recommendation  has  partly  been  fulfilled.  As  mentioned  in  the 
recommendation above, it is stated clearly at the water body level when objectives will 
be achieved. The justifications for the exemptions are applied on water body level but 
are not clearly described. 

  Recommendation:  It  is  unclear  whether  there  are  other  new  physical  modifications 
planned in RBMPs apart from those reported in the 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 

126 

 
all  possible  measures  are  taken  to  mitigate  the  adverse  impact  on  the  status  of  the 
water. All conditions for the application of Article 4(7) in individual  projects must be 
included and justified in the RBMPs as early in the project planning as possible 

Assessment:  Poland  has  assessed  the  application  of  projects  that  could  cause  an 
exemption under Article 4(7). A significant number of projects was reported to fulfil all 
the  requirements  as  outlined  in  Article  4(7).  Judging  the  fulfilment  of  this 
recommendation requires further assessment.  

  Recommendation:  Designate  artificial  and  HMWBs  and  justify  their  designation; 
develop  a  system  for  classifying  them  and  establish  a  coherent  and  comprehensive 
monitoring network to enable their classification; duly justify exemptions at the water-
body level. 

Assessment:  For  the  assessment  of  the  recommendation  as  regards  to  HMWBs  and 
Good ecological potential see chapter 7. As regards exemptions the justifications for the 
exemptions were provided at water body level but were not clearly described. Therefore 
this has been partially fulfilled. 

  Recommendation:  Improve  methodology  and  transparency  in  the  application  of 
exemptions  for  the  second  RBMP.  This  should  rely  on  strategic  planning  including 
adequate  assessment  of  better  environmental  options,  clear  defined  criteria  for  the 
application  of  "technical  unfeasibility",  "disproportionate  costs"  and  "natural 
conditions" 

Recommendation:  The  high  number  of  exemptions  applied  in  these  first  RBMPs  is  a 

cause for concern. 

Assessment:  These  recommendations  have  partly  been  implemented.  As  mentioned in 
the recommendation above, it is stated clearly at the water body level when objectives 
will be achieved. The justifications for the exemptions are provided at water body level 
but are not clearly described. Therefore this has been partially fulfilled. 

  Recommendation: Any new or maintenance work on the drainage of agricultural lands 
should  be  assessed  against  Article  4(7),  and  only  compliant  projects  should  be 
executed. 

127 

 
Assessment: See assessment above87. 

  Recommendation:  Provide  additional  objectives  for  special  protection  in  the  RBMPs 
for  protected  areas  and  report  information  on  the  status  of  drinking  water  protected 
areas associated with groundwater bodies. There is a lack of conservation action plans 
for Natura 2000 areas. 

Assessment:  No  information  was  found.  See  Chapter  15  for  the  assessment  on 
protected areas. 

87 Poland informed that when planning, constructing water drainage facilities and maintaining waters, the need to 
achieve  environmental  objectives  set  out  in  the  WFD  is  taken  into  account.  In  Poland,  water  maintenance 
plans have been developed to collect all the planned maintenance works, taking into account the needs of flood 
protection  and  the  need  to  achieve  environmental  objectives.  The  water  maintenance  plans  have  been 
subjected  to  the  procedure  of  strategic  environmental  assessment  together  with  public  consultations.  The 
maintenance works indicated in the water maintenance plans do not have, in principle, a negative impact on 
the water status. Projects that have a negative impact on the water status have been analysed in terms of the 
WFD requirements. The final list of projects fulfilling the requirements of Article 4(7) is in the RBMPs. 

128 

 
 
 
                                                      
Topic 9

  Programme of measures  

The aim of this chapter is to provide an overview of the PoM reported by Member States; more 
specific  information  on  measures  relating  to  specific  pressures  (for  example  arising  from 
agriculture) is provided in subsequent chapters. 

The  Key  Types  of  Measure  (KTM)  referred  to  in  this  section  are  groups  of  measures 
identified  by  Member  States  in  the  PoM,  which  target  the  same  pressure  or  purpose.  The 
individual  measures  included  in  the  PoM  (being  part  of  the  RBMP)  are  grouped  into  Key 
Types of Measure for the purpose of reporting. The same individual measure can be part of 
more than one Key Types of Measure because it may be multi-purpose, but also because the 
Key  Types  of  Measure  are  not  completely  independent  silos.  Key  Types  of  Measure  have 
been introduced to simplify the reporting of measures and to reduce the very large number of 
Supplementary  Measures  reported  by  some  Member  States  (WFD  Reporting  Guidance 
2016).  

A Key Types of Measure may be one national measure but it would typically comprise more 
than one national measure. The 25 predefined Key Types of Measure are listed in the WFD 
Reporting Guidance 2016. 

The  Key  Types  of  Measure  should  be  fully  implemented  and  made  operational  within  the 
RBMP planning period to address specific pressures or chemical substances and achieve the 
environmental objectives. 

9.1 

Assessment  of  implementation  and  compliance  with  WFD 
requirements in the second RBMPs 

9.1.1  General issues 

Poland has made significant progress in the implementation of the WFD in respect of the PoM, 
although there are still some areas where the implementation could be further strengthened. 

An  indication  of  whether  or  not  measures  have  been  made  operational  is  when  they  were 
reported as being planned to tackle significant pressures (KTM level). Significant pressures are 
also  reported  at  the  water  body  level.  It  would  be  expected  that  there  would  be  measures 
planned to tackle all significant pressures. The reported significant pressures are well covered 
with operational KTMs in place to reduce the pressures in both surface waters and groundwater 

129 

 
 
for the two main RBDs (Oder and Vistula) and for the remaining eight RBDs, for surface water 
only (no significant pressures were reported for groundwater).  

Poland has mapped 1 020 national basic measures against 15 of the 25 pre-defined KTMs. A 
further  390  national  basic  measures  have  been  mapped  against  nine  nationally  developed 
KTMs.  four  of  the  national  basic  measures  that  have  been  mapped  against  the  nationally 
defined KTM “measure to optimize water consumption’ apply in only two RBDs; the other 1 
406 national basic  measures apply in all  10 RBDs. 22%  of the national basic measures have 
been  mapped  against  KTM  21  -  ‘Measures  to  prevent  or  control  the  input  of  pollution  from 
urban  areas,  transport  and  built  infrastructure’.  Poland  has  also  mapped  122  national 
supplementary  measures  against  nine  of  the  predefined  KTMs  and  a  further  17  national 
supplementary  measures  against  four  nationally  defined  KTMs.  30%  of  the  national 
supplementary measures have been mapped against KTM 20 – ‘Measures to prevent or control 
the adverse impacts of fishing and other exploitation/removal of animal and plants’, 22% have 
been  mapped  against  KTM14  –“Research,  improvement  of  knowledge  base  reducing 
uncertainty’  and  17%  against  KTM6  –“Improving  hydromorphological  conditions  of  water 
bodies other than longitudinal continuity’. None of the basic measures were reported to address 
Article 11(3)(f): Controls, including a requirement for prior authorisation of artificial recharge 
or augmentation of groundwater bodies88, but all of the other Article 11(3) requirements appear 
to  have  been  addressed  by  basic  national  measures.  An  inventory  of  national  measures  has 
been reported with links to where further information can be found. 

Generally,  fewer  types  of  KTM  were  reported  to  be  operational  to  address  significant 
pressures,  than  were  reported  to  have  national  measures  mapped  against  them.  This  implies 
that some of the national measures that were reported are not operational. The exception to this 
is  the  Ucker  RBD,  where  all  mapped  KTMs  are  used  to  tackle  significant  pressures.  For 
example:  in  the  Danube  RBD  the  number  of  KTMs  reported  to  be  tackling  significant 
pressures  for  the  Danube  is  two,  as  opposed  to  24  KTMs  that  have  had  national  measures 
mapped  against  them;  for  the  Vistula  and  Oder  RBDs  the  13  KTMs  were  reported  to  be 
tackling significant pressures, whilst 28 have had national measures mapped against them89.  

In  eight  RBDs  water  bodies  affected  by  significant  pressures  are  expected  to  achieve  good 
status  or  potential  by  2027  while  in  the  Vistula and  Oder,  up  to  10%  of  groundwater  bodies 
and  surface  water  bodies  are  not  expected  to  achieve  good  status  due  to  various  significant 

88 Poland clarified that there was one national measure to address Article 11(3)(f). 
89 Poland clarified that there are 24 KTMs assigned to the Danube RBD (23 basic measures and 4 supplementary 
ones).  For  the Vistula and  Oder  RBDs  there were 28 KTMs  assigned  to  each of  those  two  RBDs  (24 basic 
measures and 13 supplementary ones). According to the reporting schema more than one measure could have 
been assigned to one KTM. 

130 

 
                                                      
pressures.  In  addition,  in  the  Oder  RBD  between  10-20%  of  groundwater  bodies  are  not 
expected to achieve good status due to alteration of water level or volume and mining. 

The  substances  causing  failure  of  WFD  objectives  in  groundwater  together  with  the  KTMs 
being  used  in  the  second  RBMPs  to  address  these  failures  were  reported  for  the  Vistula  and 
Oder  RBDs  only.  All  River  Basin  Specific  Pollutants  identified  as  causing  a  failure  of  good 
ecological  status  or  potential  substances  in  groundwater  have  at  least  one  associated  KTM, 
usually more. No information for the River Basin Specific Pollutants causing failure of good 
status  in  surface  water  bodies  was  reported  in  any  of  the  RBDs,  although  KTMs  to  address 
River  Basin  Specific  Pollutants  were  reported  for  the  Vistula  and  Oder  RBDs.  The  Annex  0 
provided  by  Poland  states  “In  accordance  with  reporting  criteria,  for  surface  water  bodies 
failing to achieve good ecological status due to the exceedance of specific pollutant substances 
(group  3.6),  the  substances  causing  status  reduction  should  be  indicated.  The  water  status 
assessment  in  the  2010-2012  year  period  does  not  contain  information  on  the  substances 
causing  status  reduction  for  water  bodies  failing  to  achieve  good  ecological  status,  assessed 
with  the  grouping  method  (grouping  only  concerns  overall  assessments  not  particular 
substances)’. 

Information  on  the  Priority  Substances  causing water  bodies  to  fail  to  be  of  good  status  was 
provided for seven of the RBDs (Vistula, Jarft, Elbe, Oder, Pregolya, Nemunas and Dniester). 
However,  KTMs  to  address  these  substances  were  reported  for  the  Vistula,  Jarft,  Elbe  and 
Oder RBDs only.  

Information  on  indicators  of  the  gaps  to  good  status  to  be  addressed  by  the  KTMs  was 
generally  well  reported.  Poland  reported  indicators  of  the  gaps  to  good  status  for  significant 
pressures on groundwater and surface water for 2015 and 2021 and 2027 for the Vistula and 
Oder  RBDs.  The  gaps  to  good  status  were  reported  for  surface  waters  only  for  the  Danube, 
Swieza, Jarft, Elbe, Pregoya, Nemunas and Dniester RBDs. Generally the gap to good status 
decreases from 2015 to  2027 with  good status mostly  expected to  be achieved  by 2021 with 
some exceptions. For the Danube, Swieza, Jarft and Elbe RBDs good status is expected to be 
achieved  for  all  significant  pressures  by  2021.  For  the  Nemunas  and  Dniester  RBDs,  good 
status  is  expected  to  be  achieved  by  2027.  For  the  Vistula,  Oder  and  Pregoya  RBDs  good 
status  is  not  expected  to  be  achieved  for  all  significant  pressures  by  2027.  For  example,  all 
groundwater bodies affected by point sources from waste disposal sites in the Vistula RBD are 
expected to achieve good status by 2021, but for those affected by diffuse agricultural pollution 
will  not  be  expected  to  be  achieved  by  2027.  In  the  Vistula  RBD,  good  status  will  not  be 
expected  to  be  achieved  by  2027,  but  the  gap  to  good  status  is  expected  to  reduce  for  four 
significant  pressures in groundwater (Diffuse  –  Agricultural;  Hydrological alteration  - Public 

131 

 
water  supply;  Groundwater  -  Alteration  of  water  level  or  volume;  and  Nitrate)  and  for  six 
significant pressures to surface waters (Point – Aquaculture; Diffuse – Agricultural; Diffuse - 
Discharges  not  connected  to  sewerage  network;  Diffuse  –  Mining;  Hydromorphological 
alteration – Other; and Anthropogenic pressure – Other). No progress is expected at all from 
2015  in  addressing  significant  pressures  from  mining  on  surface  waters  in  the  Vistula  RBD, 
and from Hydrological alteration - Public water supply, nickel and its compounds, ammonium 
and nitrogen in groundwater in the Oder RBD. 

Cost-effectiveness  analysis  is  an  appraisal  technique  that  provides  a  ranking  of  alternative 
measures  on  the  basis  of  their  costs  and  effectiveness,  where  the  most  cost-effective  has  the 
highest  ranking.  Cost  effectiveness analysis  was  not  undertaken  for the  first  PoM  but  for  the 
second PoM it was reported that a quantitative cost-effectiveness analysis has been carried out 
in all 10 RBDs for supporting the selection of measures proposed under the 2015-2021 PoM. 
This was followed-up as part of this assessment but no direct information could be found as to 
how the cost effectiveness analysis contributed to the prioritisation of the measures. From the 
information  provided  it  appears  that  there  has  been  some  prioritisation  of  measures  for  the 
second PoM but it is not clear how this has been carried out90. 

A critical factor in the success of the implementation of the PoM is the availability of funding 
to  support  the  investments  required.  For  the  first  PoM  (2009-2015),  Poland  reports  to  have 
invested  a  total  (reported  at  national  level  only)  of  €10 780  million  on  Article  11(3)(a) 
requirements  (measures  required  to  implement  Community  legislation  for  the  protection  of 
water)  and  €37.39  million  on  Articles  11(3)(b-l),  11(4)  and  11(5)  requirements  (all  other 
measures). A total investment of €10.958 million was reported for all measures. These figures 
are inconsistent with each other. For the second PoM (2015-2021) capital investments required 
for Article 11(3)(a) requirements (measures required to implement Community legislation for 
the protection of water) are given for six of the RBDs (Danube, Vistula, Elbe, Oder, Pregolya 
and Nemunas), zero for the remaining four RBDs (one of these, the Ucker RBD is not relevant 
as there are no SWBs and no significant pressure on share of GWB – see above and explained 
in Annex 0). No annual operational and maintenance costs were reported for Article 11(3)(a). 
Capital investment and annual costs for Articles 11(3)(b-l), 11(4) and 11(5) requirements are 
also  presented,  except  for  two  RBDs  at  zero  including  Ucker  which  is  not  relevant,  but  a 
modest amount  of annual costs are expected in both  of these. The reporting of the European 
Union  funding  received  was  not  particularly  clear  for  the  first  PoM.  From  the  information 
reported it is assumed that a total of €8 663 million of European Union funds was received for 

90 Poland clarified that the selection was based on efficiency of measures and feasibility of implementation, with 
details  provided  in  the  background  document  on  update  of  the  PoM  (update  of  the  ‘Program  wodno-
środowiskowykraju’) 

132 

 
                                                      
eight  of  the  10  RBDs,  and  €0.03  million  for  the  remaining  two  RBDs.  For  the  second  PoM 
expected European Union funding figures are given separately for all 10 RBDs.  

Poland reported that clear financial commitments have been secured for PoM in all 10 RBDs in 
Poland and for all relevant sectors. Transport, energy, aquaculture and recreation were reported 
to be not relevant in any of the 10 RBDs in Poland, but it should be noted that up to 10% of 
surface  water  bodies  in  the  Vistula  and  Oder  RBDs  are  not  expected  to  achieve  good 
status/potential by 2027 due to pressures from the aquaculture sector. 

It  was  reported  that  there  was  no  joint  consultation  carried  out  on  the  RBMPs  and  Marine 
Strategy in Poland. However the preparation of the RBMP and PoM has been reported to be 
co-ordinated with the implementation of the Marine Strategy Framework Directive.91 

The RBMPs and Floods Directive92 Flood Risk Management Plans were not integrated into a 
single RBMP in Poland, but closely co-ordinated, i.e. joint consultation was carried out on the 
RBMPs and Flood Risk Management Plans, and the objectives and requirements of the Floods 
Directive  were  considered  in  the  second  RBMPs  and  PoM  in  all  10  RBDs.  Poland  indicated 
that  specific  win-win  measures  in  terms  of  achieving  the  objectives  of  the  WFD  and  Floods 
Directive,  drought  management  and  use  of  Natural  Water  Retention  Measures  have  been 
included in the PoM in all 10 RBDs. The design of new and existing structural measures, such 
as flood defences, storage dams and tidal barriers, have been adapted to take into account WFD 
environmental  objectives  and  clear  financial  commitments  have  been  secured  for  the 
implementation of the PoM in the flood protection sector in all 10 RBDs. Article 9(4) has been 
applied to impoundments for flood protection in Poland in all RBDs93. 

9.1.2  Measures related to other significant pressures 

Other significant pressures in Poland were reported as “˜anthropogenic – other’ or “unknown’ 
or “historic pollution’. Information has been reported for surface water bodies only, except for 
the Oder and  Vistula RBDs  where  information  is  also provided for groundwater bodies. The 
indicators  of the gap  to  good status for each other  significant  pressures and the indicators of 
progress expected from the corresponding KTMs were reported for 2015, 2021 and 2027 with 

91  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 

92  Directive 2007/60/EC on the assessment and management of flood risks entered into force on 26 November 

2007http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32007L0060 

93  Poland  clarified  that  “the  environmental  analysis  of  projects  and  activities  carried  out  for  the  needs  of  the 
FRMP  is  directly  reflected  in  the  process  of  the  RBMPs  update.  In  addition,  the  planned  non-technical 
measures (for example, renaturalisation of riverbanks) complement measures planned in the RBMPs in terms 
of achieving the objectives of the WFD” 

133 

 
                                                      
improvements  in  status  expected  from  2015  to  2027  with  most  water  bodies  expected  to 
achieve good status by 2021, and the remainder by 2027. 

9.1.3  Mapping of national measures to Key Types of Measure 

It  was  expected  that  Member  States  would  be  able  to  report  their  PoM  by  associating  their 
national  measures  with  predefined  KTMs.  KTM  are  expected  to  deliver  the  bulk  of  the 
improvements  through  reduction  in  pressures  required  to  achieve  WFD  Environmental 
Objectives.  A  Key  Type  of  Measure  may  be  one  national  measure  but  it  would  typically 
comprise more than one national measure. Member States are required to report on the national 
measures  associated  with  the  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 Poland. Also shown is the number of RBDs for which the KTM has been reported. 
Table  9.2 then  summarises  the  type  of  basic  measures  associated  with the  national  measures 
mapped against the KTM. 

Table 9.1 

Mapping of the types of national measures to Key Types of Measure in Poland 

National 
basic 
measures 

National 
supplementary 
measures 

Number of 
RBDs where 
reported 

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 

KTM13 - Drinking water protection measures (e.g. 
establishment of safeguard zones, buffer zones etc.) 

KTM14 - Research, improvement of knowledge base reducing 
uncertainty 

KTM15 - Measures for the phasing-out of emissions, 
discharges and losses of Priority Hazardous Substances or for 
the reduction of emissions, discharges and losses of Priority 
Substances 

KTM19 - Measures to prevent or control the adverse impacts 
of recreation including angling 

KTM2 - Reduce nutrient pollution from agriculture 

KTM20 - Measures to prevent or control the adverse impacts 
of fishing and other exploitation/removal of animal and plants 

36 

10 

61 

82 

30 

104 

170 

KTM21 - Measures to prevent or control the input of pollution 
from urban areas, transport and built infrastructure 

307 

134 

10 

10 

10 

10 

10 

10 

10 

10 

10 

31 

5 

5 

42 

3 

 
 
 
 
 
 
Key Type of Measure 

National 
basic 
measures 

National 
supplementary 
measures 

Number of 
RBDs where 
reported 

KTM25 - Measures to counteract acidification 

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 services from households 

KTM99 - Other key type measure reported under PoM - 
Administrative 

KTM99 - Other key type measure reported under PoM - 
Conservation of Natura 2000 

KTM99 - Other key type measure reported under PoM - 
Education measure 

KTM99 - Other key type measure reported under PoM - 
International coordination 

KTM99 - Other key type measure reported under PoM - 
measure in river water bodies limiting significant pressure on 
lake water body 

KTM99 - Other key type measure reported under PoM - 
Measure on national level limiting significant pressure on 
surface water body 

KTM99 - Other key type measure reported under PoM - 
Measure to optimize water consumption 

KTM99 - Other key type measure reported under PoM - 
Measures to specify conditions of water use 

KTM99 - Other key type measure reported under PoM - 
Obtaining permit 

KTM99 - Other key type measure reported under PoM - 
Prevention of major accidents 

KTM99 - Other key type measure reported under PoM - 
Spatial planning 

10 

80 

20 

26 

50 

24 

10 

36 

160 

40 

10 

4 

10 

30 

90 

10 

3 

6 

23 

4 

6 

3 

3 

5 

Total number of Mapped Measures 

1410 

139 

Source: Member States reports to WISE 

135 

10 

10 

2 

10 

10 

10 

10 

10 

10 

10 

10 

10 

3 

3 

2 

10 

10 

10 

10 

10 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 9.2 

Type of basic measure mapped to Key Type of Measures in Poland 

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 
KTM13 - Drinking water protection measures (e.g. establishment of 
safeguard zones, buffer zones etc.) 
KTM14 - Research, improvement of knowledge base reducing 
uncertainty 
KTM15 - Measures for the phasing-out of emissions, discharges and 
losses of Priority Hazardous Substances or for the reduction of 
emissions, discharges and losses of Priority Substances 
KTM19 - Measures to prevent or control the adverse impacts of 
recreation including angling 
KTM2 - Reduce nutrient pollution from agriculture 
KTM21 - Measures to prevent or control the input of pollution from 
urban areas, transport and built infrastructure 
KTM25 - Measures to counteract acidification 

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 

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136 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Key 

‘Accidental pollution’ = Article 11(3)(l): Any measures required to prevent significant losses of pollutants from technical installations and to prevent and/or reduce the impact of 
accidental pollution incidents. 
‘Controls water abstraction’ = Article 11(3)(e): Controls over the abstraction of fresh surface water and groundwater and impoundment of fresh surface waters including a register or 
registers of water abstractions and a requirement for prior authorisation of abstraction and impoundment. 
‘Cost recovery water services’ = Article 11(3)(b): Measures for the recovery of cost of water services (Article 9). 
‘Efficient water use’ = Article 11(3)(c): Measures to promote efficient and sustainable water use. 
‘Habitats or Birds’ = Habitats Directive (92/43/EEC)  or Birds Directive (2009/147/EC)  
‘Hydromorphology’ = Article 11(3)(i): Measures to control any other significant adverse impact on the status of water, and in particular hydromorphological impacts. 
‘IPPC IED’ = Integrated Pollution Prevention Control Directive (96/61/EC) and the Industrial Emissions Directive (2010/75/EU). 
‘Nitrates’ = Nitrates Directive (91/676/EEC). 
‘Other’ = Other Directives mentioned in Part A of Annex VI of the WFD. 
‘Point source discharges’ = Article 11(3)(g): Requirement for prior regulation of point source discharges liable to cause pollution. 
‘Pollutants diffuse’ = Article 11(3)(h): Measures to prevent or control the input of pollutants from diffuse sources liable to cause pollution. 
‘Pollutants direct groundwater’ = Article 11(3)(j): Prohibition of direct discharge of pollutants into groundwater. 
‘Protection water abstraction’ = Article 11(3)(d): Measures for the protection of water abstracted for drinking water (Article 7) including those to reduce the level of purification 
required for the production of drinking water. 
‘Recharge augmentation groundwaters’ = Article 11(3)(f): Controls, including a requirement for prior authorisation of artificial recharge or augmentation of groundwater bodies. 
‘Surface Priority Substances’ = Article 11(3)(k): Measures to eliminate pollution of surface waters by Priority Substances and to reduce pollution from other substances that would 
otherwise prevent the achievement of the objectives laid down in Article 4. 
‘Urban Waste Water’ = Urban Waste Water Treatment Directive (91/271/EEC). 

137 

 
 
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. 

The  information  reported  in  WISE  on  the  gaps  to  fulfil  to  achieve  good  ecological  status 
include detailed data on the significant pressures on surface and groundwaters that may cause 
failure on the environmental objectives.  For chemical status, the Member  States  reported the 
specific chemical substances causing failure. 

This information is reported at the sub-unit level. Sub-units are smaller geographic areas within 
particular  RBDs  identified  by  Member  States.  Not  all  Member  States  have  defined  and 
reported sub-units. 

Member States were required to report which KTMs are to be made operational to reduce the 
gaps to levels compatible with the achievement of WFD environmental objectives. A number 
of  indicators  were  predefined  for  each  KTM.  Values  of  the  indicators  for  the  second  and 
subsequent  planning  cycles  were  also  to  be  reported  to  give  an  indication  of  the  expected 
progress and achievements: the values for 2027 could be optionally reported. This means that 
the value of the indicator will be reduced with time as measures are implemented. A value of 
zero is comparable with 100 % good ecological status or potential or good chemical status.  

This  information  was  reported  at  sub-unit  level,  or  at  RBDs  level  if  sub-units  have  not  been 
reported by the Member State. 

9.2  Main  changes  in  implementation  and  compliance  since  the 

first RBMPs 

In general, the amount and quality of readily available information improved between the two 
reporting cycles because of the revised reporting requirements. Often there was no equivalent 
information  for  the  first  RBMPs  and  it  was  difficult,  therefore,  to  make  direct  comparisons 

138 

 
 
 
between the second RBMPs on what has changed significantly. However, information on links 
between  pressures  and  measures  were  provided  in  the  second  cycle  where  this  was  not 
available  in  the  first  RBMPs.  It  was  not  clear  for  the  first  PoM  how  measures  had  been 
selected,  but  for  the  second  RBMPs  it  was  reported  that  a  quantitative  cost  effectiveness 
analysis  was  carried  out  for  supporting  the  selection  of  measures.  However,  it  was  not  clear 
how this, or other analyses, were combined for the prioritisation of measures. Information was 
reported  for  the  second  RBMPs  on  the  scale  and  progress  with  implementation  of  measures 
with the majority of measures leading to the achievement of WFD objectives by 2027. Poland 
did not provide an explicit summary of the changes made between cycles for this topic94. 

9.3 

Progress with Commission recommendations 

The Commission recommendations based on the first RBMPs and first PoM requested action 
on the following: 

  Recommendation:  Where 

there  are  currently  high  uncertainties 

the 
characterisation of the RBDs, identification of pressures, and assessment of status, 
these need to be addressed in the current RBMPs, to ensure that adequate measures 
can be put in place before the next RBMPs.  

in 

Assessment:  Information  on  the  significant  pressures  and  how  they  are  linked  to 
KTMs  was  reported  to  WISE  –  this  information  was  not  available  for  the  first 
RBMPs. The issues of uncertainty in the characterisation and assessment of status 
have been assessed under Topics 2, 3 and 4. As far as it can be ascertained for this 
topic, this recommendation has been fulfilled. 

  Recommendation:  Quantitatively  apportion  the  contribution  each  pressure  is 
making  to  the  failure  of  WFD  objectives  at  the  RBD,  sub-basin  and  water  body 
level so that cost-effective measures can be developed and implemented.  

Assessment: Poland reported the results of an analysis of the gap to good status in 
nine of the 10 RBDs (the Ucker RBD is not relevant). Indicators were reported for 
significant pressures for 2015, 2021 and 2027, with most water bodies expecting to 
have  achieved  good  status  by  2027.  Poland  has  identified  those  significant 

94  Poland  clarified  that  it  had  “summarised  the  evaluation  of  implementation  of  the  PoM  included  in  the  first 
RBMPs.  It  is  presented  in  the  background  document  on  the  Review  and  update  of  PoM  (‘Program  wodno-
środowiskowykraju’)”.  This  shows  that  the  final  selection  of  measures  from  the  point  of  view  of  achieving 
environmental  objectives  and  costs  was  possible  after  analysing  the  effectiveness  and  feasibility  of  the 
indicated sets of measures, and then its optimisation and conducting the cost-effectiveness analysis. 

139 

 
                                                      
 
pressures  where  progress  cannot be made,  or  where, although significant  progress 
will be made, full compliance is not expected to be achieved by 2027. Poland has 
reported that a quantitative cost effectiveness analysis has been carried out, but it is 
not  clear  from  the  information  available  how  this  has  been  used  to  prioritise 
measures,  nor  how  other  analyses  have  contributed  to  the  prioritisation.  Poland 
clarified  that  it  “has  summarised  the  evaluation  of  implementation  of  the  PoM 
included  in  the  first  RBMPs.  It  is  presented  in  the  background  document  on  the 
Review  and  update  of  PoM  (‘Program  wodno-środowiskowykraju’).”  This  shows 
that  the  final  selection  of  measures  from  the  point  of  view  of  achieving 
environmental  objectives  and  costs  was  possible  after  analysing  the  effectiveness 
and  feasibility  of  the  indicated  sets  of  measures,  and  then  its  optimisation  and 
conducting  the  cost-effectiveness  analysis.  With  this  clarification  it  can  be 
determined that this recommendation has been fully fulfilled.  

  Recommendation:  Make  clearer  the  basis  for  the  selection  of  the  measures  and 
whether  a  cost-effectiveness  analysis  of  measures  (Article  5  and  Annex  III  WFD) 
has  been  carried  out.  There  is  often  a  lack  of  information  on  identification  of 
pressures and their sources, on how measures were selected and on links between 
pressures/uses and measures. 

Assessment:  Poland  reported  that  a  quantitative  cost-effectiveness  analysis  was 
carried out in all 10 RBDs for supporting the selection of measures proposed under 
the 2015-2021 PoM. There is information on links between pressures and measures 
but  not  on  identification  of  pressures  and  their  sources  and  how  measures  were 
selected.  No  clear  information  could  be  found  in  the  RBMP  or  background 
documents  on  how  cost  effectiveness  analyses,  or  other  analyses  carried  out  had 
been used for the prioritisation of measures. Poland clarified that the selection was 
based  on  efficiency  of  measures  and  feasibility  of  implementation,  with  details 
provided  in  the  background  document  on  update  of  the  PoM  (update  of  the 
‘Program  wodno-środowiskowykraju’.  The 
final  selection  of  basic  and 
supplementary  measures  was  done  upon  assessment  of  their  efficiency  and 
possibility  to  be  implemented.  Additionally  cost-effectiveness  analysis  has  been 
undertaken  for  proposed  measures  of  both  kinds.  This  recommendation  has  been 
partially fulfilled, because although the method of prioritisation is now clearer, the 
linkage of pressures and sources is still not clear. 

140 

 
  Recommendation:  Provide  in  the  second  RBMPs  information  about  monitoring  of 
progress  on  the  implementation  of  the  current  Programme  of  Measures,  and  the 
assessment of its effectiveness. 

Assessment:  Progress  has  been  made.  Information  on  indicators  of  gaps  to  good 
status and the expected implementation of KTMs were well reported. Generally the 
status  of  water  bodies  was  expected  to  improve  from  2015  to  2027  with  most 
expected to have achieved good status by 2021 or 2027 with some exceptions. This 
recommendation has been fulfilled.  

  Recommendation: Meaningful information regarding the scope, the timing and the 
funding of the measures should be included in the Programme of Measures so that 
the approach to achieve the objectives is clear and the ambition in the Programme 
of  Measures 
information  on  basic  and 
supplementary measures should be included in the summary of the Programme of 
Measures to ensure transparency of the planned actions for the achievement of the 
environmental objectives set out in the WFD. 

transparent.  All 

the  relevant 

is 

Assessment: Information regarding timing and funding of basic and supplementary 
measures  were  generally  provided,  although  there  was  some  variation  between 
RBDs. It was reported that clear financial commitments have been secured for the 
PoM  in  all  10  RBDs  in  Poland.  This  includes  all  sectors:  agriculture,  industry, 
urban,  hydropower  and  flood  protection.  Transport,  energy,  aquaculture  and 
recreation  were  reported  to  be  not  relevant,  although  it  should  be  noted  that 
aquaculture has been identified as causing a failure of good status in surface water 
bodies in some RBDs. Indicators of the progress expected in the implementation of 
the KTMs have been provided. This recommendation has been fulfilled. 

  Recommendation:  Provide  more  information  concerning  the  identification  of 
pressures, selection of measures and a commitment to indicating the links between 
the pressures and measures in the second RBMPs. 

Assessment:  Information  is  provided  on  the  links  between  the  pressures  and 
measures in the second RBMPs although no information is provided on how these 
measures  were  selected  (such  as:  the  actual  criteria  or  thresholds  used  to  define 
significance;  the  basis  of  methods  for  assessing  pressures;  how  pressures  arising 
from  flow  and  morphological  alterations  were  quantified,  and;  the  approach  for 
selection of measures). This recommendation has been partially fulfilled. 

141 

 
  Recommendation: More information should be provided regarding the Programme 
of  Measures.  In  particular  there  is  a  need  for  a  clear  link  between  pressures  and 
measures,  a  clear  identification  of  the  costs  of  measures,  who  is  responsible  for 
their implementation and on how their effectiveness will be monitored. More effort 
should  be  put  into  identifying  and  linking  the  whole  RBMPs  of  the  planning 
process, in particular regarding the monitoring network.  

Assessment:  A  quantitative  cost-effectiveness  analysis  was  carried  out  and 
measures  were  identified  for  specific  water  bodies.  There  was  a  link  between 
pressures  and  measures.  No  information  was  provided  on  impacts  in  relation  to 
apportionment of pressures between sources and sectors and whether measures are 
focused  on  sectors  contributing  the  most  pressures  or  for  which  measures  were 
considered  to  be  most  effective.  Also  no  information  was  provided  on  any 
voluntary  measures.  Information  on  who  is  responsible  for  implementation  of 
measures  and  on their financing has been  provided. No information  was provided 
for  the  part  of  this  recommendation  relating  to  the  monitoring  network.  For  this 
topic, this recommendation has been partially fulfilled. 

  Recommendation:  The  adopted  measures  in  the  Programme  of  Measures  are  not 
based on the status assessment of water bodies. This is the result of the absence of 
fully developed status assessment methods and classification systems in Poland at 
the time of publication of the RBMPs. 

Assessment: The number of water bodies failing to be of good status was reported 
against  significant  pressures,  and  the  KTMs  that  are  operational  to  address  those 
pressures were also reported. Clear indicators of the level of progress to be achieved 
in both the gap to good status, and the level of implementation of the measures are 
in  place  and  were  reported.  An  assessment  of  the  assessment  methods  and 
classification  systems  is  addressed  by  topics  2,  3  and  4.  As  far  as  this  topic  is 
concerned, this recommendation has been fulfilled.  

  Recommendation: Carry out  the quantitative assessment to assess  the gap for  all, 
not just some measures (e.g. the National Implementation Programme). The extent 
of  measures  should  be  clear  from  the  Programme  of  Measures  and  how/by  when 
the status of water bodies will be good. 

Assessment: The number of water bodies failing to be of good status was reported 
against  significant  pressures,  and  the  KTMs  that  are  operational  to  address  those 

142 

 
pressures were also reported. Clear indicators of the level of progress to be achieved 
in both the gap to good status, and the level of implementation of the measures are 
in place and were reported, together with the dates by which good status is expected 
to be achieved. Those significant pressures that cannot be fully addressed by 2027 
were  clearly  identified,  together  with  the  number  of  water  bodies  expected  to  be 
affected. This recommendation has been fulfilled. 

  Recommendation:  It  is  not  clear  whether  Poland  is  planning  to  include  the  cost-
effectiveness  analysis  in  this  RBMP  update  or  how  it  plans  to  assess  whether 
pressures were tackled effectively.  

Assessment: Poland reported that a quantitative cost-effectiveness analysis has been 
carried out in all 10 RBDs for supporting the selection of measures proposed under 
the 2015-2021 PoM. However, no details were provided of how this had been used 
in  the  selection  of  measures7.  This  recommendation  has  therefore  been  partially 
fulfilled. 

143 

 
 
 
Topic 10

  Measures related to abstractions and water scarcity  

10.1  Assessment  of 

implementation  and  compliance  with  WFD 

requirements in second RBMPs 

10.1.1  Water exploitation and trends  

Water  abstraction  pressures  were  not  reported  to  be  relevant  for  Poland.  To  put  this  into 
context, as stated in Chapter 5, in total 13 groundwater bodies (7%) were at risk of failing good 
quantitative status and they were located in the Vistula RBD and the Oder RBD. Of these, 10 
groundwater  bodies  were  at  risk  of  failing  good  quantitative  status  due  to  failing  the  water 
balance  test.  Therefore,  whilst  abstraction  pressures  may  not  be  considered  relevant,  there  is 
some evidence to suggest that there are a fairly small number of circumstances where the long-
term annual average rate of abstraction exceeds the available groundwater resource which may 
result  in  a  decrease  of  groundwater  levels.  The  Water  Exploitation  Index  +  has  not  been 
calculated,  and  no  water  quantity  data  were  reported  to  support  the  European  State  of  the 
Environment  Report  in  relation  to  Water  Quantity.  The  RBMPs  do  not  include  a  water 
resource allocation and management plan.  

10.1.2  Main uses for water consumption  

Regarding  water  consumption,  no  information  on  abstractions  from  sectors  was  provided  as 
this was either not relevant or not available.  

10.1.3  Measures related to abstractions and water scarcity  

Regarding  basic  measures  (Article  11(3)(e)),  there  is  a  concession,  authorisation  and/or 
permitting  regime  to  control  surface  and  groundwater  and  a  register  of  surface  and 
groundwater use (but not for water impoundment); and small abstractions are exempted from 
these controls.  

Measures on Article 11(3)(c) for sustainable and efficient water use have been implemented in 
the  previous  RBMPs,  and  no  new  measures  and/or  significant  changes  are  reported  to  be 
planned for the 2016-2021 period.  

Measures  for  the  prior  authorisation  of  artificial  recharge  or  augmentation  of  groundwater 
bodies (Article 11(3)(f)) were implemented in the first RBMPs, and no new measures and/or 
significant changes are reported to be planned for the 2016-2021 period. 

144 

 
Complementary measures under KTMs were reported for addressing abstraction pressures, and 
include KTM 8 - ‘Water efficiency, technical measures for irrigation, industry, energy and 
households’. 

Water reuse was also foreseen as a measure. 

10.2  Main changes in implementation and compliance since first 

RBMPs 

No changes have been identified regarding water scarcity and abstraction pressures.  

10.3  Progress with Commission recommendations 

There were no Commission recommendations based on the first RBMPs and first PoM for this 
topic. 

145 

 
 
 
 
Topic 11

  Measures related to pollution from agriculture  

11.1  Assessment  of 

implementation  and  compliance  with  WFD 

requirements in second RBMPs 

In the first RBMPs, agriculture was indicated as a significant pressure on the water resource in 
all 10 RBDs. In the second RBMPs, agriculture was only reported as a significant pressure in 
the Vistula RBD (groundwater and surface waters), the Swieza RBD (surface waters), the Oder 
RBD (surface waters and groundwater), the Pregolya RBD (surface waters), and the Nemunas 
RBD (surface waters)95.  

The  main  pressures  for  groundwater  were  reported  to  be  chemical,  microbiological  and 
nutrient  pollution,  as  well  as  diminution  of  the  quality  of  associated  surface  waters  for 
chemical or quantitative reasons. In the Oder RBD saline intrusion was reported. For surface 
waters  acidification  was  reported  in  the  Vistula  and  Pregolya  RBDs,  chemical  pollution  and 
altered habitats in the Vistula, Oder and Pregolya RBDs, nutrient and organic pollution in the 
Vistula, Swieza, Oder, Pregolya and Nemunas RBDs, saline intrusion in the Vistula and Oder 
RBDs. KTMs related to agriculture were applied in all RBDs. KTM12 - Advisory services for 
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  (basic  and  supplementary)  KTM23  -  Natural  water  retention  measures  and  KTM3  - 
Reduce pesticides pollution from agriculture were applied in all RBDs. It was stated that these 
measures  have  already  been  implemented  in  the  first  RBMPs.  A  gap  assessment  was  not 
carried  out  specifically  for  agricultural  measures  and  it  remains  unclear  how  measures  are 
contributing to close the gap. 

Implementation  of  basic  measures  (the  minimum  requirement  to  be  complied  with)  under 
Article  11(3)(h)  for  the  control  of  diffuse  pollution  from  agriculture  at  source  have  been 
applied  in  all  RBDs.  In  the  Vistula  and  Oder  RBDs  the  rules  were  applied  only  in  Nitrate 
Vulnerable  Zones.  In  all  other  RBDs  the  same  rules  were  applied  across  the  whole  RBD. 
General  binding  rules  to control diffuse nitrate pollution  from agriculture were  applied in all 
RBDs.  

95 Poland subsequently clarified that there is no surface waterbody established in the Ucker RBD, hence there is 
no  monitoring  conducted,  no  pressure  on  surface  water  identified,  no  environmental  objectives,  and  no 
derogations established, etc. However, a part of the groundwater body coded as PLGW6003 is located in the 
Ucker RBD. 

146 

 
                                                      
It was also stated in the RBMP that the use of fertilisers is prohibited within Nitrate Vulnerable 
Zones on soils flooded with water, covered with snow, frozen to a depth of 30 centimetres or 
during  rainfall;  natural  fertilizers  in  liquid  and  nitrogen  form  -  on  soils  without  vegetation 
where slopes exceed 10%; fertilizers in liquid form - during cultivation of plants intended for 
direct  human  consumption.  Prohibition  of  using  agro-aviation  equipment  under  the  indicated 
climatic conditions and at a distance of 500 metres from watercourses and water reservoirs was 
also identified. In addition, the prohibition of the use of fertilizers at a specific distance from 
lakes, water reservoirs with the indicated area, watercourses, ditches, canals, water protection 
zones and areas of the coastal strip is also reported to be in place. 

There were other additional control measures reported that would contribute to prevention of 
nitrogen, phosphorus and pesticides entering drinking water sources such as:  

  prohibition of the use of animal fertilizers in the period from first of December to the 

end of February;  

  development  of  a  set  of  principles  of  good  agricultural  practice  (including  changes 

taking place in the agricultural sector);  

  development  of  a  PoM  for  each  designated  area  particularly  vulnerable  to  pollution 

with nitrogen compounds from agricultural sources;  

  determination  of  waters  sensitive  to  pollution  with  nitrogen  compounds  from 
agricultural sources and especially vulnerable areas, from which the outflow of nitrogen 
to sensitive waters should be limited; 

  provision of adequate storage facilities for natural liquid fertilizers limiting the amount 
of  animal  fertilizers  used  during  the  year  -  it  cannot  contain  more  than  170 
kilogrammes nitrogen in the pure component per hectare of agricultural land; 

  control  of  nitrate  concentrations  in  waters  sensitive  to  pollution  with  nitrogen 

compounds from agricultural sources; and 

  assessment of water eutrophication. 

Drinking  water  safeguard  zones  have  been  established  for  water  bodies  from  which  water  is 
abstracted for human consumption96.  

96 Poland subsequently clarified that according to Article 54 of the Act of 18 July 2001 - Water Law (valid at the 
date of preparation of the 2nd RBMP), the use of fertilizers and pesticides may be prohibited or limited on the 

147 

 
                                                      
It was stated in  the PoM document that  specific measures have  been  identified for the water 
body in which these zones are located. No further details were given in supporting documents 
in  relation  to  safeguard  zones.  It  was  stated  (in  the  PoM  document)  that,  as  part  of  good 
agricultural practices, it is also recommended to undertake measures aimed at natural sorption 
and  accumulation  of  nitrates  and  phosphates  introduced  into  circulation  through  natural 
ecosystems.    Buffer  zones  (in  the  form  of  rushes,  willows  or  extensively  used  meadows) 
present between agricultural areas and water ecosystems contribute to the reduction of surface 
runoff,  as  well  as  significantly  limiting  or  even  eliminating  the  inflow  of  fertilizers  to  the 
groundwater.  These  measures  are  not  directly  regulated  by  law,  but  they  are  an  important 
recommendation  from  the  standpoint  of  the  need  to  protect  water  resources.  Buffer  zones 
prevent the flow of nutrients as well as contributing to the preservation of biodiversity. Both 
the establishment and maintenance of buffer zones, as well as soil liming, are indicated in the 
national  PoM  and  constitute  important  measures  contributing  to  the  achievement  of 
environmental objectives. 

Farmers and Farmers' Unions have been consulted under the public consultation process in all 
RBDs.  

Financing of measures has been secured in all of the RBDs.  

11.2  Main changes in implementation and compliance since first RBMPs 

In  the  first  RBMPs  agriculture  was  identified  as  exerting  a  significant  pressure  on  water 
resources  in  all  RBDs97.  In  the  second  RBMPs  it  was  only  reported  in  the  Vistula,  Swieza, 
Oder,  Pregolya  and  Nemunas  RBDs.  The  surface  covered  by  Nitrate  Vulnerable  Zones  has 
been  increased  from  the  first  to  the  second  RBMPs,  and  since  2017  Poland  applies  a  whole 
territory approach to implement the Nitrates Directive. Consequently, obligations and measures 
of the Nitrates Action Programme now apply to all farmers. 

11.3  Progress with Commission recommendations 

The Commission recommendations based on the first RBMPs and first PoM requested action 
on the following: 

area of drinking water safeguard zones. These rules were determined by the ordinance of the director of the 
regional water management authority. Currently, the drinking water safeguard zones covering only the area of 
direct  protection  are  established by  the  competent  authority of  the  National Water Holding  -  Polish Waters, 
and  the  drinking  water  safeguard  zones  covering  both  the  area  of  direct  protection  and  the  area  of  indirect 
protection are established by the voivode. 

97 Poland subsequently informed the European Commission that for each measure identified and planned in the 
RBMPs (PoM) a competent authority is responsible for its implementation. Estimated costs were assigned and 
reported. Potential source of funding are indicated in the plans, but it does not mean that financing is ensured. 

148 

 
                                                                                                                                                        
  Recommendation: Designate sufficient number of ZVNP (Nitrates Directive98 Article 3) 
in the second RBMPs cycle and adopt measures to effectively combat nitrate pollution 
in these zones as required by the Nitrates Directive and Article 11(3)(a) of the WFD.   

Assessment: The number of Nitrate Vulnerable Zones increased between the first and 
second RBMPs, and since 2017 the whole territory is designated as Nitrate Vulnerable 
Zone. The Nitrate Actions Programme now applies to all farmers, but its effectiveness 
has not been assessed. The first part of this recommendation related to ZVNP has been 
fulfilled, however further investigation on the new Action Programme would be needed 
to assess the effectiveness of its measures99. 

  Recommendation:  Adopt  measures  to  improve  nutrient  balances  oriented  towards 
manure handling and recycling on farms,  decrease nutrient discharges (fertiliser and 
pesticide  applications),  perform  more  controls  and  monitoring,  etc.  This  should  be 
followed by identification of financing sources designed to fund these measures. 

Assessment:  The  RBMPs  contained  no  information  on  measures  to  improve  nutrient 
balances or manure handling and recycling on farms, or to decrease nutrient discharges 
(fertiliser  and  pesticide  applications).  Rural  Development  Programmes  are  mentioned 
as  a  funding  source  for  measures  in  relation  to  nutrient  pollution.  The  evidence 
suggests that this recommendation has not been fulfilled100. 

Recommendation:  Address  agriculture's  impact  with  basic  measures  to  ensure  the 

achievement  of  the  established  objectives.  If  basic  measures  do  not  suffice  to  achieve 
the  environmental  objectives, 
the  Government  should  establish  supplementary 
measures (Article 11(4) and part B of Annex VI WFD). 

Assessment: The recommendation was partly fulfilled. No specific gap assessment was 
carried out therefore it remains unclear how the measures taken for the second cycle are 
expected to contribute to the achievement of WFD objectives. The implementation of 
basic measures Article 11(3)(h) for the control of diffuse pollution from agriculture at 

98 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 

99 Poland subsequently clarified that the Article of 20 July 2017 on Water Law introduces additional measures to 
reduce the pollution of waters with nitrates from agricultural sources, as well as the rules for controlling the 
application of the PoM and the penalty for breaching objectives of the Nitrates Action Programme. 

100 Poland subsequently clarified that the Act of 10 July 2007 on fertilizers and fertilization imposes an obligation 
to prepare a fertilization plan. In addition, the obligation to carry out the nitrogen balance is introduced in the 
action programs for the NVZs. A new national Nitrates Action Programme will come into force in July 2018, 
including the obligation to prepare a nitrogen fertilization plan. 

149 

 
                                                      
source  takes  place  in  all  RBDs.  However,  in  RBDs  with  agricultural  pressures  from 
nutrients supplementary measures are applied as well.  

  Recommendation:  Agriculture  is  indicated  as  exerting  a  significant  pressure  on  the 
water resource in all RBDs. This should be translated into a clear strategy that defines 
the  basic/mandatory  measures  that  all  farmers  should  adhere  to  and  the  additional 
supplementary  measures  that  can  be  financed.  This  should  be  developed  with  the 
farming community to ensure technical feasibility and acceptance. There needs to be a 
very clear baseline so that farmers know the rules and the authorities in charge of the 
Common  Agricultural  Policy  funds  can  adequately  set  up  Rural  Development 
Programmes and cross compliance water requirements.  

Assessment: There is little or no information available in the RBMPs to indicate that 
such a strategy has been developed or is under development101. 

101 Poland has indicated that its 2nd RBMPs include a reference to a strategy for the sustainable development of 
rural  areas,  agriculture  and  fisheries  for  2012-2020  and  that  among  its  objectives    are  the  protection    water 
quality, the rational use of water resources for agriculture and fisheries, and  increasing water retention. 

150 

 
 
                                                      
Topic 12

  Measures  related  to  pollution  from  sectors  other  than 

agriculture  

12.1  Assessment  of  implementation  and  compliance  with  WFD 

requirements in the second RBMPs 

In  the  context  of  this  topic,  pollution  is  considered  in  terms  of  nutrients,  organic  matter, 
sediment, saline discharges and chemicals (priority substances, river basin specific pollutants, 
groundwater  pollutants  and  other  physico-chemical  parameters)  arising  from  all  sectors  and 
sources apart from agriculture.  

Key  types  of  measures  (KTM)  are  groups  of  measures  identified  by  Member  States  in  their 
Programmes of Measures which target the same pressure or purpose. A KTM could be limited 
to one national measure but it 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. 

The following KTMs relevant to non-agricultural sources of pollution causing failure of WFD 
objectives were reported for Polish RBDs: 

  KTM 1 – “Construction or upgrades of wastewater treatment plants” 

  KTM 4 – “Remediation of contaminated sites (historical pollution including sediments, 

groundwater, soil)” 

  KTM  8  –  “Water  efficiency,  technical  measures  for  irrigation,  industry,  energy  and 

households” 

  KTM 14 – “Research, improvement of knowledge base reducing uncertainty” 

  KTM  15  –  “Measures  for  the  phasing-out  of  emissions,  discharges  and  losses  of 
Priority Hazardous Substances or for the reduction of emissions, discharges and losses 
of Priority Substances” 

  KTM  21  –  “Measures  to  prevent  or  control  the  input  of  pollution  from  urban  areas, 

transport and built infrastructure”.  

  KTM 99 – “Other key type measure reported under PoM” 

151 

 
KTMs  relevant  to  non-agricultural  sources  of  pressures  causing  failure  of  WFD  objectives 
have not been reported to WISE for the Elbe or Ucker RBDs102.  

The  WFD  specifies  that  the  PoM  shall  include,  as  a  minimum,  “basic measures”  and,  where 
necessary  to  achieve  objectives,  “supplementary  measures”  when  basic  measures  are  not 
enough to address specific significant pressures (see the Chapter 9 in this report). Quantitative 
information  on  basic  and  supplementary  measures  used  to  tackle  pollution  from  non-
agricultural sources  (number  of  measures  per KTM)  was provided  for  eight  out  of  10  Polish 
RBDs, i.e. not for the Elbe or Ucker RBDs103. 

Quantitative information on types of basic measures to tackle pollution from non-agricultural 
sources was provided for 11 measure types.  

Poland provided more targeted information on basic measures required under Article 11(3)(c to 
k).  Use  of  an  authorisation  and/or  permitting  regime  to  control  waste  water  point  source 
discharges (Basic measures Article 11(3)(g)) was reported for all RBDs for both surface and 
groundwater.  Registers  of  waste  water  discharges  (Basic  measures  Article  11(3)(g))  were 
available  in  all  RBDs  for  surface  and  groundwater.  Small  waste  water  discharges  were 
exempted  from  controls  in  all  RBDs.  There  is  prohibition  of  all  direct  discharges  to 
groundwater in all RBDs. 

Measures were reported to be in place to eliminate/reduce pollution from Priority Substances 
and other substances in all RBDs. 

12.2  Main  changes  in  implementation  and  compliance  since  the 

first RBMPs  

No  information  was  found  in  the  first  RBMP  on  substance-specific  measures.  In  the  second 
RBMPs  KTMs  were  reported  for  significant  pressures  from  specific  Priority  Substances  and 
from  River  Basin  Specific  Pollutants  causing  non-compliance  for  the  Vistula  RBD,  the  Jarft 
RBD, the Elbe RBD, the Oder RBD, the Pregolya RBD, the Nemunas RBD and the Dniester 
RBD. KTM 15 has been mapped against national measures and is also reported to be tackling 

102 Poland subsequently clarified that there is no surface water body in the Ucker RBD and that only basic national 
measures have been planned for the Ucker RBD because of its specificity. It was also clarified that 27 KTMs 
are indicated for the Elbe RBD in the report, of which 25 are linked to non-agricultural pressures.  

103 Poland subsequently clarified that basic and supplementary measures for the Elbe RBD have been indicated in 

the report. 

152 

 
                                                      
significant  pressures  in  all  RBDs.  Poland  has  reported  that  there  are  measures  in  place  to 
eliminate/reduce pollution from Priority Substances and other substances in all RBDs104. 

The  implementation  of  KTM1  and  KTM21  measures  specifically  for  benzo(b)fluor-anthene, 
dieldrin, endrin, and aldrin, was reported. 

Supporting documentation states that the aim of the Programmes of Measures in Poland is to 
cease or gradually eliminate the discharge of Priority Substances into the environment. In the 
Vistula  RBMP  significant  pressures  caused  by  emissions  were  identified,  and  based  on 
monitoring data the exceedance of the following Priority Substances in the Vistula RBD was 
reported: benzo(g, h, i)perylene and indeno(1,2,3-cd)pyrene. The presence of compounds from 
the  polycyclic  aromatic  hydrocarbons  group  in  waters  is  associated  with  atmospheric 
deposition  of  pollutants,  and  their  most  probable  sources  are  combustion  processes  in  the 
municipal sector (for example, municipal heating using improper quality of fuel or waste). 

frequently  observed  Priority  Substances  exceedances  were 

Appendix  2  to  the  Vistula  RBMP  (the  largest  RBD)  contains  information  on  all  the  Priority 
Substances identified in the Vistula RBD. Section 3.1 of the RBMP states that for rivers,  the 
the  sum  of 
most 
benzo(g.h.i)perylene and indeno(1,2,3-cd)pyrene, tributyltin compounds and cadmium and its 
compounds. Similarly, the situation was presented in lakes and water reservoirs, where it was 
also  most  frequently  reported  that  the  sum  of  benzo(g.h.i)  perylene  and  indeno(1,2,3-cd) 
pyrene as well as cadmium and its compounds was exceeded. On the other hand, in the case of 
transitional  and  coastal  waters,  the  most  frequent  exceedances  were  for  nonylphenols, 
octylphenols,  pentachlorobenzene,  endosulfan  and  cyclodiene  pesticides  as  well  as 
hexachlorobutadiene.  

for 

The following measures were reported in the Vistula RBMP regarding Priority Substances: 

  Measures  to  eliminate  surface  water  pollution  by  substances  specified  in  the  list  of 
Priority  Substances  and  to  gradually  reduce  pollution  by  other  substances  that  would 
otherwise prevent the achievement of environmental objectives; 

  The obligation to obtain a water permit for sewage discharges; 

104 Poland subsequently clarified that Priority Substances were identified for seven RBDs: the Vistula RBD, the 
Elbe RBD, the Oder RBD, the Pregolya RBD, the Nemunas RBD, the Dniester RBD and the Danube RBD. In 
the  other  three  RBDs  no  Priority  Substances  were  identified  in  2010-2011  and  no  installations  discharging 
such substances were recognised. Poland also clarified that KTM 15 was  mapped against national measures 
and reported to be tackling significant pressures in all 10 RBDs. 

153 

 
                                                      
  The  obligation  to  ensure  that  the  limit  values  for  pollutants  in  wastewater  discharged 

into waters and into the ground are not exceeded; 

  Prohibition  on  the  production  and  use  of  aldrin,  dieldrin,  endrin,  endosulfan, 

heptachlor, hexachlorobenzene, hexabromocyclododecane and DDT. 

The  RBMP  included  a  summary  of  measures  for  Priority  Substances.  The  basic  measures 
included the implementation of the review of water permits for discharge of sewage, including 
substances for which exceedances were found. In addition, measures were planned to conduct 
an  in-depth  analysis  of  the  pressures  for  those  water  bodies  for  which  it  was  impossible  to 
identify  the  reasons  for  the  exceedances  based  on  currently  available  data.  It  is  stated  in  the 
RBMPs that a special group of measures that limit the impact of Priority Substances was the 
verification  of  the  environmental  protection  programmes  for  municipalities  in  terms  of 
introduction  of  substances  from  the  polycyclic  aromatic  hydrocarbons  group  into  the 
atmosphere. There was no more detail in the RBMP or PoM document on what these special 
measures are. The verification of the environmental protection programme for municipalities is 
also mentioned in the explanation of the use of exemptions in Section 5, e.g. verification of the 
environmental protection programme for the municipality, aimed at detailed recognition and, 
as  a  result,  limiting  this  pressure  (e.g.  low  emission  pressure  for  river  water  body 
PLRW200062545213), so that it is possible to achieve indicators consistent with the values of 
good status. It appears that the above mentioned measures are mandatory.  

River  Basin  Specific  Pollutants  were  only  reported  for  the  Vistula  and  Oder  and  each  River 
Basin  Specific  Pollutant  reported  has  at  least  one  KTM  reported  to  tackle  it,  most  have  two 
KTMs  and  some  three  KTMs  reported  to  tackle  this  pressure  (KTM1  -  "Construction  or 
upgrades  of  wastewater  treatment  plants",  KTM2  -  "Reduce  nutrient  pollution  from 
agriculture", KTM8 - "Water efficiency, technical measures for irrigation, industry, energy and 
households",  KTM14  -  "Research,  improvement  of  knowledge  base  reducing  uncertainty", 
KTM21 - "Research, improvement of knowledge base reducing uncertainty").  

The following measures were reported in the RBMP:  

  The obligation to obtain a water permit for sewage discharges; 

  The  obligation  to  ensure  that  the  limit  values  for  pollutants  in  wastewater  discharged 

into waters and into the ground are not exceeded; 

  Prohibition on the production and use of chlordane, chlordecone, mirex, toxaphene, and 

hexabromobiphenyl. 

154 

 
Any other measures to prevent significant losses of pollutants from technical installations and 
to  prevent  or  reduce  the  impact  of  accidental  pollution,  for  example  from  floods,  including 
direct detection and early warning systems for such cases, are listed as: prohibition of locating 
in  areas  of  special  flood  hazard  new  projects  that  may  significantly  affect  the  environment, 
sewage  accumulation,  animal  manure,  chemicals,  as  well  as  other  materials  that  may 
contaminate  water,  carry  out  recovery  or  disposal  of  waste,  including  in  particular  their 
storage.  There  is  also  a  summary  of  measures  taken  to  prevent  or  decrease  the  influence  of 
pollution incidents. 

There  are  no  measures  specifically  planned  for  pollutants  causing  failure  of  good  chemical 
status of groundwater; only general measures have been included e.g. the implementation and 
application of groundwater quality standards and threshold values of pollutant concentrations, 
implementing measures to prevent or limit the introduction of pollutants into groundwater and 
prohibition  of  discharging  sewage  directly  into  groundwater.  Monitoring  of  groundwater 
bodies for chemical status is also listed. 

12.3  Progress with Commission recommendations 

The Commission recommendations based on the first RBMPs and first PoM requested action 
on the following: 

  Recommendation: Provide complete information on the level of compliance, and timing 
to  reach  compliance,  by  agglomerations,  including  information  on  funding,  in 
accordance with Directive 91/271/EEC (article 15 and following).  

Assessment:  Poland  reported  that  KTM1  -  Construction  or  upgrades  of  wastewater 
treatment  plants  and  KTM21  -  Measures  to  prevent  or  control  the  input  of  pollution 
from  urban  areas,  transport  and  built  infrastructure  was  in  place  for  eight  out  of  10 
RBDs.  

It was stated in the RBMPs that the Council of Ministers approved the fifth update of 
the National Municipal Wastewater Treatment Programme, which contains investment 
plans  for  the  agglomeration  in  the  field  of  sewerage  systems  and  sewage  treatment 
plants  until  2021.  No  further  details  are  given  in  the  RBMP.  The  PoM  supporting 
document provides a more detailed summary of investments, such as modernisation of 
sewer  networks,  new  wastewater  treatment  plants,  modernisation  of  waste  water 
treatment  plants  (settlement  stage),  development  and  expansion  of  waste  water 
treatment  plants.  The  document  gives  summary  information  about  which  projects  are 
completed, not completed, in progress or where there is a lack of data. Measures under 

155 

 
in 

the 

in  measures 

implementation 

their  regions  from 

the National Municipal Wastewater Treatment Programme are on-going. Some details 
are  given  at  the  regional  level  in  the  PoM  supporting  document.  Municipalities  are 
the 
responsible  for 
implementation  of  the  National  Municipal  Wastewater  Treatment  Programme.  They 
include the construction, extension or modernization of municipal wastewater treatment 
plants  as  well  as  the  construction  and  modernization  of  collective  sewer  systems.  In 
addition, municipalities carry out activities related to investments in the field of sewage 
treatment  plants  in  non-commercial  areas.  Municipalities  have  also  indicated  the 
obligation  to  conduct  control  of  proceedings  in  the  field  of  collection  of  sewage  by 
private users and entrepreneurs and treatment of sewage by private users at a frequency 
of at least every three years. The obligation to perform this task arises from Article 3 
par.  3  of  the  Act  of  13  September  1996  on  maintaining  cleanliness  and  order  in 
communities. Poland informed that it prepared and reported in 2017 to the Commission 
the  Urban  Wastewater  Directive105 
the  Masterplan 
(91/271/EEC).  The  Masterplan  was  drafted  upon  the  2017  National  Municipal 
Wastewater  Treatment  Programme  (the  fifth  update  of  the  Programme,  ‘AKPOŚK 
2017’) and contains complete information on compliance between agglomerations and 
the Directive and deadlines and costs of investments to meet requirements of the Urban 
Wastewater Directive and improve status of the environment.  

implementation  of 

for 

The recommendation has been largely fulfilled. 

  Recommendation:  control  of  chemical  pollution:  A  clear  strategy  to  tackle  chemical 
pollution should be in place. This should be based on a detailed pressure and impact 
assessment  which  clearly  identifies  the  causes  of  failure  for  water  bodies.  Basic  and 
supplementary  measures  should  be  identified  to  address  pollution  from  chemical 
substances, these should be targeted to specific water bodies that are failing to achieve 
good  status,  or  are  at  risk  of  deterioration.  A  cost-effectiveness  analysis  of  the  PoM 
should be carried out and reported. 

The  RBMPs  identify  Priority  Substances  (for  the  Vistula,  Elbe,  Oder,  Pregolya, 
Nemunas and Dniester RBDs) and River Basin Specific Pollutants (for the Vistula and 
Oder RBDs) causing non achievement of good status in Poland. In the second RBMPs, 
KTMs were reported for significant pressures from individual Priority Substances and 
River  Basin  Specific  Pollutants  causing  non-compliance  for  the  Vistula,  Jarft,  Elbe, 
Oder,  Pregolya,  Nemunas  and  Dniester  RBDs.  KTM  15  has  been  mapped  against 

105  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 

156 

 
                                                      
national  measures  and  also  reported  to  be  tackling  significant  pressures  in  all  RBDs. 
Poland  has  reported  that  measures  are  in  place  to  eliminate/reduce  pollution  from 
Priority Substances and other substances in all RBDs. 

In accordance with Article 113 paragraph 3 point 1a of the Water Law 2017, the lists of 
emissions  and  concentration  levels  drawn  up  by  the  directors  of  water  regions  when 
preparing  planning  documentation  shall  take  into  account:  1)  Priority  Substances 
specified in the regulations issued on the basis of Article. 38l par. 2 of the act - Water 
Law,  and,  2)  other  substances  than  those  indicated  in  point  1,  causing  pollution  -  for 
which  environmental  quality  standards  have  been  determined.  The  purpose  of 
preparation of such lists is to identify the substances in question, to indicate the sources 
of their emissions to the environment and to identify the areas in which their occurrence 
is  the  greatest  and  where  they  may  contribute  to  the  threat  of  failure  to  achieve 
environmental objectives. The list of emissions prepared for the Vistula RBD contains, 
among  other  things,  information  on  concentrations  and  loads  of  Priority  Substances 
discharged  into  waters  or  land  by  plants  located  in  the  river  basin.  This  was  done  at 
regional  level  based  on  the  data  from  2010  and  2011.  The  collected  data  allowed  a 
ranking  to  be  carried  out,  in  descending  order  according  to  the  total  volume  of 
discharges in the basin, separately for each year. According to it, in the analysed period, 
most of the loads of nickel and its compounds as well as lead and its compounds were 
discharged in the area of the Vistula RBD. No further details are given as regards how 
the chemical pollution is tackled.  

A  quantitative  cost-effectiveness  analysis  has  been  carried  out  in  all  10  RBDs  to 
support the selection of measures proposed under the 2015-2021 PoM, and it has been 
reported to WISE. 

Progress has been made and this recommendation has been partially fulfilled. 

157 

 
 
 
Topic 13

  Measures related to hydromorphology  

13.1  Assessment  of  implementation  and  compliance  with  WFD 

requirements in the second RBMPs 

Significant  hydromorphological  pressures  were  identified  in  three  out  of  the  10  RBDs  (the 
Vistula, Oder and Nemunas RBDs). For significant physical alterations and for dams, barriers 
and  locks,  the  relevant  sector  or  water  use  was  indicated  as  unknown  or  obsolete.  The 
significant  hydrological  and  hydromorphological  alterations  were  not  assigned  to  any  of  the 
specified sectors according to WISE either (instead the sector was reported as “other”). 

KTM 6 – “Improving hydromorphological conditions of water bodies other than longitudinal 
continuity”  was  reported  as  operational  to  address  hydrological  and  hydromorphological 
alterations in these three RBDs. KTM 5 – “Improving longitudinal continuity” was applied in 
the Vistula and Oder RBDs to address continuity obstacles and physical alterations. 

The types of specific  hydromorphological measures  planned include fish ladders, removal of 
structures, restoration of modified bank structure, as well as a number of basic measures such 
as the obligation to obtain water permits for damming, water retention, use of water for energy 
purposes, for water regulation as well as some investigative measures (e.g. establishment of a 
national database on hydromorphological changes). 

Overall  management  objectives  and  quantitative  objectives  in  terms  of  restoring  river 
continuity were reported to have been set in all RBDs. At the same time, however, only in the 
Vistula  and  Oder  RBDs  were  measures  relevant  to  restoring  river  continuity  reported  under 
KTM5. 

In  terms  of  basic  measures,  it  was  reported  that  there  is  an  authorisation  and/or  permitting 
regime in place to control physical modifications in all 10 RBDs, which covers changes to the 
riparian area of water bodies according to WFD Article 11(3)(i). It was also reported that there 
is a register of physical modifications of water bodies. 

Win-win  measures in terms of achieving the objectives of the WFD and Floods  Directive106, 
drought  management  and  use  of  Natural  Water  Retention  Measures  were  reported  to  be 
included in the PoM of all RBDs. However, KTM23 – “Natural Water Retention Measures” is 
not  reported  to  tackle  any  significant  pressures,  although  the  PoM  describes  some  activities 

106  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 

158 

 
                                                      
relevant to natural and small retention. Poland subsequently informed that measures related to 
increasing natural retention are an integral part of the Flood Risk Management Plans.  

The design of new and existing structural measures, such as flood defences, storage dams and 
tidal  barriers,  was  reported  to  have  been  adapted  to  take  into  account  WFD  objectives  in  all 
RBDs. The supporting documents to the PoM indicated that measures were planned to improve 
the functioning of retention reservoirs as well as measures related to the adaptation of existing 
drainage  systems  to  perform  retention  functions  while  maintaining  a  watercourse  for  fish 
migration.  In  addition,  in  case  of  obstacles  to  fish  migration,  supplementary  measures  are 
included to ensure river continuity (e.g. construction of fish passes).  

Ecological flows were derived and implemented partly, i.e. for some relevant water bodies, in 
eight RBDs (all except the Elbe RBD and the Ucker RBD) but the work is still on-going. In the 
Elbe RBD, ecological flows were not derived for the relevant water bodies but there are plans 
to do so during the second RBMPs. No information was found in the RBMPs about specific 
regulations which address the establishment of ecological flows or reference to initiatives for 
setting new standards to define ecological flows. Poland subsequently informed that the work 
on new standards is on-going. The methodological background should be finished within 2018 
and legislation changes are expected in the next few years. 

In  terms  of  the  level  of  ambition  for  tackling  significant  hydromorphological  pressures, 
according to the information available in the WISE reporting (for the three RBDs where such 
pressures  were  reported),  it  is  expected  that  the  number  of  water  bodies  affected  by  dams, 
barriers,  locks  will  be  reduced  from  144  to  127  by  2021  and  no  water  bodies  will  fail  to 
achieve objectives due to this pressure by 2027. Also it is expected that the number of water 
bodies affected by other hydromorphological alterations will be to a certain extent reduced by 
2021 and, by 2027 and only a few water bodies will still fail objectives due to these pressures. 

13.2  Main  changes  in  implementation  and  compliance  since  the 

first RBMPs 

The  links  between  specific  pressures  and  measures  have  improved  due  to  the  improved 
reporting on pressures and related KTMs in WISE. 

In the first RBMPs, no specific measures were reported to achieve an ecologically based flow 
regime. In the second RBMPs, it is evident that ecological flows have been partly derived and 
implemented at least in eight RBDs. 

159 

 
13.3  Progress with Commission recommendations 

The Commission recommendations based on the first RBMPs and first PoM requested action 
on the following: 

  Recommendation  (report  2015):  Consider  and  put  in  place  measures  for  addressing 
hydromorphological impacts from agriculture in line with requirement of Article 11(3) 
WFD.  

Assessment: The PoM includes basic measures which refer to the obligation to obtain 
a water permit for damming and water retention but there is no specific discussion of 
the  links  to  hydromorphological  impacts  from  agriculture.  There  is  also  mention  of 
measures on good practices supporting the achievement of good status in the field of 
natural water retention and water management in agricultural areas. Overall, based on 
the  information  found,  it  cannot  be  concluded  whether  specific  progress  on  this 
recommendation regarding impacts from agriculture has been made. 

  Recommendation:  Consider  and  prioritise  the  use  of  green  infrastructure  and/or 
natural water retention measures that provide a range of environmental (improvements 
in  water  quality,  flood  protection,  habitat  conservation  etc.),  social  and  economic 
benefits which can be in many cases more cost-effective than grey infrastructure. 

Assessment: KTM 23 – “Natural Water Retention Measures” is not reported to tackle 
any significant pressures. At the same time, a programme of retention in forests was 
reported  (this  was  also  reported  in  the  first  RBMPs)  aimed  at  retention  and 
maintenance  of  streams  and  related  infrastructure  in  good  condition.  In  addition  to 
technical  measures  related  to  the  construction  of  (among  others)  small  water 
reservoirs  and  weirs,  activities  also include  measures  aimed  at  active  protection  and 
shaping of wetlands. In the 2014-2020 financial period, it is planned to continue this 
project with specific reference to forestry adaptation to climate change, low retention 
and  counteracting  water  erosion  in  lowland  and  mountainous  areas.  Poland  also 
informed  that  measures  related  to  increasing  natural retention  are  an  integral  part of 
the  Flood  Risk  Management  Plans.  Therefore  this  recommendation  is  considered  as 
partially fulfilled. 

160 

 
 
 
Topic 14

  Economic analysis and water pricing policies  

14.1  Assessment of implementation and compliance with WFD 

requirements in the second RBMPs 

water 

irrigation 

There are contradictions between the reporting in WISE and the RBMPs regarding the 
definition  of  water  services.  Within  WISE,  three  water  services  were  reported; 
water 
abstraction/treatment/distribution, 
drinking 
abstraction/treatment/distribution  and  sewage  collection/wastewater  treatment.  In 
addition,  the  use  of  Article  9(4)  was  reported  for  flood  protection,  irrigation, 
navigation, self-abstraction (private water supplies), as well as for the additional water 
services of cooling water abstraction and water transfers between river basins, which 
are not  indicated  as  such. According to  the RBMPs, the definition of water services 
includes  municipal  water  management,  which  refers  to  water  supply  and  collection 
and  treatment  of  municipal  waste  water,  industry,  agriculture  and  forestry.  Self-
abstraction and hydropower are not included.  

Financial  cost  recovery  rates  are  provided  for  the  three  water  services  actually 
reported on WISE, i.e. for water supply and sewage (100%) and irrigation (20-26%) 
however  only  two  services,  for  water  supply  and  sewage,  were  reported  in  the 
RBMPs. The Polish Water Law (of 20th July 2017) Article 35 lists defines nine water 
services  and  Article  34  lists  sixteen  particular  water  uses.  It  was  reported  that  the 
relevant users contribute to the cost recovery of the water services, but it is not shown 
transparently which uses contribute to what degree and how. Also, the information on 
an ‘adequate’ contribution is not clear. 

Whether  the  extraction  of  irrigation  water  is  completely  exempted  from  fees  is  also 
not clear. 

Environmental and resource costs seem to be calculated and internalised for drinking 
water supply and wastewater collection and treatment, but only partially for irrigation 
and not for self-abstraction.  

Volumetric  charging  was  reported  to  be  in  use  for  drinking  water  abstraction  and 
wastewater collection and treatment but only partially for irrigation (this could be due 
to  the  fact  that  the  surface  water  abstraction  is  exempted  from  fees).  It  seems  that 
there  are  exceptions  for  agriculture  and  mining  but  the  extent  of  such  exceptions 
cannot be deduced from the information available. 

161 

 
The economic analysis was reported to have been updated. 

14.2  Progress with Commission recommendations 

The Commission recommendations based on the first RBMPs and first PoM requested action 
on the following: 

  Recommendation:  In  terms  of  measures  related  to  Article  9,  a  narrow  approach  to 
water services was applied. 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.  Environment  and 
resource  costs  should  be  included  in  the  costs  recovered.  Information  should  also  be 
provided on the incentive function of water pricing for all water services, with the aim 
of  ensuring the efficient use  of water.  Information on how  the polluter pays  principle 
has been taken into account should be provided in the RBMPs. 

  Assessment: In WISE, three water services were reported; drinking water abstraction / 
treatment  /  distribution,  irrigation  water  abstraction  /  treatment  /  distribution  and 
sewage  collection/wastewater  treatment.  In  addition,  the  use  of  Article  9(4)  was 
reported for flood protection, irrigation, navigation, and self-abstraction, as well as for 
the additional water services of cooling water abstraction and water transfers between 
river basins, which are not indicated as such. 

According  to  the  RBMPs,  the  definition  of  water  services  includes  municipal  water 
management,  which  refers  to  water  supply  and  collection  and  treatment  of  municipal 
waste water, industry, agriculture and forestry. Self-abstraction and hydropower are not 
included.  

Financial  cost  recovery  rates  were  provided  for  the  three  water  services  actually 
reported  on  WISE,  i.e.  for  water  supply  and  sewage  (100%)  and  irrigation  (20-26%). 
The summary rate for irrigation is not found in the Vistula or Oder RBMPs.  

The Polish Water Law (of 20th July 2017) Article 35 defines nine water services and 
Article  34  sixteen  particular  water  uses.  It  was  reported  that  the  relevant  users 
contribute to the cost recovery of the water services, but it was not shown transparently 
which uses contribute to what degree and how. Also, the information on an ‘adequate’ 
contribution is not clear. 

162 

 
No  cost  recovery  rates  for  agricultural  uses  of  water  other  than  irrigation  and  fish 
farming were provided in RBMP. According to the reporting on WISE, cost recovery is 
partial in the case of irrigation, while the RBMPs state that surface water abstraction for 
irrigation  (as  well  as  for  forestry,  and  for  fish  farming)  is  exempted  from  fees.  The 
financial  and  economic  rate  of  return  for  agriculture  (irrigations)  is  provided  in  the 
document  ‘Developing  a  cost  recovery  analysis  for  water  services,  including 
development  of  forecasts  in  river  basin  districts’  There  was  no  clear  statement  that 
there are fees for water abstraction from groundwater bodies for agriculture107.  

According to the data reported in WISE, environmental and resource costs are indicated 
as calculated, internalised (for irrigation water only partially) and significant. They also 
appear  to  be  calculated  and  internalised  for  drinking  water  supply  and  wastewater 
collection and treatment, but only partially for irrigation and not for self-abstraction.  

A  methodology  for  calculating  environmental  and  resource  costs  has  been  provided; 
both are divided into internalised and non-internalised costs.  

In  the  second  RBMPs,  there  has  been  a  development  of  the  methodology  in  terms  of 
resource  costs  in  which  active  surveys  were  used;  these  allowed  the  identification  of 
some  deficits  and  the  estimation  of  some  resource  costs.  However  there  is  still  no 
mechanism  in  Poland  that  registers  unmet  water  demand  in  the  industrial  and 
agricultural sector and there is a lack of systematic information about actual deficits of 
water resources.  

Internalised environmental costs are included directly in environmental charges based 
on  information  from  databases  regarding  fees  collection  (without  exactly  calculating 
them), while non-internalised environmental costs are assessed using data on so-called 
willingness to pay and also disposable income per person. This seems to be an update 
compared  to  the  first  RBMPs  where  environmental  costs  were  calculated  by  the 
contingent valuation method, which only determined the average willingness to pay for 
improving water quality. 

107 Poland has informed subsequently that the fee for water abstraction is a component of the water supply service 
(regardless  of  whether  water  is  used  for  the  municipal  sector  or  agriculture).  Costs  of  management  of  a 
company  supplying  with  water,  costs  of  replacing  pipes  or  costs  of  water  treatment  as  such  as  well  as  the 
component  of  return  rate  for  fees  for  water  abstraction  is  not  analysed  separately.  Fees  are  one  of  many 
components and when calculating the rate of return of the water supply service, these fees are included in the 
calculation. The mere fact that a given entity does not pay at all for the water supply does not mean that the 
rate of return is 0% - there are other components of the cost of water supply than the charges. Therefore, one 
can calculate (and such calculations have been carried out) the rate of return for irrigation in agriculture, even 
if the collection fees have not been calculated.  

163 

 
                                                      
It  was  stated  that  the  internalised  environmental  costs  increased  from  PLN  229.4 
million  (2006)  to  PLN  252.8  million  (2010),  i.e.  by  9%.  In  2006,  the  amount  of 
environmental costs for the whole of Poland was estimated at PLN 6693.8 million and 
for 2010 it was PLN 3364.5 million. It was not stated whether this means a very low 
cost recovery for environmental costs (it is below 10%). 

Internalised  resource  costs  are  costs  for  which  fees  have  been  paid.  Non-internalised 
resource costs are costs of lost benefits due to the unmet demand. In the first RBMPs a 
zero value was assigned in Poland for the resource costs as a result of the analysis, due 
to assumptions made and lack of data. It was stated in the document on the analysis of 
environmental and resource costs in accordance with art. 9 RDW 2000/60 / EC (2013) 
that  in  relation  to  the  first  RBMPs,  there  was  an  evolution  of  the  methodology: 
permission screening has been replaced by active surveys, which allowed identification 
of  some  deficits  and  estimation  of  a  fairly  small  stream  of  resource  costs.  However, 
methodological gaps remain. 

Regarding the incentive function of water pricing policies, the information provided is 
limited.  Volumetric charging was reported to  be  in  use  for drinking  water abstraction 
and wastewater collection and treatment but only partially for irrigation (it can be due 
to the fact that the surface water abstraction is exempted from fees). It seems that there 
are exceptions for agriculture and mining, at least, but to which degree is not explained 
in detail. 

The  collection  of  water  for  agricultural  irrigation  and  for  the  purpose  of  aquaculture 
requires water permits. 

Overall,  slight  progress  with  the  Commission’s  recommendations  can  be  noted. 
However,  significant  gaps  and  contradictions  remain.  The  recommendations  are 
partially fulfilled. 

164 

 
 
 
 
Topic 15

  Considerations specific to Protected Areas  

15.1  Assessment  of 

implementation  and  compliance  with  WFD 

requirements in the second RBMPs 

Protected  Areas  associated  with  surface  water  bodies  included  those  related  to  the  Habitats, 
Birds,  Nitrates,  Urban  Waste  Water  Treatment  (nutrient  sensitive  areas),  Bathing  Water  and 
Drinking water (Article 7)  Directives  and for groundwater bodies, the Nitrates, Urban Waste 
Water Treatment (nutrient sensitive areas), and Drinking Water Directives.  Table 15.1 shows 
the  number  of  protected  areas  of  all  types  in  each  RBD  of  Poland,  for  surface  water  and 
groundwater  bodies.  Poland  has  adopted  a  whole  territory  designation  approach  to  nitrate 
sensitive areas under the Urban Waste Water Treatment Directive. 

Table 15.1 

Number of protected areas of all types in each RBD of Poland, for surface 
and groundwater 

Protected Area type 

Number of protected area Associated with 

Rivers 

Lakes 

Transitional  Coastal  Groundwater 

Abstraction of water intended for human 
consumption under Article 7 

200 

168 

Recreational waters, including areas 
designated as bathing waters under 
Directive 76/160/EEC108 

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)109 

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) 

71 

37 

6 

131 

44 

11 

9 

3 

643 

117 

9 

4 

108  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 

109  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 

165 

 
 
 
 
 
 
 
                                                      
Protected Area type 

Number of protected area Associated with 

Rivers 

Lakes 

Transitional  Coastal  Groundwater 

Nutrient-sensitive areas, including areas 
designated as vulnerable zones under 
Directive 91/676/EEC (Nitrates 
Directive110)  

Not 
applicable 
(whole 
territory 
approach) 

Not 
applicable 
(whole 
territory 
approach) 

Not 
applicable 
(whole 
territory 
approach) 

Not 
applicable 
(whole 
territory 
approach) 

Not 
applicable 
(whole 
territory 
approach) 

Other 

1264 

111 

19 

2 

Source: Member State reports to WISE  

Figure 15.1 shows the status of water bodies associated with Protected Areas. For groundwater 
bodies, 90% or more were reported to be in good chemical and quantitative status. For surface 
waters, the situation is different with more water bodies in moderate or poor chemical and/or 
ecological status/potential. 

110  Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and 

flora http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31992L0043 

166 

 
 
                                                      
Figure 15.1  Status of water bodies associated with the Protected Areas report for Poland. 
Note: based on status/potential aggregated for all water bodies associated with 
all Protected Areas 

Source: Member State reports to WISE 

For all surface water nature (Habitats and Birds) Protected Areas, specific additional objectives 
have been set to protect all dependent habitats and species. For all nature areas, no information 
has  been  provided  as  to  whether  the  objectives  have  been  met,  which  implies  that  the 
monitoring  programme  may  not  provide  the  necessary  data  for  assessing  the  status  of  the 
Protected Area. This is in contrast to the information relating to ecological status assessments, 
which  have  been  made  with  high  confidence.  It  is  possible  that  the  objectives  have  been  set 
using a default approach. 

167 

 
 
 
For surface water Drinking Water Protected Areas, objectives have also been set, and nearly all 
have  been  met.  No  objectives  have  been  reported  for  groundwater  Drinking  Water  Protected 
Areas.  

Table 15.2 shows that the Polish ecological monitoring programme for surface water Protected 
Areas  is  fairly  comprehensive  and  includes  monitoring  sites  in  relation  to  the  relevant 
Directives.  

Table 15.2  Number of monitoring sites associated with Protected Areas in Poland 

Protected Area type 

Number of monitoring sites associated with 
Protected Areas in 

Rivers 

Lakes 

Transit
ional 

Coastal 

Ground
water 

Abstraction of water intended for human 
consumption under Article 7 

Nutrient-sensitive areas, including areas designated 
as vulnerable zones under Directive 91/676/EEC 
(Nitrates Directive) 

Areas designated as sensitive areas under Directive 
91/271/EEC (Urban Wastewater Treatment 
Directive) 

Protection of habitats or species where the 
maintenance or improvement of the status of water is 
an important factor in their protection, including 
relevant Natura 2000 sites designated under Directive 
92/43/EEC (Habitats) 

121 

167 

1 

7 

1460 

159 

791 

253 

Recreational waters, including areas designated as 
bathing waters under Directive 76/160/EEC 

47 

52 

Source: Member State reports to WISE  

9 

7 

7 

10 

8 

9 

No  data  was  reported  regarding  specific  monitoring  (quantitative  and  qualitative)  of 
groundwater dependent Protected Areas (mainly drinking water), despite the fact that the status 
for quantitative and chemical assessment has been carried out with high confidence, meaning it 
should be based on monitoring data (see Chapters 5 and 6)111. 

Specific plans for measures within Protected Areas are identified in the RBMPs, which state 
that the measures from these specific plans are coordinated with the RBMPs. It appears that the 
measures  mentioned  are  mainly  administrative  in  nature.  Safeguard  zones  have  also  been 

111 Poland subsequently clarified that both groundwater Drinking Water Protected Areas and nature (Habitat and 
Birds)  Protected  Areas  have  been  covered  by  monitoring  and  assessment.  For  groundwater  Drinking  Water 
Protected Areas an assessment was made as part of the test for quantitative status. Assessment of meeting the 
requirements for nature Protected Areas was made as part of the surface water assessment process. 

168 

 
  
 
  
 
 
 
 
                                                      
established  in  all  RBDs  and  it  is  noted  that  application  of  fertilizers  is  either  banned  or 
restricted within these zones.  

Out  of  several  thousand  Protected Areas,  exemptions  have  only  been  used  for  four  Drinking 
Water Protected Areas (all based on technical feasibility). 

A fairly large number of surface water Habitats and Birds areas have been identified, but no 
associated  groundwater  dependent  nature  areas  have  been  identified  which  is  unexpected.  A 
considerable number of Article 7 areas (drinking water – both from surface and groundwater) 
have been identified. 

15.2  Main changes in implementation and compliance since first RBMPs 

The  number  of  Bathing  Water  Protected  Areas  identified  in  the  second  cycle  of  River  Basin 
Management Plans has fallen to around half the number reported in the first cycle. 

The number of Habitats Protected Areas has more than doubled. 

In the first cycle, a considerable number of groundwater Drinking Water Protected Areas were 
monitored  (approximately  450  areas),  but  no  such  specific  monitoring  has  been  reported  in 
these second River Basin Management Plans. 

15.3  Progress with Commission recommendations 

The Commission recommendations based on the first RBMPs and first PoM requested action 
on the following: 

  Recommendation: Provide additional objectives for especial protection in the RBMPs 
for Protected Areas and report information on the status of Drinking Water Protected 
Areas associated with groundwater bodies. There is a lack of conservation action plans 
for Natura 2000 areas. 

Assessment:  Specific  objectives  have  been  set  for  Article  7  areas  (surface  water)  and 
for Birds and Habitats areas (also surface water). No objectives have been reported for 
groundwater  drinking  water  areas.  A  status  assessment  has  been  reported  for 
groundwater  Article  7  areas.  It  is  mentioned  in  the  RBMPs  that  plans  for  Protected 
Areas have been made including: 

169 

 
o  measures  aimed  at  establishing  protection  areas  for  inland  water  reservoirs, 
including  Main  Groundwater  Reservoirs,  in  particular  measures  to  protect 
drinking water,  

o 

taking  responsibility  for  sanitary  supervision  of  bathing  water  and  assessing 
water quality,  

o  extending the assessment of water quality of intended for human consumption, 
for  areas  particularly  exposed  to  pollution  with  nitrogen  compounds  from 
agricultural sources established by Polish Regulations. 

o 

o 

implementation of a PoM aimed to limit the export of nitrogen from agricultural 
sources,  

implementation  of investment plans as  part  of the National Urban  Wastewater 
Treatment Programme. 

These measures appear to be mainly administrative. 

The  recommendation  is  partly  fulfilled  as  additional  objectives  for  groundwater 
drinking water areas appear to not have been set. 

  Recommendation: Provide information on Drinking Water Protected Areas associated 
with  groundwater  bodies  and  on  the  number  of  Drinking  Water  Protected  Areas  - 
including whether they are in good status or not. 

Assessment:  The  information  has  been  provided  both  for  groundwater  and  surface 
water  drinking  water  Protected  Areas,  but  objectives  have  only  been  set  for  surface 
water  areas.  Despite  this,  a  status  assessment  has  been  reported  both  for  quantitative 
and qualitative status and for groundwater areas as well as surface waters. 

The recommendation has generally been fulfilled. 

  Recommendation:  Clarify in  the second RBMPs the objectives and planned measures 
for Protected Areas (Nitrate Vulnerable Zones, sensitive areas, Protected Areas under 
shellfish and fish water Directives, etc.). 

Assessment: Additional objectives have been set only for surface water areas related to 
Birds  and  Habitat  Directives.  No  objectives  have  been  set  for  groundwater  related 

170 

 
Protected  Areas  like  nitrate  vulnerable  areas  or  groundwater  dependent  habitat  and 
birds areas. 

Planned measures for Protected Areas are mentioned in the RBMPs (as detailed above) 
but appear to be largely administrative. 

The recommendation has been partially fulfilled. 

171 

 
 
Topic 16

  Adaptation to drought and climate change 

16.1  Assessment  of 

implementation  and  compliance  with  WFD 

requirements in the second RBMPs 

Climate  change  was  considered  in  all  RBDs  and  the  guidance  document  on  how  to  adapt  to 
climate change (Common Implementation Strategy Guidance Document No. 24112) was used. 
In  the  first  RBMPs  no  climate  change  evaluation  of  the  PoM  was  carried  out.  Such  an 
evaluation  has  been  now  carried  out  in  the  second  RBMPs.  Consideration  of  climate  change 
has been included in the assessment process for evaluating the effectiveness of measures and 
assessing  direct  and  indirect  climatic  pressures.  No  specific  sub-plans  for  addressing  climate 
change were reported for Poland. KTM 24 - ‘Adaptation to climate change’ is not reported as 
operational to address any of the significant pressures. 

According  to  the  2012  Topic  Report  on  Water  Scarcity  and  Drought  in  RBMPs113,  droughts 
were relevant for Poland at a local river sub-basin level. No exemptions have been applied for 
the country 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.  Drought  Management  Plans  have 
not been reported for Poland; this was also noted in the 2012 Topic Report114. 

16.2  Main  changes  in  implementation  and  compliance  since  the  first 

RBMPs 

A  climate  change  evaluation  check  was  carried  out  in  the  second  RBMPs.  This  was  not  the 
case in the first RBMPs.  

16.3  Progress with Commission recommendations 

There were no Commission recommendations based on the first RBMPs and first PoM for this 
topic. 

112 

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  

113  http://ec.europa.eu/environment/water/quantity/pdf/Assessment%20WSD.pdf  
114 Poland subsequently clarified that in the 2012 Plans for action against effects of drought in water regions were 
prepared  in  Poland  by  regional  water  management  boards  in  Szczecin  and  Wrocław.  One  year  later  the 
methodology for national plans (PPSS) was prepared so to have regional plans prepared according to unified 
approach.  Other  regional  plans  were  drafted  in  2014-2017  and  those  two  of  Szczecin  and  Wrocław  were 
reviewed  and  updated.  The  National  Water  Management  Authority  opened  works  on  PPSS  in  2016.  The 
document will be complementary to the RBMPs. As being not ready, PPSS was not reported in the RBMPs 
report. 

172