COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans Member State: Belgium 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: Belgium, 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) 16 final  COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans  Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans Member State: Belgium   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) 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} - {SWD(2025) 35 final}  
 
 
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Country specific staff working document 

Belgium 

ENVIRONMENT 

 
 
 
 
 
 
 
 
Content 

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

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

1. General info, Member State characterisation ............................................................................................................. 4 

2. Horizontal aspects ...................................................................................................................................................................... 8 

2.1 Governance ............................................................................................................................................................................ 8 

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

3. Policy elements contributing to biodiversity and climate change adaptation ...................................... 10 

3.1 Surface Water: what is their ecological status or potential .................................................................... 10 

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

3.3 Groundwater bodies - have they sufficient water – quantitative status ......................................... 13 

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 Belgium is doing for abstractions and water scarcity ................................................................... 16 

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 .................................................................................... 23 

4.3 What Belgium is doing to combat pollution from agriculture ............................................................... 24 

4.4 What Belgium is doing to combat pollution from other sectors .......................................................... 26 

4.5  What  Belgium  is  doing  to  combat  significant  pressures  –  overall  assessment  of  the 
Programmes of Measures .................................................................................................................................................. 27 

5. Exemptions and economics ............................................................................................................................................... 29 

5.1 To what extent are exemptions applied in Belgium .................................................................................... 29 

5.2 Use of economic analysis and water pricing – cost recovery ................................................................ 31 

6. WFD recommendations ........................................................................................................................................................ 33 

SECTION B: FLOODS DIRECTIVE .................................................................................................................................................. 36 

7. Flood risk management under floods directive (FD) ............................................................................................ 37 

7.1 Flood hazard and risk maps ...................................................................................................................................... 37 

7.2 Flood risk management plans .................................................................................................................................. 37 

8. FD recommendations ............................................................................................................................................................ 40 

2 

 
 
 
SECTION A: 
WATER FRAMEWORK 
DIRECTIVE 

3 

 
 
 
1. General info, Member State characterisation

Belgium consists of a coastal plain, a central plateau and the Ardennes upland area in the south east 
of the country. The highest point is Signal de Botrange at 694m. It is a very densely populated country 
with a population of 11,5 million with a density of about 380 persons per km2, more than three 
times the EU average, and it is slightly increasing. Belgium has one single coastal water body and 
the two most important  River  Basins  are  the  Meuse  in  the  east  and  the  Scheldt in the  west.  The 
rainfed RBD Meuse is dominated by the old medium mountain range of the Ardennes, characterized 
by dark impermeable schists and sharp valleys. The Scheldt is a rainfed lowland river and has a long 
history of industrialisation and agriculture on the fertile floodplains.  Flanders has a flat relief with 
lowland rivers with small flow rates and significant drainage and has a part of coast neighbouring 
with the North Sea. Wallonia features a much more complex mosaic landscape of valleys and hills. 
Given  the  distribution  of  competences,  the  management  of  the  water  bodies  is  quite 
compartmentalised.  The  pressures  in  different  parts  of  the  country  are  similar  but  their  intensity 
varies  considerably.  Indeed,  the  population  density  in  Flanders  is  more  than  twice  the  density  in 
Wallonia.  Belgium’s  main  challenges  relate  to  massive  pressures  from  agriculture  (nitrates  and 
pesticides  pollution),  dense  population  (land  use  and  wastewater  discharges)  and  related 
hydromorphological pressures. Legacy pollution and transboundary pollution cause specific problems. 

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 

4 

 
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 Belgium have not submitted full electronic reporting, but data for majority of 
RBDs were available. Therefore, the assessment is based on the dataset available at that time and 
the missing RBDs are based on the data mining of the pdf RBMPs. 

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 
(560) 

Trend (% good 
status/potential) 

100%

ECOLOGICAL 
STATUS 

50%

26,2% 27,4%

2015 2021

0%

100%

CHEMICAL 
STATUS 

50%

2,2% 0,0%

2015

2021

0%

Main Pressures & Changes & Exemptions 

The ecological status/potential of SWBs has slightly improved. 
Only 27,4% of water bodies are in good or better status/potential. Most of these are in Wallonia (43%), whereas Flanders only has 0,5%. All 
three Brussels’ water bodies are below good potential, the North Sea coastal water body is in moderate status. General confidence in status 
assessment has decreased. 
The monitoring coverage of quality elements, especially biological quality elements, appears to have decreased. 
Main challenges relate to massive pressures from agriculture (nitrates and pesticides pollution), dense population (land use and wastewater 
discharges), and hydromorphological pressures. Legacy pollution and transboundary pollution are also a problem. 
Hydromorphological quality elements are not frequently used for status assessment.   
Exemptions: 
172 SWBs (31 % of total SWBs) are exempted under Article 4(4) on the grounds of technical feasibility, 281 (50 % of total SWBs) on the 
grounds of disproportionate costs and 340 (61 % of total SWBs) on the grounds of natural conditions. 

All SWBs are in poor chemical status in Belgium. 
The large majority are classified with high confidence. There are no longer water bodies in unknown status.  
The priority substances added to the EQSD in 2013 are included in the monitoring network in both Flanders and Wallonia; they also seem to 
contribute to chemical status assessment, although this is only required as from December 2027.  
The main reason for failing to achieve a good status is due to uPBT substances: in Flanders, these are mainly mercury, PFOS, and heptachlor, 
in Wallonia, mainly mercury and PBDEs. Non-uPBT substances causing poor chemical status are largely metals (lead, cadmium, and nickel) 
along with industrial chemicals (nonyl-phenol and DEHP). The expectation is that by 2027, there will still be less than 5% SWBs in good 
chemical status.  
managementExemptions: 
200 SWBs (36 % of total SWBs) are exempted under Article 4(4) on the grounds of technical feasibility, 200 (36 % of total SWBs) on the 
grounds of disproportionate costs and 208 (37 % of total SWBs) on the grounds of natural conditions.  No exemptions under Article 4(5) WFD.  

6 

 
 
 
 
Ground 
Water 
Bodies (81) 

Trend (% good 
status/potential) 

100%

QUANTITATIVE 
STATUS 

50%

90,0% 87,7%

2015 2021

0%

100%

Main Pressures & Changes & Exemptions 

There has been a slight decrease of GWBs in good quantitative status.  
10 out of 81 GWBs are in poor quantitative status, 9 of which are in Flanders. 71 GWBs are in good quantitative status. 
There is a lack of consideration of Groundwater Associated Aquatic Ecosystems (GWAAEs) in all RBDS and a lack of consideration of 
Groundwater Dependent Terrestrial Ecosystems (GWDTEs) and of saline or other intrusions in the Brussels RBD. 
Water abstraction is identified as a significant, and increasing, pressure. As a result, 40 ouf of 81 GWBs (majority in Flanders) have been 
identified as at risk of failing to achieve good quantitative status by 2027 (49.4 % of total GWBs). 

Exemptions: 3 GWBs (4 % of total GWBs) are exempted under Article 4(4) on the grounds of technical feasibility and 7 (9 % of total GWBs) 
on the grounds of natural conditions.  The electronic reporting identifies 3 GWBs as being subject to a temporary deterioration under Article 
4(6) for quantitative status (in the Scheldt RBD (Flanders). This is based on natural conditions and force majeure. No exemptions under 
Article 4(5) WFD. 

There has been an increase of GWBs in good chemical status. 
Impacts on GWAAEs have not been considered for chemical status assessment except in the Brussels RBMP.  
Bad chemical status is mainly due to non compliance with quality standards. Other reasons are the failure to achieve environmental 
objectives in associated surface water bodies or significant diminution of the ecological or chemical status of such surface water bodies, 
and significant damage to terrestrial ecosystems which depend directly on the groundwater body. 

CHEMICAL 
STATUS 

50%

53,1%

41,3%

0%

2015 2021

For Flanders, the top five pollutants causing failure to achieve good chemical status are nitrate, potassium, pesticides, N,N-
dimethylsulfamide and bentazone. For Wallonia, failures are mainly due to nitrate, phosphate, and pesticides, which are all associated with 
agricultural activities.  
According to the electronic reporting (covering all RBDs), there are 47 GWBs (58% of total GWBs) at risk of failing to achieve good chemical 
status by 2027.  
Exemptions: 
5 GWBs (6 % of total GWBs) are exempted under Article 4(4) on the grounds of technical feasibility, 33 (40 % of total GWBs) on the grounds 
of disproportionate costs and 38 (47 % of total GWBs) on the grounds of natural conditions. 

7 

 
 
 
 
 
 
2. Horizontal aspects 

2.1 Governance 

Belgium is a federal state which has delegated competences with regard to water policy to the three 
regions, i.e. Brussels region, Flanders and Wallonia. This translates into a quite compartmentalised 
management of its water bodies. Belgium has one single coastal RBD (North Sea) under the Federal 
state and the two most important River Basins are the Meuse in the east and the Scheldt in the west. 
The three regions of Belgium manage different parts of these rivers. Belgium has eight River Basin 
Districts (RBDs), some of which cover the same River Basin: the Scheldt River Basin is divided into 
the  ‘Noordzee’  Federal  RBD,  the  Flemish  Scheldt  RBD,  the  Brussels  Scheldt  RBD  and  the  Walloon 
Scheldt RBD. The Meuse River Basin encompasses the Flemish ‘Maas RBD’ and the Walloon ‘Meuse’ 
RBD. Wallonia manages two others much smaller RBDs, i.e. the Rhine and Seine RBDs. Despite this 
complex governance, there is cooperation among regions through the Steering Group on Water in the 
Coordination  Committee  for  International  Environmental  Policy  (CCIEP).  Formal  coordination  also 
takes place within international RBD commissions, and bilateral consultations are held at regional 
and local level. 

There are four RBMPs: one covering the North Sea – Scheldt RBD, one covering both Flemish RBDs 
(Scheldt and Maas), one covering all four Walloon RBDs (Scheldt, Meuse, Rhine and Seine) and one 
covering the Brussels Scheldt RBD.  

It is noted positively that there is a good integration between the RBMPs and Flood Risk Management 
Plans under the Floods Directive (FD) and the North Sea RBMP is coordinated with plans under the 
Marine  Strategy  Framework  Directive  (MSFD),  through  streamlined  objectives,  joint  plans1  and 
combined monitoring. 

The public and stakeholders were actively engaged and consulted on draft RBMPs and continue to be 
involved in their implementation. In Flanders and Brussels, ‘co-creation’ workshops have been set up 
to  define measures,  especially  on  urban  resilience, water  pricing,  water in  the  urban  environment 
(citizens and professional participation). Reporting took place between July 2022 and July 2023. 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 legal obligations, others 
reported the plans in pdf format. The cut-off date for taking into account the WISE electronic reporting 
was September 2023. By that time, only Flanders, Brussels and the North Sea RBDs had finalised 
their electronic reporting. Therefore, the assessment of the latter RBDs is based on both pdfs and 
electronic reporting datasets, whereas for the four Wallonia RBDs, the assessment is based on data 
mining of the pdf RBMP. 

Transboundary cooperation 

As it is the case for its neighbour, the Netherlands, all the RBDs are international. This means that 
the state of water bodies in those river basins depend partly on the decisions taken by other Member 
States.  Only  for  the  Scheldt,  Meuse  and  Rhine,  international  agreements  and  international 

1 see in particular as regards programs of measures, chapter 6 of the North Sea RBMP: 
stroomgebiedsbeheerplan_voor_de_kustwateren_iii_2022-2027.pdf 

8 

 
 
cooperation  bodies  are  in  place  also  elaborating  an  International  River  Basin  Management  Plan, 
whereas for the Seine RBD, cooperation is informal. 

2.2 Characterization of River Basin District 

The two most important RBD’s in Belgium are the Meuse in the east and the Scheldt in the west. The 
rainfed RBD Meuse is dominated by the old medium mountain range of the Ardennes, characterized 
by dark impermeable schists and sharp valleys. The Scheldt is a rainfed lowland river and has a long 
history of industrialisation and agriculture on the fertile floodplains. 

Belgium (all RBDs included) has delineated 560 surface water bodies and 81 groundwater bodies in 
its 3rd RBMPs There are 180 heavily modified surface water bodies (32%) and 79 artificial surface 
water bodies (14%). For national water body types where an intercalibration type was reported, there 
are 41 river types, 4 lake types (0 in Wallonia), 1 coastal type and 3 transitional types.  

To benchmark and determine the status of water bodies, boundary values (reference conditions) are 
set for the high/good and good/moderate status classes. Good ecological status of water bodies is 
established by  comparing monitoring data to these two boundary values. It is  very  welcome that 
Belgium  has  established  reference  conditions  for  all  natural  surface  water  body  types  for  all 
biological and physico-chemical quality elements. These are coordinated with those in neighbouring 
Member  States.  However,  reference  conditions  for  hydromorphological  quality  elements  are  still 
missing for some river, lake and transitional water body types. 

Table 1: Number of water bodies of rivers, lakes, coastal waters, territorial waters and groundwaters  

Number of bodies 

River 
water 

Lake 
water 

Transitio
nal 
water 

Coastal 
water 

Territori
al water 

Ground 
water 

0 

0 

0 

0 

0 

7 

0 

0 

7 

0 

0 

0 

0 

0 

0 

0 

1 

1 

0 

0 

0 

0 

0 

0 

0 

1 

1 

11 

5 

10 

21 

2 

32 

0 

0 

81 

2021 

BEESCAUT_RW 

2021 

BEESCAUT_SCHELDE_BR 

2021 

BEMAAS_VL 

2021 

BEMEUSE_RW 

2021 

BERHIN_RW 

2021 

BESCHELDE_VL 

2021 

BESEINE_RW 

2021 

BENOORDZEE_FED 

2021 

Total 

Source: WISE electronic reporting  

Pressures and impacts 

77 

3 

17 

257 

16 

161 

2 

0 

533 

0 

0 

3 

0 

0 

15 

0 

0 

18 

9 

 
  
 
As  required  by  the  law,  the  RBMPs  establish  the  main  pressures  impacting  their  water  bodies.  In 
general,  industry,  heavy  freight  and  passenger  traffic,  intensive  livestock  production  and  crop 
cultivation exert significant pressures on the Belgian environment. 

Surface waters 

In  Flanders  and  Brussels,  the  most  important  pressures  are  diffuse  pressures  from  atmospheric 
deposition, historical pollution, agriculture, and discharges not connected to the sewerage network 
and stormwater overflows. Flood protection and agriculture cause pressures on hydromorphology. 

As shown in the below figure, agriculture is the biggest source of nitrogen deposition in Flanders: has 
the EU's second-highest livestock density, after the Netherlands, and the EU's highest pig density 
(75% of pork is exported). 

In  Wallonia,  the  pressures  affecting  most  surface  water  bodies  are  from  discharges  from  urban 
wastewater treatment plants and industrial activities. 

Another pressure comes from the negative impact of invasive alien species (IAS) which is especially 
severe in aquatic ecosystems and alien crayfish species are one of the most destructive invasions 
known to date, locally depleting resources in aquatic environments and changing the fauna and flora 
of ponds and rivers. 

Figure 1: showing the trophic status of surface waters in Flanders    

Source:  Joint  Research  Center  of  European  Commission  (n.d.).  JRC  NITRATES  DIRECTIVE  -  Reporting  Period 7  (2016-
2019) 
at: 
water.jrc.ec.europa.eu. 
https://water.jrc.ec.europa.eu/portal/apps/dashboards/cb6034c2a75e4df282f8a62f90c16caa   

Available 

[online] 

Trophic 

Status. 

Groundwaters  

In Wallonia, the pressures affecting most groundwater bodies are abstraction for public water supply 
and alteration of water level or volume (due to quarry drainage). The highest impact on groundwater 
comes from nutrient pollution closely followed by chemical pollution (pesticides). 

10 

 
 
In Flanders, the highest pressures come from abstractions for agriculture, industry and public water 
supply. The impacts affecting the highest percentage of water bodies are water balance and diffuse 
pressures from agriculture. 

In  the  North  Sea,  most  pressures  come  from  nutrient  pollution  from  agriculture  (nitrates  and 
phosphates) and to some extent point source industrial pollution from upstream. 

3. Policy elements contributing to biodiversity and 

climate change adaptation 

3.1 Surface Water: what is their ecological status or potential 

Monitoring 

There are two types of monitoring: i) operational monitoring to determine the status and which covers 
all water bodies at risk and ii) surveillance monitoring aimed rather at identifying impacts and long-
term changes. 

In  Flanders,  there  are  203  surface  water  bodies  covered  by  493  operational  and  56  surveillance 
monitoring sites. In Wallonia, there are 352 surface water bodies covered by 384 monitoring sites. 
For the North Sea RBD, monitoring sites have been selected to take into account the anthropogenic 
gradient  in  the  coastal  zone  caused  by  the  Scheldt  estuary.  Biological,  hydromorphological  and 
general physico-chemical quality elements are monitored in each water category. There is however 
a general decrease in monitoring coverage across most quality elements, especially biological quality 
elements. It is welcomed that for all RBDs, monitoring frequencies follow the recommendations of 
the WFD. 

Regrettably, not all quality elements are monitored as they should and the following gaps have been 
identified:  

•  hydromorphological quality elements: only morphological conditions are monitored, and only 

• 

in rivers, transitional and coastal water bodies; 
the general physico-chemical quality elements: ‘transparency’ and ‘thermal conditions’ are 
not monitored in lakes and transitional waters and only in 0.6 % of river water bodies. 

However, it is noted positively that the specific physico-chemical quality elements, i.e. the so-called 
‘river basin specific pollutants’ (RBSPs), are monitored in all water categories. 

Belgium is  using  grouping  for  the  assessment  of  ecological  status/potential,  i.e.  extrapolating the 
information from one water body to other water bodies subject to similar pressures. Expert judgment 
is almost no longer used for status assessment. 

Status assessment 

11 

 
Figure  2:  Ecological  status  or  potential  of  surface  water  bodies  (SWBs)  in  Belgium  the  1st,  2nd  and  3rd 
RBMPs   

Source: WISE electronic reporting 

While it is welcomed that some improvement can be seen compared to the previous cycle, moving 
from poor or bad ecological status/potential in the 2nd RBMPs to moderate ecological status/potential 
in the 3rd RBMPs, it is not good enough to make water bodies flip from bad to good. Thus, it must be 
stressed  that  only  27,4%  of  water  bodies  are  in  high/maximum  or  good  status/potential.  This  is 
because,  as  required  by  the  WFD,  if  one  parameter  is  beyond  the  allowed  limit,  the  status  is 
considered bad (the ‘one out all out’ principle or in other words the status is determined by the quality 
of the elements in the lowest class). That means that even if the status is improving from bad to 
poor or from poor to moderate, this will not be reflected in the classification of the water body which 
would still not be ‘good’. Thus, for Belgium this means there is only a small change of overall status 
between the 3 cycles.  

The differences between regions are striking. Most of the water bodies in good status are located in 
Wallonia (44%), whereas Flanders only has 0,5%. All three Brussels water bodies are below good 
potential, the North Sea coastal water body is in moderate status. 

Only about 20% of water bodies comply with the environmental quality standards set for the ‘river 
basin specific pollutants’ (RBSPs), which are the compounds for which the country considers there is 
a  local  problem,  and  which  form  part  of  its  ecological  status/potential.  In  Flanders,  the  most 
problematic RBSPs are: kobalt (52%), uranium, diflufenican, arsenic, flufanecet (14%) (metals and 
pesticides). The North Sea RBMP reports that the specific pollutants for the Scheldt region are copper, 
zinc and polychlorinated biphenyls (PCBs). Brussels has reported zinc, pCB's, acenaphtene and pyrene 
as the 4 RBSPs used for classification of ecological status. For Wallonia, the most problematic RBSPs 
are pesticides (linuron, dichloroaniline) as well as vinylchloride, cyanide, arsenic. 

In  Flanders,  impacts  from  nitrates  and  phosphates  coming  from  urban  settlements  have  been 
reduced  thanks  to  improved  urban  wastewater  treatment  and  reduced  discharges  from  industry. 
Unfortunately, the same cannot be  said as regards the nutrient pollution from agriculture. In this 

12 

 
 
context, it is worth noting the relatively low share (approximately 7%) of total agricultural area used 
for organic farming2. Moreover, some general physico-chemical quality elements have worsened e.g., 
salinity and thermal conditions, most likely also as a result of dry and hot summers in 2018 and 
2019. 

It is welcomed that the overall knowledge of the state of the water bodies has improved throughout 
the  cycles  and  the  number  of  unknowns  has  steadily  decreased.  However,  oddly  enough  the 
confidence in the classification has worsened between the 2nd and the 3rd RBMPs, since in the 3rd 
RBMPs, only moderate, poor, and bad classifications are classified with high confidence. 

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) 

The level of human intervention in Belgian water bodies is very important, affecting approximately 
45% of all surface water bodies in Belgium and it has increased compared to the 2nd RBMPs.  179 
water bodies (32.1 %) are designated as heavily modified (against 31.9 % in the 2nd RBMPs) and 79 
(14.2 %) as artificial (against 13% in the 2nd RBMPs). Here again the differences between the regions 
are considerable. In Brussels, which is roughly an urban area, the case is extreme as 2 out of 3 river 
water bodies are heavily modified and the third one is artificial. In Wallonia, 72 water bodies (20.5 
%) are heavily modified and 16 artificial (4.5 %). In Flanders, 106 water bodies are designated as 
heavily modified (52%) and 62 as artificial (31 %).  

As regards the methodology for heavily modified water bodies’ designation, prepared per region (yet 
coordinated), there have been no changes since the 2nd RBMPs.  

Information is provided on 1) criteria for the identification of significant adverse effects of restoration 
measures on the use and the wider environment (e.g. navigation class for waterways or importance 
of land for agriculture in the case of floodplains), as well as on 2) the types of physical alterations 
(e.g.,  channelisation,  straightening,  bed  stabilisation,  bank  reinforcement,  dredging,  channel 
maintenance) and 3) the water uses which are considered for the designation of heavily modified 
water bodies (e.g., agriculture, flood protection, navigation, water supply and hydropower).  

No  information  could  be  found  in  the  3rd  RBMPs  as  to  whether  it  was  checked  if  the  beneficial 
objectives served by the modifications of the heavily modified water bodies could be achieved by 
other environmentally better means. However, this information may have been provided in earlier 
RBMPs. 

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

13 

 
 
 
 
Defining Good Ecological Potential 

According to the WFD, and given their very man-made characteristics, the HMWBs and AWBs must 
only meet the objective of good ecological potential (GEP) rather than good ecological status (GES). 
In the Flanders and Brussels RBDs, GEP is defined in terms of biology for rivers, lakes and transitional 
waters,  taking  as  a  reference  similar  natural  water  bodies  but  excluding  elements/indicators  for 
pressures  that  cannot  be  reversed  without  significant  adverse  effects  on  water  use  and  wider 
environment (the ‘reference approach’). In Wallonia, no methodology could be identified but it is likely 
therefore to be the same as that reported in the 2nd RBMPs, i.e. the ‘mitigation measures’ approach, 
i.e.  starting  from  all  relevant  and  ecologically  effective  measures  that  do  not  have  a  significant 
adverse effect on use or wider environment, and then excluding those measures that are predicted 
to deliver only slight ecological improvement. GEP is then defined as the biological values that are 
expected from implementing the remaining identified mitigation measures. 

3.3 Groundwater bodies - have they sufficient water – quantitative status 

In this cycle, 10 GWBs out of a total of 81 (i.e. 12.3 % of total GWBs) are assessed in poor quantitative 
status due to abstractions. Here again the differences between regions are very pronounced, 9 are in 
Flanders (Scheldt RBD) and one in the Wallonia (Scheldt RBD). 

It is worth noting that 5% GWBs are also affected by saline or other intrusions from anthropogenically 
induced sustained changes in flow direction. The Walloon aquifer has recently deteriorated due to 
increased abstractions in Belgium and France to address water shortage as a result of droughts. 

Because  groundwater  levels  are  important  for  Groundwater  Associated  Aquatic  Ecosystems 
(GWAAEs),  the  status  of  the  latter  should  be  considered  for  quantitative  status  assessment,  in 
accordance with Annex V, point 2.1.2. WFD. However, this has not been the case in any RBD3. The 
same  applies  for  Groundwater  dependent  Terrestrial  Ecosystems  (GWTEs)  and  saline  or  other 
intrusions. These have been considered in most RBDs, but however not in the Brussels RBD. 

Even if not necessarily resulting in bad quantitative status, water abstraction is still considered a 
significant pressure in 35 out of 42 GWBs in Flanders, in all 5 GWBs in Brussels and in 5 out of 34 
GWBs in Wallonia. This means the long term annual average rate of abstraction exceeds the available 
groundwater resource, mainly due to energy, industry, public water supply and agriculture.  

3 although in Flanders they are indirectly considered through the consideration of surface water as a boundary condition 
for the assessment of water balances 

14 

 
 
Figure 3: Quantitative status of groundwater bodies (GWBs) in Belgium in the 1st, 2nd and 3rd RBMPs 

Source: WISE electronic reporting 

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

There are different reasons why certain water bodies are protected under specific law. Belgium has 
identified protected areas associated with water bodies in the context of the Bathing Water Directive 
(bathing waters), the Drinking Water Directive (drinking water protected areas), the Birds and Habitats 
Directives  (Natura  2000  areas),  the  Nitrates  Directive  (nitrate  vulnerable  zones)  and  the  Urban 
Wastewater Treatment Directive (nutrient sensitive areas). No Shellfish protected areas have been 
identified in Belgium. The whole of Flanders and 57% of Wallonia are designated nitrate vulnerable 
zones and the whole of Wallonia and Brussels are designated nutrient sensitive area. 

Currently, 14.7% of terrestrial area of Belgium is designated as protected areas4, falling below the 
EU value of 26.4%. However, with a coverage of 37.79% in its marine waters5, Belgium surpasses 
the EU value of 12.1%. 

Table 2: Number of water bodies associated with protected areas 

Protected area type 

Number of water bodies associated with protected areas 

Rivers 

Lakes 

Coastal 

Transitional 

Groundwater 

Bathing waters 

Drinking water protection 
area 

35  

4 

2 

24 

4 Biodiversity Information System for Europe Protected Areas (europa.eu) 
5 Wise Marine water infromation system Belgium (europa.eu) 

15 

 
 
 
 
 
 
 
 
 
Drinking water protected 
area Wallonia RBDs 

3 

5 

Natura 2000 protected site  81 

1 

3 

Natura 2000 Wallonia 

Natura 2000: 240 sites covering 13% of Wallonia 

Nutrient sensitive area 

3 

Nutrient sensitive area 
Wallonia 

All Wallonia 

Nitrate vulnerable zone 

Nitrate vulnerable zone 
Wallonia 

8 zones covering 57% of Wallonia  

29 

1 

1 

Source: WISE electronic reporting for Flanders, Brussels and North Sea RBDs and background documents for Wallonia  

Additional monitoring is applied for drinking water protection zones, in accordance with the law. There 
are also specific monitoring sites in relation to Natura 2000 protected areas and bathing waters, as 
well as for nutrient and nitrate vulnerable zones.  

Additional objectives for protected areas have been set in all RBMPs but regrettably not for all water 
bodies associated with protected areas. It is noted with concern that these objectives have not been 
consistently met. This is particularly relevant for Natura 2000 areas which require good water quality 
for specific protected species, including enough flow diversity, depth variation, sedimentation, removal 
of fish migration barriers. 

Additional measures have been planned in all RBMPs for Natura 2000 sites and for drinking water 
protection areas: this includes for instance developing specific standards for surface water quality in 
(the vicinity of) special protection areas with surface water-dependent habitats and species (including 
sufficient  flow  diversity,  depth,  sedimentation,  removal  of  barriers).  Another  important  measure 
consists  in  combating  invasive  alien  species  such  as  crayfish.  For  drinking  water,  measures  may 
consist  in  the  establishment  of  drinking  water  safeguard  zones:  these  include  the  surface  water 
bodies  themselves  but  also  the  plots  of  land  draining  into  these  surface  water  bodies.  For 
groundwater, this may  also  imply  restrictions  on  use  of  surface  and  below  ground  to  protect  the 
quality of the groundwater that is being pumped. 

3.5 What is being done to prevent/reduce hydromorphological pressures 

In Flanders, significant hydromorphological pressures include flood protection, agriculture, navigation, 
and  hydropower.  In  Wallonia,  hydromorphological  pressures  are  mostly  associated  with  barriers 
preventing  fish  migration  (40  major  barriers  are  identified  in  navigable  water  bodies  and  1  484 
barriers  in  non-navigable  water  bodies).  Hydropower  is  also  an  important  pressure,  with  21 
hydropower stations located in navigable water bodies and 131 in non-navigable water bodies.  

This results in  hydrological  alteration, physical  alteration of channel, bed, riparian area and shore 
(Flanders); presence of dams, barriers and locks (Flanders and Wallonia); and physical loss of whole 
or part of the water body (Flanders and Wallonia). 

16 

 
 
 
 
 
 
 
 
 
 
 
 
Basic  measures  include  permitting  and  general  control  regimes,  in  accordance  with  the  WFD.  In 
Flanders,  a  detailed  guidance  document6  describes  the  procedures7  to  be  applied  in  case  of  new 
projects  resulting  in  non-temporary  changes  to  surface  or  groundwater.  However,  these  controls 
should regularly be reviewed, so as to enable their adaptation where so required to ensure better 
protection of water bodies. In this respect, no information could be identified on the periodic review 
of water permits as required by the WFD.  

As mentioned earlier, the level of human intervention in the water bodies is quite considerable, so 
the country has embarked in some efforts to re-naturalise the water system. 

The Flanders RBMP includes following measures: fish ladders; bypass channels; habitat restoration, 
building spawning and breeding areas; sediment/debris management; removal of weirs and barriers, 
reconnection  of  meander  bends  or  side  arms;  lowering  of  riverbanks;  restoration  of  bank/bed 
structure; channel narrowing; setting of ecological flows; flood plains; dredging minimisation and/or 
modification; control of invasive alien species; research, improvement of knowledge. Measures will 
also address soil erosion and sediment loads, but not those due to land drainage. 

In  Brussels measures  include  the improvement  of the  quality  of  riverbanks  and  beds,  creation  of 
meanders and development of areas conducive to the development of aquatic fauna and flora, as 
well as the removal of obstacles to the migration of fish and setting of ecological flows8. 

In Wallonia, measures include the restoration of longitudinal continuity of water bodies (removing a 
total  of  89  obstacles  in  water  bodies  by  2027),  restoration  of  lateral  continuity  by  re-instating 
meandering in water bodies.  

It  is  noted  with  concern  that,  whilst  Flanders  has  developed  a  comprehensive  methodology  for 
defining ecological flows, the actual ecological flows still have not yet been defined. Also, it is unclear 
whether  ecological  flows  are  linked to  water  permits.  No  information  was identified  on  ecological 
flows in the Wallonia RBMPs. A mention is made of ‘reserved flows’ which are the minimum flows to 
be  guaranteed  to  support  ecological  functions  in  water  bodies  that  seem  to  be  applicable  to 
hydropower. 

Indicators on the gap to be filled for significant hydromorphological pressures by 2027 have not been 
identified in any of the RBMPs. 

All  RBMPs include  ‘win-win’  measures  to  achieve  objectives  of the WFD  and Floods  Directive  and 
address  drought  management  in  the  form  of  ‘natural  water  retention  measures’,  ‘nature-based 
solutions’ and ‘green infrastructure measures. These include nature-friendly design and management 
of shores and riverbeds; reduction of sediment supply to match the carrying capacity of the water 
system; development of space for sediments. 

3.6 What Belgium is doing for abstractions and water scarcity 

Considering the significant pressure due to abstraction in Flanders, it should report on consumptive 
uses and on the relevant estimation methods; this obligation was fulfilled through earlier reporting 
by Belgium to WISE State of the Environment (SoE)9 on Water Quantity. This includes information on 

6 https://www.integraalwaterbeleid.be/nl/publicaties/afbeeldingen/handleiding-aanvragen-adviseren-en-verlenen-van-
vergunningen-ifv-doelstellingen-kaderrichtlijn-water 
7 The Flemish authorities have indicated that it must be modified to take account of the most recent jurisprudence of the 
Court of Justice, considering that also temporary deterioration should be prohibited, unless justified in accordance with 
Article 4(7) WFD. 
8 In accordance with CIS guidance n° 31 
9 WISE-3: https://cdr.eionet.europa.eu/help/WISE_SoE/wise3  

17 

 
 
abstraction/consumption  for  agriculture,  mining  and  quarrying,  industry,  energy  (including  cooling 
water) and public water supply both from surface water and groundwater. 

Based  on  available  statistics10,  the  major  users  in  Belgium  are  (in  descending  order):  electricity 
generation  including  cooling  water,  industry,  households  and  services,  agriculture  and  mining  and 
quarrying11. 

Since 2016, increasing trends are observed in agriculture (+25.3%), mining and quarrying (+12.3%), 
households and services (+2.7%) and industry (+2.5%). This is reflected by the fact that at least 35 
GWBs in Flanders are considered at risk of failing to achieve good quantitative status by 2027. 

Measures 

Across the regions, there seems to be a good control and knowledge of the water abstractions which 
take  place.  Indeed,  in  Flanders,  all  abstractions  are  registered  and  above  a  certain  volume  a 
permitting regime applies (more than 500 m3/year for navigable surface water). It is welcome that 
in Brussels, currently the register and permitting regime applies to all abstractions, whereas in the 
previous cycle small abstractions were still exempted. In Wallonia, a register and permitting regime 
are  in  place to  control  all surface  and  groundwater abstractions  and  impoundments,  without  any 
threshold.  

As required by the law, permits are generally issued for a fixed limited period, which varies depending 
on the region.  However, in Flanders, permits for groundwater abstraction are granted for unlimited 
duration, unless the groundwater body is situated in a recovery area, in which case the permit is 
granted for 6 or 20 years. For surface water abstractions, the permits are granted for 1 year but 
automatically prolonged by payment of a fee. Permits which are granted for unlimited duration or 
automatically prolonged, should, according to the law, be at least subject to a periodic review. In all 
regions, permits can be refused or revised under specific conditions, in order to maintain or achieve 
the  environmental  objectives  in  the  RBMPs.  However,  it  is  unclear  whether  there  is  a  mandatory 
systematic review.   

Oddly, there does not seem to be an explicit link between the implementation of ecological flows and 
the controls over abstractions and impoundments. On the other hand, risks to ecological conditions 
may be considered as a ground for restricting or banning abstractions temporarily (eg during droughts 
or at the occurrence of toxic algal blooms) or permanently (eg to protect ecologically highly sensitive 
non-navigable waterways or for the protection of navigation in navigable waterways).  

Inspections  are  carried  out  to  prevent  cases  of  unauthorised  abstractions  or  violation  of  permit 
conditions. 

Basic  and  supplementary  measures  related  to  water  efficiency,  technical  measures  for  irrigation, 
industry, energy and households have been implemented in the 2nd RBMPs and additional measures 
are planned for the 3rd cycle.  

In Flanders, where water abstraction is a significant pressure, new measures are planned, including 
in the field of “Research, improvement of knowledge base reducing uncertainty” and “Adaptation to 
climate  change”.  Other  measures  aim  to  increase  water  supply  through  natural  water  retention 

10 https://ec.europa.eu/eurostat/databrowser/view/env_wat_abs__custom_8401102/default/table 
11 It should be noted however that conventional statistic abstraction data of Eurostat, EEA and OECD do not take account 
of evaporation /leakages of water stored in reservoirs further to abstractions. Leakage and evapotranspiration losses can 
however be significant in MSs with many reservoirs and/or older irrigation and distribution systems 

18 

 
 
measures / nature-based solutions (e.g. green-blue corridor through villages, cities and open spaces; 
large- and small-scale water buffers), water reuse and rainwater harvesting (eg from roofs). 

3.7 Adaptation to climate change 

The Flanders and Wallonia RBMPs prioritize measures through assessing, inter alia, the contribution 
of measures to climate mitigation and adaptation. 

At the federal level, there is a measure to restore the estuarine tidal nature (i.e. mudflats/salt marsh 
vegetation to act as a buffer against disturbance in the nutrient balance, as a result of coastal erosion 
and  disappareance/retraction  of  natural  wetlands).  Within  the  Flanders  RBMP,  multiple  measures 
refer to the 2010 National Climate Change Adaptation Strategy and the Flemish ‘Blue Deal’12, which 
is an ambitious plan to combat water scarcity and manage drought risks. First and foremost, the Blue 
Deal  aims  to  encourage  a  mindset  shift:  a  new  approach  to  water  management.  It  focuses  on 
retaining water locally wherever possible, using less water, reusing more water and tackling wasteful 
consumption e.g. by restoring groundwater resources (closed stock management), increasing water 
availability  (through,  inter  alia,  promotion  of  infiltration);  and  further  studies  and  knowledge 
development. 

The Flemish Blue Deal aims to tackle water scarcity and drought issues in a structural way, focussing 
on 1) increased climate resilience of the water system and 2) accelerated transition to economical, 
sustainable  and  circular  water  use.  It  forms  the  basis  for  the  Water  scarcity  and  Drought  Risk 
Management Plan, which is integrated into the 3rd RBMP. That plan assesses the impacts of water 
scarcity and droughts, based on climate change related drought indicators (duration and intensity of 
dry  periods).  It  shows  the first  results  of  the  drought modelling  and  gives  an overview  of  related 
economic costs for agriculture, shipping, industry. 

The Brussels and Walloon RBMPs also include an assessment of the impact of climate change on 
water status, as well as measures to address increased risks of prolonged droughts and floods. The 
Wallonia  RBMP  includes  a  comprehensive  drought  strategy,  setting  out  structural  measures  to 
address the findings of the effects of climate change and water resources, aimed at regulating water 
use  and  demands, protecting  and  enhancing  resources  and  adapting the urban,  rural  and  natural 
environment to future droughts. The North Sea RBMP assesses the main impacts of climate change 
on the coastal water body, e.g. storm related floods, coastal erosion and loss of natural wetlands. 

Flood management 

The Floods Directive requires to consider the impacts of climate change on the occurrence of floods, 
and therefore in the preparation of Flood Hazard and Risk Maps (FHRMs) and Flood Risk Management 
Plans (FRMPs). More information on these can be found in Section B. However, considering the close 
relationship  between  overall  water  management  and  floods  management  and  the  importance  of 
climate change effects on both, consideration of these effects is jointly addressed in this section.  

Consideration of climate change in the FHRMs 

Since FHRMs are based on the Preliminary Flood Risk Assessments (PFRAs), it is important to assess 
first whether the latter consider the impacts of climate change on flood risk. It appears this has been 
done in all regions in Belgium at the time of the second PFRAs; however, the different regions all took 

12 ‘Blue Deal’ 

19 

 
 
a slightly different approach. In Flanders, altered precipitation and sea level rise as a result of climate 
change  have  been  taken  into  consideration  in  the  predictions  of  flood  risks,  e.g.  the  high  impact 
scenario shows that the flood risk in Flanders will rise by a factor of 5 to 10 by 2100. In Wallonia, 
the results of the AMICE60 project to assess climate change impacts were taken into account, using 
the Holocene. Each of the four DHIs (District Hydrographique International) include a large, detailed 
chapter on climate change. The results show that a rise in flow rate of 15% can be expected in the 
period 2021-2050 and 30% in the period 2017-2100. The Brussels PFRA report only includes a short 
reference to climate change impacts; however, apart from this there is little information on the impact 
of climate change (e.g. no quantitative data). 

As regards consideration of climate change effects in the actual FHRMs, for Flanders, the FHRMs now 
include three separate climate change scenarios, i.e. one for pluvial, one for coastal and one for fluvial 
flooding. Flanders has produced maps for pluvial and coastal flooding that include climate change. 
For Wallonia, the contextual information (various map layers) included since the 1st FHRMs has not 
changed  and  climate  change  has  therefore  not  yet  been  considered  explicitly  on  the  maps  for 
Wallonia. However, the maps now include a new ‘extreme event’ scenario, implicitly and potentially 
therefore including variations due to climate change. For Brussels, there is now one specific map for 
fluvial floods, for which one climate change scenario is included (extreme scenario). Climate change 
has however not been considered in the pluvial map. 

Consideration of climate change in the FRMPs 

The Flanders FRMP states that it is generally accepted that climate change will lead to larger and 
more frequent floods from fluvial, pluvial and seawater sources. For Brussels, the Water Management 
Plan describes meteorological variables observed in recent years, highlighting the already observable 
effects of climate change and recent scientific results, with a view to extrapolating expected climate 
change over the course of this century for the Brussels Region. In Wallonia, it is expected that both 
fluvial  and pluvial floods will change under the long-term climate change scenarios. All three 2nd 
FRMPs  prioritise  addressing  the  impacts  of  climate  change  on  flood  risk  to  a  greater  extent.  For 
example, the Brussels plan makes ‘resilience to climate change’ a core element. In contrast to the 
1st FRMP, where Belgium's 2010 National Climate Change Adaptation Strategy was not mentioned 
in any plan, both Flanders and Wallonia now refer to Belgium’s 2017 National Adaptation Plan. All 
three FRMPs also describe climate impacts on flooding. 

4. Policy elements contributing to zero pollution 

4.1 Surface Water: what is their chemical status 

Monitoring 

In the Flanders’ and North Sea RBDs the scale of the monitoring network has slightly decreased for 
rivers, and remained the same for lakes, transitional and coastal/territorial waters. It is much more 
limited than for ecological status and focuses on the longer-term evolutions and less on assessments 
of (evolutions in) chemical status in individual water bodies. It is worth noting that the measurement 
results for the priority substances per water body are available in the water body fiches. Frequencies 
are in accordance with the law. All 53 chemical substances listed in Annex I of the environmental 
quality standards directive (EQSD) are monitored (including those added by Directive 2013/39/EC), 
but not in all water bodies. There are nevertheless 242 sampling sites for a total of 203 SWBs in 
Flanders. As regards long term trend monitoring of substances likely to accumulate in sediment or 

20 

 
biota, Flanders RBMP reports on monitoring in biota of only 613 out of the 20 substances likely to 
accumulate in sediment or biota.  

It  is  very  welcome  that  Flanders  has  reported  a  detailed  emission  inventory  and  fact  files  per 
substance14 documenting uses, points of release, and relevant information. This detailed information 
is  key  for  understanding  the  primary  pressures  and  sources  of  release  for  the  surface  water 
environment. 

The  four  Walloon  RBDs  comprise  384 monitoring  sites  covering  352  surface water  bodies.  All  53 
chemical substances listed in the EQSD are covered. Monitoring in biota is done where required. No 
information on use of grouping approaches or expert judgement could be identified. Frequencies are 
in accordance with the law. Sub-chapters describe major point and diffuse source emissions. 

In the Brussels RBD, 5 monitoring sites are used to assess chemical status of the three surface water 
bodies, all at risk of not achieving good status by 2027 (one currently not in good status). Monthly 
monitoring  applies  and  grouping  seems  to  be  applied  in  the  sense  that  not  all  substances  are 
monitored in all three SWBs. For substances/parameters for which emissions are relatively constant, 
monitoring only occurs 5 times per year. Monitoring in biota applies where required. 

As regards trend monitoring of substances likely to accumulate in sediment or biota, the Walloon and 
Brussels RBMPs report on monitoring in biota for 11 out of 20 substances concerned and monitoring 
in sediment of all 20 substances (once every three years, in accordance with the law). 

Belgium has reported on emissions, discharges and losses of all relevant substances in accordance 
with the EQSD. 

Status assessment 

In the two Flemish RBDs, none of the surface water bodies is in good chemical status, compared to 
93% in the 2nd RBMPs. This massive change is very largely due to a change in sampling procedures 
rather than actual deterioration. Indeed, in this cycle substances which tend to accumulate in biota, 
have been measured in biota instead of in water. Therefore, the assessments are not comparable 
between both RBMP cycles. 

If we look at the status assessment excluding the ubiquitous Persistent Bio-accumulative and Toxic 
substances (uPBTs), the situation has also not improved, since 21% surface water bodies were not 
in good chemical status in the 2nd RBMP against 29% in the 3rd RBMP. 

As not all water bodies are monitored for all substances, a system of grouping and extrapolation of 
results is applied in Flanders. This applies in particular for uPBTs, as it is presumed that exceedances 
occur in all water bodies where these are present. Hence there is no need to monitor all water bodies 
for them. However, in the presentation of the results, these ‘non monitored’ water bodies are marked 
as ‘grey’, which seems to presume their status is ‘unknown’ whereas the status should be marked as 
‘red’, i.e. failing good status. 

The most problematic substances are mercury, heptachlor and heptachlor epoxide, PFOS, brominated 
diphenyl  ethers,  Benzo(a)pyrene,  fluoranthene,  tributyltin  and  cadmium  (Maas  only),  all  exceeding 
standards in more than 50% of monitoring. 

In the Walloon and Brussels RBDs, none of the surface water bodies are in good chemical status. Yet 
if  uPBTs  are  not included,  68%  of  Walloon  water bodies  would  be  in good  chemical  status.  Most 
failures are due to uPBTs: mercury, PBDEs, PAHs and tributyltin. A number of other priority substances 

13 anthracene, Di(2-ethylhexyl)phthalate (DEHP), hexachlorocyclohexane, lead, tributyltin, and quinoxyfen 
14 Inventaris Prioritaire Stoffen (integraalwaterbeleid.be) 

21 

 
 
are  also  responsible  for  bad  chemical  status  of  32  %  of  all  surface  water  bodies,  including 
nonylphenol, lead, cadmium, nickel, DEHP and also pesticides. For Brussels, most failures are due to 
mercury, PAHs, PFOS and tributyltin and, to a lesser degree, PBDEs, dioxins and furans, heptachlor 
and hexabromocyclododecane. 

The North Sea coastal water body is also not in good chemical  status, only because of uPBTs, in 
particular mercury, PAHs and PBDEs. 

In conclusion, for all RBDs, the bulk of water bodies in poor chemical status is due to a small handful 
of chemicals, primarily uPBTs, in particular mercury. The latter is a common phenomenon in many 
Member States and has triggered a myriad of actions in the EU to act at source and prohibit its use 
in many products. A major source is however long-range transboundary air deposition coming from 
other continents. 

The expectations for 2027 are not promising: in Flanders less than 5% of all surface water bodies 
are expected to achieve good chemical status by 2027; in Wallonia close to 100 % of surface water 
bodies will remain in poor status by 2027, but 72% of all surface water bodies could reach good 
chemical status by 2027 (current 68%) if uPBTs were excluded. The same applies for Brussels, i.e. all 
3 surface water bodies are likely to remain in bad chemical status due to uPBTs. 

Figure 4: Chemical status of surface water bodies (SWBs) in Belgium in the 1st, 2nd and 3rd RBMPs 

Source: Wise electronic reporting  

22 

 
 
Figure 5: Top-10 Priority Substances causing failure to achieve good chemical status15 in surface water 
bodies in Belgium (Flanders, Brussels and North Sea RBDs)  

Source: WISE electronic reporting in Flanders, Brussels and North Sea RBDs 

Figure 6: Most problematic 10 substances taking also into account the 12 newly added priority substances 
in 201316 (Flanders, Brussels and North Sea RBDs) 

Source: WISE electronic reporting in Flanders, Brussels and North Sea RBDs 

15 Only taking into account the 33 Priority substsances (out of list of 45) for which the deadline for compliance has 
passed; for substsances 34 to 45, whilst they must be monitored, their deadline of compliance is 2027 
16 Directive 2013/39/EU amending Directive 2008/105/EC added 12 new substances i.e. numbered 34 to 45 to the priority 
substances list. For the 3rd RBMP, Member States only had the obligation to monitor them. Compliance with the 
Environmental Quality Standard values for these 12 new priority substances will be assessed in 2027. 

23 

 
 
 
 
 
 
4.2 Groundwater Bodies: what is their chemical status 

Monitoring 

All groundwater bodies in Flanders and Brussels RBDs (47 out of the total of 81 GWBs in Belgium) 
are monitored for chemical status assessment, which is a slight increase compared to the 97.5 % in 
the 2nd RBMPs. There are 66 surveillance monitoring sites and 52 operational monitoring sites. All 
relevant substances (including GWD Annex I and Annex II (Part B) substances and WFD Annex V Point 
2.4.2 core parameters subject to EU wide and national standards) are monitored.  

In Wallonia, the number of surveillance monitoring sites has reduced from 463 in the 2nd RBMP to 
397 in the 3rd RBMP.  The number of operational monitoring sites depends on sites for which one or 
more  parameters  are  of  concern,  eg  because  close  to  or  exceeding  the  quality  standard  or  the 
threshold value or because of a significant upward trend. Monitoring covers all relevant substances, 
i.e. 42 chemical substances in the 3rd RBMP compared to 29 in the 2nd RBMP, now also covering 
mercury and 12 pesticides. 

As  required  under  the  Groundwater  Directive  (Art.  5),  all  regions  apply  trend  monitoring  and  an 
assessment of environmentally significant sustained upward trends in pollutants in GWBs identified 
as being at risk. 

Status assessment 

The methodology for groundwater chemical status assessment is described in the 3rd RBMPs and 
considers general quality, impacts on drinking water protected areas and of saline or other intrusions 
in all RBDs. GWAAEs and GWDTEs have been reported for all RBDs but impacts on GWAAEs have not 
been considered for chemical status assessment except in the Brussels RBMP.   

Grouping of GWBs is not used for the assessment of the chemical status of GWBs. 

It is noted very positively that an improvement can be seen compared to the previous cycle: indeed 
the number of GWBs in bad status has dropped from 58.8 % in the 2nd RBMPs to 45.7 % in this cycle. 
Yet in Flanders, approximately 55% are still in bad status, in Brussels 20% and in Wallonia 41%.   

In Flanders, the improvement is the result of effective measures to address pressures from pollution, 
but  may  also  be  linked  to  the  exclusion  of  non-relevant  metabolites  of  pesticides  from  the 
groundwater chemical status assessment, considering these are not subject to EU maximum limit 
values.  On the other hand, in Wallonia, 5 non relevant metabolites of pesticides continue to be taken 
into account in chemical status assessment. 

For 2027, 28 GWBs are still at risk of failing to achieve good chemical status (34,5 %): 25 out of 47 
in Flanders and Brussels (or 53%) and only 3 out of 34 (or 8.8 %) in Wallonia.   

24 

 
Figure 7: Chemical status of groundwater bodies (GWBs) in Belgium in the 1st, 2nd and 3rd RBMPs 

Source: WISE electronic reporting  

Like for surface waters, a small subset of compounds is causing the problem: in all RBDs nitrates and 
pesticides;  in  Flanders  and  Brussels  also  potassium,  pesticides,  N,N-dimethylsulfamide  and 
bentazone; and sustained upward trends are noted for nitrates, pesticides, tetrachloroethylene and 
ammonium; in Wallonia also ammonium, total phosphorus; and sustained upward trends are noted 
for nitrates, pesticides and bentazone. 

For transboundary groundwater bodies, coordination of threshold values takes place in the context 
of the working program of the International Scheldt and Meuse Commissions. 

4.3 What Belgium is doing to combat pollution from agriculture 

Regrettably, the Flanders RBMP reports that only 63% of measures included in the 2nd RBMPs have 
been implemented. For the 3rd cycle, most measures will be implemented in the context of the action 
programme under the Nitrates Directive and the CAP Strategic Plan17. Focus is on intensive livestock 
farming  and  potato  farming  which  are  particularly  susceptible  to  nitrates  leaching  into  the 
environment. Other sources of nitrogen are industry and traffic18. 

The Flemish government has launched a special action plan “the great river acceleration”19, including 
over 1000 actions to reduce, inter alia, the impacts from nitrates and phosphates from agriculture. 
This will be done by means of a revised manure policy (Manure Action Plan - implementation of the 
measures under the Nitrates Directive), which should have been in place in January 2023 but is still 

17 In this respect, it may be useful to refer to the recent study on ‘Mapping and Analysis of CAP Strategic Plans - 
Assessment of joint efforts for 2023-2027’ 
18 However, contrary to ammonia evaporating from manure reacting to nitrogen, the nitrogen formed by NOx can travel 
much longer distances before being deposited. 
19 conceptnota_grote-stroomversnelling.pdf (integraalwaterbeleid.be), see also in English River Basin Management Plan 
Scheldt and Meuse 2022-2027 (integraalwaterbeleid.be) 

25 

 
 
 
missing(), an erosion policy and a new agricultural policy (adjustment of conditionality linked to basic 
income  support  from  CAP  to  reduce  nutrients  and  pesticides,  use  of  agri-environment  climate 
interventions and eco-schemes, including an eco-scheme for buffer strips larger beyond the standard 
conditionality or small landscape features having the same buffering capacities which helps to avoid 
nutrient and pesticide leaching ). Measures also aim towards crop optimisation on sensitive parcels. 
In  erosion  sensitive  areas,  subsidies  will  be  conditional  on  implementation  of  measures  to  avoid 
erosion. 

The Nitrogen Decree (approved January 202420) aims to halve nitrogen emissions by 2030. However, 
as a result of massive farmer protests, it still includes a possibility for farmers to apply exemptions 
from the set threshold, on a case by case assessment. Also the most heavy polluters still get a last 
chance to seriously reduce nitrogen emissions, so as to avoid closure by 2030, e. g. by use of air 
scrubbers  that  remove  nitrogen  (ammonia)  from  the  air.  These  are  very  costly  but  there  will  be 
compensation for reducing emissions. The effects of the Nitrogen Decree on improving water quality 
by reducing nitrogen deposition on surface waters are not provided. The obligation of zero fertilization 
in the VEN area (Flemish Ecological Network, valuable nature) seems to have been removed from 
the environmental impact report (MER) of the draft new manure action plan (MAP7). Notwithstanding 
an infringement procedure under the Nitrates Directive, Flanders is still running late with the review 
of its Nitrate Action Programme (NAP 7 =MAP 7). The last derogation under the Nitrates directive 
which allowed manure spreading above the limit of 170 kg N/ha expired end of 2022.  

In the Wallonia RBMPs, agriculture is responsible for 50% of the gap for nitrogen and phosphorus, 
above wastewater treatment discharges (40%) and industrial emissions (10%). The measures are 
split between basic and supplementary. 

Basic measures include implementation of the CAP (for the new programming period 2023-2027), 
planting of up to 4000 km of hedges to protect water resources from pollution from nutrients and 
pesticides, the Plan for Reduction of Pesticides implementing the EU objective of 50% reduction of 
the use and risks associated with pesticides, and the definition of zones vulnerable to pesticides. 

Supplementary  measures  include  adaptation  of  the  general  plan  for  reducing  ammonia  from 
agriculture to implement the Nitrates Directive, the objective to increase the 7,5%21 of the agricultural 
land  converted  to  organic  farming  to  30%  by  2030,  a  ban  of  new  agricultural  draining  in  wet 
grassland, implementation of the CAP (for the new programming period 2023-2027) in respect of 
eco-schemes requirements on financial compensation for commitment by farmers not to use some 
pesticides and financial support for mechanical weeding of farm land), updating agricultural controls, 
measures helping to track evolution of use of pesticides by farmers, measures to reduce soil erosion 
in agricultural zones and sediments in water bodies. 

It  is  noted  positively  that  the  RBMPs  describe  qualitatively  the  expected  effectiveness  of  the 
measures. 

It  is  also  worth mentioning  that  about  1,5%  of  all agricultural  land  in Flanders  is  now22  used  for 
organic  agricultural  production  (2/3  for  grass  and  fodder  and  1/3  for  crops)  and  12,5  %  of  all 
agricultural land in Wallonia.23 Further growth in organic agriculture is expected in Flanders (with an 
objective of almost quadrupling their present area) and more moderately in Wallonia towards 18%, 
contributing to reducing use of fertilizers and losses of nutrients. 

20 The Decree has been challenged by both NGOs and Farmer’s Unions in August 2024 before the constitutional court 
21 File:Organic-area-2022.jpg - Statistics Explained (europa.eu) 
22 Belgium (Flanders) - European Commission (europa.eu) 
23 Contexte et contenu du plan stratégique wallon de la PAC - Portail de l'agriculture wallonne (wallonie.be) 

26 

 
 
Funding 

In Flanders, the basic measures under the Nitrates Directive and the CAP are  born by the farming 
community. The supplementary measures are funded by the CAP and national funds. It is welcome 
that  there  is  a  detailed  overview  of  the  investment  and  operational  costs,  and  funding,  for  all 
measures24. 

The Wallonia RBMP estimates the cost of implementing agricultural measures to be 6 million € per 
annum.  It  is  noted  positively  that  there  is  a  detailed  overview  of  the  operationalisation  of  the 
measures and their financing. 

Gap assessment 

It is important to highlight that the Flanders RBMP includes a detailed gap assessment for nitrogen 
and phosphorous. This allows, in line with the requirements under the WFD, to identify the needs, as 
well as progress towards the achievement of the objectives. The agricultural sector is responsible for 
around 55% for N and 27% for P. It is very welcome that for each water body there is an estimation 
of  the  necessary  reduction  of  N  and  P  in  order  to  achieve  the  status  objective,  including  an 
identification of the key contributing sectors. This type of assessment is not seen in many countries. 
It is however not specified how much each sector should contribute. 

Also in Wallonia, in contrast with other countries, there are detailed gap assessments of the need for 
nutrient reductions for each surface water body. It is however not specified how much each sector 
should contribute. 

The  North  Sea  RBMP  includes  basic  and  supplementary  measures.  Basic  measures  include  the 
reduction of nutrients from agriculture. Supplementary measures include a prohibition to use active 
substances in aquaculture, e.g. pesticides, antimicrobial substances, disinfecting substances. 

The program of measures of the North Sea RBD is based on the program developed in the framework 
of the MSFD. Good status largely depends on measures across borders, and upstream in Flanders, 
Brussels and Walloon RBDs. 

4.4 What Belgium is doing to combat pollution from other sectors 

Pollution in this context concerns 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. 

As pathways of pollution are very different, many different types of measures are needed. 

The main measures reported in Flanders and North Sea RBMPs are: 

•  Construction or upgrades of urban and industrial wastewater treatment plants; 
•  Voluntary measures: e.g. toolbox for investment opportunities in remediation infrastructure 

and updating the Code of Good Practice in function of climate adaptation;  

•  Ensure smart wastewater and stormwater infrastructure; 
•  Remediation of (historical) contaminated sites (sediments, groundwater, soil); 
• 
Improving riverbed quality by remediation of contaminated river sediments; 
•  Setting emission limits for problematic substances from industrial and other point sources, 

limiting emissions from mineral oil spills; 

24 See page 21 of River Basin Management Plan Scheldt and Meuse 2022-2027 (integraalwaterbeleid.be) 

27 

 
 
• 

• 

for the North Sea RBD: prohibition to use tributyltin (TBT) in shipping, waste management 
plans in harbour areas, fishery and shipping bans and prevention of emissions from ships, 
quality control of sediments discharged in sea areas, incident management, development of 
environmentally  friendly  anti  fouling  substances,  ban  on  use  of  certain  pesticides  in 
aquaculture, and of lead in fisheries; 
implementing  and  updating  environmental  permits  for  wastewater  discharges  (also  from 
installations not covered by the ‘Industrial Emissions Directive’ (IED); systematic follow-up of 
‘Best Available Techniques’ under the IED; address pollution from industrial disasters.   

In the Walloon RBDs, main measures include: 

•  Measures related to wastewater treatment; including tertiary treatment to reduce nitrates, 
phosphates, and organic matter in more than 50% of urban wastewater treatment plants; 
construction/finalisation of new wastewater treatment plants; ensure conformity of individual 
treatment  systems;  assess  the  opportunity  to  revise  the  amount  of  industrial  taxation  to 
reconsider the contribution of industrial sector to water pollution; 
In  addition,  five  supplementary  measures  are  listed:  management  of  water  parasites  in 
wastewater network; management of wastewater during rain events; optimize the energetic 
efficiency  of  wastewater  treatment  plan;  improve  maintenance  of  sewers;  improve 
management of wastewater and rainwater; 

• 

•  measures  to  address  pollution  from  industrial  sites,  including  the  review  and  update  of 

permits in line with environmental objectives and revision of general binding rules; 

•  measures to tackle point source and diffuse emissions of micropollutants; 
•  measures  to  connect  more  areas  below  2,000  population  equivalent.  to  the  waste  water 

treatment system. 

The Brussels RBMP includes a total of 115 measures, focussing on eight areas, including improved 
urban  wastewater  treatment,  increased  connection  to  the  urban  waste  water  treatment  network, 
addressing stormwater overflows and direct discharges. There is increased focus on the polluter pays 
principle, through measures to modify taxation of industry to enforce action to reduce pollution and 
water  use  and  the  aim  to  develop  a  new  mechanism  departing  from  purely  consumption  based 
tariffication so as to integrate, in the long term, environmental costs in the tariffication scheme.  

It  is  worth  noting  that  in  all  RBMPs,  water  pricing  policy  measures  and  measures  for  the 
implementation of recovery of cost of water services are listed.  

4.5 What Belgium is doing to combat significant pressures – overall 

assessment of the Programmes of Measures 

Gap assessment 

All  RBMPs  include  quantitative  or  qualitative  gap  assessments.  No  gap  has  been  observed  in  the 
implementation of the WFD provisions related to governance and public participation.  

Cost-effectiveness 

All  RBMPs  include  a  detailed  cost-effectiveness  analysis,  using  qualitative,  quantitative  or  a 
combination of both qualitative and quantitative assessments. 

In  general,  the  cost-effectiveness  analysis  is  based  on  a  solid  impact  assessment  of  main 
pressures/impacts,  a  thorough  assessment  of  the  effectiveness  of  existing  measures  and  an 
identification  of  the  main  shortcomings  (gap  analysis),  and  the  identification  of  a  longlist  and 

28 

 
selection  of  possible  additional  measures  (shortlist)  based  on  effectiveness,  technical  feasibility, 
support, costs and benefits. Cooperation with experts and consultation of sectors, stakeholders and 
citizens is likely to contribute to successful implementation. 

Financing of measures 

A critical factor in the success of the measures is the availability of budget/funding. 

In all RBMPs, detailed tables show overviews of costs and funding, distinguishing according to the 
type of measures.  

As regards the North Sea RBMP, measures are taken from the program of measures developed in the 
framework of the MSFD, including costs and -mostly national- funding of measures.  

For the Flanders RBDs, costs include limited costs for private operators and more extensive costs for 
remediation  operators.  In  addition  to  the  EU  funds,  the  Flanders  region  uses  regional  and  local 
budgets. The RBMP includes an estimation of investment costs and operational costs for the 1100 
actions  required  for  achieving  good  status,  including  for  all  cases  the  available  share  of  the 
investment and operational budgets, so as to estimate the total cost for the period 2022-2027, and 
what part of those estimated costs is considered available and what part is not. The largest costs 
are for investment in sanitation projects (expansion and optimisation of water treatment) and flood 
protection. It follows from the figures25 provided that it will not be possible to achieve good status 
due to a considerable lack of available funding. 

In the Walloon RBMP26, the cost estimation is based on the costs for implementing the measures 
during the 2nd cycle, subdivided between sectors according to the polluter pays principle. The financial 
impact  on each  sector is estimated in  order to  determine  and  eliminate  measures  that  would  be 
considered  disproportionately  costly.  The  resulting  total  annual  budget  (budget  based  on  ‘public 
consultation’) for Wallonia for the period 2021-2027 has been estimated at 32 million euro. It should 
be noted that costs were considered disproportionate only for the agricultural sector. This was not 
the case for the costs on households and industry.  

Prioritisation of measures 

Flanders has a specific approach for prioritising measures, based on a distinction between types of 
areas: priority water bodies, focus water bodies and other water bodies27. The classification of the 
203 Flemish surface water bodies into area classes was based on various criteria: current condition 
(physico-chemical  and  biological)  and  distance  to  target,  trend,  existing  pressures,  presence  of 
protected  areas,  potential  for  realizing  win-wins,  presence  of  valuable  local  water  bodies,  terrain 
knowledge,  current  and  planned  projects  (remediation  infrastructure  and  others),  local  dynamics 
within the area, modelling results, etc. Only for the first three classes of surface water bodies, it is 
aimed to reach good status by 2027, for class 4 water bodies, 50% should reach good status by 
2027, the rest by 2033 and for class 5 and 6, 33% should reach good status by 2027 and the others 
beyond 2033.  Groundwater bodies activities were not prioritized based on areas.  

25 For the Flanders RBDs, a more detailed table is available which distinguishes between types of measures; see page  21 
non technical summary River Basin Management Plan Scheldt and Meuse 2022-2027 (integraalwaterbeleid.be)   
26 See page 27 of non technical summary Wallonie fiche non technique Enjeux PG3 -Wallonie (1).pdf 
27 A priority area is a surface water body for which good status was expected to be reached in 2021, but has not been. 
There are 57 such priority water bodies (speerpuntgebieden) corresponding to Classes 1-3. There are also 97 focus areas 
(aandachtsgebieden) corresponding to  Class 4 and 5. These are Flemish water bodies where good status is  considered 
achievable  by  2027  or  where  there  is  a  strong  local  dynamic  to  implement  actions  that  contribute  significantly  to  an 
improvement. There are also 41 other water bodies (Class 6). 

29 

 
 
In the Walloon RBMP, since costs of measures to address pressures from agriculture are considered 
disproportionately costly in the 3rd RBMPs, these are not prioritised. Focus is on improving/expanding 
the urban wastewater treatment network, on measures for industry and on measures to protect water 
as a resource.   

Scenario beyond 2027 

Both  the  Flanders  and  Walloon  RBMPs  seem  to  consider  the  possibility  of  reaching  good  status 
beyond 2027, through additional measures not yet implemented during the 3rd RBMP because of a 
lack of funding. Whilst the aim to keep a high level of ambition is positive, this further postponement 
is  not  in  accordance  with  the  WFD  objectives  since,  after  2027,  the  WFD  only  allows  for  time 
exemptions  for  ‘natural  conditions’,  or  exemptions  based  on  Article  4(5)  WFD,  i.e.  for  a  ‘lowered’ 
objective  as  a  result  of  disproportionate  costs/unfeasibility.  This  requires  demonstration  that  all 
technically feasible and not disproportionately costly measures have been put in place but that either 
nature takes more time to recover or that it is still not possible to achieve good status. For exemptions 
under  Article  4(5),  the  assessment  of  disproportionate  costs  should  be  based  on  an  objective 
comparison between costs and benefits and cannot be purely based on lack of available funding. 

5. Exemptions and economics 

5.1 To what extent are exemptions applied in Belgium 

Belgium makes considerable use of different exemptions which are possible. Indeed according to the 
law, where the objective of good status is not yet achieved, exemptions can be applied in accordance 
with Article 4, paragraphs 4, 5, 6 and 7.  

Exemption grounds  

All surface water bodies are in poor chemical status and 25 % of surface water bodies are in good 
ecological status / potential. For groundwaters, 87 % of groundwater bodies are in good quantitative 
status and 54 % are in good chemical status.  

Considering the important amount of water bodies not yet in good status, a significant number of 
exemptions are still applied. All exemptions are either time related or for (temporary) deterioration. 
It is very welcome that no exemptions according to Article 4(5) have been applied in any of the RBMP 
cycles, meaning that Belgium does not intend to lower its objectives under the WFD, as for now. It 
follows  from  the  Flemish28  and  Walloon29  RBMPs  that  the  aim  is  to  achieve  good  status  though 
beyond 2027. This would 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.  However,  as  not  all  non 
disproportionately costly measures will be implemented during this cycle, it will be problematic to 
justify an extension in 2027. 

Table 3: Reasons for exemption under Article 4(4) for each region in Belgium (more than one exemption 
can apply per water body) 

Region 

Technical 
feasibility 

Disproportionate 
costs 

Natural 
conditions 

28 4-visievorming.pdf (integraalwaterbeleid.be) 
29 See page 178 RBMP wallonie.pdf 

30 

 
 
Wallonia - SWB - ecological status 

Wallonia - SWB - Chemical status 

Wallonia – GWB – quantitative status 

Wallonia – GWB – chemical status 

Brussels Capital - SWB - ecological status 

Brussels Capital - SWB - chemical status 

Brussels Capital – GWB – chemical status 

Federal – SWB – Ecological status 

Federal – SWB – chemical status 

Flanders - SWB – ecological status 

Flanders – SWB – chemical status 

Flanders – GWB – quantitative status 

Flanders – GWB - chemical status 

84 

113 

1 

2 

3 

3 

1 

1 

84 

84 

2 

2 

93 

137 

1 

14 

2 

3 

1 

1 

2 

202 

203 

6 

23 

13 

2 

2 

1 

1 

2 

196 

196 

19 

Source: WISE electronic reporting for Flanders, Brussels and North Sea RBDs and background documents for Wallonia RBDs 

(temporary) deterioration due to ‘force majeure’ – Article 4(6) WFD 

In Flanders, 47 water bodies have deteriorated status compared to the 2nd RBMPs. However, according 
to the RBMP, for 16 of those there has not been an actual deterioration but the change  seems to 
stem rather from a ‘misclassification’; for 27 water bodies deterioration was justifiable under Article 
4(6)  WFD.  For  four  water  bodies  no  justification  can  be  provided.  The  most  common  reasons  for 
deterioration  are  related  to  limited  flows  due  to  dry  summers,  management  works,  floods  and  a 
massive invasion of crabs.   

It  is  worth  noting  that  no  Article  4(6)  exemptions  are  reported  in  the  3rd  RBMPs  of  Brussels  and 
Wallonia.  

Deterioration as a result of new projects - Article 4(7) WFD. 

It is worth stressing that no exemptions according to Article 4(7) have been applied in any of the 
three cycles of RBMPs. This may point to an under-implementation of the requirements of Article 
4(7) according to 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.  

The Flanders RBMP refers to a new approach30 and guidance for justifying potential deterioration, to 
take  account  of  the  Weser  ruling in  which  the  Court  has  given  a  strict  definition  to  the  notion  of 
deterioration of status. It cannot yet be concluded if there will be a need for exemptions in the course 
of the 3rd cycle, because relevant policy decisions have not been taken or the assessment is still to 
be or being carried out. If exemptions are applied, they will probably be reported in the next cycle 
RBMPs. The Walloon RBMP also includes detailed guidance for implementing Article 4(7) and only 
refers to one case in which a preliminary assessment was carried out but it was concluded that either 

30 Toetsing aan doelstellingen kaderrichtlijn Water — nl (integraalwaterbeleid.be) 

31 

 
 
 
 
 
 
 
deterioration  of  status  was  unlikely  or  that  further  assessments  would  be  required  for  the  more 
specific projects to be carried out under the plan.  

Level of justification for all exemptions applied 

In the Flanders RBMP, detailed justification of the exemptions at the level of the individual water body 
is only provided for the 17 surface water bodies which had been identified in the 2nd RBMPs as priority 
areas for which good status was considered achievable by 2021. However, de facto this was not the 
case by the time of drafting the 3rd RBMP. For these water bodies, there is a detailed explanation of 
the reasons for the (continued) application of the exemption and why planned measures have not 
been implemented (i.e. for budgetary or technical reason), or have not yielded the expected results. 

For all water bodies, natural conditions are reported in addition to disproportionate costs or technical 
feasibility. Technical feasibility is mostly related to difficulties with land acquisition or additional time 
required for project implementation (acquisition, research and study, tendering, etc.). There are also 
new challenges related to invasive alien species and droughts. According to a Background document 
on  exemptions31,  disproportionate  costs  under  Article  4(4)  WFD  can  be  justified  either  because 
‘unreasonable’,  i.e.  costs  are  not  proportionate  to  the  benefits  (not  only  monetary  but  also 
qualitatively described benefits), or because not proportionate to the financial capabilities of industry, 
agriculture,  households  and  government.  This  is  mainly  documented  in  the  Program  of  Measures 
which also makes references to the background document on funding of measures32. 

The Wallonia RBMP includes information on the justification of the disproportionate costs, natural 
conditions and technical feasibility. The information is specific to the water bodies concerned with 
relatively more information presented for groundwater bodies. Disproportionate costs are invoked 
when  the  cost  of  additional  measures  is  disproportionate  in  relation  to  the  ability  to  pay  of  the 
stakeholders  concerned,  or  in  relation  to  the  expected  environmental  benefit.  The  RBMP  includes 
information on values that are used as part of disproportionality assessments, these are specific by 
sector (e.g. over 2% increase in water services bill for household with small revenues is considered 
to be disproportionate). 

The  Brussels  RBMP  reports  detailed  information  on  Article  4(4)  exemptions,  applied  to  individual 
water bodies. The approach to assess disproportionate costs considers the availability of funds and 
budgetary capacities of the economic actors (households, businesses, public authorities). This implies 
e.g.  an  evaluation  of  the  impact  of  a  100%  cost  recovery  rate  on  average  taxable  income  for 
households and on added value for businesses. It also considers the impact on public expenditure. 

The  electronic  reporting  suggests  that  the  coastal  surface  water  body  is  exempted  for  ecological 
status  on  grounds  of  technical  feasibility,  disproportionate  costs  and  natural  conditions  and  is 
exempted for chemical status on grounds of disproportionate costs and natural conditions.  However, 
regrettably, the North Sea RBMP does not include information on exemptions. This would also be very 
important for the implementation of the Marine Framework Strategy Directive. 

5.2 Use of economic analysis and water pricing – cost recovery 

All RBMPs report progress in the economic analysis and information in accordance with WFD Annex 
III, including as regards key cost estimates associated with the various water services, differentiated 
over user types/sectors, price estimates associated with the various water services, estimates of the 
investments needs and of the potential costs of relevant measures, as well as judgements about the 

31 https://sgbp.integraalwaterbeleid.be/beheerplan/achtergronddocumenten/afwijkingen 
32 https://sgbp.integraalwaterbeleid.be/beheerplan/achtergronddocumenten/ad_financiering-van-water-2017.pdf  

32 

 
 
most cost-effective combination of measures. For the North Sea RBMP, the information is integrated 
for measures under the MSFD, the WFD and the Natura 2000 Directives. In general, the 3rd RBMPs 
do not include clear estimates on consumptive water uses, their shares and the respective long-term 
trends. However, the available statistics suggest an increasing trendin water demand in many sectors 
(e.g.  agriculture,  mining  and  quarrying,  households  and  services  and  industry).  Yet,  without  a 
quantitative  confrontation  of  long-term  supply  and  demand,  the  economic  analysis  does  not 
sufficiently explore when and where bottlenecks may occur beyond 2027.  

Water pricing and price incentives to efficient water use  

The Flanders RBMP distinguishes four water services (public drinking water supply and distribution, 
public  wastewater  collection  and  sanitation,  self-abstraction  and  self-service  with  regards  to 
sanitation), broken down in the three broad water user sectors: industry, households and agriculture. 

This RBMP clarifies how pricing policies aim to influence water consumers towards a more efficient 
water use. There are four groups of water pricing: 

•  The integrated water bill covering water supply and sanitation. The water tariff consists of a 
fixed access fee and a volumetric component with an increasing rate over two rate brackets 
for households, but for industry and agriculture a fixed unit rate independent of consumption 
volume. The latter dents the incentive to use water efficiently. In addition, annual abstractions 
of less than 500m3 per year are exempt of a tariff. The social correction for vulnerable groups 
is set at 80 % for the total amount. 

•  Charges/levies:  for  companies  extracting  water  or  discharging  wastewater,  charges  apply. 
They  reflect  environmental  and  resource  costs  but  are  not  precisely  tied  to  recoverable 
expenses,  therefore  not  constituting  a  clear  application  of  the  polluter-pays-principle;  the 
pricing  scheme  for  irrigation  has  a  volumetric  component  but  only  when  groundwater  or 
surface water is used from a navigable waterway (water use from non-navigable waterways 
is free of charge). 

•  Self-services are considered covered by the cost recovery principle insofar as  the users in 

question bear all costs directly associated with these activities.  

•  General  government  funds  cover  the  cost  of  water  system  management  by  the  Flemish 
government,  provinces,  municipalities,  etc.  Contributions  come  from  various  water-use 
sectors  through  different  types  of  taxes,  unrelated  to  individual  consumption  or 
environmental pressures. 

The other RBMPs do not have a similar overview of water pricing policy. In general, an explicit account 
as to whether these policies provide an adequate incentive to efficient water use, appears absent. 

Cost recovery and the contributions by water use sectors  

The  Flanders  RBMP  reports  full  and  nearly  full  cost recovery  rates for  the  three  broad  water  use 
sectors and for each water service identified. For water supply, the cost recovery rate exceeds 100 % 
for industry and the agricultural sector and is 91% for households (suggesting a cross-subsidy from 
the former two to the latter sector). For sanitation, households achieved 95% cost recovery in 2017, 
and industry 115 % (respectively 98% and 110% when looking at municipal sanitation costs). In the 
case of self-service for water supply (pumping groundwater), since sectors do not receive subsidies 
for  the  infrastructure, the cost  recovery  rate  is  considered  100%.    In  the  case  of  self-service  for 
waste-water  sanitation,  this  varies  across  municipalities  for  what  concerns  households;  whereas 
companies  generally  do  not  receive  financial  support  therefore  assuming  a  100%  cost  recovery. 
Farmers have the option to seek assistance, often in the form of subsidies covering up to 30% of the 
initial investment. 

33 

 
The Wallonia RBMP reports that for water supply services, there is a cost recovery of 100% across 
sectors, with cost recovery from agricultural and industrial sectors above 100%, while for households 
it is slightly below 100%. Concerning the sanitation service, the cost recovery rates are significantly 
lower for the industrial sector (between 9%-57% depending on the RBD), whereas for the household 
sector,  cost  recovery  rates  are  significantly  higher  than  100%  (they  vary  between  117-135% 
depending on the RBD). 

The Brussels RBMP calculates cost-recovery rates for 3 aggregated water uses (industry, households, 
agriculture). 

In all RBMPs, there doesn’t seem to be  an explicit account whether this variation in sectoral  cost 
recovery rates reflects adequate contributions of water user sectors to the water services’ cost. There 
does not seem to be a comprehensive discussion either on the factors allowing mitigation of the cost 
recovery efforts as listed in article 9 of the WFD (albeit the social  tariff and subsidies mentioned 
above are in place for socio-econimic reasons). 

Environmental and Resource cost (ERC) and application of the Polluter Pays Principle (PPP) 

The Flanders RBMP provides quantitative estimates for ERC drawing on a general exercise to estimate 
the value of access to sufficient and clean water, at macro-level (eg for various topics, such as health 
benefits, benefits for tourism and nature and biodiversity, for property value of being close to water, 
and carbon retention and ecology). But it is not clear to what extent the ERC estimates have informed 
the rates of the reported abstraction and environmental charges. 

The Wallonia RBMPs report that their ERC estimates largely reflect the costs of pollution abatement 
and prevention measures. 

None  of  the  RBMPs  appear  to  go  much  further  than  a  general  assurance  that  the  PPP  has  been 
applied, and no direct links are made between the pressures and impact assessment. The Flanders 
RBMP provides a qualitative explanation of how PPP has co-shaped the structure of water bill, and 
refers to the wastewater charge. Similarly, the Walloon RBMP refers to the ‘ecotoxicity’ parameter 
which is now taken into account in the setting the tax rates for industrial wastewater. 

6.  WFD recommendations 

Belgium should urgently address problems including hydromorphology (river dynamics, bank characteristics, 
etc.), concentrations of nutrients and chemicals in surface water, as well as, to a limited extent, in groundwater, 
and water shortages during dry periods. Considering that availability of funding seems to be a major problem 
for  implementing  measures, better  use  should be  made  of  the cost  recovery  and polluter  pays  principle,  in 
relation to all water services and all water users. Permits for abstraction, impoundment and discharges should 
be subject to mandatory periodic review. 

More in particular, Belgium should: 

1. 

increase the level of ambition and accelerate action to reduce the compliance gap as much as possible by 
2027. This implies:  

a) 

b) 

the development of more robust Programmes of Measures based on a clearer assessment of the gap 
to be bridged to reach good status and a clearer prioritization of measures. 

tackling  decisively  obstacles  identified  in  the  implementation  of  measures,  such  as  insufficient 
administrative capacities and resources.  

34 

 
c)  Ensure that all permits related to abstractions and discharges are strictly enforced, better linked to the 
status of the impacted water bodies, include conditions to ensure appropriate ecological flow and water 
balance where so required, and be subject to periodic review so as to avoid deterioration of status. 

2. 

increase  investments  and  ensure  adequate  financing  to  effectively  implement  the  Programmes  of 
Measures to reach the objectives of the WFD. This involves in particular: 

a)  Continue to carry out appropriate and sufficiently detailed cost-benefit analysis of proposed measures 

and explain how this has led to the final selection of those measures.  

b)  Make further efforts towards full application of the cost recovery principle to all water use activities 
that  have  an  impact  on  water  bodies  and  ensure  that  also  self-abstractions  (from  non-navigable 
waterways) are subject to water pricing.  

c)  Make all sectors (also industry and agriculture in Flanders) subject to fixed and variable price per unit 

of water used.  

d)  Consider  funding  of  measures  to  address  pollution  from  agriculture,  including  through  the 

implementation of the Cohesion Policy. 

3. 

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,  and 
taking particular account of the fact thatthose pressures are aggravated by climate change. This implies, 
inter alia:   

a)  Stepping  up  action  to  reduce  nutrient  and  pesticides  pollution,  including  through  continued  close 
cooperation with the farming community and the authorities in charge of the implementation of the 
CAP, through implementing additional mandatory measures if voluntary measures appear insufficient 
and through securing greater synergies between the WFD goals and other policies and instruments, 
including CAP, MSFD and NiD.  

b)  Continue  to  show  ambition  and  pragmatism  in  tackling  chemical  pollution,  by  developing  a  more 
substance-specific approach both in surface and groundwater, with focus on Priority Substances, river-
specific and groundwater specific pollutants; look for solutions to address pollution from ubiquitous 
substances. 

c)  Ensure that ecological flows, i.e.  the level of water that must be left in the water body for the ecosystem 
to  properly  function,  are  set  out  in  the  legislation  or  general  binding  rules  so  as  to  facilitate  their 
implementation in permitting. 

4.  Where the objectives of the Directive for a specific water body cannot be met and exemptions are invoked, 
Member States 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 
water body and ensure that their application is regularly reviewed. This implies: 

a)  Recognising that the possibilities for time related exemptions (Article 4 (4)) are extremely limited and 
will no longer be allowed after 2027 (except if duly justified for natural conditions); in particular in 
Flanders there should be a more transparent and detailed justification of exemptions, since in Flanders 
such justifications are only provided for 17 prioritised water bodies; as well as in the North Sea RBD 
which does not provide any justification for exemption. 

b)  Much more information on the exemptions under Article 4(7) WFD for new projects, including new dams 
and  water  transfers.  This includes better  justifications  of  the  use  of these exemptions  by detailing 
cumulative  effects,  the  assessment  of  better  environmental  options,  and  the  measures  taken  to 
mitigate the adverse impacts of new developments. 

35 

 
5.  As regards monitoring, assessment, data management and reporting, Member States should: 

a) 

b) 

In cooperation with the Commission and the EEA, ensure timely reporting in line with WFD requirements 
and  more  complete  electronic  reporting  for  future  cycles  (in  particular  the  Brussels  and  Walloon 
Regions). 

further strengthen monitoring systems to close gaps both in terms of geographic coverage, water types 
and parameters covered and improve confidence in the status assessment, by reducing reliance on 
expert judgement or grouping of different water bodies and completing the work on setting up reference 
conditions for all quality elements (including hydromorphological). 

c)  More systematically include the water needs of groundwater dependent aquatic ecosystems in the 
assessment  of  the  quantitative  and  chemical  status  of  groundwater  bodies  and  include the  water 
needs  of  groundwater  dependent  terrestrial  ecosystems  for  the  purpose  of  quantitative  status 
assessment in the Brussels Region.  

36 

 
 
SECTION B: 
FLOODS DIRECTIVE 

37 

 
 
 
7. Flood risk management under floods directive (FD) 

The 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  seven  Units  of  Management  (UoMs)  in  Belgium,  which  are  the  same  as  the  Water 
Framework  Directive’s  River  Basin  Districts  (RBD).  Fluvial,  pluvial,  sea  water,  and  Artificial  Water 
Bearing Infrastructure types of floods are considered as potentially significant sources of flooding in 
Belgium. Belgium has designated 27 Areas of Potential Significant Flood Risk (APSFRs).  

7.1 Flood hazard and risk maps 

There are three different FHRM viewers for the three regions (Flanders33, Wallonia34 and Brussels35), 
with different approaches. Coastal flooding is only relevant for Flanders and these maps are included 
in the FHRM viewer for Flanders. The viewers provide maps for floods with low probability (1/1 000 
years for all regions), with medium probability (1/100 years for all regions, only 1/25 – 1/50 years 
for  pluvial  floods  in  Brussels)  and  with  high  probability  (1/25  years  for  Wallonia,  1/10  years  for 
Brussels and Flanders). All maps show flood extent and water depth. However, for Wallonia, water 
levels are shown in lieu of depths for large parts of the river network. All maps also show the number 
of inhabitants and the type of economic activity potentially at risk, including installations regulated 
under the Industrial Emissions Directive (IED). Finally, the FHRMs also show the potentially affected 
protected areas identified in Annex IV(1)(i), (iii) and (v) to Directive 2000/60/EC. 

In terms of changes in the contextual information (i.e. the way in which information about the maps 
is conveyed to the public) since the 1st FHRMs, the most important changes per region relate to the 
consideration of climate change scenarios. For more information, reference is made to section 3.7 on 
‘adaptation to climate change’.    

In terms of methodologies used to prepare flood hazard maps and methodologies used to prepare 
flood risk maps, there has been no change since the 1st FHRMs.  

7.2 Flood risk management plans 

Objectives and measures 

33 https://www.waterinfo.be/default.aspx?path=Public/Kaarten/P01_Overstromingsrichtlijn  
34 Flood Hazard Map: https://geoapps.wallonie.be/Cigale/Public/" \l "VIEWER=ZI Flood Risk map: 
https://geoapps.wallonie.be/Cigale/Public/#VIEWER=RI 
35 https://geodata.environnement.brussels/client/view/1a3cae6b-dd04-4b28-a3e2-
c432dc83e24f?_ga=2.30736700.2008677153.1662963503-1915286757.1661152750 and 
https://geodata.environnement.brussels/client/view/7bbf42dd-1042-482a-958d-e40981592507 

38 

 
 
The  FRMPs  can  be  found  on  the  web  pages  of  Belgium’s  three  regional  governments,  Brussels36, 
Flanders37, and Wallonia38.  

Objectives 

Each of the FRMPs have reported one overall objective accompanied by a series of sub-objectives.   

For Flanders, the FRMP’s main objective calls for protection from floods and a sub-objective calls for 
reducing flood damage. The main objective refers to protection of economic activity, the environment, 
cultural heritage and people.    

For Wallonia, the FRMP’s main objective calls for reducing adverse consequences of floods, including 
those on economic activity, the environment, cultural heritage and human health. The Wallonia FRMP 
also lists objectives at sub-basin level.  

For Brussels, the FRMP’s main objective calls for reducing the frequency and magnitude of flooding. 
A  sub-objective  of  the  Brussels  FRMP  calls  for  reducing  vulnerability  to  flooding.  The  objectives 
however  do  not  specifically  refer  to  protection  of  economic  activities,  the  environment,  cultural 
heritage or human health. 

All three FRMPs also set objectives for non-structural initiatives such as raising awareness, enhancing 
knowledge, or improving crisis management.  

Measures 

Belgium  reported  1  531  measures  to  EIONET,  from  all  three  FRMPs.  Wallonia  has  also  reported 
measures at sub-basin level to EIONET. The Flanders FRMP refers to sub-basin plans but the sub-
basin measures are not reported to EIONET.  

EIONET provides for prioritisation categories for measures, ranging from critical to low. Belgium (all 
three regions) has reported priorities for 1 453 measures out of 1 531 (95 %), with 776 measures 
(51 % of prioritised measures) categorised as critical; 325 as very high (21 %); 30 as high (2 %); 32 
as moderate (2 %); 290 as low (19 %). All three FRMPs outline the prioritisation process used: multi-
criteria analysis (MCA) is used in Flanders and Wallonia.  

The Brussels and Wallonia FRMPs provide detailed information on the costs of their measures but 
not  an  overall  budget.  The  Flanders  FRMP,  on  the  other  hand,  provides  an  overall  budget.  Public 
budgets appear to be the main source of funding for measures in all three Belgium FRMPs. However, 
on the whole, information regarding the financing of the measures within the three plans is either 
lacking (for the Wallonia FRMP) or limited (for the Brussels and Flanders plans). The Flanders FRMP 
describes a social cost-benefit analysis method used for the Sigma Plan for the Scheldt estuary; it is 
not clear to what extent it was used for the FRMP itself.  

The  three  FRMPs  include nature-based  solutions in their measures.  The  Flanders  plan  has  a  sub-
objective  to  ‘give  space  to  water’  and  the  Wallonia  plan  has  a  sub-objective  for  riverbeds  and 
floodplains. Both the Flanders and Wallonia FRMPs also include measures for natural water retention, 
while the Brussels FRMP notes that the urban nature of the region does not allow the identification 
of new natural water retention areas. None of the plans provide detail on how nature conservation is 
addressed in their other measures.  

36 https://environnement.brussels/citoyen/nos-actions/plans-et-politiques-regionales/plan-de-gestion-de-leau 
37 https://sgbp.integraalwaterbeleid.be/ 
38 https://inondations.wallonie.be/home/directive-inondation/plans-de-gestion-des-risques-dinondation/pgri-2022-
2027.html. 

39 

 
 
While the Brussels and Flanders FRMPs are integrated into the RBMPs, neither these plans nor the 
Wallonia FRMP provide detail on how the WFD objectives were addressed.  

All  three  regions  have  reported  prevention,  protection  and  preparedness  measures.  The  Flanders 
FRMP refers to protection from flooding in its main objective. The Brussels and Wallonia FRMPs have 
objectives  for  crisis  management.  All  three  FRMPs  include  measures  related  to  land  use  and 
sustainable spatial planning. 

Progress 

The plans for Flanders and Wallonia provide detailed information on progress in implementing the 
measures  under  the  1st  FRMPs  and  describe  how  progress  is  monitored.  However,  they  do  not 
specifically assess progress towards the objectives of the 1st FRMPs. The Flanders FRMP39 shows that 
by the end of 2020, for Measure Group 6 (the FRM measures) about 20 % of all actions in the first 
FRMP had been implemented, 10 % were being implemented, 30 % were in preparation, and 15 % 
had been abandoned, interrupted or were considered not relevant (no information was found in the 
Flanders FRMP why certain actions were designated into the last category). The remaining measures, 
about 25 %, were either in progress, including continuous measures, or not classified. The Wallonia 
plan provides, in its chapter 4, a graph for each of the four UoMs showing the number of measures 
from the 1st FRMP that have been extended to the second FRMP by sub-basin, according to their type 
and  their  progress  of  implementation.  The  2nd  FRMP  notes  that  53  out  of  491  general  and  local 
projects  in  the  1st  FRMP  were  abandoned.  The  plan  lists40  these  projects  and  the  reasons  for  not 
implementing  them,  including  a  lack  of  financing,  or  the  project  was  not  considered  a  priority  or 
assessed as not effective. For the 42 global measures, eight were completed, four abandoned, and 
the remainder either started or in implementation, including continuous measures. The Brussels FRMP 
lacks a systematic overview of progress of measures and only discusses it to some extent, without 
however describing the mechanisms for monitoring progress. It identifies the measures under the 1st 
FRMP that were not taken forward. As regards the progress of measures under the 1st FRMP that 
were taken forward, these are only covered for the WFD.  

Belgium has reported the information on progress of implementation to EIONET as follows: ongoing 
construction (20 measures, 1% of all measures); ongoing (recurrent e.g. maintenance works) (113 
measures, 7 %); in preparation (9 measures, 1 %); not started (1 389 measures, 91 %). No measures 
were reported as being abandoned/interrupted or as completed.  

All Wallonia UoMs reported measures as either ongoing or not started. For the two Flanders UoMs 
(BESCHELDE_VL and BEMAAS_VL) and the Brussels UoM (BEESCAUT_SCHELDE_BR), measures are 
reported as under ongoing construction or in preparation. In the Flanders UoMs only 3 % of measures 
were  reported  as  not  started  (one  measure  in  each  UoM),  compared  to  21  %  in  Brussels  (three 
measures) and between 66 % and 96 % in the Wallonia UoMs. 

Governance 

All three FRMPss refer to international coordination and cooperation, mainly through the international 
river commissions. The Flanders plan also refers to bilateral exchange and coordination undertaken 
with France and the Netherlands. No further details are provided on the contents or results of this 
coordination. 

For  Flanders,  the  Committee  on  Integrated  Water  Policy (CIW)  provided  a  specific  website  for the 
public consultation process with all information centralised including the draft plan, the SEA report 

39 Flanders FRMP, chapter 6.2. 
40 Wallonia FRMP, chapter 4, Table 41. 

40 

 
 
and  the  non-technical  summary.  The  Brussels  and  Wallonia  FRMPs  provide  an  overview  of  the 
comments  received  in  the  public  consultation  and  how  they  were  addressed.  The  Brussels  FRMP 
provides detailed information on feedback from the public consultations, something not found in the 
1st FRMP. 

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’.    

Progress identified in the 2nd FRMPs 

All of Belgium’s FRMPs include a clear and explicit description of the measures with regard to their 
aims, location, implementation process and timeline. Belgium has provided information on the costs 
of measures, for the FRMP as a whole in the case of Flanders, and for individual measures, for all 
three regions. Also, all three FRMPs report geographic coverage for all measures. The FRMPs also 
describe climate impacts on flooding and prioritise addressing the impacts of climate change on flood 
risk to a greater extent. Each FRMP provides an overview of international cooperation, though they 
do not provide details on the contents or results of this cooperation. All three FRMPs refer to bilateral 
consultations with the other regions. The Flanders FRMP states that cooperation and participation 
between the three regions has been strengthened since the 1st FRMP, including via the creation of a 
consultation platform on water under the Water Steering Group. The Brussels and Wallonia FRMPs 
both  describe  broad  ranges  of  activities  for  stakeholder  involvement  for  the  development  of  the 
second  plans.  The  Brussels  FRMP  provides  detailed  information  on  feedback  from  the  public 
consultations, something not found in the 1st FRMP. 

8. FD recommendations 

Based  on  the  assessment  of  the  reported  FHRMs  and  FRMPs,  Belgium  should  consider  the  following 
recommendations to enhance flood risk management: 

• 

The  three  regions’  FHRM  viewers  have  varying  degrees  of  user  friendliness.  Considering  that  all  three 
viewers concern regions of the same country, and that flood risk knows no borders, the next update of 
each of the three viewers should foresee a level of harmonisation amongst them. Ideally there should be 
one all-encompassing FHRM. 

•  All Flood Hazard Maps should show either water depths or water levels as per Article 6 of 

the Directive. 
It should be clear in the FHRM whether climate change has been considered and future impacts of climate 
change presented. 

The three FRMPs each state that the whole region has been designated as an APSFR, at the same time, 27 
APSFRs were identified and the FHRMs show different parts of the three regions subject to flooding under 
different scenarios. Hence there seems to be a discrepancy which should be clarified. 

The Brussels and Wallonia FRMPs should include summary maps of their APSFRs. 

The FRMP should provide detail on how the FHRM was used in the choice of objectives and measures. 

Provisions for the protection of cultural heritage at risk from flooding should be discussed in the FRMP. 

• 

• 

• 

• 

• 

41 

 
• 

• 

The FRMP’s objectives should be made more specific, where possible linked to quantitative indicators and 
be timebound, and better coordinated between the regions. An assessment of the progress made towards 
the achievement of the objectives should be included in all three FRMPs. 

The FRMP should set out the methods used to monitor progress of measures and explain clearer the actual 
progress of the measures (including those finished in the course of the first FRMP). 

•  Where relevant, the FRMP should incorporate CBA for the prioritisation of measures that lend themselves 

to it and provide a clear description of the methodology used. 

• 

• 

• 

The consultation periods for the draft FRMPs should be coordinated between the three regions. 

The FRMP should set out clearly the coordination with the WFD. 

The FRMP should set out clearly the international cooperation and coordination activities carried out. 

•  Where  appropriate,  the  FHRM should  consider  flow velocity or  relevant  water  flow  and  the  FRMP  flood 

conveyance routes, as these are relevant to emergency response. 

42