COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans Member State: Estonia 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: Estonia, 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) 26 final  COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans  Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans     Member State: Estonia Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC)   Third River Basin Management Plans  Second Flood Risk Management Plans {COM(2025) 2 final} - {SWD(2025) 13 final} - {SWD(2025) 14 final} - {SWD(2025) 15 final} - {SWD(2025) 16 final} - {SWD(2025) 17 final} - {SWD(2025) 18 final} - {SWD(2025) 19 final} - {SWD(2025) 20 final} - {SWD(2025) 21 final} - {SWD(2025) 22 final} - {SWD(2025) 23 final} - {SWD(2025) 24 final} - {SWD(2025) 25 final} - {SWD(2025) 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 

Estonia 

ENVIRONMENT 

 
 
 
 
 
 
 
 
Content 

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

SECTION A: WATER FRAMEWORK DIRECTIVE .......................................................................................................................... 4 

1. General info, member state characterisation ............................................................................................................. 5 

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

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

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

3. Policy elements contributing to biodiversity and climate change adaptation ...................................... 12 

3.1 Surface Water: what is their ecological status or potential .................................................................... 12 

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) .......................................... 14 

3.3 Groundwater bodies - have they sufficient water – quantitative status ......................................... 15 

3.4 Protected Areas (identification, monitoring, objectives and measures) ........................................... 16 

3.5 What is being done to prevent/reduce hydromorphological pressures ............................................ 17 

3.6 What Estonia is doing for abstractions and water scarcity ..................................................................... 18 

3.7 Adaptation to climate change .................................................................................................................................. 19 

4. Policy elements contributing to zero pollution ........................................................................................................ 20 

4.1 Surface Water: what is their chemical status ................................................................................................. 20 

4.2 Groundwater Bodies: what is their chemical status .................................................................................... 22 

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

4.4 What Estonia is doing to combat pollution from other sectors ............................................................ 24 

4.5  What  Estonia  is  doing  to  combat  significant  pressures  –  overall  assessment  of  the 
Programmes of Measures .................................................................................................................................................. 25 

5. Exemptions and economics ............................................................................................................................................... 25 

5.1 To what extent are exemptions applied in Estonia ...................................................................................... 25 

5.2 Use of economic analysis and water pricing – cost recovery ................................................................ 27 

6. WFD recommendations ........................................................................................................................................................ 28 

SECTION B: FLOODS DIRECTIVE .................................................................................................................................................. 31 

7. Flood risk management under floods directive (FD) ............................................................................................ 32 

7.1 Flood hazard and risk maps ...................................................................................................................................... 33 

7.2 Flood risk management plans .................................................................................................................................. 33 

2 

 
 
 
 
SECTION A: 
WATER FRAMEWORK 
DIRECTIVE 

3 

 
 
 
1. General info, member state characterisation

Estonia,  the  northernmost  country  of  the  three  EU  Baltic  States,  extends  over  45 330  square 
kilometres1 and has a flat terrain in general with highest point reaching 318 m (Suur Munamägi), and 
over  2 000  islands.  Being  among  the  least  densely  populated  countries  in  Europe,  Estonia  has 
1 365 884 inhabitants2, a large share lives in the capital city Tallinn (around 400 000 inhabitants). 
Half of the Estonian territory is covered by forests and almost a quarter is protected by different legal 
regimes. Currently, 20.9% of Estonia’s terrestrial territory is designated as protected areas, which is 
slightly below the EU value of 26.4%3. 

Estonia  has  three  River  Basin 
Districts  (RBDs)  and  all  of  them 
are  parts  of  international  RBDs 
(Table  1).  It  is  worth  noting  that 
the other countries sharing those 
RBDs  are  Latvia,  as  well  as 
Russia.  

In total, Estonia has 746 surface 
water bodies that are mainly river 
tributaries  and  31  groundwater 
bodies (Table 2). To be noted that 
Estonia did not report transitional 
waters. 

Just as it was the case in the 2nd 
River  Basin  Management  Plans 
(RBMPs), surface water bodies in 
Estonia  remain  largely  in  their 
natural  state,  with  around  7.1% 
of  surface  water  bodies  are 
heavily  modified  (HMWBs)  and 
5.7%  are  artificial  water  bodies 
(AWBs). 

Table 1. Overview of Estonia's RBDs 

RBD 

Name 

Size (km2) 

Coastal water area 
(km2) 

Countries sharing 
RBD 

EE1 

EE2 

EE3 

West-Estonian 

East-Estonian 

Koiva 

Source: WISE electronic reporting 

45 383 

23 759 

1 309 

12 949 

1 552 

0 

LV 

LV, RU 

LV, RU 

1 Eurostat – Area by NUTS 3 region (not including territorial waters): 
https://ec.europa.eu/eurostat/databrowser/bookmark/fabcfca6-4abb-4a84-ac1c-7bb335af436a?lang=en  
2 Eurostat – Population change – Demographic balance and crude rates at national level:  
3 Biodiversity Information System of Europe: https://biodiversity.europa.eu/countries/estonia  

4 

 
 
 
RBD 

EE1 

EE2 

EE3 

Table 2. Number of water bodies and the total length (km) of rivers, as well as total area (km2) of lakes, 
coastal waters, territorial waters and groundwaters. 

Rivers 

Lakes 

Coastal waters 

Territorial 
waters 

Groundwaters 

No 

Total 
length 
(km) 

No 

Total 
area 
(km2) 

No 

Total 
area 
(km2) 

No 

Total 
area 
(km2) 

No 

7 

6 109 

3 

73 

14 

12 934 

266 

5 278 

43 

1 900 

22 

373 

7 

8 

2 

0 

1 553 

0 

Total 

635 

11 760 

93 

1 980 

16 

14 488 

Source: WISE electronic reporting 

Reporting 

1 

1 

- 

2 

8 927 

1 787 

- 

10 714 

15 

14 

2 

31 

Total 
area 
(km2) 

58 362 

51 224 

2 059 

111 646 

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

By  September  2023,  Estonia  submitted  full  electronic  reporting  and  therefore  the  assessment  is 
based on this dataset. 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 

Trend (% good 
status/potential) 

Main Pressures & Changes & Exemptions 

The total number of SWBs has slightly decreased since the 2nd RBMPs, from 752 to 746. 

ECOLOGICAL 
STATUS 

The number of surveillance monitoring sites and operational monitoring sites has decreased by 19% and 46%, respectively. However, more 
quality elements are being monitored.  

The ecological status of Estonia's SWBs has deteriorated since 2nd RBMPs. No coastal waters reach good ecological status, and only 63% of 
SWBs are expected to be in good ecological status in 2027. 

Estonia applies exemptions under Article 4(4) to 39.8% of SWBs and under Article 4(5) to 6.6% of SWBs for ecological status. 

In total, 14% of surface water bodies are monitored for chemical status. All 45 priority substances and all three matrices (water, biota, 
sediment) are included in the monitoring.  

CHEMICAL 
STATUS 

The graph shows chemical status including uPBT substances. Since the 2nd RBMPs, no improvement is reported and 83% of SWBs remain in 
unknown status due to insufficient monitoring. No coastal water bodies reach good chemical status. In 2027, only 40% of SWBs are expected 
to be in good chemical status, with 50% remaining in unknown status, and 12% not achieving good status. 

Estonia applies exemptions under Article 4(4) to 5.6% of SWBs, and under Article 4(5) to 7% of SWBs for chemical status. 

6 

 
 
 
 
 
 
 
 
Ground 
Water 
Bodies 

Trend (% good 
status/potential) 

The number of GWBs has slightly decreased from 39 to 31. 

Main Pressures & Changes & Exemptions 

80% of area of GWBs are monitored. The confidence in classification has improved significantly, reaching 80% of GWB assessed based on 
high confidence. 

QUANTITATIVE 
STATUS 

Two GWBs (6.5%) fail to achieve good quantitative status. These two and two additional GWBs are at risk of not reaching good status by 
2027.  

Estonia applies exemptions under Article 4(4) due to technical feasibility and article 4(5) to both GWBs. Additionally, exemption under Article 
4(4) is applied due to natural condition to one GWB. 

CHEMICAL 
STATUS 

8 GWBs (26%) are in poor chemical status. While six of them are expected to be in good status by 2027, there are still 2 GWBs remaining in 
poor chemical status. In addition to these 8 GWBs, further 10 GWBs are at risk not being in good chemical status in 2027. 

All groundwater bodies are monitored for chemical status, but the coverage of monitoring accounts 85% of groundwater area. 

Exemptions under Article 4(4) are applied to 17 GWBs and under Article 4(5) they are applied to two GWBs (6.5%). 

7 

 
 
 
 
 
 
 
 
2. Horizontal aspects 

2.1 Governance 

Estonia  has  multiple  competent  authorities  in  charge  of  the  different  aspects  of  the  River  Basin 
Management Plans (RBMPs), most of them at national levels. The number of authorities in charge of 
water management has risen from three to nine compared to the 2nd RBMPs. The coordination of 
the implementation is of the responsibility of the Ministry of Environment. The coordination of the 
implementation of the Water Framework Directive (WFD) and the Floods Directive (FD) as well as the 
Marine Strategy Framework Directive (MSFD) is crucial for a proper implementation of environmental 
objectives. To be noted that greater number of involved authorities ensures that various aspects and 
views are considered during the planning, if the coordination is well conducted. 

In Estonia, all RBMPs include the objectives of both Directives (FD and MSFD). Particularly positive is 
the fact that the Estonian authorities reported that all RBMPs, Flood Risk Management Plans (FRMPs) 
and Programmes of Measures established under the MSFD were drawn up in parallel and they were 
synchronized.  Also,  public  consultation  actions  were  organised  together  so  ensuring  synergies 
between RBMPs, FRMPs and marine measures. This synergetic approach is very important to achieve 
the  objectives  of  these  directives.  The  consultation  took  place  in  several  steps  and  lasted  for  six 
months. 

As regards transboundary coordination, Estonia continues to have an international co-operation with 
Latvia,  whereby  there  is  an  international  agreement  place.  Cooperation  with  Russia  traditionally 
occurred under the established Estonian-Russian Joint Commission on the protection and sustainable 
use of transboundary waters. Estonia is a contracting party of the Cooperation for the Protection of 
the Marine Environment of the Baltic Sea (HELCOM)4 and the measures are linked to the Baltic Sea 
Action Plan 2021.  

To be noted that the recently updated KOTKAS5, an Estonian permit register and information system, 
supports automatic exchange of water data and real-time reporting, thus improving data quality and 
saving resources of authorities and creating a standardised data taxonomy for all sectors. 

2.2 Characterization of River Basin District 

Regarding  the  2nd  RBMPs,  the  Commission  had  encouraged  Estonia  to  ensure  that  reference 
conditions are established for all relevant quality elements for all surface waters. It is positively noted 
that in the 3rd RBMPs,  most  of the reference conditions for biological  quality elements have been 
intercalibrated. However, there is a gap in the intercalibration of reference conditions for fish fauna 
in very large rivers. Indeed, the 3rd RBMPs report that reference conditions have been established for 
all hydromorphological quality elements for all coastal water body types. However, gaps remain for 
some lakes for which reference conditions have not been established. 

For  the  pressures,  it  is  encouraging  to  note  that  the  knowledge  has  improved;  however,  perhaps 
because  many  of  the  unknows  have  been  cleared,  Estonia  indicates  that  the  pressures  on  the 
ecological status of surface water bodies seem to be very high. Compared to the two other Baltic 
countries, Estonia seems to face less eutrophication problems but still it is worrying that many water 
bodies are failing due to nutrient conditions. 

4 Cooperation for the protection of the marine environment of the Baltic Sea: https://helcom.fi/  
5 Keskkonnaotsuste Infosüsteem: https://kotkas.envir.ee/  

8 

 
 
Surface waters 

The most significant pressure identified is diffuse pollution which affects more than 90% of the water 
bodies. More precisely, the problem is nutrient pollution that affects 93% of the water bodies (Figure 
1).  While  the  unknown  anthropogenic  pressure  was  reported  to  affect  the  highest  percentage  of 
surface water bodies (approximately 70%) in the 2nd RBMPs, more information of diffuse and other 
pressures has removed the uncertainty  of unknown pressures in the 3rd RBMPs (aligned to only 5 
water bodies). The most significant impacts on surface waters are nutrients which  have increased 
from 11% in the 2nd RBMPs to 94% in the 3rd RBMP. It is not clear if this change is due to better 
assessment of the pressure or due to more emissions. To note, the pressure of invasive alien species 
(IAS) on waters has not been assessed. While, in total, there are 9 aquatic species of EU concern in 
Estonia6, no concrete measures are introduced to combat IAS. 

Figure 1. The most significant impacts on surface water and groundwater bodies in Estonia in 3rd RBMPs 
(expressed as percentages of numbers of water bodies) 

Source: WISE electronic reporting 

The  excess  of  nutrients  discharged  into  the  surface  waters  leads  to  eutrophication  causing 
proliferation  of  algae  blooms  and  oxygen  depletion  in  both  lakes  and  coastal  waters.  Under  the 
Nitrates Directive reporting, Estonia indicated that many monitoring points across the country show 
surface waters as eutrophic or at risk of becoming eutrophic (Figure 2). 

6 EASIN - European Alien Species Information Network: https://easin.jrc.ec.europa.eu/easin/  

9 

 
 
 
 
Figure 2. Map of the monitoring points showing eutrophication assessment in Estonia, according to the 
reporting of the Nitrates Directive.7 

Groundwaters 

A clear evolution can be seen between the two cycles. Saline intrusion and organic pollution have 
been reported as the greatest impacts on the quality of groundwater with 26% for both types of 
impacts (Figure 1). Whereas in the 2nd RBMPs, the most significant pressures were unknown for most 
water bodies and chemical pollution for 22% of water bodies. It is worth noting that according to 
Estonian  authorities,  there  are  no  significant  pressure  for  71%  of  groundwater  bodies, but in  the 
electronic reporting to the Commission, this percentage seems to be 42%. Contrary to surface waters, 
the percentage of groundwater bodies reported to be significantly impacted by chemical pollution 
has considerably decreased since the 2nd RBMPs (from 21% to 3%). 

Estonia  mentions  the  impact  of  oil  shale  mining,  which  is  causing  the  deterioration  of  their 
groundwater bodies. These mining activities have a direct influence on groundwater quality due to 
the  use  of  machinery, mining  by-products  becoming  dissolved  in  the  water,  and  minerals  formed 
when the rock is exposed to air becoming dissolved in the water.8 Subsequently, the sector abstracts 
large  amounts  of  water  both  for  the  operation  itself  and  for  removal  of  groundwater  to  prevent 
flooding of the mine. 

Estonia shares water information via a map service 

 NITRATES DIRECTIVE - Reporting Period 7 (2016-2019) – trophic status: 
https://water.jrc.ec.europa.eu/portal/apps/dashboards/cb6034c2a75e4df282f8a62f90c16caa  
8 A study on the EU oil shale industry – viewed in the light of the Estonian experience: 
https://easac.eu/fileadmin/PDF_s/reports_statements/Study.pdf  

10 

 
 
 
The Maa-amet geoportaal9 is a map-based service providing an overall view of the status of water 
bodies. Figure 3 shows the screenshot of the service. 

Figure 3. Maa-amet geoportaal provided by the Estonian Land Board (screenshot of the service). 

Source: maa-amet geoportaal 

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  Estonia,  the  number  of  surveillance  monitoring  sites  has  decreased  by  19% 
compared to 2nd RBMPs and even more for the number of operational monitoring sites which have 
decreased by 46%. However, Estonia explains that operational monitoring programme is reviewed 
and re-planned yearly and therefore, the eventual number of sites is not yet available. 

In the 3rd RBMPs, the surveillance monitoring is covering 48.2% of river length, 100% of lake area, 
0% of coastal area. Whereas operational monitoring is covering 2.1% of river length, 0% of lake area, 
and  100%  of  coastal  area.  Estonia  explains  that  surveillance  monitoring  needs  are  mapped  and 
planned with operational monitoring plan for each year taking into account information gathered with 
surveillance monitoring and implemented measures. 

It is positive that more quality elements are being monitored and used for classification than in the 
2nd RBMPs. However, hydromorphological quality elements are monitored only in lakes and rivers, but 
not in coastal waters. As regarding gaps in the monitoring, for rivers, there is no thermal, or salinity 
conditions monitored,  for lakes, no thermal,  oxygenation, or salinity conditions monitored, and for 

9 Maa-amet geoportal: https://xgis.maaamet.ee/xgis2/page/app/kem_veemajanduskava  

11 

 
 
 
coastal waters, no tidal regime, thermal oxygenation, nor salinity conditions being monitored. Thus, 
it appears that the implementation of monitoring and classification is still not complete. 

It is important to highlight that while Estonia is monitoring river basin specific pollutants (RBSPs) in 
all water body types, only 15% of (115) surface water bodies are assessed using RBSP monitoring. 
More effort in increasing RBSP monitoring of lakes and coastal waters seems to emerge compared 
to rivers. An improvement can be seen also for the territorial water which is now monitored for RBSPs. 

Status assessment 

The assessment of the ecological status is based on at least one biological quality element for 457 
(61%)  surface  water  bodies  while  4  water  bodies  are  assessed  based  on  expert  judgement  or 
modelling.  For  the  rest  289  water  bodies,  no  biological  quality  elements  are  used  and  they  are 
classified based on mainly physico-chemical quality elements. Compared to the 2nd RBMPs, the use 
of  biological  monitoring  for  status  assessment  has  increased  from  401  (2nd  RBMPs)  to  457  (3rd 
RBMPs) water bodies. 

Regrettably,  the  ecological  status  or  potential  of  the  surface  water bodies  has  continuously  been 
deteriorating  from  70% (1st  RBMPs)  to  60%  (2nd  RBMPs)  and  53% (3rd RBMPs)  in good  ecological 
status or potential. Furthermore, there are no more water bodies in high ecological status. Figure 4 
shows the evolution along the different planning cycles. This trend can, at least partly, be explained 
by  the  fact  that  the  knowledge  on  the  status  of  the  water  bodies  has  considerably  increased  in 
Estonia. However, it does not close the possible deterioration of the status.  

The confidence in the classification has not improved, in fact, the proportion of water bodies classified 
based  on  unknown  confidence  has  drastically increased.  Against  this background,  Estonia  expects 
that only 70% of the water bodies will be in good status by 2027.  

Figure 4. Ecological status or potential of surface water bodies (SWBs) in Estonia in the 1st, 2nd, and 3rd 
RBMPs. 

Source: WISE electronic reporting 

12 

 
 
3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) 

Hydromorphological characteristics of surface water bodies concern the quantity and dynamics of 
water flow, the connection of surface water bodies to groundwater bodies, continuity of rivers, as 
well as river depth, river width and their variation in structure as well as the substrate of the riverbed 
structure of the riparian zone.  

Overall, 8.3% of total river water bodies in the 3rd RBMP are designated as heavily modified, and 6.3% 
of river water bodies and 3.2% of lake water bodies as artificial (Figure 5). The number of heavily 
modified river water bodies has slightly decreased since the 2nd RBMPs, from 56 to 53 water bodies. 
While in the 2nd RBMPs, one coastal water body had been designated as heavily modified, in the 3rd 
RBMPs there are none.  

The changes are due to new information from monitoring and research, and new delineation of water 
bodies. One change in the designation was due to the removal of a barrier. The reason for designating 
water bodies as heavily modified is land reclamation (affecting 81% of HMWBs), barriers (affecting 
40% of HMWBs) and periodic anthropogenic water shortages (affecting 37% of HMWBs). In 2019, an 
interim assessment of the status of water bodies found that there were 132 water bodies not in 
good or high ecological status due to barriers.  

According to the status assessment, two heavily modified water bodies are in good, 31 in moderate, 
17 in poor and three in bad ecological potential. For artificial water bodies, 35 are in good, three in 
moderate and two in poor ecological potential. The methodology for assessment of good ecological 
potential  (GEP)  is  ongoing  and  not  yet  completed  in  Estonia,  and  in  the  RBMPs,  the  same  class 
boundaries  are  used  for  natural  waters.  Habitat  types  of  aquatic  biota,  among  others,  are  not 
considered in GEP assessment, which indicates an important gap. 

Figure 5. The proportion of natural, heavily modified, and artificial water bodies by water category and 
total. 

Source: WISE electronic reporting 

3.3 Groundwater bodies - have they sufficient water – quantitative status 

Monitoring 

The number of groundwater bodies in Estonia was decreased from 39 (2nd RBMPs) to 31 (3rd RBMPs), 
due to re-delineation, but the total groundwater body area did not change. To be noted that a joint 

13 

 
 
monitoring programme for Estonia and Latvia has been established  through an Interreg project in 
2018-202010. However, Estonia reported no transboundary groundwater bodies. 

There has been a slight increase in monitoring sites for quantitative monitoring from 243 (2nd RBMPs) 
to 256 (3rd RBMPs). Grouping of groundwater bodies is not used in the assessment of the quantitative 
status of groundwater bodies so that currently 100% of Estonia’s groundwater bodies in terms of 
number are subject to quantitative monitoring; however, monitoring is not covering the total area of 
groundwaters (80.3% of coverage)11. 

Status assessment 

It has been reported that two groundwater bodies (6.5% of total groundwater bodies) are assessed 
in poor quantitative status (Figure 6), and Estonia estimates that they will remain in poor status by 
2027. Two further groundwater bodies are at risk of failing to remain in good quantitative status by 
2027.  80.6%  of  the  classifications  conducted  are  of  high  confidence  and this indicates  a  notable 
improvement  compared  to  the  2nd  RBMPs  which  had  a  high  level  of  confidence  for  only  5.1%  of 
groundwater bodies. 

Two groundwater bodies, which are currently at good status, are at the same time at risk of failing 
good  quantitative  status  by  2027  because  of  ecological  decrease  in  associated  surface  waters, 
distortion of the water balance, and lowering of water table. Furthermore, water abstraction is seen 
as one of the pressures on groundwaters in Estonia. In 2016-2021, the average annual abstraction 
from groundwater amounted up to 228 million cubic metres, from which the majority because of 
mining and quarrying12. 

10 Interreg project ‘Water bodies without borders’: https://wbwb.eu/  
11 Data derived from WISE electronic reporting. According to the Estonian authorities, the coverage of quantitative 
monitoring is 100%. 
12 Eurostat - Annual freshwater abstraction by source and sector (not considering leakages or evaporation from the 
surfaces of reservoirs and canals after abstraction): https://ec.europa.eu/eurostat/databrowser/bookmark/82866331-
d833-482a-96c6-a09d5d06a2d4?lang=en 

14 

 
 
Figure 6. Quantitative status of groundwater bodies (GWBs) in Estonia in the 1st, 2nd, and 3rd RBMPs. 

Source: WISE electronic reporting 

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

A large proportion of Estonian’s territory has been nationally designated under protection. In fact, 
protected water areas (746 for surface waters and 14 for groundwaters) have been identified for all 
relevant Directives in the 3rd RBMPs: Nitrates Directive, Birds and Habitats Directives, Bathing Water 
Directive, Urban  Waste  Water  Treatment Directive. The  only  designated  nitrate  vulnerable zone  is 
located in the north-central part of Estonia. Sensitive areas have been designated under the Urban 
Waste Water Treatment Directive, as well, given that national legislation (Water Act) requires all river 
basins with wastewater treatment plants to be designated as sensitive. Furthermore, no areas have 
been identified for the protection of economically significant aquatic species. 

Figure 6 indicates the progress in the status of water bodies associated with protected areas in the 
2nd RBMPs and 3rd RBMPs.13 It is encouraging that the status of groundwater bodies associated with 
protected areas has improved since the 2nd RBMPs for both quantitative and chemical status. 

13 It should be noted that there was a technical problem during electronic reporting (confirmed by the Estonian 
authorities). The information assessed has been limited which affects the overview picture of protected areas in Estonia 
and the estimation of progress made compared to the 2nd RBMPs. 

15 

 
 
 
Figure 7. Progress in the status of water bodies associated with protected areas in the 2nd RBMPs (2016) 
and 3rd RBMPs (2022).  

Note: Due to electronic reporting difficulties, the status of surface water bodies associated with  protected areas are not 
shown for the 3rd RBMPs (2022) 

Source: WISE electronic reporting 

By 2022, 27.2% of the Estonian territorial sea has been under protection. HELCOM updated its Baltic 
Sea Action Plan in 2021, a strategic programme of measures and actions for a healthy Baltic Sea. 
The plan has also been part of the programme of measures reported under the MSFD which has been 
assessed in parallel. 

3.5 What is being done to prevent/reduce hydromorphological pressures 

In  Estonian  RBMPs,  restoration  and  mitigation  measures  have  been  planned,  such  as  removal  of 
barriers, construction of fish ladders, reviewing of permit conditions to address hydromorphological 
alterations, land reclamation in terms of restoring river continuity etc. Estonia has spent millions of 
euros to reconnect its rivers, with financial support from the EU. Estonia has also in place a register 
of  physical  modifications  of  water  bodies,  so  that  better  information  (and  control)  of  existing 
hydromorphological pressures to be allowed. Moreover, a study of the impact of the dams on aquatic 

16 

 
 
 
environment is planned in the programme of measures aiming to fill knowledge gaps and to set the 
conditions  for  and  monitoring  of  the  minimum  ecological  flow.  Estonia  intends  to  implement 
ecological  flows  for  all  relevant  water  bodies  by  2027.  It  is  encouraging  that  the  number  of 
implemented hydromorphological measures has increased during the past six-year period. However, 
in  Estonian  RBMPs,  there  is  no  clear  explanation  whether  and  how  nature-based  solutions  are 
prioritised for planning. The only mention is that measures for improving natural water retention has 
been implemented in 20 water bodies, four in the Eastern RBD and the rest in the Western RBD 

The contribution of Estonia to river restoration by removing dams is showing good development. One 
example is the removal of the Sindi Dam in the Pärnu River, which is demolished in 2018-2019 and 
the  restoration  work  was  remunerated  with  the  Natura  2000  Award14.  Estonia  is  diversifying  its 
energy mix in particular via pumped storage hydropower. In fact, such a plant with a total capacity 
of 550 MW will be constructed starting in 202515. 

In  coastal  waters,  measures  related  to  hydrographical  changes  are  adequately  linked  to  the 
programme of measures under the MSFD. 

3.6 What Estonia is doing for abstractions and water scarcity 

As water scarcity is an issue of global concern, this is not the case with Estonia where water sources 
are not under stress. However, the estimation of the annual Water Exploitation Index Plus (WEI+) for 
2007-2019 varies between 2.4 and 2116, while water scarcity is generally considered to occur when 
the ratio of water abstraction to long-term average available water resources exceeds 20. It is also 
worrying that contrary to the 2nd RBMPs, in which water abstraction did not constitute a significant 
pressure  factor  on  surface  waters  in  Estonia,  in  3rd  RBMPs  water  abstraction  is  identified  as  a 
significant pressure factor for both rivers and lakes, i.e., affecting 5.4% of total river water bodies 
and 2% of total lake water bodies. 

Regarding groundwaters, currently, two water bodies are at risk to fail good quantitative status in 
2027, influenced primarily by water abstraction for the public water supply network and for mining 
activities.  The  3rd  RBMPs  include  clear  measures  to  address  significant  pressure  from  water 
abstraction  in  those  groundwater  bodies  assessed  in  poor  quantitative  status  and  those  surface 
water bodies assessed in less than good ecological status / potential. But anticipated effectiveness 
of measures cannot be estimated since no information has been provided on the gap to achieve the 
objectives in 2027. 

Having a closer look on Estonia’s legal regime laying down basic principles for water abstractions, it 
was found that water abstraction exceeding certain thresholds requires a permit, i.e., a water permit 
or an integrated permit according to Estonian Water Act. In Estonia, permit requirements are reviewed 
during  regular  inspections  of integrated permits,  including  those  necessary  to  comply  with  Article 
11(5) WFD, but according to the Estonian law integrated permits and water permits are generally 
issued for unlimited period, which raises some doubts whether there is in place systematic control 
mechanism for permits. 

14 Natura 2000 Award - Improving the Pärnu river basin for its migratory fish: 
https://environment.ec.europa.eu/topics/nature-and-biodiversity/natura-2000-award/meet-natura-2000-heroes/improving-
parnu-river-basin-its-migratory-fish_en  
15 A bulletin by the energy company Zero Terrain/Energiasalv: https://zeroterrain.com/estonias-first-pumped-hydro-energy-
storage-project-zero-terrain-partners-with-the-estonian-government-and-receives-a-grant-of-e19m/  
16 Water exploitation index, plus (WEI+) from 2009 to 2019: 
https://ec.europa.eu/eurostat/databrowser/bookmark/8e6c6e33-3a7c-4c9a-b6c7-11710a1fbba0?lang=en  

17 

 
 
3.7 Adaptation to climate change 

Estonia acknowledges the impact of climate change on drought as a possible risk in the near future. 
While climate change adaptation measures are mentioned in all three Estonian RBMPs, they do not 
report any surface water bodies or groundwater bodies having failed to reach good status based on 
climate change. Thus, no adaptation measures have been identified. In its national Climate Change 
Adaptation  Development  Plan17,  Estonia  is  setting  up  basic  measures  such  as  identifying  more 
effective water reuse options, investigating important water management issues, and assessing the 
relevant socio-economic impacts. No Drought Management Plan has been developed. It is notable 
though that Estonia is pioneering in exploring more sustainable farming practices such investing on 
research for drought-tolerant plants18. 

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 on both, consideration climate change is jointly addressed in this section.  

The first FHRMs reference studies on climate change impacts on floods, but this was done in the form 
of a literature review. No information on specific climate change related data were used in preparing 
the flood hazard maps. Since then, several studies and analyses have been published, based on which 
it was possible to more accurately assess the impact of climate change on the occurrence of floods 
and take this into account when preparing FHRMs, although Estonia concluded that the impact of 
climate change, even in 2100, is minimal. 

The  FRMPs  have  a  separate  chapter  on  climate  change,  giving  an  overview  of  climate  change 
projections  and  their  implications  for  floods.  Additional  data  have  been  collected  and  updated 
forecasts have been made19, and this is relatively more comprehensive in the  second FRMPs. The 
FRMPs state that, as the impact of climate change on floods is not considered major, they do not 
have measures specifically to address the likelihood and potential adverse consequences of flooding 
related to climate change. Nonetheless, a climate sensitivity analysis20 was carried out for all actions 
during the preparation of the Action Plan 2022-2027 (as was the case for the Action Plan 2015-21 
of  the  first  FRMP).  Spatial  planning  and  land  use  measures  are  generally  categorised  as  having 
medium climate sensitivity, i.e. they should not be directly affected by climate change in most cases, 
although indirect effects may occur. In addition, one nature-based solution in the Action Plan 2022-
2027 – to support water retention on agricultural lands – refers to agricultural land management 
practices that can support climate change adaptation and flood risk mitigation or prevention, such as 
buffer strips and permanent grasslands, as well as the restoration and maintenance of floodplain 
meadows that preserve space for high water. The Action Plan states that this will be implemented 
under Estonia’s Common Agricultural Policy Strategic Plan. 

17 Kliimamuutustega kohanemise arengukava aastani 2030: https://kliimaministeerium.ee/rohereform-
kliima/kliimapoliitika/kliimamuutustega-kohanemine  
18 Breeding of drought-tolerant plants reduces food shortages: https://ut.ee/en/content/breeding-drought-tolerant-plants-
reduces-food-shortages  
19 Estonian Environmental Agency, Estonian future climate scenarios to 2100’, 2016, https://www.klab.ee/wp-
content/uploads/sites/4/2016/04/2016-04-07-KAUR_Lopparuanne.pdf 
20 FRMP of West Estonia (EE1), pp. 30-33; FRMP of East Estonia (EE2), pp. 25-28; FRMP of Koiva (EE3), pp. 15-18. 

18 

 
 
4. Policy elements contributing to zero pollution 

4.1 Surface Water: what is their chemical status 

Monitoring 

Estonia receives a low score in terms of monitoring its surface waters for chemical status both in 2nd 
and 3rd RBMPs as only 14% of all water bodies in Estonia are subject to monitoring (with 45 priority 
substances not all included) which in practice means that a great number of surface water bodies 
remains  at unknown  status.  It  must  be  noted  that  Estonia  does  not make  use  of  grouping  water 
bodies or modelling like many other Member States which entails a large number of water bodies in 
unknown chemical status.  

The 3rd RBMPs discuss surveillance monitoring for all three matrices: water, biota, and sediment. 

As  regards  monitoring  frequency,  the  3rd  RBMPs  state  that  surveillance  monitoring  occurs  less 
frequently than the minimum set by the WFD, due to budgets and available resources. 

The  insufficient  monitoring  of  surface  water  bodies  provokes  some  uncertainty  to  what  extent 
chemical pollution affects the Estonian surface water bodies.  

Status assessment – Evolution of chemical status of surface water bodies since the 2nd 
RBMPs 

As explained above, large proportion (83%) of the water bodies were not assessed for chemical status 
which is slightly lower than in the 2nd RBMPs (Figure 8). Out of the assessed water bodies, 9.7% (72 
water bodies) are in good and 7.6% (57 water bodies) not achieving good chemical status. Without 
the uPBT substances, the percentages are 14.6% and 2.7%, respectively. None of the coastal and 
territorial waters are in good chemical status, while without the uPBT substances, all water bodies 
except one would be in good chemical status. The comparison to the 2nd RBMPs shows no significant 
change  in  good  chemical  status  but  a  slightly  higher  percentage  assessed  as  poor.  Estonia  is 
expecting that almost 74% of surface water bodies to be in good chemical status by 2027.  

19 

 
Figure 8. Chemical status of surface water bodies (SWBs) in Estonia in the 1st, 2nd, and 3rd RBMPs. 

Source: WISE electronic reporting 

The  reason  for  failure  in  achieving  good  chemical  status  is  mainly  due  to  two  specific  priority 
substances (Figure 9): mercury and polybrominated diphenyl ethers (PBDEs). Both pose significant 
threat  to  humans  and  aquatic  environment,  and  they  belong  to  ubiquitous,  persistent, 
bioaccumulative, and toxic (uPBT) substances. In the 2nd RBMPs, in addition to mercury, other metals 
(cadmium, lead, nickel) and two pesticides (cybutryne and dichlorvos) were causing failure. 

Figure 9. The top-10 Priority Substances causing failure to achieve good chemical status in surface water 
bodies in Estonia with addition of one new priority substance. 

20 

 
 
 
Note: The new priority substance according to the 2008/105/EU as amended by 2013/39/EU21 is marked with asterisk (*). 

Source: WISE electronic reporting 

To  be  noted  that  according  to  a  survey  published  in  February  2024,  the  Estonian  Environmental 
Investment Centre, in cooperation with the police and border guard, found up to eight kilogrammes 
of mercury on one of underwater shipwrecks sunk during World War II22. 

4.2 Groundwater Bodies: what is their chemical status 

Monitoring 

All 31 groundwater bodies are monitored for chemical status with a coverage of 85% of groundwater 
area, which means that some groundwater bodies are only partially covered. Despite the decrease in 
the  number  of  groundwater  bodies,  total  groundwater  body  area  has  remained  almost  the  same 
compared to the previous cycle. Estonia has decreased the number of monitoring sites from 394 to 
353 for surveillance monitoring and increased them from 160 to 173 for operational monitoring. All 
substances causing risk of deterioration23 of chemical status are subject to monitoring. 

Status assessment 

The assessment of groundwater bodies considers chemical  substances, saline or other intrusions, 
impacts  on  drinking  water  protected  areas  and  impacts  on  groundwater  associated  aquatic 
ecosystems (GWAAE) and on groundwater dependent terrestrial ecosystems (GWDTE). The confidence 
in the assessment has improved, having over 40% of water bodies classified with high confidence. 

Compared to the 2nd RBMPs with 8 groundwater bodies in poor chemical status, in the 3rd RBMPs, the 
same number of groundwater bodies (25.8%24) are still in poor chemical status (Figure 10). By 2027, 
only 6 of these 8 groundwater bodies are expected to achieve good chemical status while two will 
remain  in  poor  chemical  status.  In  addition  to  the  above  mentioned  8  water  bodies,  further  10 
groundwater bodies are at risk of failing to achieve good chemical status by 2027. 

21 Directive 2008/105/EC as amended by Directive 2013/39/EU added 12 new substances i.e. numbered 34 to 45 to the 
priority substance list. For the 3rd RBMP, Member States have 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. 
22 Environmental Investment Centre - Up to 8 kg of mercury discovered in a shipwreck located in Estonian waters: 
https://kik.ee/en/news/8-kg-mercury-discovered-shipwreck-located-estonian-waters-0  
23 Substances in GWD Annex I and Annex II (Part B) and core parameters in WFD Annex V section 2.4.2  
24 The proportion of the groundwater bodies in poor status is higher compared to the 2nd RBMPs because of different 
number of total groundwater bodies. 

21 

 
 
Figure 10. Chemical status of groundwater bodies (GWBs) in Estonia in the 1st, 2nd, and 3rd RBMPs. 

Source: WISE electronic reporting 

Most of the failure in status is due to significant impairment caused by human activities, like mining 
of oil shale, industry and agriculture and significant environmental risk from pollutants across the 
groundwater  body.  Other  reasons  reported  are  the  negative  impact  on  the  ecology  of  associated 
surface waters, the deterioration of water quality in drinking water protected areas and saline or 
other intrusion which might be linked to overabstraction of groundwater bodies adjacent to the coast. 
The  pollutants  or  their  indicators  posing  risks  to  GWBs  are  chemical  oxygen  demand  (COD), 
ammonium,  mono-basic  phenols,  aminomethylphosphonic  acid  (AMPA,  a  metabolite  from 
glyphosate)  and  sulphate.  In  fact,  ammonium  concentrations  together  with  COD  and  chloride  are 
showing  an  increasing  trend.  The  increasing  chloride  concentration  is  probably  related  to  salinity 
intrusion caused by overabstraction. As regards nitrates, the trend is unclear, because provided data 
in relation to nitrogen and phosphorus balance in agricultural land from Estonian official statistics 
website  refer  back  to  2012.  EEA’s  data  reported  under  the  Nitrates  Directive  show  that  nitrate 
concentrations in Estonian groundwater for the period 2016-2019 exceed the maximum allowable 
concentration (50 mg NO3/l) in around 3% of monitoring stations25.  

Given  that  the  greatest  share  of  ammonium  emissions  is  a  result  of  chemical  fertilizer  used  in 
agriculture, the increasing trend indicates that that Estonia’s programme of measures for agricultural 
pollution after the 2nd RBMPs was still not effective as regards nitrogen pollution. It is also notable 
that  Estonia  reported  in  the  3rd RBMPs  that  26%  of  groundwater  bodies  are  affected  by  organic 
pollution, while in the 2nd RBMPs it was not mentioned as a significant impact. 

25 EEA – Nitrate in groundwater (published Oct 2023): https://www.eea.europa.eu/en/analysis/indicators/nitrate-in-
groundwater-8th-eap  

22 

 
 
 
4.3 What Estonia is doing to combat pollution from agriculture 

The  primary  sector  (agriculture,  forestry  and  fishing)  accounts  for  around  2.5%  of  Estonia’s  total 
gross value added (GVA)26, more than the EU average. Forests cover around 50% and agricultural 
land almost 25% of Estonia’s territory. The average size of agricultural area per holding is one of the 
three biggest in Europe: in 2020 the average size in Estonia was 86 hectares of agricultural area per 
holding27 while the EU average is only 17.4 hectares28. Around 23% of agricultural land is managed 
organically29. The share of the organic agricultural land and productivity has been increasing for 63% 
over the last decade30. In the Estonian CAP Strategic Plan for 2023-2027, the 23% area receiving 
support for organic agriculture is maintained31. Moreover, support is programmed to manage more 
than 70 000 hectares of pastures and meadows to preserve and enhance their natural and cultural 
environmental value. 

The Water Act (2019) is one of the main legal acts on which the central measures of the programmes 
of measures 2015-2021 of the Estonian RBMPs are based on. The programmes of measures state 
that  the  current  resources  for  inspection  and  enforcement  of  measures  to  tackle  agricultural 
pressures are not sufficient. Furthermore, it should be noted that there is no specific assessment of 
achievements since the 2nd RBMPs and of the expected effects of the measures in the 3rd RBMPs 
either. No reference to the measures under the MSFD has been made and the assessment of the 
programme of measures addressing eutrophication under the MSFD is considered not adequate with 
several areas for room of improvement. 

4.4 What Estonia is doing to combat pollution from other sectors 

As regards tackling pollution from non-agricultural sources such as urban and industrial discharges 
and mining of oil shale, the available information does not allow for detailed assessment. Pollution 
from mercury, cadmium, lead, nickel, PBDEs, PFOS, and PAH etc was identified as important due to 
emissions  from  point  sources,  with  the  two  most  wide-spread  substances  mercury  and  PBDEs. 
Estonia reported measures to reduce the pressure on the chemical status, such as ‘Compliance with 
the  restrictions  on  discharge  of  pollutants,  including  hazardous  substances,  into  the  water’  and 
‘Reducing and limiting the release of hazardous substances into water by means of permit’. However, 
in Estonian RBMPs there is no information about effectivity or how the proposed measures will reduce 
the pollution. 

It is welcomed though that in the 3rd RBMPs, there are plenty of measures related to the control of 
urban wastewater pollution and wastewater pollution in sparsely populated areas, such as further 
treatment  of  current  urban  wastewater  of  agglomerations  below  2000  person  equivalents  and 
establishment of water supply and sewage systems in sparsely populated areas. It is notable that a 

26 Estonia – CAP Strategic Plan – Overview: https://agriculture.ec.europa.eu/cap-my-country/cap-strategic-plans/estonia_en  
27 Analytical Factsheet - Estonia - Ten objectives for a future Common Agricultural Policy (CAP): 
https://agridata.ec.europa.eu/extensions/CountryFactsheets/CountryFactsheets.html?memberstate=Estonia#SO2-6  
28 Eurostat – Farms and farmland in the European Union – statistics: https://ec.europa.eu/eurostat/statistics-
explained/index.php?title=Farms_and_farmland_in_the_European_Union_-
_statistics#The_evolution_of_farms_and_farmland_between_2005_and_2020  
29 Eurostat - Developments in organic farming in 2021:  
 https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Developments_in_organic_farming  
30 Agrifood statistics – Increasing the share of organic farming: 
https://agridata.ec.europa.eu/extensions/CountryFactsheets/CountryFactsheets.html?memberstate=Estonia#SO6-4  
31 Mapping and analysis of CAP strategic plans (2023-2027): https://agriculture.ec.europa.eu/common-agricultural-
policy/cap-overview/cmef/regulation-and-simplification/mapping-and-analysis-cap-strategic-plans_en 

23 

 
 
great number of planned  measures includes administrative actions, for example better control  of 
compliance with permits and knowledge improvement actions. Similarly to above, the link to MSFD 
programme of measures is not made and the measures reported under that Directive are inadequate. 

4.5 What Estonia is doing to combat significant pressures – overall 

assessment of the Programmes of Measures 

In total, 182 measures were introduced in Estonia: 122 basic measures, 57 supplementary measures 
and  3  both  basic  and  supplementary  measures.  All  of  them  are  linked  to  a  specific  Key  Type  of 
Measures  (KTM).  However,  similarly  to  the  2nd  RBMPs,  no  information  has  been  provided  on  the 
expected gap to good status in 2021 or 2027. On the other hand, quantitative cost-effectiveness 
analysis has been carried out for technical measures in all three RBDs. The programme of measures 
states that the cost for basic measures is almost EUR 152 million and for supplementary measures, 
it is almost EUR 702 million. Most of the measures (90% of supplementary and 74% of all measures) 
are allocated to agricultural producers with a total cost of EUR 632 million. 

In the 3rd RBMPs, Estonia has mapped measures to reduce mercury and other priority substances in 
surface water bodies, such as PBDE and Cadmium in fish; anthracene, TBT, Lead, and Cadmium in 
sediment; cybutrin, Lead, dichlorophos, fluoranthene, benzo(a)pyrene, benzo(g,h,i)perylene, PFOS, PAH, 
Mercury, and Nickel in water.  

Furthermore, Estonia reported that a pan-Estonian survey of mercury deposition from air emission 
sources into the water environment has been planned to be undertaken. The aim is to develop suitable 
management to limit the impact of mercury deposition on surface water and to develop solutions to 
prevent and limit emissions from local sources of mercury. 

The Baltic Sea has been one of the areas with most intensive international cooperation in terms of 
environmental protection and various policies are being implemented to protect the Baltic Sea and 
achieve its good status before the WFD and the MSFD took place, such as the Convention on the 
Protection of the Marine Environment of the Baltic Sea Area (HELCOM). There are many pressures 
affecting the Baltic Sea and they accelerate biodiversity loss, which leads to severe socio-economic 
consequences, for instance for tourism and fishing. The trends in dissolved inorganic nitrogen (and 
orthophosphate concentrations) in transitional, coastal and marine waters in Europe, for the period 
1980-2021, are increasing in Estonia and that eutrophication remains a large-scale problem in the 
Baltic Sea32. The assessment of the MSFD programme of measures show low adequacy of Estonia’s 
measures in the areas of nutrient pollution and contaminants. 

So far, Estonia seems not to have been able to reduce its chemical pressures. 

5. Exemptions and economics 

5.1 To what extent are exemptions applied in Estonia 

As the good status has not been achieved in all water bodies, Estonia has applied a significant number 
of  exemptions  under  WFD  Article  4(4)  and  Article  4(5)  in  the  3rd  RBMPs.  Article  4(6)  and  4(7) 
exemptions  were  not  applied.  It  seems  that  new  projects  were  considered  as  part  of  water  use 

32 EEA - Nutrients in transitional, coastal and marine waters in Europe (published Jan 2024): 
https://www.eea.europa.eu/data-and-maps/figures/trends-in-dissolved-inorganic-nitrogen-3  

24 

 
 
permitting  or  integrated  environmental  permitting  procedures,  without  however  any  express 
reference to the application of Article 4(7) in the RBMPs. 

Figure 11 shows the use of exemptions under Article 4(4) and 4(5) in Estonia, based on electronic 
reporting.33 

According to electronic reporting, Article 4(4) exemptions for groundwater quantitative status have 
been applied to both groundwater bodies (6.5%) which are in poor status increasing from zero in the 
2nd RBMPs and to 17 groundwater bodies for chemical status (54.8%). Article 4(4) exemptions for 
surface water ecological status / potential have been applied to 297 water bodies (39.8%) increasing 
from 252 water bodies in the 2nd RBMPs (33%)34. For chemical status, only 42 water bodies (5.6%) 
have been exempted in the 3rd RBMPs. In the 2nd RBMPs, the number of water bodies was low, too. 

Regarding chemical status of groundwaters, Article 4(4) exemptions should be applied only for water 
bodies which are not in good status. In the case of Estonia, there are 8 groundwater bodies not in 
good  chemical  status,  but  contradictorily,  the  exemption  for  chemical  status  applies  to  greater 
number (i.e. 17 GWBs). This discrepancy might be linked to the fact that in addition to the 8 water 
bodies in poor status, there are further 10 water bodies in risk of failing to achieve good status by 
2027. 

Figure 11. The use of exemptions according to Art. 4(4) and 4(5) WFD in surface water bodies (SWBs) and 
groundwater bodies (GWBs) in Estonia. The figure shows the proportion of water bodies for each type of 
exemptions. 

Source: WISE electronic reporting 

According  to  electronic  reporting,  Article  4(5)  exemptions  have  been  applied  to  49  surface  water 
bodies (6.6%)  for  ecological  status, increasing  from  one  water  body  since the  2nd  RBMPs, and  51 
surface water bodies (6,8%) for chemical status as well as to two groundwater bodies (6.5%) for 

33 According to the Estonian authorities, there has been an error in the electronic reporting and the numbers slightly differ 
from the numbers in the RBMPs and their PoMs. 
34 It should be noted that the number of surface water bodies in Estonia has changed between the 2nd and 3rd RBMPs 
preventing a direct comparison of the application of Article 4(4) between the planning cycles. 

25 

 
 
 
chemical and quantitative status. To be noted that no Article 4(5) was applied to groundwaters in the 
2nd RBMPs. 

No exemptions according to Article 6(3) of the Groundwater Directive (GWD) have been reported as 
part of the electronic reporting. However, the 3rd RBMPs report one groundwater body to be exempted 
in  accordance  with  Article  6(3)  GWD.  An  inventory  has  been  established  of  exemptions  from  the 
prohibition of direct discharges of pollutants into groundwater. 

Regarding  justifications  for  applying  exemptions  under  Article  4(4),  it  can  be  seen  that  technical 
feasibility, disproportionate costs and/or natural conditions are used as an argument. Article 4(5) has 
been  applied  on  the  grounds  of  technical  feasibility  and  disproportionate  costs  for  surface  water 
bodies  and  on  the  grounds  of  disproportionate  costs  for  groundwater  bodies  with  information 
provided  at  the  water  body  level.  Furthermore,  it  should  be  noted  that  Estonia  developed  a 
methodology to set criteria for justifying exemptions (Annex 10 to RBMPs) for both Article 4(4) and 
Article 4(5) exemptions. 

5.2 Use of economic analysis and water pricing – cost recovery 

Estonia identifies abstraction, damming, storage, drinking water supply and sanitation, and discharge 
of treated effluent as water services. An economic analysis has been carried out for measures related 
to urban areas, contaminated sites, agriculture, industry (electricity production, mining, food, other), 
public water supply, aquaculture, and hydromorphological restoration. The 3rd RBMPs do not provide 
a comprehensive report on the economic analysis as requested by WFD Annex III and neither do they 
provide a summary about what has been updated compared to previous economic analysis. However, 
the Estonian authorities indicate that numeric data has been updated compared to the 2nd RBMPs. 

As the update appears to be based on a dataset with only observations of the recent past (2014 – 
2018) and no forecasts for later years, it appears that the economic analysis does not have the long-
term perspective as foreseen in WFD Annex III, to begin with the “long term forecasts of supply and 
demand for water.” In this way, it remains unclear how the economic analysis has made use of the 
long-term climate scenario assessments underpinning Estonia’s national Climate Change Adaptation 
Plan35, if at all. The limited period of observation appears to be the reason as well for the absence of 
reporting  estimates  of  the  volume,  prices  and  costs  associated  with  water  services  in  the  next 
implementation period and beyond. 

The Programme of Measures lists the measures together with their estimated costs, but without an 
explicit link to the economic analysis. It remains therefore unclear how the reported largely qualitative 
cost-effectiveness  assessment  make  judgements  about  the  most  cost-effective  combination  of 
measures  on  a  few  sets  of  technical  measures  (measures  on  hydromorphological  and  sediment 
pressures,  supplementary  measures  in  the  agricultural  sector,  and  abatement  measure  targeting 
residual  pollution).  More  generally,  it  is  not  clear  whether  for  a  larger  set  of  measures,  including 
investments, cost-effectiveness analysis has been used as a screening and selection tool, similar to 
the climate proofing instrument that reportedly has prioritised measures based on their flexibility and 
adaptability in the face of climate change impacts.  

The  gaps  in  the  economic  analysis,  as  regards  the  long  term  and  cost  effectiveness,  render  the 
investment planning unclear as well as the related choices on their financing and cost recovery. This 
matters  as  Estonia’s  investments  in  expanding  and  upgrading  the  capacity  in  the  water  sector 
received substantial financial support from EU Funds. The Estonian national and EU funding for water 

35 National Energy and Climate Plan: https://kliimaministeerium.ee/en/national-energy-and-climate-plan  

26 

 
 
infrastructure in 2014-2023 has been in total EUR 77.2 million and EUR 133.4 million36, respectively. 
The finance options for new investments (and hence the investments themselves) partly depend on 
the share of the related capital costs recovered over time from the water services’ users.  

The RBMP reports that in the 2014-2018 period, a financial  cost  recovery  rate of 86.2 % for the 
collective water supply and sanitation services combined over entire Estonia. There does not appear 
a disaggregation into recovery rates for individual water services and / or water user sectors, such as 
households, industry and agriculture. Unfortunately, the RBMPs do not clearly explain which revenues 
have been taken on board in the calculations, and how the financial support and depreciation / capital 
costs have been accounted for. This calculation is not followed by an economic analysis exploring the 
evolution of the cost recovery in the next programming period, and how this relates to policy choices 
as  regards  water  pricing  and  the  investment  and  finance  planning  over  the  longer  term  (such  as 
whether to include depreciation over time for the investment part financed with grants). 

The  RBMPs  lack  an  explicit  account  as  to  whether  the  water  pricing  policies  provide  adequate 
incentives for an efficient use of water; whether the various water user sectors and water uses give 
an adequate contribution to the water services’ costs; and which grounds have been used to justify 
less than full cost recovery.  

The reported information on actual prices (the average tariff for collective water supply and sanitation 
services) is not enough to assess the extent of incentives, but the qualitative information on pricing 
suggests some incentives. It concerns the overall high cost recovery rate and the tariff differentiation 
across  regions  suggest  such  incentives.  Also,  the  design  of  the  water  pollution  charges  seems 
focussed on incentivising abatement, since polluters get a rebate on this charge if their discharges 
remain  below  concentrations  limits  stated  in  their  permits.  However,  the  RBMPs  mention  that 
affordability  concerns  have  informed  water tariffs  for  households,  but  without information  on  the 
extent that these adaptations focus vulnerable and / or poor households, it is not clear how much the 
price incentives have been dented overall.  

The  application  of  the  polluter  pays  principle  in  the  cost  recovery  is  corroborated  with  a  general 
reference  to  the  costing  and  pricing  arrangements,  outlined  above.  The  pollution  abatement  and 
prevention costs are estimated and used to calculate a broader cost recovery rate. However, from 
the available information, it is not clear whether the actual polluters or rather the water services’ 
customers pay for these costs. In addition, it is not discussed how the pollution charge rebate relates 
to the implementation of the polluter pays principle in the water services’ cost recovery as such a 
rebate would reduce the coverage of the environmental costs.  

6. WFD recommendations 

Recommendations - Estonia should: 

1.  Address the identified lack of compliance of achieving good status by increasing the level of ambition and 

reducing the compliance gap as much as possible until the next reporting cycle. 

36 Investments for Sustainable Water Management (dated 25 October 2023): 
https://lifecleanest.ee/sites/cleanest/files/2023-
10/Investments%20for%20Sustainable%20Water%20Management%20%20-%20Tanel%20Oppi.pdf  

27 

 
 
2. 

3. 

Increase  the  investments  and  ensure  adequate  financing  in  prevention  and  restoration  to  ensure 
achievement of good status as required by the Directive e.g., by making better use of the ‘polluter-pays 
principle’  and  by  eliminating  environmental  harmful  subsidies  whilst  ensuring  affordable,  just  and 
implementing fair pricing mechanisms for all water users in line with Article 9 WFD. This should be based 
on  a  robust  economic  evaluation  of  measures  to  improve  the  cost-effectiveness  analysis  and  the 
prioritisation of measures as well as a better estimation of the investments applied as well as the funding 
needs. 

Identify and put in place all basic measures and necessary supplementary measures to reduce existing 
persistent  environmental  challenges  (pressures)  preventing  the  achievement  of  good  status  as  those 
pressures  will  be  aggravated  by  climate  change  (e.g.,  pollution  concentrates  in  times  of  less  water 
availability). 

This implies, for example: 

a)  Reduction of nutrient and other chemical pollution including the setting and achievement of maximum 
nutrient loads in all river basin districts to achieve the objectives of WFD, MSFD and ND with particular 
focus on the vulnerability of the Baltic Sea; 

b)  Addressing pesticide pollution by reducing their use and phasing out unsustainable practices as well as 
diffuse sources for the most relevant priority substances (namely mercury, polybrominated diphenyl 
ethers (PBDEs), cadmium, lead, nickel, cybutryne, and dichlorvos); 

c)  Further prevention and reduction of point source pollution to address nutrients and priority substances 
and  river  specific  pollutants  e.g.,  by  reviewing  existing  permits  for  point  source  emissions  to  lower 
pollutant loads; 

d)  Expanding the efforts on nature-based solutions including re-naturalisation and ecosystem restoration 
which will reduce the hydromorphological pressures on its water bodies (e.g., reducing pressures from 
agricultural drainage); 

e)  Stepping up efforts to improve river continuity, ensuring minimum ecological flows, improve the general 

hydrological situation also in cooperation with neighbouring countries; 

f)  Wider  use  of  abstraction  permits  and  fees  for  all  water  users,  monitoring  the  actual  abstracted 
amounts, and harmonisation of the inconsistent use of exemptions from water fees with the aim to 
ensure a balance between abstraction and recharge of water bodies in which withdrawals take place, 
with the aim of achieving good quantitative status of groundwaters and good hydrological conditions 
of surface waters; 

g) 

Including a clear provision on periodical review of abstraction and impoundment permits as well as 
other permits related to hydromorphological changes and describing how this review is implemented 
in the following RBMPs; 

h)  Setting specific measures to achieve the additional objectives for all protected areas under relevant 

Directives and ensuring their link to the WFD implementation. 

4.  Enhance the consideration of climate change in all RBMPs and/or develop regional drought management 
plans  where  droughts  are  foreseen  to  causing  problems  to  the  economics  and  society.  Although  not 
explicitly  required  by  the  Directive,  failure  to  do  so  will  make  it  increasingly  difficult  to  achieve  the 
Directive’s objective and, in some case, even lead to a deterioration of waters where progress has been 
achieved.  

5. 

Improve  further  governance  and  better  coordinate  between  the  different  administrative  levels  and 
authorities dealing with the implementation of the WFD and other related pieces of legislation. This also 

28 

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

Moreover,  Estonia  should  improve  the  comparability  of  status  assessment  with  other  EU  countries, 
specifically regarding the assessment of physico-chemical and hydromorphological conditions related to 
their sensitive biological quality elements. 

6.  Better apply Article 4(7) in relation to all projects potentially deteriorating status of water bodies (also if 

this would only be temporary) with sound and thorough justifications in the RBMPs. 

7. 

Further close knowledge gaps and improve data availability, access to data, as well as data quality and 
comparability by harmonising methods and electronically collected data across river basin districts and 
marine regions, on monitoring, assessments, projections, economic assessment, etc. and make all data 
openly available through timely publication in line with the requirements of the Open Data Directive and 
INSPIRE Directive.  

This implies immediate actions:  

a)  Strengthening the monitoring of surface waters by covering all relevant quality elements and chemicals 
in all water categories. An increased level of monitoring should lead to a lower dependence on expert 
judgment for the classification of ecological status / potential and chemical status.  

b)  Developing  chemical  status  monitoring  programmes  to  ensure  all  relevant  priority  substances 

(including mercury) and River Basin Specific Pollutants are identified.  

c)  Providing a detailed quantitative assessment of the additional need for measures to address nutrients, 

pesticides, and pollution from all the sectors in all RBDs. 

d)  Assessing how the planned measures will close the gaps to good status. This will allow to address all 

point pollutions with concrete measures and better prioritise its measure at water body level. 

This also implies actions for the next RBMPs:  

e)  Working towards improving the level of confidence in the classification of groundwater quantitative 

status. 

f)  Assessing the impacts of climate change on the status of the biological and other quality elements at 
water body level in all RBDs and introduction of possible measures to tackle or mitigate the adverse 
impact of climate change. 

g)  Reporting transboundary groundwater bodies. 

h)  Better assessing the achieved and expected effects of the measures in previous cycles providing more 

details related to pollution from pesticides at water body level. 

i) 

Further developing the methods to assess ecological potential to include the sensitive biological quality 
elements in the assessment. 

j)  Continuing the efforts to establish type-specific reference for all biological quality elements especially 
in very large rivers, and complete reference conditions for hydromorphological quality elements in all 
lake water bodies. 

k) 

Improving the methodology for establishing ecological flow  

l)  Clarification of the prioritisation of nature-based solutions. 

29 

 
 
SECTION B: 
FLOODS DIRECTIVE 

30 

 
 
 
7. Flood risk management under floods directive (FD) 

The Directive requires each Member State 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. 

There are three Units of Management (UoMs) in Estonia, which are the same as the Water Framework 
Directive’s River Basin Districts (RBDs). Fluvial and sea water are considered as potentially significant 
sources of flooding in Estonia. Estonia has designated 14 Areas of Potential Significant Flood Risk 
(APSFRs). The influence of climate change on flood risk has been generally considered in Estonia at 
the time of the second preliminary flood risk assessment. Contradictory, Estonia seems to experience 
significant climate change, whilst no significant impacts on floods are expected, i.e. both past floods 
and their significance and impacts remain at the current level. However, the River Basin Management 
Plans  appear  to include  a  more detailed  analysis  of  impacts  of  climate  change  on  floods  and  an 
overview  of  flood  risk  mitigation  measures,  but  a  clear  link  and  reference  to  these  documents  is 
missing from the 2018 report (i.e. the updated 2018 flood risk assessment of Estonia37). 

37 2018, https://envir.ee/media/828/download  

31 

 
 
 
7.1 Flood hazard and risk maps 

Estonia is using online map portals38 for their FHRMs which were prepared at the national level. Maps 
for floods with low probability (1/1 000 years), with medium probability (1/100 years) and with high 
probability  (1/50  years  for  the  high  probability  and  1/10  years  for  the  very  high  probability)  are 
provided. Flood extent is shown on all maps. Water depth is not shown on the maps; however, water 
levels  are  shown  instead.  Number  of  inhabitants  is  shown  on  the  maps.  Likewise,  the  type  of 
economic activity is shown on the maps. Installations according to the Industrial Emissions Directive 
are shown. Potentially affected protected areas39 are shown in the FHRMs. 

APSFRs were updated at the time of the second PFRA and more comprehensive FHRMs were created. 
Existing hydrometeorological observation data series to update the probabilistic scenarios of water 
levels were used. Almost all calculations were updated and only for two APSFRs (Maardu city and 
Kärdla city) calculations were left unchanged. The FHRMs have been updated with new map layers, 
for example, with a cultural heritage layer. 

In terms of changes of contextual information (i.e. the way in which information about the maps is 
conveyed to the public) since the first FHRMs, the Estonian geoportal is constantly updated, and these 
changes are also applicable to the FHRMs. The portal has an option to add different additional map 
layers, for example, economic activities, hospitals, ambulance stations/emergency medical services 
and rescue teams. This allows users to add objects of interest to the FHRMs. 

In terms of changes in methodologies used to prepare flood hazard maps since the first FHRMs, the 
mapping was based on the same principles as for the first FHRMs. The data were reviewed again for 
all APSFRs and appropriate modifications made  based  on measurement series from the available 
hydrometeorological observation data. 

In terms of changes in  methodologies used to prepare flood risk maps since the first FHRMs, the 
estimation of the number of residents in the APSFR has been changed. Residence data, according to 
the new methodology, are based on residences indicated in the population register, not residences 
indicated in the census. Therefore, the current population numbers for the second FHRMs differ when 
compared to 2013 number for the first FHRMs. 

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

7.2 Flood risk management plans 

Objectives and measures 

The  three  FRMPs  can  be  downloaded  from  the  floods  page  of  the  Climate  Ministry’s  website40 
(previously  Ministry  of  Environment).  All  three  FRMPs  set  out  common  objectives  for  flood  risk 
management: four main objectives and seven sub-objectives set for all UoMs. The three FRMPs state 
that the purpose of the objectives is to minimise or prevent the adverse effects of flooding on human 
health, cultural heritage, environment, and economic activity. Sub-objectives call for reducing flood 
impacts, ensuring safety, and preventing damage during flood events. Several objectives call for non-
structural initiatives, including limiting construction in flood-prone areas, operating a flood forecasting 
and warning system and raising awareness. Estonia reported 101 measures to EIONET. The three 

38 https://xgis.maaamet.ee/xgis2/page/app/yua  
39 Protected areas according to Annex IV(1)(i), (iii) and (v) to WFD 
40 https://kliimaministeerium.ee/merendus-veekeskkond/vesi/uleujutused  

32 

 
 
FRMPs  list  measures,  and,  for  each  measure,  one  or  more  specific  actions.  The  methodology  for 
setting priorities is presented in the FRMPs, and the assigned priority for each action is given in the 
common  Action  Plan  2022-2741  presented  with  each  FRMP.  Estonia  reported  the  priority  of  its 
measures to EIONET. Nine measures are reported with critical priority – three each for prevention, 
protection,  and  recovery  and  review,  and  three  in  each  UoM.  The  Action  Plan  2022-27  provides 
indicators to monitor the completion of its actions. Estonia has reported to EIONET the progress of 
its measures. 

The three FRMPs provide information (in their common Action Plan) on the costs of the actions. The 
likely funding source is identified for each action. Estonia’s Environmental Investment Centre (EIC) is 
the most frequently mentioned source of funding. The EIC manages domestic funds, EU Cohesion 
Policy funds, and revenue from the EU Emissions Trading System (EU ETS). The Action Plan for the 
most part does not specify  which funds will cover the costs, though EIC resources in general  are 
mainly  foreseen  for  research  and  structural  measures.  In  addition,  EU  Cohesion  Policy  funds  are 
indicated as a specific source of financing only for the construction or reconstruction of rainwater 
drainage systems in APSFRs. EU Cohesion Policy funds are expected to be used more widely for flood 
measures, but further details are not provided. Government budgets (state and local) are mainly used 
to  implement  various  training  and  administrative  measures.  Some  measures  are  foreseen  to  be 
funded by businesses or households. A qualitative cost-benefit analysis (CBA) method was used for 
the actions in the Action Plan. The FRMPs have been drawn up and updated in parallel with RBMPs 
and  their  PoMs  harmonising  the  planning  of measures  affecting  water  bodies  in  order to identify 
synergies  and  mitigate  potential  conflicts.  The  FRMPs  call  for  combined  implementation  of  some 
measures with those for the RBMPs. The Action Plan encourages the use of nature-based solutions 
that support water retention on agricultural lands, in water bodies and in wetlands, and calls for the 
consideration of nature-based solutions when funding technical measures. According to the three 
FRMPs, the first main objective calls for preventing flood-related risks. Estonia has reported 30 flood 
prevention measures to  EIONET,  19  flood  protection measures  and  24  preparedness  measures.  A 
sub-objective calls for limiting new construction in flood-prone areas. The common Action Plan for 
the  three  FRMPs  identifies  actions  related  to  spatial  planning,  including  training  sessions  and 
instructional materials, and the consideration of flood areas in territorial plans. The FRMPs mention 
that relevant aspects of nature conservation are considered in all APSFRs.  

According  to  the  second  FRMPs,  the  first  FRMPs  lacked  clear  criteria  by  which  to  measure  the 
achievement of their objectives; nonetheless, the second FRMPs provide an indication of progress 
based on information on the progress of the measures in the first FRMPs: approximately 70% of the 
activities of the first plan were started or had been completed by the end of 2020, it can be concluded 
that the objectives of the first plans are also moving towards achievement42.The second FRMPs state 
that attention has been paid to a clearer presentation of their objectives and to methods to assess 
their achievement (which methods are explained in the FRMPs) and that of the implementation of 
measures43.Compared  to  the  first  FRMPs,  the  objectives  in  the  second  FRMPs  are  more  clearly 
formulated, as are the sub-objectives. Indicators are set to evaluate fulfilment of the objectives. The 
sub-objectives of the second FRMPs are clearly linked to measures and actions. Progress on measures 
is  reported  by  Estonia  as:  ongoing  construction  for  10  measures  (10%  of  all  measures);  ongoing 
maintenance (recurrent, e.g. maintenance works) for 66 measures (66%), in preparation for three 
measures (3%); and not started for 22 measures (22%). The progress of almost all preparedness 
measures (23 measures, 96% of all preparedness measures) is reported as ongoing maintenance 

41 Action Plan is an Annex to the FRMP, https://kliimaministeerium.ee/merendus-veekeskkond/vesi/uleujutused. 
42 FRMP of West Estonia (EE1), p. 38; FRMP of East Estonia (EE2), p. 33; FRMP of Koiva (EE3), p. 23. 
43 FRMP of West Estonia (EE1), p. 38; FRMP of East Estonia (EE2), p. 33; FRMP of Koiva (EE3), p. 23. 

33 

 
 
(recurrent, e.g. maintenance works). Measures in this category are reported for all aspects, with the 
smallest number and share for ‘other’ measures (three). Conversely, 10 ‘other’ measures are reported 
as not started (59% of ‘other’ measures), compared to no recovery and review measures and one 
preparedness measure (4% of this category). For prevention measures, nine measures (30% of this 
category) are reported as not started. All three measures reported as in preparation are recovery and 
review measures (27% of all recovery and review measures). Measures in ongoing construction are: 
four  ‘other’  measures  (24%  of  all  ‘other’  measures);  and  three  prevention  and  three  protection 
measures (10% and 16% of these categories, respectively). At the time of the first FRMPs, Estonia 
reported all measures as progress ongoing. The three FRMPs44 state that 62 of the actions can be 
considered implemented, with a further 17 being implemented. Four actions are not started. For 27 
actions, the FRMPs state that it is not possible to give an assessment of the state of implementation 
either  due  to  a lack  of information  or  the  nature  of  the measure, but  do  not provide  any  further 
explanation. The information in the FRMPs thus does not match the information reported to EIONET.  

Governance 

According  to  the  FRMPs,  the  planned  measures  do  not  affect  flood  risk  in  the  territory  of  the 
neighbouring countries. The FRMPs of the West Estonia UoM and the Koiva UoM state that a joint 
meeting of Estonia, Latvia and Lithuania: all three countries presented their draft 3rd RBMPs and their 
draft 2nd FRMPs for discussion of cross-border cooperation. 

The FRMPs explain that several mechanisms were used to inform the public and interested parties 
about the consultation process on the draft FRMPs. Public consultation and public discussions of the 
draft second FRMPs took place over six months and was organised together with consultation of draft 
RBMPs, marine strategy programmes of measures, and land reclamation conservation plans, in order 
to increase participation. 

The FRMPs were not subject to a Strategic Environmental Assessment. 

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 second FRMPs 

The second FRMPs provide more information on the FHRMs, including a description of the results. The 
objectives in the second FRMPs are more clearly formulated, as are the sub-objectives. Indicators are 
set to evaluate fulfilment of the objectives. The sub-objectives of the second FRMPs are clearly linked 
to measures and actions (measures are made up of actions). Moreover, the FRMP and Action Plan 
2022-2027  determines  indicators  to  monitor  the  completion  of  actions  and,  by  extension,  of 
measures. A CBA methodology was not presented in the first FRMPs, although it was stated that CBA 
was used to prioritise actions, specifically for construction and engineering actions at the local level. 
The second FRMPs, by contrast, contain a clear description of a qualitative methodology used for all 
actions. There is progress in providing measure cost information for each UoM. The Action Plan 2022-
2027  also  provides  information  on  the  compatibility  of  actions  with  WFD  objectives.  In  the 
consultation on the second FRMPs, materials from public meetings, including the questions asked 
and answers given, were published on the government website after the meetings. A wider range of 
stakeholders  was  reported  as  being  involved  in  the  second  FRMPs,  including  water  supply  and 
sanitation, energy and hydropower, navigation/ports, fisheries and aquaculture, industry, NGOs and 
academia. The second FRMPs discuss transboundary coordination on flood risk management, a topic 

44 FRMP of West Estonia (EE1), pp. 37-38; FRMP of East Estonia (EE2), pp. 32-33; FRMP of Koiva (EE3), pp. 22-23. 

34 

 
 
missing in the first FRMPs. In terms of impacts from climate change, the approach is broadly similar 
to the first FRMPs, however, additional data have been collected and updated forecasts have been 
made. 

8. FD recommendations 

Based on the reported information and the FHRMs and FRMPs assessed, Estonia should: 

• 

• 

• 

• 

consider pluvial flooding in the FHRM; 

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

include, in the FRMP, an assessment of the progress made towards the achievement of the objectives; 

consider insurance as a measure for adaptation to climate change; 

8.  where appropriate consider flow velocity or relevant water flow in the FHRM and flood conveyance routes 

in the FRMP, as these are relevant to emergency response; 

9. 

conduct a Strategic Environmental Assessment for the FRMP, depending on the nature of the measures. 

35