COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans Member State: Luxembourg Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC) Third River Basin Management Plans Second Flood Risk Management Plans
Date: 2025-02-04
Institutions: Directorate-General for Environment, European Commission
Subjects: Luxembourg, adaptation to climate change, application of EU law, environmental risk prevention, flood, risk management, water, water management, water pollution, watercourse

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.2.2025  SWD(2025) 35 final  COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans  Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans Member State: Luxembourg   Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC)  Third River Basin Management Plans Second Flood Risk Management Plans {COM(2025) 2 final} - {SWD(2025) 13 final} - {SWD(2025) 14 final} - {SWD(2025) 15 final} - {SWD(2025) 16 final} - {SWD(2025) 17 final} - {SWD(2025) 18 final} - {SWD(2025) 19 final} - {SWD(2025) 20 final} - {SWD(2025) 21 final} - {SWD(2025) 22 final} - {SWD(2025) 23 final} - {SWD(2025) 24 final} - {SWD(2025) 25 final} - {SWD(2025) 26 final} - {SWD(2025) 27 final} - {SWD(2025) 28 final} - {SWD(2025) 29 final} - {SWD(2025) 30 final} - {SWD(2025) 31 final} - {SWD(2025) 32 final} - {SWD(2025) 33 final} - {SWD(2025) 34 final}  
 
 
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Country specific staff working document 

Luxembourg 

ENVIRONMENT 

 
 
 
 
 
 
 
 
 
Content 

Content ................................................................................................................................................................................................... 2 

SECTION A: WATER FRAMEWORK DIRECTIVE .......................................................................................................................... 3 

1. General info, member state characterisation ............................................................................................................. 4 

2. Horizontal aspects ...................................................................................................................................................................... 9 

2.1 Governance ............................................................................................................................................................................ 9 

2.2 Characterization of River Basin District ................................................................................................................. 9 

3. Policy elements contributing to biodiversity and climate change adaptation ...................................... 11 

3.1 Surface Water: what is their ecological status or potential .................................................................... 11 

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) .......................................... 12 

3.3 Groundwater bodies - have they sufficient water – quantitative status ......................................... 14 

3.4 Protected Areas (identification, monitoring, objectives and measures) ........................................... 14 

3.5 What is being done to prevent/reduce hydromorphological pressures ............................................ 15 

3.6 What Luxembourg is doing for abstractions and water scarcity ......................................................... 17 

3.7 Adaptation to climate change .................................................................................................................................. 18 

4. Policy elements contributing to zero pollution ........................................................................................................ 19 

4.1 Surface Water: what is their chemical status ................................................................................................. 19 

4.2 Groundwater Bodies: what is their chemical status .................................................................................... 20 

4.3 What Luxembourg is doing to combat pollution from agriculture ...................................................... 21 

4.4 What Luxembourg is doing to combat pollution from other sectors ................................................. 22 

4.5  What  Luxembourg  is  doing  to  combat  significant  pressures  –  overall  assessment  of  the 
Programmes of Measures .................................................................................................................................................. 23 

5. Exemptions and economics ............................................................................................................................................... 23 

5.1 To what extent are exemptions applied in Luxembourg ........................................................................... 23 

5.2 Use of economic analysis and water pricing – cost recovery ................................................................ 25 

6. WFD recommendations ........................................................................................................................................................ 25 

SECTION B: FLOODS DIRECTIVE .................................................................................................................................................. 28 

7. Flood risk management under floods directive (FD) ............................................................................................ 29 

7.1 Flood hazard and risk maps ...................................................................................................................................... 29 

7.2 Flood risk management plans .................................................................................................................................. 30 

8. FD recommendations ............................................................................................................................................................ 32 

2 

 
 
 
SECTION A: 
WATER FRAMEWORK 
DIRECTIVE 

3 

 
 
 
1. General info, member state characterisation

Luxembourg is a landlocked hilly country (2.597 km2) with large mixed forests in the north and a 
relatively urbanized area in the south, with a long industrial tradition. Luxembourg has ca 650 000 
inhabitants, of which ca 20% in Luxembourg city. Population growth is relatively high. This explains 
an increasing soil sealing and urban sprawl. It is the wealthiest country in the EU with the financial 
sector being the main driving force of its economy. Shipping in the Moselle is also an important engine 
of the economy.  

tributary 

It must be noted that given the size of Luxembourg, it shares many of its water bodies with other 
countries  and  surface  water  bodies  are  mainly  upstream  river  tributaries.  The  country  has  6 
groundwater  bodies  and  106 
surface  water  bodies.  Most  are 
tributaries to the Moselle (itself 
a  tributary  to  the  Rhine).  One 
upstream 
(the 
Korn/Chiers) flows to the Meuse 
River  basin.  Protected  areas 
under the Natura 2000 network 
represent 27% of Luxembourg’s 
surface. The N2000 area status 
is  reported  as  unfavourable  or 
poor,  but  no  additional  water 
objectives nor measures are set. 
Trout is considered an important 
fish,  also  for  tourism  and  sport 
angling.  While 
agriculture 
represents  1%  of  the  country’s 
GDP,  it  covers  53%  of  the  land 
use and most of the farmland is 
around  the  floodplain  of  the 
Moselle 
Livestock 
River. 
production (and  particularly  the 
dairy  sector)  accounts  for  80% 
of  agricultural  profits.  Forest 
area accounts for 36%.

Reporting 

The deadline for reporting the 3rd RBMPs was in March 2022. The Commission and the EEA together 
with Member States developed an electronic reporting system in WISE (Water Information System 
for  Europe).  Its  use  was  voluntary.  Some  Member  States  used  it  to  fulfil  their  obligations,  others 
reported the plans in pdf format. The cut-off date for the WISE e-reporting was September 2023 and 
the MS were assessed based on the datasets available by this date.  

By  September  2023  Luxembourg  had  not  submitted  full  electronic  reporting.  Therefore,  the 
assessment is based on the data mining of the pdf RBMPs. 

4 

 
Despite the cut off dates for the production of this report, reporting continued, and, for the State of 
Water report, the EEA aggregated the results available by July 2024 in their products and dashboards 
available at WISE Freshwater web portal. 

5 

 
 
 
Changes in Status, Pressures, Exemptions & Measures 

Surface 
Water 
Bodies 
(106) 

Trend (% good 
status/potential) 

Main Pressures & Changes & Exemptions 

ECOLOGICAL 
STATUS 

Since 2015, a further deterioration of ecological status is reported in Luxemburg. 0% of SWBs are expected to achieve good ecological status 
by 2027. The main pressures are nutrients and pesticides of agricultural origin, as well as hydromorphological pressures that affect 101 of 
the 106 SWBs.  
Exemptions under Article 4(4) have increased from 97% to 100% 
The apparent deterioration can be mainly attributed to improved compliance with monitoring and assessment methodologies by Luxembourg. 

6 

 
 
CHEMICAL 
STATUS 

The poor chemical status of Luxembourg's SWBs is mostly caused by a limited number of mainly uPBT substances, among them airborne 
PAHs and scrubber water discharges and air born deposition of mercury from combustion processes. Excluding these substances, still only 8% 
of SWBs are in good status as fluoranthene is frequent above its thresholds in Luxembourg. Cadmium and the banned pesticide cypermethrin 
are the main other pollutants.  

Exemptions under Article 4(4) continue to apply for all surface water bodies (100%) 

Comparing the status in 2015 to the status in 2021 is not simple since the monitoring has changed substantially. New priority substances are 
monitored, new thresholds were set (now stricter for 2 frequent pollutants in Luxembourg) and more RBSPs were included. 

Ground 
Water 
Bodies (6) 

Trend (% good 
status/potential) 

Main Pressures & Changes & Exemptions 

7 

 
 
 
 
QUANTITATIVE 
STATUS 

CHEMICAL 
STATUS 

100% of the groundwater bodies is in good quantitative status in 2021. No water bodies are reported at risk of failing good status in 2027. 
However, Groundwater-dependent terrestrial ecosystems (GWDTEs), relevant for 5 groundwater bodies, and groundwater-associated aquatic 
ecosystems (GWAAEs), relevant for 2 groundwater bodies, are not yet considered in the quantitative status assessment. Reported Natura 
2000 data show mostly poor nature status. Relation of the poor N2000 nature status with dependence of associated groundwater is 
unclear. Risk is high that one or more concerned groundwater bodies are not in 100% good quantitative status. Furthermore, water balances 
are not yet used to evaluate the status. 

3 Groundwater Bodies fail to achieve good chemical status and maintain to be at risk of failing good status by 2027. This is mostly due to 
diffuse agricultural pollution of nutrients and pesticides. This is reflected in the top 3 pollutants in groundwater bodies, which are nitrates, a 
herbicide and its metabolites (metolachlor-ESA and metazachlor-ESA). Additionally, two groundwater bodies fail to pass the drinking water 
protected area test due to pesticides. 

LU uses exemptions under Article 4(4) (natural conditions based on a migration time study for one ground water body). 

2044 is indicated as expected date to achieve good status for these 3 pollutants. GWDTEs (for 5 groundwater bodies) and GWAAEs (for 2 
groundwater bodies) needs are not considered in the chemical assessments. 

8 

 
 
 
 
 
2. Horizontal aspects 

2.1 Governance 

Luxembourg has two competent authorities: the Ministry of Environment, Climate and Biodiversity 
responsible for enforcement and coordination of implementation and the Water Management Agency 
responsible for the supervision of drinking water supply and most of the other water related tasks 
including the preparation of the River Basin Management Plan and reporting to the EU Commission. 
Luxembourg  reported  the  3rd  River  Basin  Management  Plan  as  documents  in  July  2022  and  no 
electronic reporting was done before the cut-off date. 

Luxembourg  participates  since  its  start  in  the  International  Commission  for  the  Protection  of  the 
Rhine (ICPR) as 97.3% of the country belongs to the Moselle-Saar sub-basin of the Rhine River Basin 
District (RBD). It also participates in the International Meuse Commission because of one river (0.2% 
of the territory) in the Meuse RBD. Luxembourg participates as a landlocked country in the OSPAR 
Convention for the protection of the Marine Environment of the North-East Atlantic. 

It is worth highlighting that the public participation on the RBMP has been organized around several 
round  tables  with  various  types  of  stakeholders,  including  agriculture,  energy  and  industry.  The 
outcomes of such discussions led to correcting errors and contributed to adding new information, 
adjustment of specific measures, changes to the selection of measures and commitment to action in 
the next planning cycle. 

2.2 Characterization of River Basin District 

Luxembourg  has  106  surface  water  bodies;  all  are  considered  river  water  bodies  except  for  two 
reservoirs,  and  six  groundwater  bodies.  This  means  that  no  water  bodies  are  assessed  as  lakes, 
except for two reservoirs that are still in a process to be assessed as lakes. The word lake is not used 
by Luxembourg, but the two reservoirs are (still) to be assessed as lakes. According to guidance all 
Heavily Modified Water Bodies (HMWBs) with a dam can be considered lakes. 

It is important to note that the very large majority of the surface water bodies are natural, and a 
small proportion (8, less than 9%) is considered to be heavily modified by human intervention. 

Table 1. Overview of Luxembourg ‘s River Basin Districts (RBDs)  

RBD 

Name 

Rivers 

Groundwater 
bodies 

LU000 

Rhine 

103 

LU001 

Meuse 

3 

TOTAL 

106 

6 

0 

6 

Source: 3rd RBMPs electronic reporting 

9 

 
 
 
 
Pressures 

Surface water bodies 

Various significant pressures are reported as being equally responsible for the failures to achieve 
good  ecological  and/or  chemical  status.  Diffuse  pollution,  point  sources  of  pollution  (industrial 
discharges, urban wastewater plants, historical contaminated sites), hydromorphological pressures 
(alteration  of  the  riverbed,  shores  or  riparian  areas  and  various  forms  of  barriers)  and  historic 
anthropogenic pressures are all reported to impact all surface water bodies.  

Diffuse pollution from agriculture is identified as a significant pressure on nearly all water bodies. 
Luxembourg is having in 2021 a 6% coverage of organic agriculture1, which is relatively low as 9.9% 
of total agricultural land in the EU is organic in 2021. The 2019 report on the implementation of the 
Nitrates  Directive  (figure  1)  shows  that  most  waters  in  Luxembourg  are  eutrophic,  and  the  few 
remaining are at risk to become eutrophic. 

Figure 1. Luxembourg Trophic Status reported 2019 

SourceSSource: JRC Nitrates Directive reporting at NUTS level (eutrophication) 

Note : 0% of the monitoring stations are above the threshold of 50mg/l  

Moreover, point source and hydromorphological changes are the most significant pressures.  

Luxembourg is facing also increasingly the pressure of invasive alien species (IAS), impacting the 
ecology  and/or  the  economy  and  even  the  social  well-being.  In Luxembourg, 10  of  the  21  IAS  of 
national  concern  species  are  shellfish,  fish  or  macroinvertebrates  relevant  which  hamper  the 
achievement  of  good  ecological  status.  The  Asian  clam  (Corbicula  fluminea),  Zebra  mussel 
(Dreissena polymorpha),  killer  shrimp  (Dikerogammarus villosus)  and  Japanese  knotweed  (Fallopia 
japonica) are included. Another sign of a pressure is the disappearance of native freshwater mussels 
that  have  a  key  role  on  improving  water  quality.  Indeed,  of  the  former  seven  species  found  in 
Luxembourg,  two  species  are  now  considered  extinct  in  the  wild.  Fortunately,  the  situation  has 
improved in recent years. The highly protected thick shelled river mussel (Unio crassus) has recovered 
slightly, so this pressure might be decreased in time and the projects such as the LIFE Unio Project 
(www.unio.lu) has certainly contributed to an improvement of this species in the river Our. 

1 Developments in organic farming - Statistics Explained (europa.eu) 

10 

 
 
 
 
Groundwater bodies 

A similar situation is depicted here, whereby the most significant pressures were diffuse pollution 
from agriculture (nitrates and pesticides) and from local pollution (contaminated sites).  

Luxembourg  did  a  good  analysis  setting  up  thresholds  of  significance  for  almost  all  identified 
pressures to establish what constitutes a significant pressure. Thus, the Plan indicates the pressures 
which are so significant that they are likely to prevent achieving the environmental  objectives. On 
that basis, by 2027, Luxembourg does not expect to reach good status for all its surface water bodies 
and  expects  no  significant  improvement  for  the  three  groundwater  bodies  that  were  not  in  good 
status in 2021. 

3. Policy elements contributing to biodiversity and 

climate change adaptation 

3.1 Surface Water: what is their ecological status or potential 

Monitoring 

Surface water monitoring is undertaken every four weeks at 17 locations in 16 % of the surface 
water  bodies.  These  sites  include  the  3  surveillance  monitoring  sites  and  the  14  operational 
monitoring sites. Operational monitoring is done to determine the status and covers all water bodies 
at risk and surveillance monitoring based on sufficient representative monitoring sites is aimed rather 
at identifying impacts and long-term changes.  

The low proportion of covered water bodies entails that the rest of the water bodies are appraised 
through extrapolation, modelling and grouping approaches. Hence there is a significant reliance on 
grouping, extrapolation and/or modelling for the assessment of status of surface waters.  

It is worth praising that in this Plan Luxembourg has increased the number of parameters monitored 
and included in the assessment of the status: namely water hardness and impacts on bioavailability 
of metals and in some locations also biota (largely based on fish), and suspended sediments at one 
location, in order to support the international work of the Rhine Commission. The increased number 
of  parameters  checked  and  increased  frequency in monitoring  physico-chemical  quality  elements 
may have had an impact on the lack of significant positive progress. Luxembourg informs that the 
3rd RBMP provides information on the methods used to assess the reliability and accuracy of the 
ecological status classification. However, detailed results on the robustness of the assessment are 
not provided. 

To assign different classes to a water body, clear thresholds are needed for the poor, moderate, good 
and high ecological status based on the various biological quality elements (e.g. snails, worms, dragon 
fly  larvae,  nematodes,  daphne,  fish,  water  plants,  algae)  that  are  expected to be  present.  But the 
supporting conditions for these life forms, i.e. physico-chemical quality elements (e.g. temperature, 
presence  of  O2  in  the  water,  nutrients,  transparency)  and  River  Basin  Specific  Pollutants  are  co-
determining the ecological status of the water bodies. Reference conditions must be set for good 
status, underpinned by similar ecologically healthy natural water bodies having high and good status. 
Luxembourg established these reference conditions for various groups of aquatic life (water plants, 
fish, etc) for their five river types and also adopted the thresholds set by Germany for one group of 
aquatic life (phytobenthos = algae) that is not frequent in Luxembourg’s rivers.  

11 

 
Figure 2 illustrates the evolution of the ecological status /potential of the 106 surface water bodies 
between the 1st, 2nd, and 3rd RBMPs.  It shows that from the 2nd RBMP to the 3rd RBMP the few 
water bodies in good ecological status (or potential) lost this quality (from 3 % to 0 %). In the 3rd 
RBMP, roughly almost half of water bodies are in moderate ecological status and over a half is even 
worse (41 % in moderate, 20 % in poor and 39% in bad ecological status2. All added, this means 
regrettably, that 100% of the water bodies are in less than good ecological status (or potential). This 
failure to reach good ecological status is mostly due to diffuse and point source pollution, producing 
high amounts of nutrients and thus causing the eutrophication of all water bodies in Luxembourg. 
The new plan includes now a more accurate and WFD-compliant delineation of the water bodies that 
no longer makes a distinction (as it was in the previous cycles) between the upstream part of certain 
streams that were showing good status and the downstream part. This change in methodology entails 
that the newly combined water body is not qualifying for good ecological status anymore. While there 
seems to be an overall deterioration for the third cycle, it needs to be noted that this may be due, at 
least partially, to the increase in diversity of monitored quality elements and the frequency of the 
monitoring  since  Luxembourg  improved  their  monitoring  substantially.  Another  reason  that  could 
partially explain the lack of progress is the new delineation methodology mentioned above.  

Figure 2. Ecological status or potential of surface water bodies, as reported in 1st, 2nd and 3rd RBMPs 

Source: WISE electronic reporting 

2 Numbers are based on pdf data mining of the RBMP 

12 

 
 
 
 
 
3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) 

The level of human intervention in the water systems is quite low as can be seen in the table below. 

Table 2. Modifications of surface water bodies (2021) 

Modifications  

Rivers  

Lakes  

HEAVILY MODIFIED 

(8 SWBs, 7% out of all SWBs) 

6% (6 HMWBs 
preliminary assessed 
as natural rivers) 

1% (2 reservoirs HMWBs are 
under study to get a GEP) 

ARTIFICIAL 

(total 0%) 

0% 

0% 

Out  of  the  106  surface  water  bodies,  98  are  designated  as  natural  and  eight  are  designated  as 
heavily  modified.  Despite  of  their  designating,  six  HMWBs  are  being  assessed  on  the  base  of 
thresholds set for “natural rivers” and classified to good ecological status (and not potential). The two 
remaining HMWBs considered as (hydroelectricity) reservoirs, are still in a study process for getting 
their Good Ecological Potential (GEP) defined. The Dutch approach was used in a study to establish a 
GEP for all HMWBs. The selection and implementation of targeted measures should subsequently 
enable this GEP to be achieved. However, during its application for the 3rd Plan, it turned out the Dutch 
method was not fit for the circumstances in Luxembourg. As a result, assessment used the natural 
river  water  body  assessment.  Just  as  it  was  the  case  for  the  2nd  RBMPs,  eight  water  bodies  are 
considered heavily modified water bodies because of dams (Mosel, Sauer and Our), shipping (Mosel), 
construction (all HMWB) and urban development (Alzette, Chier. Didelengerbaach). To be noted that 
urban  developments  and  constructions  are  more  frequently  the  cause  of  modifications  than 
hydropower. 

Figure 3. Percentage of heavily modified and artificial water bodies  

Percentage of heavily modified and artificial water bodies of 
Luxembourg

120

100

80

60

40

20

0

natural waterbodies

HMWBs

artificial waterbodies

total SWB

Source: datamining 3rd RBMP 

13 

 
 
 
All Luxembourg’s heavily modified water bodies are considered to belong to the river category by 
Luxembourg, while a HMWB may according to reporting guidance should be delineated as a lake or 
reservoir and the two hydroelectricity reservoirs certainly do not function as rivers. Hydrological and 
morphological alterations (changes in flow, lateral and transverse barriers, etc.) are for the first time 
integrated in the assessment for ecological status in the 3rd RBMP. None of the HMWBs have good 
ecological status/potential in 2nd RBMP nor in the 3rd RBMP and Luxembourg does not expect them to 
reach  a  GES/GEP  in  2027.  All  of  the  HMWBs  are  classified  on  the  basis  of  the  biological  quality 
elements (like water plants, fish, crayfish) sensitive to hydro morphological alterations and these are 
monitored and have at least one operational monitoring point per HMWB.  

For 28 surface water bodies (14%) there is not enough flow in the river to have good functioning 
water life and options for human use of the water downstream (minimum ecological flow). This is 
mentioned as a cause for 28 water bodies to not achieve good ecological status. 

3.3 Groundwater bodies - have they sufficient water – quantitative status 

It is positive to note that the levels of all but one of the groundwater bodies are monitored, and that 
when including expert judgement, they all have good quantitative status as shown in the graph below. 
For the groundwater that is not yet monitored, its status is assessment has moderate uncertainty.  

Figure 4. GWB quantitative status 

Source: WISE electronic reporting  

It is noted with concern that the status assessment does not yet consider the necessary water needs 
for the ground water associated ecosystems (GWAAEs) in the water (this is relevant for 2 groundwater 
bodies)  and  the  groundwater  dependant  ecosystems  on  the land (GWDTEs)  (this is  relevant for  5 
groundwater bodies). As N2000 network is occupying a considerable share of the territory, this is an 
important element that is missing. According to the N2000 monitoring data the protect habitats and 
species in Luxembourg are not in a favourable conservation status, though this is not making yet a 
direct link with groundwater availability. The RBMP states that studies are underway to determine 
the groundwater related needs of the ecosystems that are possibly not in good conservation status 

14 

 
 
because of lack of sufficient groundwater. This River Basin Management Plan does not yet include 
water  balance  calculations,  but  this  is  now  programmed  by  the  end  of  the  3rd  River  basin 
Management  Plan  (2021-2027).  Despite  the  missing  insights,  that  present  risks  for  a  decreased 
quantitative  status  in  2027,  Luxembourg  expects  to  maintain  the  good  quantitative  status  of  all 
groundwater well beyond 2027. 

3.4 Protected Areas (identification, monitoring, objectives and measures) 

There  are  different types and  reasons  why  certain water  bodies  are  protected  under  the  law.  For 
surface water bodies, protected areas have been designated under the Drinking Water, Bathing Water, 
Habitats  and  Birds  Directives  as  well  as  for  areas  designated  for  the  protection  of  economically 
significant  aquatic  species  (e.g.  aquaculture).  Several  areas  have  been  designated.  We  note  with 
concern, that this Plan has a small reduction of number of protected areas compared to the previous 
plan.  

The country has designated 45 protected areas for the purpose of drinking water abstraction. Only 
one of those is in a surface waterbody. The others are in five groundwater bodies (in a total of six). 
The protected drinking water areas include mandatory and voluntary measures, including a ban on 
specified pesticides, that are currently being implemented. The designation of drinking water related 
protected  areas  is  not  yet  fully  completed.  After  the  first  five  protected  areas  for  groundwater 
regulated  in  2015,  39  more  have  been  delineated  over  the  years  until  2022.  Luxembourg  relies 
almost entirely on groundwater for its drinking water supply. Indeed, there are now 45 drinking water 
protected areas, out of which only one is related to surface water. It is worth noting that these 45 
areas  cover  around  80%  of  the  relevant  area  necessary  to  protect  the  source  of  drinking  water 
production. The area around an abstraction point to produce drinking water is divided in several zones: 
the  core  being  the  part  where  only  activities  related  to  the  abstraction  and  maintenance  of  the 
infrastructure is permitted. Around the core, there are zones where the application of fertilisers and 
pesticides  are  prohibited.  The  voluntary  measures  focus  on  the  existing  activities  in  the  newly 
designated protected areas with a special focus on agriculture. As the protection of the drinking water 
protected areas is relatively recent, no change in status of the water bodies is noted. 

There are 18 bird protection sites designated under the Birds Directive and 48 sites designated under 
the  Habitats  Directive.  The  share  of  surface  water  bodies  that  are  relevant  for  these  protected 
habitats and species is not clear in the Plan. The Plan indicates that the conservation status of all 
water-dependent  habitats  and  species  is  unfavourable  and,  in  some  cases,  even  poor.  Since 
Luxembourg  considers  that  achievement  of  a  good  ecological  status  is  sufficient  to  meet  the 
requirements of the Birds and Habitats Directives, no additional objectives have been set. The Plan 
indicates  that  measures  related  to  water  bodies  and  ecosystems  dependent  on  groundwater  are 
developed  jointly  between  the  nature  and  forest  administration  and  the  water  management 
administration and thus possible conflicts in objectives can be addressed from the start. As mentioned 
earlier, the quantitative and qualitative status of groundwater bodies does not consider the water 
needs for depending sensitive ecosystems. As regards bathing waters, Luxembourg indicates that 
two additional bathing areas are in the process of being designated, on top of the three areas already 
designated in the 2nd Plan and maintained in the 3rd Plan. The process of designation has not been 
completed because the monitoring for these new bathing areas only started in 2020. The status of 
bathing waters has been found to be excellent for all twelve monitoring stations in the existing three 
bathing areas. There is one more monitoring point for these areas since the 2nd Plans. 

15 

 
The entire country is designated as sensitive area under the Urban Wastewater Treatment Directive 
and as Nitrates Vulnerable Zone under the Nitrates Directive.  It is worth noting that all surface waters 
having problems with high concentrations of nutrients or at risk to be eutrophic as will be touched 
upon later in the measures to combat diffuse pollution. The challenge now is to maintain and to keep 
up with the population growth. 

3.5 What is being done to prevent/reduce hydromorphological pressures 

The 3rd RBMP includes 2,133 measures related to  hydro morphology. Of those 231 measures are 
being implemented and 1,902 are listed as possible measures. Out of those that are started, 77 are 
described as implemented in the RBMP during the 2015-2021 period. Half of these 77 measures are 
focused  on  restoring  ecological  continuity  (fish  ladders  and  establishment  of  near  natural  flow 
regime). There are 3 new basic measures implemented from 2021 concerning the assessment of the 
present hydrological regime, restoration and securing near natural flows and restoration and securing 
of  near  natural  water  balances;  but  no  methodology  to  define  near  natural  flows,  or  balances  is 
reported yet nor is a clear link to permitting integrated. 

Particularly highlighted is the renaturalisation of the River Pétrusse, co-funded by the EIB, listed as 
an  example  of  a  measure  that  is  currently  being  implemented  to  tackle  hydro  morphological 
pressures. Canalized in the 1930s, this stream goes through the city of Luxembourg. Renaturalisation 
will help reducing the flood risks, increase biodiversity and help in climate change adaptation of the 
city’s atmosphere. 

Furthermore, Luxembourg introduces measures to reduce the flow rate during floods and increase 
the infiltration capacity both of which are beneficial for reducing further pollution in the catchment 
area.  Flood-reducing  measures  in  rural  areas  can  achieve  multiple  synergies  with  other  policy 
objectives, such as soil protection through erosion reduction or reducing low water levels through 
increased retention and infiltration. Other measures include removing bed and bank protection and 
restoration of floodplains. 

All  impoundments  and  other  crossing  structures  are  now  included  in  the  hydro  morphological 
monitoring carried out for the improvement of the assessment for ecological status. It is still unclear 
if this is going to have repercussions in permits or measures. Information (e.g. using CIS Guidance), 
how e-flows have been derived and implemented on ecological flow was announced in the 2nd RBMP 
but  is  not  identified  in  this  plan.  Furthermore,  the  implementation  of  measures  related  to  hydro 
morphology remains low and the analysis of gaps to be closed is missing. 

Luxembourg decided in 2023 to renew all permits, even those that had no limited time of being valid. 
In the updating, the latest insights regarding necessary steps to reach good ecological status are 
included. In the RBMP, this is already mentioned as under discussion. On the other hand, the WFD 
objectives have been taken into account in the design of new and existing structural measures, such 
as flood defences, storage dams and barriers in both RBDs for the future. 

The mitigation measures for the two reservoirs in the Sûre and in the Our are linked to the identified 
pressures but are limited by the need to preserve their use for hydroelectricity. The elaboration of 
these measures implies the involvement of economic and energy technology experts to ascertain the 
costs  and  ensure  that  the  measures  maintain  the  mode  of  operation.  The  HMWB  of  the  Moselle 
(mainly  related  to  shipping  and  urban  developments)  is  in  the  meantime  also  the  subject  of  a 
feasibility study to identify the pressures and the possible mitigation measures. Conclusion is that 

16 

 
Luxembourg  is  finally  setting  more  emphasis  on  assessing  and  mitigating  hydro  morphological 
pressures, however, the two reservoirs which are heavily modified because of hydropower are still 
not  assessed  in  a  definitive  way  and  have  no  defined  good  ecological  potential  including  the 
mitigation  measures  considered  feasible.  For  the  six  other  HMWBs  with  modifications  related  to 
shipping  and  urban  developments  or  constructions,  the  ecological  potential  has  not  yet  been 
assessed. These six are assessed preliminarily as natural rivers. The options to improve the status of 
these water bodies and the way they are managed in relation to ecological continuity and e-flow on 
the one hand and the maintaining of the other functions they serve, are not clear yet. It remains 
unclear whether achieving the (still not defined) objectives for these water bodies in 2027 will be 
possible. 

3.6 What Luxembourg is doing for abstractions and water scarcity 

Water scarcity is not recognized as an issue at the national level and water  abstraction from the 
groundwater  is  locally  significant  only  for  one  groundwater  body  in  the  Rhine  RBD.  This  is  rather 
normal  for  an  upstream  country  receiving  enough  rains  but  given  the  long-lasting  international 
collaboration  in  the  international  Rhine  and  Meuse  districts,  transboundary  issues  could  rise  to 
influence  Luxembourg,  because  of  downstream  needs.  Luxembourg  delineates  the  groundwater 
bodies exactly on the borders, while hydrology continues and is subject to bilateral cooperation. This 
could call for enhanced transboundary cooperation as regards chemical pollution and quantitative 
aspects. 

Relevant basic measures for the control and management of water abstraction and impoundments, 
as  well  as  water  efficiency  measures  in  all  sectors  were  implemented  since  the  previous  cycles. 
Luxembourg  conveys  that  the  introduction  of  higher  drinking  water  prices  in  2010  immediately 
showed results.  

Figure 5. Water abstraction by economic sector 

Source: EEA WISE Water abstraction by source and economic sector in Europe, June 2022 

As regards the review of permits for abstractions, authorizations, given by the Minister since 2019, 
are valid for a maximum period of seven years. Authorizations for groundwater issued since 2015 
are limited in time and are valid until December 2024 at the latest.  Luxembourg has pre-established 
inspection  plans  for  groundwater  abstractions,  unexpected  inspections  for  surface  water.  These 

17 

 
 
inspections do not guarantee a review of the authorizations more frequently than once every seven 
years.  Luxembourg  stresses  that  the  water  law  explicitly  allows  for  Authorities  to  review  when 
deemed needed. The various authorizations specify the maximum flow rates that can be taken, and 
which have been determined based on the results of pumping tests. Regarding the authorizations 
issued  before  2015  (not  limited  in  time),  Luxembourg  is  having  internal  discussions  currently 
concerning the option of legislative modification of the water law, that enables to invalidate or review 
the authorizations issued to ensure that the sum of abstractions does not jeopardize the quantitative 
status of groundwater bodies. Increase of awareness on water abstractions is growing also due to 
the increasing population.  From January 2023 agricultural abstractions from surface water are to 
be registered and water metering for all sectors is introduced in the planned new permits. By end of 
the 3rd RBMP period, Luxembourg has the intention to calculate water balances instead of using only 
old data. 

3.7 Adaptation to climate change 

Just as it was the case in the previous cycle, no waterbody is identified as being particularly hit by 
the  impacts  of  climate  change.  Considering  the  close  relationship  between  overall  water 
management and floods management and the importance of climate change effects on both, climate 
change effects are jointly addressed in this section.    

Flood management  

Luxembourg considered initially climate change impacts in 2014, at the time of the first preliminary 
flood risk assessment; there was no new mention of climate change  considerations in the second 
PFRA. 

The second FRMP indicates that potential changes in flood risk as a consequence of climate change 
have been taken into account in protection measures, but further details are not provided. The FRMP 
refers to coordination with the National Climate Change Adaptation Strategy 2017-18, with some 
common measures to both. Climate change is also considered in the design of technical measures. 
The FRMP provides information3 on how climate change is affecting Luxembourg, based on research 
carried out in the last 15 years. It is assumed that in the future, Luxembourg’s annual amount of 
precipitation will remain constant, but distributed differently across the year, i.e. more precipitation 
expected in winter and less in summer, with the intensity of precipitation increasing in summer. Heavy 
rain4  is  considered5  a  key  risk  for  future  flooding  in  the  context  of  climate  change.  Given  the 
remarkable increase in heavy rain events, Luxembourg’s water management agency drew up a heavy 
rain strategy6 in autumn 2018. 

In July 2021 Luxembourg also had to evacuate dozens of people because of heavy rains causing 
flash floods that caused fatalities and had heavy impact in Germany, Belgium, and the Netherlands. 
The material damage of the flooding was significant in Luxembourg, but no fatalities were reported 
in Luxembourg7. 

3 Chapter 6.11. 
4 This could be referred to as flash floods. 
5 Chapter 6.12. 
6AGE, Starkregenrisikomanagement in Luxemburg von Starkregengefahrenkarten zum integralen, kommunalen 
Maßnahmenkonzept, n.d., https://enquetes-
download.public.lu/enquiryFile_1680/Anhang_1_Starkregenrisikomanagement_in_Luxemburg_aktualisiert.pdf 
7 Luxembourg – Dozens Evacuated After Record Rainfall Causes Rivers to Break Banks – FloodList 

18 

 
 
Studies have been conducted, including, by means of a pilot project, to ascertain potential effects of 
heavy  rain  events  on  fluvial  flooding  (flash  floods),  even  if  this  source  is  not  yet  considered  as 
significant. 

Droughts and water scarcity management 

Drought is not considered as a current challenge in Luxembourg, but nevertheless they are planning 
to develop a drought management plan. To this end there is a national working group integrating 
irrigation agriculture actors (Waasserdësch) and there are several pilot projects dealing with water 
availability issues for that sector. In addition to that, there is a technical working group on e-flows. It 
is worth noting that the 3rd River Basin Management Plan integrates water-related climate change 
adaptation  considerations  and  possible  future  measures  defined  in  the  National  Climate  Change 
Adaptation  Strategy  in  the  Program  of  measures.  This  is  done  with  the  intention  to  improve  or 
maintain the present status, but also to enhance resilience against natural disasters (floods). These 
measures are climate-proofed and focused on securing quality and quantity of surface water, and 
quantity of groundwater. 

Yet the 3rd river basin management  plan does not seem to contain a detailed analysis of future 
climate change impacts on water balance. However, a project is planned in 2024 and 2025 to identify 
climate change induced changes on water balance, discharge, and water temperature for the near 
and for the far future.. This project will help to detect possible future climate change-based impacts 
on the water bodies and develop adaptation measures. 

4. Policy elements contributing to zero pollution 

4.1 Surface Water: what is their chemical status 

Monitoring 

Luxembourg reports that a dedicated monitoring network is in place to meet the requirements of the 
WFD that includes monitoring for all priority substances. However, due to analytical and economic 
constraints, for the period 2015  -2020, only 24 out of 45 priority substances were monitored. In 
terms  of  approach  to  monitoring  strategies,  surface  water  monitoring  is  undertaken  monthly  at 
approximately 10 % of the water bodies with grouping and extrapolation used to determine chemical 
status for the remainder. Luxembourg indicates that for 16% of the surface water bodies monitored 
the assessment featured a high confidence of the chemical status. For the other 84%, which were 
assessed  by  using  extrapolation  and  grouping  through  modelling,  the  level  of  confidence  was 
medium. 

Status Assessment  

All  106  surface  water  bodies  are  in  poor  chemical  status.  Figure  6  shows  the  evolution  over  the 
different cycles. 

19 

 
Figure 6. SWB chemical status 

Source: WISE electronic reporting  

This is partly due to a small number of a group of substances that are present everywhere in some 
concentration,  because  they  are  also  transported  far  as  air-pollution,  before  coming  in  the  water 
system through rain or dust deposits (uPBT). If ubiquitous substances were not taken into account, 
8% of the surface water bodies would be in good chemical status. In 2015, this number was 10%. A 
reason for that is the significant presence of fluoranthene which is not a uPBT but which has a very 
strong impact on the good chemical status in the 3rd RBMP.  Figure 4.2 depicts which ones are the 
substances causing the highest numbers of failures (mercury and brominated diphenyl ethers, PAH 
and fluoranthene but also cadmium, PFOS and the herbicide cypermethrin). 

20 

 
 
Figure 7. Top-10 of water polluting substances causing failure to achieve good chemical status8 

Top-10 Priority Substances causing failure of good chemical status as 
percentage of SWB

anthracene

cypermethrin

cadmium

PFOS

mercury & compounds

PBDE

PAH

Fluoranthene

0

20

40

60

80

100

120

Source: datamining PDF 3rd RBMP  

4.2 Groundwater Bodies: what is their chemical status 

Monitoring 

All of the groundwater bodies are subject to surveillance monitoring. The 31 surveillance monitoring 
sites have not changed between the three RBMPs. The WFD monitoring network has recently been 
reviewed and adapted to include 38 monitoring sites, to be used from 2021 onwards. These sites are 
also part of the operational network. Monitoring includes all the substances listed on Annex I and 
Annex II of the GWD. 

Status Assessment 

It is a source of concern that 50% of the groundwater bodies (which represent 79% of the area of 
groundwater  bodies)  are  in  poor  chemical  status because  of  nitrates  and  pesticides.  A  significant 
deteriorating trend has been identified for the Devonian groundwater body in the North and for the 
chemical substance metazachlor-ESA. Given the groundwater residence times estimated, the status 
for the other five groundwater bodies therefore is expected to remain the same.  

The assessment of the chemical status of groundwater bodies has not taken into account the needs 
of nature (Groundwater Associated Aquatic Ecosystems, or GWAAEs) due to the lack of information. 
Similarly,  five  of  the  six  groundwater  bodies  are  linked  to  Groundwater  Dependant  Terrestrial 
Ecosystems (GWDTEs), but a lack of understanding of the influence of groundwater quality on their 
poor condition meant that this has not been considered in the chemical status assessment.  Although 
there was an engagement to do this assessment for the 3rd RBMP, this is still lacking. This seems to 

8 These Priority Substances include the PS added in 2013. LU included them in their chemical status assessment, in spite 
of the fact only monitoring was obligatory. 

21 

 
 
be now envisaged for the 4th RBMP. The following figure shows the evolution of groundwater chemical 
status as reported in 2009, 2015 and 2021 RBMPs.  

Figure 8. GWB chemical status 

Source: WISE electronic reporting 

4.3 What Luxembourg is doing to combat pollution from agriculture 

The  RBMP  does  not  include  the  gap  to  target  by  2027  for  the  necessary  reductions  of  N,  P  or 
pesticides. Thus, the plan does not include an estimation of the necessary contribution by agriculture 
to the reduction of nitrogen and phosphorous, although the meat and dairy sector contribute to 80% 
of the agricultural profits. This also holds true for the necessary reductions in nutrient (N/P) pollution 
in  the  flow  of  surface  water  from  Luxembourg  towards  the  various  neighboring  member  states, 
participating  in  the  International  Rhine  and  Meuse  Commissions.  The  Programme  of  Measures 
includes,  in  addition  to  the  measures  of  the  Nitrate  Action  Plans,  a  list  of  voluntary  agricultural 
measures (supported under the Common Agricultural Policy) to reduce diffuse pollution. In the CAP 
Strategic Plan9 for the period 2023-2027 it is planned  that  92% of LU’s agricultural  area will  be 
covered with commitments to protect water quality, 91% of the agricultural area will benefit from 
support  for  sustainable  nutrient  management,  and  36%  of  the  area  will  be  covered  with 
commitments for the sustainable use of pesticides. The EU average for such support is 21%, 15% 
and 27% respectively. In the 3rd RBMP LU is reporting voluntary CAP 2023-2027 measures targeting 
of the agriculturally used land Luxembourg notes that in the 2nd period for the WFD (2015-2021) the 
uptake of farmers of voluntary measures under de CAP 2014-2022 ￼ Luxembourg intends to apply 

9 “Mapping and analysis of CAP strategic plans” (2023-2027)  the link Mapping and Analysis of CAP Strategic Plans 
- European Commission (europa.eu) 

22 

 
 
 
 
more  control  and  higher  financial  incentives  to  increase  the  voluntary  uptake  and  achieve  more 
agricultural reduction of pollution. 

Luxembourg included a WFD payment intervention in its CAP Strategic Plan to compensate farmers 
for the reduced yields related to the ban of the use of a selected set of pesticides in drinking water 
protected  areas.  There  are  six  relevant  CAP  eco-schemes  and  agri-environment  climate  (AEC) 
interventions to limit nutrient and pesticide losses. One of the AEC interventions supports farmers 
which move to less intensive livestock systems (i.e. reduction of livestock density by at least 15% 
within the first three years). Luxembourg states that most agricultural measures, both mandatory 
and voluntary, are paid by the agricultural sector or from CAP funding. Luxembourg flags that some 
of the of measures proposed in the 3rd RBMP, could not be integrated in the CAP Strategic Plan but 
that discussions on the topic continue. 

Luxembourg also mentions the development of tools for a leaching risk-based approach to assess 
agrochemical release to waters. 

There is no information about the effectiveness of the voluntary agricultural measures in the Plan. 

4.4 What Luxembourg is doing to combat pollution from other sectors 

Luxembourg indicates that most chemical pollutants causing failure are diffuse pollutants coming 
from  air  depositions  (also  coming  in  from  great  distances)  and  thus  concludes  that  there  are  no 
possibilities  to  reduce  these  pollutions  at  the  source  through  the  River  Basin  Management  Plan’s 
measures.  

Luxembourg  reached  fully  implemented  the  Urban  Wastewater  Treatment  Directive  in  2018,  so 
wastewater  has been  another  important  source  of nutrients (N  and  P).  Luxembourg programmed 
1269 measures related to the management of urban wastewater and its treatment in the 2nd RBMP. 
The Plan states that a little more than 60% of these measures have been implemented and around 
350  urban  wastewater  management  measures  are  in  progress.  It  is  stated  that  the  rest  of  the 
measures are part of this 3rd plan. There are no details of how many measures are expected to be 
fully  implemented  by  the  end  of  the  3rd  planning  period.    The  use  of  an  authorization  and/or 
permitting  regime  to  control  wastewater  point  source  discharges  is  reported  for  surface  and 
groundwater in both RBDs.  Wastewater treatment plants are subject to registration in an internal 
register  and,  when  meeting  the  reporting  thresholds,  in  E-PRTR.  This  is  due  to  the  fact  that  in 
Luxembourg all discharges from wastewater treatment plants irrespective of size are all subject to 
a discharge permit. Some direct discharges to groundwater are authorised in accordance with the 
law in both RBDs in Luxembourg. 

Luxembourg still has a few production sites of a steel group but had important steel industry in the 
past (till 1997) 10 which has certainly contributed to the nitrogen pollution in the country. The high 
levels of traffic and road transport probably contribute also to the nitrogen pollution.  

Mercury and PAHs are closely related to combustion of wood at homesteads (close by) or biomass, 
lignite,  and  charcoal  energy  production.  Reduction  of  these  emissions  through  measures  at  the 
Member State level do exist like stimulating the reduction in combustion of fossil fuels.  

10 The steel industry and Luxembourg - Luxembourg (public.lu) and The transformation of ARBED: 1973-2001. A European 
business and labour history (TransARB) - C²DH - University of Luxembourg I Uni.lu and ARBED - Wikipedia  

23 

 
 
It  needs  to  be  stressed  that  the  plan  does  not  include  a  gap  analysis  on  distance  to  target  for 
pollutants from non-agricultural sectors. Without a proper assessment of the effort to be made, the 
choice of measures for these other sectors is made more difficult. 

4.5 What Luxembourg is doing to combat significant pressures – overall 

assessment of the Programmes of Measures 

The absence of clear gaps analyses and absence of information about the effectiveness of the earlier 
programmed measures do not allow to conclude if the programmed measures are sufficient to bridge 
the gaps. The links between the Key Type Measures and pressures do not appear explicitly present in 
the RBMP documents although the Plan describes a detailed process of measure selection based on 
knowledge of pressures.  This plan has added a focus on the identification of significant pressures 
for morphological alterations and modifications of flow regimes through abstractions or regulations 
of the flow. Consequently, the plan includes measures to mitigate or compensate these alterations. 
The  Cost  Effectiveness  Analysis  is  mentioned  in  the  RBMP,  but  the  Plan  does  not  clarify  how  the 
evaluated cost effectiveness is used to select and prioritize measures. The funding does not seem to 
be a barrier for the implementation of the measures. The percentage of measures which are new 
compared to the 2nd RBMP (to ascertain how much of a business-as-usual approach has been taken) 
remains unclear. 

5. Exemptions and economics 

5.1 To what extent are exemptions applied in Luxembourg 

In the second cycle, 97% of surface water bodies were exempted from good ecological status. This 
has increased to 100% in the third cycle. This means that all surface waterbodies are exempted from 
achieving good ecological status in the country.   

As  it  was  already the  case  for  the previous  cycle,  50%  of  the groundwater bodies  are  subject  to 
exemptions pursuant to Article 4 (4) of the WFD as regards chemical status.  

On grounds of technical feasibility, 99 of the surface waterbodies are subject to reach less than Good 
Ecological Status (GES)/Good Ecological Potential (GEP) and all the 106 surface waterbodies (100%) 
to subject to reach less than good chemical status. 

On  grounds  of  disproportionate  costs,  91,5%  of  the  surface  waterbodies  are  exempted  from 
achieving good ecological status. Whereas natural conditions are evoked to justify that 101 surface 
waterbodies are not achieving a GES/GEP and for 106 SWB to achieve a less than good chemical 
status). 

This means that a significant number of water bodies benefit from more than one exemption.  

For groundwater, natural conditions are evoked as a reason not to achieve good chemical status for 
50%  of  the  water  bodies.  Natural  conditions  underlying  the  exemptions  concern  natural 
hydrogeological conditions and the long time needed for the re-establishment of flora and fauna. 
Technical feasibility refers to a lack of, or insufficient information on, the cause of the problem or the 
absence of an appropriate technical solution. Disproportionate costs refer to affordability, benefits to 
be achieved versus consequences of non-action, distribution of costs, social and sectoral impacts, 
and other reasons. 

24 

 
 
 
Figure 9. Type of exemptions reported to be applied to surface water and groundwater bodies for the 3rd 
RBMPs  

Source: 3rd RBMP data mining 

It is seen positively that for each water body there is a reasoned justification based on a transparent 
set of criteria. However, only for one groundwater body Lower Lias a specific study on residence times 
is provided to underpin the natural conditions justification. There are no further specific references to 
individual water body studies included in appendix 15 and 16 to specify in more detail, as required 
by the WFD,  natural  conditions involved,  or  the  technical  feasibility,  or  the  disproportionate  costs. 
Moreover, the detailed underpinning studies are not referenced. 

It is noted in the plan, that there is no intention to set lower environmental objectives for these water 
bodies, but rather to achieve environmental objectives after 2027. In their view, all measures which, 
according to the current state of knowledge, are needed to achieve good status/potential, are already 
provided  for  in  the  program  of  measures.  It  is  clear  however  that  not  all  measures  will  be 
implemented by the end of 2027. This approach is referred to as 'water bodies with special regime' 
and is based on maintaining the environmental objectives of the WFD but acknowledging that it will 
take longer to achieve these objectives. This approach might not be compatible with the WFD. After 
2027,  exemptions  under  Article  4(4)  may  only  be  possible  if  justified  on  the  basis  of  natural 
conditions, i.e. where it can be demonstrated that all measures are in place and implemented prior 
to the end of the third cycle (end 2027), but that nature takes more time to recover. 

For  all  exempted  water  bodies,  programs  of  measures  are  in  place,  with  a  clear  timeline  and 
estimated costs of measures. However, the timeline goes beyond 2027. Where the latter cannot be 
justified by ‘natural conditions’ (i.e. measures will start to be implemented before the end of 2027, 
but ‘nature takes more time to recover’), this will not be compatible with the WFD, which only provides 
for such time extensions up to the 3rd RBMPs, namely until end 2027.  

No exemptions according to Article 4(7) have been applied. The plan notes that the use of this type 
of exemption may become relevant in the future in light of new development activities and sets out 
principles  for  applying  this  type  of  exemption  but  without  laying  down  specific  set  of  application 
criteria. This may point to an under-implementation of the requirements of Article 4(7) according to 

25 

 
which any new project potentially affecting water body status should be assessed upon its impacts 
and, where so required because of potential deterioration or preventing the achievement of good 
status, be justified in accordance with the detailed criteria set out in Article 4(7) WFD. 

5.2 Use of economic analysis and water pricing – cost recovery 

The updated economic analysis (as required by WFD Annex III) appears incomplete. The forecasts for 
water supply and demand run only until 2027, and consequently the analysis lacks the necessary 
long run perspective and thus an explicit / corroborated link  with climate adaptation / the climate 
adaptation perspective. Neither is there a clear investment planning. There is extensive reporting on 
variable and fixed cost components of the broad water services water supply and sanitation services, 
split over the broad water user sectors agriculture, industry, and households. 

LU has carried out a combination of qualitative and quantitative cost-effectiveness analysis, but the 
applied multi-criteria analysis renders it hard to track whether the set of measures is indeed cost-
effective. 

The extensive quantitative information on cost price components and quantitative descriptions of the 
pricing suggest that the pricing policy has been more informed by the ‘revenue raising’ motive with 
adequate sectorial contributions rather than the incentive motive. Unfortunately, the account on the 
adequacy  of  price  incentives  appears  incomplete  and  implicit.  A  reference  to  a  fall  in  water 
consumption over time is presented as evidence of the incentives of the volumetric components in 
cost-based pricing. Yet, the disparity of price levels over user sectors, the lack of increasing unit rates 
over  consumption  volume  as  well  as  of  a  variation  of  abstraction  tariffs  with  scarcity  conditions 
suggests there is an unused potential in applying price incentives. 

There is a qualitative account on the adequacy of sectorial contributions (although not clearly named 
as such). Water tariffs reportedly reflect the varying need of security of supply, which is reflected in 
a different cost profile for water distribution. The latter is also cited as a mitigating factor to the 
water services’ cost recovery in areas with lower population density and challenging geographical 
conditions. In addition, a “social cap” on prices is reported. It is not clear whether these factors amount 
to lower cost recovery or rather a pooling of costs over larger areas and user categories. The PP is 
applied but with a limited scope. There is an explicit system to account for the environmental costs 
of water services provision. It leads to a variation in prices depending on the users in relation to their 
contribution to the pressures. 

6. WFD recommendations 

Recommendations - Luxembourg should: 

1. Step up its level of ambition and accelerate action to achieve as much as possible to bridge the big gap to 
reach good ecological status/potential and good chemical status for its surface water and good chemical and 
good quantitative status (including the needs of depending or associated ecosystems) for groundwater bodies. 
This includes specifically that Luxembourg considerably increases its efforts to  

a) 

limit nutrient (nitrogen and phosphorous) pollution from agriculture, wastewater plants, overflows of 
sewage systems, and industry. 

26 

 
b) 

limits the pesticide use to prevent further contamination of groundwater or surface water. 

c)  adapt its legal instruments to implement ecological flows as fast as possible. 

d)  define the Good Ecological Potential and adopt urgently the measures to achieve it.  

e)  mitigate hydromorphological pressures. 

f)  enhance  quantitative  water  management  establishing  water  balances  including  climate  change 
projections and the necessary regular review of abstraction permits, including agricultural abstractions 
too. 

2. 

Identify and put in place, as appropriate, additional measures to reduce existing persistent environmental 
challenges (pressures) preventing the achievement of good status based on robust gap analyses. 

a)  Luxembourg should do a thorough gap analysis per river basin, including the analyses about the needed 
load reductions in pollutants to be achieved by various economic sectors. This concerns all types of 
pollution, pesticides and nutrients and hydromorphological pressures. This will contribute to a better 
targeted PoM, having the necessary effectiveness and targeting in the most responsible sectors.  

b)  Luxembourg should evaluate the effectiveness of measures put in place in earlier PoMs to warrant the 
success of the new programmed measures. This is especially important for the nutrients and pesticides. 

c)  Measures in the PoM for the chemical pollution are limited to review of industrial permits. There is 
however no reason to avoid national or regional measures for airborn uPBT pollutants. The River basin 
Management Plans should consider all measures preventing the achievement of good status. Phasing 
out of the emissions of uPBTs must be carried out. 

3. 

Improve funding, cost-recovery and price incentives and ensure the proper implementation of Article 9 and 
the  economic  analysis  to  underpin  the  PoM,  including  the  long-term  perspective  considering  climate 
change. Luxembourg should provide a transparent account of the cost recovery, including the calculation 
and internalization of environment and resource costs for all activities with a significant impact on water 
bodies. In addition, Luxembourg should clarify the way cost effectiveness analyses are used in prioritizing 
measures including the long-term perspective. There seems to be an untapped potential in applying pricing 
as an incentive given the disparity of price levels over user sectors. This could be done by increasing unit 
rates over consumption volume as well as of a variation of abstraction tariffs with scarcity conditions. 

4.  Step  up  the  pace  of  implementation  of  the  present  PoM  as  climate  change  is  increasingly  creating 
(seasonal)  water  shortages  (entailing  higher  pollution  levels),  risks  for  flash  floods  and  is  increasingly 
creating algae blooming in eutrophic water. It is important to reiterate that the current assessment of the 
quantitative status of the ground water bodies does not yet include, as required by the law, the water 
needs  of  aquatic  and  terrestrial  dependent  ecosystems.  This  may  lead  to  an  assessment  that  is  an 
overestimation of the good quantitative status. The calculation of water balances should be started as 
soon as possible. 

5.  Where the objectives of the Directive for a specific water body cannot be met and exemptions are invoked, 
Luxembourg should do so in line with ECJ jurisprudence on the restrictive interpretation of exemptions and 
better justify the use of exemptions, providing sufficiently detailed justifications at the level of the specific 
water body and ensure that their application is regularly reviewed. This implies: 

a)  Ensuring  that  all  measures  necessary  for  achieving  good  status  or  potential  by  end  of  2027  are 
identified and initiated (implemented) during this cycle, to avoid unjustified time exemptions beyond 
2027 (i.e. other than exemptions based on natural conditions) or an unjustified conversion to Article 
4(5)  exemptions  in  2027  (i.e.  other  than  based  on  objectively  established  disproportionate 
costs/unfeasibility after identification of all measures necessary to achieve good status) 

27 

 
b)  Recognising that the possibilities for time extensions (Article 4 (4)) are extremely limited and will no 
longer  be  allowed  after  2027  (except  if  duly  justified  for  natural  conditions)  and  taking  action 
appropriately, 

c)  Clearly informing in a transparent manner about the application of Article 4(7) exemptions and apply 
it  correctly  with  sound  and  thorough  justifications  in  the  RBMPs  for  new  projects  implying  water 
transfers, water reservoirs or important abstractions 

d) 

laying down a specific set of criteria for applying Article 4(7), taking into considering the restrictive 
interpretation of the Court of Justice of the concept of deterioration, requiring Member States to assess 
impacts and potential deterioration of new modifications/projects. 

6.  As  regards  monitoring,  assessment,  data  management  and  reporting,  Luxembourg  has  made  some 

considerable progress in several aspects, particularly on monitoring, but should: 

a)  accelerate the reporting of the electronic data 

b)  create clarity about the environmental objectives (good ecological potential  (GEP) for the 8 Heavily 
Modified Water Bodies (HMWBs as soon as possible. Well targeted action for possible improvements is 
urgent to still have a chance to get implemented in time.  

c) 

Increase the number of the water bodies being monitored and reducing the reliance on grouping and 
modelling for the 84% of water bodies that are not monitored for biological quality elements. This will 
improve the certainty of the status assessments. 

d)  complete  the  identification  of  the  hydromorphological  pressures.  The  envisaged  implementation  of 
hydromorphological quality elements however is still very limited. There is a need to accelerate the 
implementation of mitigation/compensation for the hydromorphological pressures.  

e)  expand the monitoring of priority substances as most priority substances are monitored in only 16% 
of the water bodies, to increase the certainty of the assesments. Moreover, not all the substances are 
monitored at all sites.  

f)  absolutely include the water needs of associated or dependent ecosystems in water and on land to the 
quantitative assessment of ground water bodies and ensure protected areas in particular are afforded 
adequate objectives and measures to ensure their protection. This is also needed to ensure favourable 
conservation status under the Birds and Habitats Directives. Moreover, Luxembourg should overcome 
the last unknown groundwater body that is still not monitored quantitatively and chemically despite 
the commitment taken in the 2nd RBMP 

7.  As regards transboundary cooperation, Luxembourg should quantify its possible impact downstream and 
adjust its national PoM accordingly. Despite the excellent and long-established transboundary collaboration 
in the International Rhine and in the International Meuse Commissions, Luxembourg provided very limited 
information in the River Basin Management Plan on the necessary reductions in nutrient (N/P) pollution in 
the flow of surface water from Luxembourg towards the various neighbouring Member States. 

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SECTION B: 
FLOODS DIRECTIVE 

29 

 
 
 
7. Flood risk management under floods directive (FD) 

The Flood Directive requires each Member State (MS) to scan its territory for flood risks, assess the 
potential adverse consequences of future floods for human health, the environment, cultural heritage 
and economic activity, identify the significant risks, map the flood extent and the potential adverse 
consequences, and take measures to reduce the flood risk. These activities are reflected in (a) the 
preliminary  flood  risk  assessments,  or  PFRAs  (including  the  identification  of  areas  of  potential 
significant flood risk, or APSFRs), (b) the preparation of flood hazard and risk maps, or FHRMs, and (c) 
the establishment of flood risk management plans, or FRMPs. The preliminary assessments, mapping 
and planning for flood risk are repeated in six-yearly cycles. 

There  are  two  Units  of  Management  (UoMs)  in  Luxembourg,  which  are  the  same  as  the  Water 
Framework Directive’s River Basin Districts (RBD). Fluvial, pluvial, groundwater, and Artificial Water 
Bearing Infrastructure floods are considered as potentially significant sources of flooding. 17 Areas 
of Potential Significant Flood Risk (APSFRs) have been designated.  

7.1 Flood hazard and risk maps 

Luxembourg is using a GIS-based geoportal11 at national level for their FHRM and showing the whole 
country. Maps for floods with low probability (1/1 000 years), with medium probability (1/100 years) 
and with high probability (1/10 years) are provided. The maps show: flood extent, water depth, number 
of  inhabitants,  type  of  economic  activity  and  industrial  installation  covered  by  the  Industrial 
Emissions Directive. The maps equally show the potentially affected protected areas, except for the 
single potentially impacted recreational water body (on the Moselle River). Luxembourg has produced 
maps for two additional APSFRs designated in the second PFRA. 

11 http://eau.geoportail.lu/ 

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In terms of changes in the way in which information about the maps is conveyed to the public,  overall, 
there has been an improvement compared to the previous cycle, this includes:  (a) a separate section 
on the geoportal which allows visualisation of all water courses designated as APSFRs, (b) the Hazard 
maps  include  areas  of  potential  flooding  not  directly  linked  to  the  river,  but  due  to  pressurised 
groundwater from a nearby flooded river, (c) Hazard maps show mobile flood protection and areas 
flooded if this protection fails. 

For the first FHRMs, the Commission pointed to the need to include more details on the methodologies 
used to prepare flood hazard maps.  The preparation of the first FHRMs was based on INTERREG 
projects whereas Moselle River mapping is based on the German Federal working group on water 
(LAWA)12. A brief summary was provided in the second PFRA for the LAWA method13 14. 

As regards the consideration of climate change effects in the preparation of flood hazard and risk 
maps, reference is made to section 3.7 on ‘adaptation to climate change’. 

7.2 Flood risk management plans 

Objectives and measures 

On the Luxembourg government’s website dedicated to water management15 there is no section for 
flood risk management, and the FRMP is only found via webpages on EU Directives16. Luxembourg 
set  four  objectives  in  its  second  FRMP  which  are  the  same  as  in  the  previous  cycle  but  more 
elaborated: i) reducing the impact of flood, ii) reducing flood risks via prevention actions, such as early 
warning  systems,  evacuation  plans  and  public  awareness;  iii)  recovery  and  iv)  review  actions, 
including the development of new strategies to address risks.  

Such objectives do not refer to the  types of adverse consequences to be  addressed. Luxembourg 
reported 313 measures which include former measures and new ones. It also established a level of 
priority for each measure: 25 % were reported as high priority, 39 % as moderate and 36 % as low. 
To be noted that no measures were reported as very high priority or critical. The FRMP describes the 
approach used to establish the prioritisation of the measures. To measure progress in implementation 
of the measures, Luxembourg has set up a database or a type of scoreboard showing the level of 
progress in implementation (from proposed, to under implementation, to implemented). 

As regards funding, the second FRMP does not provide information on the costs of the measures, but 
specific funding sources are included. According to the FRMP17, flood protection measures are financed 
by  the  municipalities  or  by  municipal  special  purpose  associations,  which  are  entitled  to  state 
subsidies. Subsidies are provided via the national government’s fund for water management (Fonds 
pour la gestion de l’eau, FGE). 

12 https://www.lawa.de/ 
13 Luxembourg has subsequently clarified that “There have been updates on the land use data (from Corine to the 
national Land Use Database, which has a higher Resolution) and changes were made on the presentation (see Legend) of 
the maps. Of course, the data has been updated.” 
14 Section 2.6. in https://eau.gouvernement.lu/dam-
assets/administration/documents/projekthochwasserkaarten2021/hwrmp2021/Entwurf-
Hochwasserrisikomanagementplan-2021-2027.pdf 
15 https://eau.gouvernement.lu/de.html and https://eau.gouvernement.lu/fr.html 
16 https://eau.gouvernement.lu/fr/administration/directives/directiveinondation/2ieme-cycle.html      
17 Chapter 7.7. 

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The plan mentions that a Cost Benefit Analysis is required for structural measures. 

As regards the integration with the WFD, it is mentioned that coordination with the WFD takes place 
at  several  levels,  including  between  authorities  and the  environmental  objectives  of  the WFD  are 
considered in the implementation of FRMP measures. Indeed, Luxembourg reported WFD measures 
as part of the FRMP.  

The  FRMP  describes  how nature  conservation  aspects,  particularly  Natura  2000  sites,  need  to  be 
considered when implementing measures.  The plan also includes natural water retention measures 
(NWRMs), for instance to preserve natural floodplains.  

Luxembourg reported 19 prevention measures (all in the Rhine UoM) and 142 protection measures 
(most in the Rhine UoM). One of the objectives includes a call for the development of early warning 
systems. Luxembourg reported 24 preparedness measures (23 in the Rhine UoM, one in the Meuse 
UoM). There is a type of measure called ‘local flood risk management concept’, which contains several 
spatial planning/land use measures. 

There is progress in linking measures to the objectives, which is clearly presented in the second FRMP. 
While the second FRMP states that its development involved an assessment of the progress towards 
the  objectives  of  the  first FRMP18,  a  description  of  the  results  of  this  assessment  was  not  found. 
However, the plan provides some information on the progress in the implementation of the measures 
under the first FRMP, including a table19 with the number of measures implemented under the first 
FRMP. A description on the progress in implementation of measures under the first FRMP is provided 
but it appears that in early 2021, a majority of the measures under the first FRMP had not been 
started.  

Governance 

The FRMP provides information on coordination at the FHRM stage, via the International Commissions 
to protect Moselle and Saar (IKSMS). No links are provided to international FRMPs, such as those for 
the international Meuse and Rhine basins. 

The FRMP was published on the websites of the AGE and the Ministry of the Environment, Climate 
and  Sustainable  Development,  as  well  as  on  the  national  portal  for  participation  procedures.  The 
public hearing lasted three months for individuals, with municipalities given an additional month20. 
The  Minister  for  the  Environment  also  invited  people  to  a  public  video  conference.  It  is  said  that 
stakeholders are also involved via local flood partnerships, but no more details are provided.  

Consideration of climate change 

As regards the consideration of climate change effects in the preparation of flood risk management 
plans, reference is made to section 3.7 on ‘adaptation to climate change’. 

18 Chapter 1.2. 
19 Chapter 4.3.1 FRMP. 
20 Article 56 Luxembourg Water Law sets out the modalities of this consultation. 

32 

 
 
 
 
Progress identified in the second FRMPs 

The objectives in the second FRMP are more specific, and there is a clear link between measures and 
objectives, but they are not measurable. For some objectives, the type of measures and number of 
actions are mentioned. Moreover, a damage potential study was commissioned based on the FHRMs, 
which identified the potential monetary damage. In addition, specific funding sources are included 
now. The second FRMP and Luxembourg’s reporting also provide information on the prioritisation of 
individual measures. In other areas of progress, the FRMP’s list of new and adapted measures to be 
implemented identifies the responsibilities of authorities, which was not the case in the first FRMP. 
Some progress was seen in estimating potential damage, which could provide the basis for future 
Cost  Benefit  Analysis  for  structural  measures.  The  second  FRMP  describes  coordination  with  the 
National Climate Change Adaptation Strategy 2018-2027 and links measures between the two. 

8. FD recommendations 

On  the  basis  of  the  assessment  performed,  in  addition  to  the  good  progress  on  a  number  of  points, 
Luxembourg should:  

1.  As regards the Flood Hazard and Flood Risk Maps 

• 

• 

• 

• 

provide more details on the methodologies employed to prepare them; 

include the consideration of  pluvial flooding and consider climate change; 

display  bodies  of  water  designated  as  recreational  waters,  including  areas  designated  as  bathing 

waters under Directive 76/160/EEC potentially impacted by flooding; 

provide detail on how the FHRM was used in the choice of objectives and measures; 

2.  As regards the Flood Risk Management Plans 

•  make objectives specific and where possible linked to quantitative indicators and be timebound.  An 

assessment of the progress made towards the achievement of the objectives should be included; 

• 

• 

provide information on the costs of all measures 

offset out the method to monitor the implementation of the measures; 

•  where  relevant,  incorporate  CBA  for  the  prioritisation  of  measures  that  lend  themselves  to  it  and 

• 

• 

provide a clear description of the methodology used; 

base the likely impact of climate change also on future climate scenarios; 

provide more detail on the public consultation, especially the comments received, and how they were 

taken into account; 

•  where appropriate, consider in the FHRM flow velocity or relevant water flow and in the FRMP flood 

conveyance routes, as these are relevant to emergency response. 

• 

33