COMMISSION STAFF WORKING DOCUMENT Second River Basin Management Plans - Member State: Malta 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: Malta, 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) 48 final  COMMISSION STAFF WORKING DOCUMENT Second River Basin Management Plans - Member State: Malta 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) 49 final} - {SWD(2019) 50 final} - {SWD(2019) 51 final} - {SWD(2019) 52 final} - {SWD(2019) 53 final} - {SWD(2019) 54 final} - {SWD(2019) 55 final} - {SWD(2019) 56 final} - {SWD(2019) 57 final} - {SWD(2019) 58 final} - {SWD(2019) 59 final} - {SWD(2019) 60 final} - {SWD(2019) 61 final} - {SWD(2019) 62 final} - {SWD(2019) 63 final} - {SWD(2019) 64 final} - {SWD(2019) 65 final} - {SWD(2019) 66 final} - {SWD(2019) 67 final} - {SWD(2019) 68 final} - {SWD(2019) 69 final} - {SWD(2019) 70 final} - {SWD(2019) 71 final} - {SWD(2019) 72 final} - {SWD(2019) 73 final} - {SWD(2019) 74 final} - {SWD(2019) 75 final} - {SWD(2019) 76 final} - {SWD(2019) 77 final} - {SWD(2019) 78 final} - {SWD(2019) 79 final} - {SWD(2019) 80 final} - {SWD(2019) 81 final} - {SWD(2019) 82 final} - {SWD(2019) 83 final} - {SWD(2019) 84 final}  
 
 
Table of contents 
Acronyms...................................................................................................................................... 5 

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

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

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

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

Recommendations ...................................................................................................................... 17 

Topic 1

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

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

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

1.3  Progress with Commission recommendations .............................................................. 24 

Topic 2

  Characterisation of the River Basin District............................................................. 25 

2.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle   ...................................................................................................................................... 25 

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

2.3  Progress with Commission recommendations .............................................................. 35 

Topic 3

  Monitoring, assessment and classification of ecological status in surface water 

bodies 

 ................................................................................................................................... 38 

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

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

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

Topic 4

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

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

4.2  Main changes in implementation and compliance since the first cycle ....................... 71 

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

1 

 
 
 
 
 
Topic 5

  Monitoring, assessment and classification of quantitative status of groundwater 

bodies 

 ................................................................................................................................... 76 

5.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle   ...................................................................................................................................... 76 

5.2  Main changes in implementation and compliance since the first cycle ....................... 83 

5.3  Progress with Commission recommendations .............................................................. 83 

Topic 6

  Monitoring, assessment and classification of chemical status of groundwater bodies 
 ................................................................................................................................... 85 

6.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle   ...................................................................................................................................... 85 

6.2  Main changes in implementation and compliance since the first cycle ....................... 90 

6.3  Progress with Commission recommendations .............................................................. 91 

Topic 7
  Designation of Heavily Modified and Artificial Water Bodies and definition of Good 
Ecological Potential................................................................................................................... 93 

7.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle for designation ............................................................................................................... 93 

7.2  Main changes in implementation and compliance since the first cycle ....................... 96 

7.3  Progress with Commission recommendations .............................................................. 96 

Topic 8

  Environmental objectives and exemptions ................................................................ 97 

8.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle   ...................................................................................................................................... 97 

8.2  Main changes in implementation and compliance since the first cycle ..................... 103 

8.3  Progress with Commission recommendations ............................................................ 103 

Topic 9

  Programme of measures.......................................................................................... 105 

9.1  Assessment of implementation and compliance with WFD requirements in the second 
cycle   .................................................................................................................................... 105 

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

9.3  Progress with Commission recommendations ............................................................ 116 

Topic 10

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

2 

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

10.2  Main changes in implementation and compliance since the first cycle .................. 124 

10.3 

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

Topic 11

  Measures related to pollution from agriculture................................................... 126 

11.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle .......................................................................................................................... 126 

11.2  Main changes in implementation and compliance since the first cycle .................. 127 

11.3 

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

Topic 12

  Measures related to pollution from sectors other than agriculture ..................... 130 

12.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle .......................................................................................................................... 130 

12.2  Main changes in implementation and compliance since the first cycle .................. 133 

12.3 

Progress with Commission recommendations ........................................................ 134 

Topic 13

  Measures related to hydromorphology ................................................................ 137 

13.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle .......................................................................................................................... 137 

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

13.3 

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

Topic 14

Economic analysis and water pricing policies .................................................... 140 

14.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle and main changes since the first cycle ............................................................ 140 

14.2 

Progress with Commission recommendations ........................................................ 141 

  Considerations specific to Protected Areas (identification, monitoring, objectives 

Topic 15
and measures) .......................................................................................................................... 144 

15.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle .......................................................................................................................... 144 

15.2  Main changes in implementation and compliance since the first cycle .................. 147 

15.3 

Progress with Commission recommendations ........................................................ 147 

Topic 16

Adaptation to drought and climate change .......................................................... 149 

3 

 
 
 
 
16.1  Assessment of implementation and compliance with WFD requirements in the 
second cycle .......................................................................................................................... 149 

16.2  Main changes in implementation and compliance since the first cycle .................. 149 

16.3 

Progress with Commission recommendations ........................................................ 150 

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

2015 and reported to the European Commission in March 2016. 

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

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

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

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

6 

 
 
 
 
 
 
General Information 

Map A  

Map of River Basin Districts 

Source: WISE, Eurostat (country borders) 

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

Malta has a population of 450 000 people and a total surface area greater than 316 km2. Malta 
is a group of three islands in the Mediterranean Sea - Malta, Gozo and Comino. The terrain is 
low and rocky with coastal cliffs. 

Malta has identified one river basin district, which is 712 km2 and covers the whole country’s 
territory. The Malta RBD does not share catchments with other Member States or with other 

countries.  The  information  on  the  national  river  basin  district  including  sharing  countries  is 
provided in Table A. 

Table A 

Overview of Malta‘s River Basin Districts  

RBD 

Name  Size (km2)  Countries sharing borders 

MTMALTA  Malta 

712 

- 

Source: River Basin Management Plans reported to WISE  

7 

MTMediterranean SeaMTMALTAMTMALTA0510km 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Status of second river basin management plan reporting 

Malta published its RBMP on 16 February 2016. Documents are available from the European 

Environment Agency EIONET Central Data Repository https://cdr.eionet.europa.eu/.  

8 

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

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

 

Governance and public consultation 

  Malta  organised  an  extensive  process  for  the  active  involvement  of  stakeholders, 
including for the development of measures and the discussion of their implementation 
(thus implementing a Commission recommendation from the first cycle). 

  Malta  prepared  a  joint  plan  that  incorporated  both  its  RBMP  and  its  Flood  Risk 
Management  Plan  and  thus  implemented  a  Commission  recommendation  from  the 

first cycle to ensure coordination of these plans. 

 

Characterisation of the RBD 

 

Inland water bodies have been delineated since the first RBMP. However, river, lake 

and transitional water bodies do not  appear to  have equivalent  intercalibration types 
and type-specific reference conditions have not been established. Malta considers that 

such  reference  conditions  cannot  be  established  at  this  stage  and  that  for  inland 
surface  water  bodies,  the  characteristic  hydrological  intermittency  and  complexity 

renders the hydromorphological and physico-chemical evaluations of ecological status 
extremely difficult and further long-term trend data are necessary. 

 

Further  characterisation  work  for  groundwater  bodies  has  been  undertaken  since  the 
first  RBMP,  with  the  inclusion  of  the  assessment  of  linkages  with  surface  water 

bodies. 

 

For  surface  water  and  groundwater  bodies,  significance  of  pressures  is  reported  as 

being  linked  to  the  potential  failure  of  objectives.  However,  the  significance  is  not 
defined  in  terms  of  thresholds  and  it  was  reported  that  a  relatively  high  number  of 
significant  pressures  (14)  were  not  assessed  for  surface  water,  including  “dams, 

barriers  and 
to 
hydromorphological  alterations were qualitatively  described for inland surface water 

locks  and  physical  alterations”,  although  pressures  due 

bodies in the second RBMP.  

9 

 
 
 
 

 “Anthropogenic  pressure  –  unknown”  is  reported  to  affect  all  surface  water  bodies 

and  diffuse  and  point  pressures  from  undefined  sources  are  reported  for  47  %  of 
surface  water  bodies.  This  shows  that  the  activities  and  sectors  have  still  not  been 
adequately identified1.  

 

It was reported that only five Priority Substances were included in the inventory. The 

RBMP explains that the inventory only covers substances that are relevant in Maltese 
water bodies, but the criteria for relevance were not provided. No basic estimation of 

emissions  was  provided  for  these  substances  of  minor  relevance.  This  is  not  in  line 
with  the  Common  Implementation  Strategy  Guidance  Document  n°28.  Tier  1  (point 

source  information)  was  implemented  for  substances  in  the  inventories  (while  the 
Guidance  Document  recommends  implementing  at  least  Tier  1+2  for  substances 

relevant at RBD level). The quality of the input data is reported as uncertain. 

  Monitoring, assessment and classification of ecological status  

 

Since  the  first  RBMP,  monitoring  has  been  established  for  all  the  required  quality 

elements  in  coastal  waters  and  for  most  of  the  required  quality  elements  in  rivers, 

lakes, and transitional waters. 

 

Ecological status was reported as unknown for all rivers, lakes and transitional waters 

and  no  biological  quality  elements  were  classified  in  those  three  water  categories. 
Hydromorphological  quality  elements  were  not  classified  in  any  water  category, 

except morphological conditions in transitional waters. 

 

Phytoplankton  and  benthic  invertebrates  were  monitored  in  coastal  water  but  not 

classified on the basis of an intercalibrated method.  

 

Five River Basin Specific Pollutants were identified and were monitored, in sediment 

only, at a frequency lower than the minimum recommended frequency. 

 

Environmental  Quality  Standards  were  reported  for  the  five  River  Basin  Specific 

Pollutants  in  sediment.  They  were  not  derived  in  accordance  with  the  Technical 

Guidance  n.  27  and  the  analytical  methods  are  not  in  line  with  the  requirements  of 
the  Quality  Assurance/Quality  Control  Directive 
Articles  4(1)  and  4(2)  of 

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

1   Malta subsequently clarified that terminology “anthropogenic pressure  – unknown”  was used in cases where 

presence of contaminants in surface water bodies could not be attributed to a particular source.  

10 

 
 
                                                      
 

Intercalibration  was  not  done  for  phytoplankton  and  benthic  invertebrates  in  coastal 

waters, nor for any biological quality elements in rivers, lakes and transitional waters. 

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

 

For the first RBMP, the chemical status for all water bodies (all coastal water bodies) 

was unknown. In the second RBMP, Malta has delineated inland surface water bodies 
transitional  water  bodies,  and  all  water  bodies  have  been  classified. 
and 

Approximately half of the water bodies have good chemical status (rivers, lakes and 
transitional) and half are failing to achieve good status (all coastal water bodies).  

  Water bodies seemed to be classified with  medium  to  high confidence, according to 

the RBMP. 

 

 

 

 

All surface water bodies are monitored with the exception of coastal waters (78 % are 
monitored). This results from both an increase in monitoring of coastal water bodies 
and monitoring of the newly delineated freshwater bodies, since the first RBMP. 

All 41 Priority Substances are monitored, including all priority substances discharged, 
and all are taken into account in the assessment of status. The monitoring frequency 

for  some  Priority  Substances  in  the  water  column  in  coastal  waters  meets  the 
minimum  recommended  frequency  for  surveillance  but  not  for  operational 

monitoring.  In  surface  freshwaters,  the  frequency  is  less  than  the  minimum 
recommended.  

Hexachlorobenzene, mercury and hexachlorobutadiene are not monitored in biota for 
status assessment. 

 All  14  of  the  relevant  Priority  Substances  were  monitored  for  trend  assessment  in 
sediments and/or biota in all water bodies (14 substances in coastal water bodies, and 

13 substances in lake, river, and transitional water bodies). The monitoring frequency 
is lower than the recommended minimum frequency. 

  Monitoring,  assessment  and  classification  of  quantitative  status  of  groundwater 

bodies 

 

There is still a gap in quantitative monitoring, but Malta subsequently clarified that it 
is intending to extend the monitoring framework to all groundwater bodies within the 

implementation timeframe of the second cycle. 

11 

 
 
 

The  level  of  confidence  of  the  status  results  is  reported  high,  but  only  3  out  of  15 

groundwater  bodies  are  monitored,  which  cover  approximately  80  %  of  the  total 
groundwater body area. Malta subsequently clarified that the existing hydrogeological 

setting did  not  allow water level  measurements.  The groundwater  quantitative status 
was therefore assessed by a water-balance model. 

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

 

The  coverage  of  groundwater  bodies  by  surveillance  and  operational  monitoring  is 
complete. Also all WFD core parameters are monitored (in contrast to the conclusions 

drawn from the electronic reporting). 

 

The percentage of the total groundwater body area failing good status is still very high 

and there is no significant improvement. 

 

Terrestrial ecosystems and surface waters were considered in status assessment.  

 

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

Ecological Potential 

 

There  is  still  no  consistent  description  of  the  methodology  for  the  designation  of 
heavily modified water bodies in the Maltese RBMP. The RBMP only explains why 

the two main coastal heavily modified water bodies are designated as such, including 
a  description  of  substantial  changes  in  character  and  significant  adverse  effects  of 

restoration measures on the use or wider environment. For the five transitional water 
bodies,  which  were  designated  due  to  historical  usage,  as  well  as  the  two  lake  and 

river  heavily  modified  water  bodies,  no  criteria  or  explanations  for  the  designation 
were described. 

 

In the second RBMP,  good ecological  potential  is  reported as defined following the 
Prague approach, whereas in the first RBMP, good ecological potential had not been 

defined  due  to  the  delay  in  the  implementation  of  the  monitoring  programmes.  The 
approach  developed  to  define  good  ecological  potential  in  the  second  RBMP  only 

concerns  the  two  coastal  heavily  modified  water  bodies.  Good  ecological  potential 
definition on the basis of biological quality elements and mitigation measures has only 

taken  place  for  the  two  coastal  heavily  modified  water  bodies,  while  for  the  other 
heavily  modified  water  bodies  (rivers,  lakes,  and  transitional  waters),  no  biological 
quality  elements  were  established/assessed  and  mitigation  measures  have  been 

12 

 
 
identified.  It  is  explained  that  due  to  the  unique  characteristics  of  inland  surface 

waters,  additional  data  is  required  to  understand  the  complex  dynamics  associated 
with such water bodies. 

 

Environmental objectives and exemptions 

 

Environmental  objectives  were  reported  for  coastal  water  bodies  and  groundwater. 
However,  the  dates  by  when  lake,  river,  and  transitional  water  bodies  will  achieve 

good  ecological  status/potential  are  reported  as  unknown.  Good  chemical  status  for 
river, lake and transitional water bodies was reported to be achieved by 2015 but the 

dates for achieving good chemical status for coastal waters are unknown. 

 

 

Drivers, pressures and pollutants leading to exemptions are reported. 

Justifications  for  exemptions  have  been  provided  at  water  body  level.  Criteria  have 
been developed for the application of exemptions with regard to technical feasibility 
and  disproportionate  costs.  Overall  the  application  of  exemptions  has  been  reduced 

between the two cycles. 

 

Programme of Measures 

 

The financing of measures is one area of progress. Clear costs are presented and it is 

reported  that  76  %  of  the  funding  for  the  measures  will  be  provided  by  European 
Union  funds.  Financial  commitment  for  the  remaining  measures  has  been  obtained 

from all relevant sectors. 

 

Not  all  the  significant  pressures  identified  in  groundwater  bodies  are  addressed  by 

KTMs. There is a discrepancy between the national measures mapped to KTMs and 
the KTMs reported to be addressing significant pressures2. 

 

There is a discrepancy between the national KTMs reported as being used to address 
significant pressures and those against which national measures have been mapped. 

 

Very  limited  information  on  the  gap  to  good  status  was  reported.  Where  data  was 

provided,  indicators  were  generally  only  provided  for  2015.  Where  information  is 

2   Malta reported that this is a result of an oversight during the reporting given that all KTMs were linked to the 
two  most  important  significant  pressures  which  are  “abstraction  or  flow  diversion  –  agriculture”  and  – 
“Abstraction or flow diversion - Public water supply”. 

13 

 
 
                                                      
reported for 2021 it was reported that the water bodies concerned were expected to be 

of good status. 

  Measures related to abstractions and water scarcity 

  Water abstraction pressures are reported as relevant for Malta; and 13 % of groundwater 
bodies face water quantity-related problems for achieving good quantitative status. 

 

The Water Exploitation Index + is 97 % (2014) which is an extraordinarily high figure 

and might indicate risks of sustainable water use. 

 

The  river  basin  management  plan  does  not  include  a  water  resource  and  allocation 

management plan. 

  Measurement  and  monitoring  are  the  basis  for  calculating  urban  water  consumption. 
Measures have been implemented to better calculate agricultural water consumption.  

 

Exemptions  for  permitting  and  registering  for  small  abstractions  might  need  to  be 
reviewed  and  abstractions  controls  need  improvement,  as  a  significant  proportion  of 

groundwater bodies does not achieve good quantitative status. 

  Measures related to pollution from agriculture 

 

 

 

 

 

 

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

A gap assessment for nutrients has not  been undertaken  and management objectives 

for nutrient pollution have not been set. 

Safeguard zones have been established for abstractions.  

Implementation of basic measures Article 11(3)(h) for the control of diffuse pollution 

from agriculture at source is ensured and the same rules apply across the whole RBD. 

Financing of agricultural measures is secured.  

The  level  of  ambition  is  unclear,  as  the  area  covered  by  measures  to  achieve 
environmental  objectives  is  not  reported.  Malta  however  subsequently  clarified  that 

the whole RBD’s area is covered. 

14 

 
 
 
  Measures related to pollution from sectors other than agriculture 

  Malta reported KTM to tackle significant chemical pressures.  

  Malta  also  reported  measures  specifically  to  address  mercury,  the  only  Priority 

Substance (mercury) identified as causing failure. 

 

There is no specific measure to tackle Zinc. 

  Measures related to hydromorphology 

 

In  the  second  RBMP,  no  significant  hydromorphological  pressure  affecting  water 
bodies was identified in Malta, and therefore no related hydromorphological measure 

was reported. According to the information subsequently provided by Malta, physical 
alterations have been reported for Heavily Modified Water Bodies rather than under 

significant  hydromorphological  pressures.  In  terms  of  measures,  however,  natural 
water  retention  measures  (KTM23)  are  planned  to  tackle  significant  abstractions  or 

flow diversion pressures from public water supply on groundwater.  

 

Ecological flows have not been derived or implemented so far but there are plans to 

do  so  during  the  second  cycle.  In  this  context,  no  specific  measure  is  planned  to 
achieve  ecological  flows  and  their  establishment  is  not  addressed  by  specific 

regulations. However, it is indicated that Malta is still in the phase of establishing the 
baseline for deriving ecological flows. 

Economic analysis and water pricing policies  

Cost  recovery  calculations remain limited  –  environmental and resource  costs have not 

been included. 

 

 

 

Pricing  policies  have  not  been  modified  to  show  how  “adequate  incentives”  were 

provided. 

 

 

 

The Polluter Pays Principle is not adequately reflected in the water pricing policies. 

A narrow definition of water services has been used. 

Considerations  specific  to  Protected  Areas  (identification,  monitoring,  objectives 

and measures) 

15 

 
 
 

Although some explanations  on the monitoring of Protected Areas were  provided in 

the RBMP, no monitoring programme was reported to WISE for protected areas under 
the Bathing Water, Birds and Drinking Water Directives.  

 

Additional objectives have already been set in particular for Drinking Water Protected 
Areas,  as  well  as  for  some  of  the  Protected  Areas  under  the  Birds  and  Habitats 

Directives.  Work  is  still  in  progress  for  the  remaining  Birds  and  Habitats  Protected 
Areas,  and  no  additional  objective  was  reported  for  Bathing  and  Nitrates  Protected 

Areas. 

 

Safeguard  zones  have  been  established  around  the  groundwater  bodies  associated  to 

Drinking  Water  Protected  Areas.  However  for  other  protected  areas,  it  is  unclear 

whether  all  necessary  measures  have  properly  been  identified  as  not  all  relevant 
additional objectives have been set. 

 

Adaptation to drought and climate change 

  Climate  change  was  considered  and  the  Common  Implementation  Strategy  guidance 

document on how to adapt to climate change was used. 

  Adaptation  measures (KTM24  –  “adaption to  climate change”) have not  been applied to 

address any of the significant pressures. 

  Drought management plans have been reported for Malta. 

16 

 
 
 
 
Recommendations  

  Malta  should  further  strengthen  monitoring  of  surface  waters  by  covering  all  relevant 

quality elements in all water categories, particularly in rivers, lakes and transitional waters. 
For  those  water  categories,  surveillance  and  operational  monitoring  should  be  clearly 

identified with adequate monitoring strategies.  

  Malta should continue to develop reference conditions for Biological Quality Elements in 

rivers and lakes and for supporting Quality Elements for all water bodies. 

  Further work is needed on the apportionment of pressures among sources, so that adequate 

measures can be identified. 

  Malta  should  provide  more  precise  information  on  the  method  used  for  the  selection  of 
River Basin Specific Pollutants especially on how diffuse sources  are taken into account. 

Malta  should  make  sure  that  the  environmental  quality  standards  meet  the  minimum 
requirements for the protection of freshwater and marine ecosystems from possible adverse 

effects,  as  well as of human health. Malta should also  make sure that analytical  methods 
are in line with the requirements of Articles 4(1) or 4(2) of the Quality Assurance/Quality 

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

  Malta should develop a complete assessment method for all biological quality elements for 
lakes,  rivers  and  transitional  waters.  Assessment  methods  should  also  be  developed  for 

hydromorphology  for  all  water  categories.  Moreover,  Malta  should  ensure  that  the 
assessment  methods  for  the  physicochemical  quality  elements  are  linked  to  the  relevant 

biological quality elements. 

  The  monitoring  frequencies  should  be  at  least  as  high  as  the  recommended  minimum 
frequencies from the WFD and EQS Directive. Priority substances should be monitored in 
biota  where  relevant  for  status  assessment,  with  sufficient  spatial  coverage  to  reach 
sufficient  confidence  in  the  assessment.  If  reduced  frequencies  or  a  different  matrix  are 

used, the corresponding explanations should be provided, as required by the Directives.  

  Monitoring  for  quantitative  status  of  groundwater  is  still  insufficient,  Malta  should 

continue to work on completing the monitoring schemes.  

17 

 
 
  A consistent  methodology  needs to  be developed for the designation of heavily modified 
water  bodies  for  all  relevant  water  categories  based  on  sound  monitoring  performed 
according to WFD requirements. The designation of heavily modified water bodies needs 

to comply with all the requirements of Article 4(3). Criteria need to be developed for the 
assessment of significant adverse effects on their use or the wider environment and the lack 

of  significantly  better  environmental  options,  which  need  to  be  specifically  mentioned  in 
the  RBMPs.  Further  efforts  are  needed  to  define  ecological  potential  also  in  terms  of 

biology for all relevant water categories. 

  Progress  needs  to  be  continued  to  further  improve  the  understanding  of  pressures  and 
effects on water body status, particularly with regard to ecological status of surface water 

bodies. The assessment of the timeframe until when the WFD objectives will be achieved 
needs  to  be  completed,  taking  into  account  a  revised  and  updated  assessment  of  the 

justifications of Article 4(4) and 4(5) exemptions.  

  No  Article  4(7)  exemptions  were  reported  to  be  applied  although  new  physical 
modifications  are  planned.  Malta  needs  to  ensure  a  thorough  assessment  of  possible  new 

modifications in line with the requirements of the WFD. 

  Malta  should  prioritise  measures  and  explain  in  more  detail  its  approach  to  identifying 

them in the next RBMP. 

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

should be designed and implemented to close that gap. 

  Efforts should be made to directly link the status of individual water bodies with measures 

for the third planning cycle. 

  KTMs should address all the significant pressures identified in groundwater bodies. 

  The problem of water scarcity and over-abstraction that are significant pressures and cause 
poor quantitative status should continue to be tackled (results of targeted measures are yet 
to be assessed). 

  Malta  should  complete  a  comprehensive  gap  assessment  for  diffuse  pollutant  loads  from 
agriculture (nutrients, agri-chemicals, sediment, organic matter) across all waters and link it 

18 

 
 
directly  to  mitigation  measures  in  the  third  RBMP  (as  per  WFD  Article  11(3)(h)),  to 

facilitate the achievement of WFD objectives. 

 

In the third RBMPs, Malta should specify, for all measures, the area of agricultural land to 

be covered by measures for achieving WFD objectives. 

  Malta  should  continue  to  develop  a  clear  strategy,  in  cooperation  with  the  farming 
community,  which  defines  the  basic  measures  that  all  farmers  should  adhere  to  and  the 
supplementary measures that can be financed via the Rural Development or other funding 

sources. 

  Malta  should  continue  to  address  any  remaining  instances  of  the  discharge  of  animal 
husbandry waste in the sewage collecting system and ensure that there are explicit links in 

the RBMPs between the WFD and supporting programmes and instruments (e.g. Nitrates 
Directive, Rural Development, etc.). 

  Malta  should  endeavour  to  establish  the  drivers  behind  Zinc  pollution  and  identify 

substance-specific measures. 

  Malta  should  use  the  inventory  of  emissions  to  identify  the  need  for  measures,  including 

supplementary measures if appropriate. 

  Further efforts should be made to ensure that chemical pollutants entering water bodies via 

urban waste water treatment plants are tackled. 

  Malta needs to ensure that the hydromorphological pressures are reported and included in 
the next RBMP, both for natural and heavily modified water bodies, and that the necessary 
restoration measures are implemented. 

  Malta  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. 

  Malta  should  apply  cost  recovery  for  water  use  activities  having  a  significant  impact  on 
water  bodies  or  justify  any  exemptions  using  Article  9(4).  Malta  should  transparently 

present how financial, environmental and resource costs have been calculated and how the 

19 

 
 
contribution  of  the  different  users  is  ensured.  It  should  transparently  present  the  water-

pricing policy, and provide a transparent overview of estimated investments and investment 
needs. 

  Malta  should  complete  the  monitoring  programmes  for  all  relevant  types  of  Protected 
Areas,  and  should  fully  report  them  to  the  Commission.  Malta  should  set  additional 
objectives  where relevant  for all the Protected Areas, so  as  to  identify and implement  all 

necessary measures. 

20 

 
 
 
 
Topic 1

  Governance and public participation 

1.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle 

1.1.1 Administrative arrangements – river basin districts 

Malta is a group of three islands. It has designated one RBD, Malta, for which it has prepared 
one  RBMP,  entitled  the  Second  Water  Catchment  Management  Plan  for  the  Malta  Water 

Catchment  District  2015-2021.  This  plan  also  incorporates  Malta’s  Flood  Risk  Management 
Plan. 

1.1.2 Administrative arrangements – competent authorities 

Malta  reports  two  Competent  Authorities  for  its  RBMP:  The  Environment  and  Resources 
Authority and The Energy and Water Agency. Their main roles are: 

  The  Environment  and  Resources  Authority:  monitoring  and  assessment  of  surface 
water,  enforcement  of  regulations,  pressure  and  impact  analysis,  economic  analysis, 

preparation  of  the  RBMP  and  Programme  of  Measures,  public  participation, 
implementation  of  measures,  coordination  of  implementation,  and  reporting  to  the 

European Commission.  

  The  Energy  and  Water  Agency:  monitoring  and  assessment  of  status  of groundwater, 
pressure  and  impact  analysis,  economic  analysis,  preparation  of  the  RBMP  and 
implementation  of  measures, 
Programme  of  Measures,  public  participation, 

coordination of implementation and reporting to the European Commission. 

1.1.3 River  Basin  Management  plans  –  structure  and  Strategic  Environmental 

Assessment 

Malta’s  RBMP  contains  in  its  annexes  the  Flood  Risk  Management  Plan  (see  section  1.1.5 

below) and a Drought Risk Management Plan. 

Malta  reported  that  a  Strategic  Environmental  Assessment  had  not  been  undertaken  for  the 

RBMP  and  Flood  Risk  Management  Plan.  Malta  subsequently  informed  that  a  Strategic 
Environmental  Assessment  screening  exercise  indicated  that  a  Strategic  Environmental 

Assessment is not required. This screening exercise indicated that the RBMP is unlikely to lead 
to  additional  significant  environmental  effects  over  and  above  those  positive  effects  which 

were identified in the Strategic Environmental Assessment carried out for the first RBMP. In 
addition,  the  main  measures  foreseen  under  the  second  RBMP  were  assessed  under  the 

21 

 
 
Strategic Environmental Assessment process for the Operational Programme for Malta, under 

which all these main measures are identified. 

1.1.4 Public consultation 

According  to  the  information  reported  in  WISE  by  Malta,  the  public  and  interested  parties 

were  informed  by:  the  internet,  invitations  to  stakeholders,  local  authorities,  media  (papers, 
television, radio), meetings and printed material. Documents were available by direct mailing 

(email) and by download. 

The  following  stakeholder  groups  were  actively  involved  in  the  development  of  the  RBMP: 

agriculture/farmers, fisheries/aquaculture, industry, local/regional authorities, navigation/ports, 
NGOs/nature  protection  and  water  supply  and  sanitation.  The  mechanism  for  stakeholder 

involvement was involvement in drafting and other outreach activities, which included bilateral 
meetings and workshops with individual stakeholders or groups. 

The public consultation had the following impacts on the RBMP, according to the information 
reported by  Malta:  addition  of new information,  adjustment of specific measures, changes to 
the  selection  of  measures,  commitment  to  action  in  the  next  RBMP,  commitment  to  further 

research and understanding of cost effectiveness. 

The  RBMP  highlighted  that  a  series  of  stakeholder  consultation  activities  led  to  the 

formulation  of  the  measures  for  the  draft  Programme  of  Measures.  These  consultation 
meetings discussed the issues faced by the respective sectors, and stakeholders were involved 

in the development of specific measures. The general public, agriculture, public sector, utilities 
and  the  commercial  sector3  are  named  as  groups  involved.  Following  the  drafting  of  the 
Programme  of  Measures,  further  consultation  meetings  were  undertaken  to  discuss  the 
measures  identified  with  stakeholders,  focusing  on  issues  related  to  the  implementation  of 

these measures.  

The  consultation  process  was  initiated  in  March  2014  with  a  National  Conference,  which 
discussed the Significant Water Management Issues. This national conference was open to the 
general  public  and  was  extensively  advertised  in  the  local  press.  Following  this  national 

conference,  a  series  of  national  workshops  were  held  between  March  and  October  2014, 
focusing on specific issues: (i) the Significant Water Management Issues; (ii) efficient use of 

water  resources;  (iii)  water  use  by  the  industrial  and  commercial  sectors;  (iv)  optimising 
groundwater  management;  (v)  energy-water  nexus;  and,  (vi)  development  of  a  Water 

Management  Plan  (Programme  of  Measures).  These  public  consultation  workshops  were 

3   Malta subsequently clarified that the commercial sector included the tourism sector. 

22 

 
 
                                                      
followed by  a second phase of the consultation  process  which  focused on informal meetings 

with representatives of the main water use categories in the Maltese islands. No more than 20 
participants were invited to each of these meetings, to ensure dynamic discussions.  

During this second consultation phase, 12 consultation meetings were held with representatives 
of the agricultural sector (including a meeting in Gozo) during the period November to March 

2015. The total attendance to these meetings reached around 300 full time farmers, around 25 
% of the total full time farming population in the Maltese islands. These consultation meetings 

were organised in cooperation with the Assocjazzjoni tal-Bdiewa (Farmers Association).  

The consultation process was concluded with a National Stakeholder Consultation Workshop, 

jointly organised by the two WFD competent authorities. This workshop presented the updated 
draft RBMP to stakeholders and provided an opportunity for a final discussion on the second 

RBMP. 

1.1.5 Integration  with  the  Floods  Directive  and  the  Marine  Strategy  Framework 

Directive 

Malta prepared a single plan that incorporated both its second RBMP and its first Flood Risk 
Management  Plan  (FRMP)  under  the  Floods  Directive4.  As  noted  above,  the  FRMP  is 
presented  in  an  annex  to  the  RBMP.  Moreover,  the  FRMP  and  RBMP  share  measures  and 
common sections, such as the discussion of potential climate impacts. In addition, Malta held a 

joint  consultation  for  the  RBMP  and  FRMP  and  for  the  Marine  Strategy  Framework 
Directive5.  

1.1.6 International coordination 

Malta does not share its RBD with any other Member States or countries. 

1.2  Main changes in implementation and compliance since the first cycle 

In the first cycle, Malta's competent authorities were the Maltese Resource Authority, and the 
Maltese Environment  and Planning  Authority.  In the second cycle, the competent  authorities 

are the Environment and Resources Authority, and the Energy and Water Agency (reflecting a 
reorganisation of government bodies).  

4   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  

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

23 

 
 
                                                      
1.3  Progress with Commission recommendations 

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

requested action on the following: 

  Recommendation: Ensure good coordination between public administration and other 
stakeholders to improve the planning and implementation of Programme of Measures 
and to monitor their effectiveness. 

Assessment:  Based  on  information  available  in  the  RBMP,  Malta  carried  out  an 
the  planning  and 
extensive  process 

for  stakeholder 

involvement, 

including 

implementation of measures. Consequently, this recommendation has been fulfilled.  

  Recommendation: Ensure effective coordination between WFD and Floods Directive6, 

especially in the elaboration of flood risk and hazard maps.  

Assessment: Malta has  prepared a joint  RBMP and Flood  Risk  Management  Plan for 
the second cycle. On this basis, this recommendation has been fulfilled. 

6   Directive 2007/60/EC on the assessment and management of flood risks entered into force on 26 November 

2007 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32007L0060  

24 

 
 
 
 
                                                      
Topic 2

  Characterisation of the River Basin District 

2.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle  

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

bodies 

The same number of coastal and groundwater bodies was delineated in the second RBMP as 
there were in the first RBMP (Table 2.1 and Table 2.2). Overall there was an increase in the 

total number of surface water bodies from 9 to  19 (Table 2.1). There were no inland surface 
water bodies delineated in the first cycle, but they were reported to be delineated in the second 

cycle.  There  were  two  new  lake  water  bodies,  three  river  water  bodies,  and  five  transitional 
water  bodies.  The  RBMP  explained  that  they  were  delineated  on  the  basis  of  technical 

information  which has become available during the course of the implementation  of the first 
cycle. 

In the second cycle, 53 % of identified surface water bodies were natural with the remainder 
designated  as  heavily  modified.  There  were  no  artificial  water  bodies.  Overall  there  was  an 

increase in the number of heavily modified bodies between the  first and second cycles, from 
two to nine surface water bodies, which included one newly delineated lake, one river and the 

five transitional water bodies (Figure 2.1). The water uses and physical alterations have been 
reported for each heavily modified water body category. 

Table 2.1 

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

Rivers 

Lakes 

Transitional 

Coastal 

Year  RBD 

Number 
of water 
bodies 

2016  MTMALTA 

2010  MTMALTA 

3 

0 

Total 
length of 
water 
body 
(km) 

3.75 

Number 
of water 
bodies 

2 

0 

Total 
area 
(km2) of 
water 
bodies 

0.04 

Number 
of water 
bodies 

5 

0 

Total 
area 
(km2) of 
water 
bodies 

0.12 

Number 
of water 
bodies 

9 

9 

Total 
area 
(km2) of 
water 
bodies 

399 

398 

Source: WISE electronic reporting 

25 

 
 
 
 
 
 
 
Table 2.2 

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

Year 

2016 

2010 

RBD 

Number 

Area (km2) 

Minimum  Maximum  Average 

MTMALTA 

MTMALTA 

15 

15 

0.39 

0.4 

220.4 

217 

23.79 

23.69 

Source: WISE electronic reporting7 

Figure 2.1 

Proportion  of  surface  water  bodies  in  Malta  designated  as  artificial,  heavily 
modified and natural for the second and first cycles. Note that the numbers in 

parenthesis are the numbers of water bodies in each water category  

Source: WISE electronic reporting  

Table 2.3 shows the differences in size distribution of surface water bodies in Malta between 

the second and first cycles. The minimum size and maximum size of coastal water bodies have 
remained  largely  the  same.  The  minimum  size  criteria  were  not  reported  to  WISE  for  the 
catchment area for rivers or the surface area for lakes. However, it is evident that small water 
bodies have been delineated in the second cycle8.  

7   Malta subsequently clarified that the changes in the area of the groundwater bodies between what was reported 
in  2010  and  2016  results  from  changes  in  the  method  of  area  calculation,  which  has  led  to  the  slight 
discrepancies in the extent of the groundwater bodies.  

8   Malta subsequently clarified that the size for river water bodies was reported in terms of area not length in the 
shapefile SurfaceWaterBody_MT_20170206. Section 4.2.1 of the second RBMP provides ‘area of catchment’ 

26 

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

between the two cycles. It also shows that coastal waters and groundwater have remained the 
same and that new river, lake, and transitional water bodies have been delineated. 

Table 2.3 
cycles 

Ye
ar 

20
16 

20
10 

RBD 

MTMA
LTA 

MTMA
LTA 

Size  distribution  of  surface  water  bodies  in  Malta  in  the  second  and  first 

River length (km) 

Lake area (km2) 

Transitional area (km2) 

Coastal area (km2) 

Mini
mum 

Maxi
mum 

Aver
age 

Mini
mum 

Maxi
mum 

Aver
age 

Mini
mum 

Maxi
mum 

Aver
age 

Mini
mum 

Maxi
mum 

Aver
age 

0 

0 

0 

0.01 

0.04 

0.02 

13.34 

96.95 

Source: WISE electronic reporting  

11.4 

98 

44.3
3 

44.2
1 

Table 2.4 

Type of change in delineation of groundwater and surface water bodies in 
Malta between the second and first cycles 

Type of water body change for second cycle 
(wiseEvolutionType) 
aggregation 

changeBothAggregationAndSplitting 

Groundwat
er  

Lake
s 

Rive
rs 

Transition
al 

Coast
al 

changeCode 

changeExtendedArea 

noChange 

creation 

deletion 

splitting 

Total water bodies before deletion 

Delineated for second cycle (after deletion from first 
cycle) 

15 

15 

15 

2 

3 

2 

2 

3 

3 

5 

5 

5 

9 

9 

9 

Source: WISE electronic reporting 

2.1.2 Typology of surface water bodies 

The numbers of water body types for coastal waters has remained the same between the  first 
and  second  cycles.  There  are  an  additional  three  types  in  the  second  cycle  for  the  newly 

and  ‘length  of  watercourses’  for  ‘river  water  bodies’  and  Section  4.2.2  provides  ‘areas  of  water  bodies’  for 
standing waters (‘lakes’). 

27 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                                                                                                                        
delineated  rivers,  lakes,  and  transitional  water  bodies  (Table  2.5).  For  coastal  waters,  the 

typology has been made biologically relevant by using phytoplankton as the single biological 
quality element.  

Member  States  were  asked  to  report  “Not  applicable”  if  there  is  no  corresponding 
intercalibration  type  for  national  water  body  types.  The  coastal  water  body  national  types 

(heavily  modified  and  natural)  have  been  intercalibrated,  but  the  river,  lake,  and  transitional 
water bodies have no equivalent intercalibration types. 

For inland waters, the RBMP states that the physical  descriptors in  System  A and System  B 
were used but are insufficient to precisely characterise the unique waters. Malta is, therefore, 

attempting to use alternative means to characterise the waters where possible. The description 
of  the  characteristics  of  these  water  bodies  is  provided  but  that  types  have  not  been  fully 

established for inland waters. No further information was provided. 

Table 2.5 

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

RBD 

Rivers 

Lakes 

Transitional 

Coastal 

MTMALTA 

2010 

0 

2016 

1 

2010 

0 

2016 

1 

2010 

0 

2016 

1 

2010 

4 

2016 

4 

Source: WISE electronic reporting  

2.1.3 Establishment of reference conditions for surface water bodies 

Table 2.6 shows the percentage of surface water body types in Malta with reference conditions 
established  for  the  first  and  second  cycles.  Type-specific  reference  conditions  have  been 

established  for  relevant  biological  quality  elements  for  all  coastal  water  bodies,  but  not  for 
transitional  water  bodies.  Physico-chemical  quality  elements  and 
rivers, 

lakes,  or 

hydromorphological  quality  elements  reference  conditions  do  not  appear  to  have  been 
established  for  any  water  body  categories.  This  may  lead  to  some  weaknesses  in  the 
classification of status/potential for inland waters9. 

9   Malta subsequently highlighted that the second RBMP (Section 6.2.1) explains why such reference conditions 
cannot  be  established  at  this  stage.  Malta  stated  that  for  inland  surface  water  bodies,  the  characteristic 
hydrological intermittency and complexity renders the hydromorphological and physico-chemical evaluations 
of ecological status extremely difficult and further long-term trend data are necessary. 

28 

 
 
 
 
 
                                                      
Table 2.6 

Percentage of surface water body types in Malta with reference conditions 

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

types in each category 

Water 
category 

Water 
types 

All  

Rivers (1) 

Some 

None 

All  

Lakes (1) 

Some 

Transitional 
(1) 

None 

All  

Some 

None 

All  

Coastal (4) 

Some 

None 

Biological quality 
elements 

Hydromorphological 
quality elements 

Physico-chemical 
quality elements 

100 % 

100 % 

100 % 

100 % 

100 % 

100 % 

100 %  

100 %  

100 % 

100 % 

Source: WISE electronic reporting 

100 % 

100 % 

2.1.4 Characteristics of groundwater bodies 

The geological formation of the aquifer types in which groundwater bodies reside, along with 

the  details  of  whether  groundwater  bodies  are  layered,  have  been  reported.  Further 
characterisation  work  has  been  reported  since  the  first  cycle  with  the  inclusion  of  the 

assessment of linkages with surface water bodies and terrestrial ecosystems, however there was 
no link identified with terrestrial ecosystems10. 

2.1.5 Significant pressures and impacts on water bodies 

In the second RBMP, “anthropogenic pressure  – unknown” was reported to affect the largest 
proportion of surface water bodies (100 %) followed by “point – other” (47 %), and “diffuse - 
other (47 %)” (Figure 2.2). In the first RBMP, Malta only reported pressures at an aggregated 
level.  Overall,  there  was  a  decrease  in  point  source,  diffuse  source,  and  hydromorphological 

pressures (Figure 2.3). 

10   Malta subsequently clarified that the immediate areas around river water bodies are the only places which can 
support  water  dependent  terrestrial  ecosystems,  since  these  are  the  only  areas  where  water  is  naturally 
available.  Hence,  Malta  have  specified  that  the  groundwater  bodies  which  have  been  marked  as  having 
linkages  with  surface  water  bodies  should  also  be  considered  as  having  linkages  with  dependent  terrestrial 
water ecosystems. 

29 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
 
                                                      
For  the  second  RBMP,  it  was  reported  that  14  significant  pressures  were  not  assessed  for 

surface  water,  including  “dams,  barriers  and  locks,  and  physical  alterations”,  although 
hydromorphological  alterations  were  qualitatively  described.  In  addition,  the  main  pressure 
reported was “anthropogenic pressure – unknown”11.  

For  groundwater  bodies,  “diffuse  –  agricultural”  was  reported  most  frequently  (100  %  of 

groundwater  bodies)  (Figure  2.2).  There  were  no  significant  pressures  for  groundwater  that 
were not assessed reported by Malta. 

Figure 2.2 

The  most  significant  pressures  on  surface  water  bodies  and  groundwater 
bodies in Malta for the second cycle12 

11   Malta subsequently clarified that terminology “anthropogenic pressure – unknown”  was used in cases where 
presence of contaminants in surface  water bodies could not be attributed to a particular source. Malta stated 
that this was the case for mercury levels of which concentrations cannot be attributed to either point or diffuse 
sources with certainty. 

12   Malta highlighted that the Point – IED plants in Figure 2.2 was reported as a significant pressure type for the 
Malta Mean Sea Level GWB, however, this it is a reporting error. Malta clarified that given that the  Point – 
IED installations whilst present in the surface catchment area of the groundwater body are not considered as 
significant in terms of the pressures that they can potentially exert on the Malta Mean Sea Level GWB.  

30 

 
 
 
 
 
                                                      
 
Source: WISE electronic reporting  

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

second cycles. Pressures are presented at the aggregated level. Note there were 
19 identified surface water bodies for the second cycle and nine for the first 

cycle. 

Source: WISE electronic reporting 

31 

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

pressure - unknown” in all water body categories (Figure 2.4). It was the only impact reported 
for  rivers,  lakes,  and  transitional  water  bodies.  Chemical  pollution  was  reported  to  be 

impacting 87 % of groundwater bodies. Malta did not report on impacts in the first RBMP. 

Figure 2.4 

Significant impacts on surface water and groundwater bodies in Malta for the 

second cycle. Percentages of number of water bodies  

Source: WISE electronic reporting  

32 

 
 
 
 
 
 
 
2.1.6 Definition and assessment of significant pressures on surface and groundwater 

For  surface  waters,  numerical  tools  and  expert  judgement  were  used  to  define  significant 

pressures from point and diffuse sources, but only expert judgement was used for abstraction 
and water flow pressures. For surface water bodies, the significance of pressures is reported as 

being  linked  to  the  potential  failure  of  objectives,  but  they  were  not  defined  in  terms  of 
thresholds. 

For  groundwaters,  numerical  tools  and  expert  judgement  were  used  to  define  significant 
pressures  from  point  and  diffuse  sources,  abstraction  and  artificial  recharge,  and  other 

pressures.  The  significance  of  pressures  is  reported  to  be  linked  to  the  potential  failure  of 
objectives, but the significance of pressures has not been defined in terms of thresholds. 

There is no detailed information available on the criteria for the identification of pressures, nor 
for the determination of their significance in the second RBMP 13.  

2.1.7 Groundwater bodies at risk of not meeting good status 

87 % of groundwater bodies were reported to be at risk of failing to meet good chemical status. 
The  pollutants  putting  groundwater  bodies  at  risk  of  failing  good  chemical  status  have  been 
reported  for  all  RBDs.  13  %  of  groundwater  bodies  were  reported  to  be  at  risk  of  failing  to 

meet good quantitative status. 

2.1.8 Quantification of the gap and apportionment of pressures  

No  information  was  found  in  the  second  RBMP  relating  to  which  activities/sectors  are 

contributing  significantly  to  the  different  impacts  that  are  causing  failure  of  good  ecological 
status/potential.  

One priority substance (mercury and its compounds) was reported to be causing failure of good 
chemical status in Malta. Malta has not reported to WISE the values of the gap to good status 
for this substance for 2021 (or 2027)14. 

13   Malta  subsequently  clarified  that  the  identification  of  significant  pressures  in  the  second  RBMP  was 
undertaken on the same analytical basis adopted during the development of the first RBMP and therefore was 
not  described  in  the  second  RBMP.  The  significant  pressure  were  analysed  in  terms  of:  (1)  Quantitative 
Pressures:  water  use  assessments  for  the  different  water  using  sectors,  correlated  to  the  water  sourcing 
infrastructure and capacity; and (2) Qualitative Pressures: land use extent, prevailing economic activities and 
typologies.  Malta  stated  that  the  significance  of  such  pressures  was  then  corroborated  through  the  use  of: 
qualitative  and  quantitative  monitoring  data;  the  physical  extent  of  the  particular  activity;  and  the 
environmental  operational  framework  in  force  at  the  site  of  the  activity  (in  the  case  of  highly  significant 
activities).  Malta  also  stated  that  the  identification  of  pressures  where  these  information  are  not  actually 
present is actually difficult to undertake and this is because the development of the RBMP is to be based on 
factual and accurate data. 

33 

 
 
                                                      
2.1.9 Inventories of emissions, discharges and losses of chemical substances 

Article  5  of  the  Environmental  Quality  Standards  Directive15  requires  Member  States  to 
establish an inventory of emissions, discharges and losses of all Priority Substances and other 
pollutants listed in Part A of Annex I of the 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).  

Malta has established an inventory of emissions, however only five Priority Substances were 
included, namely: tributyltin-cation, benzene, lead, nickel, and cadmium. The RBMP explains 

that the “National Inventory of Emissions, Discharges and Losses” for Priority Substances and 
other substances of concern to the surface water environment only covers substances that are 

relevant  in  Maltese  water  bodies.  Criteria  for  relevance  were  not  provided,  but  the  second 
RBMP  explains  that  the  inventory  was  based  on  an  assessment  of  available  ambient 
monitoring  data,  the  use  of  E-PRTR  emissions  and  statistics  on  the  import  of  chemical 

substances to  Malta during a specified time period. This  does not  seem  to  be entirely in  line 
with the Common Implementation Strategy Guidance Document n°28, which recommends that 

“For  the  substances  discarded  (i.e.  for  substances  of  minor  relevance)  MS  [Member  States] 
should  try  to  provide  a  basic  estimation  of  emissions,  discharges  and  losses  from  available 

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

The two step approach from the Common Implementation Strategy Guidance Document n°2816 
has been followed for all substances included in  the inventories. For these substances, Tier 1 

(point  source  information)  was  implemented  (while  the  Guidance  Document  recommends 
implementing at least Tier 1+2 for substances relevant at RBD level). The quality of the input 

data is reported as uncertain. 

14   Malta subsequently clarified that the second RBMP does have measures targeting chemical quality, including 
measures  which  specifically  address  mercury  in  coastal  waters.  Malta  confirmed  that  the  timeframes  for 
achievement  of  good  status  in  this  regard  cannot  be  defined  at  this  stage  and  that  action  is  required  to  be 
undertaken to address uncertainty.   

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

Parliament 

Council 

and 

the 

of 

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

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

34 

 
 
                                                                                                                                                        
2.2  Main changes in implementation and compliance since the first cycle 

Overall, there was an increase in the total number of surface water bodies from 9 to 19. There 

were no inland surface water bodies delineated in the first cycle, but they were reported to be 
delineated in the second cycle. There were two new lake water bodies, three new river water 

bodies, and five new transitional water bodies. There are an additional three water body types 
in  the  second  cycle  for  the  newly  delineated  river,  lake,  and  transitional  water  bodies.  For 

coastal waters, the typology has been made biologically relevant by using phytoplankton as the 
single biological quality element. 

In the second RBMP, “anthropogenic pressure  – unknown” was reported to affect the largest 
proportion of surface water bodies (100 %) followed by “point – other” (47 %), and “diffuse - 

other (47 %)”. In the first cycle, Malta only reported pressures at an aggregated level. Overall, 
there was a decrease in point source, diffuse source, and hydromorphological pressures. 

2.3  Progress with Commission recommendations 

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

  Recommendation:  Delineate  inland  surface  water  bodies  in  the  second  RBMPs  cycle 

and develop reference conditions.  

Assessment: In the second cycle, two lake water bodies, three river water bodies, and 
five  transitional  water  bodies  had  been  delineated.  This  resulted  in  a  significant 

increase  in  the  total  number  of  surface  water  bodies  from  9  to  19.  Type-specific 
reference  conditions  have  been  established  for  relevant  biological  quality  element  for 

all  coastal  water  bodies,  but  not  for  river,  lake,  or  transitional  water  bodies.  Physico-
chemical and hydromorphological quality elements reference conditions do not appear 

to  have  been  established  for  any  water  body  categories.  This  may  lead  to  some 
weaknesses  in  the  classification  of  status/potential.  The  Maltese  RBMP  explains  why 
such reference conditions cannot be established at this stage. For inland surface water 
bodies,  the  characteristic  hydrological  intermittency  and  complexity  renders  the 

hydromorphological  and  physico-chemical  evaluations  of  ecological  status  extremely 
difficult and further long-term trend data are necessary. This recommendation has been 

partially fulfilled.  

  Recommendation: Where there are currently high uncertainties in the characterisation 
of the RBDs, identification of pressures, and in the assessment of status, these need to 

35 

 
 
be addressed in the current cycle, to ensure that adequate measures can be put in place 

before the next cycle. 

Assessment:  For  surface  waters,  numerical  tools  and  expert  judgement  were  used  to 

define significant pressures from point and diffuse sources, and only expert judgement 
was used for abstraction and water flow pressures. For groundwaters, numerical tools 

and expert judgement were used to define significant pressures from point and diffuse 
sources,  abstraction  and  artificial  recharge,  and  other  pressures.  For  surface  and 

groundwater  bodies,  significance  of  pressures  are  reported  as  being  linked  to  the 
potential  failure  of  objectives,  but  they  were  not  defined  in  terms  of  thresholds. 

Therefore, there does not appear to be progress towards the part of the recommendation 
requiring the methodologies to use concrete thresholds or criteria17.  

In terms of apportionment of sources of pressures to economic sectors, this appears to 
have been done for groundwaters with the main significant pressures being “diffuse  – 

agricultural”. However, this has not been carried out for surface waters, where the main 
pressure was reported to be “anthropogenic pressure – unknown” (100 %), followed by 
“point – other” (47 %), and “diffuse – other” (47 %). No information was found in the 

RBMP relating to which activities/sectors are contributing significantly to the different 
impacts that are causing failure of good ecological status/potential. Therefore, there has 

been some progress with this part of the recommendation, but source apportionment is 
required for surface waters18. 

  Recommendation:  Private  groundwater  abstraction  as  a  major  pressure  on 

groundwater bodies should be adequately monitored. 

Assessment:  This  recommendation  applies  to  a  number  of  Topics.  In  terms  of 

characterisation  of  significant  pressures  on  groundwater  quantitative  status, 
“groundwater - alteration of water level or volume” has been identified as a significant 

pressure in 46 % of the groundwater bodies in Malta. The tools used were reported to 

17   Malta  subsequently  stated  that  in  the  case  of  groundwater  bodies,  the  significance  of  pressures  was  also 
correlated  with  monitoring  data,  so  as  to  enable  the  level  of  significance  to  be  identified.  Malta  noted  that 
specific  studies  to  enable  these  issues  to  be  comprehensively  addressed  were  undertaken,  which  led  to  the 
development  of  specific  measures  addressing  these  issues.  Malta  stated  if  further  focused  activities  are 
required, a technical meeting is being requested with the Commission so as to discuss further tools available, 
which Malta would be interested in adopting. 

  Malta  also  stated  that  for  surface  waters,  the  definition  of  thresholds  for  pressures  requires  better 
understanding  of  sources.  Malta  highlighted  that  measures  have  been  included  that  target  the  reduction  of 
current uncertainties, thus working towards definition of thresholds in upcoming cycles. 

18   Malta  subsequently  highlighted  that  measures  have  been  included  that  target  the  reduction  of  current 
uncertainties in source apportionment for surface waters and that source apportionment can be carried out once 
there is more certainty with respect to anthropogenic activity and pressures in surface water bodies. 

36 

 
 
                                                      
be a combination of both expert judgement and numerical models, as well as additional 

direct  monitoring of abstraction through the metering of private groundwater sources. 
Therefore,  in  terms  of  characterisation  of  significant  quantitative  pressures  on 

groundwater the recommendation has been fulfilled. 

37 

 
 
 
 
Topic 3

  Monitoring,  assessment  and  classification  of  ecological 

status in surface water bodies 

3.1  Assessment of implementation and compliance with WFD requirements 

in the second RBMP 

3.1.1 Monitoring of ecological status/potential 

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 first and second RBMPs. It can be seen that no data was reported for the 
first RBMP.  

Table 3.1 

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

reported in the first RBMP, data for the second RBMP 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  

Total by type of site 

0 

0 

0 

0 

0 

0 

5 

5 

Total number of 
monitoring sites used for 

surveillance and/or 
operational monitoring 

First RBMP 

0 

0 

0 

10 

No data reported 

Sources: WISE electronic reporting 

Table  3.2  gives  the  number  of  sites  used  for  different  purposes  for  the  second  RBMP.  The 
purposes  of  monitoring  shows  that  surveillance  and  operational  monitoring  is  only  listed  for 

coastal waters, while for the other water categories the sites are reported to be for the purpose 
of ecological status and chemical status. The reasons why this monitoring is not split into the 

two  different  WFD  monitoring  programmes  may  be:  (i)  insufficient  data  and  knowledge  not 
yet  allowing  status  classification,  or  (ii)  very  few  water  bodies  delineated  for  these  water 

categories. For coastal waters, the number of monitoring sites for ecological status assessment 
of coastal waters (36 sites) is not the same as those given for surveillance (5) and operational 
(5),  but  is  the  same  as  for  State  of  the  Environment  (SOE-EIONET)  monitoring  (36).  The 

38 

 
 
 
 
  
 
reason  for  this  difference  cannot  be  the  same  as  suggested  for  the  other  water  categories, 

because  the  coastal  water  bodies  have  been  classified  for  ecological  status/potential  (see 
below).  

Table 3.2 

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

Monitoring Purpose 

CHE - Chemical status 
ECO - Ecological status 

Rivers 
3 
3 

Lakes 
2 
2 

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

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

OPE - Operational monitoring 
REF - Reference network monitoring site 
SOE - EIONET State of Environment 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 

3 

3 

3 

3 

2 

2 

2 

2 

Source: WISE electronic reporting  

Transitional  Coastal 

5 
5 

5 

5 

5 

5 

15 
36 

13 

26 

5 
2 
36 
5 

11 

36 

Malta subsequently stated that surveillance and operational monitoring stations were identified 

and  used  to  represent  status  at  water  body  level.  The  surveillance  stations  in  some  cases 
coincide  with  protected  areas  or  reference  sites,  while  the  operational  stations  are  linked  to 

pressures. The WFD monitoring stations were supplemented by additional monitoring stations 
that were identified on  a national  scale. While not  part of the WFD monitoring network, the 

national stations supplement such networks by providing further data to better inform the WFD 
and assessment processes. 

Figure  3.1  shows  the  proportion  of  water  bodies  subject  to  surveillance  and  operational 
monitoring. No data were reported for 2010. 

Figure 3.2 shows the proportion of water bodies in each ecological status/potential class that is 
subject to surveillance monitoring. All coastal water bodies at high status were included in the 

surveillance  monitoring  programme.  There  was  no  surveillance  monitoring  in  lakes,  river  or 
transitional water bodies.  

39 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 3.1 

Percentage  of  water  bodies  included  in  surveillance  and  operational 

monitoring  in  Malta  for  the  first  RBMP  (2010)  and  second  RBMP  (2016). 
Note  no  differentiation  is  made  between  water  bodies  included  in  ecological 

and/or chemical monitoring 

Source: WISE electronic reporting  

Figure 3.2 

Proportion  of  water  bodies  in  each  ecological  status/potential  class  that  is 

included in surveillance monitoring in Malta 

Source: WISE electronic reporting. A differentiated presentation between ecological status and potential and 
including all types of quality element can be viewed here - 
https://tableau.discomap.eea.europa.eu/t/Wateronline/views/WISE_SOW_QualityElement_Status_Compare/SWB
_QualityElement_Group?iframeSizedToWindow=true&:embed=y&:display_count=no&:showAppBanner=false
&:showVizHome=no 

40 

 
 
 
 
Transboundary surface water body monitoring 

No  transboundary  water  bodies  were  identified  by  Malta,  and  no  monitoring  sites  were 

reported to be part of international networks (except the State of the Environment monitoring 
stations).  

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  RBMP.  No  differentiation  is  made  between  purposes  of  monitoring.  All  required 

biological  quality  elements  are  monitored  in  each  water  category,  except  fish  in  rivers  and 
lakes.  Malta  subsequently  stated  that  the  reason  is  that  there  are  no  established  fish 

communities in rivers and lakes. All the hydromorphological quality elements are monitored, 
relevant 
except  hydrological  conditions/tidal 

transitional  waters.  All 

regime 

in 

physicochemical quality elements were reported as being monitored in all the water categories, 
except transparency in lakes and transitional waters, although Malta subsequently clarified that 

due to the difficulty in measuring transparency in shallow waters, turbidity was measured. 

Table 3.3 

Quality elements monitored for the second RBMP in Malta (excluding River 
Basin Specific Pollutants). Note; quality element may be used for surveillance 

and/or operational monitoring  

Biological quality elements 

Hydromorphological quality elements 

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

s
e
t
y
h
p
o
r
c
a
M

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

c
i
h
t
n
e
B

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

h
s
i
F

s

m
r
e
p
s
o
i
g
n
A

e
a
g
l
a
o
r
c
a
M

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  No 

Yes  Yes  Yes  Yes  No 

No  No 

No  No 

Transitional 

Yes  Yes  Yes  Yes  Yes  No  No  No  No 

Coastal 

Yes 

Yes 

Yes  Yes  No  No 

y
t
i
u
n
i
t
n
o
C

s
n
o
i
t
i
d
n
o
c

Yes 

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

Yes 

Yes 

No 

Yes 

General physicochemical quality elements 

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

s
n
o
i
t
i
d
n
o
c

No 

l
a
m
r
e
h
T

s
n
o
i
t
i
d
n
o
c

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 

Rivers 

Lakes 

n
e
g
o
r
t
i

N

s
n
o
i
t
i
d
n
o
c

Yes 

Yes 

s
u
r
o
h
p
s
o
h
P

s
n
o
i
t
i
d
n
o
C

Yes 

Yes 

e
t
a
c
i
l
i
S

No 

No 

s
n
o
i
t
i
d
n
o
c

y
t
i
n
i
l
a
S

Yes 

Yes 

s
u
t
a
t
s
n
o
i
t
a
c
i
f
i
d
i
c
A
Yes 

Yes 

41 

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

s
n
o
i
t
i
d
n
o
c

Yes 

Yes 

Yes 

Yes 

r
e
h
t
O

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

s
n
o
i
t
i
d
n
o
c

t
n
e
i
r
t
u
n

No 

No 

 
 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Transitional 

Coastal 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

No 

No 

No 

No 

Source: WISE electronic reporting  

River Basin Specific Pollutants and matrices monitored 

Malta  reported  that  58  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, information from the  RBMP indicated that this 
was  not  the  case  and  only  five  (fluoride,  copper,  chromium,  manganese  and  zinc)  of  the  58 
substances  were  considered  by  Malta  to  be  River  Basin  Specific  Pollutants.  For  the  first 

RBMP, Malta had identified a preliminary list of 10 non-priority specific pollutants considered 
to  be  equivalent  to  River  Basin  Specific  Pollutants.  The  preliminary  list  was  reduced  to  five 

substances using the  results of the first  monitoring campaign for the 10  substances and  from 
the  inventory  of  emissions.  Three  River  Basin  Specific  Pollutants  from  the  preliminary  list 

(beryllium,  boron  and  fluoride)  are  subject  to  further  investigative  monitoring  of  the  water 
body including the main harbour (Marsaxlokk). 

All delineated water bodies are monitored for at least one River Basin Specific Pollutant for all 
water  categories,  except  for  two  coastal  water  bodies  (Table  3.4),  which  is  an  improvement 

since the first RBMP when there was no monitoring of these pollutants reported. Monitoring is 
performed  only  in  sediment  and  is  reported  to  be  for  trend  assessment  (which  might  be  a 

mistake in reporting).  

Minimum  monitoring  frequencies  in  biota  are  specified  for  the  assessment  of  Priority 

Substances  in  Article  3(2)c  of  EQS  Directive  2008/105/EC:  this  is  once  per  year  for 
operational  and surveillance monitoring purposes, unless greater intervals  can be justified on 

the basis of technical knowledge or expert judgment. It thus seems consistent to monitor River 
Basin  Specific  Pollutants  at  the  same  frequency  in  biota,  or  in  sediment,  which  is  also  an 

integrative matrix.  

Monitoring  for  the  five  River  Basin  Specific  Pollutants  has  been  undertaken  once  per  cycle. 

This is not in line with the minimum frequency mentioned above, and it is also lower than the 
minimum  frequency  for  long-term  trend  monitoring  for  priority  substances.  No  explanation 

could be found for these reduced frequencies. Malta mentioned that depending on the results, 
future monitoring will be decided.   

42 

 
 
 
Table 3.4 

Number  of  sites  used  to  monitor  River  Basin  Specific  Pollutants  for  the 

second  RBMP  and  for  the  first  RBMP  in  Malta.  Note  the  data  from  both 
cycles may not be fully comparable as different definitions were used and also 

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

RBMP 

Rivers 

Lakes 

Transitional 

Coastal 

second 

Sites used to monitor River Basin Specific 
Pollutants 

3 

2 

5 

17 

first  

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

NR 

NR 

NR 

NR 

Source: WISE electronic reporting. NR = not reported 

Use of monitoring results for classification 

Coastal  water  bodies  were  the  only  category  where  biological  quality  elements  were  used  in 

the  classification  of  ecological  status/potential:  the  classification  was  solely  based  on 
monitoring  results.  General  physicochemical  quality  elements  were  also  used  and  based  on 

monitoring  results.  River  Basin  Specific  Pollutants  were  not  used  in  the  classification  even 
though they were monitored in sediment. Hydromorphological quality elements were reported 

to be monitored, but were not used in the subsequent classification.  

The  classification  of  the  ecological  status/potential  of  lakes  and  rivers  was  only  based  on 

physicochemical quality  elements including River Basin Specific Pollutants which were only 
monitored in sediment, even though biological and hydromorphological quality elements were 

reported  to  be  monitored  (but  not  as  part  of  surveillance  or  operational  monitoring 
programmes). However, for transitional water bodies, the status classification was also based 

on morphological conditions, as well as the physicochemical quality elements including River 
Basin  Specific  Pollutants  which  again  were  only  monitored  in  sediment.  As  for  lakes  and 

rivers,  biological  quality  elements  were  also  reported  to  be  monitored,  though  not  part  of 
operational or surveillance monitoring programmes. 

3.1.2 Ecological Status/potential of surface water  

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

43 

 
 
 
All  the  rivers,  lakes  and  transitional  waters  have  unknown  ecological  status/potential  due  to 

lack  of  knowledge,  data,  and  assessment  methods.  The  distribution  of  status  classes  for 
classified water bodies shown in the map is therefore only representing coastal waters. Figure 

3.3 shows the confidence in the classification of ecological status/potential. The confidence for 
water  bodies  with  unknown  ecological  status/potential  (rivers,  lakes,  and  transitional  waters) 

was  reported  as  medium  (which  may  be  a  reporting  error).  The  coastal  water  bodies  are  all 
classified  with  high  confidence  based  on  classification  of  all  the  required  biological  and 

physico-chemical  quality  elements,  although  the  hydromorphological  quality  elements  have 
not been used.  

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

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

Source: WISE electronic reporting  

44 

 
 
 
 
 
Map 3.1 

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

most recently assessed status/potential of the surface water bodies 

High 

Good 

Moderate 

Poor  

Bad 

Unknown 

River Basin Districts 

Countries outside the European Union 

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

A differentiated presentation of this data between ecological status and potential and including all types of quality 
element can be viewed here - 
https://tableau.discomap.eea.europa.eu/t/Wateronline/views/WISE_SOW_QualityElement_Status_Compare/SWB
_QualityElement_Group?iframeSizedToWindow=true&:embed=y&:display_count=no&:showAppBanner=false
&:showVizHome=no 

Figure 3.4 compares the ecological status of surface water bodies in Malta for the first RBMP 

with that for the second RBMP (based on the most recent assessment of status/potential) and 
that  expected  by  2015).  It  should  be  noted  that  there  were  only  coastal  waters  in  the  first 

RBMP and all the “unknown” status relates to the new lake, river and transitional water bodies.  

45 

0510kmMTMALTAMT 
 
 
  
  
  
  
  
  
  
  
 
 
The proportion expected to be in good or better status in 2015 shows that the majority of water 

bodies are expected to  achieve the good status  objective by 2015. However, this is  uncertain 
because of the large quantity of water bodies with unknown status.  

Figure 3.4  Ecological status or potential of surface water bodies in Malta for the second 
RBMP,  for  the  first  RBMP  and  expected  in  2015.  The  number  in  the 

parenthesis  is  the  number  of  surface  water  bodies  for  both  cycles.  Note  the 
period  of  the  assessment  of  status  for  the  second  RBMP  was  2012  and  only 

includes coastal waters. The year of the assessment of status for first RBMP is 
not known. 

Source: WISE electronic reporting  

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

ecological  status/potential.  The  information  for  Malta  is  shown  in  Figure  3.5.  The  time  for 
achieving  the  objectives  is  unknown  for  a  large  proportion  of  transitional  waters,  rivers,  and 

lakes. Most of the coastal water bodies are expected to be in good status already in 2015, while 
the rest are expected to achieve good status during the period 2016-2021.  

46 

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

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

Source: WISE electronic reporting  

Classification of ecological status in terms of each classified quality element 

Figure 3.6 shows that most of the coastal water bodies are in good or high status for each of the 

biological  quality  elements.  According  to  the  information  reported  in  WISE,  the  biological 
quality elements have not been classified in the other water categories: a status assessment of 

the biological quality elements was not carried out because no potential classification method 
was identified due to the paucity of data and limited knowledge about these waters.  

The  WISE  reporting  on  the  use  of  biological  quality  elements  differs  from  the  information 
provided  by  Malta  in  the  framework  of  the  assessment  of  ex-ante  conditionalities  for  EU 

funding.  In  this  framework,  Malta  mentioned  that  in  coastal  waters,  only  macroalgae  and 
angiosperms  were  used  as  biological  quality  elements  and  that  the  remaining  two  biological 

quality elements (benthic invertebrates and phytoplankton) could not be intercalibrated due to 
data  and  methodological  problems  encountered.  Malta  subsequently  clarified  that  the  status 

assessment for benthic invertebrates and phytoplankton  was based on monitoring results that 

47 

 
 
 
have  not  been  successfully  intercalibrated,  but  have  been  used  in  the  interim  until  further 

monitoring and the second intercalibration phase has been carried out. 

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

classification of coastal waters in Malta. Note that water bodies with unknown 
status/potential have been excluded from the presentation 

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 

be  treated  with  some  caution  as  there  are  differences  between  the  numbers  of  surface  water 
bodies classified for individual elements from the first to the second RBMP. The only quality 

element  that  were  reported  in  both  the  first  and  second  RBMPs  is  angiosperms  in  coastal 
waters, which shows an improvement from 60 % to 100 % in good or high status. 

48 

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

biological  quality  elements  in  rivers  and  lakes  between  the  first  and  second 
RBMPs  

Source: WISE electronic reporting 

Figure 3.8 and Figure 3.9 illustrate the basis of the classification of ecological status/potential 
(or unknown status) of surface water bodies for the second RBMP. The figures show that most 

of  the  classification  is  based  on  physicochemical  quality  elements,  except  in  coastal  waters, 
where  also  the  biological  quality  elements  are  classified.  The  hydromorphological  quality 
elements  are  not  used  in  any  water  category  except  two  transitional  water  bodies  where 

morphological  conditions  have  been  classified.  The  River  Basin  Specific  Pollutants  are 
classified  in  all  water  bodies  in  rivers,  lakes,  and  transitional  waters,  but  are  not  used  for 

classification of coastal waters.  

The  classification  of  the  individual  quality  elements  is  illustrated  in  Figure  3.10.  All  the 

classified  quality  elements  in  all  the  water  categories  are  based  on  monitoring,  and  none  are 
based on grouping or expert judgement. 

49 

 
 
 
 
 
Figure 3.8 

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

in Malta using 1, 2, 3 or 4 types of quality element 
Note:  The  four  types  are:  biological;  hydromorphological,  general  physico-chemical  and  River  Basin 
Specific Pollutants. 

Source: WISE electronic reporting 

Figure 3.9 

The  percentage  of  surface  water  bodies  in  Malta  where  no  biological, 
hydromorphological,  general  physico-chemical  quality  elements,  nor  River 
Basin  Specific  Pollutant  have  been  used  in  the  classification  of  ecological 

status or potential 

Source: WISE electronic reporting  

50 

 
 
 
 
 
 
 
Figure 3.10  Basis  of  the  classification  of  ecological  status/potential  in  Malta.  The 

percentages are in terms of all waterbodies in each category 

Source: WISE electronic reporting 

51 

 
 
 
 
Assessment methods and classification of biological quality elements 

Malta highlighted that there are knowledge gaps on the natural biological conditions of rivers, 

lakes and transitional waters. This is the reason why biological reference conditions could not 
be established, obstructing the assessment and classification of biological quality elements in 

these water categories.  Malta further points out that they are “at a stage of testing methods”. 
This testing seems to require further data and knowledge for Mediterranean rivers and lakes.  

Intercalibration has only been achieved for macroalgae and angiosperms in coastal waters, but 
it is not clear whether the results were used in the second RBMP, because the intercalibrated 
boundaries were only reported in the Intercalibration Official Decision in 2018 (not in 2013)19. 
For the other quality elements in coastal waters (phytoplankton and benthic invertebrates), the 

intercalibration process could not be completed. For the other water categories, there were no 
classification methods  developed for any of the biological  quality elements,  and therefore no 

intercalibration.  

Assessment methods for hydromorphological quality elements 

Hydromorphological  assessment  methods  have  not  been  developed,  except  morphological 
conditions  in  transitional  waters.  The  basis  for  the  methodology  is  unclear,  as  reference 

conditions have not been reported. 

Assessment methods for general physicochemical quality elements 

There are no reference conditions or standards reported for any of the physicochemical quality 

elements,  due  to  lack  of  data  and  knowledge.  It  is  therefore  surprising  that  these  quality 
elements are still used for classification of ecological status of all water bodies in all the water 

categories. It is also indicated in the RBMP that the current classification of nutrients in coastal 
waters  is  based  on  an  interim  approach  adopting  chlorophyll  boundaries  from  Greece  and 
Cyprus and using the eutrophication scale provided in Simboura et al. 200520 for assessing the 
phytoplankton  chlorophyll  a  status.  It  is  not  clear  whether  this  scale  has  also  been  used  to 

derive interim class boundaries for nutrients.  

It is therefore likely that the assessment methods for physicochemical quality elements are not 

linked to the relevant biological quality elements.  

19   Malta  subsequently  stated  that  the  intercalibrated  boundaries  for  macroalgae  and  angiosperms  in  coastal 

waters were used for assessment purposes. 

20   Simboura, N., Panayotidis, P., Papathanassiou, E., 2005. A synthesis of the biological quality elements for the 
implementation  of  the  European  Water  Framework  Directive  in  the  Mediterranean  ecoregion:  the  case  of 
Saronikos Gulf. Ecol. Indic. 5, 253–266. 

52 

 
 
                                                      
Malta subsequently stated that the status classes for nutrients are still to be determined on the 

basis of longer-term data. In the interim, nutrients data were analysed in terms of distribution 
of  nutrient  concentrations  across  monitoring  stations,  also  in  relation  to  pressures.  Expert 

judgement was employed for determination of ecological status. 

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

The  selection  of  River  Basin  Specific  Pollutants  is  reported  to  be  based  on  an  inventory  of 

emissions,  of  substances  and  the  results  of  monitoring  in  sediments  (only).  Environmental 
Quality Standard values are reported for sediment for the five substances that were found after 

the  monitoring  and  emissions  inventory:  copper,  chromium,  manganese,  zinc,  and  fluoride. 
There  are  different  environmental  quality  standard  values  reported  for  the  different  water 

categories:  standards  for  five  substances  were  applied  to  rivers,  lakes  and  transitional  waters 
and  three  (chromium  copper  and  zinc)  to  coastal  waters.  However,  River  Basin  Specific 

Pollutants did not seem to be included in status assessment in coastal waters. 

The only  exceedance of  Environmental Quality Standards reported was in a lake water body 
and was for zinc. 

The Environmental Quality Standards for River Basin Specific Pollutants were not derived in 
accordance with the 2011 Technical Guidance Document No 2721. 

The analytical methods used for the River Basin Specific Pollutants do not meet the minimum 
performance  criteria  laid  down  in  Article  4.1  of  the  Quality  Assurance/Quality  Control 
Directive (2009/90/EC)22, nor with the requirements laid down in Article 4.2 of the Directive 
for the strictest standard applied.  

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

The  one-out,  all-out  principle  has  been  used  for  coastal  waters,  which  is  the  only  water 
category  where  the  biological  quality  elements  have  been  classified.  However,  the  details  of 

the combination rules were not reported.  

3.2  Main changes in implementation and compliance since the first RBMP 

Monitoring has been established for all the required quality elements in coastal waters, and for 
most of the required quality elements in rivers, lakes, and transitional waters, in contrast to the 
first RBMP, when there was no monitoring reported. Though not all required biological quality 

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

WFD%2027%20EC%202011.pdf 

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

53 

 
 
                                                      
elements  and  hydromorphological  quality  elements  are  monitored  in  these  three  categories 

(such as fish in transitional waters), this expanded monitoring programme shows considerable 
progress since the first RBMP. There is also now monitoring of River Basin Specific Pollutants 

in  sediment,  and  in  all  water  categories,  indicating  that  there  has  been  progress  also  in  this 
aspect since the first RBMP. 

Ecological  status  for  angiosperms in  coastal  waters has improved since the  first RBMP from 
60  %  to  100  %  in  good  ecological  status.  For  the  other  water  categories,  no  changes  in 

ecological  status  can  be  evaluated  because  of  lacking  information  on  assessment  and 
classification in the first RBMP. 

The confidence in  the classification of ecological status  in  coastal waters has improved from 
low-medium in the first RBMP to high in the second, because the classification was based on 

only angiosperms in the first RBMP, while it is now based on all the required biological and 
physicochemical quality elements.  

3.3  Progress with Commission recommendations 

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

  Recommendation:  Ensure  in  the  second  RBMPs  cycle  a  fully  operational  monitoring 
programme,  covering  at  least  the  following  topics:  groundwater  chemical  status 

(nitrate  levels  in  the  annual  recharge),  groundwater  quantitative  status,  the  inland 
surface water bodies (considering all WFD quality elements), the identification of river 

basin-specific pollutants, and protected areas.  

Assessment:  Malta’s  monitoring  programme  in  coastal  waters  covers  all  relevant 

quality  elements,  however  there  are  still  limitations  in  the  way  River  Basin  Specific 
Pollutants  are  monitored  (no  explanation  could  be  found  for  the  lower  than 

recommended  monitoring  frequencies,  and  the  monitoring  does  not  seem  to  be 
performed in accordance with Directive 2009/90/EC). In addition, there are still large 

uncertainties  relating  to  monitoring  of  rivers,  lakes  and  transitional  waters.  For 
example, apparent monitoring of these three water categories is said to be for ecological 

status  but  has  not  been  reported  as  being  for  WFD  surveillance  or  operational 
monitoring.  The  reasons  why  this  monitoring  is  not  split  into  the  two  different  WFD 

monitoring programmes  may be:  (i) insufficient  data and knowledge not  yet  allowing 
status classification, or (ii) very few water bodies delineated for these water categories.  

54 

 
 
Therefore this recommendation has only been partially fulfilled23.  

  Recommendation:  Methodologies  and  assessment  methods  for  biological  quality 
elements and other quality elements should be established for good ecological status. 

Assessment:  A  method  for  classification  of  macroalgae  in  coastal  waters  has  been 
developed/adopted  from  neighbouring Member Status and successfully intercalibrated 

together  with  the  method  for  angiosperms.  Monitoring  has  started  for  all  the  other 
required  and  relevant  biological  and  supporting  quality  elements  in  all  the  water 

categories,  to  obtain  data  for  developing  the  classification  methods  for  those  quality 
elements.  The  physicochemical  quality  elements  are  also  classified.  Therefore,  there 

has been some progress with this recommendation. However, data and knowledge are 
still  insufficient  for  establishing  the  assessment  methods,  so  it  is  not  yet  possible  to 

assess  the  ecological  status  for  biological  quality  elements  for  lakes,  rivers  and 
transitional waters. This  is  also  related  to  the temporary nature of the inland water of 

Malta,  as  well  as  to  the  lack  of  reference  sites  regarding  the  definition  of  natural 
reference  conditions.  Moreover,  the  current  methods  used  for  classification  of 

ecological status for the physicochemical quality elements are not linked to good status 
for the relevant biological quality elements (also for coastal waters, where good status 

class boundaries have been intercalibrated for macroalgae and angiosperms). 

Therefore this recommendation has been partialy fulfilled.  

  Recommendation: River Basin Specific Pollutants will need to be identified, with clear 
information  on  how  pollutants  were  selected,  how  and  where  they  were  monitored, 

where there are exceedances and how such exceedances have been taken into account 
in  the  assessment  of  ecological  status.  Environmental  quality  standards  should  be 

derived for all River Basin Specific Pollutants. 

Assessment:  Five  River  Basin  Specific  Pollutants  have  been  identified,  which 

constitutes an improvement compared to the  first RBMP, in which no such substance 
was  identified.  (It  is  interesting  to  note  that  monitoring  was  reported  in  all  water 

categories,  which  also  constitutes  a  significant  improvement  compared  to  the  first 
RBMP where no such  monitoring existed). However, the information reported on the 

monitoring and on the Environmental Quality Standards derived does not always seem 
consistent.  

23   Malta has subsequently clarified that the monitoring programme for inland surface water is an iterative process 

and will be improved upon as more knowledge is gained.  

55 

 
 
                                                      
Environmental  quality  standard  values  are  reported  for  sediment  for  five  substances, 

however  one  of  these  five  substances  seem  not  to  have  actually  been  identified  as  a 
River  Basin  Specific  Pollutant  by  Malta.  No  Environmental  Quality  Standard  was 

reported for one of the substances identified as a River Basin Specific Pollutant. There 
are  different  environmental  quality  standard  values  reported  for  the  different  water 

categories, however River Basin Specific Pollutants were not taken into account in the 
assessment  of  status  in  coastal  waters.  The  2011  Technical  Guidance  Document  No  27 

has not been used to set the environmental quality standard values.  

There has been progress on this recommendation, it has been partially fulfilled.  

  Recommendation: Use the inventory of emissions to review the monitoring programme 
and  the  list  of  River  Basin  Specific  Pollutants  for  the  second  RBMPs,  and  to  identify 

appropriate measures against chemical pollution. 

Assessment: The selection of River Basin Specific Pollutants now seems to be based on 

an  inventory  of  emissions,  supported  by  information  on  the  substances  imported  and 
using  the  results  of  monitoring  in  sediments.  However  the  information  reported  on 

which substances were identified as River Basin Specific Pollutants is unclear. It is also 
unclear whether diffuse sources were taken into account (it is somewhat surprising that 

only metals have been selected). 

Therefore this recommendation has been partially fulfilled.  

  Recommendation: Where there are currently high uncertainties in the characterisation 
of the RBDs, identification of pressures, and in the 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:  This  recommendation  relates  to  a  number  of  Topics  in  terms  of 
uncertainty in ecological status classification coastal water bodies are all classified with 
high  confidence  based  on  classification  of  all 
the  required  biological  and 
physicochemical quality elements. However, inland waters are of unknown status with 

medium confidence. 

Therefore this recommendation has been partially fulfilled.  

56 

 
 
 
Topic 4

  Monitoring,  assessment  and  classification  of  chemical 

status in surface water bodies 

4.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle  

4.1.1 Monitoring of chemical status in surface waters 

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

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

ecological status/potential and chemical status.  

Surveillance monitoring programmes should allow Member States to supplement and validate 

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

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

from the programme of measures. 

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

monitoring programmes in Malta for the second RBMP.  

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

surface  waters  for  the  second  RBMP.  According  to  the  WFD,  chemical  status  should  be 
monitored  and  assessed  up  to  12  nautical  miles;  however  territorial  waters  have  not  been 

identified, monitored or assessed by Malta. In this figure, no distinction is made between sites 
used for surveillance and/or operational purposes. More detailed information can be found on 
the website of the European Environment Agency24. 

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

57 

 
 
                                                      
Figure 4.1 

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

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

purpose 

Source: WISE electronic reporting 

All  sites  are  used  for  the  monitoring  of  ecological  and  chemical  status  of  rivers,  lakes  and 

transitional waters, 47 % of coastal sites are monitored for chemical status, whereas all coastal 
sites  are  monitored  for  ecological  status.  Between  the  two  RBMPs,  there  has  been  a  net 

increase  in  the  number  of  sites  used  to  monitor  chemical  status  (reaching  17,  2,  3  and  5  for 
coastal, lake, river and transitional water bodies respectively in the second RBMP) and a net 

increase in the number of water bodies monitored for chemical status (7, 2, 3 and 5 for coastal, 
lake, river and transitional water bodies respectively in the second RBMP). This includes both 

an  increase  in  monitoring  of  coastal  water  bodies  and  monitoring  of  the  newly  delineated 
freshwater bodies. 

Figure 4.2 summarises the proportion of water bodies monitored for chemical status in surface 
waters  for  the  second  RBMP.  In  this  figure,  no  distinction  is  made  between  water  bodies 

monitored for surveillance and/or operational purposes. Also given is the proportion of water 
bodies monitored for any purpose and, for comparative purpose, those for ecological status. 

58 

 
 
 
Figure 4.2 

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

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

bodies in that category 

Source: WISE electronic reporting 

In  all  water  categories  apart  from  coastal  waters,  all  surface  water  bodies  are  monitored  for 
chemical status; 78 % of coastal water bodies are monitored.  

All  nine  coastal  water  bodies  were  reported  to  be  failing  to  achieve  good  chemical  status. 
Seven (78 %) of these water bodies were monitored for operational purposes. No other surface 

water bodies were reported to be failing to achieve good chemical status. 

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

biota for status assessment 

Monitoring for status assessment 

Requirements 

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

assessment  of  the  status  of  surface  water  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  the  chemical  status  of  all  water  bodies  in  the 
RBD. According to the EQS Directive (version in force in 2009), mercury, hexachlorobenzene 

59 

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

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

Spatial coverage 

Malta  reports  that  78  %  of  coastal  water  bodies  are  monitored  for  more  than  10  Priority 

Substances and this increases to 100 % for river, lake, and transitional water bodies.  

There  is  one  chemical  monitoring  site  in  each  lake,  river  and  transitional  water  body,  which 

constitutes  a  very  thorough  spatial  coverage  in  terms  of  waterbodies  monitored.  For  coastal 
water  bodies,  seven  out  of  the  nine  water  bodies  are  reported  to  be  monitored  for  chemical 

status using 17 monitoring sites. (The presence of several monitoring sites in one water body, 
as  is  the  case  in  monitored  coastal  waters  in  Malta,  allows  reaching  higher  precision  in  the 

assessment, especially for larger waterbodies). 

According to WISE, monitoring of sediments and/or biota is not reported to be used for status 

assessment in Malta. Mercury, hexachlorobenzene and hexachlorobutadiene were monitored in 
Posidonia  oceanica  in  coastal  waters,  but  no  corresponding  environmental  quality  standard 
seems to have been derived. 

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 in water were reported for 36 Priority Substances at site level. Priority 
substances  were  monitored  12  times  per  year  every  three  years  in  coastal  waters  and  three 
times  a  year  every  three  years  in  river,  lake,  and  transitional  water  bodies.  However,  the 

frequency for sevenPriority Substances in the water column for inland waters (rivers, lakes and 
transitional)  dichloromethane,  di(2-ethylhexyl)phthalate,  fluoranthene,  lead,  mercury,  nickel, 

and trichloromethane is expected to increase to six times per year, but it is not clear whether 
this  will  be  maintained  in  every  year  in  the  cycle  or  every  three  years  as  for  the  other 

substances.  

60 

 
 
It is clear, therefore, that the monitoring frequency for some Priority Substances in the water 

column in coastal waters meets the minimum intra-annual frequency of 12 times per year but 
for others, and especially in inland waters, the frequency is lower. No information was found 

on  how  these  reduced  frequencies  have  been  chosen  (expert  judgment,  technical  knowledge, 
others). 

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  substances25  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 

Malta reports that arrangements are in place for the long-term trend analysis of concentrations 

of those Priority Substances that tend to accumulate in sediment and/or biota. 

Malta  has  monitored  in  sediment  and/or  biota  all  14  relevant  Priority  Substances  mentioned 
above  in  coastal  water  bodies,  and  13  of  them  in  lake,  river,  and  transitional  water  bodies. 

Malta  has  monitored  3  of  the  14  of  the  Priority  Substances  in  biota  in  coastal  water  bodies 
(hexachlorobenzene, mercury and hexachlorobutadiene). The RBMP indicates that monitoring 

in  biota  in  coastal  waters  is  undertaken  in  Posidonia  rhizomes  and  will be  maintained  in  the 
second cycle to establish trends. Monitoring in other biota is also reported to be planned. 

From  a  water  body  perspective,  monitoring  of  sediments  has  been  fairly  comprehensive 
covering  all  lake,  river  and  transitional  water  bodies  and  seven  out  of  nine  coastal  water 

bodies. A similar situation is presented for the three substances in biota but with six of the nine 
coastal water bodies reported to have been monitored. 

Frequencies 

With  regard  to  monitoring  in  sediment  and/or  biota  for  assessment  of  trends,  the  minimum 

frequency  is  once  every  three  years  (Article  3(3)  of  the  EQS  Directive)  unless  technical 
knowledge and expert judgement justify another interval. 

25   Anthracene,  brominated  diphenylether, 

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

chloroalkanes,  DEHP, 

cadmium,  C10-13 

61 

 
 
                                                      
Sediment and biota have been monitored once (in 2012) with monitoring in subsequent  years 

to  be decided. The  reporting provided no information on whether subsequent  monitoring has 
been carried out. 

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. 

Section 2.1.9 of this report describes the implementation of the requirement for establishing an 
inventory  of  emissions  in  Malta.  All  Priority  Substances  identified  as  discharged  are 

monitored.  However,  the  list  of  Priority  Substances  in  the  inventory  is  limited  to  5,  so  it  is 
unclear whether all discharged priority substances have been identified.  

It  should  be  noted  however  that  39  groups  of  priority  substances  are  monitored  in  Malta, 
according to WISE.  

Malta  provided  a  statement  with  regard  to  monitoring  of  Priority  Substances  and  their 
inclusion in an inventory.26 

26   The compilation of the inventory is based on the results of the monitoring data, the E-PRTR emissions data 
and  importation  data.  It  should  be  noted  that  the  data  presented  in  the  RBMP  is  based  on  the  first  baseline 
surveys  for  surface  waters  carried  out  in  2012-2013.  For  the  purpose  of  the  baseline  surveys,  all  priority 
substances  were  monitored  in  order  to  provide  a  complete  picture  of  the  presence  (or  otherwise)  of 
contaminants in the water bodies. Therefore priority substances were monitored even if there was no evidence 
of discharge. Most of these chemicals were below detection limits, and hence of limited relevance to surface 
waters and the inventory. This explains the discrepancy between the number of substances monitored as part 
of  the  baseline  survey  and  the  number  of  substances  in  the  inventory.  On  the  other  hand,  Malta’s  second 
RBMP notes that the assessments made in this inventory are considered to be draft and preliminary; containing 
a considerable degree of uncertainty due to an incomplete dataset of information and it is therefore subject to 
modification in the light of data.   

62 

 
 
                                                      
Performance of analytical methods used  

In Malta, for all monitored Priority Substances the analytical methods used meet the minimum 
performance  criteria  laid  down  in  Article  4(1)  of  the  Technical  specifications  for  chemical 
analysis and monitoring of water status27 for the strictest standard applied.  

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

quantification is as specified in Article 5 of the Technical specifications for chemical analysis 
and monitoring of water status in Malta.  

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. For Malta, the assessment of chemical status was undertaken between 2011 and 2013; 
the  RBMP  confirms  that  a  water  column  survey  of  surface  freshwaters  was  undertaken 
between  December  2011  and  February  2012  supplemented  with  a  one-week  survey  in 

freshwater sediments in 2013 and with coastal monitoring undertaken between 2011 and 2013. 

The one-out-all-out principle was applied to assess chemical status. 

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

The  assessment  of  chemical  status  for  the  second  RBMP  was  expected  to  be  based  on  the 
standards laid down in the EQS Directive (version in force on 13 January 2009 

28).  Some  Member  States  did  not  fully  implement  the  Directive  in  the  first  RBMPs  as  the 
transposition deadline was in July 2010, after the adoption of the first RBMPs. 

27   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  

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

63 

 
 
                                                      
Map 4.1 

 Chemical status of surface water bodies in Malta based on the most recently 
assessed status of the surface water bodies  
Note: Standard colours based on WFD Annex V, Article 1(4)(3).  

Source: WISE, Eurostat (country borders) 

The  chemical  status  of  surface  waters  in  Malta  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 Agency29.  

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

64 

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

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

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

laid  down  in  EQS  Directive  (version  in  force  on  13  January  2009.  Some 
Member States did not fully implement the Directive in the first RBMPs as the 

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

Category 

Second RBMP 
Rivers (3) 

Lakes (2) 

Transitional (5) 

Coastal (9) 

Total (19) 

First RBMP 
Coastal (9) 

Total (9) 

Good 

Failing to achieve good 

Unknown 

Number 

% 

Number 

% 

Number 

% 

3 

2 

5 

100 % 

100 % 

100 % 

10 

53 % 

9 

9 

100 % 

47 % 

Source: WISE electronic reporting 

9 

9 

100 % 

100 % 

It should be noted that there has been a re-delineation of water bodies between the two RBMP. 
Overall, the number of surface water bodies has increased from 9 in the  first RBMP to 19 in 

the  second  cycle  as  RBMP  has  delineated  surface  freshwater  bodies  in  response  to  the 
Commission’s  recommendation  in  the  first  RBMP.  In  terms  of  chemical  status  for  coastal 

waters, it has changed from unknown to failing to achieve good chemical status and the newly 
delineated  freshwater  bodies  have  been  classified  as  good  chemical  status.  In  terms  of  the 

Natural/Heavily Modified water body categorisation, the proportion of water bodies with good 
chemical  status  is  78  %  for  heavily  modified  and  30  %  for  natural  water  bodies.  This 

represents a very significant improvement in knowledge. 

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

All  of  the  classifications  are  given  a  medium  level  of  confidence  according  to  information 
reported  to  WISE.  However,  the  RBMP  reported  classifications  with  both  high  and  medium 

confidence  but  no  further  information  on  the  methodology  for  assessing  confidence  and 
precision.  Confidence  in  the  classification  of  chemical  status  for  the  first  RBMP  was  not 

reported. 

65 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 4.3 

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

Malta based on the most recently assessed status/potential 

Source: WISE electronic reporting  

Figure 4.4 compares the chemical status of surface water bodies in Malta for the  first RBMP 
with that for the second (based on the most recent assessment of status) and that expected by 
2015.  There  was  a  large  decrease  in  the  proportion  of  surface  water  bodies  classified  as 

“unknown” in the second RBMP compared to the first. The actual proportion of water bodies 
reported to be at good status in the second RBMPs (53 %) matched what was expected by the 

end of 2015. 

Malta  assessed  the  status  of  the  two  unmonitored  coastal  water  bodies  based  on  expert 

judgment. 

66 

 
 
 
 
 
 
Figure 4.4 

Chemical  status  of surface water bodies in Malta  for the second RBMP, for 

the  first RBMP  and  expected  in  2015.  The number  in  the  parenthesis  is  the 
number  of  surface  water  bodies  for  both  cycles.  Note  the  period  of  the 
assessment of status for the second RBMP was 2011 to 2013. The year of the 
assessment of status for first RBMP is not known 

Source: WISE electronic reporting  

Directive  2013/39/EU  amended  the  EQS  Directive.  In  particular,  it  set  more  stringent 
environmental  quality  standards  for  seven  substances30.  Member  States  were  required  to 
indicate if the new standard caused the status of the surface water body to appear to deteriorate. 
This was the case for 63 % surface water bodies in terms of lead, 56 % for fluoranthene, and 

38 % for nickel in Malta across all water categories. Good chemical status should be reached 
by 2021 in relation to the revised environmental quality standards, unless Member States apply 

exemptions under WFD article 4(4) and/or less stringent objectives under WFD article 4(5). 

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

status.  The  information  for  Malta  is  shown  in  Figure  4.5.  No  information  was  reported  to 
WISE or in the RBMP on when good chemical status of coastal water bodies is expected to be 

achieved:  Malta  clarified  that  the  date  of  achievement  of  good  status  is  unknown  for  this 
category  of  water.  No  data  on  the  expected  achievement  of  good  status  was  reported  in  first 

cycle. Rivers, lakes and transitional waters were assessed and reported as being at good status 
within the second RBMP, and the status is expected to remain the same in 2015.  

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

compounds, Polyaromatic hydrocarbons (PAH) 

67 

 
 
 
 
                                                      
Figure 4.5 

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

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

Source: WISE electronic reporting 

Priority Substances causing the failure of good chemical status 

Member  States  were  expected  to  report  exceedances  based  on  the  revised,  more  stringent 

Environmental Quality Standards from Directive 2013/39/EU. However from the figure below, 
it is assumed that the initial standards were used to report exceedances (more substances were 

reported to cause failure based on the 2013 standards). 

A  single  Priority  Substance  (mercury)  was  reported  to  be  causing  failure  to  achieve  good 
chemical  status  in  surface  water  (coastal)  bodies  in  Malta  (Figure  4.6).  Exceedances  were 
reported for the annual average values of the environmental quality standard of this substance 

and not for the maximum allowable concentration.  

68 

 
 
 
 
 
 
 
Figure 4.6 

The  top  Priority Substances causing failure to  achieve good chemical status 

in surface water bodies in Malta 

Ubiquitous persistent, bioaccumulative and toxic Priority Substances 

Source: WISE electronic reporting   

According  to  article  8(a)  of  the  EQS  Directive31,  eight  priority  substances  and  groups  of 
priority  substances  are  behaving  like  ubiquitous,  persistent,  bioaccumulative  and  toxic 
substances32.  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  progress  made  in  tackling  other  priority  substances,  Member 

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

Mercury  was  the  only  substance  reported  to  be  causing  the  failure  of  surface  water  bodies 
(coastal water bodies only) to meet good chemical status, based on the environmental quality 

standards  in  force  in  2009.  The  influence  of  these  ubiquitous  persistent  and  bioaccumulative 
substances on the overall chemical status is very significant as illustrated in the 2018 State of 
Water report of the European Environment Agency33. 

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

PFOS, dioxins, hexabromocyclodecane and heptachlor 

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

interactive format at :  
https://tableau.discomap.eea.europa.eu/t/Wateronline/views/WISE_SOW_SWB_Chemical_Status_Maps/SW
B_Failing_Good_Chemical_Status_RBD?iframeSizedToWindow=true&:embed=y&:showAppBanner=false&
:display_count=no&:showVizHome=no  

69 

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

Malta reported that 39 Priority Substances were both monitored and used in the assessment of 
chemical status. The remaining Priority Substances were not monitored but are included in the 

assessment  of  chemical  status,  they  are:  octylphenol  (4-(1,1',3,3'-tetramethylbutyl)-phenol), 
trichlorobenzenes  (all  isomers)  34.  Malta  subsequently  clarified  that  this  must  be  an  error  in 
reporting as all priority substances are 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)  offer  at  least  the  same  level  of  protection  as  the  standard  established  in  the 

Directive. 

Malta  reported  that  alternative  and/or  additional  standards  for  particular  Priority  Substances 

had not been applied.   

Use of mixing zones  

Article  4  of  EQS  Directive  provides  Member  States  with  the  option  of  designating  mixing 

zones  adjacent  to  points  of  discharge  in  surface  waters.  Concentrations  of  substances  may 
exceed  the  relevant  environmental  quality  standard  within  such  mixing  zones  if  they  do  not 

affect the compliance of the rest of the 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  of  the  measures  taken  to 
reduce the extent of the mixing zones in the future. 

Mixing zones have not been designated under Article 4 of the EQS Directive in Malta. 

34   Malta  indicated  that  these  substances  were  monitored  and  that  substances  within  groups  were  reported  as 
separate  substances.  The  following  reference  was  provided  which  confirms  this  (see  tables  5  and  6): 
Monitoring Programme for Priority Substances and certain other pollutants in inland surface and transitional 
waters 
https://era.org.mt/en/Documents/MEPA%20T08-2-11%20-%20Inland%20Waters%20(v24-8-
12%20+%20Appendices).pdf.  Another  reference  relating  to  coastal  waters  was  also  provided:  Monitoring 
programme for coastal waters 
https://era.org.mt/en/Documents/CW%20Mon%20Final%20Part%201.pdf 

70 

 
 
                                                      
Background Concentrations and Bioavailability 

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

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

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

Natural background concentrations for metals and their compounds are not reported to be taken 
into  consideration  where  such  concentrations  may  prevent  compliance  with  the  relevant 

environmental  quality  standard.  Malta  clarified  that  uncertainty  over  the  levels  of  such 
background concentrations prevented taking them into consideration but stated that measures 

in the second RBMP would be geared towards addressing such uncertainties, particularly in the 
case  of  mercury,  as  the  failing  chemical  pollutant  in  coastal  water  bodies.  Malta  also  stated 

further monitoring data would be required for inland surface waters.  

When assessing monitoring results against relevant environmental quality standards, Malta has 
taken into account water quality parameters that affect the bioavailability of metals. 

4.2  Main changes in implementation and compliance since the first cycle 

Overall  in  Malta,  between  the  two  RBMPs,  there  has  been  a  net  increase  in  monitoring  for 

chemical status, both in the number of monitoring sites (17, 2, 3 and 5 for coastal, lake, river 
and transitional water bodies respectively in the second RBMP) and water bodies (7, 2, 3 and 5 

for  coastal,  lake,  river  and  transitional  water  bodies  respectively  in  the  second  RBMP).  This 
includes both  an increase in  monitoring of coastal water bodies and monitoring of the newly 

delineated freshwater bodies. For the first RBMP, the chemical status for all water bodies (all 
coastal water bodies) was unknown but for the second cycle all water bodies were classified. 

For the second cycle, approximately half of the water bodies have good chemical status (rivers, 
lakes  and  transitional)  and  half  are  failing  to  achieve  good  status  (all  coastal  water  bodies). 

This represents a very significant improvement in knowledge between the two RBMPs. 

Overall in Malta, no Priority Substance was reported to have improved from failing to achieve 
good  to  good  chemical  status  since  the  first  RBMP;  the  only  change  in  chemical  status  was 

from  unknown  to  failing  to  achieve  good  chemical  status  in  coastal  waters.78  %  of  coastal 
water bodies are monitored for more than 10 Priority Substances and 100 % for river, lake and 

71 

 
 
transitional water bodies. Malta reported that all 41 Priority Substances were both monitored 

and used in the assessment of chemical status across all surface water bodies and all categories. 

4.3  Progress with Commission recommendations 

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

requested action on the following: 

  Recommendation: Where there are currently high uncertainties in the characterisation 
of the RBDs, identification of pressures, and in the 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:  This  recommendation  applies  to  a  number  of  Topics.  In  terms  of  the 

assessment  of  pressures  on  surface  water  bodies  failing  to  achieve  good  chemical 
status, this affected only coastal water bodies in Malta, with the pressures contributing 

to  the  greatest  number  of  coastal  water  bodies  failing  to  achieve  good  status  being 
“point  –  other”,  “diffuse  –  other  and  anthropogenic  pressure  –  unknown”.  The 

significant pressures do not appear to be well characterised despite the failure of good 
chemical  status  arising  from  a  ubiquitous,  persistent,  bioaccumulative,  and  toxic 

substance; namely, mercury. Malta state that “anthropogenic pressure – unknown” was 
used  in  cases  where  presence  of  contaminants  in  surface  water  bodies  could  not  be 

attributed  to  a  particular  source.  This  was  the  situation  for  mercury  for  which 
concentrations could not be attributed to either point or diffuse sources with certainty. 

Malta state that measures have been put forward in the second RBMP which includes 
one measure for addressing the uncertainties on sources of mercury in coastal waters. 

With regard to assessment of chemical status, confidence in the classification is given 
as  medium  based  on  fairly  comprehensive  monitoring  for  Priority  Substances  in 

2012/13.  All  lake,  river  and  transitional  water  bodies  were  monitored  for  all  priority 
substances in 2011-2013 (in particular all discharged substances), this was also the case 

for  almost  all  coastal  water  bodies.  Monitoring  frequencies  for  some  Priority 
Substances  in  the  water  column  in  coastal  waters  meets  the  recommended  minimum 

frequency  of  12  times  per  year  but  for  others,  and  especially  in  inland  waters,  the 
frequency is  less than the minimum  frequency, and no explanation could  be found in 

the  RBMP  for  these  reduced  frequencies.  No  monitoring  was  performed  in  biota  for 
status assessment. In terms of addressing high levels of uncertainty in chemical status, 

significant progress has been made towards fulfilling this recommendation.  

72 

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

  Recommendation:  Ensure  in  the  second  RBMPs  cycle  a  fully  operational  monitoring 
programme,  covering  at  least  the  following  topics:  groundwater  chemical  status 

(nitrate  levels  in  the  annual  recharge),  groundwater  quantitative  status,  the  inland 
surface water bodies (considering all WFD quality elements), the identification of river 

basin-specific pollutants, and protected areas. 

Assessment:  This  recommendation  applies  to  a  number  of  topics.  In  terms  of  the 

surface  water  monitoring  programme  for  chemical  status,  it  appears  that  monitoring 
programmes  for  Priority  Substances  are  in  place  to  assess  the  status  of  surface  water 

bodies  in  Malta.  All  lake,  river  and  transitional  water  bodies  were  monitored  for  all 
priority substances in 2011-2013 (in particular all discharged substances), this was also 

the case for almost all coastal water bodies. However, territorial waters have not been 
monitored, and their status was not assessed. Monitoring frequencies for some Priority 

Substances  in  the  water  column  in  coastal  waters  meets  the  recommended  minimum 
frequency  of  12  times  per  year  but  for  others,  and  especially  in  inland  waters,  the 

frequency is  less than the minimum  frequency, and no explanation could  be found in 
the  RBMP  for  these  reduced  frequencies35.  In  terms  of  chemical  status  for  surface 
waters,  significant  progress  has  been  made  towards  fulfilling  this  part  of  the 
recommendation. However it is still partly fulfilled. 

  Recommendation:  All  the  substances  listed  in  the  EQS  Directive  will  need  to  be 
monitored  in  all  surface  water  body  categories  to  allow  full  assessment  of  chemical 

status  in  relation  to  the  environmental  quality  standard  listed  in  the  EQS  Directive. 
Mercury,  hexachlorobenzene  and  hexachlorobutadiene  should  be  monitored  in  biota 

for  comparison  with  the  biota  standards  in  the  EQS  Directive,  unless  water 
environmental quality standard providing an equivalent level of protection are derived. 

The reporting  of  chemical  status in  WISE and the RBMP should be consistent. Trend 
monitoring  in  sediment  or  biota  for  several  substances  as  specified  in  EQS  Directive 

Article 3(3) will also need to be reflected in the next RBMP. This recommendation has 
been split  into sub-sections  based on the actions listed under the  recommendation for 
assessment purposes.  

35   Malta  subsequently  clarified  that  prior  to  determining  surveillance  and  operational  monitoring  further 
knowledge is required on Malta’s  highly dynamic inland surface  waters: the development of the  monitoring 
programme  for  inland  surface  water  is  an  iterative  process  and  will  be  improved  when  more  knowledge  is 
gained. 

73 

 
 
 
                                                      
o  All the substances listed in the EQS Directive will need to be monitored in all 
surface  water  body  categories  to  allow  full  assessment  of  chemical  status  in 
relation to the environmental quality standard listed in the EQS Directive. 

Assessment:  Monitoring  in  2012/13  covered  the  full  range  of  Priority  Substances 
including all those PS discharged, in  rivers, lakes, transitional and coastal  waters, but 

not  in  territorial  waters.  Malta  applies  all  the  environmental  quality  standards  from 
Annex  I  of  the  EQS  Directive  for  assessment  of  the  chemical  status.  Monitoring  of 

mercury,  hexachlorobenzene  and  hexachlorobutadiene  for  status  assessment  was 
carried  out  in  water,  but  Malta  did  not  derive  an  environmental  quality  standard  in 

water that would be at least as protective as the biota environmental quality standard. 
These three substances  were also  monitored in  Posidonia oceanica, but  Malta did  not 

derive a standard for this matrix. Very significant progress has been made in fulfilling 
the  recommendation,  however  it  is  not  yet  entirely  fulfilled  (see  assessment  below  in 

relation to mercury, hexachlorobenzene and hexachlorobutadiene).  

o  Mercury, hexachlorobenzene and hexachlorobutadiene should be monitored in 
biota  for  comparison  with  the  biota  standards  in  the  EQS  Directive,  unless 

water  environmental  quality  standard  providing  an  equivalent  level  of 
protection are derived. 

Assessment:  Hexachlorobenzene,  mercury  and  hexachlorobutadiene  have  been 
monitored in biota but for trend assessment only. These substances are monitored for 

status assessment in the water column but there is no evidence available as to whether 
the  standard  used  is  as  least  as  protective  as  the  biota  EQS.  This  aspect  of  the 

recommendation has not been fulfilled. 

o  The reporting of chemical status in WISE and the RBMP should be consistent. 

Assessment:  Malta  reported  detailed  information  in  WISE  on  which  substances  are 
monitored in which waterbodies. This recommendation has been fulfilled. 

o  Trend  monitoring  in  sediment  or  biota  for  several  substances  as  specified  in 
EQS Directive Article 3(3) will also need to be reflected in the next RBMP.  

Assessment:  Malta  has  monitored  in  sediment  and  /  or  biota  all  14  relevant  Priority 
Substances  in  coastal  waters,  but  only  13  of  them  in  river,  lake  and  transitional 

waterbodies. The spatial coverage appears to be quite extensive. Monitoring has taken 
place once in 2012, and with further monitoring to be decided. No information could be 

74 

 
 
found  on  this  further  monitoring,  so  it  was  not  clear  whether  the  recommended 

minimum frequency from the EQS Directive was reached.  

This aspect of the recommendation is therefore partially fulfilled.  

  Recommendation: Use the inventory of emissions to review the monitoring programme 
and  the  list  of  RBSPs  for  the  second  RBMPs,  and  to  identify  appropriate  measures 

against chemical pollution. 

Assessment: All priority substances were monitored in all lake, rivers and transitional 

waterbodies,  and  in  almost  all  coastal  water  bodies.  It  could  not  be  determined 
precisely  whether  the  inventory  of  emissions  was  used  to  revise  the  monitoring 

programme however all  substances appear to  be  monitored in  almost  all waterbodies. 
Malta mentioned that monitoring programmes will be further reviewed as necessary on 

the basis of the information gathered so far. This recommendation can be considered as 
fulfilled in relation to chemical status in surface waters. 

75 

 
 
 
 
Topic 5

  Monitoring, assessment and classification of quantitative 

status of groundwater bodies 

5.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle 

5.1.1 Monitoring of quantitative status in groundwater 

The  total  number  of  groundwater  bodies  in  Malta  is  15  (Table  2.2).  The  number  of 

groundwater  bodies  and  the  total  groundwater  body  area  have  not  changed  between  the  first 
and  second  RBMPs.  Four  of  fifteen  groundwater  bodies  are  identified  as  drinking  water 

protected areas.  

Thirteen groundwater bodies are not subject to monitoring for quantitative status (Table 5.1), 
meaning  87  %  of  groundwater  bodies  are  not  monitored  (Table  5.2)36,37.  Looking  at  the 
groundwater  body  area,  the  two  monitored  groundwater  bodies  represent  80  %  of  the  total 
groundwater body area and therefore 20 % of the area is not monitored38. Review of the RBMP 
and  background  documents  found  evidence  that  grouping  of  groundwater  bodies  was 
undertaken, based on the hydrogeological characteristics of the groundwater bodies.  

Table 5.1 

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

RBD  

Total 
ground-
water 
bodies 
directly 
monito-
red 

Monitoring Purpose 

CHE - 
Chemica
l status 

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

OPE – 
Operatio
-nal 
monitori
ng 

QUA - 
Quantitati
ve status 

SOE - 
EIONET 
State of 
Environme
nt 
monitoring 

SUR – 
Surveil-
lance 
monitor
ing 

MTMALTA 

15 
Source: WISE electronic reporting. The numbers in brackets were subsequently provided by Malta and do not 
match the data reported to WISE. 

2 (3) 

15 

15 

Table 5.2 

Proportion of groundwater bodies in Malta monitored for quantitative status 

No of groundwater 
bodies with 
quantitative 
monitoring 

Total No. 
groundwater 
bodies 

RBD Code 

% of total groundwater bodies 
monitored for quantitative status 

36   Malta subsequently clarified that three and not two groundwater bodies are subject to quantitative monitoring, 

which was a reporting error. 

37   Malta  subsequently  clarified  that,  as  reported  in  the  second  RBMP  (page  252)  water  level  monitoring  is 

installed in these groundwater bodies, but failed to work.  

38   Malta subsequently clarified that three groundwater bodies monitored for quantitative status represent 81 % of 

the total groundwater body area and therefore 19 % of the area is not monitored.  

76 

 
 
  
 
 
 
 
                                                      
MTMALTA 

2 (3) 

15 

13.33 % (20 %) 

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

Two groundwater bodies were monitored in  the first  cycle, which remained the same for the 

second  cycle  according  to  the  reported  information,  although  Malta  clarified  that  currently 
three  groundwater  bodies  are  monitored39.  The  number  of  monitoring  sites  for  quantitative 
status is listed in Table 5.3, which shows that it decreased from 42 in the first RBMP to 38 in 
the  second  cycle.  The  RBMP  and  background  documents  assessment  revealed  that  Malta  is 

planning to upgrade the monitoring programme which is due to start during this second cycle. 
The  project  is  planned  to  focus  on  the  optimisation  of  the  national  hydrological  monitoring 

capability. 

Table 5.3 

Number of groundwater monitoring sites in Malta and their purpose  

RBD Code 

Total groundwater 
monitoring sites 

Monitoring Purpose 

OPE - 
Operational 
monitoring 

QUA - 
Quantitative 
status 

SUR - 
Surveillance 
monitoring 

Unknown 

MTMALTA 

80 

42 

38 

42 

3 

Source: WISE electronic reporting 

The  RBMP  and  background  documents  assessment  found  that  in  Mean-Sea-Level-Aquifer-
systems, groundwater boreholes dedicated for the measurement of water level were used. The 

second River Basin Management Plan states, that in addition to water level monitoring, initial 
conductivity  well  profiles  have  been  undertaken  in  the  Mean-Sea-Level-Aquifer-systems.  In 

the perched (upper coralline limestone) aquifer systems, the measurement was more difficult, 
due  to  the  hydrogeological  properties  of  these  systems,  which  presents  an  extremely  thin 

unsaturated  zone  (and  therefore  low  standing  water  levels),  which  does  not  permit  the 
installation  of  traditional  water  level  metering  equipment.  Hence,  only  pilot  initiatives  were 

undertaken to test the feasibility of using "groundwater flow" measurements in spring channels 
as  an  alternative  metric  for  assessing  quantitative  status.  In  the  RBMP,  it  is  then  stated  that 

these methods failed for the perched aquifer systems, and that water balances were also used, 
as in the Mean-Sea-Level-Aquifer-systems. 

39   Malta  subsequently  clarified  that  three  and  not  two  groundwater  bodies  were  subject  to  quantitative 

monitoring in the first RBMP, and thus there has been an increase in monitored groundwater bodies.  

77 

 
 
 
 
                                                      
5.1.2 Assessment and classification of quantitative status for groundwater 

Map 5.1 displays the most recently assessed quantitative status of groundwater bodies based on 

status. It shows that 13 of 15 groundwater bodies (87 %) were of good quantitative status and 
two  (13  %)  were  failing  good  status  (Figure  5.1).  On  a  groundwater  body  area  basis,  this 

situation is the reverse with about 80 % of the total RBD area failing good quantitative status. 
Figure  5.2  shows  that  the  confidence  in  status  classification  is  high.  All  groundwater  bodies 

had  a  classified  qualitative  status  in  the  first  and  in  the  second  RBMP.  Thus,  there  were  no 
water bodies with unknown status. 

The total number of groundwater bodies failing good quantitative status decreased significantly 
from four groundwater bodies (27 %) in the first RBMP to two (13 %) in the second RBMP 

but it decreased only slightly from 84 % to 80 % in terms of total groundwater body area. The 
RBMP and background documents provide reasons for the improvement. 

In  Malta,  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.  Both  groundwater  bodies  are  failing  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.  The  expected  date  of  achievement  of  good  quantitative 

status in Malta is the end of this cycle, year 2021, as shown in Figure 5.4.  

78 

 
 
 
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) 

79 

GoodPoorUnknownRiver Basin DistrictsCountries outside the EU 
 
 
 
Figure 5.1  Quantitative status of groundwater bodies in Malta for the second RBMP, for 

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

assessment of status for the second RBMP was 2010 to 2014. The year of the 
assessment of status for first RBMP is not known 

Source: WISE electronic reporting 

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

in Malta based on the most recent assessment of status  

Source: WISE electronic reporting 

80 

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

based on the most recent assessment of status  

Source: WISE electronic reporting 

Notes: 
‘Water balance’ = long-term annual average rate of abstraction exceeds the available groundwater resource which 
may result in a decrease of groundwater levels. 

‘Surface water’ = Failure to achieve Environmental Objectives (Article 4 WFD) for associated surface water 
bodies resulting from anthropogenic water level alteration or change in flow conditions; significant diminution of 
the status of surface waters resulting from anthropogenic water level alteration or change in flow conditions. 

‘Groundwater dependent terrestrial ecosystems’ = Significant damage to groundwater dependent terrestrial 
ecosystems resulting from an anthropogenic water level alteration. 

‘Saline or other intrusion’ = Regional saline or other intrusions resulting from anthropogenically induced 
sustained changes in flow direction. 

81 

 
 
 
Figure 5.4  Expected date of achievement of good quantitative and good chemical status 

of groundwater bodies in Malta. 15 groundwater bodies delineated for second 
RBMP 

Source: WISE electronic reporting 

The RBMP describes that due to the failed efforts of undertaking water level measurements in 
the perched groundwater bodies (due to  the specific hydro-geological  characteristics of these 

aquifer systems) the quantitative groundwater status in the second RBMP was assessed using a 
water-balance  model.  The  results  were  then  discretised40,  with  the  results  presented  in  the 
RBMP. The results showed that two groundwater bodies had poor quantitative status, and the 
rest good quantitative status41.  

In  Malta,  the  criterion  of  “available  groundwater  resource”  has  been  fully  applied  in 

accordance with WFD Article 2(27) and all environmental objectives have been considered in 
status assessment. 

In total two groundwater bodies (13 %) were reported to be at risk of failing good quantitative 
status due to harm to actual or potential legitimate uses or functions of groundwater. 

40   Malta  subsequently  clarified  that  the  original  wording  of  ‘extrapolated’  should  be  replaced  by  the  term 
‘discretised’  as  detailed  assessments  had  been  undertaken  on  groundwater  body  level.  The  water  balance 
calculation  was  performed  first  at  a  grouping  level  (based  on  hydrogeological  characteristics)  and  then  at 
groundwater body level. Both assessments contribute to status assessment. 

41   Malta subsequently clarified that grouping is explained under Section 5.5.1 of the second RBMP (pg. 249). 

82 

 
 
 
 
                                                      
5.1.3 Consideration  of  groundwater  associated  surface  waters  and/or  groundwater 

dependent ecosystems 

In two  groundwater bodies,  groundwater associated surface waters have  been reported. They 

are not related to risk, and have been considered in status assessment. 

Groundwater dependent terrestrial ecosystems have not been reported. Nevertheless, they have 
been considered in status assessment.42 

5.2  Main changes in implementation and compliance since the first cycle 

In terms of delineation, all 15 groundwater bodies remained unchanged since the first RBMP. 

The monitoring situation remains incomplete: the number of monitored groundwater bodies is 

still only 3 of 15, representing 81 % of the total groundwater body area. 

The  status  situation  improved  slightly,  with  the  number  of  groundwater  bodies  failing  good 

status  declining  from  four  to  two,  and  the  affected  total  groundwater  body  area  declined 
slightly from 84 % to 80 %. 

The  RBMP  and  background  documents  did  provide  a  summary  of  the  changes  to  the 
quantitative  groundwater  monitoring  system  or  classification  methodologies  in  the  Maltese 

RBMP.  Some  descriptions  were  provided  on  "lessons  learned"  from  the  first  cycle 
(confirmation of the "risk" classification approach and grouping of groundwater bodies). 

5.3  Progress with Commission recommendations 

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

  Recommendation: Where there are currently high uncertainties in the characterisation 
of the RBDs, identification of pressures, and in the 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: Most groundwater bodies are still not  subject  to  quantitative monitoring. 

RBMP and background documents assessments showed that groundwater bodies were 

42   Malta subsequently clarified that, given the geographical and natural features of the territory, the groundwater 
bodies  indicated  as  having  linkages  with  surface  water  bodies  should  also  be  considered  as  having  linkages 
with terrestrial water dependent ecosystems. 

83 

 
 
                                                      
grouped  into  seven  groups  of  groundwater  bodies.  Nevertheless,  there  is  still  a 
significant monitoring gap and therefore this recommendation has not been fulfilled43. 

  Recommendation:  Private  groundwater  abstraction  as  a  major  pressure  on 

groundwater bodies should be adequately monitored. 

Assessment:  The  monitoring  programme  for  quantitative  groundwater  status  uses 

water-balance models which incorporate these abstractions as factors. Summarising, it 
can be stated that the monitoring programme for the quantitative groundwater status is 

indirectly  linked  to  the  significant  pressure  "water  abstraction"  via  the  models;  the 
monitoring  itself  measures  only  the  water  level  in  the  boreholes,  thus  measuring  all 

input  and  output  to  and  from  the  system  together.  Malta  subsequently  added  the 
following  information:  practically  all  private  groundwater  abstraction  sources  have 

been metered and abstraction data is being collected and analysed. Given this additional 
information, the recommendation can be considered as fulfilled.  

  Recommendation:  Ensure  in  the  second  RBMPs  cycle  a  fully  operational  monitoring 
programme,  covering  at  least  the  following  topics:  groundwater  chemical  status 

(nitrate  levels  in  the  annual  recharge),  groundwater  quantitative  status,  the  inland 
surface water bodies (considering all WFD quality elements), the identification of river 

basin-specific  pollutants,  and  protected  areas.  This  monitoring  programme  should 
ensure  the  following  crucial  steps  in  the  WFD  process:  clear  definition  of  quality 

elements, Good Ecological Status and Good Ecological Potential, an apportionment of 
sources with regard to the different pressures/impacts, and a quantification of the gap 

to achieving objectives for all pressures affecting all water bodies. 

Assessment:  As  already  mentioned  above,  it  is  reported  to  WISE  that  only  2  of  15 

groundwater bodies are subject to monitoring. The RBMP and background documents 
assessments  showed  that  groundwater  bodies  were  grouped  into  seven  groups  of 

groundwater bodies. Despite the progresses, there is still a monitoring gap and therefore 
this recommendation cannot be considered as fulfilled.44 

43   Malta  subsequently  clarified  that  efforts  to  increase  monitoring  spread  were  undertaken  during  first  RBMP, 
but  failed.  A  new  measure  to  develop  alternative  monitoring  facilities  has  been  included  under  the  second 
RBMP’s Programme of Measures. 

44  Malta  subsequently  provided  this  additional  information:  the  monitoring  gap  is  being  addressed  through  a 
project  funded  under  the  Cohesion  Fund  which  aims  at  the  optimisation  of  groundwater  monitoring 
(quantitative  and  qualitative)  infrastructure  in  Malta.  The  implementation  of  this  project  started  in  January 
2018. 
project: 
(https://www.energywateragency.gov.mt/uncategorized/enhancing-national-monitoring-for-improved-water-
resources-management/) 

information 

Additional 

the 

on 

84 

 
 
                                                      
Topic 6

  Monitoring,  assessment  and  classification  of  chemical 

status of groundwater bodies 

6.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle 

6.1.1 Monitoring of chemical status in groundwater 

All 15 (100 %) groundwater bodies are subject to surveillance monitoring (Table 5.1) and to 

operational monitoring in both the first and second RBMPs. The number of monitoring sites is 
listed in Table 5.3 and shows a slight increase from 40 in the first RBMP to 42 in the second 

RBMP.  The  number  of  operational  monitoring  sites  has  also  been  increased  since  the  first 
RBMP, from 40 to 42. 

87 % of the groundwater bodies are at risk of failing good chemical status.  All substances at 
risk  of  causing  deterioration  in  chemical  status  are  subject  to  surveillance  monitoring.  The 

WFD  core  parameters  nitrate,  ammonium  and  electrical  conductivity  are  monitored,  but  the 
WFD core parameters oxygen and pH are not monitored.45 

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.  They  show  that  3  of  15  groundwater  bodies  (20  %)  were  of  good  chemical 
status,  and  the  remaining  12  groundwater  bodies  (80  %)  are  failing  good  status.  In  terms  of 

area this means that about 97 % were failing good chemical status. Figure 6.2 shows that there 
is high confidence in status classifications. All groundwater bodies had a classified qualitative 

status in the first and in the second RBMP; that is, there were no water bodies with unknown 
status. 

The total number of groundwater bodies failing good chemical status decreased since the first 

RBMP from 13 (87 %) to 12 (80 %) groundwater bodies (Figure 6.1) - from 98 % to 97 % of 
the total groundwater body area. The expected date of achievement of good chemical status in 

Malta is shown in Figure 5.4. It shows that less stringent objectives have already been achieved 
for  approximately  20  %  of  groundwater  bodies  and  20  %  achieved  good  status  in  2015,  the 

remainder will achieved good status in the next planning cycles: 40 % from 2016 -2021 and 20 
% from 2022 to 2027. 

45   Malta subsequently clarified that this is a reporting error and in fact all WFD core parameters are monitored. 

85 

 
 
                                                      
Map 6.1  Map  of  chemical  status  of  groundwater  bodies  in  Malta  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) 

86 

GoodPoorUnknownRiver Basin DistrictsCountries outside the EU 
 
 
 
 
 
Figure 6.1 

Chemical status of groundwater bodies in Malta for the second RBMP, for 

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

assessment of status for the second RBMP was 2010 to 2014. The year of 
the assessment of status for first RBMP is 2009 

Source: WISE electronic reporting  

Figure 6.2 

Confidence in the classification of chemical status of groundwater  bodies 

in Malta based on the most recent assessment of status  

Source: WISE electronic reporting  

87 

 
 
 
 
 
The reasons for the failure of good chemical status of groundwater bodies are shown in Figure 

6.3.  For  13  groundwater  bodies  the  general  assessment  of  the  chemical  status  for  the 
groundwater body as a whole failed. This assessment considers the significant environmental 

risk from pollutants across a groundwater body and a significant impairment of the ability to 
support human uses. Five groundwater bodies were failing good chemical status due to saline 

intrusion. Figure 6.5 shows the pollutants causing failure of status and sustained upward trend.  

Figure 6.3  Reasons  for  failing  good  chemical  status  in  Malta  for  the  most  recent 

assessment of status 

Source: WISE electronic reporting  

Notes: 

‘Surface water’ = Failure to achieve Environmental Objectives (Article 4 WFD) in associated surface water 
bodies or significant diminution of the ecological or chemical status of such surface water bodies. 

‘Groundwater dependent terrestrial ecosystems’ = Significant damage to terrestrial ecosystems which depend 
directly on the groundwater body. 

‘Saline or other intrusion’ = Regional saline or other intrusions resulting from anthropogenically induced 
sustained changes in flow direction. 

‘Drinking Water Protected Area’ = Deterioration in quality of waters for human consumption. 

‘General water quality assessment’ = Significant impairment of human uses; significant environmental risk from 
pollutants across the groundwater body. 

The calculation of the extent of exceedance of a groundwater quality standards or groundwater 

threshold  values  in  the  RBD  of  Malta  was  based  on  the  number  of  monitoring  sites  in  the 
groundwater  body.  Groundwater  threshold  values  have  been  established  for  all  pollutants  or 

indicators of pollution causing a risk of failure of good chemical status and background levels 
have been considered in the groundwater threshold value establishment. 

88 

 
 
 
 
A trend and trend reversal assessment methodology was available and assessments have been 

performed in the RBD. 

Figure 6.4 

Percentage  of  groundwater  bodies  in  Malta  at  risk  of  failing  good  chemical 

status and good quantitative status for the second RBMP 

Figure 6.5 

Top groundwater pollutants causing failure of good chemical status in Malta 

Source: WISE electronic reporting 

Source: WISE electronic reporting  
Note: only two pollutants reported causing failure. 

89 

 
 
 
 
 
 
Figure 6.6 

Top pollutants with upward trends in groundwater bodies in Malta 

Source: WISE electronic reporting  

6.1.3 Consideration  of  groundwater  associated  surface  waters  and/  or  groundwater 

dependent ecosystems 

In  two  groundwater  bodies  groundwater  associated  surface  waters  have  been  reported.  They 
were  not  related  to  risk  and  they  have  been  considered  in  status  assessment.  Groundwater 

dependent  terrestrial  ecosystems  have  not  been  reported.  Nevertheless,  they  have  been 
considered in status assessment. 

Groundwater associated aquatic ecosystems and groundwater dependent terrestrial ecosystems 
have been considered in the establishment of groundwater threshold values. 

6.2  Main changes in implementation and compliance since the first cycle 

The  RBMP  mentioned  that  due  to  the  results  of  the  analysis  of  the  second  surveillance 
monitoring  programme,  there  was  no  need  for  the  inclusion  of  further  parameters  in  the 

operational  monitoring  strategy  for  the  second  RBMP.  The  only  change  made  in  the 
operational  monitoring strategy during the  second  RBMP implementation  period entailed the 

90 

 
 
 
 
 
 
inclusion of the new core parameters (nitrites and phosphate) introduced by the amendment of 
the Groundwater Directive46. 

Since the first cycle the monitoring for chemical status in groundwater has remained complete. 

The status however has not improved, with about 97 % of the total groundwater body area is 
still failing to achieve good chemical status.  

6.3  Progress with Commission recommendations 

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

  Recommendation: Where there are currently high uncertainties in the characterisation 
of the RBDs, identification of pressures, and in the 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:  All  15  groundwater  bodies  were  subject  to  surveillance  and  operational 
monitoring  in  the  first  RBMP  and  this  is  still  the  case  in  the  second  RBMP.  The 

confidence in the status results is high. This recommendation has been fulfilled. 

  Recommendation:  Ensure  in  the  second  RBMPs  cycle  a  fully  operational  monitoring 
programme,  covering  at  least  the  following  topics:  groundwater  chemical  status 
(nitrate  levels  in  the  annual  recharge),  groundwater  quantitative  status,  the  inland 

surface water bodies (considering all WFD quality elements), the identification of river 
basin-specific  pollutants,  and  protected  areas.  This  monitoring  programme  should 

ensure  the  following  crucial  steps  in  the  WFD  process:  clear  definition  of  quality 
elements, Good Ecological Status and Good Ecological Potential, an apportionment of 

sources with regard to the different pressures/impacts, and a quantification of the gap 
to achieving objectives for all pressures affecting all water bodies. 

Assessment:  All  groundwater  bodies  are  subject  to  operational  monitoring.  However, 
the RBMP and background documents assessment could not provide any indication that 

46   Groundwater Directive (GWD): Directive 2006/118/EC of the European Parliament and of the Council of 12 

December 2006 on the protection of groundwater against pollution and deterioration. 

91 

 
 
                                                      
 
there has been progress  towards monitoring nitrate levels  in  the annual  recharge. The 
recommendation therefore has been partially fulfilled.47 

47  Malta  subsequently  clarified  that  the  establishment  of  the  monitoring  network  for  nitrate  levels  in  annual 
recharge  (which  will  be  the  first  of  its  kind  in  the  EU,  and  goes  beyond  the  requirements  of  the  WFD)  is 
included under the national hydrological monitoring project funded under the Cohesion Fund, and is therefore 
planned  for  implementation  during  the  second  RBMP.  This  recommendation  was  actually  not  a  European 
Commission recommendation but a Member State (Malta) initiative to ensure a more coherent monitoring of 
groundwater chemical status. 

92 

 
 
 
 
 
                                                      
Topic 7

  Designation  of  Heavily  Modified  and  Artificial  Water 

Bodies and definition of Good Ecological Potential 

7.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle for designation  

7.1.1 Designation of Heavily Modified and Artificial Water Bodies 

The  WFD  requires  a  review  of  designation  every  six  years.  In  the  second  cycle,  Malta  has 

designated  one  river  water  body,  one  lake  water  body  and  five  transitional  water  bodies  as 
heavily  modified  water  bodies,  in  addition  to  the  two  coastal  water  bodies  designated  as 

heavily modified water bodies in the first cycle. The proportion of total water bodies in each 
category in Malta that has been designated as heavily modified or artificial is shown in Figure 

7.1. 

Figure 7.1 

Proportion  of  total  water  bodies  in  each  category  in  Malta  that  has  been 

designated as heavily modified or artificial  

Source: WISE electronic reporting 

The heavily modified river water body is designated due to irrigation and wider environment, 

the  coastal  heavily  modified  water  bodies  were  designated  mainly  due 

while 
tourism/recreation, navigation/ports, urban development and industry supply. 

to 

93 

 
 
 
The  main  physical  alterations  of  river,  lake,  and  transitional  heavily  modified  water  bodies 

were  channelisation/  straightening/  bed  stabilisation/  bank  reinforcement.  Coastal  heavily 
modified water bodies are affected by dredging and coastal modifications/ ports. 

There is no consistent description of the methodology for the designation of heavily modified 
water  bodies  in  the  Maltese  RBMP.  The  RBMP  explains  why  the  two  main  coastal  heavily 

modified  water  bodies  were  designated  as  heavily  modified,  including  a  description  of 
substantial changes in character and significant adverse effects of restoration measures on the 

use or wider environment.  

The criteria used to  define substantial  changes  in character due to  physical  modifications for 

the two coastal heavily modified water bodies were: significant and irreversible morphological 
alteration,  extent  of  area  of  modified  bottoms,  related  to  dredging  activities,  percentage  of 

length  of  modified  shore,  area  covered  by  ports  and  navigation  facilities,  area  of  modified 
segments,  frequency  and  extent  of  dredging  activities.  No  thresholds  for  these  criteria  were 

provided. According to Malta the activities used to define HMWB in coastal waters are typical 
of and restricted to the main harbour areas, both of which were designated as HMWBs in view 
of the substantial modifications resulting from those activities.  

The  criteria  used  to  assess  significant  adverse  effects  of  measures  needed  to  reverse  the 
hydromorphological  quality  of  the  two  coastal  heavily  modified  water  bodies  include 

endangered  national  heritage  or  historical/cultural  monuments,  release  of  priority  and/or 
priority  hazardous  substances  due  to  reservoirs  of  historic  contaminated  sediments  in  port 

areas, significant job reduction, significant reduction of shipping/transport (for example due to 
the reduction of depth/width of fairway should dredging be discontinued), percentage loss of 

cargos  or  reduction  in  passenger  traffic  should  quays/facilities  be  removed,  impossibility  to 
change the current hydromorphological condition as port facilities are completely consolidated 

in an urban area. 

For  the  two  coastal  heavily  modified  water  bodies,  the  RBMP  also  states  that  the  objectives 

served  by  the  modified  characteristics  of  the  water  body  cannot  for  reasons  of  technical 
feasibility  and/  or  disproportionate  costs  be  reasonably  achieved  by  any  other  alternative 

means, which are significantly better environmental options.  

For the five transitional water bodies, which were designated due to historical usage, as well as 

the  two  lake  and  river  heavily  modified  water  bodies,  no  criteria  or  explanations  for  the 
designation were described in the RBMP. 

94 

 
 
7.1.2 Definition of Good Ecological  Potential for Heavily Modified  and Artificial  Water 

Bodies 

Good  ecological  potential  is  reported  as  defined  at  water  body  level,  following  the  Prague 

approach,  assuming  that  ecological  potential  can  be  achieved  if  all  feasible  and  practical 
mitigation  measures  are  taken  to  address  hydromorphological  impacts.  The  approach 

developed to define  good ecological  potential in the second RBMP concerns the two  coastal 
heavily modified water bodies. For the other heavily modified water bodies, no information on 

good ecological potential definition was provided in the RBMP. 

Dredging minimisation and sediment management were reported as mitigation measures which 

have been identified to  define  good ecological  potential for the two coastal  heavily modified 
water bodies. However, the ecological changes that the mitigation measures were designed to 

achieve were not described. 

Good  ecological  potential  was  also  reported  to  have  been  defined  in  terms  of  biology.  The 

biological quality element for which biological values have been derived to define maximum 
ecological  potential  and  good  ecological  potential  are  phytoplankton,  macroalgae, 
angiosperms,  and  benthic  invertebrates.  The  estimation  of  values  for  the  biological  quality 

elements  of  ecological  potential  in  the  harbours  was  based  on  methods  that  are  applied  to 
natural  waters  and  which  have  been  intercalibrated  at  Mediterranean  level.  Good  ecological 

potential definition on the basis of biological quality elements has only taken place for the two 
coastal heavily modified water bodies, while for the other heavily modified water bodies (river, 

lake,  and  transitional),  no  biological  quality  elements  are  established/  assessed.  The  second 
RBMP explains that due to the unique characteristics of inland surface waters, additional data 

is required to understand the complex dynamics associated with such water bodies. 

For  coastal  waters,  a  method  for  assessing  benthic  invertebrates  and  a  method  for  assessing 

angiosperms  are  reported  as  sensitive  to  altered  habitats  due  to  morphological  changes.  The 
method  to  assess  macroalgae  is  reported  as  sensitive  to  altered  habitats  due  to  both 

morphological  and  hydrological  changes.  For  rivers,  a  method  for  assessing  benthic 
invertebrates is reported as sensitive to altered habitats due to morphological and hydrological 

changes.  For  lakes,  a  method  to  assess  benthic  invertebrates  is  reported  as  sensitive  to 
hydrological  changes.  For  transitional  waters,  there  are  no  biological  quality  element 

assessment methods sensitive to hydromorphology. 

A comparison between good ecological potential and good ecological status has not been made 

in the RBD. 

95 

 
 
7.2  Main changes in implementation and compliance since the first cycle 

As indicated above, heavily modified water bodies have been designated in the second RBMP 

in  all  surface  water  categories  (one  river  heavily  modified  water  body,  one  lake  heavily 
modified water body, five transitional heavily modified water bodies, and two coastal heavily 

modified water bodies), whereas in the first RBMP, only coastal water bodies were designated 
as  heavily  modified  water  bodies.  The  five  transitional  heavily  modified  water  bodies  were 

considered  to  be  heavily  modified  systems  as  they  have  been  continuously  engineered 
throughout history. For the river and lake heavily modified water bodies newly designated, the 

reasons for the designation were not explained. It seems though that these water bodies had not 
been adequately monitored in the first cycle, and hence no status could be determined. 

In the first RBMP, the designation of heavily modified water bodies appeared to be based on a 
screening of pressures and expert judgement. In the second RBMP, there is still no consistent 

description of the methodology for designation but an explanation of the criteria used for the 
designation  of  the  two  coastal  heavily  modified  water  bodies  was  provided.  No  such 

descriptions were given for the other heavily modified water bodies.  

In the second cycle, good ecological potential was reported to be defined following the Prague 

approach, whereas in the first cycle, good ecological potential had not been defined due to the 
delay in the implementation of the monitoring programmes. 

7.3  Progress with Commission recommendations 

There were no Commission recommendations based on the first RBMP and first Programme of 
Measures for this topic. 

96 

 
 
 
Topic 8

  Environmental objectives and exemptions 

8.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle 

8.1.1 Environmental objectives 

The  environmental  objectives  are  defined  in  Article  4  of  the  WFD.  The  aim  is  long-term 
sustainable water management based on a high level of protection of the aquatic environment. 

Article 4(1) defines the WFD general objective to be achieved in all surface and groundwater 
bodies,  that  is,  good  status  by  2015.  Within  that  general  objective,  specific  environmental 

objectives are defined for heavily modified water bodies (good ecological potential and good 
chemical status by 201548), 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 coastal water bodies and groundwater. The dates by 
when lake, river and transitional water bodies will achieve good ecological status/potential are 
reported as unknown49. Good chemical status for river, lake and transitional water bodies was 
reported to be achieved by 2015 but the dates for  achieving good chemical status for coastal 

waters are unknown. 

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  Malta  is  provided  in 

Chapter 15 of this report. 

Assessments  of  the  current  status  of  surface  and  groundwater  bodies  in  Malta  are  provided 

elsewhere in this report: for ecological status/potential of surface waters in Chapter 3; chemical 
status of surface waters in Chapter 4; quantitative status of groundwater bodies in Chapter 5; 

chemical  status  of  groundwater  bodies  in  Chapter  6;  and  for  the  status  of  surface  and 
groundwater bodies associated with Protected Areas in 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 

48 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. 

49   Malta subsequently clarified that the second  RBMP explains that due  to the  unique  characteristics of  inland 
surface  waters,  additional  data  is  required  to  understand  the  complex  dynamics  associated  with  such  water 
bodies. 

97 

 
 
                                                      
summarised:  for  ecological  status/potential  of  surface  waters  in  Chapter  3  chemical  status  of 

surface  waters  in  Chapter  4;  quantitative  status  of  groundwater  bodies  in  Chapter  5;  and  for 
chemical status of groundwater bodies in Chapter 6.  

8.1.2 Exemptions 

Where  environmental  objectives  are  not  yet  achieved  exemptions  can  be  applied  in  case  the 
respective conditions are met and the required justifications are presented 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 for the four main sets of environmental objectives. 

Figure 8.1 

Water bodies in Malta expected to be in at least good status in 2015 and use 
of  exemptions.  1  =  Surface  water  body  ecological  status/potential;  2  = 

Surface  water  body  chemical  status;  3  =  Groundwater  body  quantitative 
status; 4 = Groundwater body chemical status 

Source: WISE electronic reporting. For some water bodies the date for achievement of good status is unknown. 

Article  4  of  the  WFD  allows  under  certain  conditions  for  different  exemptions  to  the 
objectives:  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, 

98 

 
 
 
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 
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 objectives in Malta. 

99 

 
 
Figure 8.2 

Type  of  exemptions  applied  to  surface  water  and  groundwater  bodies  for 

the  second  RBMP  in  Malta.  Note:  Ecological  status  and  groundwater 
quantitative  status  exemptions  are  reported  at  the  water  body  level. 

Chemical  exemptions  for  groundwater  are  reported  at  the  level  of  each 
pollutant  causing  failure  of  good  chemical  status,  and  for  surface  waters 

for each Priority Substances that is causing failure of good chemical status 

Source: WISE electronic reporting  

100 

 
 
 
  
Application of Article 4(4) 

Article  4(4)  has  been  applied  in  surface  waters  and  groundwaters.  In  the  RBMP  technical 
feasibility  and  natural  conditions  were  used  as  an  argument  for  justifying  exemptions 

according to Article 4(4). The RBMP provides detailed justifications at water body level.   

The  main  drivers  for  exemptions  were  reported  to  be  agriculture  and  urban  development  in 

relation  to  exemptions  for  groundwater  bodies.  Malta  subsequently  clarified  that  the  main 
drivers  are  actually  due  to  the  natural  conditions,  i.e.  the  long  response  time  of  the  aquifers 

systems. For surface waters, agriculture, industry, transport and urban development as well as 
unknown drivers are reported.  

The main pressures to  surface waters  leading to  exemptions  were point pollution from  urban 
waste  water,  diffuse  pollution  from  urban  run-off  and  agricultural,  abstraction  or  flow 

diversion,  physical  alteration  of  channel/bed/riparian  area/shore,  hydromorphological 
alteration,  and  introduced  species  and  diseases.  Table  8.1  outlines  reported  pressures 

responsible for Priority Substances failing to achieve good chemical status, which are unknown 
anthropogenic pressures. 

Table 8.1 

Pressure on surface water bodies responsible for Priority Substances in Malta 

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 

8 - Anthropogenic pressure - Unknown 

1 
Source: WISE electronic reporting 2016 

9 

Article 4(5) - 
Technical 
feasibility 
exemptions 

Number 

0 

For groundwater, the main pressures are abstraction for public supply, agriculture and diffuse 

agricultural  pollution  (Table  8.2).  The  main  drivers  behind  these  pressures  were  urban 
development  and  agriculture  for  groundwater  and  surface  water  and  in  addition  industry  and 

transport for surface water. 

101 

 
 
 
 
Table 8.2 

Pressure responsible for pollutants in Malta failing to achieve good chemical 

status in groundwater and for which exemptions have been applied  

Significant pressure on groundwater 

Number 
of failing 
pollutants 

Number of exemptions 

Article 4(4) - Natural 
conditions 

2.2 - Diffuse - Agricultural 

3.1 - Abstraction or flow diversion - Agriculture 

1 

1 

11 

5 

Source: WISE electronic reporting 

The main impacts causing exemptions under Article 4(4) are nutrient pollution in groundwater 

and surface water. Surface water is further impacted by altered habitats due to morphological 
and hydrological changes (includes connectivity) and chemical pollution.  

Application of Article 4(5) 

Article 4(5) was applied in coastal waters and groundwaters. The justification for exemption to 
the  chemical  status  of  groundwater  bodies  relates  to  technical  feasibility.  For  the  Grand 

Harbour  (coastal  water)  the  justification  was  based  on  disproportional  costs.  According  to 
WISE  disproportional  costs  were  justified  by  affordability,  cost-effectiveness  analysis, 

distribution of costs, and social and sectoral impacts. In the RBMP further details are given and 
it is stated that reversing the hydromorphological alterations of the Grand Harbour would have 

significant adverse effects on the wider environment. This could lead to:  

  Endangering the national heritage and the area’s rich culture 

  Reduce the economic activities around the area such as: cruise tourism, ferries to Sicily, 
waterfronts’  retail  activity,  and  other  indirect  economic  activities  generated  through 
tourism  

  Material loss in employment which are directly and indirectly related to the economic 

activity of the Grand Harbour area.   

Application of Article 4(6) 

No exemptions according to Article 4(6) have been applied.  

102 

 
 
Application of Article 4(7) 

In  the  Grand  Harbour  water  body,  several  new  developments  are  planned  (for  example,  a 
cruise terminal, waterfront development, and a “Dock 1 Project”) but no exemptions according 

to Article 4(7) have been applied. 

Application of Article 6(3) Groundwater Directive50 

No exemptions according to Article 6(3) Groundwater Directive have been applied. 

8.2  Main changes in implementation and compliance since the first cycle 

The  number  of  groundwater  bodies  to  which  Article  4(5)  has  been  applied  has  decreased  by 

one groundwater body. 

8.3  Progress with Commission recommendations 

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

reports requested action on the following: 

  Recommendation: It is unclear whether there are new physical modifications planned 
in RBMPs. If this is the case, the use of exemptions under Article 4(7) should be based 

on  a  thorough  assessment  of  all  the  steps  as  requested  by  the  WFD,  in  particular  an 
assessment  of  whether  the  project  is  of  overriding  public  interest  and  whether  the 
benefits  to  society  outweigh  the  environmental  degradation,  and  the  absence  of 

alternatives that would be a better environmental option. Furthermore, these projects 
may only be carried out when all possible measures are taken to mitigate the adverse 

impact  on the status of the water. All  conditions for  the application of  Article  4(7) in 
individual projects must be included and justified in the RBMPs as early in the project 

planning as possible.  

Assessment:  No  exemptions  according  to  Article  4(7)  have  been  applied.  However  in 
the Grand Harbour water body several new developments are planned (for example, a 
cruise  terminal,  waterfront  development,  and  a  "Dock  1  Project”)  but  no  exemptions 

according to Article 4(7) have been applied.  

  Recommendation:  While  the  WFD  does  provide  for  exemptions,  there  are  specific 
criteria that must be fulfilled for their use to be justified. The application of exemptions 

50   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  

103 

 
 
                                                      
 
needs  to  be  more  transparent  and  the  reasons  for  the  exemptions  should  be  clearly 

justified in the plans” 

Assessment:  In  the  RBMP  technical  feasibility  and  natural  conditions  were  used  to 

justify exemptions according to Article 4(4). The RBMP provides detailed justifications 
on water body level. The recommendation has been fulfilled.  

  Recommendation:  Malta  should  indicate  in  the  second  RBMP  when  WFD  objectives 

will be achieved. Exemptions should be adequately justified at water body level.  

Assessment:  The  dates  by  when  surface  water  bodies  will  achieve  good  ecological 
status/potential  (lake,  river  and  transitional  water  bodies)  were  not  reported. 

Information  is  available  for  coastal  water  bodies  and  groundwater.  For  the  chemical 
status no dates were given for coastal waters. Exemptions are justified on water body 

level. This recommendation has been partly fulfilled.  

104 

 
 
 
 
 
Topic 9

  Programme of measures  

The aim of this chapter is to provide an overview of the Programme of Measures reported by 

the  Member  State;  more  specific  information  on  measures  relating  to  specific  pressures  (for 
example arising from agriculture) is provided in subsequent chapters. 

The  Key  Types  of  Measures  (KTM)  referred  to  in  this  section  are  groups  of  measures 
identified  by  Member  States  in  the  Programme  of  Measures,  which  target  the  same 

pressure  or  purpose.  The  individual  measures  included  in  the  Programme  of  Measure 
(being  part  of  the  RBMP)  are  grouped  into  Key  Types  of  Measures  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 Measures 

are not completely independent. Key Types of Measures have been introduced to simplify 
the  reporting  of  measures  and  to  reduce  the  very  large  number  of  Supplementary 

Measures reported by some Member States in 2010 (WFD Reporting Guidance 2016).  

A  Key  Type  of  Measure  may  be  one  national  measure  but  it  would  typically  comprise 
more than one national measure. The 25 predefined Key Types of Measures are listed in 

the WFD Reporting Guidance 2016. 

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

9.1  Assessment of implementation and compliance with WFD requirements 

in the second cycle 

9.1.1 General issues 

An  indication  as  to  whether  or  not  measures  have  been  fully  implemented  and  made 

operational is when they have been reported as being planned to tackle significant pressures (at 
the  Key  Types  of  Measure  level).  Significant  pressures  are  also  reported  at  the  water  body 

level.  It  would  therefore  be  expected  that  there  would  be  measures  planned  in  the  RBMP  to 
tackle all significant pressures. For groundwater bodies KTMs are in place to address only two 

of the significant pressures reported as causing groundwater bodies to fail to be of good status: 
“abstraction  or  flow  diversion  –  agriculture”  and  –  “Abstraction  or  flow  diversion  -  Public 
water supply”. The other significant pressures that have been reported as causing groundwater 

105 

 
 
 
bodies to fail to be of good status but which do not have operational KTMs in place to address 
them are 1.3 - Point - IED plants51, 1.4 - Point - Non IED plants, 1.6 - Point - Waste disposal 
sites, 2.2 - Diffuse – Agricultural, and 6.2 - Groundwater - Alteration of water level or volume. 

For  surface  waters  all  significant  pressures  reported  as  causing  a  failure  of  objectives  were 
reported to be addressed by KTMs52. 

51 national basic measures and 54 national supplementary measures have been mapped against 
11 of the 25 predefined KTMs. Of these, 27 % of the national basic measures and 26 % of the 

national  supplementary  measures  have  been  mapped  against  KTM  8  -  "Water  efficiency, 
technical  measures  for  irrigation,  industry,  energy  and  households".  30  %  of  the  national 

supplementary  measures  have  been  mapped  against  KTM  14  -  "Research,  improvement  of 
knowledge  base  reducing  uncertainty".  Malta  has  developed  a  number  of  other  KTMs, 

specifically awareness raising related to marine litter and waste management, conservation of 
water  dependent  habitats  and  species,  improving  data  management  structures,  improving 

marine and terrestrial emergency response and refine existing regulatory controls. Of the basic 
measure types only those required by Articles 11(3)(a)(c)(f)(g)(h)(i)(k) have been adopted. An 
inventory of national measures has been reported with links to where further information can 

be found. 

Basic measures have been mapped against more KTMs than have been reported to be tackling 

significant pressures – those that are not linked to any pressure are: 

 

 

 

KTM2 – Reduce nutrient pollution from agriculture; 

KTM3 – Reduce pesticides pollution from agriculture 

KTM6 – Improving hydromorphological conditions of water bodies other than 
longitudinal continuity; 

 

KTM7  –  Improvements  in  flow  regime  and/or  establishment  of  ecological 

flows; 

 

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; 

51   Malta also reported measures specifically to address mercury. 
52   Malta  subsequently  clarified  that  point-IED  sources  are  identified  significant  because  of  their  potential  to 
pollute  groundwater  –  current  monitoring  data  shows  that  such  sources  do  not  currently  cause  any 
groundwater bodies to fail to be of good status. Point-non-IED plants were identified as a significant pressure 
due to their wide geographical coverage. 

106 

 
 
                                                      
 

KTM18 – Measures to prevent or control the adverse impacts of invasive alien 

species and introduced diseases; 

 

KTM19  –  Measures  to  prevent  or  control  the  adverse  impacts  of  recreation 

including angling; and 

 

KTM21  –  Measures  to  prevent  or  control  the  input  of  pollution  from  urban 

areas, transport and built infrastructure. 

KTM  1  -  "Construction  or  upgrades  of  wastewater  treatment  plants"  has  not  been  mapped 
against national measures but it is reported to be tackling significant pressures53.  

A number of new KTMs developed by Malta are reported to be tackling significant pressures, 
specifically: 

- 

- 

- 

characterise  and  quantify  hydrological  input  of  land  based  contaminants  (including 
litter) to coastal waters from major sub catchments,  

investigate the role of transboundary contaminants through hydrographic pathways and 
the extent of its contribution to marine contamination,  

carry out investigations to gauge potential contribution of contaminants to our coastal 
waters by atmospheric deposition,  

- 

carry  out  a  survey  of  all  direct  discharges  to  sea  and  identify  their  source  with  the 

objective of setting up a plan to curtail / regulate such discharges,  

- 

establish a Mercury Management Plan to enable the investigation of potential sources 

of mercury and potential mitigation measures. 

This list of new KTMs is completely different to the list of new KTMs against which national 

measures have been mapped. Further clarity on the status of the measures adopted to address 
significant pressures is required. No information is provided in Malta on percentage of water 

bodies  affected  by  significant  pressures  that  are  not  expected  to  achieve  good  status  or 
potential  by  2027,  and  further  investigation  in  RBMP  and  background  documents  of  the 

53   Malta subsequently clarified that KTM 1 – Construction or upgrades of wastewater treatment plants was not 
chosen  as  a  KTM  because  upgrades  or  improvements  to  the  wastewater  treatment  plants  are  generally 
considered  as  part  of  the  general  upgrading  process  of  these  plants,  which  programme  falls  under  the 
implementation process of the UWWTD Directive. 

107 

 
 
                                                      
assessment  showed  that  the  selection  of  measures  has  not  taken  the  status  of  the  water  body 
into account54. 

There were two pollutants causing failure to achieve good status in groundwater bodies: nitrate 

(in  12  groundwater  bodies)  and  electrical  conductivity  (in  five  groundwater  bodies).  No 
information is provided on either the River Basin Specific Pollutant causing a failure of good 
status in surface water bodies or the measures in place to address the failure55. 

Mercury  is  the  only  priority  substance  causing  failure  to  achieve  good  status  in  nine  surface 

water  bodies.  A  new  KTM  SWM10  –  “Establish  a  Mercury  Management  Plan  to  enable  the 
investigation of potential sources of mercury and potential mitigation measures” is reported to 

be in place to address this.  

Very limited information was reported on the gap to good status to be addressed by the KTMs 

for  significant  pressures  and  the  progress  in  implementation  of  the  measures  expected, 
however in some cases numeric indicators were provided.  

Indicators  of  the  gap  to  good  status  of  groundwater  bodies  were  reported  for  the  significant 
pressures  “abstraction  or  flow  diversion  –  agriculture”  and  “abstraction  or  flow  diversion  - 
public  water  supply”.  Indicators  for  the  progress  in  the  implementation  of  measures  were 

reported for two KTMs for each of these two pressures. For both pressures, two water bodies 
were reported to be affected, and good status is expected to be achieved by 2021.  

Indicators for the gap to good status of surface water bodies were reported for the significant 
pressures,  “point  -  urban  waste  water”,  “point  –  other”,  “diffuse  –  other”,  “anthropogenic 

pressure  –  unknown”  and  “mercury  and  its  compounds”.  Indicators  of  the  level  of  progress 
expected in the implementation of the measures to address these pressures were also reported. 

For the significant pressure “point - urban waste water”, only one water body is reported to be 
affected  and  good  status  is  expected  to  be  achieved  by  2021.  For  all  the  other  significant 

pressures,  nine  water  bodies  are  reported  to  be  affected  in  2015,  but  no  indication  of  the 
progress that is expected in 2021 or 2027 is provided. 

54   Malta  subsequently  confirmed  that  the  selection  of  measures  has  taken  into  consideration  the  status  of  the 
water bodies, since measures address significant management issues identified on the basis of monitoring data 
and water body status.  

55   Malta  subsequently  clarified  that  measures  targeting  the  poor  chemical  quality  of  water  bodies,  are  in  fact 
addressing  all  River  Basin  Specific  Pollutants  (in  relation  to  ecological  status)  and  Priority  Substances  (in 
relation  to  chemical  status).  ‘General  Surface  Water  Measures’  aim  to  tackle  the  most  significant  point  and 
diffuse sources identified as an outcome of the monitoring programmes carried out under the first RBMP  

108 

 
 
                                                      
9.1.2 Cost effectiveness of measures 

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  used  as  a  tool  for  the  appraisal  of 

measures  in  the  first  RBMP  due  to  a  lack  of  data.  For  the  second  RBMP  the  information 
reported  to  WISE  indicated  that  a  combination  of  both  quantitative  and  qualitative  cost-

effectiveness  analysis  has  been  carried  out  in  Malta,  supporting  the  selection  of  measures 
proposed under the 2016-2021 Programme of Measures.  

The  prioritisation  of  measures  was  further  investigated  by  examining  the  RBMP  and 
background  documents  where  it  was  found  that  there  has  been  no  real  prioritisation  of 

measures. It is stated that a cost-effectiveness analysis has been performed on all measures that 
will  be  implemented  during  the  second  cycle,  assessing  "costs"  and  "effectiveness"  by  a 

scoring system, resulting in a ranking of measures by the costs per scoring point. However, it is 
not clear whether such a prioritisation was actually performed or played any role in selecting 
the measures or  assigning priorities for implementation.  It  is  mentioned in  the description of 

one measure only ("FLD 5 - implementation of sustainable urban drainage systems and natural 
water retention measures as identified under measure FLD 3") that concrete projects will "be 

prioritised according to the project mitigation potential, both from a quantitative perspective 
(reduction  in  rainwater  runoff  generation)  and  the  impact  on  the  population  and  economic 

activities in the catchment". 

9.1.3 Financing of Measures 

A  critical  factor  in  the  success  of  the  implementation  of  the  Programme  of  Measures  is  the 

availability of funding to support the investments required.  

Investment costs for the first Programme of Measures (2009-2015) have been reported as EUR 

99  700  000  for  Article  11(3)(a)  requirements  (measures  required  to  implement  community 
legislation for the protection of water) and EUR 77 370 000 for the requirements of Articles 
11(3)(b)(l),  11(4)  and  11(5)  (all  other  measures).  This  represents  a  total  investment  of  EUR 
177 000 000 .  

For  the  second  Programme  of  Measures  (2016-2021)  it  has  been  reported  that  a  capital 
investment of EUR 9 500 000 will be required for Article 11(3)(a) measures, but that no annual 

operation or maintenance costs will be incurred. The capital investment required for measures 
required by Articles 11(3)(b)( l), 11(4) and 11(5) (all other measures) is reported to  be  EUR 

109 

 
 
190 400 000 with annual operation and maintenance costs of EUR 6 237 000. Depreciation has 

not been included in any calculations.  

European  Union  investment  expenditure  for  the  Programme  of  Measures  is  reported  to  have 

been EUR 32 700 000 for the first Programme of Measures (18 %) and EUR 152 200 000 for 
the second planning cycle (76 %).  

It has been reported that clear financial commitments have been secured for the Programme of 
Measures in Malta from all relevant sectors.  

9.1.4 Coordination  with  the  Marine  Strategy  Framework  Directive  and  the  Floods 

Directive 

There was a joint consultation carried out on the RBMPs and Marine Strategy in Malta. The 
preparation  of  the  RBMP  and  Programme  of  Measures  has  been  reported  to  be  coordinated 
with  the implementation of the Marine Strategy  Framework  Directive56.  It has been  reported 
that there is a need for additional measures or more stringent measures beyond those required 

by  WFD  to  control  litter  in  order  to  contribute  to  the  achievement  of  the  relevant  Marine 
Strategy Framework Directive objectives in costal and marine environments.  

The  RBMP  and  Floods  Directive  Flood  Risk  Management  Plan  have  been  integrated  into  a 

single plan in Malta (also refer to in Chapter 1 on  Governance and public participation). The 
joint  consultation  was  carried  out  on  the  RBMP  and  Flood  Risk  Management  Plan,  and  the 

objectives and requirements of the Floods Directive have been considered in the second RBMP 
and Programme of Measures in Malta. Malta 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  Programme  of  Measures.  The 

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

financial commitment has been secured for the implementation of the Programme of Measures 
in  the  flood  protection  sector.  Article  9(4)  has  not  been  applied  to  impoundments  for  flood 
protection in Malta57. 

56   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  

57   Malta  subsequently  clarified  that  impoundments  for  flood  protection  are  not  relevant  in  the  geographical 
context of Malta, and hence this is the reason why Article 9(4) has not been applied to impoundments for flood 
protection 

110 

 
 
                                                      
9.1.5 Measures related to other significant pressures 

Only one other significant pressure has been reported 8 – “anthropogenic pressure unknown”, 

which  is  causing  failures  in  surface  water  bodies.  The  percentage  of  surface  water  bodies 
affected by this pressure has not been reported, but the indicator of the gap to good status for 

2015 was reported to be nine water bodies. Other national KTMs have been reported as being 
in  place to  address  these measures. No indication of the progress  to  good status  expected by 

2021 or 2027 has been reported.  

A total of six measures are being planned to tackle significant other pressures: three measures 

encompassed  by  KTM  18  -  "Measures  to  prevent  or  control  the  adverse  impacts  of  invasive 
alien  species  and  introduced  diseases"  and  three  measures  encompassed  by  KTM  19  - 

"Measures to prevent or control the adverse impacts of recreation including angling").  

 

The  measures  for  KTM  18  -  "Measures  to  prevent  or  control  the  adverse  impacts  of 

invasive alien species and introduced diseases" are: plan, implement and monitor an alien 
plant/fauna eradication programme;  eradicate pests  that are  a threat  to  water dependent 

species;  and  extend  the  basic  measure  related  to  the  removal  of  alien  species  from  the 
Qattara  habitat,  as  identified  in  the  Natura  2000  management  plan,  to  the  Ghadirra  ta 

Sarraflu.  

 

The  measures  for  KTM  19  -  "Measures  to  prevent  or  control  the  adverse  impacts  of 

recreation including angling" are: development of bathing water profile for bathing areas; 
lobby with users of protected areas for better protection; and to patrol the protected areas 
during the hunting season, weekends, public holidays and planned activities58.  

 

Additionally, an awareness campaign on the impacts of marine litter (KTM 99 – “Other 
key type measure reported under Programme of Measures”) is planned59.  

No measures are reported for KTM20 - "Measures to prevent or control the adverse impacts of 

fishing and other exploitation/removal of animal and plants". 

58   Malta subsequently provided additional information that a further measure under KTM99 – Other Key Type of 
Measure  Reported in the Programme of Measures  - Streamline designated Bathing  waters as defined by the 
Environmental Health Directorate  with designated  Swimming  Zones as regulated by Transport Malta  where 
these two areas overlap or are in close proximity to each other was also relevant to this KTM. 

59   Malta subsequently provided additional information that a measure listed under KTM21 - Measures to prevent 
or  control  the  input  of  pollution  from  urban  areas,  transport  and  built  infrastructure  -  Develop  a  system  to 
encourage adequate litter management and control in coastal areas and a measure listed under KTM99 - Other 
key  type  measure  reported  in  the  Programme  of  Measures  -  Targeted  awareness  campaign  on  impacts  of 
marine litter are also relevant. 

111 

 
 
                                                      
9.1.6 Mapping of national measures to Key Types of Measure 

It was expected that Member States would be able to report their Programme of Measures by 

associating their national measures with predefined KTMs. KTMs are expected to deliver the 
bulk  of  the  improvements  through  reduction  in  pressures  required  to  achieve  WFD 

Environmental  Objectives.  A  KTM  may  be  one  national  measure,  but  it  would  typically 
comprise more than one national measure. Member States are required to report on the national 

measures  associated  with  the  KTMs,  and  whether  the  national  measures  are  basic  -  Article 
11(3)(a) or Article 11(3)(b-l), or supplementary - Article 11(4).  

Table 9.1 summarises the number of national measures that have been mapped to the relevant 
KTMs  in  Malta.  Table  9.2  then  summarises  the  type  of  basic  measures  associated  with  the 

national measures mapped against the KTM. 

112 

 
 
 
Table 9.1 

Mapping of the types of national measures to Key Types of Measure in Malta  

National 
basic 
measures 

National 
supplementary 
measures 

Number 
of RBDs 
where 
reported 

Key Type of Measure 

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 

KTM18 - Measures to prevent or control the adverse impacts 
of invasive alien species and introduced diseases 

KTM19 - Measures to prevent or control the adverse impacts 
of recreation including angling 

KTM2 - Reduce nutrient pollution from agriculture 

KTM21 - Measures to prevent or control the input of 
pollution from urban areas, transport and built infrastructure 

KTM23 - Natural water retention measures 

KTM3 - Reduce pesticides pollution from agriculture. 

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 

KTM99 - Other key type measure reported under 
Programme of Measures – Awareness raising related to 
marine litter and waste management 

KTM99 - Other key type measure reported under 
Programme of Measures - Conservation of water dependent 
habitats and species 

KTM99 - Other key type measure reported under 
Programme of Measures - Improving data management 
structures 

KTM99 - Other key type measure reported under 
Programme of Measures - Improving marine and terrestrial 
emergency response 

KTM99 - Other key type measure reported under 
Programme of Measures - Refine existing regulatory 
controls 

16 

1 

1 

1 

5 

4 

2 

9 

2 

2 

3 

2 

4 

1 

4 

1 

14 

14 

8 

1 

2 

1 

1 

3 

3 

Total number of Mapped Measures 

51 

54 

Source: WISE electronic reporting 

113 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

 
 
 
 
 
 
 
 
 
 
Table 9.2 

Type of basic measure mapped to Key Type of Measures in Malta  

Key Type of Measure 

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 
KTM18 - Measures to prevent or control 
the adverse impacts of invasive alien 
species and introduced diseases 
KTM19 - Measures to prevent or control 
the adverse impacts of recreation including 
angling 
KTM2 - Reduce nutrient pollution from 
agriculture 
KTM21 - Measures to prevent or control 
the input of pollution from urban areas, 
transport and built infrastructure 
KTM3 - Reduce pesticides pollution from 
agriculture. 

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 
KTM99 - Other key type measure reported 
under PoM 

Basic Measure Type 

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o
m
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a
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t
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g

5 

2 

1 

r
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n
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y
t
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u
S

s
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a
t
s
b
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S

1 

1 

1 

1 

2 

1 

1 

1 

1 

1 

1 

1 

1 

2 

2 

3 

1 

8 

13 

Source: WISE electronic reporting  

Key 

‘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. 
‘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. 

114 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
‘Urban Waste Water’ = Urban Waste Water Treatment Directive (91/271/EEC). 

9.1.7 Pressures for which gaps to be filled to achieve WFD objectives have been reported 

and the Key Types of Measures 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 cycle 

Often there is no equivalent information for the first cycle and it is difficult, therefore, to make 
direct  comparisons  between  the  two  RBMPs  on  what  has  changed  significantly.  Little 

information was reported on the scale and expected progress with implementation of measures 
in  the  second  cycle  leading  to  the  achievement  of  WFD  objectives.  It  was  not  clear  how 

115 

 
 
 
measures  were  selected  in  the  first  cycle.  For  the  second  Programme  of  Measures,  it  is  not 

clear whether measures have still not been selected on the basis of the status of the water body 
or otherwise60. It has been reported that the combination of both, quantitative and qualitative 
cost  effectiveness  analysis  has  been  carried  now  to  support  the  selection  of  measures  in  the 
second cycle.  

The  main  changes  in  the  implementation  of  the  WFD  in  relation  to  the  Programme  of 
Measures were further investigated through a review of the RBMP and background documents 

where it was found that there is no summary of changes/updates regarding the Programme of 
Measures61.  Instead,  the  Maltese  RBMP  explains  the  actions  done  in  the  first  management 
cycle  (in  Chapter  7  of  the  RBMP),  and  states:  "Some  of  the  issues  identified  in  the  previous 
preparation  phase  (that  is,  2009)  of  the  first  Water  Catchment  Management  Plan  are  still 

present  day  realities  and  are  therefore  reiterated  in  this  plan  (refer  to  Chapter  7  for  details 
about  what  was  implemented  under  the  first  cycle).  In  addition,  however,  comprehensive 

monitoring  of  our  coastal  waters  in  2012-13  has  brought  to  the  fore  additional  issues  of 
concern.  Additional  measures  have  therefore  been  identified  to  deal  with  these  management 
issues. Such measures would be required in order to ensure that good status is maintained in 

waters where this has already been achieved; and good status is met in those waters where this 
is yet to be accomplished." However, there is no overview of which measures stem from the 

first  cycle,  which  from  the  second,  and  which  ones  will  be  continued  from  the  first  into  the 
second cycle. 

Malta has reported a significant increase in the funding available for the second Programme of 
Measures, which includes a significant increase in the contribution from EU funds. 

New legislation or  regulations to  implement  the Programme of Measures were considered in 
the first cycle and have been reported to be in progress. 

9.3  Progress with Commission recommendations 

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

requested action on the following: 

60   Malta subsequently clarified that the size of the smaller groundwater bodies in Malta, ranging between 1 and 5 
square kilometres, precludes the development of measures to specifically address the specific issues at water 
body  scale.  In  as  much,  comprehensive  measures  were  developed  to  address  all  the  identified  issues  on  an 
RBD  scale.  In  respect  of  surface  waters,  Malta  notes  that  the  measures  are  targeted  to  address  all  the 
significant management issues identified, which were in turn identified on the basis of monitoring data and the 
status of water bodies.  

63   Malta subsequently clarified that such an analysis of the measures in the first and second RBMPs was included 
in  Annex  V  to  the  RBMP.  Unfortunately,  the  version  of  the  RBMP  uploaded  by  Malta  to  WISE  did  not 
include Annex V (only Annexes I, II and III) and therefore this could not be assessed. 

116 

 
 
                                                      
  Recommendation: Where there are currently high uncertainties in the characterisation 
of the RBDs, identification of pressures, and in the 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:  It  is  not  completely  clear  how  measures  were  selected,  but  it  has  been 

reported cost effectiveness of measures have been carried out as combination of both, 
quantitative and qualitative cost effectiveness analysis to support selection of measures. 

This  was  further  investigated  through  a  review  of  relevant  RBMP  and  background 
documents of the assessment in which it was found that the status of water bodies has 

not been taken into consideration in the selection of measures. The exact methods used 
for the selection of measures are also not clear. Malta subsequently clarified that “due 

to the small size of groundwater bodies in Malta (particularly the smaller groundwater 
bodies)  measures  were  developed  on  the  scale  of  the  River  Basin  District.  However 

these  measures  comprehensively  address  all  the  status-failing  objectives  in  all  the 
groundwater bodies. The same applies for surface water bodies.” Given this additional 

information, it can be considered that Malta has partially fulfilled this recommendation, 
but if possible, should make efforts to directly link the status of individual water bodies 

with measures for the third planning cycle. 

  Recommendation:  Meaningful  information  regarding  the  scope,  the  timing  and  the 
funding  of  the  measures  should  be  included  in  the  Programme  of  Measures  so  the 
approach  to  achieve  the  objectives  is  clear  and  the  ambition  in  the  Programme  of 

Measures  is  transparent.  All  the  relevant  information  on  basic  and  supplementary 
measures should be included in the summary of the Programme of Measures to ensure 

transparency  on  the  planned  actions  for  the  achievement  of  the  environmental 
objectives set out in the WFD. 

Assessment:  In  the  first  cycle,  the  participation  of  industrial  and  tourism  sectors  was 
very low, measures were projected to cost about 0.009 % and 0.05 % of the gross value 
added of the industrial and tourist sectors respectively. This was a strong contradiction 
with  the  statements  that  are  used  to  extend  the  deadline  for  the  achievement  of 

objectives. The agriculture sector was not even mentioned as contributor for sharing the 
costs of measures. The costs of basic measures have now been reported. Financing of 

measures  has  been  reported  with  approximately  76  %  of  costs  being  covered  by 
European  Union  funds  in  the  second  cycle.  Clear  financial  commitments  have  been 

secured  for  agricultural,  industry,  urban,  transport,  aquaculture,  recreation  and  flood 
protection  in  the  second  cycle.  Hydropower  and  energy  have  been  reported  not  to  be 

117 

 
 
relevant.  It  is  not  clear  on  what  basis  the  contribution  between  different  sectors  is 

assessed.  In  the  RBMP  Malta  has  provided  a  detailed  list  of  the  measures  to  be 
implemented  including  some  actions  for  the  implementation  of  these  measures. 

However – some of these timescales are quite loosely defined (e.g. “Terms of reference 
for  the  study  will  be  developed  and  awarded  by  second  quarter  2016”).  Furthermore 

there  is  no  assessment  of  the  contribution  that  it  is  expected  that  each  measure  will 
make  to  the  achievement  of  good  status.  Therefore  this  recommendation  has  been 

partially fulfilled. 

  Recommendation: Identify clearly basic measures in the second RBMPs to allow for a 

clear assessment of the need for additional measures. 

Assessment: From the data reported it is clear that basic measures have been identified 

and  national  basic  and  supplementary  measures  have  been  mapped  against  KTMs, 
including new KTMs. An inventory of national measures has been reported with links 

to where further information can be found. However, because the basis for the selection 
of measures is not clear, the assessment of the need for additional measures is not clear, 

and therefore this recommendation has been partially fulfilled.  

  Recommendation:  Ensure  in  the  second  RBMPs  that  measures  adopted  in  the 
Programme of Measures are based on a reliable status assessment of water bodies and 
are  linked  to  the  relevant  pressures.  Malta  should  also  specify  the  impact  of  the 

planned measures. 

Assessment:  It  was  not  clear  from  the  data  reported  to  WISE  whether  this 

recommendation had been met.  It  was therefore  further investigated by reviewing the 
RBMP  and  background  documents  where  it  was  found  that  the  Programme  of 

Measures is not based directly on the status assessment of water bodies. No information 
on the proportion of water bodies affected by significant pressures has been reported to 

WISE.  The  information  on  reported  on  the  impact  of  the  planned  measures  does  not 
cover all measures reported. Whilst it is clear that Malta has based the development on 

the Programme of Measures on the significant water management issues identified, no 
assessment of the contribution of each measure will make to the achievement of good 

status  in  water  bodies  has  been  carried  out.  This  recommendation  has  been  partially 
fulfilled but further steps are required. 

  Recommendation: Ensure that the RBMPs clearly identify the gap to good status, and 
that the Programme of Measures is designed and implemented to close that gap. Malta 

118 

 
 
should  indicate  in  the  second  RBMP  when  WFD  objectives  will  be  achieved. 

Exemptions should be adequately justified at water body level.  

Assessment: Malta has taken some significant steps to identify the gaps to good status 

for  some  parameters.  The  Programme  of  Measures  has  been  developed  in  order  to 
address  the  significant  water  management  issues  identified,  but  no  quantitative 

assessment of the contribution  each measure will make  to  the closure of the gaps has 
been  carried  out.  Malta  has  identified  where  good  status  cannot  be  achieved  and 

provided justification for this, but it is unclear what level of confidence there is in the 
ability of the measures to deliver good status. This recommendation has been partially 

fulfilled.  

  Recommendation: Prioritise measures and explain in more detail in the second RBMP 

its approach to identifying them. 

Assessment: It has been reported that cost effectiveness of measures have been carried 

out as a combination of both, quantitative and qualitative cost effectiveness analysis to 
support  the  selection  of  measures.  Further  information  was  sought  in  the  RBMP  and 

background  documents  on  this  issue.  Clear  information  on  the  prioritisation  of 
measures  could  only  be  found  for  one  measure,  and  it  is  not  clear  whether  a 

prioritisation  using  cost-effectiveness  analysis  has  been  carried  in  the  selection  of 
measures. This recommendation has therefore not been fulfilled.  

  Recommendation:  Available  funding,  in  particular  the  European  Union  funds  (for 
example,  RDP funds, Structural and Investment  Funds, LIFE Integrated  Projects  and 

Horizon  2020)  needs  to  be  exploited  as  much  as  feasible  in  order  to  implement 
Programme  of  Measures.  Consequently,  appropriate  priorities  should  be  set  in  the 

programming  documents  (PA,  OPs  and  RDPs)  of  the  new  European  Union  funding 
policy 2014- 2020. 

Assessment:  Clear  financial  commitment  has  been  reported  as  secured  in  Malta.  It  is 
reported that approximately 76 % of costs will be covered by European Union funds in 

the second cycle, compared to 18 % in the first cycle. This recommendation has been 
fulfilled. 

  Recommendation: Perform the cost-effectiveness analysis as planned. Based on this, a 
clear prioritisation of measures and an explanation of the process should be developed. 

The  justification  for  disproportionality  of  costs  of  measures  should  be  improved.  The 

119 

 
 
effectiveness  of  the  implemented  measures  will  have  to  be  demonstrated  by  the 

assessment of the status/potential of water bodies in the second RBMP.  

Assessment: It has been reported that cost effectiveness of measures have been carried 

out  as  combination  of  both  quantitative  and  qualitative  cost  effectiveness  analysis  to 
support  selection  of  measures.  Further  information  was  sought  in  the  RBMP  and 

background documents of the assessment. It is clear that the status of water bodies has 
not been taken into consideration in the development of the Programme of Measures62, 
and an explanation of the process for the selection and prioritisation of measures could 
not be found. From the aspect of the Programme of Measures this recommendation has 

not been fulfilled.  

62   Malta stated that due to the small size of groundwater bodies in Malta (particularly the smaller groundwater 
bodies)  measures  were  developed  on  the  scale  of  the  River  Basin  District.  However  these  measures 
comprehensively address all the status-failing objectives in all the groundwater bodies. The same applies for 
surface water bodies.   

120 

 
 
 
 
                                                      
Topic 10

  Measures related to abstractions and water scarcity  

10.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle 

10.1.1  Water exploitation and trends  

Water abstraction pressures are reported as relevant for Malta; and 13 % of groundwater bodies 
face  water  quantity-related  problems  for  achieving  good  quantitative  status.  The  Water 

Exploitation Index + is 97 % (2014) which is an extraordinarily high figure and might indicate 
risks  of  sustainable  water  use.  No  water  quantity  data  have  been  reported  to  support  the 

European State of the Environment Report in relation to Water Quantity. The RBMP does not 
include a water resource and allocation management plan. 

10.1.2  Main uses for water consumption  

Regarding water consumption, 48 % of groundwater is used by agriculture, and 37 % by urban 
uses. Agricultural use is however determined mainly from statistics. Note there is a difference 

between  information  reported  and  the  RBMP  content  on  the  source  of  data  for  agricultural 
water  abstractions.  Measurement  and  monitoring  are  the  basis  for  calculating  urban  water 

consumption. 

10.1.3  Measures related to abstractions and water scarcity  

Regarding  basic  measures  -  Article  11(3)(e),  in  Malta  there  is  a  concession,  authorisation 

and/or permitting regime to control groundwater and a register of groundwater use; and small 
abstractions are  exempted from  these controls.  There is  no information  in the second RBMP 

regarding  the  procedures  and  resources  in  place  to  control  abstractions;  the  second  RBMP 
(Section  7.2.1)  only  presents  a  list  of  the  regulations  enacted,  without  providing  any 
information on controls and compliance mechanisms63. The first RBMP showed the enactment 
of an optimised regulatory framework to control abstraction of groundwater better64.  

63   Malta  subsequently  clarified  that  the  information  on  controls  and  compliance  mechanisms  are  included  as 

statutory provisions under the cited legislation. 

64   Malta  subsequently  clarified  that  the  Subsidiary  Legislation  423.12  requires  all  groundwater  abstraction 
stations  to  be  registered  independent  of  their  annual  yield.  Subsidiary  Legislation  423.40  however  exempts 
specific abstraction points from metering when: (a) no pump or other mechanical device is installed or used to 
abstract groundwater from such groundwater source; (b) if it is proved by the  user to be a cultural property 
under the Cultural Heritage Act; or (c) if it is declared as such by the user that the source is used solely for 
domestic purposes by the user’s household and where the abstraction yield from such source does not exceed 
one cubic metre per day. It is noted that all ‘perched aquifer’ systems, where exempted abstraction points are 
located,  are  classified  to  be  in  good  quantitative  status.  It  is  further  noted  that  some  of  these  groundwater 
sources have historical value having been constructed during the Roman or Arabic periods (prior to 1000AD) 

121 

 
 
                                                      
The regulatory framework of the second RBMP is based on the following legislation:  

  Legal Notice 254 of 2008, entitled Borehole Drilling and Excavation Works within the 
Saturated  Zone  Regulations,  which  established  a  regulatory  framework  for  borehole 

drilling and excavation works carried out partly or totally within the saturated zone.  

  Legal  Notice 255 of 2008, entitled Notification of Groundwater Sources  Regulations; 
which  established  a  time-limited  period  wherein  existing  groundwater  abstraction 
sources were to be notified to the regulator, following which all un-notified abstraction 

sources would be considered as illegal.  

  Legal  Notice  241  of  2010,  entitled  Groundwater  Abstraction  (Metering)  Regulations, 
which  established  a  requirement  for  the  metering  of  all  significant  groundwater 

abstraction sources.  

  Legal  Notice  395  of  2010,  entitled  Groundwater  Sources  (Application)  Regulations; 
which allows the notification of historical and low yield (measures on Article 11(3)(c) 
for  sustainable  and  efficient  water  use  have  been  implemented  in  the  previous  cycle, 

and new measures and/or significant changes are planned for the 2016-2021 period).  

The second RBMP is based on supplementary measures, and no basic measures were targeted 

at  promoting  efficient  and  sustainable  water  use.  Demand-side  supplementary  measures 
included: 

  Development  of  a  water  demand  map  representing  the  spatial  variation  of  water 
demand in terms of quality and quantity, and establishment of benchmarks for efficient 
water use.  

  Support mechanisms for water consumption audits in households. 

  Support  schemes  for  the  uptake  of  efficient  irrigation  technology  by  the  arable 

agricultural sector. 

and water is abstracted from them by buckets. Whenever cases of illegalities are encountered by the regulatory 
authorities, imposition of administrative fines and the permanent closure of the source are applied, and in case 
of non-compliance, criminal prosecution follows. Furthermore, it is clarified that the second RBMP includes 
several  measures  to  promote  an  efficient  and  sustainable  water  use.  These  measures  were  considered  to  be 
supplementary in nature. Furthermore, impoundments for flood protection are not relevant in the geographical 
context  of  Malta.  The  only  impoundments  present  in  Malta  relate  to  small  masonry  dams  in  dry  valleys 
(referred to as dry rivers for the purpose of EU reporting) which have been developed in the late 1800’s with 
the scope of collecting rainwater runoff for infiltration and use by the agricultural sector. The total collection 
capacity  of  these  small  masonry  dams  is  below  125,000  m3,  and  hence  are  of  marginal  importance  from  a 
quantitative perspective. 

122 

 
 
                                                                                                                                                        
  Support schemes for the uptake of efficient water technology by the animal husbandry 

sector. 

  Support  schemes  for  the  development  of  rainwater  harvesting  facilities  in  the 

agricultural and commercial sectors. 

  Establishment of minimum technical and economic levels of leakage in the municipal 

distribution network, and achievement of these thresholds. 

  Development of a long-tern National Water Conservation Campaign. 

  Establishment  of  a  voluntary  eco-labelling  scheme  for  water-use  fixtures  and 

appliances. 

  Upgrading the water use efficiency of public buildings and structures. 

For each of these measures, a planned implementation time horizon and responsible authorities 

were identified in the RBMP. 

In the RBMP, there is some information on what was implemented in the first cycle, but it is 

not clear to which degree or how the measures/ topics listed were implemented on the ground: 

The  RBMP  does  not  report  quantitative  information  on  implementation  or  effects  on  water 

body status. However, it does state that: 

  The measures included the metering of groundwater abstraction sources operated by the 
agricultural and commercial sectors; and the development of a data analysis tool which 
would  permit  the  identification  of  high-water  abstractors  to  direct  the  focus  of  agri-

advisory services. 

  Measures  for  the  prior  authorisation  of  artificial  recharge  or  augmentation  of 
groundwater  bodies  under  Article  11(3)(f)  have  been  implemented  in  the  previous 
cycle,  and  new  measures  and/or  significant  changes  are  planned  for  the  2016-2021 

period. 

  KTM8  -  "Water  efficiency,  technical  measures  for  irrigation,  industry,  energy  and 
households"  and  KTM  14  -  “Research,  improvement  of  knowledge  base  reducing 
uncertainty” were applied to tackle abstractions for agriculture and KTM23 – “Natural 

water retention measures” was applied to tackle abstractions for public water supply. 

123 

 
 
  Water reuse was also foreseen as a measure. 

Exemptions for permitting and registration of small abstractions might need to be reviewed, as 
13 % of groundwater bodies do not achieve good quantitative status. 

10.2 Main changes in implementation and compliance since the first cycle 

Malta has taken action to improve its control on groundwater abstractions, by the adoption and 
implementation  of  specific  regulations.  However,  the  knowledge  base  for  appropriate  water 

resource allocation management seems to be insufficient, as there is still limited data collection 
from metering within the agricultural sector65. This is in spite of the implementation in the first 
cycle  of  the  metering  of  groundwater  abstraction  sources  operated  by  the  agricultural  and 
commercial  sectors,  and  the  development  of  a  data  analysis  tool  which  will  permit  the 
identification  of  high-water  abstractors  to  direct  the  focus  of  agri-advisory  services66. 
Furthermore,  exemptions  for  permitting  and  registration  for  small  abstractions  might  need  to 
be  reviewed,  and  further  control  on  abstractions  ensured  as  a  significant  proportion  of 
groundwater bodies do not achieve good quantitative status67. 

10.3 Progress with Commission recommendations 

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

  Recommendation:  The  problem  of  water  scarcity  and  over-abstraction  that  are 
significant  pressures  and  cause  poor  quantitative  status  should  be  tackled  with 
appropriate  measures.  Malta  should  include  targeted  measures  to  reduce  over 

abstraction in order to avoid salt water intrusion where possible. 

Assessment:  The  actions  expected  to  be  implemented  included  implementation  and 

enforcement  of  the  new  legislation  on  groundwater  abstractions  to  balance  water 

65   Malta  subsequently  clarified  that  the  metering  of  all  private  groundwater  sources  including  those  in  the 
agricultural sector has been almost completed. In fact, more than 3 000 private groundwater sources have been 
metered, and analysis of abstraction data shows a median range of 1,500 – 2,000 m3 of abstracted groundwater 
from each groundwater abstraction source. This amounts from 4 to 5.5 m3/day of groundwater abstraction per 
source, and hence significantly lower than the 10m3/day significance threshold under the WFD. Groundwater 
abstraction by the agricultural sector peaks in April/May and July/August, periods coinciding with the spring 
and summer crops respectively 

66   Malta subsequently clarified that the development of a water demand assessment tool to enable the correlation 
of agricultural water demand with groundwater abstraction by the agricultural sector will be developed during 
the implementation period of the second RBMP through the LIFE Integrated Project awarded to Malta earlier 
in 2018. 

67   Malta subsequently clarified that there are no exemptions for permitting and registration for small abstractions 
as  claimed.  National  legislation  requires  all  groundwater  abstraction  sources  to  be  registered  with  the 
authorities, and this includes even low-yield sources where groundwater is abstracted by buckets. 

124 

 
 
                                                      
abstraction  with  recharge.  This  would  likely  ensure  both  the  good  quantitative  and 

avoid  salt  water  intrusion.  In  particular,  abstraction  should  be  included  under  cross 
compliance once the legislation on authorisations of abstraction is in place.  

Malta has taken action to improve its control on groundwater abstractions, by adopting 
and  implementing  specific  regulations.  However,  the  knowledge  base  for  appropriate 

water resource allocation management seems to be insufficient, as there is still limited 
data collection from metering within the agricultural sector (Malta reports agricultural 
abstraction volumes  are  determined mainly  from statistics)68. This  recommendation is 
considered to be partially fulfilled.  

68   Malta  subsequently  clarified  that  data  from  the  metering  programme  is  available  and  was  included  in  the 
second RBMP. However, due to the significant differences in the abstraction volumes registered through the 
metering  programme,  a  precautionary  approach  was  adopted  and  data  from  water  demand  assessments  was 
used in the actual status assessments. In parallel with this, a verification (calibration) exercise was initiated to 
corroborate metering data. Such calibration exercise includes the use of satellite imagery for the estimation of 
crop  water  demand  and  actual  land-use.  A  decision  support  tool  for  the  calculation  remote  sensing  for 
agricultural  water demand is  also planned under the recently launched  LIFE Integrated  Project targeting the 
implementation of the  second RBMP (LIFE  16 IPE MT 008). In fact,  more than 3 000 private groundwater 
sources  have  been  metered,  and  analysis  of  abstraction  data  shows  a  median  range  of  1,500  –  2,000m3  of 
abstracted  groundwater  from  each  groundwater  abstraction  source.  This  amounts  from  4  to  5.5  m3/day  of 
groundwater  abstraction  per  source,  and  hence  significantly  lower  than  the  10m3/day  significance  threshold 
under the WFD. 

125 

 
 
 
                                                      
Topic 11

  Measures related to pollution from agriculture  

11.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle 

Pressures  related  to  agriculture  were  clearly  identified  for  groundwater.  Pressures  reported 
were:  chemical  pollution,  abstraction,  and  saline  pollution.  A  gap  assessment  was  not 
performed69,  and  it  remains  unclear  how  much  the  planned  measures  will  contribute  to  the 
achievement  of  the  objectives.  KTM  2  -  "Reduce  nutrient  pollution  from  agriculture"  (two 

basic  measures  and  one  supplementary),  KTM  3  -  "Reduce  pesticides  pollution  from 
agriculture"  (one  basic  measure),  and  KTM  23  –  “Natural  water  retention  measures”  were 

applied. In the second Maltese RBMP, however, there was no reference at all to KTMs. Hence, 
these  measures  cannot  be  identified  in  the  Programme  of  Measures,  and  it  cannot  be 

determined if these are voluntary or mandatory. 

Basic measures under Article 11(3)(h) for the control of diffuse pollution from agriculture at 

source  were  applied  with  the  same  rules  across  the  whole  RBD.  General  binding  rules  to 
control diffuse pollution from agriculture were applied to nitrates, organic pollution, and other 
pollutants70.  

Around the four groundwater bodies associated to drinking water protected areas71 safeguard 
zones have been established on the basis of the zone of influence72, around public groundwater 
abstraction sources, determined according to the Dupuit-Forchheimer well discharge equation 

(300  m  radius).  The  measures  to  prevent  nitrogen,  phosphorus  or  pesticides  from  entering 
drinking water resources are the same in the first and second RBMPs. 

No information on agricultural pressures in coastal waters is reported in WISE73. 

Farmers and Farmers Unions have been consulted under the Public Consultation process.  

Financing of agricultural measures was secured for Malta.  

69   Malta  subsequently  clarified  that,  it  has  started  the  process  to  develop  a  pilot  unsaturated  zone  monitoring 
network to assess the quality of recharge within the unsaturated zone. This network will provide information 
on the annual recharge to groundwater and hence will permit the undertaking of a gap assessment. 

70   Malta  subsequently  clarified  that  measures  to  address  nutrient  contamination  of  groundwater  have  been 
addressed through the development of Malta’s Nitrates Action Programme under the Nitrates Directive. This 
Programme is a basic measure under the Nitrates Directive. 

71   The  Malta Mean Sea  Level  groundwater body, the  Mgarr Perched groundwater body, the Mizieb Mean Sea 

Level groundwater body, and the Gozo Mean Sea Level groundwater body 

72   Drawdown cone in the piezometric surface of the aquifer 
73   Malta  subsequently  clarified  that  management  issues  identified  for  coastal  waters  include  nutrient 

contamination in enclosed bays and harbours.  

126 

 
 
                                                      
11.2 Main changes in implementation and compliance since the first cycle 

While in the first cycle it was not clear how the funding of measures will take place, funding 

has now been secured. 

11.3 Progress with Commission recommendations 

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

requested action on the following: 

 

Recommendation: Agriculture is indicated as exerting a significant pressure on 

the  water  resources  in  Malta.  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  farmers'  community  to  ensure  technical  feasibility  and 
acceptance. There needs to  be a very clear baseline so that any farmer knows 

the rules this can be adequately advised and enforced and so that the authorities 
in charge of the Common Agricultural Policy funds can adequately set up Rural 

Development Programmes and cross compliance water requirements.  

Assessment:  ‘Reduce  nutrient  pollution  from  agriculture’  refers  to  basic  and 
mandatory  measures.  A  gap  assessment  was  not  performed,  so  it  remains 

unclear how the different measures under the various Directives will contribute 
to close the gap to target. Therefore, this recommendation has not been fulfilled.  

 

Recommendation:  Improve  the  implementation  of  the  Nitrates  Directive74 
(especially  to  counter  illegal  disposal  of  farm  manure  on  fields  due  to  lack  of 
adequate  storage  facilities).  Malta  should  establish  a  methodology  for 

addressing  the  pressure  from  nitrates  and  submit  information  on  the 
enforcement, monitoring and controls.  

Assessment:  The  information  on  the  implementation  of  the  Nitrates  Directive 
and  the  Nitrates  Action  Programme  is  scarce  in  the  Maltese  RBMP.  No 

comprehensive  information  on  the  enforcement,  monitoring  and  controls  is 

74   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 

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

nitrates 

127 

 
 
                                                      
provided. What is mentioned to have taken place (first cycle) or will take place 
(second cycle) are the following activities75:  

  Controls/enforcement:  “…it  is  expected  that  the  continuous  controls, 
enforcement  and  evaluation  procedures  related  to  the  overseeing  of 
the  Nitrates  Action  Programme  Regulations, 
implementation  of 

estimated to cost €140 000 per annum will be maintained”. 

 

Information and training: “An Info Nitrates campaign funded by LIFE+ 

was also carried out during the first cycle. This campaign was designed 
to provide farmers and livestock breeders with information and training 

to  act  in  accordance  with  the  Nitrates  Directive  and  the  associated 
Action Plan. Throughout the campaign a total of 849 farmers and 1 739 

part-time  farmers  holding  more  than  1.5  hectares  of  land  received 
training.  Farmers  were  provided  with  soil  analysis  kits  and  training 

sessions were also held with 925 livestock breeders”.  

  Additional  studies:  “A  crop  yield  study  and  the  undertaking  of  studies 
related to manure quality and soil nitrogen content estimated as well as 

the  building  and  management  of  a  soil  monitoring  surveillance 
network”.  

  Database:  “The  maintenance  of  a  database  for  monitoring  changes  in 
agricultural  practices  in  terms  of  farm  holdings,  manure  application 

and soil and manure analysis”. 

Therefore progress has been made but it is only partially fulfilled76.  

 

Recommendation:  Submit  a  plan  on  resolving  the  discharge  of  animal 

husbandry  waste  in  the  sewage  collecting  system  because  the  Maltese 
wastewater treatment plants had a performance problem as regards compliance 

75 Malta subsequently stated that in addition to the action listed, other measures have also been established for the 
protection of public groundwater abstraction sources through Malta’s Nitrates Action Programme, which are 
the following:  
- Farmers or land managers have to keep a cropping plan of their holding and to practice crop rotation whilst 
taking into consideration the nutrient requirements of the crops ; 
- Farmers with a holding size of >1 ha have to prepare a Nutrient Management Plan (NMP) for their holding 
which describes how the major plant nutrients (nitrogen, phosphorus and potassium) will be managed. 

76   Malta subsequently stated that this information has been reported for the Nitrates Directive and is available at 

this link: 
 https://cdr.eionet.europa.eu/mt/eu/nid/envv5xyla/Clean_AnnexV-NiDRPT_Final.docx/manage_document.  

128 

 
 
                                                      
 
 
with  the  chemical  oxygen  demand  standards.  This  was  linked  to  farm  manure 

discharges in the collecting system 

Assessment: A plan on resolving the discharge of animal husbandry waste in the 

sewage  collecting  system  seems  to  have  been  initiated  in  the  supplementary 
measure  SWM  9  –  “Creation  and  Implementation  of  the  Agriculture  Waste 

Management  Plan".  It  is,  however,  not  entirely  clear  how  far  this  plan  has 
advanced.  It  is  stated  that  it  already  started  in  2015.  However,  the  text 

describing the measure is imprecise: "…the Government is committed towards a 
management plan to better tackle the agricultural waste. This has already been 

proposed with some measures to ensure compliance with the relevant European 
Union  and  national  legislation.  Such  a  plan  will  outline  a  comprehensive 

governance structure which will  be responsible for co-ordinating centrally the 
management  of  all  farm  waste".  It  is  therefore  unclear  if  the  plan  is  already 
finalised and/or has been implemented77. 

77   Malta subsequently clarified that a plan on resolving the discharge of animal husbandry waste was submitted 
by  Malta  under  the  implementation  process  of  the  Urban  Wastewater  Treatment  Directive  and  is  currently 
being implemented.  

129 

 
 
 
                                                      
Topic 12

  Measures  related  to  pollution  from  sectors  other  than 

agriculture  

12.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle 

In  the  context  of  this  topic,  pollution  is  considered  in  terms  of  nutrients,  organic  matter, 

sediment, saline discharges and chemicals (priority substances, river basin specific pollutants, 
groundwater  pollutants  and  other  physico-chemical  parameters)  arising  from  all  sectors  and 

sources  apart  from  agriculture.  Key  types  of  measures  are  groups  of  measures  identified  by 
Member States in their Programmes of Measures which target the same pressure or purpose. A 

KTM  could  be  one  national  measure  but  would  typically  comprise  more  than  one  national 
measure. The same individual measure can also be part of more than one KTM because it may 

be multipurpose, but also because the KTMs are not completely independent of one another.  

KTMs  relevant  to  non-agricultural  sources  of  pressures  causing  failure  of  WFD  objectives 

have been reported electronically for the Maltese RBD and include only: 

KTM1 - “Construction or upgrades of wastewater treatment plants” 

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” and 

KTM99 – “Other key type measure reported under PoM”.  

Within KTM99, the following measures have been reported:  

KNO  3:  Characterise  and  quantify  hydrological  input  of  land  based  contaminants  (including 
litter) to coastal waters from major sub-catchments.  

KNO 4:  Investigate the role transboundary contaminants through hydrographic pathways and 
the extent of its contribution to marine contamination.  

KNO 5: Carry out investigations to gauge potential contribution of contaminants to our coastal 
waters by atmospheric deposition. 

KNO  6:  Carry  out  a  survey  of  all  direct  discharges  to  sea  and  identify  their  source  with  the 
objective of setting up a plan to curtail/regulate such discharges. 

130 

 
 
These  KTMs  do  not  include  KTM16  -  “Upgrades  or  improvements  of  industrial  wastewater 

treatment plants (including farms)”.  

The  WFD  specifies  that  the  Programme  of  Measures  shall  include  “basic  measures”  as  a 

minimum,  and  where  necessary  to  achieve  objectives,  “supplementary  measures”  may  be 
required  when  basic  measures  are  not  enough.  Quantitative  information  on  basic  and 

supplementary  measures  used  to  tackle  pollution  from  non-agricultural  sources  (number  of 
measures per KTM) has been provided for Malta. Quantitative information on basic measures 

to  tackle  pollution  from  non-agricultural  sources  is  provided  for  one  type  of  basic  measure 
incorporated into each KTM (nitrates / improving data management structures). 

In  the  RBMP  and  background  documents,  two  basic  and  one  supplementary  measure  were 
identified as associated with 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”.  

 

 

The  basic  measures  are  called  KEY  1  –  “Continue  to  refine  the  regulatory 
framework  for  industrial  operational  practices”  and  SWM  2  –  “Continue  to 

control priority hazardous substances, Priority Substances and other substances 
of concern via the environmental permitting process”.  

The  supplementary  measure  is  called  KEY  2  -  “Create  an  effective  feedback 
mechanism  within  the  Environment  and  Resources  Authority  to  ensure 

compliance and risk mitigation”.  

These two measures KEY 1 and SWM 2 were already included in the first RBMP, and apply to 

all surface waters. They affect all installations in the RBD, including installations that have a 
discharge point to surface waters along the coast. Both are mandatory measures. The measure 

called KEY 2 is an indirect basic measure affecting the authorities themselves. 

RBMP  and  background  documents  also  identified  the  application  of  KTM21  -  “Measures  to 
prevent or control the input of pollution from urban areas, transport and built infrastructure”: 
four basic and five supplementary measures are associated with this KTM. The basic measures 

are:  

 

BAS  UWWTD_1  –  “connecting  the  remote  hamlet  of  Bahrija  directly  to  the 

main sewerage network”, 

131 

 
 
 

KEY 1 – “Continue to refine the regulatory framework for industrial operational 

practices”,  

 

SWM 1 – “Continue to strengthen the relationship between environmental and 

planning 
Directive78 concerns”, 

regulatory  processes 

(including  Marine  Strategy  Framework 

 

SWM  2  –  “Continue  to  control  priority  hazardous  substances,  Priority 

Substances  and  other  substances  of  concern  via  the  environmental  permitting 
process”. 

Malta  subsequently  clarified  that  the  hamlet  of  Bahrija  and  households  along  the  route  from 
Bahrija to Rabat have been connected to the main sewage system and therefore this measure 

has been completed.  

Malta also clarified that in addition to the measures outlined in the second RBMP, there are 16 

measures entailing works for the upgrading and extension of the sewage network and related 
infrastructure in  various parts of Malta, as well as upgrading works on the urban wastewater 

treatment  plants.  These  specific  measures  form  part  of  the  operational  and  maintenance 
programme  of  the  public  utility  and  were  not  listed  in  the  second  RBMP’s  programme  of 
measures. 

All these 4 basic measures date back from the first RBMP, or stem from the Urban Wastewater 
Treatment  Directive.  They  apply  to  all  surface  waters,  affect  all  installations  in  the  RBD, 

including installations which have a discharge point to surface waters along the coast, and are 
all mandatory measures. The Urban Wastewater Treatment Directive measures indirectly also 

affect groundwater. 

The supplementary measures are:  

  KEY  2  –  “Create  an  effective  feedback  mechanism  within  the  Environment  and 

Resources Authority to ensure compliance and risk mitigation”,  

  SWM 5 – “Publish guidelines for the disposal of dredged material”,  

  SWM 7 – “Develop a system to encourage adequate litter management and control in 

coastal areas”,  

78   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  

132 

 
 
                                                      
  SWM 9 - “Creation and Implementation of the Agriculture Waste Management Plan”, 

and  

  SWM  14  -  “Develop  a  strategic  policy  framework  to  encourage  integrated  valley 

management”.  

All  these  supplementary  measures  are  indirect  measures  (for  example  strategy  development, 

and development of plans), and are voluntary (non-mandatory). 

Malta provided more targeted information on basic measures required under Article 11(3)(c to 

k).  Use  of  authorisation  and/or  permitting  regime  to  control  waste  water  point  source 
discharges  -  basic measures  Article 11(3)(g)  - was reported for the Maltese  RBD for surface 

and  groundwater.  Registration  of  wastewater  discharges  (Basic  measures  Article  11(3)(g))  is 
mandatory  in  the  Malta  RBD  for  surface  and  groundwater.  There  are  no  thresholds  below 

which wastewater discharges do not require permits and are not subject to registration. There is 
a prohibition of all direct discharges to groundwater.79 

There are measures in place to eliminate/ reduce pollution from Priority Substances and other 
substances  in  the  Malta  RBD.  In  the  description  of  these  measures,  however,  individual 

substances are not explicitly referred to. 

12.2 Main changes in implementation and compliance since the first cycle  

In the first RBMP there was no assessment of chemical status for surface water bodies and no 

environmental  quality  standard  set  for  River  Basin  Specific  Pollutants.  Therefore,  there  was 
little  information  on  which  to  base  the  measures.  This  is  despite  the  fact  that  the  pressures 

analysis  identified  a  number  of  significant  pollution  sources  such  as  industrial  discharges, 
agriculture,  anti-fouling  practices,  and  some  specific  pollutants  such  as  polycyclic  aromatic 

hydrocarbons  and  heavy  metals.  The  first  plan  contained  some  generic  measures  that  could 
contribute to reducing chemical pollution. 

In the second RBMP, there are two measures that aim at improving the regulatory and permit 
system  (KEY  1  –  “Continue  to  refine  the  regulatory  framework  for  industrial  operational 

practices”  and  SWM  2  –  “Continue  to  control  priority  hazardous  substances,  Priority 

79   Malta subsequently provided this additional information: discharges to the public sewer network are regulated 
by  S.L.545.08.  Enforcement  of  this  legislation  is  bestowed  to  the  Water  Services  Corporation  where  every 
commercial/trading  premises  discharging  trade  effluent  to  the  public  sewer  shall  apply  and  obtain  a  Public 
Sewer Discharge Permit. This process involves the submission of documentation relating to chemicals used, 
proof of maintenance of treatment facilities, proof of transfer of hazardous wastes, sampling of trade effluent 
and  inspection  of  each  premises.  Subject  to  the  results  of  analysis  performed  being  below  the  required 
thresholds, the permit is granted to the particular entity for a period of one year. 

133 

 
 
                                                      
Substances and other substances of concern via the environmental permitting process”) for all 

pollutants, Priority Substances and River Basin Specific Pollutants, dating from the first cycle. 
In  the  description  of  these  measures,  however,  the  individual  substances  are  not  explicitly 

referred to. 

Malta clarified that the measures mentioned cover all pollutants (Priority Substances and River 

Basin  Specific  Pollutants)  which  are  discharged  into  surface  waters  by  industrial  operations 
through  the  environmental  permitting  process.  The  Environmental  Permitting  System 

addresses the type of pollutants depending on relevance of the pollutant to the activity being 
permitted. 

Malta mentioned that measures under KTM15 apply primarily to coastal waters.  

Zinc is the only River Basin Specific Pollutant reported to cause failure of good status (in one 

surface water body, a lake). The drivers are not identified clearly, but atmospheric deposition 
and pipes containing the material are discussed. No action is being taken to tackle the problem. 

Malta  clarified  that  measures  in  the  second  RBMP  address  discharges  of  all  substances 
including River Basin Specific Pollutants (KEY 1, SWM 2) and atmospheric deposition (KNO 
5). The issue of pipes is not deemed relevant to the surface water body. 

Mercury was reported as the sole parameter that caused failure in chemical status in all waters 
in  the  second  RBMP.  It  is  associated  with  fuel  combustion  of  coal,  waste  or  oil;  municipal 

sewage  discharge,  and  the  atmospheric  deposition  of  mercury.  Measures  under  KTM1, 
KTM15,  and  KTM16  would  probably  be  used  to  tackle  these  pressures/sources.  However, 

measures are assigned only for KTM15.  

Groundwater  bodies  were  affected  mostly  by  agricultural  pollutants  and  abstractions; 

information on agricultural measures is in Chapter 11.  

12.3 Progress with Commission recommendations 

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

  Recommendation:  “Use  the  inventory  of  emissions  to  review  the  monitoring 
programme and the list  of  RBSPs for  the second RBMPs, and to  identify appropriate 

measures against chemical pollution” 

Assessment: According to Malta’s clarifications, measures cover all pollutants (Priority 

Substances  and  River  Basin  Specific  Pollutants)  which  are  discharged  into  surface 

134 

 
 
waters  by  the  industrial  operational  practices  through  the  environmental  permitting 

process.  It  is  less  clear  how  the  inventory  of  emissions  has  been  used  to  determine 
measures  to  tackle  other  sources  of  pollution,  including  indirect  sources  and  diffuse 

emissions from non-agricultural sources.  

  Recommendation:  “Submit  a  plan  on  resolving  the  discharge  of  animal  husbandry 
waste in the sewage collecting system because the Maltese wastewater treatment plants 
had a performance problem as regards compliance with the chemical oxygen demand 

standards.  This  was  linked  to  farm  manure  discharges  in  the  collecting  system.” 
“Permitting procedures should guarantee the respect of WFD requirements” 

Assessment:  KTM1  -  “Construction  or  upgrades  of  wastewater  treatment  plants”  has 
been reported for the Malta RBD. However, this KTM seems be associated neither with 

this  recommendation  nor  with  discharges  of  the  agricultural  sector.  There  is  no 
reasoning  provided  for  this  in  the  RBMP.  However,  Malta  clarified  that  regarding 

KTM1, the ongoing measures for the management  of wastewater treatment  plants are 
considered as basic measures for the implementation of the UWWTD. Measures for the 

polishing  of  treated  waters  are  considered  as  water  reuse  measures,  addressing  the 
development  of  polishing  plants  which  are  separate  from  the  statutory  wastewater 

treatment  process.  Hence  such  measures  are  considered  under  other  KTMs.  This 
recommendation is considered partially fulfilled. 

  Recommendation:  It  is  important  that  there  is  an  ambitious  approach  to  combatting 

chemical pollution and that adequate measures are put in place. 

Information  reported  to  WISE  shows  that  only  one  priority  substance  (Mercury)  and 
one River Basin Specific Pollutant (Zinc) are causing non-compliance in Malta. In the 

second  RBMP  a  KTM  has  been  reported  to  address  the  pressure  from  mercury,  and 
measures  under  KTMs  1  and  16  might  also  be  relevant,  although  none  have  been 

assigned as specifically tackling mercury. KTM  15 has been mapped  against national 
measures.  Malta  has  reported  that  there  are  measures  in  place  to  eliminate  /  reduce 

pollution from Priority Substances and other substances. However, as regards the only 
River Basin Specific Pollutant (Zinc) identified to be causing failure, there is no clear 

identification of the drivers, and no measures are proposed to tackle the problem. 

Malta  provided  further  information  that  measures  in  Malta’s  second  RBMP  address 

discharges of all substances including River Basin Specific Pollutants (KEY 1, SWM 

135 

 
 
2) and atmospheric deposition (KNO 5). The issue of pipes is not deemed relevant to 

the surface water body, but Malta provided no explanation to support this statement. 

While Malta has not specifically reported KTM 16, industrial wastewater treatment is 

specifically  considered  as  part  of  the  environmental  permitting  systems  (covered  by 
Measures KEY 1 and SWM 2).  

Therefore this recommendation has been only partially fulfilled. 

136 

 
 
 
 
Topic 13

  Measures related to hydromorphology  

13.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle 

In the second RBMP, no significant hydromorphological pressure affecting water bodies was 
identified in Malta, and therefore no related KTM was reported.80 The types of pressures which 
have  not  been  assessed  for  surface  waters  include  dams,  barriers  and  locks,  and  physical 
alterations.  Given  that  47  %  of  surface  water  bodies  are  heavily  modified,  it  is  unclear  why 

these pressures were not reported as significant and no relevant information could be found in 
the RBMP. Malta subsequently mentioned that physical alterations were reported for Heavily 

Modified Water Bodies rather than under significant pressures. In addition, the main pressures 
reported were unknown anthropogenic pressures.  

The lack of identification of significant hydromorphological pressures may be due to the lack 
of appropriate assessment methods and of appropriate monitoring data to understand the nature 

of  hydrological  and  morphological  modifications  in  Maltese  waters.  The  RBMP  does  not 
provide information on the criteria for the identification of pressures or on tools used to define 

significant pressures related to hydromorphology.  

It  is  reported  though  that,  in  terms  of  basic  measures,  there  is  an  authorisation  and/or 

permitting  regime  in  place  to  control  physical  modifications,  which  covers  changes  to  the 
riparian  area  of  water  bodies  according  to  WFD  Article  11(3)(i).  There  is  also  a  register  of 

physical modifications of water bodies. 

Win-win  measures  to  achieve  the  objectives  of  the  WFD  and  Floods  Directive,  drought 

management, and use of Natural Water Retention Measures are reported to be included in the 
Programme  of  Measures.  KTM  23  –  “Natural  water  retention  measures”  has  been  made 

operational  to  tackle  significant  abstractions  or  flow  diversion  pressures  from  public  water 
supply  on  groundwater.  There  are  four  measures  reported  under  KTM  23  –  “Natural  water 

retention  measures”,  of  which  two  are  not  Natural  Water  Retention  Measures,  but  technical 
rainwater harvesting measures. Although the other two measures clearly refer to Natural Water 
Retention Measures, they are not very specific, referring to actions aiming at the development 

and  implementation  of  a  master  plan  for  sustainable  drainage  systems  and  natural  water 

80   Malta subsequently mentioned that hydromorphological pressures have been considered for transitional waters 
and for rivers. Due to current uncertainties, the ecological status of such inland surface water bodies could not 
be determined. Within this context, Malta’s second RBMP adopts water-related measures put forward by the 
Natura  2000  management  plans,  including  measures  dealing  with  hydromorphological  alterations  (e.g. 
enlargement of the water habitat and restoration of habitat) for transitional waters. 

137 

 
 
                                                      
retention in the urban and rural framework of the Maltese islands as environmentally friendly 

flood mitigation measures (envisaged to start in 2019). 

In addition, the design of new and existing structural measures is reported to have been adapted 

to take into account WFD objectives. 

Ecological flows have not been derived or implemented so far for the relevant water bodies in 

Malta but there are plans to do so during the second cycle. In this context, no specific measures 
were  planned  to  achieve  ecological  flows,  and  the  establishment  of  ecological  flows  is  not 

addressed  by  specific  regulations.  However,  it  is  indicated  that  Malta  is  still  in  the  phase  of 
establishing the baseline for deriving ecological flows.  

In  the  first  cycle,  Malta  had  included  one  measure  related  to  ecological  flows,  which  is  also 
presented  in  the  second  RBMP,  namely  ECO  1-1  “Establish  Ecological  flows  within  sub-

catchments of ecological importance (NATURA 2000 sites)”. The description of the measure 
indicates that years of frequently gathered data are required to understand the contribution of 

natural flows to the water-dependent habitats and species. In addition, further work would be 
required  to  understand  the  habitat  requirements  and  the  selection  of  indicator  species.  The 
process of establishing ecological flows will therefore extend into subsequent WFD cycles. In 

addition,  the  Natura  2000  Management  Plans  that  were  designed  during  2012-2014  are 
expected  to  contribute  to  the  process  of  understanding  water  related  requirements  and  hence 

can inform the process of developing ecological flows. 

Also  in  the  description  of  the  monitoring  programme,  it  is  stated  that  Malta  will  monitor 

hydromorphological  elements  twice  every  month  for  every  year  in  order  to  gather  sufficient 
data  to  support  the  ongoing  attempt  to  better  understand  the  water  related  requirements  of 

habitats and species and ecological flows. 

13.2 Main changes in implementation and compliance since the first cycle 

In  the  first  RBMP,  hydromorphological  pressures  were  identified,  namely  dredging  and 
hydromorphological  alterations  in  two  harbours  and  physical  modifications  related  to  urban 

development.  One  measure  explicitly  targeted  hydromorphological  pressures:  develop  and 
implement  planning and environmental guidance on major coastal engineering works, in  two 
coastal  heavily  modified  water  bodies  (harbours).  In  the  second  RBMP,  no  significant 

hydromorphological pressure has been reported and therefore no relevant KTM is planned to 
address these. 

138 

 
 
13.3 Progress with Commission recommendations 

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

requested action on the following: 

  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,  increase  of  water  infiltration  and  thus  aquifer  recharge,  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” has been made operational 
to tackle significant abstractions or flow diversion pressures from public water supply 

on  groundwater.  There  are  four  measures  reported  under  this  KTM,  of  which  two 
clearly refer to Natural Water Retention Measures. These refer to actions aiming at the 
development and implementation of a master plan for sustainable drainage systems and 
natural  water  retention  in  the  urban  and  rural  framework  of  the  Maltese  islands  as 

environmentally  friendly  flood  mitigation  measures  (envisaged  to  start  in  2019). 
Therefore,  this  recommendation  is  partially  fulfilled,  with  further  progress  awaited 

concerning the future implementation of the planned measures.  

139 

 
 
 
 
Topic 14

  Economic analysis and water pricing policies  

14.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle and main changes since the first cycle 

Water services  were narrowly  defined, covering  only drinking water supply  and waste water 
treatment. Therefore, the sole entity that falls under the definition of water services supplier is 

the  Water  Services  Corporation,  which  is  the  public  utility  responsible  for  the  water 
production, storage, distribution and sale, as well as the collection, treatment, and disposal of 

treated wastewater. Cost recovery levels were stated to be at 88 % of the total costs of water 
services in Malta (in 2014). 

Water pricing and its incentive function is explained on a general level in the Maltese RBMP. 
Malta itself has a water pricing policy in place, with a rising block tariff system for both the 

residential  and  non-residential  consumers,  that  is,  some  incentives  are  provided  to  consume 
less water. It is not explained whether the incentives were adequate or not81. 

Although the Polluter Pays Principle is mentioned in a general way in the Maltese RBMP, it is 
not really considered in the pricing policies or the cost recovery.  

Although  environmental  and  resource  costs  are  discussed  on  a  general  level  in  the  Maltese 
RBMP,  there  is  no  information  on  whether  or  how  they  have  been  considered  in  designing 

pricing policies or calculating cost recovery rates. 

The  2005  economic  analysis  is  reported  to  have  been  updated,  based  on  the  findings  of  the 

Economic  and  Social  Analysis  carried  out  as  part  of  Malta’s  implementation  of  the  Marine 
Strategy  Framework  Directive82  initial  assessment.  It  is  also  expanded  by  an  economic 
characterisation  of  groundwater  use.  As  part  of  the  development  process  of  this  economic 
characterisation  of  groundwater  use,  the  methodological  approach  of  the  first  cycle  was 

reviewed  and efforts  have been made to  provide  greater detail  on the cost  recovery levels  of 
water  services  and  the  contribution  of  the  Programme  of  Measures  towards  groundwater 

sustainability. 

81  In June  2018 Malta informed the Commission that the  structure of the  water tariffs and the characteristics of 
Maltese water consumption (low per capita consumption, high tariff rate, average elasticity of tariff change to 
consumption) provide for "adequate" incentives to use water effectively. However, this obviously covers only 
the water users which are connected to the water system.  

82 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  

140 

 
 
                                                      
The methodological approach adopted in the Maltese economic analysis, particularly to define 

the cost recovery levels, is based on the respective Common Implementation Strategy guidance 
document83 and on the discussions held during Commission workshops on the implementation 
of the relevant articles of the WFD. In the RBMP this is explained in a chapter on economic 
characterisation of groundwater use, where water services and water pricing is also explained. 

It  is  not  clear,  however,  why  this  is  described  under  an  economic  characterisation  of 
groundwater use, as other water body categories are also effected (for example, coastal waters 

through the discharge of treated waste water into the sea). The chapter ends with a section on 
the Economic Impact of Groundwater, which includes a justification or argument not to price 

private groundwater abstraction by agricultural users. 

14.2 Progress with Commission recommendations 

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

requested action on the following: 

  Recommendation: The cost-recovery should address a broad range of water services, 
including  impoundments,  abstraction,  storage,  treatment  and  distribution  of  surface 
waters, and collection, treatment and discharge of waste water, and also when they are 

"self-services",  for  instance  self-abstraction  for  agriculture.  The  cost  recovery  should 
be transparently presented for all relevant user sectors, and environment and resource 

costs 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 

an efficient use of water. Information on how the polluter pays principle has been taken 
into account should be provided in the RBMPs. 

  Recommendation  (2015):  Develop  fully  the  economic  analysis  of  water  use  including 

calculation of Environmental and Resource cost. 

Assessment: Water services are narrowly defined, covering only drinking water supply 
and waste water treatment. It is stated in the RBMP that “water users are excluded from 

this  definition,  as  clarified  by  the  European  Court  of  Justice  case  in  European 
Commission vs. the Federal Republic of Germany (C-525/12 of 11 September 2014)”. 

As a result, the sole entity that falls under the definition of water services supplier is the 
Water  Services  Corporation,  the  public  utility  responsible  for  the  water  production, 

83   https://circabc.europa.eu/sd/a/cffd57cc-8f19-4e39-a79e-20322bf607e1/Guidance%20No%201%20-

%20Economics%20-%20WATECO%20(WG%202.6).pdf  

141 

 
 
                                                      
storage,  distribution  and  sale,  as  well  as,  the  collection,  treatment  and  disposal  of 

treated wastewater. 

Cost recovery levels are calculated based on the financial reports of the Maltese Water 

Services Corporation and the income generated by user charges; only financial costs are 
covered as such. The cost recovery rate calculated in this way is stated to be at 88 % of 

the total costs of water services in Malta (in 2014). 

Regarding  private  abstractions  of  groundwater,  it  is  stated  that  “groundwater  is  also 

directly  abstracted  by  a  number  of  economic  operators.  This  privately  abstracted 
groundwater may be used for one´s own consumption or production purposes or may 

be  sold  to  other  end-users  and  transported  using  the  services  of  water  tankers.  These 
activities  fall  outside  the  responsibility  of  the  Water  Services  Corporation  and  are 

regulated by the Maltese Resource Authority in-line with government policy direction 
in  this  area.”  Nevertheless,  cost  recovery  rates  are  also  calculated  for  private 

abstractions  for  groundwater,  leading  to  the  conclusion  that  because  the  provision  of 
water  by  the  Maltese  Water  Services  Corporation  is  actually  cheaper  than  private 
abstraction (considering costs for equipment, electricity, boreholes and other costs), the 

users would eventually switch to public supply (at least this is implied). There were no 
water charges for private abstractions84. 

Water pricing and its incentive function, is explained on a general level in the Maltese 
RBMP. Malta itself has a water pricing policy in place, with a rising block tariff system 

for  both  the  residential  and  non-residential  consumers,  that  is,  some  incentives  are 
provided  to  consume  less  water.  However,  an  exception  is  made  for  non-residential 
consumers  with  an  annual  consumption  greater  than  40 000  m3  per  year.  The  three 
water  users,  households,  industry  and  agriculture,  were  reported  to  benefit  from  the 

water  services  identified.  It  is  not  explained  whether  the  incentives  are  adequate  or 
not85. 

Although  the  Polluter  Pays  Principle  is  mentioned  in  a  general  way  in  the  Maltese 
RBMP,  it  is  not  really  considered  in  the  pricing  policies/the  cost  recovery.  While 

100 % of the costs of drinking water provision are covered by the users, only half of the 
costs of waste water treatment were covered. The other half is covered by a government 

84   Malta  subsequently  clarified  that  this  is  a  reporting  error  and  that  private  abstractions  pay  all  operation  and 

maintenance costs, which on average amount to EUR 0.25/m³. 

85   In June 2018 Malta informed the Commission that the structure of the water tariffs and the characteristics of 
Maltese water consumption (low per capita consumption, high tariff rate, average elasticity of tariff change to 
consumption) provide for "adequate" incentives to use water effectively. However, this obviously covers only 
the water users which are connected to the water system. 

142 

 
 
                                                      
contribution  (that  is,  tax  money).  This  is  justified  by  what  is  called  the  “beneficiary 

pays”  principle,  on  account  of  the  environmental  benefit  being  produced  by  this 
activity.  For  example,  a  cleaner  marine  environment  and  enhanced  protection  of  the 

environmental  conditions  in  the  immediate  shoreline,  including  beaches  that  are  an 
important  for  tourism  and  recreation  activities  and  improved  health  conditions  for 

marine flora and fauna. This can be regarded as contrary to the Polluter Pays Principle. 

Furthermore,  it  is  stated  that  “the  regulatory  authority”  is  in  the  process  of 

implementing a proposal which would  entail  a full  cost  recovery of the cost  of water 
services  in  Malta,  through  the  combination  of  pricing  from  consumers,  reflecting  the 

“user pays principle”, and a contribution from public resources to reflect environmental 
benefits of groundwater conservation arising from specific activities undertaken by the 

Water Services Corporation, reflecting the “beneficiary pays principle”. Moreover, the 
system  will  entail  strong  elements  of  financial  incentives  to  reduce  losses  and 

enhancing  the  recycling  of  water  resources,  in  line  with  the  principles  of  “resource 
cost” and “polluter pays”, but there is no more concrete information about these future 
plans. 

Although  environmental  and  resource  costs  are  discussed  on  a  general  level  in  the 
Maltese RBMP, there is no information on whether or how they have been considered 

in designing pricing policies or calculating cost recovery rates. 

Overall  it  can  be  concluded  that  as  there  are  still  significant  gaps  towards  a  water 

pricing policy according to Article 9, this recommendation has not been fulfilled. 

143 

 
 
 
 
Topic 15

  Considerations 

specific 

to 

Protected 

Areas 

(identification, monitoring, objectives and measures) 

15.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle 

Protected Areas have been identified for five relevant Directives: the Birds Directive, Habitats 

Directive,  Bathing  Water  Directive,  Urban  Wastewater  Directive  and  Drinking  Water 
Directive.  Malta  has  taken  a  whole  territory  approach  to  designation  under  the  Nitrates 

Directive so no specific Protected Areas are reported (Table 15.1). 

Table 15.1  Number of protected areas of all types in each RBD of Malta, for surface and 

groundwater 

Protected Area type 

Abstraction of water intended for 
human consumption under Article 7 

Recreational waters, including areas 
designated as bathing waters under 
Directive 76/160/EEC86 
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 
Directive)87 

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)88 

Nutrient-sensitive areas, including 
areas designated as vulnerable zones 

Number of Protected Areas in 

Rivers 

Lakes 

Transitional 

Coastal 

Groundwater 

1 

2 

1 

2 

3 

1 

5 

87 

5 

1 

86   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  

87   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  

88   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 

144 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
Number of Protected Areas in 

Rivers 

Lakes 

Transitional 

Coastal 

Groundwater 

Protected Area type 

under Directive 91/676/EEC (Nitrates 
Directive89) and areas designated as 
sensitive areas under Directive 
91/271/EEC (Urban Wastewater 
Treatment Directive)90 

Areas designated for the protection of 
economically significant aquatic 
species 

Other 

2 

Source: WISE electronic reporting 

The  status  assessment  is  mainly  done  with  high  or  medium  confidence  -  which  is  in  good 

correspondence with the monitoring activities reported to WISE for the Protected Areas related 
to  the Habitats,  Nitrates, and Urban Waste Water Treatment  Directives  (Table 15.2).  For the 

remaining Directives (Bathing Water, Birds and Drinking Water) no monitoring activities have 
been reported into WISE91. An overview of status reported in WISE is included in Figure 15.1. 

Table 15.2  Number of monitoring sites associated with Protected Areas in Malta 

Protected Area type 

Number of monitoring sites associated with 
Protected Areas in 

Rive
rs 

Lak
es 

Transitio
nal 

Coast
al 

Groundwa
ter 

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

3 

2 

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

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

3 

2 

Source: WISE electronic reporting  

40 

5 

5 

26 

11 

13 

89   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 

90   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  

91   Malta subsequently informed the Commission that that the monitoring network for groundwaters contains 115 
sites  in  Protected  Areas,  as  well  as  17  surveillance  and  operational  monitoring  stations  under  the  Water 
Framework Directive. A monitoring network for Bathing Waters is also in place for specific monitoring sites, 
(87 sites).  

145 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
Figure 15.1  Status  of  water  bodies  associated  with  the  Protected  Areas  report  for  Malta. 

Note: based on status/potential aggregated for all water bodies associated with 
all Protected Areas 

Source: WISE electronic reporting 
For the Habitats and Birds Directives, specific water objectives have been set for the Protected 

Areas to protect dependent habitats and species but for a third of these areas, work is still on-
going to determine needs. For the remaining areas the objectives are already met. 

Objectives  have  been  reported  for  two  groundwater  Drinking  Water  Protected  Areas.  (This 
seems  inconsistent  with  other  information  reported  to  WISE  on  the  total  number  of 

groundwater Drinking Water Protected Areas – see Table 15.1). Objectives are reported to be 
met in one area but not the other.  

Monitoring programmes have been reported for the Habitats, Nitrates and Urban Waste Water 
Treatment  Directives,  but  not  for  the  Birds  Directive  and  Bathing  Water  Directive  and 

146 

 
 
 
 
groundwater  dependent  Protected  Areas92.  For  drinking  waters,  there  is  a  significant  change 
compared to the first cycle, when 15 groundwater drinking water sites were monitored93.  

Regarding  additional  measures  for  the  Birds  and  Habitats  Directive  Protected  Areas, 

information  was  not  reported  because  the  needs  still  are  to  be  determined  for  the  Protected 
Areas,  where  the  objectives  not  yet  have  been  met.  For  the  remaining  Protected  Areas,  the 

objectives have already been met. 

Exemptions have been applied for around a third of the Habitat and Birds Directives’ Protected 
Areas  due  to  natural  conditions.  No  exemptions  have  been  applied  for  Bathing  Waters, 
therefore exemptions were used for less than 10 % of the Protected Areas. 

15.2 Main changes in implementation and compliance since the first cycle 

The  number  of  Protected  Areas  under  Article  7  relating  to  abstraction  of  drinking  water  has 
changed from seven in the first RBMP to one in the second cycle. For the Urban Waste Water 

Treatment Directive, the numbers have fallen from eight Protected Areas in the  first cycle to 
one in the second94. 

The number of monitoring sites in surface water has increased significantly from close to zero 
in the first cycle to 23 (habitat), 36 (nitrate) and 11 (urban wastewater treatment) in the second 

RBMP.  

For groundwater, no monitoring data have been reported in the second cycle, whereas the first 
cycle report contains 15 monitoring sites for groundwater drinking water Protected Areas95. 

15.3 Progress with Commission recommendations 

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

requested action on the following: 

92   Malta  subsequently  clarified  that  the  groundwater  monitoring  network  includes  sites  which  are  strategically 
located to provide information on the groundwater flowing to groundwater dependent protected areas. These 
groundwater dependent protected areas are located around the small ‘river’ water bodies.   

93   Malta  subsequently  clarified  that  89  groundwater  abstractions  stations  were  monitored  in  drinking  water 
protected areas during the first cycle, and 115 sites were  monitored during the second cycle. The number of 
stations  from  the  WFD  surveillance  and  operational  monitoring  programmes  located  in  Drinking  Water 
Protected Areas remained at 17 in both River Basin Management Plans. 

94   Malta subsequently clarified that the  number of protected areas under article 7 relating to the abstraction of 
drinking water under the second RBMP amounts to five and not one as claimed in the evaluation report; these 
5  protected  areas  (within  five  distinct  bodies  of  groundwater)  have  been  reported  as  one  feature  in  the  GIS 
reporting. 

95 Malta clarified that the monitoring sites in Drinking Water Protected Areas are the same sites which were used 

during the 1st RBMP. 

147 

 
 
                                                      
  Recommendation: Malta should ensure measures are targeted and sufficient for proper 

protection of Protected Areas. 

Assessment: In general, measures have not been reported for Protected Areas. For two-

thirds of the Birds and Habitat Protected Areas, the objectives have been met. For the 
remaining  third,  objectives  have  been  set,  but  work  is  still  on-going  to  determine  the 

needs  of  the  areas.  Objectives  have  been  set  for  the  two  groundwater  drinking  water 
areas and for one area the objective has been met. Therefore, the basis for introducing 

measures does not seem to be in place. 

A few mandatory measures have been implemented in safeguard zones however. 

No  information  was  supplied  about  objectives  set  or  met  for  other  types  of  protected 
areas such as bathing waters or nitrate sensitive areas, so the need for measures cannot 
be assessed.96 

Overall, this measure has been partially fulfilled. 

96   Malta  subsequently  clarified  that  all  Bathing  Water  Protected  Areas  have  achieved  the  objectives  of  the 
Bathing  Waters  Directive  whereby  excellent  water  quality  was  reported  at  all  sites  over  the  23  week 
monitoring  period  during  2014.  For  the  Nitrates  Directive,  the  assessment  is  carried  out  under  the  WFD 
assessment of water bodies and the Annex V of the Nitrates Report.  

148 

 
 
 
                                                      
Topic 16

  Adaptation to drought and climate change 

16.1 Assessment of implementation and compliance with WFD requirements 

in the second cycle  

Climate change was considered in Malta and the guidance on how to adapt to climate change 
(Common Implementation Strategy Guidance Document No. 2497) was used. No specific sub-
plans  addressing  climate  change  are  reported  for  Malta.  A  climate  change  check  of  the 
Programmes of Measures for the second RBMP was carried out. Adaptation measures KTM24 

-  “adaption  to  climate  change”,  have  not  been  applied  to  address  any  of  the  significant 
pressures. 

Even though there is no legal obligation to prepare Drought Management Plans, many Member 
States  have  prepared  them  in  order  to  cope  with  droughts.  A  Drought  Management  Plan  has 
not been reported for Malta98. However, in 2012 such plans were in place (see “Topic report 
on: Assessment of Water Scarcity and Drought aspects in a selection of European Union River 
Basin  Management  Plans”99).  No  exemptions  have  been  applied  for  Malta  following  Article 
4(6) due to prolonged droughts. 

16.2 Main changes in implementation and compliance since the first cycle 

Drought Management Plans were reported in 2012. No information is provided for the second 
cycle, however Malta clarified that a Drought Management Plan exists in the second RBMP100. 
In the first RBMP no climate check of the Programme of Measures was carried out100. Such a 
check has been now carried out in the second RBMP. 

97   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  

98   Malta subsequently clarified that Malta’s second RBMP includes a specific Drought Management Plan as an 
Annex to the main RBMP document. Hence a Drought Management Plan has been reported for Malta. In this 
regard it is however noted that Malta’s climatic conditions are defined as ‘semi-arid’ and hence Malta faces 
conditions of ‘permanent drought’. In as much, Malta’s second River Basin Management Plan should also be 
considered to be a Drought Management Plan in its own right,  since this is the major quantitative challenge 
faced by Malta. It is unfortunate that the review does not recognize these natural conditions which Malta faces, 
and  which place the country  at a disadvantaged state compared to other Member States. Guidance  from  the 
Commission  is  therefore  requested  as  to  whether  Article  4(6)  can  also  be  applied  to  permanent  droughts 
(permanent conditions of water scarcity) in addition to prolonged droughts. Annex 1 of the second RBMP  – 
Management Plans for Extreme Events (pg 549) 

99   http://ec.europa.eu/environment/water/quantity/pdf/Assessment%20WSD.pdf  
100  Malta  subsequently  clarified  that  the  first  RBMP  included  a  climate  check  of  the  Programme  of 

Measures.(Chapter 11) https://era.org.mt/en/Documents/1st%20WCMP_final.pdf 

149 

 
 
                                                      
16.3 Progress with Commission recommendations 

There were no Commission recommendations based on the first RBMP and first Programme of 

Measures for this topic. 

150