COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans Member State: France 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: France, 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) 15 final  COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans   Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans  Member State: France  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) 16 final} - {SWD(2025) 17 final} - {SWD(2025) 18 final} - {SWD(2025) 19 final} - {SWD(2025) 20 final} - {SWD(2025) 21 final} - {SWD(2025) 22 final} - {SWD(2025) 23 final} - {SWD(2025) 24 final} - {SWD(2025) 25 final} - {SWD(2025) 26 final} - {SWD(2025) 27 final} - {SWD(2025) 28 final} - {SWD(2025) 29 final} - {SWD(2025) 30 final} - {SWD(2025) 31 final} - {SWD(2025) 32 final} - {SWD(2025) 33 final} - {SWD(2025) 34 final} - {SWD(2025) 35 final}  
 
 
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Country specific staff working document 

France 

ENVIRONMENT 

 
 
 
 
 
 
 
 
 
Content 

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

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

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

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

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

2.2 Characterization of River Basin District .............................................................................................................. 10 

3. Policy elements contributing to biodiversity and climate change adaptation ...................................... 14 

3.1 Surface Water: what is their ecological status or potential .................................................................... 14 

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) .......................................... 15 

3.3 Groundwater bodies - have they sufficient water – quantitative status ......................................... 16 

3.4 Protected Areas (identification, monitoring, objectives and measures) ........................................... 17 

3.5 What is being done to prevent/reduce hydromorphological pressures ............................................ 19 

3.6 What France is doing for abstractions and water scarcity ...................................................................... 20 

3.7 Adaptation to climate change .................................................................................................................................. 21 

4. Policy elements contributing to zero pollution ........................................................................................................ 22 

4.1 Surface Water: what is their chemical status ................................................................................................. 22 

4.2 Groundwater Bodies: what is their chemical status .................................................................................... 24 

4.3 What France is doing to combat pollution from agriculture ................................................................... 26 

4.4 What France is doing to combat pollution from other sectors ............................................................. 27 

4.5  What  France  is  doing  to  combat  significant  pressures  –  overall  assessment  of  the 
Programmes of Measures .................................................................................................................................................. 28 

5. Exemptions and economics ............................................................................................................................................... 28 

5.1 To what extent are exemptions applied in France ........................................................................................ 28 

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

6. WFD recommendations ........................................................................................................................................................ 32 

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

8. FD recommendations ............................................................................................................................................................ 41 

2 

 
 
 
SECTION A: 
WATER FRAMEWORK 
DIRECTIVE 

3 

 
 
 
1. General info, member state characterisation

France being the largest country in the EU, is home to a great diversity of land-based and marine 
ecosystems,  thanks  to  the  position  of  the  European  mainland  and  the  outermost  regions  and 
overseas  territories.  Bordered  by  8  other  countries,  it  lies  split  between  the  Atlantic  and  the 
Mediterranean. France has a population of 67 million people and a population density of 105.6 people 
per km² which is roughly the EU average. France is the third-biggest manufacturing country in Europe. 
France's agricultural sector is among the largest in value, adding up to EUR 72.9 billion with 456 000 
farms of an average size of 69 hectares. France including its outermost regions has 28% of its land 
covered by protected nature areas. However, its overseas territories are very big biodiversity hotspots 
and 52% of French Guyana land is covered by protected areas.  

France has an extensive river system consisting of the four major rivers Seine, the Loire, the Garonne, 
the Rhône and their tributaries, whose combined catchment includes over 62% of the metropolitan 
territory. The Rhône divides the Massif Central from the still glacier topped Alps and flows into the 
Mediterranean  Sea.  The  Garonne  meets  the  Dordogne  just  after  Bordeaux,  forming  the  Gironde 
estuary, the largest estuary in Western Europe which after approximately 100 kilometres empties 
into  the  Atlantic  Ocean.  Other  water  courses  drain  towards  the  Meuse  and  Rhine  along  the 
northeastern borders.  

4 

 
 
Relevant outermost regions for the 3rd River Basin Management Plans next to South American French 
Guyana are two departments in the Indian Pacific: Mayotte and Reunion; two departments and one 
overseas community in the Caribbean: Martinique, Guadeloupe and St Martin. France has 11 million 
square  kilometres  of  marine  waters  within  three  oceans  under  its  jurisdiction,  of  which  97%  are 
overseas.  The  climate  of  the  Indian  Pacific  islands  Reunion  and  Mayotte  has  a  strong  seasonal 
irregularity,  with  heavy  intensive  rainfalls  occurring  in  a  short  summer  period.  Reunion  Island  is 
regularly exposed to cyclones. All Caribbean islands are located along the paths of cyclones/storms 
too. While rivers are abundant in Guadeloupe and Martinique, freshwater is severely lacking in St 
Martin, and wetlands are limited. French Guyana (more than one-seventh the size of Metropolitan 
France) is mostly (90%) covered by primary tropical forests and has 8% of all French surface water 
bodies. The territory is subject to the Amazon estuary dynamics. 52% of its land territory is covered 
by natural parks and other protected areas, including the 20300 km2 “Parc Amazonien de Guyane”. 
Given this diversity, France has a very large number of water bodies; more than 11.000. 

Reporting 

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

By  September  2023  France  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.  This  3rd RBMPs  Member  State  Compliance  Assessment 
report  has  been  partially  drafted  based  on  information  in  the  Member  State’s  RBMPs  and  of 
information submitted through the Water Information System for Europe (WISE) electronic reporting 
system. At the time of reporting the WISE electronic reporting covered all RBDs except the 2 RBDs, 
Reunion  and  French  Guyana  (together  covering  10%  of  French  surface  water  bodies  and  of  5% 
ground water bodies). The more detailed analyses have focused on mainly 4 River Basin Districts 
(Scheldt, Rhone-Mediterranean, Guadeloupe and Mayotte), combined with more thematic checks on 
Seine-Normandy and Loire-Bretagne. It had to be based on a combined assessment of electronic and 
non-electronic data which might have resulted in a certain distortion of results.  

5 

 
 
Changes in Status, Pressures, Exemptions & Measures1 

Surface 
Water 
Bodies 
(11406) 

Trend (% good 
status/potential) 

Main Pressures & Changes & Exemptions 

ECOLOGICAL 
STATUS 

In the 3rd RBMP e-reporting complemented with datamining in the pdf of FRK (French Guyana), 43,6% of the surface waterbodies (SWBs) is in 
good or high ecological status /potential. This small decrease from 44.2% (2nd RBMP) is related to a relatively high decrease in French 
Guyana (FRK) representing 882 (8%) of the French waterbodies, because of improved monitoring. France without French Guiana has in total 
0,1% increase in good ecological status water bodies. 

Exemptions applied according to Article 4(4) have been justified on grounds of technical feasibility (23.8% of SWBs), disproportionate cost 
(1.4% of SWBs) and natural conditions (3.5% of SWBs). 
Article 4(5) exemptions for lowered objectives on the grounds of infeasibility (32% of SWBs) and disproportionate costs (16% of SWBs). 

France estimates for 97.9 % of surface water bodies environmental objectives will be in reached in 2027. This includes the high level (32%) 
of 4(5) exemptions lowered objectives that France estimates to be achieved in 2027. This means 65,9% good status/potential estimation in 
2027. 1,8% of the environmental (possibly lowered) objectives will be reached beyond 2027.  This leaves 0,3% of unknown when to be 
reached for ecological good status/ potential or lowered ecological objective. 

The quality of assessments varies significantly among the RBDs. 8% of all waterbodies has been downgraded in status because according to 
the reporting too high concentrations of new French RBSPs (11 added and one removed since 2nd RBMP). However, RBSP are not monitored 
systematically in a high percentages within a waterbody or in all categories of waterbodies and/or included in ecological status assessments 
in all RBDs. An absence of reference conditions for some biological quality elements (like fish for big rivers) and for physico-chemical quality 
elements for many coastal and transitional water body types is noted.  

1 This assessment is based upon the WSP assessment D1 draft, the response of France including the WSP corrections or adaptations because of the most important elements in this 
response and upon the electronic reporting reported by France before the cutoff date 01-09-2023. Detailed analyses in the assessment is not including FRK (French Guyana) nor FRL 
(Réunion), that were included in 2016. Therefore comparing graphs with the 1st and 2nd RBMP do include FRK and FRL, partly based on datamining. 

6 

 
 
 
 
 
 
CHEMICAL 
STATUS 

Progress is mixed. There is an increase of SWBs in good chemical statusin comparison to the 2nd RBMP, despite the present exclusion of 
Guyana and Reunion. However, the number of water bodies in poor status increased also from 16 to 22% in 3rd RBMPs thanks to improved 
known status. 

Exemptions applied according to Article 4(4) have been justified on grounds of technical feasibility (19.6% of SWBs), disproportionate cost 
(0.4% of SWBs) and natural conditions (11.1% of SWBs). 
Article 4(5) exemptions with lowered objectives are justified on the grounds of infeasibility (0.4% of SWBs) and disproportionate costs (0.01% 
of SWBs).  

It is expected that in 2027 approximately 68,4% of the SWBs will be in good chemical status, 16,7 % is estimated to achieve this beyond 
2027 and what will be the fate of 14,6% of the SWBs in 2027 is unknown. 

Ground 
Water 
Bodies  

Trend (% good 
status/potential) 

Main Pressures & Changes & Exemptions 

QUANTITATIVE 
STATUS 

Based on 3rd RBMPs e-reporting complemented with datamining of the pdf of FRK (French Guiana) 88,1% of the groundwater bodies are in 
good quantitative status.  
The main reason for extra failing quantitative status is full compliance of quantitative status assessment methods including in practise 
mainly the needs of aquatic ecosystems in associated surface waters.  
The needs of ground water dependant terrestrial ecosystems are formally included in the applied assessment method but in practise often 
not yet included for e.g. 80% of N2000 areas. Changes in the water balance / lowering of the water table (4.2% of GWBs) is included. 

Exemptions applied according to Article 4(4) have been justified on grounds of technical feasibility (6.5% of SWBs), disproportionate cost 
(0.7% of SWBs) and natural conditions (1.3% of SWBs). 
Article 4(5) on the grounds of infeasibility (2% of GWBs) and disproportionate costs (0.4% of GWBs).  

7 

 
 
 
 
 
 
 
 
CHEMICAL 
STATUS 

Furthermore, based on the 3rd RBMPs e-reporting and pdf mining, at least 2 % of total GWBs are at risk of failing to achieve good 
quantitative status by 2027. The GWBs at risk of failing to achieve good quantitative status are in eight RBDs with available e-reporting. 

Based on 3rd RBMPs e-reporting complemented by pdf datamining, there is a slight decrease in good chemical status of groundwater 
bodies. Given the reality that 50% of the ground water bodies has been redelineated, the comparison in % of numbers of waterbodies is not 
justified. The total GWB area has however stayed the same. here are 53 % of groundwater bodies having no impact. 

Exemptions applied according to Article 4(4) have been justified on grounds of technical feasibility (11.6% of SWBs), disproportionate cost 
(8.7% of SWBs) and natural conditions (17.1% of SWBs). 
Article 4(5) exemptions lowering the objectives have been justified on the grounds of infeasibility (15.5% of GWBs) and disproportionate 
costs (0.4% of GWBs).  

Overall confidence in the assessment decreased. The reasons for this are still not clear, but possibly the new delineation of about 50% of all 
ground water bodies is the cause.  

The top five pollutants causing failure to achieve good chemical status of GWBs are pesticides including their relevant metabolites, nitrate, 
ammonium, total trichloroethylene and tetrachloroethylene, and phosphate.  

In the 3rd RBMPs e-reporting complemented with datamining, 7,7% or 53 GWBs are expected to fail to achieve good chemical status by 
2027. 

8 

 
 
 
 
 
 
 
2. Horizontal aspects 

2.1 Governance 

France has 12 River Basin Management Plans (RBMPs) covering 14 River Basin Districts (RBDs). Five 
out of these 12 are outside continental Europe. This was similar in the 2nd RBMP but in the 1st RBMP 
there was not one for Mayotte. 

The plans list three levels of competent authorities at national and River Basin District (RBD) level. 
These  include  12  Comités  de  bassin  (Basin  Committees)  and  two  other  levels  are  the  Prefet 
coordinateur de basin and the Ministry of Ecological Transition. 

The Rhine-Meuse Committee covers the Meuse and Rhine River Basin Districts. The Artois-Picardie 
Committee covers the Scheldt and Sambre. These Committees are responsible for the preparation of 
the RBMPs. For each Committee, there is a Basin Coordinating Prefect, responsible for the assessment 
of ground and surface water, for the coordination of implementation, economic analysis, enforcement 
of regulations, monitoring of groundwater and surface water, preparation and implementation of the 
Programme of Measures, pressure and impact analysis, public participation. Exceptionally for the RBD 
Corsica and Mayotte, instead of a Prefect, the Competent Authority is the Président du conseil executif 
de Corse and the Representative of the State, respectively. Finally, the Ministry of Ecological Transition 
is responsible for reporting to the European Commission. The implementation of the WFD at the local 
level  has evolved  as  France  has  reformed  the  structure  of the local  authorities  to  rationalise the 
number  and  organisation  of  various  cooperative  structures  responsible  for  water  supply  (462 
structures),  sanitation  (954  collective  or  148  non-  collective),  flood  prevention  and  aquatic 
environment management (108 new competence GEMAPI).  

All French RBMPs include objectives for the Floods Directive (FD) and the Marine Strategy Framework 
Directive (MSFD). The consultation process for the French National RBMP’s appears to have followed 
the requisite six months of public consultation for all RBDs except for Mayotte. Mayotte had its draft 
RBMP available for six months of consultation, but information is lacking for other elements. The 
significant water management issues were consulted through an online survey without a summary 
of the significant issues provided to participants.  

As regards consultation, more information on the transparency of the consultation process, and the 
comments addressed during the consultation and the feedback provided to those comments should 
be made available to the public after the consultation. A summary of the consultation should also be 
provided. It is not clear how stakeholders are involved in the preparation of the RBMPs on the Guyanne 
and Réunion RBDs. It should be noted that France was late in reporting its RBMPs. 

From  the  14  River  Basin  Districts, there  are  7  which  are  transboundary:  Scheldt,  Meuse,  Sambre, 
Rhine, Rhone and coastal Mediterranean and Seine. The management of these rivers also depend on 
decisions taken by other countries. As regards transboundary cooperation, the Scheldt, Meuse and 
Rhine are governed by International River Basin Commissions. The other stretches of transboundary 
rivers (Seine, tributary of the Po, tributary of the Ebro and Rhone) have forms of bilateral cooperation 
although no international RBMP has been adopted. The Rhone-Mediterranean RBMP is considering 
the establishment of an institutional space for a comprehensive collaboration with Switzerland given 
the impact of climate change on the Rhone in the decades to come. 

9 

 
2.2 Characterization of River Basin District 

France  has  11 406  surface  water  bodies  plus  689  groundwater  bodies  (see  table  1).  A  few 
Metropolitan River Basin Districts are dominating in number of river water bodies (RWBs): Adour-
Garonne  (2680  RWBs),  Rhone-Mediterranean  (2638  RWBs),  Loire-Brittany  (1887  RWBs),  Seine-
Normandy (1651 RWBs). French Guyana however, in the Amazone delta also has 851 river water 
bodies  and  contributes  7.5%  to  the  French  surface  water  bodies.  In  the  coastal  waters  the 
Atlantic/North-Sea coastal water bodies (72) dominate in numbers the Mediterranean (46), Caribbean 
(30) or Pacific (29) ones. Table 1 lists all the water bodies designated by France per river basin district 
(RBD) and per type of water. 

Table 1: Overview of France‘s River Basin Districts (RBDs)  

RBD 

Name 

Rivers 

Lakes 

Transitional 
Waters 

Coastal 
Waters 

Groundwater 
Bodies 

FRA 

Scheldt 

FRB1 

Meuse  

FRB2 

Sambre 

FRC 

Rhine 

55 

141 

11 

473 

FRD 

Rhone-Mediterranean 

2638 

FRE 

Corsica 

FRF 

Adour-Garonne 

FRG 

Loire-Brittany 

210 

2680 

1887 

FRH 

Seine-Normandy 

1651 

- 

- 

- 

- 

- 

- 

Guadeloupe 

Martinique 

Guyana 

Réunion 

Mayotte 

TOTAL 

47 

20 

851 

24 

26 

4 

3 

1 

24 

94 

6 

107 

108 

46 

1 

1 

1 

1 

0 

4 

0 

0 

0 

27 

4 

11 

30 

8 

0 

1 

29 

2 

0 

5 

0 

0 

0 

32 

14 

10 

39 

19 

11 

19 

1 

12 

17 

16 

7 

1 

12 

241 

15 

144 

146 

57 

7 

8 

2 

27 

6 

10714 

397 

116 

179 

689 

The number of surface water types in each RBD has not really changed since the 2nd RBMPs largely 
due to a French decree of 2010 establishes the national  typology of surface water, including the 
methodologies and criteria to be  used. However, for groundwater bodies, more than half of them 
have been subject to re-delineation. Those changes are concentrated mainly in a few metropolitan 
RBDs (FRF and FRG) which have many groundwater bodies. Due to the new change in typology, the 

10 

 
 
comparability  between  cycles  is  rendered  more  difficult,  particularly  as  regards  monitoring  and 
assessment  of  state.  Through  this  re-delineation  the  number  of  groundwater  bodies  in  France 
increased by 6.8% from 645 (2nd RBMPs) to 689 (3rd RBMPs), but the total groundwater body area 
did not change. France reports no transboundary groundwater bodies in the 3rd RBMPs e-reporting2.  

To attribute different classes to a water body, clear thresholds are needed for the poor, moderate, 
good and high ecological status. Reference conditions must be set for good status, underpinned by 
similar ecologically healthy natural water bodies having high and good status. France established 
these  reference  conditions  for  all  biological  quality  elements  for  most  river  types  and  for  some 
biological quality elements in most lake types. Equally, reference conditions have been established 
for some physico-chemical quality elements in most water types.  

However, regrettably, as regards hydromorphological quality elements, just as it was the case in the 
2nd RBMPs, there are no type-specific reference conditions for any of the water body types across all 
water categories (in the 12 RBDs for which electronic reporting is available). As regards transitional 
waters and most coastal waters, some type-specific reference conditions are missing for biological 
quality elements (see section 3.1 for more detail).  

Pressures 

Hydromorphological pressures (alteration of the riverbed, shores or riparian areas and various forms 
of barriers) touching 65 % of the water bodies is the most significant pressure on French surface 
water bodies. The reporting does not indicate the causes of these dominant pressures in France. It 
can be construed that the large number of heavily modified water bodies (HMWBs) gives an indication 
of the magnitude of the activities in France having an impact on hydromorphology. The HMWBs are 
related to flood protection (35%), hydropower (23%), transport (18%), urban development or other 
use (15%) for the most important activities. Smaller hydromorphological pressures not yet leading 
to the designation of water bodies as heavily modified, are most probably related to hydropower, 
transport and urbanisation as well, agriculture may also play a role. 

France  is  the  largest  producer  of  hydroelectricity  in  the  European  Union  (France  67  TWh/year3. 
Metropolitan  France  has  developed  its  gross  hydropower  potential  to  more  than  90%.  and  that 
contributes between 11 and 13%4 of the country’s gross final energy consumption. More than 2000 
contracts are however signed for small and micro power plants in France producing < 10 MW and 
together less than 1% of the French energy consumption but are contributing to hydro morphological 
pressures.  5 A small increase in French hydroelectricity  production is still  foreseen till  20506.  It is 
important  to  mention  the  ongoing  infringement  procedure  against  France  to  restore  the  river 
continuity in a part of the Rhine, as agreed in the context of the International Commission for the 
Protection  of  the  Rhine.  As  a  result,  considerable  efforts  are  being  made  to  improve  continuity, 
affected by hydropower in the Upper Rhine. 

Another energy related cause of hydro morphological pressures is the nuclear power production and 
conventional  power  production.  France  produces  about  40,6%7  of  its  electricity  consumption  with 
nuclear power using large amounts of water as a vital cooling agent. France has 18 nuclear power 
plants (totalling 56 reactors), producing 70% of its total electricity production, making it the second 

2 However, the Rhone-Mediterranean RBD (FRD) reports 6 transboundary GWBs in its 3rd RBMP document. 
3 2017 Hydropower Status Report 
4 Share of electricity from hydropower France 2022 | Statista 
5 Small and Micro Hydropower – European Rivers Network (ern.org) 
6 Documents | Cour des comptes (ccomptes.fr) 
7 2022 European Semester: Country Reports - European Commission (europa.eu) 

11 

 
 
largest nuclear energy producer globally after the U.S.A8. Conventional fossil fuel power plants add 
to the energy production related hydromorphological pressures because of the cooling water needed. 

In France 65% of the freight transport in tonne-km in 2022 was maritime and 2 % inland waterway9. 
Several  rivers  (Rhine,  Rhone,  Garonne,  Seine,  Scheldt)  and  added  canals  are  important  for  inland 
shipping and there are important harbours at the Atlantic and Mediterranean coast.  

The second most important significant pressure in France comes from agriculture. 41% of the surface 
water bodies (including FRK and FRL) are under pressure from diffuse pesticides and nutrient diffuse 
pollution  from  agriculture.  Eutrophication  of  the  surface  water  bodies,  and  some  coastal  areas is 
acute and recurrent episodes of green algae with massive discharges of algae can be observed in 
some coastal areas. This was the subject of a critical report of the French Court of Auditors10. Next 
to the pressure on the surface water it is a cause of great concern that 31% of the groundwater 
bodies are polluted by pesticides (in 84% of the failing GWBs) and nitrates (in 49% of failing GWBs) 
increasingly forcing to close drinking water wells.  France identifies in the 3rd RBMPs water abstraction 
as a significant pressure for only 2 RBDs, namely the Adour-Garonne RBD (FRF) and Mayotte RBD 
(FRM). The droughts faced in 2022 seem to have increased the awareness of abstraction pressures 
in more RBDs. Moreover, in the electronic reporting for surface water, abstractions in France (without 
FRK  and  FRL)  have  been  identified  as  a  significant  pressure  for  a  large  share  of  the  surface 
waterbodies (175) causing the failure to achieve good ecological status or potential. These SWBs are 
located in almost all RBDs with available e-reporting, excluding FRB2 Sambre.  Metropolitan France 
has only irrigation on 4.9% of the agricultural land, largely for (fodder)  corn, but these areas are 
concentrated  where  there  are  already  serious  episodes  of  water  stress.  Irrigation  is  much  more 
deployed in the outermost and overseas territories where 15% of the farmland is irrigated. 

8 France 2022 (iaea.org) 
9 Freight transport statistics - modal split - Statistics Explained (europa.eu) 
10 La politique publique de lutte contre la prolifération des algues vertes en Bretagne | Cour des comptes (ccomptes.fr) 

12 

 
 
 
Figure 1: Map of the monitoring points showing eutrophication assessment in  France, according to the 
reporting of the Nitrates Directive 

 Source: Joint Research Center of European Commission (n.d.). JRC NITRATES DIRECTIVE - Reporting Period 7 (2016-2019) 

Trophic 

Status. 

[online] 

water.jrc.ec.europa.eu. 

Available 

at: 

https://water.jrc.ec.europa.eu/portal/apps/dashboards/cb6034c2a75e4df282f8a62f90c16caa  

Note: 1% of the monitoring stations are above the threshold of 50mg/l 

Water abstraction (understood as consumptive use or net consumption) is identified as a significant 
pressure at the RBD level or in significant portions of an RBD for only two RBDs in France in the 3rd 
RBMPs e-reported in sept 2023, namely the Adour-Garonne RBD (FRF) and the Mayotte RBD (FRM) 11. 
This constitutes notwithstanding the limited number, a meaningful change since the 2nd RBMPs, when 
water  abstraction  was  not  reported  as  a  significant  pressure  in  any  RBD.  The  RBDs  Rhone-
Mediterranean  (incl.  Corse),  Reunion,  Martinique  and  Guadeloupe  do  not  report  abstraction  as  a 
significant pressure, in spite significant abstractions for irrigation and cooling.  

For  groundwater,  abstractions  have  been  identified  as  a  significant  pressure  for  73  groundwater 
12bodies  (GWBs)  (i.e.  10.6  %  of  total  GWBs),  which  are  in  poor  quantitative  status  in  2021. 
Furthermore, water abstraction is identified as a significant pressure for at least 91 GWBs (i.e. 13.2 
% of total GWBs), which are at risk of failing to achieve good quantitative status by 2027. For surface 
water, abstractions have been identified as a significant pressure for at least 17.3 % of total SWBs 
(1971 SWBs) failing to achieve good ecological status or potential.  

A recent increase in the construction of off-stream reservoirs, mainly for irrigation purposes, which 
are filled with groundwater in the winter, may impact the quantitative groundwater status, especially 

11 However, it is noted that quantitative management is acknowledged as 1 out of 4 Significant Water Management 
Issues (SWMIs) reported in the 3rd RBMP of the Loire-Brittany RBD and as 1 out of 7 Strategic Objectives reported in the 
3rd RBMPs of the Rhone-Mediterranean RBD. The potential contradiction with available e-reporting for these two RBDs 
needs further clarification by the country. 
12 These specific numbers are derived without counting FRK and FRL, these may be slightly higher as Reunion has water 
stress. 

13 

 
 
 
when the replenishment with climate change is structurally decreasing. This groundwater may be 
necessary for depending or associated ecosystems and thus this could put ecosystems are risk. Such 
reservoirs have raised legal, social and environmental concerns and are the subject of very heated 
debates and frequent litigations. 

The development of new reservoirs, dams and water transfers could be considered a maladaptation 
issue, if not properly justified with exemptions in accordance with all elements of Article 4(7) where 
necessary (see 3.7) and fully consistent with the water scenarios, investment planning, cost recovery 
and pricing policies, as laid down in the RBMP. Possible cumulative effects on the hydrological cycle 
and climate change should be considered. No information or justification has however been reported 
or announced regarding the mentioned water transfers or reservoirs in the 3rd RBMP reporting (see 
5.1). 

French water management is also facing increasing pressures from invasive alien species, impacting 
the ecology and/or the economy and even the social well-being. The pressure of invasive alien species 
is especially high in the French Outermost regions, having each their own list in the French legislation 
(e.g.  the  brown  rat  as  a  reason  for  bird  species  to  disappear).  Invasive  water  plants  that  are  of 
European and of French concern include 33 species relevant for fresh and brackish water in France 
including its Outermost regions. Plants like the yellow flowering water primrose (Ludwigia grandiflora) 
and the purple flowering water hyacinth (Pontederia crassipes) are fast multiplying and completely 
suppressing indigenous species in nutrient rich aquatic environments.  

Figure 2 : The most significant pressures on surface water bodies and groundwater bodies in France in the 
3rd RBMPs (expressed as percentages of numbers of water bodies) 

Source: 3rd RBMPs e-reporting 

14 

 
 
 
3. Policy elements contributing to biodiversity and 

climate change adaptation 

3.1 Surface Water: what is their ecological status or potential 

Monitoring 

France already had an extensive monitoring network in 2nd RBMPs. This has been a bit expanded and 
more biological quality elements are now monitored, giving a more precise picture of the ecological 
status.  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 in sufficient representative points 
aimed rather at identifying impacts and long-term changes.  

There  is  a  broad  coverage:  45%  of  all  river  water  bodies  are  monitored  for  River  Basin  Specific 
Pollutants (FRK and FRL not counted), 83% of the lake water bodies, 100% of the coastal and 89% 
of  the  transitional  water  bodies.  However,  the  monitoring  of  physico-chemical  quality  elements 
(including the nutrients) in coastal waters has been significantly decreased in the FRD and FRE river 
basin districts which concerns the Mediterranean coast. Whereas in the Atlantic coast, the monitoring 
of physico- chemical parameters is increasing in the FRF and FRH districts.  

As  regards  hydromorphological  quality  elements,  there  is  a  full  methodology  to  monitor  them 
including class boundary values for rivers and lakes. These quality elements are, however, monitored 
in a limited number of water bodies, despite the magnitude of the hydromorphological pressures. 
France  indicated  that  expert  judgement  is  used  also  to  complement  the  very  limited  data  on 
hydromorphological quality. 

For this planning period, 11 national new River Basin Specific Pollutants have been added, and one is 
declassified. They do not seem to be systematically monitored in all RBDs the same way, nor in all 
water body types and in a rather limited amount of water bodies. This makes it difficult to ascertain 
how they are considered in the assessment and what is their influence – as 11 substances extra may 
trigger failures- in the status assessment.  

Status assessment 

A  variety  of  different  methodologies  can  be  observed  in  the  different  River  Basin  Districts.  The 
assessments  seem  to  be  based  on  monitoring  data  featuring  different  types  of  gaps,  showing 
differences between the RBDs and among the types of water concerned. This reduces considerably 
the comparability between RBDs.  

The status assessments of many transitional and coastal water bodies may present a considerable 
uncertainty since they do not seem to have reference conditions and there are gaps on the data on 
nutrients. France does not have intercalibrated reference conditions for fish in transitional waters nor 
in  very  large  rivers,  and  for  benthic  fauna  in  very  large  rivers.  For  several  types  of  lakes,  the 
intercalibration of reference conditions for benthic fauna is in progress. It is worth mentioning that 
since there are no reference conditions set for hydromorphological pressures, as mentioned earlier, 
these pressures, defined as quite significant, are not considered in the status assessment, except for 
a few river and coastal water bodies in good ecological status. For the river water bodies, 80% of the 
water bodies now have a status assessment including consideration of data on nitrates. 53% of all 

15 

 
the  water  bodies  have  an  ecological  status  assessment  based  on  monitoring  and  1%  on  expert 
judgement (especially in outermost regions). It is worth mentioning that the monitoring of biological 
elements has improved and expanded, but with a significant higher relative frequency in rivers and 
lakes, than in transitional and coastal water bodies. The results of the phytoplankton monitoring show 
a slight improvement in the proportion of good status since the 2nd RBMPs, but a decrease for all 
other biological quality elements. 

Figure 2 shows the reported evolution of the ecological status in the 1st, 2nd, and 3rd RBMPs and the 
estimated achievement of “good or better status” or “achieved less stringent objectives” by 2027 and 
a small proportion of water bodies “failing to achieve good status by 2027”.  

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

Source: 3rd RBMPs e-reporting and datamining FRK 

The data shows a reduction in the number of water bodies in good  status which can be,  at least 
partially, explained by the increase in knowledge and monitoring. 

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.  As shown in Figure 3, the level of human intervention in the water 
system is very significant, particularly regarding lakes and transitional waters. The number of HMWBs 
and artificial water bodies compared to the 2nd RBMP are stable. The plans include the reasons that 
triggered the heavy modifications for HMWBs. No information could be found to explain the main 
causes for artificial water bodies.  

Environmental objectives have been set for all modified water bodies, but the definitions of the good 
environmental potential (GEP) for heavily modified water bodies (HMWBs) are not clearly established 
in  particular  as  regards  the  aspects  of  mitigating  and  compensating  measures.  The  details  vary 

16 

 
 
across the RBDs: for some RBDs, no information could be found, and for others, an indication was 
given that definition of GEP is still under development. A majority of France’s heavily modified water 
bodies still do not reach good ecological potential and 72 % of the HMWBs and AWs get lowered 
objectives in this 3rd RBMP applying Art. 4(5).  

Figure 4: Modification of water bodies for different categories 

Modifications 

Rivers (% of 
total rivers) 

Lakes (% of 
total lakes) 

Transitional 
Waters (% of 
total TWs) 

Coastal 
Waters (% of 
total CWs) 

Total 
(% of total 
SWBs) 

HEAVILY 
MODIFIED 

4,80% 

68% 

31% 

6,60% 

ARTIFICIAL 

1,20% 

15% 

0% 

0% 

7% 

2% 

It should be stressed that no information is found on the mitigation measures needed to reach a 
good ecological potential in the 3rd RBMPs, although these were reported in the 2nd RBMPs for the 9 
Metropolitan RBDs and for certain Caribean RBDs. It is important to start implementing the necessary 
measures for these water bodies before 2027 (see section 5.1).  

3.3 Groundwater bodies - have they sufficient water – quantitative status 

It  is  noted  that  72.6%  of  France’s  groundwater  bodies  (excluding  FRK  and  FRL)  are  subject  to 
quantitative monitoring. This may  seem a slight  reduction compared to the previous cycle, where 
74.7% had quantitative monitoring. As mentioned earlier, given the changes in delineation creating 
a 6,8% increase in groundwater bodies this is probably an operational consequence. Yet, given the 
increasing effects of climate change, France is advised to the improve their quantitative monitoring.  

The assessment of quantitative status considers general quality, as well as impacts on Groundwater 
Associated  Aquatic  Ecosystems  (GWAAEs)  and  impacts  on  Groundwater  Dependent  Terrestrial 
Ecosystems (GWDTEs), saline or other intrusions and impacts on drinking water protected points in 
all 12 RBD’s13. This is a significant improvement in methodology compared to 2015. Then GWAAEs 
and GWDTEs were not considered in all RBDs in the groundwater chemical assessment. 14. This is an 
improvement compared to the previous cycle, where they were not considered in all RBDs.  

However, the knowledge of the needs of these sensitive dependent ecosystems does not seem to be 
available for 75 % of the N2000 areas depending on these groundwater bodies (see 3.4) and for 
sensitive  aquatic  ecosystems  only  formal  surface  water  bodies  are  included. Hence  to  accurately 
consider  the  needs  of  ecosystems,  knowledge  should  be  improved  to  establish  an  accurate 
assessment of the good quantitative status. 

13 with e-reported data except FRK and FRL 
14 with available e-reporting at 1 sept 2023 

17 

 
 
 
 
Figure 5: The evolution of the good quantitative status over the different cycles including FRK and FRL 

Source: e-reporting complemented with datamining in FRK 

It  is  a  matter  of  strong  concern  that,  in  metropolitan  France,  at  least  10.6%  of  the  groundwater 
bodies are in poor quantitative status because of abstractions exceeding the available groundwater 
resource. This sometimes causes saline intrusions that have a very strong impact on ecological and 
chemical status. For one groundwater body the status is still unknown. The groundwater bodies in 
poor  quantitative  status  or  at  risk  of  failing  are  located  in  8  out  of  12  RBDs  with  available  e-
reporting15: Scheldt RBD (FRA), Rhine RBD (FRC), Rhone-Mediterranean RBD (FRD), Corsica RBD (FRE), 
Adour-Garonne RBD (FRF), Loire-Brittany RBD (FRG), Guadeloupe RBD (FRI), Mayotte RBD (FRM). Graph 
3.3  shows  the  evolution  compared  to  the  first  and  second  RBMP16.  This  percentage  in  poor 
quantitative status has largely been the same over the first two cycles (9% in the 2009 assessment 
and 10.2% in the 2015 assessment), but now it amounts to 11,9 %. This indicates a slight decrease 
in good quantitative status groundwater bodies which could be partially caused by the changes in 
delineation or a better assessment of the water needs of dependent ecosystems.  It is noted that 
France expects to achieve 100% good quantitative status by 2027 despite the stagnant situation. 

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

There  are  different types and  reasons  why  certain water  bodies  are  protected  under  the  law.  For 
surface water bodies, protected points and areas have been designated under the Drinking Water, 
Bathing Water, Habitats and Birds Directives as well as for areas designated for the protection of 
economically significant aquatic species (e.g. aquaculture). 

Protected surface water areas have been identified for all relevant Directives (Habitats, Birds, Drinking 
Water and Bathing). For groundwater, protected areas have been identified in relation to Article 7 -
for drinking water -and for the Habitats and Birds Directives areas dependent on groundwater. France 

15 not counting FRK and FRL 
16 including FRK (based on data mining) and FRL. (later than 1 sept e-reporting). 

18 

 
 
 
has also reported Nitrate Vulnerable Zones pursuant to the Nitrates Directive and sensitive areas 
pursuant  to  the  Urban  Wastewater  Treatment  Directives.  A  few  protected  areas  for  economically 
important aquatic species (shellfish) have been designated in transitional and coastal waters. The 
table below outlines the number of waterbodies associated with each of the protected areas in the 
Member State. 

Table 2: Number of protected areas in France by 2022, per type of protected area and type of associated 
water body, not counting FRK and FRL 

Protected area type 

Number of protected areas in France 

Rivers  Lakes 

Coastal 

Transitional  Groundwater 

Bathing waters 

Drinking water protection points 

648 

886 

356 

99 

Natura 2000 protected site 

3400 

195 

Nitrate vulnerable zone 

1694 

41 

Sensitive area 

7707 

317 

Shellfish designated water 

1242 

13 

299 

16 

131 

328 

93 

8 

161 

19 

99 

130 

27422 

372 

185 

The data on monitoring sites for protected areas indicate a reasonable coverage (i.e. comparison of 
the number of protected areas and number of monitoring sites). Some improvements are clear, the 
coverage of monitoring of drinking water protected points has improved since the 2nd RBMPs.  

There is regrettably little progress with the ecological and chemical status of surface water bodies 
associated  with  protected  areas  since  2016.  While  the  share  of  high  ecological  status  and  good 
chemical status has slightly increased between 2016 and 2022, the share of bad ecological status 
has also increased in the same period. For the relevant groundwater bodies only negligible changes 
are reported. 

Specific objectives for protected areas 

All  shellfish  protected  areas  have  additional  objectives  set.  For  all  shellfish  protected  areas,  the 
microbiological standards are different from those in the repealed Shellfish Directive 2006/113/EC. 
The reporting does not provide further information on whether the standards are stricter than the 
repealed legislation. The objectives have been met in 132 out of 458 water bodies (i.e. 29 %) and 
for five water bodies the set objectives have not been met. There is no information provided for the 
remaining 321 water bodies associated with shellfish protected areas. Why the additional objectives 
were not met is not explained.  

In Natura 2000 areas associated with surface water bodies (898 out of 405517), only 20 % of the 
sites have additional objectives and it is indicated that the needs are not yet known. None of the sites 
for which additional objectives have been set have met those. The causes for these failures could not 
bebe found. Out of the 1114 Natura 2000 sites associated with groundwater bodies18, 98% do not 
have additional objectives set. For 75% this is because the additional needs are not known, and for 

17 excluding FRK and FRL 
18 not counting FRK and FRL 

19 

 
 
 
 
 
 
 
23% (260), this is because WFD good status is deemed sufficient. Information on the achievement 
of the additional  objectives is only available for 23 Natura 2000 protected sites (2 %)  which are 
reported as not having met the objectives. The lacking knowledge necessary to correctly assess the 
quantitative status of 75% of the groundwater bodies with dependant N2000 sites is noted. None of 
the additional objectives for 2% reported being met in this reporting plus the 75% of unknown needs 
is creating high concern about the N2000 sites and the real quantitative status of the ground water 
bodies involved, now being reported mainly as good quantitative status. 

All drinking water protected points associated with surface water bodies have additional objectives 
set. The majority of these (70 %) have met the additional objectives. The information is not available 
for  seven  areas.  The  remaining  290  sites  (i.e.  29  %)  have  not  met  the  additional  objectives.  All 
drinking water protected points associated with groundwater bodies have had additional objectives 
set. The large majority (83 %) have met these objectives, while a further 15 % have not met these 
objectives. Information is not provided for 273 drinking water protection areas. France has received 
a reasoned opinion in February 2023 because of failure to fulfil the obligations under the Drinking 
water  Directive  as  regards  the  nitrates  in  drinking  water  supply  in  110  units  concerning  70  000 
inhabitants.  

Additional measures related to Protected areas 

Additional measures have been adopted for surface and groundwater bodies in some, but not all, of 
the assessed RBMPs. Whether additional measures are set or not depends on the type of protected 
areas. Additional measures were identified in the Rhone-Mediterranean RBD for Natura 2000 areas 
with a proven functional link to groundwater and / or surface water bodies and containing aquatic 
and wetland habitats of community interest. This concerned 6 % of the water bodies in the RBD. 
These  additional  measures  have  been  set  to  support  the  additional  objectives  of  achieving  a 
favourable conservation status for habitats by 2027.  

Measures for the protection of drinking water safeguard zones have been set up in all the four RBMPs 
assessed in detail19. Criteria for the establishment of the safeguard zones have been provided in the 
Rhone-Mediterranean RBMP, but not in the others. All drinking water safeguard zones are recorded in 
the national database SISE-EAU20 

3.5 What is being done to prevent/reduce hydromorphological pressures 

It is noted positively that France has created an inventory of all the obstacles crossing the water, 
which  includes  an  online  viewer  which  is  constantly  updated21.  A  positive  step  concerning  the 
mitigation of influences of dams and constructions on the flows in the water bodies was the adoption 
in 2006 of Article L214-18 in the French environmental law (water law), prescribing an obligation for 
constructions  to  keep  a  minimal  flow  in  the  channel  of  the  water  body  that  could  guarantee 
permanently the life, the circulation and the reproduction of species that lived in the water. This law 
has been reviewed in 2017 to create option to exempt water mills and in 2023 including a possible 
derogation  if  electricity  supply  would  be  threatened  or  seriously  undermined.  Compensatory 
measures should be financed by the extra income generated. 

19 FRA, FRD, FRI, FRM 
20 Système d’Information des services Santé-Environnement Eau 
21 L'Atlas-Catalogue du Sandre (eaufrance.fr) 

20 

 
 
As regards barriers in the rivers, progress has been made in the ecological continuity in France, and 
today  6  out  of  10  migration  barriers  in  French  hydropower  dams  have  been  equipped  with  fish 
migration aid so far. However, the remaining interruptions due to (partly obsolete) hydropower dams 
and registered obstacles still hamper river continuity. Worth mentioning is the restoration of river 
continuity in the RBD Seine-Normandy opening 500 km of river stretch in the Seine river basin and 
1000 km in the coastal area which are now accessible to the Atlantic Salmon. In particular, the biggest 
demolition of an old hydropower dam in Europe, the dam of Vézin which finished in 2022, has already 
allowed fauna and salmon to significantly recover and come back. 

A small increase in French hydroelectricity production is still foreseen till 2050. Given the >90% level 
of the potential already operational in hydropower production, this increase is a challenge, that may 
risk  putting  at  stake  surface  water  bodies  with  no  or  little  hydromorphological  pressures  if  the 
ecological values are not taken sufficiently into consideration. In the Programme of Measures, the 
following  key  type  measures  (KTM)  are  listed:  KTM5  -  Improving  longitudinal  continuity  (e.g. 
establishing  fish  passes,  demolishing  old  dams);  KTM7  -  Improvements  in  flow  regime  and/or 
establishment  of  ecological  flows;  KTM14  Research,  improvement  of  knowledge  base  reducing 
uncertainty;  KTM23  Natural  water  retention  measures;  KTM24  Adaptation  to climate  change.  The 
RBMPs  reported  the  following  KTMs  for  supplementary  measures  only:  KTM6  Improving 
hydromorphological conditions of water bodies other than longitudinal continuity.  

3.6 What France is doing for abstractions and water scarcity 

Measures related to water scarcity and abstractions are very different in the different RBDs. The 3rd 
RBMP was adopted before the new Plan Eau22 adopted in March 2023. The latter aims to stimulate 
reductions in water use, announcing 53 measures and setting targets for 2030 and accompanying 
funding.  

On average, between 2008 and 2018, the annual volume of water consumed in Metropolitan France 
is estimated at 5.3 billion m3 (or 82 m3 per inhabitant)23. Agriculture is the main water-consuming 
activity  at  45%,  followed  by  cooling  systems  for  power  plants  (31%),  drinking  water  (21%)  and 
industry (4%). The relative importance varies greatly per river basin, depending on: population density 
(Scheldt  -62%  and  Seine-Normandy-56%),  energy  production  (Rhone-Mediterranean-46%  and 
Rhine-Meuse- 58%) or share of irrigated agriculture (Adour-Garonne-78% and Loire-Brittany-55%). 
These statistics consider abstracted volumes, not the net consumption that is integrating the notion 
of the return flows to the regional water system. 

Just as in the previous cycle, in the 3rd RBMPs, basic and supplementary measures to address water 
abstraction  have  been  planned  in  the  two  RBDs  where  abstractions  have  been  identified  as  a 
significant pressure.  These measures include authorisations and registrations. Water abstraction is 
regulated under the Environmental Code.  Abstractions are recorded in a publicly available national 
database.  France  has  delineated  “water  distribution  areas”  (ZRE in  French)  that  are  affected by a 
chronic  lack  of  water  in  relation  to  needs  (water  stress).  In  these  ZRE’s  either  declaration  or 
authorization is required for abstractions above 8m3/h. The 3rd RBMP did not report on the periodicity 
of controls, nor about the frequency of updates of such authorizations. The duration of validity of 
single abstraction authorizations cannot exceed 15 years. Regional water authorities are obliged to 
establish a water balance at sub-basin level for these ZRE regions and only on the basis of a water 

22 Présentation du Plan eau. | Élysée (elysee.fr) 
23  Eurostat data 

21 

 
 
balance  grant  permits  for  water  abstraction.    In  non-ZRE-areas,  abstractions  under  1000m3/year 
(groundwater)  and  under  10.000  m3/year  (surface  water)  are  not  subject  to  authorization  or 
declaration.  However,  the  competent  authority  may  impose  any  measures  necessary  to  prevent 
damage or environmental degradation.  

Relevant measures on defining and implementing e-flows are ongoing before 2015 but regrettably 
programmed to be finished in 2027. Measures related to control of abstractions and water efficiency 
were  implemented  in  the  previous  cycle  and  they  are  also  planned  for  this  cycle.  The  national 
hydrogeological institute BRGM publishes every month the relative level of the groundwater bodies24. 

Natural water retention is encouraged, increasingly so in the Plan Eau of March 2023 (see end of 
this  paragraph).  It  is  to  be  noted  that  France  aims  to  double  the  agricultural  area  under  organic 
farming by 2027 to reach 18% of the total agricultural area. However, the French 3rd RBMPs contain 
also provisions to build reservoirs and perform water transfers to increase water supply.  

International cooperation is established in the Meuse, the Scheldt and the Rhine, including on water 
abstraction  /  scarcity  issues:  joint  monitoring,  planning,  stakeholder  engagement,  measure 
implementation and exchanges of practises with low flows. 

3.7 Adaptation to climate change 

All  RBMP’s  include  an  objective  to  ‘adapt  to  the  effects  of  climate  change’,  with  a  series  of 
measures  related  to  (inter  alia)  water  management,  restoration,  and  conservation  in  separate 
documents. The information included in the RBMPs is more generic and  dwells on the impacts of 
climate change, without clear indication how these impacts have been considered for the Programme 
of  Measures  in  the  RBMPs  or  in  the  status  assessment.  France  has  adopted  a  National  Climate 
Change Adaptation Strategy in 2006 and published  a National Adaptation Plan for Climate Change 
(PNACC)on 25 October 2024. The governance for the RBMPs and the Climate Adaptation Plans is the 
same in all river basins, which normally should ensure coherence. The country uses different Models 
– Explore 1 and 2- to identify ranges of impacts to take into account in water management.25 The 
respective RBMPs (2022) do not report any surface or groundwater bodies having failed to reach 
good status due to climate change. 

As  regards  floods,  all  five  Flood  Risk  Management  Plans  assessed  refer  to  the  importance  of 
adaptation to climate change and outline measures to address the expected effects of climate change 
on  the  likelihood  and  potential  adverse  consequences  of  flooding.  The  Adour-Garonne  (FRF)  plan 
having its first objective on adaptation. Three of the five FRMPs refer to coordination with the national 
adaptation  strategy,  and  all  five identify  measures to  address  climate  impacts.  All  five  refer  to  a 
heightened  frequency  of  extreme  events  by  2050,  with  the  Escaut  (FRA)  and  Rhine  (FRC)  placing 
particular emphasis on the predicted intensification of winter precipitation and a decrease in total 
cumulative summer precipitation (albeit with risk of heavy rainfall in summer). The FRMP of the Rhine 
(FRC) refers to a heightened frequency and intensity of pluvial floods from heavy rainfalls. The FRMP 
of the Adour-Garonne (FRJ) predicts a significant increase in flooding due to sea-level rise. The second 
FRMPs assessed provide details on climate change impacts, including how that information was used 

24 État des nappes d'eau souterraine | BRGM 
25 Inforegio - Compendium of good practices and solutions for climate change adaptation in the Outermost Regions of the 
EU (europa.eu) 

22 

 
 
to develop the plans. Additionally, more detailed studies on how climate change might impact flooding 
have been carried out.   

As regards droughts, there are no national requirements to produce drought management plans, but 
voluntary instruments that address water stress at local scales (the PTGE, arrêté sècheresse, SAGE) 
are used to prevent or reduce water stress. After the extreme long drought of 2022 France adopted 
the Plan Eau (see 3.6), with 53 measures to reduce water use in all sectors and reducing leakages in 
networks, including new drought management guidelines26.” The country recently also took a number 
of measures to better predict and mitigate drought risks including public access to this information. 
As the RBMPs were reported before the drought of 2022, these recent drought related measures are 
not in the RBMPs. While not mentioned clearly in France’s 3rd RBMPs, the construction of “substitution 
or  alternative  reservoirs”  filled  with  groundwater  during  winter  months  for  irrigating  farmland  is 
raising  concerns  for  the  viability  of  groundwater  depending  terrestrial  ecosystems  and  e-flows  in 
surface water bodies. 

4. Policy elements contributing to zero pollution 

4.1 Surface Water: what is their chemical status 

Monitoring  

The scale of the monitoring network varies by RBD, including less developed monitoring networks 
particularly for overseas territories. The overall monitoring network has been expanded further in the 
3rd RBMPs though France already had an extensive monitoring network for chemical status before. In 
2016, 71 % of all lakes, 24 % of all river water bodies, 63 % of all coastal water bodies and 89 % 
of all transitional water bodies were covered by a monitoring site. It is noted that 10 out of the 12 
RBDs27  conduct  operational  monitoring  for  chemical  status  compliance  with  the  minimum 
requirements of the WFD, including all mandatory substances (45PS and 8 EQSD substances). The 
review  of  the  2nd  RBMPs  stated  Metropolitan  France  included  41  substances,  but  that  overseas 
territories deviated with 5 substances less. The number of sites and the frequencies of monitoring 
for biota and sediment illustrates a significant spatial scale diversity for biota monitoring with a at 
least the minimum frequency.  

Status assessment 

It is noted that it is difficult to conclude on the level of confidence of the chemical status assessments 
from the reported data. The number of unknowns has steadily decreased over the 3 cycles as shown 
in figure 5 including FRK28 and FRL.  

Especially  in  French  Guyana  improved monitoring  shows  part  of  unknown  upstream  water  bodies 
from the 2nd RBMP are chemically polluted. Legal and illegal goldmining activities are related to this 
upstream mainly mercury related pollution. Illegal mining uses mercury to concentrate the gold. Legal 
mining causes the naturally in the soils present mercury to get released through excavating.  

26 Guide circulaire secheresse-conforme1605.pdf (ecologie.gouv.fr) 
27 electronically reported by 1-09-2023 
28 on the base of datamining of the pdf 

23 

 
 
 
 
Figure 6: Chemical status for surface water bodies in France by 2010, 2016 and 2022, for all water bodies 
including datamining for FRK 

Source: 3rd RBMPs electronic reporting including datamining FRK 

Results are mixed since there is a considerable improvement in the knowledge, with less unknowns, 
there is also a positive trend with an improvement in proportion of waterbodies in good chemical 
status surface water bodies but also there are more surface water bodies in poor chemical status.  
There is a small number of substances that have a very significant effect on the number of SWBs 
that fail to achieve good chemical status. These can be seen in Figures 6 and 7. 

Figure 7: The top-10 Priority Substances causing failure to achieve good chemical status in surface water 
bodies in France by 2022 (legally required 33 Priority Substances) 

24 

 
 
 
Figure 8: 
surface water bodies in France by 2022 (new 1-45 Priority Substances)2930 

The  top-10  Priority  Substances  causing  failure  to  achieve  good  chemical  status  in 

The poor chemical status of surface waters in France is attributed to PAHs (5 of the top 10 priority 
substances), mercury and PFOS. PAHs are caused by various kinds of combustion processes and are 
affecting more than  70% of  the  water  bodies.  This is  similar  to  the  2nd  RBMP where  80%  of  the 
surface water bodies had too high PAH concentrations. PFOS was only mandatory for monitoring but 
is emerging as a widely spread very toxic and persistent pollutant even more present than mercury 
inside Metropolitan France. The % in number of water bodies failing because of mercury increased 
also from 12% (2nd RBMP) to 16% in the 3rd. This increase is substantial as more water bodies are 
assessed now compared to the 2nd RBMP.  

Without  counting  the  uPBTs  France  would  be  having  78%  instead  of  68%  good  chemical  status 
surface water bodies. 

Next to the uPBTs there are two pesticides, isoproturon and cypermethrin causing failure in the French 
assessment, although cypermethrin (added in 2013) also is just mandatory to monitor. To be noted 
that France is the biggest consumer of pesticides of the countries reporting their sales to Eurostat, 
but also having a big area of utilised agricultural land. It is worth noting that some overseas territories 
have other priority substances that are key. For example, RBD Martinique indicates that lindane (a 
banned pesticide) is the main pollutant causing failure. 

4.2 Groundwater Bodies: what is their chemical status 

Monitoring  

In  the  3rd  RBMPs  82%  of  the  689  groundwater  bodies  are  monitored  for  chemicals31,  which  is  a 
relative important decrease compared to the 85% of a smaller number of groundwater bodies in the 
2nd RBMPs. 10 groundwater bodies in poor status are not monitored in the RBDs FRF and FRG. 47 

29 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.  

30 France included PFOS and cypermethrin in their status assessment, instead of only monitoring them; though it was not 
mandatory to include these substances in the chemical status assessment.  

31 not counting FRK and FRL 

25 

 
 
 
 
Groundwater bodies of poor status have no operational chemical monitoring, mainly in FRG. All the 
mandatory substances are monitored in all RBDs. 

Status assessment 

The assessment of the general chemical situation of a groundwater body is based on the harmonised 
methodology proposed in the EU Guidelines,32 . Figure 8 shows the evolution since the 1st RBMP33, 
and a slight decrease in good status from 69,1% to 68%. This apparent deterioration of 1,1% of the 
groundwater bodies could be partly related to the improved assessment and perhaps partly due to 
the new delineation of GWBs. 

Figure 9: Chemical status of groundwater bodies (% of numbers of GWBs)  by 2009, 2015 and 2021 

Source e-reporting complemented with data mining for FRK 

Comparability  between  2nd  and  3rd  cycles  is  hampered  by  the  significant  new  delineation  of 
groundwater bodies. Despite no noticeable improvement over the cycles till 2022, France expects in 
the e-reporting of 2022 and 2023 that 90% of groundwater bodies will be in good chemical status 
or meeting environmental objectives by 2027.  

The top five pollutants causing failure to achieve good chemical status of groundwater bodies are 
pesticides  including  their  relevant  metabolites  followed  by  nitrates,  chloride,  ammonium,  total 
trichloroethylene and tetrachloroethylene, and phosphate. It is noted that more than one substances 
may  cause  failure  to  the  same  groundwater  body.  Nitrates,  pesticides  including  their  relevant 
metabolites and electrical conductivity show sustained upward trends in groundwater bodies. This 
shows that the pressures from agriculture on the groundwater bodies are sustained.  

32 CIS Guidance document 18 (2009): Groundwater status and trend assessment, derived as a ‘conceptual model’ in line 
with point 3 of Annex III (Assessment of groundwater chemical status) of the GWD. 
33 including FRK (based on data mining) and FRL 

26 

 
 
 
Figure 10: Top-5 groundwater pollutants causing failure of good chemical status in groundwater bodies 
in France by 2021 proportional to the total of failing GWBs 

The same types of diffuse pollutants cause the failure in status for 31.1% of the total groundwater 
bodies which are including drinking water protected points. This used to be 38% in the previous cycle 
with 6,8% less groundwater bodies. Thus, with the caveat that there are comparability problems, 
there may be a slight improvement for the chemical status of groundwater bodies related to diffuse 
agricultural pollution. 

4.3 What France is doing to combat pollution from agriculture 

Agriculture  has  been  identified  as  a main  pressure in  all metropolitan  RBDs in  France,  mainly  for 
diffuse  pollution,  including  predominantly  pesticides  followed  by  nitrogen  and  phosphorus.  In  the 
RBDs reviewed in detail34 no quantified gap assessment could be found. That means that there is no 
estimation of the necessary load reduction of pesticides and nutrients by agriculture to achieve good 
status in each RBDs. RBD FRG has however produced a quantified gap analyses for nutrients related 
to  the  coastal  water  eutrophication  problems  (Algae  Vertes).  This  is  not  coupled  to  a  quantified 
approach for the various sources. The PoMs for all RBDs include information on the number of water 
bodies for which an agriculture targeting measure is planned in the 3rd RBMPs, but no indication of 
how  much  the  reduction  in  emissions  should  be.  This  gap  also  exists  for  transitional  waters 
downstream.  France features 9% of agricultural land under organic farming and intends to double 
this to 18 % by 202735 with support from the CAP Strategic Plan (2023-2027). This is extremely 
important as the main pressure on the quality of groundwater is diffuse agricultural pollution, mainly 
pesticides and nitrates. Under the CAP Strategic Plan, France also plans to support commitments for 

34 FRA, FRD, FRI and FRM 
35 At a glance: France’s CAP Strategic Plan (europa.eu) 

27 

 
 
 
 
 
 
improved pesticide management on 61% of its agricultural area36. A Nitrates Action Plan was adopted 
in 2020 but pressures on the status of ground water bodies are predicted to keep increasing until 
2027. 

The description and level of details for the specific agricultural measures vary across the RBMPs. In 
general, they all describe that measures for agriculture include basic (mandatory) and supplementary 
measures. The PoMs in the 3rd RBMPs include detailed fiches for water bodies where the measures 
are  applicable,  the  area  covered,  and  the  objectives  targeted  are  presented.  The  basic  measures 
comprise the  nitrate  action  programmes,  regulations  on  the use  of plant protection products,  the  
conditionality of the Common Agricultural Policy37, the implementation of the Ecophyto II+ plan and 
the  establishment  of  catchment  protection  areas  around  drinking  water  catchments.  In  the 
description of the basic measures, it is further described that there are supplementary measures 
based  on  extending  requirements  beyond  what  is  required  by  for  example  the  Nitrates  Directive. 
Additional  measures  are  present  in  high-stake  areas  such  as  drinking  water  catchment  areas, 
catchment  areas  subject  to  erosion  or  green  algae  bay  catchment  areas  (in  Brittany).  These 
supplementary measures are financed through CAP (2023-2027) support  The use of pesticides is 
explicitly addressed in the RBMP of the intensively agriculturally used Seine-Normandy.  The RBMP 
notes  the  importance  of  measures  for  reversing  the  trend.  The  National  Plan  Ecophyto  II  was 
particularly  important  for  this  objective,  thus  its  pausing  can  be  a  serious  drawback  for  the 
achievement of the environmental objectives. It is very important that the new PoMs do not include 
new measures but rather rely on prioritising the full implementation of the defined measures in 2015. 

4.4 What France is doing to combat pollution from other sectors 

France has taken many measures to address pollution from other sectors than agriculture. All the 
pressures  identified  from  industry  and  urban  wastewater  treatment  are  covered  by  measures 
associated with Key Type Measures (KTMs). All RBDs have planned targeted measures, but there is 
no quantified gap analyses for the substances involved, nor estimated efficiency of the measures 
programmed in most RBDs. 

The French gap assessment consists of reporting the number of water bodies where pollution from 
other sectors and sources than agriculture requires (further) measures. This includes the number of 
water bodies affected by specific hazardous substances (both Priority Substances and River Basin 
Specific Pollutants). The dates by when the good status is expected to be achieved has been reported 
in a few cases. A gap analysis is included in the Seine Normandie RBMP, it presents the percentage 
of emissions reductions needed by chemical substance to reach the objectives of the WFD by 2027. 

Measures  to  reduce  point  source  emissions  in  all  RBDs  include  improvement,  upgrade  and 
reconstruction of urban and industrial wastewater collection and treatment. The ongoing procedure 
before the recent Court ruling (C-268/23) which condemned France for about non-compliance with 
the  Urban  Wastewater  Treatment  Directive  in  78  agglomerations  must  be  mentioned  here  as 
wastewater treatment plants are a crucial step to reduce nutrients from wastewater. The court case 

36 See “Mapping and analysis of CAP strategic plans” (2023-2027) 
(file:///C:/Users/faltech/Downloads/mapping%20and%20analysis%20of%20cap%20strategic%20plans-
KF0323354ENN%20(3).pdf) 
37 “Mapping and analysis of CAP strategic plans” (2023-2027)  the link Mapping and Analysis of CAP Strategic Plans 
- European Commission (europa.eu) 

28 

 
 
 
concerns fifteen agglomerations of over 2000 inhabitants failing to meet the additional requirements 
related to the protection of sensitive areas from nutrients. In July 2024 the European Commission 
decided to refer France to the Court of Justice of the European Union for failing to comply with the 
maximum  nitrate  concentration  in  drinking  water  set  in  the  Drinking  Water  Directive  (Directive 
(EU)2020/2184).    Sometimes  stormwater  basins  to  prevent  overflows  of  the  sewage  are  also 
explicitly targeted as measures. To specifically reduce pollution with priority substances and RBSPs, 
various measures are planned to address these, without however the same level of clarity in all RBDs 
as  regards  which  substances  are  addressed  to  what  extend  by  which  measures  and  where.  The 
various RBDs do include knowledge increase on micro pollutants and on technical and economical 
feasible  solutions  for  improved  treatment  in  various  industrial  sectors.  Controlling  and  updating 
discharge permits and connections to sewage networks, reducing emissions from various industrial 
processes (some RBD’s mention specific sectors, other RBDs do not), reducing discharges from port 
activities (wastewater, dry-docking areas, etc.) on the coast and navigation axis is mentioned in a few 
and managing and reducing pollution from abandoned contaminated sites or significant sources of 
contamination.    Measures  are  foreseen  to  suppress  and  minimize  Guyana’s  chemical  pollution 
because of legal and illegal gold mining activities by 2027 for the water bodies that are in the nature 
reserves  or  in  the  national  parc.  For  surface  water  bodies  outside  the  protected  areas  (10%  of 
Guyana’s surface water bodies and approximately 1% of the total French) exemptions are foreseen 
to reach good status after 2027. 

4.5 What France is doing to combat significant pressures – overall 

assessment of the Programmes of Measures 

Compared to the previous cycle, the relationship between the measures and the pressures is better 
established. Indeed, all significant pressures are associated with a Key Type of Measure (KTM) and 
an extensive list of national measures. Basic measures are reported against all  except one of the 
requirements  of  Article  11(3)  of  the  WFD.  It  is  also  conveyed  that  a  large  number  of  individual 
substances, including both River basin Specific Pollutants and  Priority Substances, have also been 
addressed by  KTMs.  France  has  adopted  187  national  basic measures  clustered  in  19 predefined 
KTMs. In addition, a total of 838 national supplementary measures have been adopted and clustered 
against  21  predefined  KTMs  and  one  nationally  defined  KTM.    The  application  of  both  basic  and 
supplementary  measures  varies  between  RBDs.  In  all  the  RBMPs,  the  KTMs  reported  as  tackling 
significant pressures in each RBD include national basic and / or supplementary measure. However, 
what remains unclear is their effectiveness and proportion of supplementary measures  which are 
mandatory as opposed to voluntary. On the other hand, there are national measures which have not 
been  reported  as  tackling  significant  pressures.  Therefore,  these  may  not  yet  have  been  put  into 
operation. The four screened RBMPs feature different approaches and levels of details in the reporting 
of the cost-effectiveness analysis and in the explanations of how such analysis influenced the final 
prioritisation of measures. Information on cost effectiveness and prioritization is lacking completely 
for some RBMPs as well.  

A critical factor in the success of the PoM is the availability of budget/funding. The information on 
the sources of  funding varies very considerable  among the 3rd RBMPs of France. In  some, public 
costs  as  well  as  costs  of  private  operators  are  included  (to  be  funded  privately  by  individual 
companies). In other RBMPs no private funding is mentioned and fewer details are provided.  France 
identified several obstacles which are responsible for the lack of progress in the implementation of 
measures. These include delays, lack of finance, lack of governance mechanism. It is conveyed that 

29 

 
  
it is considered that international cooperation is well coordinated with the national programme of 
measures and both dimensions are complementary. 

5. Exemptions and economics 

5.1 To what extent are exemptions applied in France 

According to the Water Framework Directive, 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. Exemptions should 
be well documented and applied restrictively as a last resort. They should regularly be reviewed if 
still  justified.  France  has  applied  a  significant  number  of  exemptions  of  different  types  in  the  3rd 
RBMPs.  These  exemptions  are  justified  with  short,  standardized  sentences  in  a  tabular  form. 
References for underpinning studies for most justifications are missing in the RBMP’s and in many of 
the background documents. It should be noted that more than one exemption type can be applied to 
the same surface or groundwater body. 

There has been a national instruction in 2020 how to deal with the formal WFD deadline of 2027. 
The general rule was to keep as high a level of ambition in the environmental objectives as possible. 
This was further detailed by a nationally determined limited increase in percentage of water bodies 
in good ecological status to be achieved in 2027, which varied for the various RBDs. This incremental 
improvement  was  the  result  of  stakeholder  involvement.  For  those  water  bodies  where  no  good 
status would be achieved in 2027 lowered objectives could be considered and had to be justified 
pursuant to Article 4(5). 

Figure 11: Type of exemptions reported to be applied to surface water and groundwater bodies for the 
3rd RBMPs in France, not counting FRK and FRL  

Source: 3rd RBMPs e-reporting 

Note: ecological status and groundwater quantitative status exemptions are reported at the water body level. 
Chemical  exemptions  for  groundwater  are  reported  at  the  level  of  each  pollutant  causing  failure  of  good 

30 

 
chemical status, and for surface waters for each Priority Substance that is causing failure of good chemical 
status For the purposes of this Figure the number of water bodies exempted for chemical status is used. Please 
note that while the WISE reporting uses a label “Article 4(5)- Technical feasibility” it should be read as “Article 
4(5)- Infeasibility”. Please note that the same water body can be exempted on multiple grounds. 

Article 4(4) 

Time related exemptions under Article 4(4) WFD are applied on the grounds of disproportionate costs, 
technical feasibility and natural conditions. A water body can have a 4(4) exemption on the grounds 
of technical feasibility as well as on the grounds of disproportionate costs or only one ground. The 
information  provided  to  justify  the  exemptions  was  limited;  no  references  were  made  to  specific 
characteristics of the individual water body nor references to underpinning studies. According to the 
electronic reporting, in France (not including Guyana and Reunion), the exemptions according to Article 
4(4) have been presented:  

A.  on grounds of technical feasibility: 

•  groundwater bodies:  

80 GWBs or 11.6 % for chemical status  

45 GWBs or 6.5 % for quantitative status  

• 

for surface water bodies:  

2714 SWBs or 23.8 % for ecological status/potential  
2230  s or 19.6 % for chemical status)  

B.  on grounds of disproportionate costs:  
for groundwater bodies:  

60 GWBs or 8.7 % for chemical status 

• 

5 GWBs or 0.7 % for quantitative status  

• 

for surface water bodies: 

161 SWBs or 1.4 % for ecological status / potential, and 
47  WBs or 0.4 % for chemical) 

C.  on grounds of natural conditions: 
for groundwater bodies:  

 118 GWBs or 17.1 % for chemical status, and  

• 

 9 GWBs or 1.3 % for quantitative status 

• 

for surface water bodies:  

 403 SWBs or 3.5 % for ecological status / potential and  

1269 SWBs or 11.1 % for chemical status). 

Article 4(5)  

Under Article 4(5) France lowers the WFD- objectives for 2027 of at least 32% of the surface water 
bodies for the ecological status and at least 15.5% of the groundwater bodies for the chemical status. 
More than one exemption justification ground (infeasibility or disproportionate costs) is often invoked 
for the same water body, often also on top of more types of exemptions (i.e. for ecological status and 
for chemical status). It must be noted that in the previous cycle France lowered the objectives under 
Article 4(5) for only approximately ten water bodies (out of approximately 10000 water bodies). Thus, 
this  change  in  this  cycle  has  a  very  strong  impact  on  the  expected  water  body  status  in  2027. 
Sometimes France considers that the lowered environmental objectives have already been reached 

31 

 
 
 
 
   
 
 
 
 
 
 
       
 
 
 
 
 
in  2021  and  others that they  will  be  reached in  2027.  This  approach  of  switching  to  Article  4(5) 
reduces  the  number  of  Art  4(4)  exemptions  invoked  (see  fig  8.2),  especially  compared  to  other 
Member States using mainly Art.4(4). Article 4 (5) exemptions are justified with information provided 
at  the  water  body  level  in  a  tabular  short,  standardised  sentence  format  having  the  same 
shortcoming  highlighted  for  the  Article  4(4)  exemptions.  According  to  the  electronic  reporting  for 
France (except for French Guyana and Reunion), Article 4(5) exemptions have been applied.  

A.  on the grounds of infeasibility  
• 

for groundwater bodies:  

107 GWBs or 15.5 % for chemical status, and  

13 GWBs or 2 % for quantitative status  

• 

for surface water bodies: 

3635 SWBs or 32 % for ecological status, and  

45 SWBs or 0.4 % for chemical) and   

B.  on grounds of disproportionate costs 
• 

for groundwater bodies:  

7 GWBs or 1 % for chemical status, and  

• 

for surface water bodies: 

1 SWB or 0.01 % for chemical status, and  

3 GWBs or 0.4 % for quantitative status  

1840 SWBs or 16 % for ecological status / potential.  

This  lack  of  underpinning  or  references  is  especially  regrettable  as  the  relevant  WFD  provisions 
require  to  set  out  and  explain  in  the  RBMPs  the  reasons  for  each  exempted  water  body.  The 
Commission has, in its reports on the first and second RBMPs, issued the recommendation to provide 
more detailed justifications for exemptions under Article 4(4) and Art 4 (5), in particular to develop a 
more  consolidated  methodology  to  justify  exemptions  to  the  achievement  of  environmental 
objectives (in particular as regards the assessment of affordability and disproportionate costs). 

Article 4(6) and Article 4(7) 

It is noted that while seemingly no exemptions have been declared under Article 4(6) and Article 4(7) 
these are mentioned in the reported plans in some RBDs. This also may seem at odds with the widely 
reported  development  of  storage  and  water  transfer  capacity  in  France.  However,  two  RBMP’s 
(Mayotte  and  Artois-Picardie/Scheldt)  include  information  on  several  Article  4(7)  exemptions.  This 
discrepancy in the 3rd RBMP reporting from France is noted. 

5.2 Use of economic analysis and water pricing – cost recovery 

France has an updated economic analysis based on long term water supply and demand scenarios 
but  not  (yet)  linked  to  climate  adaptation.    The  updated  analysis  discusses  the  effects  of  policy 
measures as well as of water pricing on water use efficiency. It is however not yet based on long 
term water supply and demand scenarios (well beyond 2027) linked to climate adaptation scenarios. 
A study (Explore2) recently published in June 2024 will make this possible in the 4th RBMP report. 
Estimates of relevant investments are provided as totals and for water supply and sanitation services 
separately. These are also considered for calculating cost recovery rates.  

As  regards  funding,  all  RBMPs  describe  prioritisation  criteria  used  to  build  their  Programme  of 
Measures. The levels of detail reported vary on the cost effectiveness analyses applied and the way 
cost effectiveness was used in the total prioritisation. Some RBDs are not reporting information on 
cost  effectiveness  at  all.    The  four  RBMPs  assessed  in  detail  (Scheldt,  Rhone-Mediterranean, 

32 

 
      
 
 
 
 
       
 
 
 
 
Guadeloupe and Mayotte) included an assessment of costs of PoMs and specifically for agricultural 
measures. Only the Rhone-Mediterranean RBMP specified funding sources for agricultural measures 
or the implementation of the PoM overall. For all RBMPs funding for the measures came from national 
as well as EU funds.  

Water services, cost recovery rates and subsidies 

A new national study calculates cost-recovery rates of the two broad public water services (drinking 
water supply and sanitation) in the different river basin districts, while individual water services (such 
as water reuse, storage and impoundments) are not recognised as such. A list of water uses with 
significant impact on water bodies has been identified, and households, industry and agriculture as 
the (broad) water user sectors (usually the only user sectors mentioned).  Hence, the RBMPs all report 
three types of cost recovery rates, varying in the inclusion of yearly and renewal investments. The 
reported  rates  are  often  well  below  100%  when  including  the  investments;  only  in  the  Rhone-
Mediterranean  the  cost  recovery  rates  are including  the investment.  The  subsidies  on  operational 
costs as well as the limited recovery of investments costs do not seem clearly justified. For the Rhone-
Mediterranean the cost recovery rates differ over the water user sectors, as farmers pay less than 
three quarters of the reported operational costs of the services they use, while industries pay slightly 
more than the operational costs they generate. The RBMPs tend to provide clear, explicit information 
on tariffs and revenues as well as on subsidies, but an explicit justification on the role of the water 
tariff and charges as adequate incentives is missing. All RBDs reported subsidies on operational costs 
of  water  services.  The  two  oversea  districts  of  Guadeloupe  and  Mayotte  indicate  also  subsidies 
directed  at  water  users.  The  reporting  on  the  revenues  of  water  abstraction,  pollution  and  other 
water-related charges varies over RBMPs . It is noted positively that in all screened RBMPs, volumetric 
pricing systems are in place for drinking water and irrigation; together with the reported unit rates 
increasing with volume, they provide a clear incentive. However, the widely absent pricing of resource 
costs, and, more generally, the low cost-recovery rates suggest that the incentive function of the 
pricing instrument is well below its potential.  

Environmental and resource costs and the Polluter Pays Principle 

The  reported  pricing  in  the  four  studied  RBDs  (Scheldt,  Guadeloupe,  Mayotte  and  Rhone- 
Mediterranean) reflect the national price regulation which foresees one joint tariff for the two broad 
water services: drinking water supply and sanitation services. The RBMPs do not indicate that water 
body status or scarcity conditions are considered when defining water prices. Irrigation water pricing 
schemes (as reported by Guadeloupe and Rhone-Mediterranean) also have a volumetric component. 
There seems to be no national pricing framework for irrigation. Only constant rates per m3 have been 
reported with regards to irrigation (no increasing unit rates). Information is missing as to whether 
scarcity  conditions  are  considered  in  setting  irrigation  water  prices.  Likewise,  water  abstraction 
permits require the payment of an abstraction fee which is related to the actual volume of water 
abstracted, but unrelated to the degree of scarcity. The RBMPs provide quantitative estimates through 
a dedicated model of water economy, for environmental costs, often split over households, industry, 
and  agriculture.  It  remains  unclear  whether  the  environmental  costs  include  the  resource  costs 
(related  to  costs  of  scarcity).  The  calculations  reported  show  outcomes  that  suggest  a  low  cost-
recovery for environmental costs. Hence there is a need to widen the application of the polluter pays 
principle through identifying bottlenecks in recouping pollution costs preferably from polluters rather 
than  the  water  services  customers  in  general.  Environmental  damage  is  hence  not  yet  being 
sufficiently compensated; the related issue of adequate contributions from the different water user 
sectors not addressed. 

33 

 
6. WFD recommendations 

Recommendations - France should: 

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

In particular, 

a)  Better quantify the gaps to be bridged to reach the objectives per river basin, including higher clarity 
about the quantified challenges to be met by the various economic sectors and the measures to be 
taken to also meet the downstream objectives for sensitive water bodies,  

b)  Provide a detailed quantitative assessment of the additional need for measures to address nutrients, 
pesticides, and pollution, including attention for hydromorphological pressures and the contribution of 
mitigation measures from all the sectors in all RBDs.  

c)  Assess 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 measures at water body level.  

2. 

identify  and  put  in  place  additional  measures  to  reduce  existing  persistent  environmental  challenges 
(pressures) preventing the achievement of good status based on robust gap analyses. This implies, inter 
alia:    

a)  Stepping up action to drastically reduce nutrient pollution. Assessing for each measure what achieve 
benefit will be. This should consider the achievement of the objectives of WFD, MSFD and ND with 
particular focus on the vulnerability of transitional and coastal waters on all French and transboundary 
influenced coasts. The share in the effort of all relevant economic actors should be addressed for each 
water body. 

b)  Addressing pesticide pollution by reducing their use and phasing out unsustainable practices as well as 
emissions of most relevant priority substances, including by reviewing permits (namely PAH’s, mercury, 
pesticides cypermethrin and isoproturon, polybrominated diphenyl ethers (PBDEs), and including some 
problematic  priority  substances,  like  Lindane  (HCH),  as  key  issue  in  Outermost  regions  and  where 
possible PFOS). 

c) 

Including a more frequent than the presently once every 15 years periodical review of abstraction and 
impoundment permits as well as other permits related to hydromorphological changes and describing 
how this review is implemented and enforced in the following RBMPs to take into account the impact 
of climate change.  

d)  Stepping up action to drastically improve river continuity, ensuring minimum ecological flows, improve 

the general hydrological situation also in cooperation with neighbouring countries. 

e)  Expanding the efforts on nature-based solutions including re-naturalisation and ecosystem restoration 

which will reduce the hydromorphological pressures on water bodies.  

f)  The drinking water points need improved protection measures as many wells are already closed or at 

risk to be closed because of (pesticides and nitrates) pollution.  

g)  Step up the efforts to achieve the additional objectives set for shellfish areas  

3.  Where the objectives of the Directive for a specific water body cannot be met and exemptions are invoked, 
in line with ECJ jurisprudence on the restrictive interpretation of exemptions and better justify the use of 

34 

 
exemptions, provide sufficiently detailed justifications at the level of the water body and ensure that their 
application is regularly reviewed.  

This implies: 

h)  Providing public access and references in the RBMPs to transparent, thoroughly underpinned case by 
case justifications for the exemptions when Article 4(4) and Article 4(5) or possibly in the future Article 
4(6) are considered necessary to be applied, 

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

4.  As regards funding, 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’  when  establishing  water  tariffs  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, including the 
long term, to improve the cost-effectiveness analysis and the prioritisation of measures as well as a better 
– more complete- estimation of the investments to be applied as well as the funding needs. This must  
also include the Outermost regions. 

5.  As regards adaptation to climate change, better consider the impacts of climate change in all RBMPs.  

This entails: 

a)  developing  regional  drought  management  plans  where  droughts  are  foreseen  particularly  in  the 

outermost regions as knowledge about probable impacts there is still underdeveloped. 

b) 

Improving the climate proofing of measures included in the PoMs and where relevant develop adequate 
measures or plans for climate resilience and drought management to achieve the objectives of the 
WFD more effectively. 

c)  Proactively establishing or improving, regularly update and monitor accurate water balances for all 
river basins, that take into account all inputs and abstractions and natural losses as well as the needs 
of water dependent ecosystems.  

d)  Taking effective measures to promote water reuse, efficiency and circularity, while maximising the use 

of nature-based solutions for more sustainable water storage across soils and ecosystems. 

e)  Changing agricultural practices to reduce the dependence on irrigation for some crops, in particular 
crop  diversification  and  more  sustainable  soil  management  techniques  that  allow  for  a  better 
infiltration and/or retention of rainwater.  

f)  when planning new dams and reservoirs or water transfers, or programs of reservoirs carefully assess 
their environmental impacts including cumulative impacts, especially regarding the objectives of the 
WFD and ensure that such interventions are part of an integrated water management and of coherent 
water resilience strategies, which, amongst others, duly considers long-term climate scenarios. 

6.  As regards governance, enhance the coordinate between the different administrative levels and foster more 
common  approaches  between  the  different  RBDs  as  there  are  considerable  disparities  between  the 
assessment and methodologies used.  

7.  As regards monitoring, assessment, data management and reporting, France should: 

35 

 
 
 
a)  Speed up definitions of GEP for heavily modified water bodies, providing clarity about the compensation 
and/or mitigation measures needed to reach the GEP and start implementation as soon as possible, 

b)  Ensure sustainable groundwater and surface water management by considering climate change impact 
on the flows and on the replenishment of groundwater bodies before allowing new abstractions and 
ensure regular reviewing of permits to incorporate the most recent insights. Permitting should consider 
cumulative effects of abstractions with already existing and possibly programmed abstractions in the 
(sub) basin on the regional hydrological cycle. 

c)  Speed up in defining and implementing e-flows through integration in permitting and hydro-barriers 

management, with a priority for the 3 RBDs reporting significant abstraction pressures, 

d)  Continue to improve 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 modelling, an improved prediction by the models calibrated with these data and less dependence 
on expert judgment (for outermost regions) for the classification of ecological status / potential and 
chemical status. This will also enhance the level of confidence of the assessments. 

e) 

Improve the transparency and comparability of monitoring and status assessment among the 14 river 
basin districts (including the outermost regions) and with other EU countries, specifically regarding the 
assessment of river basin specific pollutants, physico-chemical and hydromorphological conditions. 

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,  (PFRAs)  including  the  identification  of  areas  of  potential 
significant flood risk, (APSFRs), (b) the preparation of flood hazard and risk map (FHRMs), and (c) the 
establishment of flood risk management plans (FRMPs). 

Information from the PFRA/APSFR assessment 

There are 14 Units of Management (UoMs) in France, which are the same as the Water Framework 
Directive’s  River  Basin  Districts  (RBD).  Fluvial,  pluvial,  groundwater,  and  sea  water  floods  are 
considered as potentially significant sources of flooding in France. France designated 118 Areas of 
Potential  Significant  Flood  Risk  (APSFRs).  The  impacts  of  climate  change  on  flood  risk  had  been 
considered in France, however at the time of the second PFRAs no reference to a national adaptation 
strategy or adaptation/resilience building could be found. 

7.1 Flood hazard and risk maps 

Highlights 

France is using a national geoportal38 for the second FHRMs. FHRMs were prepared at the national 
level and show the whole country. Maps for fluvial floods with low probability (1/1 000 years), with 
medium probability (1/100 years) and with high probability (1/10 years) are provided. Flood extent is 
shown on all maps. Water depth is shown on all maps. Number of inhabitants is not presented on the 
maps. Some information on number of inhabitants potentially affected is available as background 
information on the geoportal, but it is not clear what the numbers relate to as it appears that in most 
cases total number of inhabitants is provided, and in some cases the population affected at medium 
probability flooding only. However, it is unclear if the information relates to an APSFR or to some 
other geographical area. The location of some economic activities (seven categories, including large 
scale activities, such as Seveso and non-Seveso sites, intensive animal rearing, wind farms, quarries) 
is  mapped  at  national  level  using  symbols  and  can  be  viewed  as  a  layer  on  the  FHRMs  on  the 
geoportal. IED installations are shown. Potentially affected protected areas identified in Annex IV(1)(i), 
(iii) and (v) to Directive 2000/60/EC are not shown in the FHRMs. 

Changes since the first FHRMs 

Two UoMs now include seawater as a source of flooding for the development of the second FHRM 
(not  reported  in  the  first  FHRMs  as  a  source  of  flooding).  Pluvial  sources  of  flooding  have  been 
identified in some UoMs in the second FHRMs (likewise, none in the first FHRMs).  

Changes of contextual information since the first FHRMs 

38 https://www.georisques.gouv.fr/cartes-interactives#/  

38 

 
 
An important development is that maps for all UoMs can now be viewed on the national geoportal 
and their presentation is harmonised across all UoMs. The three probability scenarios (10, 100 and 
1 000  years  corresponding  to  high,  medium  and  low  probability)  are  applied  uniformly  on  the 
geoportal. Hazard maps can be viewed by choosing various layers, e.g. probabilities (high, medium 
and  low)  and  three  means  of  flooding,  i.e.  exceedance,  submersion  and  run-off,  corresponding  to 
fluvial,  coastal  and  pluvial  flooding.  The  different  sources  can  be  viewed  combined  or  separately 
where fluvial (exceedance) and coastal (submersion) flooding are the sources. Pluvial flooding (run-
off) has only been found visualised for one UoM (FRI – Guadeloupe), where pluvial is included as a 
source according to EIONET reporting. Water depth can be seen at a certain zoom level, the depth 
categories are the same for exceedance and submersion, but different for run-off. 

Changes in methodologies used to prepare flood hazard maps since the first FHRMs 

There has been gradual  change in the approach since the first FHRMs. The biggest change is the 
standardisation of the presentation of maps at national level on the geoportal. In addition, pluvial 
sources of flooding have been identified in some APSFRs in the second PFRAs (none in the first cycle), 
although only one was found mapped in an FHRM. 

Changes in methodologies used to prepare flood risk maps since the first FHRMs 

Some  important  elements  which  were  considered  and  shown  on  the  pdf  maps  published  as  first 
FHRMs,  are  not  displayed  on  any  of  the  harmonised  maps  on  the  national  geoportal,  such  as 
population affected, protected areas and cultural heritage. For example, impacted cultural heritage 
was displayed on the pdf maps for FRC, FRD, FRF, FRG and FRH in the first FHRMs. This is no longer 
the case on the harmonised maps of the national geoportal (it could be that because some maps 
from  the  first  FHRMs  are  still  up  to  date  errors  were  made  in  compiling  the  databases  and  only 
indicating what has changed). 

Changes since the first FHRMs in the consideration of climate change 

In the first FHRMs it was reported that the long-term trends (climate change) were considered by 
using average sea level rise. An assumption was made in the first PFRAs that a 1m sea level rise 
would be observed across the coast by 2100, this was reduced to 60 cm for the first  FHRMs. The 
impact of climate change on the occurrence of floods has been considered in the second FHRMs too. 
For example, a report for the Loire Bretagne (FRG) UoM considers the impacts of sea level rise in 
detail in the coastal zone. Similar reports are available for all coastal UoMs. Hazard maps at medium 
probability with and without the effect of climate change based upon the 60cm projected sea level 
rise have been produced. 

7.2 Flood risk management plans 

Highlights 

The  national  Ministry  of  Ecological  Transition  and  Territorial  Cohesion  has  a  webpage39  on  flood 
prevention  that  provides  links  to  websites  of  the  Regional  Directorates,  where  the  FRMPs  can  be 
downloaded. France has set three overall objectives at national level. Each FRMP assessed has set 
individual  objectives;  these  are  not,  however,  directly  linked  to  the  broad  areas  of  the  national 

39 https://www.ecologie.gouv.fr/prevention-des-inondations#scroll-nav__3  

39 

 
 
objectives. The five FRMPs assessed all contain objectives addressing adverse consequences. All five 
FRMPs assessed have objectives that call for increasing knowledge of flood risks and for sustainable 
land use planning and all five FRMPs assessed have measures for sustainable spatial planning. Some 
have objectives calling for better crisis management and governance. None of the objectives refer 
directly to adverse consequences on economic activity; however, a national objective call for reducing 
flood damage costs, which can include those for economic activities. None of the objectives refer 
directly to adverse consequences of flooding on the environment, though measures address pollution 
issues arising from floods. None of the objectives refer directly to adverse consequences of flooding 
on cultural heritage, though flood risks for cultural heritage are assessed in the five FRMPs, which 
also have measures to protect cultural heritage. France has reported 683 measures to EIONET. The 
five FRMPs assessed all identify measures to be undertaken. The measures in the second FRMPs are 
not specific and measurable, and the plans indicate that they will be specified in lower-level plans at 
local and APSFR levels. France reported 283 prevention measures and the FRMPs include measures 
for flood prevention, notably for spatial planning. France reported 125 protection measures and 193 
preparedness measures and the FRMPs refer, among others, to measures for emergency planning. 
France  has  reported  priorities  for  all  measures.  There  are  five  possible  categories  for  reporting 
measure priorities to EIONET, ranging from critical to low. France uses three of these categories: very 
high priority (161 measures, 24 % of the total), high priority (421 measures, 62 %), and moderate 
priority (21 measures, 3 %). In addition, there are 80 measures (12 % of total) whose priority is not 
reported: these are all the measures of the Seine UoM (FRH). Four of the five second FRMPs assessed 
report information on the progress of indicators for the first FRMPs. As noted above, all of the second 
FRMPs assessed identify indicators (which was not the case in the first FRMPs) to measure their own 
progress. Not all these indicators however have targets or timeframes. The FRMPs maintain a link 
between objectives, sub-objectives and measures. They maintain a link to lower-level plans as well. 
The FRMPs assessed do not set out priorities of their measures but do state that measures should 
be undertaken first in APSFRs (while France has reported in EIONET three different levels of priorities 
for  its  measures,  both  overall  and  within  its  UoMs,  the  FRMPs  do  not  describe  the  approach  to 
prioritisation of measures.). France has reported progress for all of its measures to EIONET, however 
the second FRMPs assessed vary in the detail they provide on the progress of measures included in 
the first FRMPs. The second FRMPs assessed list indicators to measure overall progress, although not 
that of individual measures. France uses four categories to denote progress of measures in EIONET: 
ongoing construction, ongoing maintenance (recurrent, e.g. maintenance works), in preparation, and 
not  started.  It  does  not  report  any  measures  as  completed  or  as  abandoned/interrupted.  Ten 
measures are reported with more than one category of progress40. The largest share of measures is 
reported as ongoing (recurrent, e.g. maintenance works): 367 measures or 52 % of the total. Under 
this  category,  130  measures  (35  %)  are  identified  as  prevention  measures  and  116  (32  %)  are 
preparedness. The next largest share of measures, 186 (27 % of all measures) are listed as ongoing 
construction, just over half of which (98 measures, 53 %) are prevention measures. All of the UoMs 
have measures that are ongoing (recurrent, e.g. maintenance works). Measures reported as ongoing 
construction  are found  in 10  of  the  14 UoMs: these  account  for  the majority of  measures in  the 
Meuse (FRB1), Rhine (FRC) and Seine (FRH) UoMs. Measures not started are reported for half of the 
UoMs (seven out of 14), with most in the Seine UoM (FRH): 21 measures, 35 % of the 60 measures 
not started. The five second FRMPs assessed provide at least some information on the progress of 
measures under the first FRMPs. The FRMP for the Rhine-Meuse (FRC) provides a link to an external 

40 Eight of these 10 measures are for the Martinique UoM (FRJ), each with two categories of progress reported. One is for 
the Loire UoM (FRG), again with two categories of progress reported, and the other is for the La Réunion UoM (FRL), with 
the category of progress reported three times with two different categories. No explanation was provided for this 
reporting, but all categories are counted here and in Annex A to this report.  

40 

 
 
document41 that describes progress under the first FRMP. This provides an overview of work for the 
measures under each objective: it provides maps, for example, showing progress in the development 
of  SLGRIs  and  in  the  introduction  of  the  GEMAPI  tax  in  the  UoM.  The  FRMP  for  the  Rhone  (FRD) 
contains a chapter42 that discusses progress in terms of the objectives and provides an overview of 
progress on the measures under each objective. While is reports progress in many areas, it notes that 
the transfer of critical services out of flood areas has proceeded slowly. Similar levels of detail were 
not found, however, in the other FRMPs. The plan for the Adour-Garonne (FRF), for example, mentions 
that  the  results  of  the  first  FRMP  were  assessed,  including  via  a  questionnaire  to  government 
authorities such as those responsible for lower-level plans43; details of the results were not found, 
however. 

The second FRMPs provide information on funding sources, but only one of the five FRMPs assessed 
provides  an  overview  of  the  costs  of  its  measures.  Three  of  the  five  FRMPs  assessed  provide 
information on insurance for flood risks. One FRMP assessed provides information on the national 
public insurance scheme for natural catastrophes and on insurance issues. In addition, three of the 
five FRMPs refer to the GEMAPI tax44 that France has introduced to finance flood risk management 
measures. Two FRMPs have measures to carry out cost-benefit analysis and multi-criteria analysis. 
A national document provides guidance on coordination between the FRMPs and RBMPs and indeed 
the FRMPs assessed describe coordination with the WFD. France has reported that coordination with 
WFD objectives was undertaken in most of its UoMs. All five FRMPs assessed refer to assessments 
of  the  impacts  of  flood  risk  management  measures  on  the  environment,  including  natural  areas. 
Three of the five FRMPs identify common measures with the respective RBMPs and have objectives 
or sub-objectives for natural  water retention whereas all the FRMPs assessed have measures for 
natural water retention.  

Two FRMPs (Escaut (FRA) and Rhine UoM (FRC)) refer to transboundary cooperation via international 
river commissions. For the FRMP of the Adour-Garonne UoM (FRF), separate documents are provided 
on EIONET on coordination with Spain45 and Andorra46 in relation to public consultation. For the other 
UoMs, transboundary actions are presented as a continuation of the efforts of the previous FRMPs. 

The  five  FRMPs  describe  the  public  and  stakeholder  consultations  that  were  organised.  The 
consultation process for the draft FRMPs followed national regulations (Articles L566-11 and 12 of 
the Environment Code), which require two types of consultation: a six-month public consultation and 
a four-month consultation of stakeholders, including local  and basin authorities, regional  councils 
and environmental organisations. The public and stakeholder consultations were conducted at the 
same time as those of the RBMPs under the WFD. 

41https://www.grand-est.developpement-durable.gouv.fr/IMG/pdf/bilan_de_la_mise_en_oeuvre _du_pgri_2016-
2021_districts_rhin_meuse_.pdf  
42 FRMP ITD, Chapter 2. 
43 FRMP for FRF, pp. 20-21. 
44 GEMAPI concerns the powers of local authorities in the field of management of aquatic environments and flood 
prevention, https://www.ecologie.gouv.fr/gestion-des-milieux-aquatiques-et-prevention-des-inondations-gemapi 
45 Referral from the Occitanie region to the Spanish Ministry (informing of the public consultation and requesting the 
opinions of the Spanish Ministry on the RBMPs and FRMPs), 8 February 2021, 
https://cdr.eionet.europa.eu/fr/eu/floods2019/frmp_2022/documents/frf/envyqskga/FR_FRF_FRMP_05_Saisine_ministere_e
spagnol.pdf 
46 Referral from the Occitanie region to the Andorran Ministry (informing of the public consultation and requesting the 
opinions of the Andorran Ministry on the RBMPs and FRMPs), 8 February 2021, 
https://cdr.eionet.europa.eu/fr/eu/floods2019/frmp_2022/documents/frf/envyqsejg/FR_FRF_FRMP_04_Saisine_ministere_a
ndorran.pdf 

41 

 
 
Consideration of climate change 

Section 3.7 depicts how France has taken into account climate change considerations when drafting 
the Flood risk Management Plans.  

8. FD recommendations 

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

• 

• 

• 

• 

• 

• 

• 

consistently consider in FHRMs: WFD protected areas, including areas intended for abstraction of water 
for human consumption, and cultural heritage sites; 

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

provide links in the FRMPs to the national geoportal where all FHRMs can be viewed; 

Include an assessment of the progress made towards the achievement of the objectives in all FRMP; 

provide information on the costs of all measures in all FRMPs;  

provide  information  on  the  methods  used  to  prioritise  measures  in  the  FRMPs  and  on  the  final 
prioritisation; 

The FRMP should set out the progress of the measures in more detailed and consistent manner; 

•  where relevant, incorporate CBA in the FRMPs for the prioritisation of measures that lend themselves 

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

• 

provide on the FRMP detail on the public consultation and stakeholder involvement, in particular, the 
comments received, and how they were taken into account; 

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

conveyance routes, as these are relevant to emergency response. 

42