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

Netherlands 

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 ...................................... 12 

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

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

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

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

3.5 What is being done to prevent/reduce hydromorphological pressures ............................................ 18 

3.6 What The Netherlands is doing for abstractions and water scarcity................................................. 19 

3.7 Adaptation to climate change .................................................................................................................................. 20 

4. Policy elements contributing to zero pollution ........................................................................................................ 21 

4.1 Surface Water: what is their chemical status ................................................................................................. 21 

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

4.3 What the Netherlands is doing to combat pollution from agriculture .............................................. 25 

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

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

5. Exemptions and economics ............................................................................................................................................... 30 

5.1 To what extent are exemptions applied in the Netherlands ................................................................... 30 

5.2 Use of economic analysis and water pricing – cost recovery ................................................................ 32 

6. WFD recommendations ........................................................................................................................................................ 34 

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 plan .................................................................................................................................... 38 

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

2 

 
 
 
SECTION A: 
WATER FRAMEWORK 
DIRECTIVE 

3 

 
 
 
1. General info, Member State characterisation

The  Netherlands  is  for  a  large  part  situated  below  the  sea  level  (25%  of  surface  area).  It  has  a 
population of 17,4 million with a density of 500 persons per km2, almost 5 times the EU average. It 
hosts Europe’s largest port and finds itself at the most downstream point of four international river 
basins (Rijn, Maas, Schelde and Eems). 54% of its territory is used for agriculture and the country is 
the world’s n° 2 exporter of farm products and has the fourth largest greenhouse gas emissions per 
capita of the EU. All these elements create heavy pressures on the quality of its freshwaters.  The 
Netherlands is (still) a water rich country but climate change may increase coastal and river flood 
risks and urban drainage, increase algae blooms and possibly also result in scarcity (in some areas). 
About  one  fourth  of the  country  is  designated  Natura  2000  (160  areas), two  thirds  of  which  are 
‘open’  freshwater.  The  whole  country  is  designated  as  nitrate  sensitive  area  under  the  Nitrates 
Directive. 

The Netherland’s 4 River Basin Districts count 745 surface water bodies (33 more than in the 2nd 
RBMPs) and 23 groundwater bodies. Most surface water bodies are heavily modified (286 HMWBs) 
or artificial (435 AWBs), only 24 are natural. 

Reporting 

The deadline for reporting the 3rd River Basin Management Plans (RBMPs) was in March 2022. The 
Commission and the European Environment Agency (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 

4 

 
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  The  Netherlands  submitted  full  electronic  reporting  and  therefore  the 
assessment is based on this dataset. 

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

5 

 
 
 
Changes in Status, Pressures, Exemptions & Measures 

Surface 
Water 
Bodies 
(745) 

Trend (% good 
status/potential) 

100%

ECOLOGICAL 
STATUS 

50%

0%

0,3% 0,0%
2021
2015

100%

CHEMICAL 
STATUS 

50%

39,2%

9,4%

0%

2015

2021

Main Pressures & Changes & Exemptions 

There is a very slight deterioration of the situation (0,3% to 0% in good status); however, there are less water bodies in bad and poor status. 
Also, the status of some biological quality elements has improved. Nevertheless only 5,2% of water bodies are expected to reach good status 
by 2027. 
The number of monitoring sites has seriously increased. 

Main drivers for pressures are dense population, land use, economic/agricultural activities, past pollution and transboundary pollution. This 
affects hydromorphology (canalisation, flood protection, agriculture), and results in pollution from nitrates, fertilizers/pesticides, and river 
basin specific pollutants. The Netherlands apply EQS for a very high number of RBSPs. The RBSPs that impact most water bodies are arsenic 
(67% of SWBs), cobalt (79%), selenium (64%), silver (42%) and zinc (39%). Pesticides affect 10% of SWBs and ammonium 70%. 

Art 4(4) exemptions apply to all SWBs, mostly for reasons of natural conditions and technical feasibility, disproportionate costs ranking third. 
Art 4(6) exemptions have seriously increased from 18 to 87. No exemptions under Article 4(5) are applied (no 'lowering of objectives'). 

Serious deterioration since the second RBMPs: from 39,2% of SWBs in good chemical status in 2nd RBMPs to only 9,4% in good chemical 
status in 3rd RBMPs. This may partly be due to increased confidence in status assessment and increased monitoring and stricter standards 
applying to some substances.    
Only 20% of SWBs is expected to reach good chemical status by 2027 (66% of SWBs will comply with EQS for non-ubiquitous priority 
substances and 49% will comply with EQS for ubiquitous chemicals).   
Only about 10% of priority substances cause bad status, most relevant are: polybrominated diphenyl ethers (PBDEs) (79%) fluoranthene 
(27%), mercury (26%), benzo(g,h,i)perylene (24,7%), benzo(b)fluoranthene (20%), tributyltin (15%), Benzo(a)pryene (6%), benzo(k)fluoranthene 
(5,8%). Mercury is responsible for the failure in 25% of the water bodies. This ubiquitous presence of mercury is common to many Member 
States, also as a result of long range air deposition from other continents.  
NL applies Art 4(4) WFD for all exemptions, on grounds of natural conditions (70%) or technical infeasibility (65%), only 12% on grounds of 
disproportionate costs.  

6 

 
 
 
 
 
Ground 
Water 
Bodies  

Trend (% good 
status/potential) 

100%

Main Pressures & Changes & Exemptions 

100,0

% 95,7%

50%

QUANTITATIVE 
STATUS 

Only one GWB (4,3%) has deteriorated status compared to the 2nd RBMPs due to water balance. Three are at risk of not achieving good 
status by 2027, because of insufficient water for groundwater-dependent terrestrial ecosystems (2) and water balance.  
Out of the 23 GWBs, 15 have been identified for abstraction of drinking water.  
A more stringent method is used to determine the groundwater at risk compared to the 2nd RBMPs.  
The prolonged drought period in 2018 played a large role in the deterioration of status of one GWB, as the abstraction rate was much 
higher than the recharge rate.  

4.3 % of GWBs have been exempted for quantitative status on the grounds of technical feasibility under Article 4. 

0%

2015 2021

7 

 
 
 
100%

CHEMICAL 
STATUS 

50%

87,0% 87,0%

0%

2015 2021

No change since 2nd RBMPs; 3 out of 23 GWBs are in bad chemical status; top 3 pollutants affecting most GWBs are nitrates, chlorides, 
total phosphorus.  

For drinking water abstraction points, a trend assessment found 36 rising trends (approximately 10 % of all abstractions), as a result of 
impacts by the pesticide bentazone, arsenic and Nickel. Declining trends were identified for other pesticides, metals and nitrate.  
There is a slight decrease in the number of monitoring points, in particular for the purpose of operational monitoring.  
Also, there are no national threshold values for mercury, nitrites, ammonium and sulphate, but there are values for pharmaceuticals.  
By 2027, it is expected that two out of the 3 GWBs currently not in good chemical status will still be not be in good chemical status. The 
pollutants posing the risk include nitrate, chloride, pesticides and total phosphorus. Many of the exemptions under Article 4(4) are for reason 
of natural conditions, as more time may be needed for GWBs to recover from pollution.  

8 

 
 
 
 
2. Horizontal aspects 

2.1 Governance 

The Netherlands has timely reported, i.e. by the end of May 2022, one national RBMP covering four 
River Basin Districts (RBDs) and integrating their respective RBMPs. This is a change from the previous 
cycles, where four  separate  RBMPs were established and  reported.  All RBDs are international: the 
Rhine, which covers 69 % of the national territory, the Meuse, the Scheldt and the Ems. International 
RBMPs  for  all  four  RBDs  have  also  been  reported.  The  water  governance  is  quite  complex  and 
decentralised,  and  sub-plans  exist  at  different  levels:  the  12  provinces  are  responsible  for 
groundwater management, the 21 regional water authorities for surface water management and the 
municipalities have a major role in sewage treatment. Water boards are in charge of implementation. 
The  Ministry  of  Infrastructure  and  Water  Management  has  a  main  role  in  preparing  RBMPs  and 
Programmes of Measures and for coordinating implementation. 

This decentralised water management and delegation or devolution of responsibilities, which is in 
line with the Water Framework Directive (WFD), has the benefit of involving all actors. However, it 
may hamper progress if responsibilities are unclear, and the allocation of duties may leave some 
orphan  tasks.  This  results  for  instance  in  delays  to  implement  hydromorphological  measures; 
insufficient enforcement of mandatory nutrient removal from sewage treatment plants; insufficient 
permit  updates  for  activities  impacting  water  quality  and  quantity;  inadequate  supervision  and 
enforcement and unsolved spatial planning issues1. 

On the basis of available information, it is noted that the Netherlands provides a case of good practice 
for the public’s involvement, as required by the WFD. The public has been appropriately consulted on 
timetable, work programme, overview of significant water management issues and draft RBMP for 
the required six months (internet, invitations to stakeholders, local authorities, media and meetings). 
Information on comments and how these were taken into account has been made publicly available2.  
Civil society is quite active in the Netherlands, and has taken the government to court, which has 
resulted in an obligation for the latter to increase its action to tackle climate change3. Such action 
will also benefit water quality and empowers civil society to step up action also in other areas. In 
2019, a ruling by the Administrative Jurisdiction Division of the Council of State led to new measures 
under the Integrated approach to Nitrogen very much linked to nitrogen depositions and emissions.  
Since then, it is proving politically difficult to impose additional obligations on the agricultural sector 
to curb nutrients emissions. 

All four RBDs are covered by international agreements (with a permanent cooperation body) and by 
international  RBMPs.  There  is  a  coordinated  approach  to  characterisation,  monitoring,  HMWB 
designation, exemptions, water abstraction/scarcity and pollution and coordinated databases and/or 
geographical information system. It is worth noting that strikingly, as regards the measures to be 
taken, these are rather left to the national plans. 

The RBMP includes a chapter clarifying the coordination with other directives, including the Floods 
and  Marine  Strategy  Framework  Directives.  In  respect  of  the  latter,  there  is  also  intensive 

1 See in this respect recommendation one formulated by the ‘Raad voor Leefomgeving en infrastructuur’ an independent 
advisory body, in its Advisory letter "Good Water, Good Policy” of 11 May 2023 
2 Structuurvisie Nationaal Water Programma | Tweede Kamer der Staten-Generaal 
3 The Urgenda Climate Case against the Dutch Government was the first in the world in which citizens established that their 
government has a legal duty to prevent dangerous climate change. 

9 

 
 
international coordination and coordination on programmes of measures (e.g., in terms of addressing 
plastic pollution), in line with the requirements on governance set out in the WFD. 

2.2 Characterization of River Basin District 

In addition to the ‘natural’ types of water bodies, the Netherlands has also classified a lot of their 
water  bodies  as  heavily  modified  and  artificial,  to  take  into  account  the  high  level  of  human 
intervention  on  their  water  bodies.  This  makes it  impossible for the  latter to achieve  good  status 
because  that  would  prevent  the  water  bodies  to  provide  for  the  activities  causing  the 
modification/artificialisation (e.g., canal, ports, dams, flood protection). In the ‘artificial water body’ 
category, they have identified 12 artificial water types of ditches and canals. Instead, they will need 
to comply with the objective of good ecological potential, as further described in section 2.3. 

Table 1. Overview of the Netherlands’ River Basin Districts and the number of water bodies per RBD  

RBD 

Name  

% 
national 
territory 

Rivers 
number 

Lakes 
number 

Transitional 
number 

Coastal 
number 

Territorial 

GWBs 

NLRN 

Rhine 

NLSC 

Scheldt 

NLMS 

Meuse 

NLEM 

Ems 

69 

8 

18 

6 

127 

369 

1 

101 

5 

50 

59 

14 

3 

3 

1 

1 

4 

1 

1 

1 

1 

1 

1 

1 

11 

5 

5 

2 

Figure 1. Overview of level of intervention in Dutch waters 

Level of human intervention in Dutch water bodies 

100%

80%

60%

40%

20%

0%

Rivers

Lakes

Coastal Waters

Transitional waters

Natural

Heavily modified

Artificial

To benchmark and determine the status of water bodies, boundary values are set for the high/good 
(establishment of reference conditions) and good/moderate status classes. Good ecological status of 
water bodies is established by comparing assessed monitoring data to these two boundary values. It 
is welcomed that the Netherlands has established reference conditions for all natural surface water 
body types for:  

10 

 
 
 
 
(1)  biological  quality  elements  (i.e.  for  macroinvertebrates,  fish,  phytoplankton  and  other  aquatic 
flora4 in accordance with the Intercalibration Decision of 2018) but not for fish and phytoplankton in 
very large rivers5, nor for phytoplankton in coastal waters6;  

(2) all physico-chemical quality elements (including thresholds for nitrogen and phosphorus);  

(3) hydromorphological quality elements (limited parameters for transitional and coastal waters). 

The classification methodology for water types is included in a background document7. 

As  required  by  the WFD,  the  environmental  objectives  have  been  reported  in  all  RBDs.  Additional 
objectives have also been set for water bodies associated with Protected Areas where so needed to 
ensure compliance with the requirements of the Directives applicable to those Protected Areas. 

The RBMP establishes the main pressures that are exerted upon them.  

The main pressures on surface waters come from agriculture, atmospheric deposition, other diffuse 
pollution and transport; in addition, there is considerable pressure from dams, barriers and locks; the 
most relevant impacts are chemical pollution (87%), organic pollution (85%) and nutrient pollution 
(73%). Of particular concern are the family of polybrominated diphenylethers (PBDEs, ubiquitous) 
which cause the biggest number of surface water bodies to fail good chemical status. There is an 
improvement as regards nutrient pollution (13% decrease) but regrettably a significant exacerbation 
of  chemical  pollution  (+37%)  compared  to  the  previous  cycle.  A  recent  study  has  assessed  the 
sources of PFOS and other PFAS. There still seems a lack of identification of sources of ammonium 
partly because of the dynamic character of its concentration (impact of temperature) and uncertainty 
of natural background levels in groundwater (associated with surface water). In terms of river basin 
specific pollutants, it needs to be recalled that the Netherlands is monitoring a very high number of 
pollutants in surface water, more than 808, which they consider are of concern in their territory. This 
pollution takes different forms, and some pollutants are much more present than others. While not 
explicitly mentioned in the RBMP, invasive species (e.g., invasive crayfish) can also cause problems 
insofar as they disrupt the freshwater ecosystem by their burrowing and grazing behaviour.  

The main pressure on groundwater comes from diffuse pollution, the main driver behind that pressure 
being agriculture and other sources resulting in organic pollution (52%), chemical pollution (50%) 
and  damage  to  groundwater-dependent  terrestrial  ecosystems  (39%).  This  has  not  changed 
compared to the 2nd RBMP. As regards other possible pressures, the problem of overexploitation of 
groundwater  compared  to  the  replenishment  rate  remains  limited  (currently  only  affecting  one 
groundwater body) but the situation is expected to deteriorate by 2027.  

Figure 2. shows the pressure from agriculture on the trophic status of surface water, based on monitoring 
under the Nitrates Directive 

4 Justification accepted in the context of the Intercalibration exercise, for not using phytobenthos in all types 
5  NL  considers  phytoplankton  not  a  mandatory  BQE  to  be  assessed  in  large  rivers;  for  fish,  the  method  could  not  be 
intercalibrated due to an insufficient number of samples 
6 However, for chlorophyll-a (phytoplankton) for coastal waters, the Netherlands has doubts that these values are suitable 
and started an investigation with Germany  
7 STOWA 2018-49 Maatlatten - 2020v4.pdf 
8 These are the so-called river basin specific pollutants, which are part of the specific physico chemical quality elements 
supporting good ecological status  

11 

 
 
 
Source: JRC NITRATES DIRECTIVE - Reporting Period 7 (2016-2019) Trophic Status9 

There are factsheets available for each water body, which describe the water body, its objectives, its 
current  status,  pressures  and  impacts,  measures  and  a  summary  of  the  exemptions  and  related 
justifications10. 

3. Policy elements contributing to biodiversity and 

climate change adaptation 

3.1 Surface Water: what is their ecological status or potential 

Monitoring 

The Netherlands has enhanced its diagnosis capacity. Indeed, the number of monitoring points has 
considerably increased (+ 17%) compared to the previous cycle11. There are two types of monitoring: 
i) operational monitoring to determine the status and which covers all water bodies at risk and ii) 
surveillance  monitoring  aimed  rather  at  identifying  impacts  and  long-term  changes  and  design 
monitoring programmes, covering 37.2 % of river lengths, 84.6 % of lake area, 91.6 % of transitional 
water area and 91.6 % of coastal water area. 

As regards operational monitoring, the country applies a risk-based monitoring, that means that not 
all  biological  and  physico-chemical  parameters  are  monitored  in  all  water  bodies  but  rather 

9 Link available at: Nitrates Directive - Reporting 7 (europa.eu) 
10 KRW-factsheets | Het Waterkwaliteitsportaal 
11 Monitoring water | Informatiepunt Leefomgeving (iplo.nl) 

12 

 
 
 
representative water bodies are used for monitoring and the results are extrapolated to other water 
bodies subject to similar pressures and impacts. This is in line with the WFD. The status is based on 
the most recent monitoring results (which can differ per substance or location). 

As  regards  surveillance  monitoring,  contrary  to  operational  monitoring  which  only  monitors  the 
relevant parameters (i.e. the parameters sensitive to the pressures affecting a specific water body), 
surveillance monitoring covers all biological quality elements. For rivers, lakes and transitional water 
bodies, these are phytoplankton, macrophytes, benthic invertebrates, and fish (not phytobenthos12), 
whereas for coastal water bodies phytoplankton and benthic invertebrates. However, in two of the 
coastal waters other aquatic flora (eg angiosperms) is also monitored. 

All  general  physico-chemical  quality  elements  (nutrients,  oxygenation,  transparency,  thermal 
conditions, salinity conditions, acidification) are now monitored in most water body types, except for 
coastal water bodies where only nutrient and oxygenation conditions are monitored. 

According to the available information, hydromorphological quality elements are not monitored under 
any monitoring programme. Nevertheless, in the ‘ex ante analysis’ the current hydromorphological 
conditions  and  the  expected  conditions  are  taken  into  account  in  the models to  assess  biological 
status (for quality elements sensitive to hydromorphological changes). 

In conclusion, while  the number of monitoring stations has increased and biological  and physico-
chemical  parameters  are,  in  general,  well  covered,  the  monitoring  of  hydromorphological  quality 
elements (hydrology, morphology, continuity) seems insufficient, considering that several biological 
quality elements are sensitive to hydromorphological changes. For some coastal water bodies, ‘other 
aquatic flora’ and several general physico-chemical quality elements seem insufficiently monitored 
and  hence  not  used  for  status  assessment.  For  details  on  frequencies,  the  RBMP  refers  to  the 
Monitoring and Status Assessment Protocol13. 

Status assessment 

Surface water 

In the 3rd RBMP, there are no surface water bodies in good ecological status/potential and 64.2 % 
(478)  in  moderate  status/potential,  26.3  %  (196)  in  poor  status/potential  and  8.7  %  (65)  in  bad 
status/potential. Only 0.8 % (2) are in unknown status. 

12 Justification accepted in the context of the intercalibration exercise 
13 https://www.helpdeskwater.nl/publish/pages/162259/protocol-monitoring-en-toestandsbeoordeling-krw-errata-
verwerkt-2021.pdf  

13 

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

Source: WISE electronic reports  

The above figure 3 shows that the number of water bodies in good status/potential remains extremely 
low and actually has decreased over the cycles from 0.3% to zero. What has been happening over 
the 3 cycles is a positive gradual shift from bad to poor to moderate- with a steady reduction of 
surface  water  bodies  in  bad  status  and  the  number  of  surface  water  bodies  in  poor  status 
progressively declining. While this is undoubtedly a beneficial evolution, it is not good enough to make 
water bodies flip from bad to good. 

This is because, as required by the law, if one parameter is beyond the allowed limit, the status is 
considered bad (the ‘one out all out’ principle or in other words the status is determined by the quality 
of the elements in the lowest class). That means even if the status is improving from bad to poor or 
from poor to moderate, this will not be reflected in the classification of the water body which would 
still not be ‘good’. For the Netherlands this means that there is no change of overall status between 
the  3  cycles.  It  must  be  highlighted  that  the  Netherlands  has  established  environmental  quality 
standards for 80 pollutants of national concern (‘river basin specific pollutants’ or RBSPs).  

14 

 
 
Figure 4: most problematic pollutants (metals) causing failure to achieve good ecological status/potential 

Percentage of water bodies failing to achieve good status per hazardous 
substance

Zinc

Silver

Selenium

Cobalt

Arsenic

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

As regards, non-metals, the most problematic is imidacloprid (pesticide) seriously affecting 10% of 
water bodies and ammonium affecting 70% of the water bodies. Almost 70% of all water bodies 
comply with thresholds for nutrients (N and/or P), and 55% of all inland freshwaters, which is a clear 
improvement as compared to the 2nd RBMPs. By 2027, 75% of surface water bodies are expected to 
comply with nutrient thresholds. However, the Netherlands still benefit from a derogation under the 
Nitrates Directive until December 202514, allowing to spread more manure on the fields. 

Overall, considering pressures from chemicals and nutrients, and the application of the one-out-all-
out principle, at the current pace of improvement, it is not surprising that the Netherland expects that 
by 2027 only 5.2 % of surface water bodies will be in good ecological status/potential. 

Nevertheless, the status of some biological quality elements has improved. This is in particular the 
case  for  fish  and  phytoplankton.  Also,  some  general  physico-chemical  quality  elements  have 
improved status (transparency, oxygen), reflecting improved biology. Temperature and chloride are 
more problematic, due to recent warmer summers. Hydromorphological quality elements have not 
been assessed for status because these are only relevant for water bodies in high status or maximum 
potential of which there are none. 

According  to  four  Dutch  knowledge  institutes,  the  current  plans  are  insufficient  to  reach  climate, 
nitrate and nature targets. To solve the problem, farmers would need to implement far more costly 
and far-reaching measures on their farms whereas, in order to achieve the nature and water targets, 
much more nature is needed than currently agreed15. 

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) 

As shown in the below table, the level of human intervention in the Dutch water bodies is unparalleled 
in the EU. 

14 Publications Office (europa.eu) 
15 Plannen voor natuur, stikstof en klimaat onvoldoende om doelen te halen (nos.nl) 

15 

 
 
 
 
 
Table 2: Level of human intervention in Dutch water bodies 

Modifications 

Rivers 

Lakes 

Transitional 
waters 

Coastal waters 

HEAVILY MODIFIED - total 38% of 
all SW 

91% 

14%  

67%  

33,3% 

ARTIFICIAL - total 58% of all SW 

4%  

86% 

20%  

0%  

The  main  physical  alterations  affecting  the  water  bodies  are:  channelisation/straightening/bed 
stabilisation/ bank reinforcement, weirs/dams/ reservoirs and land drainage (river water bodies)/locks 
(all other types). The most common reasons driving alterations are flood protection, navigation and 
ports.  For  artificial  water  bodies  (AWBs),  no  information  could  be  found  on  the  reasons  for  their 
creation. 

The RBMP only briefly describes the methodology to designate a water body as HMWB, referring for 
details  to  factsheets  provided  at  water  body  level16.  These  explain  for  each  water  body  the 
sustainable human development activities or pressures causing the water body to be considered as 
heavily modified and the resulting limits for taking measures towards good ecological potential. They 
also clarify the lack of technically feasible and non-disproportionately costly better environmental 
options (i.e. less disturbing or not disturbing to water bodies) to achieve the same objectives. 

According to the WFD, and given their very man-made characteristics, the HMWBs and AWBs must 
only meet the objective of good ecological potential (GEP) rather than good ecological status (GES). 

Like for GES, GEP is defined in relation to a reference condition which is the maximum ecological 
potential (MEP), i.e. the biological status (algae, aquatic flora, macrofauna and fish) reflecting as far 
as  possible  that  of  the  closest  comparable  surface  water  body  taking  into  account  the  modified 
characteristics of the HMWB/AWB. Physico-chemical quality elements are also taken into account, via 
their relationship with biology. It is to be welcomed that the Dutch method for assessing GEP has 
improved since the 2nd RBMPs. For canals and small waterways, the GEP is compared to the GES of 
the canal with the highest quality in the Netherlands. Chapter 5.4.3 of the national RBMP summarizes 
the mitigation measures that have been applied to compensate  as much as possible the adverse 
ecological effects of the physical alteration. They are reported in the factsheets and refer to a national 
guideline  for  assessment  of  the  effects  of  mitigation  measures  on  GEP  and  calculation  of  their 
significance17. 

No water bodies have been classified as being in MEP or even GEP. This is also due to non compliance 
with  environmental  quality  standards  (for  River  basin  specific  pollutants),  which  equally  apply  to 
natural and heavily modified/artificial water bodies. 

16 Available at: https://www.waterkwaliteitsportaal.nl/krw-factsheets 
17 https://www.stowa.nl/sites/default/files/assets/PUBLICATIES/Publicaties%202018/STOWA%202018-
15%20handreiking%20defdefversie.pdf 

16 

 
 
 
3.3 Groundwater bodies - have they sufficient water – quantitative status 

Groundwater abstractions and artificial recharges are registered, in line with the WFD. Abstractions 
are not considered a significant pressure, as the overall water balance of most groundwater bodies 
is positive. 

In all RBDs, and as required by the WFD, groundwater bodies are associated with one or more surface 
water body and as a result of this, groundwater associated aquatic ecosystems (GWAAEs) are taken 
into  account  in  quantitative  status  assessment.  The  same  applies  to  groundwater  dependant 
terrestrial ecosystems (GWDTEs). 

In the face of growing precipitations changes, it is positive that all groundwater bodies except one 
are  in  good  quantitative  status.  The  latter  has  deteriorated  to  poor  quantitative  status  due  to 
abstraction exceeding recharge, as a result of the drought period in 2018 in the Meuse RBD. However, 
for the future, in addition to the groundwater body already currently in poor quantitative status, two 
more are at risk of not meeting good quantitative status in 2027, as a result of significant pressure 
from  agriculture  affecting  groundwater  dependent  terrestrial  ecosystems.  The  Dutch  government 
intends to  implement  46  recommendations  to make  the Netherlands more  resilient  to  periods  of 
drought. 

Figure  5:  Quantitative  status  of  groundwater  bodies  (GWBs)  in  the  Netherlands,  in  the  1st,  2nd  and  3rd 
RBMPs 

Source: WISE electronic reports 

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

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

17 

 
 
Zone under the Nitrates Directive. However, no sensitive areas have been designated under the Urban 
Wastewater  Treatment  Directive.  It  must  be  noted,  though,  that  all  urban  wastewater  treatment 
plants must ensure at least 75% reduction of nutrients (phosphorus and nitrogen) in the wastewater 
before it is discharged. Currently, 26,5% of the non-marine area of the Netherlands is covered by 
areas that are protected as Natura 2000 sites under EU nature legislation18 or as nationally protected 
areas. While this value is slightly about the EU average of 26.4%, one has to keep in mind that most 
of the Dutch protected areas are water surfaces. The EU Biodiversity Strategy has set a target of 
reaching 30% protected area coverage at the EU level by 2030. 

For groundwater, protected areas have been designated under the Drinking Water, Habitats and Birds 
Directives. Indeed, 15 groundwater bodies are identified as drinking water protected areas, of which 
7 are transboundary. 

Table 3: Number of protected areas, per type of area and associated water body  

Protected area type 

Number of Water Bodies Associated with protected areas in 

Rivers 

Lakes 

Coastal 

Transitional 

Territorial 

Groundwater 

Bathing waters 

Drinking water 
protection area 

Natura 2000  

Shellfish designated 
water 

12 

6 

67 

0 

64 

5 

153 

2 

7 

0 

9 

8 

3 

0 

4 

2 

0 

0 

4 

4 

0 

15 

20 

0 

Additional  objectives have been set  for both surface and groundwater pertaining to Natura 2000 
protected  areas19,  Shellfish  (for  microbiological  contamination)  and  Drinking  Water  Directive 
protected areas (to maintain the water quality). 

Separate monitoring networks have been established, sometimes overlapping with monitoring under 
the respective directives. 

The RBMP summarizes additional  measures for protected areas. Moreover, under the Nature Pact 
€415 million of yearly funding goes to measures aimed at achieving the objectives of Natura 2000 
and Water Framework Directives. In addition, since 2021, €300 million of yearly funding goes to the 
restoration  and  protection  of  nature.  Overall,  the  additional  objectives  for  protected  areas  seem 
covered by an appropriate number of specific measures (including creation of special habitats for 
fish,  for  flora  and  fauna,  construction  of  purification  wetland,  vegetation  and  water  quality 
management,  planting  of  vegetation  along  water  bodies,  managing  of  large-scale  groundwater 
contamination,  restricting  of  recreational  use  and  shipping,  change  in  agricultural  use,  financial 
measures, communication, legislative changes). 

There is no information on the actual achievement of the additional objectives. It is positive that the 
share of surface water bodies associated with protected areas, which are in poor ecological status 
or potential, has decreased and the majority (56.4%) is now classified in moderate status/potential. 
On  the  other  hand,  an  opposite  trend  is  seen  for  the  chemical  status  of  such  bodies  which  has 
deteriorated  and  88.2%  are  now  failing  good  chemical  status.  Regrettably  quantitative  status  of 

18 Netherlands (europa.eu) 
19 See: Landelijk Meetnet effecten Mestbeleid | RIVM 

18 

 
 
 
groundwater  bodies  associated  to  protected  areas  has  slightly  worsened20.  This  would  lead  to 
conclude that the special measures as well as the additional objectives set for those protected areas 
are clearly insufficient to address the pressures from chemical pollution, whereas they seem to have 
produced positive effects on biological parameters. 

3.5 What is being done to prevent/reduce hydromorphological pressures 

River  continuity  has  been  identified  as  an  overall  management  objective  for  all  four  RBDs  and 
measures include bypass channels, fish ladders, development of an inventory of barriers, removal or 
adaptation of dams. 

It is welcomed that there is an authorisation regime in place to control physical modifications to the 
riparian area of water bodies; there is a systematic revision of permits to address hydromorphological 
alterations, often associated with water availability and quality in Natura 2000 areas. It is reported 
that  new  and  modified  structures,  including  upgrade  of  flood  defences,  storage  dams  and  tidal 
barriers,  have been  adapted  to  take  into  account  WFD  objectives.  However, it is  not  clear  if  such 
projects  have,  as  required  by  the  WFD,  been  made  subject  to  a  preliminary  assessment  of  their 
impacts  and,  where  so  required  because  of  likely  negative  impacts,  whether  the  necessary 
justification has been provided and mitigation measures planned and implemented. This may be due 
to  the  implementation  of  policy  rules  to  avoid  deterioration  of  ecological  status  due  to  new 
developments21. 

Yet as mentioned above, the level of human intervention is very high and since a large part of the 
country  is  under  the  sea  level,  flood protection  is  one  of  the main  hydromorphological  pressures. 
Agriculture  also  triggers  a  very  large  number  of  these  alterations.  The  programme  of  measures 
identifies pressures caused by drainage and soil erosion or sediment run offs. 

The RBMP includes measures to address diffuse pollution from urban runoff (59 water bodies) and 
agriculture (563 water bodies). Other measures tackle the physical alteration due to i) flood protection 
(82  water  bodies  concerned),  ii)  agriculture  (151  water  bodies  concerned),  navigation  (30  water 
bodies concerned) and other pressures (94 water bodies concerned), as well as hydrological alteration 
due to agriculture (149 water bodies). Measures to improve hydromorphological conditions other than 
longitudinal  continuity  include  habitat  restoration,  reconnection  of  meander  bends  or  side  arms, 
lowering  of  riverbanks,  restoration  of  bank  structures,  inundation  of  flood  plains,  restoration  of 
modified bed structures, measures to improve flow regime and/or establishment of ecological flows; 
measures to improve water efficiency in irrigation, industry, energy and households; natural water 
retention measures. 

The RBMP includes ‘win-win’ measures to achieve objectives of the WFD and Floods Directive and 
address drought management in the form of ‘Natural Water Retention Measures’.  It does not include 
specific information as to whether ecological flows have been established in regulations, but there 
are measures aiming towards a natural hydrological regime, gradual transition between fresh and 
seawater, as well  as control  of water levels in case of droughts. Nature-based solutions, such as 
nature friendly river banks, have been included for some but not all RBDs. 

20  water-scarcity_report_final.pdf  (panda.org)  a  recent  WWF  report  highlights  a  case  of  dysfunctional  controls  on 
groundwater extraction in The Netherlands in and around Natura 2000 sites, e.g. the Holtingerveld (province of Drenthe), 
characterised by insufficient groundwater levels to sustain terrestrial ecosystems, yet the Province failed to request the 
appropriate assessment under the Habitats Directive prior to authorising abstractions (25 other Natura 2000 sites in the 
Sand Rhine-East catchment would be in a similar situation) 
21 Staatscourant 2022, 6470 | Overheid.nl > Officiële bekendmakingen (officielebekendmakingen.nl) 

19 

 
 
The RBMP reports progress on hydromorphological measures, but only 50% of all measures (set out 
in the 2nd RBMPs) have been implemented or their implementation has started, in sharp contrast to 
measures addressing other pressures, 95% of which have been implemented or are on-going. This 
seems mostly due to the difficulty to buy the land necessary to implement the measures, as well as 
to the need for a staged approach of these measures, which are interlinked, therefore implementation 
of one is a pre-condition for implementing another one. Nevertheless, it’s worth noting that the Rhine 
and Ems RBD show good progress on measures to widen rivers and create nature-friendly river banks 
(respectively  79%  and  94%  of  all  such  planned  measures  implemented),  In  the  Maas  RBD,  all 
measures that were aimed at enhancing the water systems, including the creation of wetlands and 
lowering of floodplains (within the concept of “Room for the river” project) have been implemented. 
In terms of closing the gap for hydromorphological pressures expected between 2021 and 2027, the 
RBMP includes indicators and lists the number of measures to be implemented, by category. By 2027, 
in total 1500 fish migration bottlenecks will have been restored and 40 % of the total stream length 
will  reach  a  state  closer  to  natural.  Therefore,  it  is  estimated  that  by  2027  at  the  latest,  the 
hydromorphological status of water bodies will mostly be restored within the framework conditions 
set by the WFD. 

3.6 What The Netherlands is doing for abstractions and water scarcity 

There are permitting regimes in place, as well as registers for both abstraction and impoundment, 
and measures to promote water efficiency in all water use sectors and RBDs, as required by the WFD. 
However, some abstractions below certain thresholds are exempted from permitting and controls (to 
note that the WFD allows to exempt abstractions which have no significant impact on water status). 
Only very large abstractions from surface water bodies are subject to prior authorisation (> 50 m3 
per hour); Abstractions from groundwater bodies are subject to prior authorisation if above 150.000 
m3 per year for industrial purposes, or if for the purpose of drinking water supply or for the purpose 
of soil energy systems. In all other cases, it will depend on local regulation. 

The RBMPs provide for specific conditions under which permits can be refused or revised, in view of 
maintaining or achieving the environmental objectives. However, there is no obligation for periodic 
review  of  those  permits,  as  required  under  the  WFD.  Inspections  are  in  place  to  verify  illegal 
abstractions  or  violation  of  permit  conditions.  The  Meuse,  Scheldt  and  Rhine  RBMPs  also  refer  to 
international  coordination  activities  (e.g.  joint  monitoring,  planning,  stakeholder  engagement, 
measure implementation, management of low flows). 

Only one groundwater body out of 23 (4.3 %) failed to achieve good quantitative status by 2021 for 
reason of significant pressures from water abstraction. However, two more groundwater bodies are 
at risk of not achieving good quantitative status by 2027. This is not for reason of water abstraction 
but due to pressures from diffuse sources of pollution damaging groundwater-dependent terrestrial 
ecosystems. All three groundwater bodies are located in the Meuse RBD. 

For surface water bodies, water abstraction has only been identified as a significant pressure for 8 
river water bodies (3.4 % of total river water bodies) and 22 lake water bodies (4.5 % of all lake 
water bodies) failing to achieve good ecological status/potential, all in the Meuse and Rhine RBDs. 
This  means  a  notable  reduction  as  compared  to  the  2nd  RBMPs,  where  water  abstraction  was 
significantly affecting 42 river water bodies, 72 lake water bodies and 2 transitional water bodies in 
the Meuse, Rhine and Scheldt RBDs. 

20 

 
Based  on  national  statistics22,  the  major  users  are  (in  descending  order):  electricity  generation, 
industry, households and services, and agriculture. It is worth noting that despite the efforts on water 
efficiency, since 2015, water consumption is increasing for public water supply and agriculture23. 

Basic and supplementary measures are in place for the control and management of water abstraction 
and impoundments (controls, technical measures for irrigation, efficient water use, improvement or 
establishment of ecological flow regime). 

The Netherlands are studying possibilities to promote water reuse as a possibility to reduce water 
abstractions24. 

There is also international cooperation on water abstraction/scarcity issues, in particular on low flows 
(e.g. Meuse, Rhine). The programme “Rhine 2040 – The Rhine and Its Catchment Area: Sustainably 
Managed  and  Climate-Resilient”,  launched  in  February  2020,  aims  at  improving  sustainable 
management and climate resilience in the Rhine RBD. 

3.7 Adaptation to climate change 

The RBMP contains a section dedicated to climate change, describing general effects of climate on 
biology, chemical and general groundwater and surface water quality. It provides general advice on 
how to maintain good water quantitative status of groundwater and prepare for droughts and refers 
to energy transition as a potential approach to address climate change impacts on water (e.g. tidal 
energy or wind/solar farms). It also refers to the National Climate Change Adaptation Strategy as a 
vehicle to address, amongst others, water issues. The international river commissions have developed 
four international climate change adaptation strategies, integrated in the RBMP. 

The  long-standing  Delta  Programme25  to  combat  the  consequences  of  and  to  cope  with  climate 
change  covers  i)  protection  against  flooding  (strengthening  dikes,  maintaining  coast  with  sand 
nourishment, creating more room for rivers to reduce the risk of flooding), ii) adequate supplies of 
fresh water for both drinking and agriculture and iii) climate-resilient spatial planning.  

The strategy and actions in the Delta Programme on Freshwater are carefully aligned with the PoM 
of the WFD at national and regional levels and reinforce the WFD measures where possible.  

Flood management 

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

Since the big flood disaster that happened in 1953- Watersnoodramp- causing almost two thousand 
casualties  and  a  very  considerable  damage,  flood  control  has  been  constantly  enhanced  in  the 

22 Statistics | Eurostat (europa.eu) 
23 It should be noted however that conventional statistic abstraction data of Eurostat, EEA and OECD do not take account 
of evaporation /leakages of water stored in reservoirs further to abstractions. Leakage and evapotranspiration losses can 
however be significant in MSs with many reservoirs and/or older irrigation and distribution systems. 
24 Een verkenning van de acceptatie van waterhergebruik in Nederland (h2owaternetwerk.nl) 
25 More info on past and future programme: 2024 Delta Programme | Delta Programme | Delta Programme 
(deltaprogramma.nl) 

21 

 
 
country, particularly as climate change progresses and with increasing sea level rise. These efforts 
have led to the largest flood defence system in the Netherlands, known as Delta Works. 

However, climate change effects were not included in the maps of the 1st Flood Hazard and Risk 
Maps  (FHRMs).  In  the  2nd  FHRMs the  need  to  address  the impacts  of  climate  change  is  also  not 
explicitly reported. Moreover, the Manual “Flood Risks on the Map” indicates that for the Areas of 
Potential Significant Flood Risk (APSFRs), the current risks are assessed and the potential future effect 
of climate change on the size of a flood is not being taken into account. 

On the other hand, as opposed to the 1st FRMPs, , the 2nd FRMP does mention the national climate 
strategy,  together  with  related  policy  documents.  Climate  scenarios  prepared  by  the  Royal 
Netherlands Meteorological Institute (KNMI) were used for the 2nd FRMP. These are based on the 
scenarios  developed  by  the  International  Panel  on  Climate  Change  (IPCC).  The  KNMI’s  scenarios 
project that climate change will bring higher temperatures, more rapid sea-level rise, wetter winters, 
heavier  rainfall,  and  the  possibility  of  drier  summers.  Areas  not  protected  by  flood  defences  can 
expect  a  larger  area  experiencing  more  frequent  occurrences  of  flooding.  Pluvial  floods  are  also 
expected to increase and will be further assessed for the 3rd FRMP. On intense rainfall events (flash 
floods), the FRMP states that municipalities have undertaken work to reduce the vulnerability of urban 
environments, but it is unclear how many municipalities have undertaken this work, or plan to do so. 
The  FRMP  also  states  that,  for  the  3rd  FRMP,  the  Netherlands  will  evaluate  whether  intense 
precipitation poses a significant risk of flooding.  

Drought management 

Although  not  a  formal  requirement  under  the  WFD,  following  the  2018  drought,  a  drought 
management plan was put in place to advise relevant institutions and raise awareness, formulating 
46  recommendations  to  prevent  deterioration,  support  resilience  to  droughts  and  promote 
restoration. Equally, droughts are the most assessed and addressed climate change impacts in the 
3rd RBMPs. The economic impacts are disruption of navigation and damage to crops; whereas the 
environmental  impacts  are  increased  land  subsidence  due  to  low  water  tables,  increased  salt 
intrusion and increased pressure on nature/green areas. 

Climate change adaptation measures  

The  RBMP  provides  concrete  measures  to  prevent  deterioration,  support  resilience  and  promote 
restoration: 1) measures to broaden canals, e.g. the "Room for the River" programme26, where the 
relocation of dikes and the construction of side (new) channels have increased safety against flooding 
while also expanding habitats for plants and animals, increasing the control over water flows, and 
increasing  infiltration  capacity  through  the  establishment  of  nature-friendly  embankments;  2) 
awareness raising and 3) drought management plans that advise relevant institutions on measures 
during drought periods.  

4. Policy elements contributing to zero pollution 

4.1 Surface Water: what is their chemical status 

Monitoring 

26 Room for the River explained | Dutch Water Sector 

22 

 
 
The  Netherlands  has  updated  its  monitoring  methods,  strategically  deploying  monitoring  sites  to 
maximise the understanding of chemical status across different surface water body types. The total 
number of sites has increased from 711 to 745 (significant increase in lakes, yet a decrease in rivers). 

Grouping  approaches  have  been  used  for  status  assessment,  even  though  the  WFD  requires 
monitoring in all water bodies in which priority substances are discharged. Very detailed information27 
is given on how the state of surface water has been established. It has been done with a combination 
of in-situ monitoring, grouping and modelling. However, for what concerns monitoring of the eleven 
priority substances for which an EQS in biota has been set, which must be monitored in biota once a 
year, it seems that a reduced frequency is applied without this being justified. 

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

Figure 6: Chemical status of surface water bodies (SWBs) in the Netherlands in the 1st, 2nd and 3rd RBMPs 

Source: Wise electronic reporting  

A good element is that the status is known for all water bodies and there are no knowledge gaps. On 
the other hand, only about 10% of surface water bodies are in good chemical status: 11% of riverine 
water bodies, 4% of lakes and 0% of transitional and coastal water bodies. 

Moreover, the number of water bodies in good status has dramatically and steadily decreased over 
the three cycles from 70% to 39% to 9%. To explain this negative deterioration trend, there might 
be different reasons: i) the accuracy of measurements has considerably increased ii) the number of 
substances monitored has also increased and the limit values rendered more stringent. It needs to 
be highlighted that the new substances added at European level in 2013 have not been taken into 
account  in  this  cycle  for  the  assessment.  However,  although  it  might  not  be  possible  to  rule  out 

27 SGBP-achtergronddocumenten | Het Waterkwaliteitsportaal. 

23 

 
 
 
increasing pollution loads, measures taken to reduce mercury emissions and to enhance air quality 
should bring along some positive reductions in some of the most common pollutants. 

Most failures to achieve good chemical status are associated with a small subset of substances. In 
top  position  are  polybrominated  diphenyl  ethers  (PBDEs)  –  heavily  used  in  paints,  plastics,  foam 
furniture padding, textiles, building materials and industrial processes- they cause the failure of 79 % 
of water bodies. Then comes a group of substances coming from crude oil and combustion processes 
fluoranthene (26 %), benzo(b)fluoranthene (20%), benzo(g,h,i)perylene (24,7%), Benzo(a)pyrene (6%), 
benzo(k)fluoranthene (5,8%) and the widely used biocide tributyltin (15%). 

Worth  highlighting is the case  of mercury  that  is  responsible  for  the  failure in 25%  of  the  water 
bodies. This ubiquitous presence of mercury is a common phenomenon in many Member States and 
has triggered a myriad of actions in the EU to act at source and prohibit its use in many products. 
Major sources still remain from (long range) transboundary air deposition from other continents. 

Against this  background, it is  not  surprising that  limited  progress is  expected by  2027.  Estimates 
conclude that, around 80 % of surface water bodies will still fail to achieve good chemical status.  

Figure 7: The top-10 Priority Substances causing failure to achieve good chemical status in surface water 
bodies in the Netherlands. 

Source: Wise electronic reporting 

24 

 
Figure  8:  The  most  problematic  10  substances  taking  also  into  account  the  12  newly  added  priority 
substances in 201328. 

Source: WISE electronic reporting 

4.2 Groundwater Bodies: what is their chemical status 

Monitoring 

Most groundwater bodies have been monitored for chemical status but the number of surveillance 
and operational monitoring points have gone down from 1876 and 204 in the 2nd RBMPs to 1649 
and 80 respectively in the 3rd RBMP. Overall, 88.3 % of the total groundwater body area is subject 
to monitoring for chemical status. In addition to the quality standards set out in Annex I of Directive 
2006/118/EC, which must be  complied  with by all Member States, the Netherlands have also set 
national threshold values for a series of pollutants listed in Annex II to the GWD, for which Member 
States must consider setting threshold values, i.e. where these pollutants have been identified  as 
causing risks to good chemical status of groundwater bodies. The Netherlands have also set national 
threshold values for pollutants not listed in Annex II to GWD, i.e. for pharmaceuticals. 

As required under the GWD, the Netherlands have also carried out an assessment of environmentally 
significant  sustained  upward  trends  in  pollutants  or  indicators  of  pollution  in  (groups  of)  GWBs 
identified as being at risk. Furthermore, since good groundwater chemical status also depends on the 
impact pollutants in groundwater may have on the status of associated surface waters (Groundwater 
Associated Aquatic Systems or GWAAEs) or on the status of terrestrial  ecosystems which depend 
directly  on  groundwater  (Groundwater  Dependent  Terrestrial  Ecosystems  or  GWDTEs),  these  have 
been considered for the assessment of groundwater body chemical status, in accordance with the 
law. This implies also that specific attention has been paid to the objectives set for drinking water 
protected areas. Saline and other intrusions do not seem to be affecting chemical status. 

28 Directive 2013/39/EU amending Directive 2008/105/EC, added 12 new substances i.e. numbered 34 to 45 to the 
priority substances list. For the 3rd RBMP, Member States 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. 

25 

 
 
 
Status assessment 

Figure 9: Chemical status of groundwater bodies (GWBs) in the Netherlands in the 1st, 2nd and 3rd RBMPs  

Source: WISE electronic reporting 

Compared to surface waters, a much better situation can be seen for groundwater, partly because 
they  are  more  shielded  and  less  vulnerable  to  depositions  of  air  pollutants.  Confidence  in 
classification is high. While a very good progress seems to transpire compared to the first cycle, there 
is no real progress or deterioration compared to the previous cycle: out of 23 groundwater bodies, 
20 are currently in good chemical status, as in the 2nd RBMPs.  

Like for surface waters, a small subset of compounds is causing the problem. Only four pollutants 
are causing failure to achieve good chemical status, all of them largely linked to agriculture: Nitrates 
and pesticides (water body  NLGW0019), chloride (water body NLGW0015)  and total  phosphorous 
(water body NLGW0016). For the latter two groundwater bodies, a significant sustained upward trend 
in  these  substances  was  identified.  Therefore,  the  status  is  unlikely  to  improve  much  by  2027. 
Although  some  measures  are  in  place  to  address  the  issues,  more  time  may  be  required  for 
groundwater recovery. For that reason, the Netherlands have invoked the use of the exemption under 
Article 4(4) (natural conditions) of the WFD which allows Member State to continue to apply time 
related exemptions, even beyond 22/12/2027, if it can be demonstrated that all measures required 
to achieve good status are in place and being implemented, but the rate of recovery of the water 
body to good status may be delayed because of varying hydrogeological conditions. 

4.3 What the Netherlands is doing to combat pollution from agriculture 

As mentioned above the leaching of pollutants from agricultural land is at the heart of the pollution 
of groundwater and also to some extent of surface water. 

26 

 
 
There  is  some  concern  about  the  increased  use  of  insecticides  deltamethrin,  esfenvalerate  and 
lamda-cyhalothrin, which would, according to the Dutch Pesticide Risk Indicator29, account for 90% 
of the pollution of surface waters. Even if only accounting for 0.1% of the total sales of pesticides, 
sales have increased with 65% in 2021 compared to 2010 (7% compared to 2020). 

The RBMP refers to general binding rules to control diffuse pollution from nitrates, phosphates and 
pesticides, in accordance with Article 11(3)(h) WFD (basic measures). 

Other  measures  concern  a  structural  review  of  the  manure  policy  which  takes  into  account  the 
national Water Quality Analysis (i.e., de Nationale Analyse Waterkwaliteit). 

Also, the 7th action plan under the Nitrates Directive (202130), is key for reducing nutrient pollution; it 
includes a mix of mandatory and voluntary measures and contains six pillars, including production 
plans to improve water quality and soil quality, additional support for hotspots where water quality 
is an issue, wider buffer strips where use of pesticides is not allowed (eg 100 to 230 metres in sandy 
areas),  improved  knowledge  and  communication,  enforcement.  The  Netherlands  obtained  a 
derogation on 30 September 2022 under the Nitrates Directive (4 years, last derogation), allowing 
part of the farms to apply higher quantities of nitrogen (manure), subject to very strict conditions. 

The  Nitrogen  Act  sets  out  reduction  objectives  and  forced  scaling-down  of  certain  agricultural 
activities are no longer excluded, albeit facing fierce opposition from the farming sector. As a result, 
two financial schemes for voluntary ending or adapting of livestock businesses have been opened 
mid-June  2023.  However,  the  initial  announcement  of  possible  mandatory  measures  should  the 
voluntary  measures  prove  to  be  insufficient,  has  been  withdrawn  as  a  result  of  the  July  2024 
agreement of the new Dutch government.   

The 2013 Delta Plan for Agricultural Management (associating farmers and water managers) aimed 
at providing innovative tailored solutions to tackle emissions from agriculture, in view of solving 80% 
of associated water quality issues by 2021 and 100% by 2027. 15,000 farmers take part in the 500 
projects implemented or under implementation; the scheme is voluntary. 

There is a gap assessment for nutrients. This allows, in line with the requirements under the WFD, to 
identify  the  needs,  as  well  as  progress  towards  the  achievement  of  the  objectives.  Additional 
measures  on  wastewater  collection  and  treatment  will  reduce  the  load  of  nitrogen  by  4%  and 
phosphorous by 3%, increasing the share of surface water bodies compliant with nutrient thresholds 
from the (current) 55% to 75% by 2027 (share in previous cycles was 52 % and 47 % respectively). 
If farmers would implement the voluntary measures under the Delta Plan, the nutrients load would 
be further reduced with 15% to 30%, and by 2027, around 85% of surface water bodies would be 
compliant with nutrient thresholds. 

There is no similar gap assessment for pesticides. The RBMP merely notes that the trend analysis 
shows a reduction of the share of water bodies exceeding the quality standards for pesticides, even 
though the exceedance of some quality standards (for specific pesticides) remains almost constant. 
The Netherlands has less than 5% of agricultural land used for organic farming31. The Dutch new 
CAP Strategic Plan 2023-2027 reserves funds to support a maintenance plus an increase to 47.5% 
organic  farming  by  2027,  as  compared  to  202232.  An  increase  in  organic  farming  could  however 
provide a boost to reducing nutrient losses and reducing fertilizer and pesticide use. 

29 NMI and MIG/EICP | Pesticidemodels.eu 
30 7e Nederlandse actieprogramma betreffende de Nitraatrichtlijn | Publicatie | Rijksoverheid.nl 
31 EUs organic farming area reaches 16,9 million hectares – Eurostat (europa.eu) 
32 At a glance: The Netherlands’s CAP Strategic Plan (europa.eu) and Archive:Agricultural census in the Netherlands - 
Statistics Explained (europa.eu)  

27 

 
 
Overall, financing of agricultural measures is secured in all RBDs, through funding from the Common 
Agricultural Policy (CAP)33, Structural and Cohesion Funds and national funds. 

As part of the CAP, farmers receive €260 per hectare with an additional ‘greening’ payment of €115 
per hectare for implementation of ‘additional’ climate and environment friendly practices34. The total 
greening premium funds in the 3rd RBMPs is set at €200 million, yet it is unclear how much of it 
actually contributes to improved water quality. 

In addition, the former Dutch government has earmarked €5 billion for the implementation of basic 
measures to reduce nitrogen emissions for a 10-years period. An additional €811 million has been 
made available for the WFD (€670 million for the period 2022-2030, and €141 million euros for the 
period 2030-2035). 

However,  the  newly  formed  Dutch  government  (July  2024)  published  an  agreement35  that  is 
overruling the recently developed Dutch agricultural policy including funding of measures to address 
agricultural emissions. The agreement presupposes a thorough review of the Natura2000 areas to 
limit them to a few larger areas.  This may have negative consequences for the water quality in the 
Netherlands and the North Sea coastal waters. 

The Delta Plan for Agricultural Water Management has a total funding of €39 million up to 2027. 

There  is international  co-ordination  on  identified  Significant  Water  Management  issues (SWMI), in 
particular as regards nutrient loads entering Dutch surface water bodies, including quantification of 
relative apportionment of loads in the three International River Commissions and the International 
Collaboration for the  Eems.  At  all  border  crossings,  Dutch  ecologically  underpinned  thresholds for 
nitrogen  and  phosphorus  are  exceeded36.  These  upstream  foreign  sources  of  pollution  create 
uncertainty for achieving the objectives. 

4.4 What the Netherlands is doing to combat pollution from other sectors 

Pollution in this context concerns nutrients, organic matter, sediment, saline discharges and chemicals 
(Priority  Substances,  river  basin  specific  pollutants,  groundwater  pollutants  and  other  physico-
chemical parameters) arising from all sectors and sources apart from agriculture. 

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

The 3rd RBMP includes more details on the relationship between Key Type of Measures (KTMs) and 
pressures, associating each significant pressure with one or more KTM(s). All RBMPs report measures 
to eliminate/reduce pollution from Priority Substances and other substances. 

For  human  settlements,  additional  treatment  of  wastewater  (including  reducing  emissions  from 
stormwater) is expected to increase the share of water bodies complying with the nutrient thresholds 
from  55%  (current  share)  to  75%  in  2027 (as  set out  in  the  Nitrogen  Act).  Indeed,  authorization 
regimes  are  in  place  for  all  discharges  of  urban  wastewater  in  all  RBDs,  as  well  as  registers  of 
wastewater discharges (supplementary measure). There is a prohibition of all direct discharges to 
groundwater. For water bodies where standards are exceeded, additional treatment is planned (e.g. 

33 In this respect, it may be useful to refer to the recent study on ‘Mapping and Analysis of CAP Strategic Plans - 
Assessment of joint efforts for 2023-2027’ 
34 There has been some controversy in the Netherlands over the fact that some water boards would put at disposal of 
farmers small parts of land/ditches, for those to count towards the 4% unfarmed land triggering additional subsidies 
35 Hoofdlijnenakkoord tussen de fracties van PVV, VVD, NSC en BBB | Publicatie | Kabinetsformatie 
(kabinetsformatie2023.nl) 
36 In 2010, upon recommendation from the Commission, the Netherlands has strengthened its nutrients standards for  
rivers and streams, whereas the Flanders region has not done so, creating additional transboundary issues  

28 

 
 
improve  treatment  and  reduce  release  of  untreated  wastewater).  Discharges  from  industrial 
wastewater are mainly addressed through permitting and application of ‘best available techniques’ 
under  the  Industrial  Emissions  Directive  (2010/75/EC).  There  is  a  partnership  in  place  between 
industries  and  several  governmental  organizations  to  limit  industrial  pollution  (“Gebiedsgerichte 
Grondwater Aanpak”). The specific approach to ‘Substances of Very High Concern’ provides for a tool 
to search companies/processes to identify use of priority substances at source. It now also aims to 
include wastewater discharges to surface waters. 

The Soil Protection Act and the Environmental Management Act also aim to protect groundwater, on 
the basis of maps pointing to large-scale soil contamination in particular close to vulnerable elements 
(eg groundwater-dependent surface waters, nature protected areas, drinking water). 

The forecasts for 2027 are that at least 66% of surface water bodies will comply with the standards 
for the non-ubiquitous priority substances. For ubiquitous substances, the forecast is that 49% of 
surface  water  bodies  will  comply  in  2027.  For  the  new  priority  substances  (i.e.  those  added  by 
Directive 2013/39/EC, which can be subject to time related exemptions up to end 2039), the forecasts 
(with some uncertainty) are that 51% of the water bodies will comply in 2027. 

There is a problem of (legacy) accumulation in terrestrial or aquatic soil/sediments, making it difficult 
to estimate by when compliance can be achieved. More research is needed on sources of pollution 
caused by several substances before additional measures can be formulated. 

In conclusion, the PoMs leave unaddressed a significant gap to good status by 2027, in part due to 
the uncertainty around the reduction of upstream nutrient inflows and legacy pollution effects. 

More details are required on how the gaps will be filled for each pressure or combination of pressures, 
based on a prioritization of measures, including cost-effectiveness analysis. 

4.5 What is the Netherlands doing to combat significant pressures – 

overall assessment of the Programmes of Measures 

Measures  are  in  place  and  planned  to  address  all  significant  pressures  in  both  groundwater  and 
surface water, with at least one KTM assigned to each pressure. All basic measures (under Article 
11(3) WFD) are implemented in all RBDs.  

The RBMP maps 96 national basic measures against 11 predefined KTMs. In addition, a total of 555 
national supplementary measures have been mapped against 18 predefined KTMs and 3 nationally 
defined  KTMs  (the  latter  include  awareness  raising,  reduction  of  nutrient  pollution  from  multiple 
drivers and maintenance focused on improving water quality).  

However, the proportion of supplementary measures being mandatory as opposed to voluntary is 
unclear. In addition, some national measures have not been associated to significant pressures and 
therefore may not have been put in operation yet. The latter concern water pricing for cost recovery 
of water services from households and from industry, drinking water protection measures (eg buffer 
zones) and measures to reduce sediment from soil erosion and surface run-off. 

A  cost-effectiveness  analysis  has  been  presented  in  the  RBMP,  but  only  at  a  generic  level  for 
categories  of  measures  and  not  resulting  in  specific  prioritisation  of  measures.  The  CEA  uses 
quantitative data on volume of water, population development and production value in each RBD, to 
set out a baseline scenario for 2021-2027. There is an assessment of the cost recovery of water 
services. 

29 

 
A critical factor in the success of the PoM is the availability of budget/funding. The 3rd RBMP only 
includes costs to the public budget, which seems considerable as it is estimated at approximately € 
1.5 billion of the total planned package of measures for the period 2021-2027, shared between the 
state (approximately € 0.4 billion), the provinces and water boards (approximately € 0.2 and € 0.9 
billion respectively) and the municipalities (approximately € 45-50 million). There is no information 
on the prioritisation of measures, it appears that all measures are to be executed.   

There is a clear overview of the state of implementation of measures set out in the 2nd RBMPs. Delays 
in implementation are explained by difficulties incurred with the buying of land required to fulfil the 
measures, or the need to first wait for completion of other development measures.  

Point  source  pressures  were  in  general  well  addressed  (between  80  to  100%  of  measures 
implemented or on-going), with the exception of sanitation of soil/groundwater in Rhine RBD (67%) 
and of addressing sewage overflows in the Meuse RBD. 

Diffuse  source  pressures  were  relatively  well  addressed  with  the  exception  of  agricultural  nitrate 
emissions in the Scheldt RBD (only 50%) and Ems RBD (only 25%), and disposal of polluted dredging 
material in the Rhine RBD (only 45%).  

Hydromorphological  pressures were not sufficiently addressed, with for instance in the Rhine RBD 
only 14% of measures to deepen water systems implemented, or only 12% of measures to widen/ 
renaturalise water systems in the Scheldt RBD. 

Other, more (protected) area linked measures are very well implemented, including for instance 93% 
of measures to create specific living areas for fish. 

But all in all, of the 1847 planned measures in the 2nd RBMPs, 516 measures have been finalised 
(March 2019) and 1255 measures are still being implemented. Therefore, implementation is for 95% 
on track. 

For what concerns the 3rd RBMP, the Dutch Government has adopted the ‘IMPULSE’ programme37 to 
further push for implementation of existing measures and include some additional (mainly voluntary) 
measures, also linking to spatial planning and stressing the important cross-sectoral  character of 
water related issues. 

For  what  concerns  the  mandatory  measures,  permitting  and  controls  of  point  source  and  diffuse 
pollution,  as  well  as  of  any  activity  causing  hydromorphological  impacts,  is  very  important.  The 
Netherlands seeks to improve the link between water quality objectives and permitting, control and 
enforcement systems which had become too decentralised and fragmented. There is also a more 
integrated cooperation between installations, permitting authorities and controlling and enforcement 
authorities and appropriate training for permitting authorities now in place. However, permits may be 
granted for an unlimited period of time and no periodic review is foreseen as required under the WFD.  

Additional measures are in place to address pressures from specific pollutants causing at least 5% 
of water bodies to be in bad status. For instance, dental amalgam is no longer used, mercury is being 
taken  out  of  wastewater  from  waste  incineration.  Cadmium  and  nickel  are  causing  water  quality 
problems, in particular in the Meuse RBD (cadmium in manure from cattle and pigs and broilers has 
been seriously reduced since 2008, by reduction of cadmium in phosphate fertilisers. 

The use of PAHs coatings is forbidden on inland ships and PAH’s in water will also be reduced by new 
rules for wood burning stoves, new motors in vehicles. 

37 Waterbeleid | Tweede Kamer der Staten-Generaal 

30 

 
 
The production of PFOS has stopped in 2002 already, and PFOA is prohibited in consumer products 
since 2020. This will contribute to their reduced emissions to water. The Netherlands is in favour of 
a ban on use of PFAS (for as many applications as possible) in the context of REACH Regulation. In 
relation to ammonium, there are measures to establish reduced ammonia emission barns, injecting 
manure in soil and transport outside the Netherlands. 

For pressures from river basin specific pollutants such as arsenic, boron, cobalt, selenium, uranium 
and silver, more insight is needed into the sources before additional measures can be formulated. 

For pesticides there is a strategic plan including recommendations for more sustainable use; however, 
measures have not proven effective since harmful pesticides are often replaced by  other, not less 
harmful pesticides. Some regional authorities set additional requirements. The province Zuid-Holland 
for instance has forbidden the use of pesticides in its natura protected areas. 

Nutrients  leaching  from  agriculture,  wastewater  treatment  and  flowing  in  from  upstream 
transboundary sources remain problematic. The deposition of ammonia as a result of transboundary 
air pollution is not taken into consideration to address problematic nutrients loads. There still is a 
manure excess which prevents compliance with the Nitrates and Water Framework Directives. The 
7th Nitrates action programme focusses on hotspots and mixes mandatory and facilitating measures 
and  nation-wide  as  well  as  area  specific  measures.  Considering  the  wide  variety  in  agricultural 
sectors, the ‘Deltaplan Agrarisch Waterbeheer38’ focuses on mainly voluntary emission reductions, 
through cooperation with the relevant sectors. 

In conclusion, despite the adoption of the ‘IMPULSE’ programme, additional measures may not be 
sufficiently  effective,  as  much  seems  left  to  voluntary  uptake,  including  agreements  with  various 
sectors. There don’t seem any binding requirements on policy areas other than water management 
which are necessary to achieve good status. This situation in which actors have too much discretion 
to address WFD issues, may worsen with the entry into force of the new Environment and Planning 
Act39, as a number of activities impacting water systems will no longer need to be licensed.  It is 
worthwhile noting that the national Parliament has endorsed a motion calling on the government to 
consider a lowering of objectives in 2027 for those water bodies for which it would be unrealistic to 
comply, because of the negative economic and social consequences. 

Table 4: Reported obstacles to progress in achieving PoM objectives between the 2nd and 3rd RBMPs 

Obstacle 

Number of RBDs 

Governance 

Delays 

Lack of Finance 

Lack of Mechanism 

Lack of Measures 

Measures not cost effective 

Extreme Events 
Other:  
1. Land acquisition  
2. Drought  
3. Programmatic approaches to nitrogen  
4. PFAS policy 

0 

4 

4 

0 

0 

4 

3 (excluding Rhine) 

4 (all 4 are in all RBDs) 

38 Mededeling | Deltaplan Agrarisch Waterbeheer 
39 General information on Environment and Planning Laws | Informatiepunt Leefomgeving (iplo.nl) 

31 

 
 
5. Exemptions and economics 

5.1 To what extent are exemptions applied in the Netherlands 

According to the WFD, 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. A significant number of exemptions 
are  still  applied,  under  the  different  paragraphs  (categories  of  exemptions)  with  the  exception  of 
Article 4(5). 

There are factsheets available for each water body, which describe the water body, its objectives, its 
current  status,  pressures  and  impacts,  measures  and  provide  a  summary  of  the  exemptions  and 
related justifications40. This is a good practice and in line with the WFD requirement to specifically set 
out and explain the reasons for exemptions in the RBMPs. 

Article 4(4)-time related exemptions apply on grounds of technical feasibility, disproportionate costs 
or natural conditions.  

Their number has increased for chemical status in surface water bodies, since the number of surface 
water bodies not achieving good chemical status has increased from 61% to 91%, and they apply to 
most surface water bodies due to ubiquitous persistent bio-accumulative and toxic substances which 
are difficult to address. The reasons for these exemptions are provided at the water body level and 
for each water body a factsheet with detailed justifications for each exemption has been developed.  
Most exemptions for surface water bodies were justified on grounds of technical feasibility, followed 
by  natural  conditions  and  disproportionate  costs.  More  than  one  exemption  ground  argument  is 
usually applied to the same water body.  

Figure 10: Use of Article 4(4) exemptions for surface water bodies  

Use of Article 4(4) derogations in surface waters

1
0,9
0,8
0,7
0,6
0,5
0,4
0,3
0,2
0,1
0

Technical feasibiliy

Natural conditions

Disproportionate costs

Ecological Status

Chemical Status

For groundwater bodies, 1 out of 23 is exempted for quantitative status and 3 out of 23 for chemical 
status. Just like for surface water, more than one exemption applies per water body. Most exemptions 
were justified on grounds of technical feasibility (13% for chemical status and 4,3% for quantitative 
status), followed by natural conditions and disproportionate costs (4,3% for chemical and quantitative 
status, for both justification grounds).  

40 KRW-factsheets | Het Waterkwaliteitsportaal 

32 

 
 
 
The main reasons argued under ‘technical feasibility’ were: 

the need for further research to determine the cause of failure,  

• 
•  uncertainty of availability of land to carry out the measures and time required to go through 

procedures to acquire it 
• 
transboundary pollution and  
•  hydromorphological conditions. 

The main reasons provided under ‘natural conditions’ were 

• 

• 

• 

the  long  time  needed  for  hydromorphology,  substances  and  biology  to  adapt  to  the  new 
conditions with some measures requiring 10 years or even longer to take effect 
residual diffuse pollution from leaching pollutants since long present in the environment (e.g. 
sediments) even after reduction of the source of pollution, and  
the influence of non-native species that can have negative effect on fish stocks, native plants.  

Reasons  provided  under  ‘disproportionate  costs’  are  based  on  cost-benefit  assessments,  also 
including affordability and social and sectoral impacts. Costs and benefits are considered at the level 
of a management area, rather than at a water body scale. For some water bodies the costs were put 
in perspective of an excessive burden on the budget, a disproportionate increase in local taxes or 
levies or the necessary land not being available at market prices due to an increased demand. To 
alleviate the cost, infrastructure related measures are aligned with asset replacement periods (i.e. at 
end of lifetime). Adaptation of urban wastewater treatment plants to treat new substances is planned 
to  take  place in phases, to  allow  coordination  with innovations  generating  energy,  recovering  raw 
materials or enabling water reuse. National political considerations also play a role, in particular for 
measures to address manure whilst ensuring a viable agricultural sector. 

Article 4(5) exemptions (lowered objectives)  

It is positively noted that they have not been applied at all, as in previous cycles.  

Article 4(6) exemptions (temporary deterioration) 

Regrettably their number has seriously increased from 18 in the 2nd RBMPs to 87 in the 3rd RBMPs, 
affecting (only) surface water bodies in two RBDs (86 in the Rhine RBD and one in the Meuse RBD).  
Most  exemptions  were  justified  by  reference  to  natural  causes  (prolonged  dry  summers  in  2018, 
2019 and 2020), two because of accidents and four because of force majeure. Factsheets explain, 
for  each  affected  water  body,  quality  elements  affected  (e.g.  phytoplankton,  specific  pollutants, 
physico-chemical  parameters),  reasons,  planned  measures  and  their  anticipated  impact.  In  some 
cases  (30  water  bodies),  the  justification  is  not  appropriate  because  it  refers  to  natural 
variations/monitoring effects (an effect of methodology/monitoring). In 55 water bodies, the reasons 
for deterioration of physico-chemical quality elements were explained by drought/peak discharges. 
Where drought/showers are mentioned as grounds, in most cases this concerns an effect on physico-
chemical parameters; in only a few cases, biological quality elements are also affected. According to 
the Netherlands, this should therefore mainly be seen as an early warning, rather than as an actual 
decline. 

Article 4(7) exemptions (exemption to the obligation of non-deterioration, in case of new 
modifications or sustainable human development activities) 

An Article 4(7) derogation has only been applied to one surface water body (compared to 2 in the 2nd 
RBMPs).  There  is  an  explanation  provided  in  the  fact  sheet.  In  the  Netherlands,  deterioration  is 
assessed  on  a  time  scale  of  the  six  years  planning  period  rather  than  for  project-specific/shorter 

33 

 
timelines. A ‘Policy Rule’41 sets out guidance for project-specific evaluations. The objective is to avoid 
deterioration  or  prevention  of  achievement  of  good  status/potential  by  means  of  mitigation 
measures. There is a general exemption for projects considered not ecologically relevant. Article 4(7) 
WFD does not however set such a ‘de minimis‘ rule for assessing impacts. In addition, the ‘Policy Rule‘ 
does  not  include  guidance  for  assessing  cumulative  impacts,  overriding  public  interest  or  better 
environmental alternatives, as required by the WFD. 

The Netherlands have also raised a problem of ‘moving’ around sediments as a result of dredging 
activities which would not be in the scope of Art 4(7) (and therefore could not be justified thereunder) 
but might in some cases result in deterioration of chemical status of a water body, even if there is 
no effective additional input of pollutants into the environment. 

5.2 Use of economic analysis and water pricing – cost recovery 

Extent of reporting of the (summary) of the underlying economic analysis (Annex III WFD) 

The Netherlands report that the economic analysis from the 2nd RBMPs has been updated with data 
from after 2015, whereas the methodology has remained the same. However, the summary in the 
3rd RBMPs seems too concise to verify whether gross modo the required analysis elements listed in 
WFD Annex III have been adequately covered in the update, including investment forecasts beyond 
2027, the end of the programming period. It remains therefore unclear whether the analysis has 
made  use  of  up-to-date  long-term  water  supply  scenarios  from  the  national  climate  adaptation 
strategy (including those underlying the Delta Program). The focus in the RBMP report appears on the 
trends in the main drivers of water demand, but without a quantitative confrontation of long-term 
supply and demand, the economic analysis does not sufficiently explore when and where bottlenecks 
may occur beyond 2027.  

A supporting document reports on the costing of measures and provides a so-called “quick scan cost-
benefit analysis” which has informed the selection of measures into the Programme of Measures. It 
is however not explained whether this relates to the prescribed use of cost-effectiveness analysis.  

Cost recovery and adequate contribution of water use sectors 

The mechanism of cost recovery is laid down in a national law (Drinking Water Act, Municipalities Act, 
Water Boards Act, Water Act). […].  

The  RBMPs  reports  that  due  to  this  solid  anchoring  of  the  cost  recovery  mechanism  in  national 
legislation, the defined broad water services (drinking water supply; sanitation services; wastewater 
management; groundwater management and regional water quantity management) achieve (nearly) 
full cost recovery, similar as in the 2nd RBMPs. This implies that there are no significant subsidies 
paid for the delivery of water services, and that it is not necessary to invoke any of the mitigation 
factors to cost recovery as listed in article 9 of the WFD. 

Table 6.d of the RBMP provides data on the costs of water services and other costs related to water 
quality management, as well as how these are financed. Figures are provided at the level of water 
service, without a differentiation across water use sectors. On the other hand, WISE reporting shows 
that the broad user sectors - households, industry and agriculture - contribute to the cost recovery 
of  water  services.  However,  the  RBMP  lacks  a  clear  account  on  the  adequacy  of  these  sectorial 
contributions.  

41 Staatscourant 2022, 6470 | Overheid.nl > Officiële bekendmakingen (officielebekendmakingen.nl) 

34 

 
 
Water prices and the price incentives to use water efficiently 

The RBMPs include a clear description of how the costs are recovered for the individual water services 
through pricing measures: 

•  Drinking water supply to households is subject to an average price of 1,35 EUR per cubic 

meter, excluding all taxes;  

•  Supply of freshwater to the agricultural sector is sometimes charged by Water Boards but 
no further details are given on what the charges are or when this applies (eg in areas with 
brackish water); 

•  Collection/ disposal of rainwater/wastewater is subject to a sewerage levy by municipalities;  
•  Wastewater  treatment  is  subject  to  a  treatment  levy  for  discharges  into  sewers  and 
treatment  plants  and  pollution  levy  for  discharges  into  surface  waters;  amount  based  on 
number of pollution units; 

•  A groundwater levy is applied for large-scale withdrawals by water companies and industry, 
charged by Provinces; however no levy is applied for smaller withdrawals for domestic use 
or agricultural applications; not considered cost-effective (no metering of these uses); 

•  A regional water system management levy is charged by Water Boards. 

However, the RBMPs do not give an explicit account on the adequacy of the price incentives to use 
water  efficiently.  They  do  not  give  details  on  the  effect  of  these  pricing  policies  on  water  uses 
(including reducing and avoiding pollution), and only very limited information on the structure of the 
tariffs and levies. Also, the environmental and resources cost (ERCs) estimates, i.e. the value of water 
for alternative users including its ecological value for ecosystems, are not taken on board. 

However, triggered by the periods of drought in recent years, the Ministry of Infrastructure and Water 
Management has recently announced a new policy called ‘water en bodem sturend’42. As part of this 
new policy, the Ministry is now again explicitly looking at pricing as a potential instrument to reduce 
overall water consumption. The results will be presented in the next plans. 

Polluter Pays Principle  

There does not seem to be a comprehensive account on how the Polluter Pays Principle is applied. 
This  may  however be  considered  as  being  implicitly  covered  by  the  RBMP  discussion  of  the  price 
instruments (see above). 

Funding 

Finally,  Chapter  6.6  of  the  RBMP  lists  public  funds  available  under  various  funding  mechanisms, 
allowing for funding of measures to improve water quantity and quality: i.e. Horizon 2020 (water-
related research programmes), Structural and Cohesion Funds (ERDPF, to support activities, especially 
along borders that contribute to WFD goals) and LIFE (projects related to nature, biodiversity, circular 
economy and quality of life, climate mitigation and adaptation, energy transition). 

42 Kabinet maakt water en bodem sturend bij ruimtelijke keuzes | Nieuwsbericht | Rijksoverheid.nl 

35 

 
 
 
6. WFD recommendations 

The  Netherlands  should  urgently  address  problems  to  improve  the  hydromorphology  of  their  waters  (river 
dynamics, bank characteristics, etc.), to reduce concentrations of nutrients and chemicals in surface water, as 
well as, to a limited extent, in groundwater, and to prevent water shortages during dry periods. 

The Netherlands should therefore:  

1. 

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

a) 

the  development  of  more  ambitious  Programmes  of  Measures  including  additional  measures  and 
consider making these mandatory; 

b)  clarifying tasks and responsibilities of authorities in charge of water management and ensure better 
coordination between the different administrative levels and authorities in charge of implementing the 
Water Framework Directive and other related policies, including Marine and Nitrates Directives; 

c)  Ensuring full compliance with WFD provisions related to mandatory periodic review of permits/controls 
for all relevant activities impacting water bodies (including abstraction, impoundment, discharges).  

2. 

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

a)  Stepping up action to drastically reduce nutrient pollution (the nitrogen surplus being four times higher 
than the EU average, with 50% coming from agriculture), by assessing the effectiveness of existing 
measures and implementing additional measures as necessary to achieve the objectives of the WFD, 
including mandatory measures if voluntary measures appear insufficient and through securing greater 
synergies between the WFD goals and other policies and instruments (CAP, MSFD and NiD). This has 
also been highlighted in the recently adopted Semester report for the Netherlands, which calls for more 
efforts to make agriculture more sustainable, by cutting the use of chemical pesticides and inorganic 
fertilisers; 

b) 

Increasing funding for sustainable water management (Semester report identified a gap of €1.2 billion);   

c)  Continuing to ensure that, for chemical pollution, the Programmes of Measures include a sufficient 

number of mandatory measures to achieve compliance; 

d)  Stepping up research activities to identify sources of pollution by several substances, so as to enable 

identification of the required additional measures; 

e)  Ensuring that permits of all UWWTPs and other industrial installations discharging into surface waters 
are reviewed, and, where so required, updated prior to the end of the third RBMP cycle, so as to enable 
the identification and implementation of necessary measures to reduce pollution; 

f)  Enhancing  efforts  on  nature-based  solutions  including  re-naturalisation  and  ecosystem  restoration 

which will reduce the hydromorphological pressures on water bodies; 

g)  Providing more clarity on the establishment and use of ecological flows, that is the level of water that 

must be left in the water body for the ecosystem to properly function; 

h)  Review  the  application  of  the  Polluter  Pays  Principle  as  regards  both  the  funding  of  the  pollution 
abatement measures in the Programme of Measures and the cost recovery of water services, in view 

36 

 
of ensuring an adequate contribution of those water uses that exert an upward cost pressure on water 
supply and water treatment. 

3.  Where the objectives of the Directive for a specific water body cannot be met and exemptions are invoked, 
this should be done in line with ECJ jurisprudence on the restrictive interpretation of exemptions, providing 
a detailed justification at the level of the water body and it should be ensured that their application is 
regularly reviewed. This implies, for the Netherlands: 

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

b)  Not applying a ‘de minimis’ rule in respect of new projects potentially deteriorating status in accordance 
with Article 4(7) WFD and provide more detailed justifications on those exemptions for new projects, 
including new dams and water transfers, including by detailing cumulative effects, the assessment of 
better  environmental  options,  and  the  measures  taken  to  mitigate  the  adverse  impacts  of  new 
developments. 

4.  As regards monitoring, assessment, data management and reporting, the Netherlands should: 

a) 

further  strengthen  monitoring  systems  to  close  gaps  both  in  terms  of  geographic  coverage  and 
parameters  covered,  in  particular  monitoring  of  hydromorphological  quality  elements  in  all  water 
bodies and of general physico-chemical quality elements and other aquatic flora in all coastal water 
bodies; 

b)  Ensure  monitoring  for  chemical  status  in  all  surface  water bodies  in  which  priority substances  are 
discharged and ensure that monitoring in biota for status assessment takes place annually, unless 
longer intervals can be justified. 

37 

 
 
SECTION B: 
FLOODS DIRECTIVE 

38 

 
 
 
7. Flood risk management under floods directive (FD) 

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

There are four Units of Management (UoMs) in the Netherlands, which are the same as the Water 
Framework  Directive’s  River  Basin  Districts  (RBD).  Fluvial,  sea  water  and  artificial  water  bearing 
infrastructure are considered as potentially significant sources of flooding in the Netherlands. The 
Netherlands has designated 14 Areas of Potential Significant Flood Risk (APSFRs)43. The Netherlands 
considered the IPCC scenarios for climate change impacts on flood risks at the time of the second 
preliminary  flood  risk  assessment.  The  outcomes  of  several  projects  that  took  into  consideration 
these  IPCC  scenarios  have  been  summarized  in  the  ‘Deltaprogramma’,  which  is  the  national 
adaptation strategy. The Deltaprogramma includes scenarios on climate change, and these are used 
to identify and detect flood risks. 

7.1 Flood hazard and risk maps 

The Netherlands are using online map portals for their FHRMs. FHRMs were prepared at the national 
level and show the whole country covering all four UoMs. All APSFRs are covered by the FHRM. Maps 
for floods with low probability (1/1 000 years), with medium probability (1/100 years) and with high 
probability  (1/10  years)  are  provided,  with  legends  and  explanation  of  features.  Extremely  low 
probability (1/10  000 years)  is  also  considered,  on  a  separate map.  The maps  clearly  show  flood 
extent and water depth, using six different colours for different depths. They also clearly show the 
number  of  inhabitants  and  type  of  economic  activity,  again  distinguishing  between  six  ranges  of 
inhabitants and six types of activities. Installations covered by the Industrial Emissions Directive (IED) 
are  included,  distinguishing  between  three  different  sizes  but  the  meaning  of  those  is  not  clear. 
Potentially affected protected areas identified in Annex IV(1)(i), (iii) and (v) to Directive 2000/60/EC 
are shown in the FHRMs as “vulnerable areas”. 

In terms of changes of contextual information since the 1st FHRMs (i.e. the way in which information 
about the maps is conveyed to the public), these include: pl (a) for the 2nd FHRMs, the Netherlands 
now also reported a manual explaining the method of development of the maps, which is available 
to the public; (b) the 2nd FHRMS provide information on limitations of the maps and assessments of 
uncertainty for the low-probability scenario and (c) the 1st FHRMs only identified a single map portal 
containing both flood hazard and risk maps; whereas for the 2nd FHRMs, two portals were identified, 
one of which only contains flood risk maps.  

In terms of actual information provided on the maps, there are several similarities and differences 
since the 1st FHRMs: In the 1st FHRMs, the Netherlands presented seawater and fluvial flood hazards 
for all four UoMs. However, these were shown together on the map in an indistinguishable manner. 
The latter is still the case in the 2nd FHRMs. Indeed, despite the Netherlands having a coastline, neither 

43 The Netherlands did not designate APSFRs for the 1st PFRA, basing itself on the possibility provided under Article 
13(1)(b) of the Floods Directive.  

39 

 
 
the 1st nor the 2nd FHRMs include separate information on sea water flooding. The 1st FHRMs did not 
cover pluvial floods, groundwater floods, floods due to artificial water bearing infrastructure sources. 
On the other hand, the 2nd FHRMs (Risicokaart) now also show different national “types” of floods, 
based  on  a  classification  of  the  main  versus  the  regional  water  system  and  whether  areas  are 
protected  or  not  by  flood  defences.  They  also  consider  floods  from  artificial  water  bearing 
infrastructure, which were not considered in the 1st FRHMs. 

In the 1st FHRMs it was possible to choose which UoM is shown, which is no longer the case in the 2nd 
FHRMs.  Also, in  the  previous  FHRMs the Netherlands  reported  potentially  affected inhabitants  per 
UoM rather than per APSFR, whereas in the 2nd FHRMs no information is reported per UoM. While the 
1st FHRMs showed scenarios for three flood probabilities, the  2nd FHRMs show four scenarios, now 
also including a very low probability (extreme event) scenario. In both 1st and 2nd FHRMs, the maps 
show  water depths but  not  water  levels,  although  in  the  1st  FHRMs  flow velocities  were  provided, 
which is no longer the case in the 2nd FHRMs. In both 1st and 2nd FHRMs, the maps show potential 
adverse consequences, specifically, consequences for: an indicative number of inhabitants, areas of 
economic  activity  and  use,  facilities  containing  potentially  dangerous  substances,  properties, 
installations related to accidental pollution and locations of WFD protected areas. There is no mention 
however of cultural heritage. Unlike in the 1st FHRMs, the 2nd FHRMs now also show drinking water 
abstraction areas, Natura 2000 sites or bathing water sites, though only on the bij12 maps.  

In terms of changes in methodologies used to prepare flood hazard maps since the 1st FHRMs, 
in the 1st FHRMs, only three probabilities were considered (1/10, 1/100 and 1/1 000), whereas in the 
2nd FHRMs four were considered (also 1/10 000 years was considered for the development of the 
maps). In the  1st FHRMs, floods with return periods of 1/100  – 1/300 years were depicted on the 
medium probability hazard map, floods with return periods of 1/500 – 1/10 000 years were depicted 
on the low probability hazard map, and on the maps for high probability hazard (approximately 1/10 
years return period), floods in unprotected areas are shown. The Netherlands reported in the 1st FHRM 
that to prepare the flood risk and hazard maps, scenarios were developed that assumed hypothetical 
failure  of  the  flood  defences.  The  maps  showed  what  flood  risks  and  hazards  are  prevented  by 
maintaining  flood  defences  according  to  the  given  safety  standards.  This  methodology  was  not 
followed in the 2nd FHRMs. Whereas in the 1st FHRMs flood defences were considered as providing a 
level  of  protection  based  on  the  normative  standards  (given  above),  in  the  2nd  FHRMs  they  were 
assumed as absent and depicted on a separate layer on the map.  

In terms of changes in methodologies used to prepare flood risk maps since the 1st FHRMs, there 
is only one change, in relation to the assessment of the risk to human health: in the 1st FHRMs, this 
risk was, for each UoM, determined based on the number of inhabitants per 100m2 (shown for six 
ranges, with the different categories indicated by a different shading). There were no details on how 
this  was  calculated.  In  the  2nd  FHRMs,  it  is  specified  that  the  number  of  inhabitants  is  based  on 
Centraal Bureau voor de Statistiek statistics of the number of inhabitants per hectare.  

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

7.2 Flood risk management plan 

The 2nd FRMP (one plan integrating and updating the previous four FRMPs of the first cycle) can be 
downloaded from the website of an intergovernmental programme providing information about the 
environment and environmental legislation and is also available on the national government’s main 

40 

 
website44.  The  results  of  the  FHRMs  were  used  as  the  basis  for  the  FRMP’s  new  objectives  and 
measures. 

Objectives 

The Netherlands has set general objectives, and specific objectives for four types of flood risk areas 
(which  are  carried  over  from  the  FHRMs).  The  objectives  aim  to  reduce  flooding  consequences, 
including limiting damage in areas along the main water system which are not protected by flood 
defences and limiting the risk of death in areas protected by flood defences. The objectives also aim 
to  reduce  the  likelihood  of  flooding,  by  referring  to  spatial  planning  and  to  crisis  management.  
Notably, one objective calls for the Netherlands to be ‘climate-proof and water-robust’, which implies 
that  the  Netherlands  is  aware  of  its  vulnerability  to  floods  and  has  implemented  measures  to 
minimise  vulnerability.  The  FRMP  refers to  the  Delta  Plan  on  Spatial  Adaptation,  which  addresses 
spatial  development  in  general  and  vital  and  vulnerable  infrastructure  in  particular.  While  the 
objectives  are  expected  to  reduce  adverse  consequences  on  economic  activity,  environment  and 
cultural heritage, these elements are not specifically addressed.  

Measures 

The FRMP lists 34 measures, indicating for each measure whether it is ‘very high’ or ‘high’ priority. In 
EIONET, 119 measures are reported, 52 of which are marked as ‘very high priority’ (44 %) and the 
remaining 67 marked as ‘high priority’ (56 %). While half of the preparedness measures are very 
high priority (32 measures, 51 % of the 63 preparedness measures), only about  one-third of the 
prevention and protection measures are very high priority.  

The  FRMP  does  not  indicate  how  the  progress  of  the  measures  will  be  monitored,  though  the 
Netherlands did report the progress of its measures. 

The FRMP does not provide information on the cost of measures, nor was this information reported. 
The FRMP does not refer to the use of CBA or other economic analysis of its measures, although the 
law requires the FRMP to take account of costs and benefits. The FRMP states that the funding of 
measures is primarily at national level. The Delta Programme, a number of whose measures target 
FRM,  arranges  its  financing  through  the  national  Delta  Fund.  The  use  of  cost-benefit  analysis  or 
related methods is not mentioned in the FRMP.  

The FRMP includes summary flood hazard and risk maps, which were used as a basis for its objectives 
and measures. Flood conveyance is considered an important feature, just like natural water retention 
which is referred to in both FRMP measures and Delta Programme measures. As a rule, areas not 
protected by flood defences are considered potential areas to absorb flood waters. New measures 
should be assessed with respect to WFD objectives.  

Prevention (spatial/land-use measures), protection and preparedness measures are in place for all 
UoMs.  Preparedness  measures  include  forecasts  and  early  warning  systems.  The  FRMP  includes 
measures that mention nature-based solutions. There is no indication however that ports and (inland) 
navigation have been specifically considered. On the other hand, in line with the first general objective 
addressing climate change, the FRMP contains extensive information on the likely impact of climate 
change. 

Progress  

In the 2nd FRMP, the area-specific objectives are tailored to the different types of flood areas and 
provide specific and in some cases measurable elements. In the 1st FRMPs the Netherlands did not 

44 overstromingsrisicobeheerplan-2022 (5).pdf 

41 

 
 
indicate whether a baseline is used for monitoring progress, which is also the case for the second 
one. The 2nd FRMP and its objectives are clearly linked to a range of other national policy and planning 
documents, as well as to sub-national activities. However, the FRMP provides only an overview of 
these links and of the process for setting its objectives without describing the process in more detail. 
The general objectives of the 2nd FRMP provide a long-term vision for flood risk management. 

In the 1st FRMPs the objectives were not specific or measurable. The 2nd FRMP provides an overview 
of the achievement of the objectives in the 1st FRMPs, and reports on implementation of the measures 
related to those objectives. Progress is reported according to three categories: ongoing construction, 
ongoing  (recurrent  e.g.  maintenance  works),  and  in  preparation.  No  completed  measures  or 
abandoned/interrupted  measures  were  reported,  although  the  FRMP  mentions  those.  The  great 
majority of measures are reported as ongoing (recurrent e.g. maintenance works). Just over half are 
for  preparedness.  The  review  of  the  measures  indicates  that  essentially  all  are  implemented, 
including non-structural ones. For a measure to strengthen primary flood defences, the plan briefly 
notes that defences have been reinforced, rivers have been widened and programmes such as ‘Space 
for the River’ were completed. In addition, 797 km of regional defences were strengthened in the 
period  from  the  introduction  of  the  1st  FRMPs  to  2019.  Nonetheless,  for  most  objectives  and 
measures from the 1st FRMPs, the 2nd FRMP refers to the need for ongoing attention. Many of the 
measures in the 1st FRMPs continue in the 2nd FRMP, and this is coherent with the reporting to EIONET 
that most measures are ongoing. The 2nd FRMP indicates that its objectives and measures will be 
monitored to measure progress. 

Governance 

The FRMP highlights strong cooperation with other Member States, within the context of international 
river basin commissions and bilateral working groups. The FRMP and the Netherlands’s reporting to 
EIONET emphasises strong coordination with the WFD.  

The FRMP notes active involvement of stakeholders, though primarily through the National  Water 
Plan (NWP), not directly for the FRMP itself. The FRMP45 describes how the public was consulted for 
the NWP, to which the FRMP is annexed. The FRMP reports that the draft NWP was presented for 
public consultation for six months. This consultation covered the NWP’s annexes, including the FRMP. 
Participants in the stakeholder consultation sessions for the NWP, including a session held with public 
authorities as well as thematic sessions with civil society and interest groups, received a report on 
the session, together with feedback on whether and how their input was incorporated. 

Consideration of climate change 

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

Progress identified in the second FRMPs 

The general objectives of the 2nd FRMP provide a long-term vision for flood risk management. Contrary 
to the 1st FRMP, in the 2nd FRMP, the area-specific objectives are tailored to the different types of flood 
areas and provide specific and in some cases measurable elements. Moreover, the 2nd FRMP and its 
objectives are clearly linked to a range of other national policy and planning documents, as well as 
to sub-national activities. The 2nd FRMP does refer to the national climate strategy, it mentions pluvial 

45 FRMP, p. 54. 

42 

 
 
flooding and indicates that this source of flooding is expected to increase in importance due to climate 
impacts. 

8. FD recommendations 

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

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Consider pluvial floods in the FHRM; 

Consolidate in one website all information available on the subject or provide clear links to relevant sources 
of information; 

Explicitly consider cultural heritage in the FHRM; 

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

The relationship between the objectives set out in the FRMP and in other documents should be clearer. An 
assessment of the progress made towards the achievement of the objectives should be included in the 
FRMP. 

Include in the FRMP the methods used to monitor the progress of measure;. 

Consider insurance as a potential measure for adaptation to climate change; 

Incorporate in the FRMPs, where relevant, a CBA for the prioritisation of measures that lend themselves to 
it and provide a clear description of the methodology used; 

Provide  details  in  the  FRMP  on  public  consultation  comments  received  and  how  they  were  taken  into 
account; 

Consider an SEA for the FRMP, or if the FRMP is part of another plan that underwent an SEA, how that SEA 
is related to the FRMP; 

Consider in the FHRM, where appropriate, flow velocity or relevant water flow and the in the FRMP flood 
conveyance routes, as these are relevant to emergency response. 

43