COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans Member State: Spain 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: Spain, 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) 24 final  COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans    Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans   Member State: Spain 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) 25 final} - {SWD(2025) 26 final} - {SWD(2025) 27 final} - {SWD(2025) 28 final} - {SWD(2025) 29 final} - {SWD(2025) 30 final} - {SWD(2025) 31 final} - {SWD(2025) 32 final} - {SWD(2025) 33 final} - {SWD(2025) 34 final} - {SWD(2025) 35 final}  
 
 
y
n
a
r
V
n
a
p
e
t
S

|

m
o
c
s
l

.

e
x
e
P
©

Country specific staff working document 

Spain 

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 ...................................... 16 

3.1 Surface Water: what is their ecological status or potential .................................................................... 16 

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) .......................................... 17 

3.3 Groundwater bodies - have they sufficient water – quantitative status ......................................... 18 

3.4 Protected Areas (identification, monitoring, objectives and measures) ........................................... 20 

3.5 What is being done to prevent/reduce hydromorphological pressures ............................................ 21 

3.6 What Spain is doing for abstractions and water scarcity ......................................................................... 22 

3.7 Adaptation to climate change .................................................................................................................................. 24 

4. Policy elements contributing to zero pollution ........................................................................................................ 25 

4.1 Surface Water: what is their chemical status ................................................................................................. 25 

4.2 Groundwater Bodies: what is their chemical status .................................................................................... 28 

4.3 What Spain is doing to combat pollution from agriculture ..................................................................... 30 

4.4 What Spain is doing to combat pollution from other sectors ................................................................ 31 

4.5  What  Spain  is  doing  to  combat  significant  pressures  –  overall  assessment  of  the 
Programmes of Measures .................................................................................................................................................. 32 

5. Exemptions and economics ............................................................................................................................................... 32 

5.1 To what extent are exemptions applied in Spain .......................................................................................... 32 

5.2 Use of economic analysis and water pricing – cost recovery ................................................................ 34 

6. WFD recommendations ........................................................................................................................................................ 35 

SECTION B: FLOODS DIRECTIVE .................................................................................................................................................. 40 

7. Flood risk management under floods directive (FD) ............................................................................................ 41 

7.1 Flood hazard and risk maps ...................................................................................................................................... 41 

7.2 Flood risk management plans .................................................................................................................................. 42 

8. FD recommendations ............................................................................................................................................................ 45 

2 

 
 
 
SECTION A: 
WATER FRAMEWORK 
DIRECTIVE 

3 

 
 
 
1. General info, member state characterisation

Spain  is  the  second  largest  country  by  area  in  the  EU,  with  506,000  km²,  hosting  48,592,909 
inhabitants  in  2024  and  a  population  density  of  over  93  per  km2,  a  bit below  EU  average.  Spain 
features a very large set of coasts having approximately 8,000 kilometres of coastline, including its 
11 major islands and a marine area exceeding 1 million km², divided between the Atlantic and the 
Mediterranean. It comprises the mainland peninsula, along with the volcanic Atlantic Canary Islands 
and  the  Mediterranean  Balearic  Islands.  With  a  relatively  high  average  altitude  over  600  metres 
above sea level, Spain has a very large diversity of rivers, climatic zones and topographic features. 
The natural  fluvial  regime of Spain's rivers mainly depends on the pattern of precipitation, where 
rainwater is transformed into surface water or groundwater. A sharp contrast of precipitations can 
be observed: the north and northwest, which are directly influenced by the Atlantic, have abundant 
rainfall and no distinguishable dry season. This area is sometimes known as the España Húmeda, or 
Wet Spain, with annual precipitation exceeding 600 mm and rising occasionally to 2,000 mm. The 
remainder of the country is predominantly dry, with an annual precipitation of less than 600 mm. 
The  southeast  of  Spain  is  semi-arid,  with  annual  precipitation  below  300  mm  and  a  semi-desert 
landscape  that  at  places  is  reminiscent  of  the  Sahara.  Thus,  74%  of  the  country  is  at  risk  of 
desertification. Agriculture uses almost half of the territory and it is highly varied, with significant 
differences in types of farming between territories. The share of organic farming is around 11 %, 
slightly above the EU average of 9%. Spain is responsible for half of the EU’s production of olives 
and for one third of fruit. Agriculture is the biggest water user in the country and highly dependent 
on  irrigation  (20%  of  farmland). Urban  wastewater  treatment  and  very  high tourism  also  pose  a 
significant challenge in the country. In terms of natural  capital,  Spain is an outstanding reference 
within  EU  and  hosts  a  very  rich  biodiversity.  Currently,  28%  of  the  country’s  terrestrial  land  is 
designated as protected areas, which is slightly above the EU value of 26.4%. 

4 

 
 
 
Reporting 

The deadline for reporting the 3rd 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  cut-off  date  for  the  WISE  e-
reporting was September 2023 and the Member States (MS) were assessed based on the datasets 
available by this date. By September 2023, Spain submitted the electronic reporting of RBMPs except 
for 3 Canary Islands (i.e. Lanzarote, Fuerteventura and La Palma) and therefore the assessment is 
based  on this  dataset (detail  in  section 2.1). To  date,  Spain has  not yet  adopted  the  RBMP  of  La 
Palma. 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,  which  might  have  left  some  minor 
discrepancies when comparing numbers. 

In  order  to  supplement  the  electronic  reporting,  a  selection  of  5  River  Basin  Management  Plans 
(RBMPs) have been reviewed in further depth and details for this assessment. These are River Basin 
Districts (RBDs): Ebro RBD, Guadalquivir RBD, Jucar RBD, Segura RBD and Guadiana RBD.  

5 

 
 
Changes in Status, Pressures, Exemptions & Measures 

Surface 
Water 
Bodies  

Trend (% good 
status/potential) 

Main Pressures & Changes & Exemptions 

The total number of SWBs has increased from 5162 to 5470.  

The overall ecological status/potential remains broadly the same. Spain is expecting that 97.7 % of SWBs should be in at least good 
status/potential by 2027.  

Diffuse nutrient pollution from agriculture, point pollution from urban wastewater and altered habitats due to morphological changes are 
significant, but lower compared to previous cycle. While water abstraction continues to be very significant for a large part of the Spain, 
predictions suggest a risk of desertification and prolonged droughts associated with climate change.  

ECOLOGICAL 
STATUS 

All water bodies have been evaluated regardless of the risk assessment. Some quality elements across biological, hydromorphological, and 
physico-chemical quality elements are not monitored in all SWB categories.   

Exemptions for ecological status were applied under Article 4(4) for technical feasibility to 35.1%, for disproportionate cost to 2.9%, and for 
natural conditions to 5.4% of Surface Water Bodies (SWBs). Article 4(5) exemptions were applied to 0.5% of SWBs for infeasibility and to 
0.2% of SWBs for disproportionate cost, but the reasons are not specified and explained for each individual water body specifically. Article 
4(7) exemptions were applied to 0.2% of SWBs for new modifications.  

6 

 
 
 
 
CHEMICAL 
STATUS 

The overall chemical status remains broadly the same with some improvement, and it is expected that 98 % of surface water bodies will be in 
good chemical status. It is not clear if ES has improved the overall monitoring network or whether all priority substances have been included 
in the monitoring programs of all RBDs.  

The number of surface water bodies classified without a confidence rating has increased drastically (from 7 % to 30 %). Failure to achieve 
good chemical status is mainly linked to metals, Perfluorooctanesulfonic acid (PFOS) and pesticides, with a limited role for ubiquitous 
Persistent Bioaccumulative and Toxic (uPBT).  

Exemptions for chemical status of SWBs are applied under Article 4(4) for technical feasibility to 6.4%, for disproportionate cost to 0.2%, and 
for natural conditions to 0.6% of SWBs. Article 4(5) exemptions were applied to 0.75% of SWBs for infeasibility and to 0.75% of SWBs for 
disproportionate cost, but the reasons are not specified and explained for each individual water body specifically.  

Ground 
Water 
Bodies  

Trend (% good 
status/potential) 

The number of GWBs has increased from 762 to 804.  

Main Pressures & Changes & Exemptions 

7 

 
 
 
 
QUANTITATIVE 
STATUS 

CHEMICAL 
STATUS 

The overall quantitative status of Groundwater Bodies (GWBs) remains roughly the same with a slight decrease and at least 28.5 % of total 
GWBs are at risk of failing to achieve good quantitative status by 2027.  

Most of the GWBs fail good status mainly due to over-abstraction. The most common use of water is for agriculture (65.0 %) followed by 
cooling water in electricity generation, households and services and industry. Since 2016, total water abstraction has decreased in all 
sectors by 23.3 % in total. GWAAEs, GWDTEs and saline or other intrusions are not considered, or only partially, in the groundwater 
quantitative status assessment of all RBDs.  

Exemptions for quantitative status were applied under Article 4(4) for technical feasibility to 16.2%, for disproportionate cost to 1.4%, and 
for natural conditions to 12.6% of SWBs. Article 4(5) exemptions were applied to 0.5% of SWBs for infeasibility and to 1% of SWBs for 
disproportionate cost, but the reasons are not specified and explained for each individual water body specifically. Article 4(7) exemptions 
were applied to 0.2% of GWBs for new modifications.  

ES reports that the chemical status of GWBs has slightly improved, while 43 % of total GWBs are at risk of failing to achieve good 
quantitative status by 2027. 

The assessment of the general chemical situation of a GWB is not conducted homogeneously across different RBDs. Not all substances 
causing risk of deterioration in chemical status are monitored in all RBDs, e.g. pesticides are not monitored in 80% of RBDs. Impact on 
Groundwater Associated Aquatic Ecosystems (GWAAEs) and Groundwater Dependent Terrestial Ecosystems (GWDTEs), saline/other 
intrusions and impacts on drinking water protected areas are not considered in all RBDs. 

As in the previous cycle, the pressures and impacts affecting the highest percentage of GWBs are related to diffuse nutrient pollution from 
agriculture. 

Exemptions for chemical status were applied under Article 4(4) for technical feasibility to 15.3% and for natural conditions to 21.8% of 
SWBs. Article 4(5) exemptions were applied to 0.1% of SWBs for infeasibility, but the reasons are not specified and explained for each 
individual water body specifically. 

8 

 
 
 
 
2. Horizontal aspects 

2.1 Governance 

Depending on the type of RBD, Spain has different competent authorities:   

• 

• 

for  river  basins  that  cross  several  Regions,  the  competent  authorities  are  the  River  basin 
authorities  (Confederaciones  hidrográficas),  which  are  attached  to  the  Ministry  for  the 
Ecological Transition1  
for  river  basins  entirely  located  within  one  region,  the  competent  authorities  are  regional 
hydrological entities.   

Special regimes are applied in the islands: all the Balearic Islands form a single RBD whilst each of 
the 7 Canary Islands is an individual RBD. This means that the decision making for the management 
of the water in Spain is divided between the national and the regional administrations depending on 
the RBD. This has a bearing in the development of the RBMPs.   

In  that  context,  it  must  be  noted  that  some  RBMPs  for  the  Canary  Islands  (i.e.  Lanzarote, 
Fuerteventura and La Palma) had not been formally adopted by the cut-off date on September 2023, 
and this is subject to an infringement procedure referred to the European Court of Justice. Thus, this 
assessment does not include the data from these RBDs as no officially adopted data was reported. 
However, since the designation of the number of national waterbodies remains fairly constant, all 
figures appearing in this report are expressed considering the totality of water bodies for the whole 
Spanish territory.  

All  draft  RBMPs  were  available  for  public  consultation  for  at  least  six  months.  There  have  been 
important  improvements  in  terms  of  communication  and  transparency,  with  consultation  portals 
containing  comments  and  replies  from  public  authorities.  There  has  been  an  increased  use  of 
informative  tasks,  creation  of  registers  of  stakeholders  as  well  as  organisation  of  thematic 
workshops,  territorial  days  and  online  meetings  and  webinars.  Overall,  the  public  participation 
channels have significantly been broadened and more time and resources have been allocated to the 
consultation. However, more feedback should have been provided on how the comments received 
were taken on board.  

As regards the coordination with the Floods Directive and the Marine Strategy Framework Directive, 
although some measures included in some RBMPs are coherent with the aims of both Directives, 
there does not seem to have been a fully coordinated development of the planning tools of these 
laws nor concurrent or jointly organised public participation processes. Such coordination should be 
improved in the future to enhance synergies between these Directives. 

Cross-border and international cooperation 

Spain shares RBDs with 4 countries (France, Portugal, Andorra and Morocco with Ceuta and Melilla) 
Spanish international RBDs do not have International RBMPs (like the Danube has for instance). For 

1 https://www.miteco.gob.es/es.html 

9 

 
 
 
the four International RBDs that Spain shares with Portugal there is international agreement and a 
permanent  co-operation  body  in  place:  the  Albufeira  Convention  since  1998.2,3  For  the  two 
international RBDs shared with France, there is the Toulouse Agreement since 2006.4 Coordination 
efforts between Spain and Andorra are also in place to manage shared interests and responsibilities 
within the Ebro RBD. For Ceuta and Melilla, international cooperation including management of water 
resources  with  the  Kingdom  of  Morocco  is  established  through  the  “Treaty  of  Friendship,  Good 
Neighbourhood and Cooperation between the Kingdom of Spain and the Kingdom of Morocco” since 
1991.5  

2.2 Characterization of River Basin District 

Spain has a very large number or River Basin  Districts, that is 25. Some of the rivers flow to the 
Atlantic  and  some  to  the  Mediterranean.  The  country  has  delineated  5470  Surface  Waterbodies 
(SWB) which represents an increase of 308 of compared to the previous cycle. It has delineated 804 
Groundwater bodies (GWB) which represent 42 more than in the previous cycle. The total length of 
river water bodies decreases by 4.9%, the total area of lake water bodies increases by 270%6 and 
the total GWB area increases by 3%.  

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

RBD 

Name 

Rivers 

Lakes 

Transitional 
Waters 

Coastal 
waters 

Groundwater 
bodies 

ES010 

Miño-Sil 

248  

35  

2  

ES014 

Galicia-Coast 

412  

24  

ES017 

Eastern Cantabrian 

109  

ES018 

Western Cantabrian 

241  

13  

18  

ES020 

Duero 

646  

62  

ES030 

Tagus 

343  

169  

ES040 

Guadiana 

241  

129  

22  

14  

21  

0  

0  

4  

2  

29  

4  

15  

0  

0  

2  

24  

18  

20  

20  

64  

26  

20  

2 https://www.cadc-albufeira.eu/es.html 
3 https://www.boe.es/eli/es/ai/1998/11/30/(1) 
4 https://www.boe.es/eli/es/ai/2006/02/15/(2) 
5 https://www.boe.es/eli/es/ai/1991/07/04/(1) 
6 The vast majority of Spanish lakes are reservoirs (HMWB). In the 2nd cycle, these lakes were reported as heavily modified 
rivers, but following recommendations of the CIS Working Group DIS and the requirements of the reporting database (see 
'WFD Reporting Guidance 2022' section 2.2.3.1.), in the 3rd RBMPs it was decided that the most suitable format to report 
these reservoirs was as lakes. 

10 

 
 
RBD 

Name 

Rivers 

Lakes 

Transitional 
Waters 

Coastal 
waters 

Groundwater 
bodies 

ES050 

Guadalquivir 

344  

95  

13  

3  

86  

ES060 

Andalusian 
Mediterranean Basins 

122  

25  

7  

27  

67  

ES063 

Guadalete-Barbate 

59  

17  

10  

12  

14  

ES064 

Tinto, Odiel and 
Piedras 

41  

13  

11  

4  

4  

ES070 

Segura 

77  

19  

ES080 

Jucar 

313  

51  

1  

4  

ES091 

Ebro 

619  

176  

16  

ES100 

Catalan Basins 

250  

40  

ES110 

Balearic Islands 

70  

ES120 

Gran Canaria 

ES122 

Fuerteventura 

ES123 

Lanzarote 

ES124 

Tenerife 

ES125 

La Palma 

ES126 

La Gomera 

ES127 

El Hierro 

ES150 

Ceuta 

0  

0  

0  

0  

0  

0  

0  

0  

2  

0  

0  

0  

0  

0  

0  

0  

0  

11 

25  

36  

0  

0  

0  

0  

0  

0  

0  

0  

17  

22  

3  

33  

41  

8  

6  

6  

8  

5  

4  

3  

3  

63  

105  

105  

44  

87  

10  

4  

2  

4  

5  

5  

3  

1  

 
RBD 

Name 

Rivers 

Lakes 

Transitional 
Waters 

Coastal 
waters 

Groundwater 
bodies 

ES160 

Melilla 

1  

0  

0  

3  

3  

TOTAL  

4136  

888  

186  

260  

804  

Source: WISE Electronic reporting  

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.  

Regarding status assessment, all SWBs in Spain have been classified for ecological status/potential 
and  the  “one-out  all-out”  principle  is  applied.  However,  there  are  still  many  quality  elements  and 
RBSPs that are not used when classifying status or potential of SWBs.  

It  is  welcomed  that  for  river  types,  the  establishment  of  type-specific  hydromorphological  and 
physico-chemical  conditions  has  slightly  improved,  since  about  one  third  of  river  types  have  now 
conditions established for all relevant hydromorphological and physico-chemical quality elements. 
The situation is very different for lakes: for 93.8% of them, the competent authorities do not use 
hydromorphological  quality  elements  and  for  more  than  half  (54.7%)  they  do  not  use  general 
physico-chemical quality elements,7 This is probably the consequence of an increased number of lake 
Heavily Modified Water Bodies (HMWBs) (reservoirs) but which is of particular importance given the 
strong pressures from agricultural (nutrient) pollution.  

A similar concerning situation can be found for transitional and coastal water body types which do 
not yet have any type-specific conditions established for hydromorphological quality elements.  

When it comes to biological quality elements the situation seems to have worsened, since a higher 
percentage  of  river  types  have  now  no  type-specific  biological  reference  conditions  established 
compared  to  previous  cycle.  Although  most  biological  assessment  methods  for  the  national 
classification system have been intercalibrated with fixed class boundaries, some national types are 
not linked to common intercalibration types so it remains to be clarified how these water bodies have 
been  classified.  It is  welcomed  that  Spain  provides information  on  how  reference  conditions  have 
been coordinated between neighbouring Member States.8  

It is worth noting that the fish fauna has not been considered in the status assessment of lakes, since 
this biological quality element is considered “not applicable” on the basis of the justifications provided 
by  Spain  and  accepted  in  the  intercalibration  decision.9  Regarding  transitional  waters,  the 
intercalibration of reference conditions is flawed for benthic fauna and phytoplankton in estuaries of 
Catalonia and Valencia, as well as for aquatic species (macroalgae/angiosperms) and fish fauna. As 
regards to the coastal waters, specifically Mar Menor coastal lagoon, the intercalibration of reference 
conditions for angiosperms is in progress, and also the revision of the boundaries for Chlorophyll-a, 

7 Physico-chemical elements include thermal conditions, oxygenation conditions, acidification status and nutrient 
conditions. 
8 Transboundary coordination 
9 The 4th intercalibration decision was adopted 27 February 2024. 

12 

 
 
 
benthic  fauna  (macroinvertebrates)  and  macroalgae  are  in  progress.  Also,  there  is  a  gap  in  the 
intercalibration of macrophyte method in rivers for on geographic group (Central/Baltic).  

It  can  be  concluded  that  Spain  shows  some  clear  progress  in  the  establishment  of  type-specific 
reference  conditions  for  some  river  types,  but  it  needs  to  swiftly  advance  in  developing  these 
conditions for all.  

Gaps  to  be  filled  to  achieve  environmental  objectives  are  reported  for  42  chemical  substances. 
However, there are differences between RBDs regarding the number of chemical substances for which 
indicator gaps have been reported. There is certain ambiguity whether emission inventories10 have 
indeed been established, affecting all relevant substances. Despite a reported methodology related 
to the inventory of emissions, discharges and losses for the 3rd RBMPs have been completed, there 
has not been a legally mandated inventory in Spain.  

Regarding the setting of environmental objectives, in most of the RBDs significant pressures on both 
SWBs and GWBs are defined in terms of thresholds and linked with failure of status. On that basis, 
Spain reports that 49.7% of SWBs and 46.7% of GWBs are affected by no significant impacts.  

Surface waters  

The  pressures  affecting  the  highest  percentage  of  SWBs  in  Spain  come  from  diffuse  sources  of 
agriculture and point sources from urban wastewater. As regards agriculture, Spain’s surface used 
for agriculture amounts to 47.5% of the total land area,11 12.8% of this utilized agricultural area is 
irrigated at least once a year,12 with major outputs from four groups of crops including cereals, olive 
trees, non-citric fruits and vineyards, accounting for 67.5% of the total irrigated area of the country.13 
The landscape is also subject to intense livestock farming practices with a very high production of 
slurries.11  

In that context, it is worth mentioning that Spain has just been condemned by the European Court of 
Justice (ECJ) for failing to apply some of the provisions of the Nitrates Directive. Equally, Spain has, 
over the years, encountered  difficulties implementing the Urban Waste Water Treatment Directive 
(UWWTD). Despite the improvement in compliance over the years, for which the use of EU funding 
has been essential, the incomplete implementation of the UWWTD has led to several rulings of the 
ECJ against Spain. According to the last available data, the overall compliance rate in Spain is 84%, 
which is higher than the EU average of 76%.14  

On the other hand, is it important to highlight that Spain is one of the top Member States in the field 
of wastewater reuse, although it is focussed mainly on some Spanish regions and there is still a high 
potential to be tapped.  

As in the previous cycle, SWBs continue to have the most significant impacts from nutrient pollution 
and altered habitats due to morphological changes.  

As regards hydromorphological pressures, hydropower accounted for 17% of Spain’s total installed 
power generation capacity and the share of electricity from hydropower is 20% of total electricity 

10 Article 5 of the Environmental Quality Standards Directive (2008/105/EC) of the European Parliament and of the 
Council of 16 December 2008 on environmental quality standards in the field of water policy, amending and 
subsequently repealing Council Directives 82/176/EEC, 83/513/EEC, 84/156/EEC, 84/491/EEC, 86/280/EEC and amending 
Directive 2000/60/EC of the European Parliament and of the Council. http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:02008L0105-20130913 
11 Commission Report on the implementation of Directive 91/676/EC on 2016-2019 time period. 
12 https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Agri-environmental_indicator_-_irrigation" \t "_blank"  
13 https://www.mapa.gob.es/en/desarrollo-rural/temas/gestion-sostenible-regadios/regadio-espanya/default.aspx  
14 https://water.europa.eu/freshwater/countries/uwwt/data-visualisation/uwwt-figure-4-folder/uwwt-figure-4-es 

13 

 
 
production in 2023.15 With over 20 000 MW capacity, Spain is the third larger hydropower EU producer 
after France and Italy,16 and currently there are more than 1,300 hydropower plants using 40% of 
the total capacity of the reservoirs (i.e. 55 000 hm3). Of those, 450 were built before 1960 and more 
than 100 already existed in 1915. SWBs are significantly affected by pressures from hydropower 
with impacts on the interruption of the hydromorphological continuity of watercourses, preventing 
migratory  fish  of  reaching  their  spawning  grounds,  direct  damage  to  organisms  by  hydropower 
turbines, and habitat changes affecting water levels downstream.  

Given  the  variety  of  conditions  and  habitats,  Spain  is  quite  vulnerable  to  the  establishment  of  a 
number  of  invasive  alien  species.  Several  aquatic  invasive  species  are  already  posing  significant 
pressures on endemic aquatic ecosystems. Around 28 invasive alien species of EU concern17 create 
pressures for freshwaters in Spain. From those the following invasive aquatic plants have an specific 
impact: alligator weed (Alternanthera philoxeroides), floating pennywort (Hydrocotyle ranunculoides), 
African  elodea  (Lagarosiphon  major), Large-flower primrose-willow (Ludwigia  grandiflora),  floating 
primrose-willow  (Ludwigia  peploides),  parrot’s  feather  (Myriophyllum  aquaticum),  broadleaf 
watermilfoil  (Myriophyllum  heterophyllum),  water  lettuce  (Pistia  stratiotes),  water  hyacinth 
(Pontederia crassipes) and african payal (Salvinia molesta). For example, in the Guadiana river more 
than 900 000 tonnes of water hyacinth were removed over 15 years with a cost of more than MEUR 
40.18  In  addition,  animal  species  such  as  wels  catfish  (Silurus  glanis),  zebra  mussels  (Dreissena 
polymorpha) and some alien crayfish, also create local problems.  

15 https://cuervaenergia.com/es/comunidad/sostenibilidad/central-hidroelectrica-en-espana/ 
16 Statistics | Eurostat (europa.eu) 
17 EASIN - European Alien Species Information Network (europa.eu) 
18 https://lifeinvasaqua.com/exposicion-invasoras-mncn/ 

14 

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

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

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

water.jrc.ec.europa.eu. 

[online] 

Status. 

Available 

at: 

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

Groundwaters  

In  the3rd  RBMPs,  the  pressures  on  GWBs  come  mainly  from  agriculture  by  diffuse  sources  and 
abstractions lowering water table. According to the information provided, overall, since the 2nd RBMPs 
all pressures and impacts seem to have a decreasing trend. In this context, it is worth mentioning 
that although the RBMPs do not refer to problems of illegal abstractions of water, in the context of 
the  ongoing  infringement  case  for  the  Doñana  National  Park,  the  competent  authorities  have 
recognised  a  large-scale  problem  of  groundwater  illegal  abstractions  in  some  river  basins.  While 
efforts to stop such illegal activities are underway, they remain a very big pressure on water bodies 
and  dependent  terrestrial  ecosystems.  The  ruling  of  the  European  Court  of  Justice  on  this  case, 
highlighted the need for Spain to better control the abstractions and enhance its knowledge of the 
use of water.  

15 

 
 
3. Policy elements contributing to biodiversity and 

climate change adaptation 

3.1 Surface Water: what is their ecological status or potential 

Monitoring 

It is welcomed that, compared to the previous cycle, Spain has enhanced its diagnosis capacity by 
increasing  the  number  of  monitoring  sites  (approximately  +26%  for  surveillance  and  +20%  for 
operational monitoring).19 In this 3rd RBMPs, surveillance monitoring covers 53.7% of river length, 
67%  of  lake  area,  83.5%  of  transitional  water  area  and  83.7%  of  coastal  water  area;  while 
operational monitoring covers 58.1%, 79.0%, 27.5% and 60.9%, respectively. 

It is noted positively that overall, monitoring for most of the quality elements has increased compared 
to the previous cycle, but as mentioned earlier, some quality elements are not monitored among all 
SWBs,  especially  physico-chemical  quality  elements.  Compared  to  2nd  RBMPs,  monitoring  has:  i) 
decreased  for  macrophytes  and  benthic  invertebrates  in  lakes;  ii)  reduced  to  a  minimum  for 
phytoplankton in rivers; phytobenthos and fish in lakes; angiosperms, macroalgae and hydrological 
and tidal regimes in transitional waters and other aquatic flora in lakes and coastal waters; and iii) 
not been measured at all for morphological conditions in lakes. 

As regards River Basin Specific Pollutants (RBSPs), Spain is monitoring them in all water categories 
and a national guide including a list of 46 recommended RSBPs has been adopted. It is applicable to 
all RBDs,20 which use this list as a starting point and add other RBSPs based on their own analysis. 
The monitoring frequencies for quality elements appears to be in line with the minimum requirements 
of the Water Framework Directive (WFD(. 

State assessment 

Figure 3.1 depicts the evolution of the ecological status over the different planning cycles. It shows a 
nuanced picture. Indeed, compared to the previous cycle there is an increase in the share of SWBs in 
good or better ecological status/potential  from 56% to 58% (i.e. expected to increase to 98% by 
2027). In addition, there are less water bodies in less than good ecological status from 42% to 41%.21 

Despite  these  improvements,  there  are  less  water  bodies  in  high  ecological  status  or  maximum 
ecological potential. These may have deteriorated from high to good which may explain partly the 
higher  number  in  good  status/potential  stated  above,  whilst  decreased  for  moderate  ecological 
status/potential and increased for both poor and bad ecological status/potential. 

19 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. 
20  Real  Decreto  817/2015,  por  el  que  se  establecen  los  criterios de  seguimiento  y  evaluación  del  estado  de  las  aguas 
superficiales y las normas de calidad ambiental. 
21 Spain has created a web portal showing further granularity at RBD level Hydrological Plans and Programme of Measures 
(mapama.gob.es) 

16 

 
 
Figure 2: Ecological status or potential of SWBs, as reported in 2009, 2015 and 2021. 

Source: 3rd RBMPs e-reporting. 

Not  all  SWBs  comply  with  the  environmental  quality  standards  set  for  the  RBSPs,  which  are  the 
compounds  for  which  the  country  considers  there  is  a  local  problem,  and  which  form  part  of  its 
ecological status/potential. 35.4% of rivers, 30% of lakes, 51.4% of coastal waters and 47.8% of 
transitional  water  bodies  do  not  use  RBSPs  for  classification.  The  most  problematic  RBSPs  are 
glyphosate,  which  was  not  that  prominent 
in  the  previous  reporting  cycle,  selenium, 
aminomethylphosphonic acid (AMPA), copper, zinc and enilconazole (IMAZALIL).  

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) 

Spain features a considerable level of human intervention in its water system. Indeed, most of the 
lakes are heavily modified or artificial, but also rivers and coastal waters are subject to significant 
modifications. 

17 

 
 
 
Figure 3: The proportion of natural, heavily modified, and artificial water bodies by water category and 
total 

Source: 3rd RBMPs e-reporting. 

The most notable change compared to the previous cycle is that Spain reports a very large increase 
in the number of heavily modified lakes (from 17% to 70%, that is a change of 568 lake HMWBs). 
This may be the consequence from changing some water body categories from rivers to lakes. In the 
meantime, the share of Artificial Water Bodies (AWBs) has decreased from 15% to 5% for all lakes 
water bodies. 

As regards the environmental objectives for those HMWBs and AWBs, the approach used to assess 
good ecological potential (GEP) is also described in the national reporting guide.22 GEP is defined in 
relation to a reference condition which is the maximum ecological potential (MEP) reflecting as far 
as  possible  that  of  the  closest  comparable  surface  water  body  taking  into  account  the  modified 
characteristics. Overall, the Spanish HMWBs and AWBs are doing worse than the natural water bodies 
and experience more difficulties to achieve their corresponding environmental objectives even if those 
are of a lower level of ambition. Indeed, 50.6% of HMWBs and AWBs achieve good or high ecological 
potential in comparison to 60.9% for natural water bodies.23 

Hydromorphological  and  physico-chemical  quality  elements  are  also  taken  into  account,  via  their 
relationship with biology. Mitigation measures are reported in specific fact-sheets of the RBMPs for 
each HMWB together with the expected ecological changes due to the application of those mitigation 
measures,  and  applied  to  compensate  as  much  as  possible  the  adverse  ecological  effects  of  the 
physical  alteration.  The  most  common  water  uses  associated  with  the  high  level  of  human 
intervention are, in a decreasing order of importance: irrigation for agriculture, drinking water supply, 
energy production and flood protection.  

3.3 Groundwater bodies - have they sufficient water – quantitative status 

Monitoring 

22 Guía del Proceso de identificación y Designación de las Masas de Agua Muy Modificadas y Artificiales - Categoría Río, 
April 2021. 
23 Workbook: WFD_SWB_SurfaceWaterBody (europa.eu) 

18 

 
 
 
Although the total GWB area remains almost the  same, it is noted very positively that Spain has 
substantially increased the national network for monitoring the quantitate status of groundwater, by 
increasing in 21.5% the number of monitoring stations24 and covering at least 85% of total GWBs. 
There is no grouping of GWBs in the 3rd RBMPs. Nevertheless, this means that 14% of GWBs are not 
yet subject to monitoring for quantitative status (12% of GWBs in 2nd RBMPs) and there is still no 
quantitative monitoring for Ceuta (ES150) and Melilla (ES160) RBDs. 

Quantitative status 

It is noted with concern that Spain is still not fully considering the necessary water needs for the 
groundwater  dependant  ecosystems  in  the  water  (GWAAEs)  and  on  the  land  (GWDTEs)  for  the 
quantitative status assessment, as required in the WFD. These are not taken into account in 5 RBDs 
or just partially in 2 RBDs, most of which are located in areas under severe water stress. This means 
that for these relevant GWBs the quantitative status is not correctly assessed.  This risks to show a 
distorted picture of the real situation regarding water quantity in some regions of the country, which 
induces to over-abstraction. The very severe natural degradation in the case of the Doñana National 
Park, a flagship biodiversity hotspot in the EU, has put in evidence the crucial importance to consider 
the needs for groundwater dependent terrestrial and aquatic ecosystems. Equally worrying, saline or 
other intrusions are not considered in 5 RBDs, even though some of this RBMPs concern islands and 
coastal areas, which are especially vulnerable areas to sea water intrusions. 

Figure 4: Quantitative status of GWBs, as reported in 2009, 2015 and 2021. Missing data due to pending 
reporting. 

3rd RBMPs e-reporting 

Regrettably, the overall quantitative status of GWBs slightly decreases in the 3rd RBMPs, with 75% 
of total GWBs in good quantitative status, while in the 2nd RBMPs this figure was 76%. The level of 

24 Number of Monitoring Stations (3539 in 2015 vs 4302 in 2023) extracted from Hydrological Plans and Programme of 
Measures (mapama.gob.es) 

19 

 
 
 
confidence in the assessment also seems to have slightly declined as the number of water bodies 
classified  with  either  low  or  unknown  confidence  increases  from  15%  to  18%  compared  to  the 
previous cycle. 

Gap to target 

It is noted with significant concern that 29% of total  GWBs are at risk of failing to achieve good 
quantitative status by 2027. Despite this fact, Spain expects that only 6% of total GWBs will actually 
fail by 2027. 

The  main  reason  for  GWBs  failing  to  achieve  good  quantitative  status  is  the  over-abstraction, 
followed by far by saline/other intrusions resulting from anthropogenically induced changes in flow 
direction,  which  in  coastal  areas  is  caused  by  over  abstraction25.  Recent  studies  show  that  the 
combined impacts of climate change and groundwater pumping will significantly decrease natural 
groundwater  recharge,  reduce  soil  moisture  and  increase  actual  evapotranspiration,26,27  while 
predictions regarding desertification and prolonged droughts are becoming more certain. 

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

Protected  areas  in  Spain  cover  a  total  of  141  623  km2  on  land,  representing  the  second  largest 
terrestrial protected areas network in the EU, and 128 670 km2 at sea, the second largest marine 
network.28 Currently, 28% of Spain's terrestrial area is designated as protected areas, which is slightly 
above the EU value of 26.4%. Spain has a total of 1858 recognized Natura 2000 sites. About half of 
the protected areas in the terrestrial environment are designated exclusively as Natura 2000 sites 
and the largest part of the marine protected areas network is covered by Natura 2000 sites. 

Spain  has  designated  several  protected  areas  including:  recreational  areas  protected  under  the 
Bathing Water Directive, areas designated for the protection of drinking water supplies under the 
Drinking Water Directive, areas designated for the protection of habitats and species (Natura 2000 
–  Habitats  and  Birds  Directives),  nitrate  vulnerable  zones  protected  under  the  Nitrates  Directive, 
sensitive areas under the Urban Waste Water Treatment Directive and areas for the protection of 
shellfish designated under the (now repealed) Shellfish Directive. Since the 2nd RBMPs, the number 
of  protected  areas  has  overall  increased  for  drinking  water  protection  areas  and  Natura  2000 
protected sites. Additional monitoring sub-programmes for protected areas are often undertaken in 
many RBDs, thus overlapping, partly or fully, with the common WFD monitoring network. Since the 
2nd  RBMPs,  the  number  of  these  monitoring  sites  have  increased  overall,  especially  for  bathing 
waters, Natura 2000 areas and shellfish designated areas. 

Table 2: Number of protected areas in 2021, per type of protected area and type of associated water 
body. 

Number of Water Bodies Associated with protected areas in 

25 Recent Research Results on Groundwater Resources and Saltwater Intrusion in a Changing Environment 
(researchgate.net) 
26 Sapriza-Azuri et al., 2015, Journal of Hydrology, 529(3), 1701-1712 
27 Touhami et al., 2015, Journal of Hydrology, 527, 619-629 
28 https://biodiversity.europa.eu/countries/spain 

20 

 
 
Protected area 
type 

Rivers 

Lakes 

Coastal 

Transitional  Groundwater 

Bathing waters 

133 

70 

Drinking water 
protection area 

1400 

388 

195 

46 

41 

13 

- 

690 

Natura 2000 
protected sites 

2738 

635 

203 

152 

511 

Nitrate vulnerable 
zone 

494 

175 

Sensitive ares 

181 

28 

15 

70 

Shellfish designated 
water 

81 

1 

124 

45 

57 

52 

386 

- 

- 

Source: 3rd RBMPs e-reporting. 

Since  the  2nd  RBMPs,  there  is  very  little  progress  in  the  status  of  water  bodies  associated  with 
protected areas, with over 40% of SWBs not meeting good ecological status, over 30% of GWBs in 
poor chemical status and over 20% of GWBs in poor quantitative status. For waterbodies associated 
with Natura 2000 sites, no additional objectives are set. Indeed, Spain considers that achieving WFD 
good  status is  sufficient for  half  of  the  sites  and for  the  other half  the  needs  were  described  as 
unknown. Additional measures have only been established for safeguard zones in connection with 
drinking water protected areas in all RBDs. 

3.5 What is being done to prevent/reduce hydromorphological pressures 

Spanish water bodies have been subjected to significant hydromorphological pressures (e.g. dams) 
associated  to  specific  sectors.  Hydromorphological  alterations  are  mainly  related  to  irrigation  for 
agriculture, flood protection, hydropower, drinking water, industry, urban development, aquaculture 
and recreation. Except in the RBDs of the Canary Islands, Ceuta and Melilla; the rest of the 3rd RBMPs 
report  measures  to  tackle  hydromorphological  pressures,  which  include  fish  ladders,  sediment 
management, removal of physical structures, re-meandering, setting of ecological flows, and river 
and  floodplain  restoration.  Besides,  restoring  river  continuity  has  been  identified  as  an  overall 
management objective in at least 15 RBMPs. Many of these measures are eligible under the Next 
generation EU financing instrument. 

In  all  RBDs,  there  is  a  concession,  authorisation  and/or  permitting  regime  to  control  water 
impoundment  and  a  register  of  impoundments.  In  some  RBMPs,  there  exists  also  a  control  and 
registry  of  the  morphological  modifications  of  water  bodies,  according  to  Article  11(3)(i)  WFD, 

21 

 
including constructions/works, dredging and temporary diversion and changes in the riparian area. 
However, there is no evidence that this is generalised for all RBDs and it is also unclear whether a 
periodical  review  of  permits  has  been  introduced  in  the  legislation.  During  the  previous  reporting 
cycle,  it  was  developed  (i.e.  still  requiring  improvement  in  many  RBDs)  an  inventory  of  existing 
structures including both transverse barriers (e.g. dams, weirs, sluices, etc.) and longitudinal defence 
works  (e.g.  flood  protection  constructions),  the  results  of  which  have  been  used  to  update  the 
pressures and to assess the longitudinal  connectivity. All 3rd RBMPs include win-win measures in 
terms of achieving the objectives of the WFD and Floods Directive, drought management and the use 
of Natural  Water Retention Measures (NWRM). Other relevant initiatives for hydromorphology are 
included in the National Strategy for Green Infrastructure and Ecological Connectivity and Restoration 
from 2021,29 whose aim is to restore damaged ecosystems and consolidate a network of natural 
and  semi-natural  areas.  In  2023,  Spain  put  in  place  a  new  National  River  Restoration  Strategy30, 
which aims at protecting river natural reserves and hydrological reserves, minimise flood risks and 
restore river water bodies. 

Regarding ecological flows, many RBDs plan to carry out studies to provide better information on flow 
regime, the aquifer-river relationships and its role in maintaining ecological flows, consideration of 
all  components  of  ecological  flow,  importance  for  protected  areas,  as  well  as  for  monitoring  and 
enforcement. Nature-based solutions (NbS) are mentioned in some RBMPs, however, perhaps because 
it  has  been  published  after  the  adoption  of  some  RBMPs,  the  plans  do  not  mention  the  National 
Strategy for the Restoration of Rivers mentioned earlier,29 nor do they mentioned the 2030 Strategic 
Plan for Wetlands which was adopted in November 2023.31 

3.6 What Spain is doing for abstractions and water scarcity 

Water abstraction and exploitation continue to be very significant for a large part of Spain. Indeed, 
for all RBDs except 3 RBDs (all located in Canary Islands) water abstraction has been identified as a 
significant pressure at the RBD level or in significant portions of the RBD in the 3rd RBMPs. Water 
abstraction has been identified as a significant pressure for 572 SWBs (10.5% of total SWBs) failing 
to achieve good ecological status or potential by 2021, 203 GWBs (25% of total GWBs) failing to 
achieve good quantitative status by 2021 and 225 GWBs (28% of total GWBs) at risk of failing to 
achieve good quantitative status by 2027. 

Spain has reported the average annual Water Exploitation Index plus (WEI+)32 for the period 2017-
2021 at national level to be 19.95 %, which is just below the 20% threshold above which a country 
usually experiences water scarcity.33 However, many of the 3rd RBMPs do not provide a global WEI 
or WEI+ figure for the RBD, or in some RBDs this is broken down by exploitation systems,34 water 
bodies or just given for GWBs. The lack of harmonisation in relation to the WEI data is a matter of 
concern as this may lead to an underestimation of the magnitude of the water stress. Among those 
3rd RBMPs providing data, the RBDs with the highest WEI+ are Guadalquivir (48%), Guadiana (50%), 
Jucar  (72%)  and  Segura  (100%),  all  of  them  beyond  the  severe  risk  threshold  of  40%.  On  the 

29 Estrategia Nacional de Infraestructura Verde y de la Conectividad y Restauración Ecológicas 
30 Estrategia Nacional de Restauración de Ríos (ENRR) 2023-2030. 
31 Plan Estratégico de Humedales a 2030. 
32 According to the European Environment Agency. 
33 In the absence of Europe-wide threshold values available for WEI+, values above 20 % are generally considered to be a 
sign of water scarcity, while values equal or greater than 40 % indicate situations of severe water scarcity, according to 
Eurostat. 
34 Functional division of the territory of the hydrographic district for which the allocation of resources defined in the RBMP 
is established. 

22 

 
 
seasonal scale, Spain appears among the EU-27 countries with the most significant water scarcity 
conditions  (seasonal  WEI+  >40%),  while  for  7  RBDs  WEI+  reached  up  to  100%  during  summer 
periods. 

At country level, in 2020 the major water users in Spain were: agriculture (64%), electricity generation 
including cooling water (19%), households and services (16 %) and manufacturing industry (1%). It 
is  noted  positively  that  in  2020  compared  to  2016,  total  water  abstraction  has  decreased  in  all 
sectors: industry (-8%), agriculture (-7%), households and services (-6%) and electricity generation 
including cooling water (-2%).35. Yet, despite this decrease, there has been no overall reduction in the 
area affected by water scarcity. This means that additional efforts are needed to ensure sustainable 
water use since the frequency, intensity and impacts of drought events will increase exacerbating 
water scarcity. 

It must be noted that the River Basin Authorities in Spain manage the concession, authorisation and 
permitting regime of public surface and groundwater abstractions and impoundments. Permits can 
be refused or revised under specific conditions to achieve environmental objectives. There is, however, 
a situation of practical lack of administrative control of groundwater sources in Spain derived from 
historical legal provisions based on a regime established in 1879 and later revised in a Water Law in 
1985. Indeed,  the 1985 Water Law establishes a 75-year transitional  regime to respect  acquired 
historical  rights, subject to the registration in the “Catalogue of Private Water”.36 Each RBD has a 
water register but not all the information is available, i.e. a very significant part of the registry entries 
lacks the necessary updated data as well as the quantities that are allowed to be extracted. This 
makes it difficult to compare with the permits granted. Work is ongoing for the development of a fully 
digitalised  central  register37  (not  yet  operational  despite  expected  to  be  finished  by  2023).38 
Abstractions  for  common  uses  (human  consumption,  bathing,  other  domestic  uses,  watering 
livestock) below 7 000 m3/year do not require an authorisation. 

Water metering has not been effectively implemented in a generalised manner in all RBDs, although 
this was required under the law since 2009 (Order ARM/1312/2009). This is particularly important 
considering  the  large  amounts  of  water  used  by  different  sectors  and  the  unauthorised  water 
abstractions (without a permit or in excess of the permit). This lack of implementation of the law, is 
due  to  technological  and  regulatory  problems,  together  with  a  lack  of  control  capacity  of  the 
administrations. As a result, some RBMPs plan measures to expand water metering by 2027. 

There are large divergences in the way RBDs implement ecological flows. It is a matter of concern 
that ecological flows have been defined but only fully implemented in less than half of the RBDs. 
There is not yet an explicit link between the implementation of e-flows and granting of permits to 
control water abstractions. It is not possible to know if e-flows are guaranteeing the good status of 
water bodies as not all RBMPs consider the most relevant components for the characterisation of e-
flows (i.e. some components are not sensitive enough to the hydrological alterations). 

All  RBDs  include  measures  to  increase  water  supply,  mostly  aiming  at  meeting  the  demands  of 
agriculture and public water supply with a focus on tourism. The measures to increase water supply 

35 Annual freshwater abstraction by source and sector, Eurostat. 
36 Exists both a “Public Water Registry” of abstractions and a “Catalogue of Private Water”, this later being an inventory of 
private groundwater rights of landowners according to the 1879 Water Law. 
37 Orden AAA/1760/2016, por la que se regula la estructura informática del  Registro de Aguas y de la Base Central del 
Agua. 
38 Background document 28: Application of basic measures (Article 11.3.b-l, WFD). 

23 

 
 
include water retention measures, water reuse, desalination, shifts of abstraction from one water 
body to another, as well as to reservoirs, and water transfers between different RBDs. Regrettably, 
taking into account that 25 % of GWBs are in poor quantitative status without any progress since 
the 2nd RBMPs, coupled with the large volumes of illegal water abstractions, it would appear that 
the existing framework and its enforcement is insufficient. 

3.7 Adaptation to climate change 

The  3rd  RBMPs  contain  a  section  dedicated  to  climate  change  including  projections  of  different 
climate change scenarios; effects on ecological conditions, ecosystems and invasive species; maps of 
vulnerability  and  risks  of  desertification,  among  others.  They  also  refer  to  the  Common 
Implementation Strategy (CIS) guidance No. 24.39 Many RBDs prioritise climate change adaptation 
measures that complement those in the National Plan of Adaptation to Climate Change,40 which is 
taken as the baseline to promote coordinated and coherent action. Spain adopted in July 2022 some 
Strategic Guidelines on water and Climate change.41 In addition, many of the RBDs have their own 
regional plans developed to mitigate and adapt to the effects of climate change. However, many of 
these measures do not relate to the preservation of water bodies and no information is given on the 
climate proofing of the measures identified. Overall, it remains unclear which measures directly link 
to  climate  change  adaptation  specifically,  and  which  measures  included  in  the  RBMPs  stem  from 
national/regional plans.  

Climate  change  is  not  explicitly  mentioned  as  a  contributing  cause  for  failure  to  achieve  good 
ecological status. No information could be found on the impacts of climate change on achieving good 
status, nor the measures required to mitigate these impacts. As such, the analysis is rather limited, 
and no water bodies are identified as being under a serious risk because of climate change. Although 
temporary  deteriorations  due  to  drought  were  recorded  in  several  RBDs,  there  was  no  case  of 
exemptions under Article 4(6) from compliance with environmental objectives. 

Drought management 

Drought Management Plans (DMPs)42,43 (established in 2000, operational since 2007 and required by 
the  National  Hydrological  Plan)  are  available  for  most  of  the  RBDs.  These  DMPs  develop  various 
drought  scenarios  and  drought  indicators  together  with  a  series  of  actions/measures  aimed  at 
minimizing impacts of possible droughts which need to be activated at different stages. DMPs only 
focus on addressing temporary shortage episodes and act  rather as a management alert system 
when drought situations occur so that appropriate measures can be undertaken. These range from 
reducing water allocations, restricting/prohibiting non-essential uses and introducing supplementary 
water resources. Despite recent studies indicating that the number of SWBs in poor chemical status 
is expected to increase in the Mediterranean basins due to climate change,44 the effect of droughts 
in pollutant concentrations has not been assessed.  

Flood management 

39 Guidance document No 24 (2009): River basin management in a changing climate. 
40 Plan Nacional de Adaptación al Cambio Climático 
41 Orientaciones Estratégicas sobre Agua y Cambio Climático 
42 Spanish web portal to Drought Management Plan, Planes Especiales de Sequía (PES). 
43 Background document 19: Subplans- Special drought plans. 
44 Dorado-Guerra et al., 2023, Journal of Environmental Management, 348, 119069 

24 

 
 
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.  

The updated Spanish 2022 national guidance methodology for FHRMs45 does not refer to any changes 
in the consideration of climate change compared to the past. However, there is work in progress to 
feed the third maps with climate change impacts. This will need to be pursued.  

All  five  FRMPs  analysed  in  detail  (Eastern  Cantabrian,  Guadiana,  Júcar,  Andalusian  Mediterranean 
Basins, La Gomera) provide quantitative analyses of the impacts of climate change including in terms 
of precipitation, temperature, and sea level rise. They cite national sources, including the work of the 
Spanish Meteorological Agency (AEMET), studies on the impacts of climate change on water resources 
of the national Centre for Studies and Experimentation of Public Works (CEDEX), and the reports of 
the Spanish Office for Climate Change (OECC). The five FRMPs state that the main sources of flooding 
will continue to be sea level rise, torrential rains and, for some of the Units of Management (UoMs) 
such as Eastern Cantabrian, snowmelt. All FRMPs assessed refer to Spain’s National Climate Change 
Adaptation Plan, and provide an overview of the expected impacts of climate change and refer to 
coordination  with  the  ‘strategic  lines  of  action’  set  out  therein.  These  lines  of  action  include 
strengthening knowledge on  climate impacts,  in particular extreme  events, integrating  adaptation 
into water management, and improving flood risk management, including via nature-based solutions. 
The Adaptation Plan moreover highlights, in terms of addressing flood risks, the roles of land use and 
spatial planning, of insurance, and of preparedness actions including early warning systems. 

4. Policy elements contributing to zero pollution 

4.1 Surface Water: what is their chemical status 

Monitoring 

The  3rd  RBMPs  present  only  summarised  information,  without  details  for  SWB  classes  on  the 
percentage coverage by operational and surveillance monitoring, nor number of monitoring sites for 
chemical  status.  From  the  disclosed  information,  surveillance  monitoring  covers  50.3%  of  river 
lengths, 60.7% of lake area, 76.7% of transitional water area and 60.3% of coastal water area; while 
operational monitoring covers 57.1%, 74.1%, 53.7% and 17.3%, respectively. 

It  is  unclear  whether  the  monitoring  network  for  chemical  status  in  SWBs  has  been  expanded  or 
maintained  compared  to  the  2nd  RBMPs,  where  the  spatial  coverage  was  already  reasonable. 
Regarding pollutants, only some 3rd RBMPs include in their monitoring programs for chemical status: 
i)  the  assessment  all  priority  substances  and  ii)  monitoring  in  biota  or  sediment  (including  those 
priority substances where the biota standard applies). For setting trends, very often the frequency of 
monitoring in biota or sediment is limited to once every six years.46 There is also little evidence of 
improvement  on  the  knowledge  pertaining  to  the  priority  substances  included  in  inventories  and 

45 https://www.miteco.gob.es/es/agua/temas/gestion-de-los-riesgos-de-inundacion/propuesta-de-minimos-realizacion-
mapas-deriesgo-2ciclo_tcm30-511333.pdf 
46 Environmental Quality Standards Directive 2008/105/EC, as amended by  Directive 2013/39/EU, Art. 3.6 indicates as a 
guideline for the purpose of long-term trend analysis monitoring at least every three years. 

25 

 
 
discharged into RBDs, monitoring of discharges or links to the pressure assessment and emission 
inventory.  Not  all  inventories  considered  all  priority  substances,  so  it  is  not  clear  whether  all 
discharged substances have been identified in all RBDs. 

For the first time in the current cycle, the assessment of chemical status has been carried out in 
accordance with the RDSE,47 which defines the objectives and a series of increasingly demanding 
criteria for classifying water bodies. The overall chemical status between the 2nd and 3rd RBMPs 
remains broadly the same regarding the percentage of SWBs both in good status and poor status, 
while the number of water bodies in unknown status has fallen to 3% nationally.21 By 2027, it is 
expected that 98 % (5361 of 5470 water bodies) of SWBs will be in good chemical status. Across 
the RBMPs, Tinto-Odiel-Piedras (ES064) and Catalan (ES100) have the largest percentage of SWBs 
in poor status (32 % and 21%, respectively); while Balearic islands (ES110) and Catalan (ES100) 
have the largest share of SWBs in unknown status (45% and 24%, respectively). On the other hand, 
it  is  a  matter  of  strong  concern  the  significant  increase  in  the  number  of  water  bodies  classified 
without  a  confidence  rating  (i.e.  from  7%  of  total  SWBs  in  2nd  RBMPs  to  30%  in  3rd  RBMPs),  in 
particular 26% of the SWBs in good chemical status, and the deterioration in classification confidence 
of SWBs in poor chemical status. 

The  primary  substances  that  cause  failure  to  achieve  good  chemical  status  of  SWBs  are  mainly 
metals  (nickel,  cadmium,  mercury,  and  lead),  followed  by  PFOS  and  pesticides  (cypermethrin, 
chlorpyrifos,  hexachlorocyclohexane,  endosulfan,  and  dicofol).  Among  these,  uPBT  substances 
in  the  number  of  failures,  while  others 
(mercury  and  PFOS)  play 
(hexachlorocyclohexane,  endosulfan,  dicofol  and  PFOS)  are  recognised  Persistent  Organic 
Pollutants (POPs) under the Stockholm Convention listed for elimination or restriction.48 

just  a  minor  role 

47 Real Decreto 817/2015, por el que se establecen los criterios de seguimiento y evaluación del estado de las aguas 
superficiales y las normas de calidad ambiental (RDSE). 
48 UN Environment Programme (UNEP) – Stockholm Convention on Persistent Organic Pollutants. 

26 

 
 
Figure 5: Chemical status of SWBs, as reported in 2009, 2015 and 2021.

Source: 3rd RBMPs e-reporting. 

Figure 6: The top-10 Priority Substances causing failure to achieve good chemical status in surface water 
bodies in Spain by 2022 (legally required 33 Priority Substances). Missing data due to pending reporting. 

Source: 3rd RBMPs e-reporting. 

27 

 
 
 
Figure 7: The top-10 Priority Substances causing failure to achieve good chemical status in surface water 
bodies in Spain by 2022 (new 1-45 Priority Substances). Missing data due to pending reporting. 

3rd RBMPs e-reporting.49 

4.2 Groundwater Bodies: what is their chemical status 

Monitoring, assessment and classification of chemical status in groundwater bodies 

Since the previous cycle, Spain has reinforced its chemical monitoring of groundwater by increasing 
both the number of monitoring stations and the percentage of GWBs covered. While this improvement 
concerns all types of monitoring (surveillance, operational and investigative), it is worth highlighting 
a 51% increase in the number of monitoring stations and the at least 97% of total GWBs covered 
(at least 63% in the 2nd RBMPs) in the surveillance monitoring. Nonetheless, not all RBDs include yet 
in their programs for monitoring chemical status of GWBs all substances causing risk of deterioration, 
i.e. Groundwater Directive (GWD) Annex I and Annex II (Part B) substances and WFD Annex V (Point 
2.4.2) core parameters. It is important to mention the absence of monitoring for pesticides, nitrites, 
phosphates, trichloroethylene, tetrachloroethylene, oxygen content and pH value in at least 16% of 
the RBDs. 

Regarding  the  general  chemical  status  assessment,  only  6  RBDs  make  use  of  the  methodology 
proposed  in  the  EU  Guidelines.50  The  rest  of  RBDs  deviate  from  this  harmonised  methodology 
considered  as  good practice,  either by  setting  different  parameters  or  simply by  using  a  different 
method. There is no grouping of GWBs in the 3rd RBMPs. 

As in 2nd RBMPs, threshold values are not set in all RBDs for all substances leading to risk of not 
meeting environmental objectives and neither for all pollutants in Annex II (Part B), the most notable 
absences  being  for  lead,  mercury,  nitrites,  total  phosphorus/phosphates,  trichloroethylene  and 
tetrachloroethylene missing in at least 60% of the RBDs. For 3 RBDs, including the inter-community 
Guadiana (ES040) RBD, threshold values are completely absent for all Annex II (Part B) pollutants or 

49 Directive 2008/105/EC as amended by Directive 2013/39/EU added 12 new substances i.e. numbered 34 to 45 to the 
priority substance list. For the 3rd RBMP, Member States have only had the obligation to monitor them. Compliance with the 
Environmental Quality Standard values for these 12 new priority substances will be assessed in 2027. 
50 CIS Guidance document 18 (2009): Groundwater status and trend assessment, derived as a ‘conceptual model’ in line 
with point 3 of Annex III (Assessment of groundwater chemical status) of the GWD. 

28 

 
 
 
their  indicators.  For  naturally  occurring  substances,  background  levels  are  not  considered  in  the 
development of the respective threshold values and the chemical status assessments in all RBDs. 
Also  for  the  establishment  of  threshold  values,  in  a  significant  number  of  RBDs  it  is  missing  the 
consideration of impacts on GWAAEs, impacts on GWDTEs, saline/other intrusions and impacts on 
drinking water protected areas. 

It is a source of concern that the impact that groundwater pollutants may have on the groundwater 
dependant  ecosystems  (i.e.  aquatic  or  terrestrial)  have  not  always  been  taken  into  account,  as 
required  by  the  WFD.  Such  ecosystems  are  either  not  reported  or  not  considered  in  the chemical 
status assessment of GWBs in at least 16% of the RBDs. Chemical status assessments of some RBDs 
do not consider neither saline/other intrusions nor impacts on drinking water protected areas. Spain 
seems to struggle to identify significant and sustained upward trends in pollutants or indicators of 
pollution in GWBs identified as being at risk, as required under the GWD (Art. 5). Most RBDs do not 
provide a trend assessment methodology and do not perform a trend assessment, while only Tagus 
(ES030) RBD provides a trend reversal methodology. 

The chemical status of GWBs has slightly improved since the last cycle with at least 67% of total 
GWBs in good chemical status (65% in the 2nd RBMPs). However, 33% of total GWBs were still in 
2021 in poor chemical status, 43% of GWBs are at risk of failing to achieve good chemical status by 
202751 and 18% of GWBs are expected to fail to achieve good chemical status by 2027. Confidence 
has deteriorated significantly since the 2nd RBMPs, with a decrease of classifications with high and 
medium confidence and an increase of classifications with low and unknown confidence. GWBs mainly 
fail  because  of  their  general  water  quality,  followed  by  saline/other  intrusion  resulting  from 
anthropogenically induced changes in flow direction and deterioration in quality of waters for human 
consumption. Nitrate, chloride, conductivity, sulphates and pesticides are the main pollutants or their 
indicators causing failure to achieve good chemical status, while at the same time most of them also 
showed sustained upward trends in GWBs. 

51 See also the formal the Spanish web portal regarding declaration of GWB at risk of failing good chemical status. 

29 

 
 
Figure 8: Chemical status of GWBs, as reported in 2009, 2015 and 2021. 

Source: 3rd RBMPs e-reporting. 

Figure 9: Top-5 pollutants causing failure to achieve good chemical status in groundwater bodies by 2021. 
Missing data due to pending reporting. 

Source: WISE electronic reporting. 

4.3 What Spain is doing to combat pollution from agriculture 

The  3rd  RBMPs  identify  a  series  of  measures  to  tackle  agricultural  diffuse  pollution,52,53  mainly 
nitrates and pesticides. Basic measures and necessary complementary measures, both mandatory 
and  present  in  all  RBMPs,  include  regulatory  measures,54  measures  to  reduce  the  application  of 

52 Background document 27: Application of basic measures (Article 11(3)(a), WFD). 
53 Background document 28: Application of basic measures (Article 11.3.b-l, WFD). 
54 Real Decreto 47/2022, sobre protección de las aguas contra la contaminación difusa producida por los nitratos 
procedentes de fuentes agrarias. 

30 

 
 
 
 
nitrates, measures to create buffer strips for watercourses, model-based assessment to reduce the 
amounts  of  pollution,  action  programmes  for  vulnerable  areas  for  nitrates  contamination, 
development of a National Plan for the application control regarding the use of authorised pesticides 
and good agricultural practices for pesticide use reduction.55 While the planned measures correspond 
to identified pressures, there is a knowledge gap on the expected effects of the planned measures 
and  the  necessary  nutrient  load  reduction  to  achieve  the  environmental  objectives  exists,  which 
makes difficult to ascertain how much progress will be achieved and if measures would be sufficient. 
Although the 3rd RBMPs include measures to reduce pollution from nutrients (i.e. 54 basic and 20 
supplementary within 16 RBDs) and pesticides (i.e. 11 basic and 6 supplementary within 6 RBDs), 
there is no quantitative information provided about what are the load reductions that are needed to 
achieve the environmental objectives. 

Whilst  there  is  information  on  the  total  investment  cost  per  measures,  there  is  no  indication  of 
whether the financial commitment has been secured. In the 3rd RBMPs, there seems to be a general 
trend  to  reduce  the  number  of  measures  while  increasing  the  total  investment,  compared  to  the 
previous  cycle.  This  may  lead  to  a  more  targeted  approach,  better  prioritisation  and  ultimately  a 
higher  progress  on  implementation  at  the  end  of  the  programming  period.  Measures  related  to 
pollution are mainly funded by public administrations. Hence it remains unclear whether the polluter 
pays principle is fully implemented in the agricultural sector. When reviewing the draft CAP Strategic 
Plan in 2022,56,57 the European Commission called on Spain to improve nutrient use efficiency, clarify 
the timing and content of the actions envisaged in the frame of currently applicable and upcoming 
national  mandatory  rules  and  how  they  would  be  integrated  in  the  Good  Agricultural  and 
Environmental Condition (GAEC) 10.. Spain was also invited to properly address the potential for water 
saving and focus on the effective reduction in water use in areas of higher water pressures. According 
to Spain’s CAP Strategic Plan, the share of organic farming will double from 10% in 202258 and reach 
20% of the Spanish utilised agricultural area (UAA) by 2030. 

4.4 What Spain is doing to combat pollution from other sectors 

In the 3rd RBMPs, pollution from point source discharges is mainly addressed by a large number of 
measures  (i.e.  2176  basic  and  1325  supplementary  within  24  RBDs,  by  far  the  largest  number 
compared to other Key Types of Measures (KTMs)) and by investments in construction and upgrades 
of urban and industrial wastewater treatment plants. Nevertheless, not all RBMPs include specific 
measures to eliminate/reduce pollution from chemical substances in SWBs (i.e. Priority Substances 
or River Basin Specific Pollutants) and in GWBs (groundwater pollutants). Although the current overall 
chemical status for both surface and groundwater bodies is overall indicated, there is no specification 
on  what  exactly  this  chemical  pollution  entails  and  what  are  exactly  their main  causes  (i.e. main 
drivers). No information is given on how specific pollutants are being addressed nor a quantitative 
gap assessment on how much additional treatment would be required, thus hindering the possibility 
to carry out an analysis on whether environmental objectives will be reached by 2027. 

55 "Voluntary codes of good agricultural practices" is a basic measure established in the Nitrates Directive 91/676/EEC. It 
is voluntary for farmers to follow the codes but mandatory for the regions to establish, approve and disclose. 
56 Commission observations on the proposal by Spain for a CAP Strategic Plan 2023-2027. 
57 “Mapping and analysis of CAP strategic plans” (2023-2027). 
58 EU’s organic farming area reaches 14.7 million hectares - Products Eurostat News - Eurostat (europa.eu) 

31 

 
 
4.5 What Spain is 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,59 with at least one Key Type of Measure (KTM) assigned to each pressure. In general, 
the reported significant pressures are well covered with operational KTMs. 

The RBMPs in Spain include both environmental measures and other measures that are not meant 
to satisfy environmental objectives, for example, fulfilment of demands. All environmental measures 
are grouped into 19 main types associated to an equivalent KTM. Spain has mapped 3523 national 
basic measures against 16 predefined KTMs and 10 nationally defined KTMs. In addition, a total of 
5361  national  supplementary  measures  have  been  mapped  against  18  predefined  KTMs  and  11 
nationally defined KTMs. The application of both basic and supplementary measures varies between 
RBDs. Basic measures are reported against all the requirements of Article 11.3 of the WFD, except 
for direct groundwater pollutants. Information on gaps to be  filled is provided and so are KTM to 
achieve the objectives in SWBs and GWBs by 2021. Gap analyses have been presented for all the 
significant pressures and quantitative pressure indicators and gap values for 2021 are in place at 
water body level. Regrettably, quantitative indicators on the expected gap to good status by 2027 
have not been provided. 

A  cost-effectiveness  analysis60  has  been  presented  in  all  RBMPs,  but  do  not  provide  a  high-level 
description of the actual effectiveness of the measures and does not mention the costs that have 
been executed based on planning. The total amount of investment reported for the environmental 
objective  measures  through  public  sector  during  the  period  2021-2027  is  MEUR  24,669.86  from 
national investment and MEUR 1,428.9 from EU funding. In some RBMPs, it is mentioned a minimum 
percentage of private funding for measures related to point-source pollution, while investments from 
irrigator communities are addressed to measures aiming to reduce pressure from water abstraction 
and modernization of irrigation systems. Prioritisation of measures varies between the RBDs in Spain. 
While in some RBMPs there is no information on the prioritisation of measures, in others different 
criteria have been defined and measures have been prioritised based on a conceptual framework 
developed for the risk evaluation associated with climate change. 

5. Exemptions and economics 

5.1 To what extent are exemptions applied in Spain 

Environmental objectives have been reported in all RBDs. Similar to the 2nd RBMPs, the number of 
SWBs for which the date to achieve objectives is unknown is less than 2% (for both ecological and 
chemical status), while there are no GWBs for which the date to achieve objectives (both chemical 
and quantitative) is unknown. Additional objectives have been set for surface and groundwater bodies 
associated  with drinking water  protected  areas  and  for  surface  water bodies  associated  with the 
Shellfish Directive and, for 29 SWBs, Natura 2000 sites. 

59 The whole set of measures of Spanish RBMP can be consulted in the Spanish web portal Hydrological Plans and 
Programme of Measures (mapama.gob.es) 
60 Background document 33: Cost-effectiveness analysis for the selection of measures. 

32 

 
 
Spain has published Guidance and background documents61 for the application of the exemptions 
provided for in the WFD in compliance with the environmental objectives.62 Some RBMPs explain the 
general methodology established and some aspects that have led to the variation in the number of 
water bodies with the different types of exemptions. However, the plans recognise some gaps, i.e. the 
concept  for  technical  infeasibility  as  used  in  Article  4  of  the  WFD  has  not  yet  been  developed  in 
Spanish regulations. Regrettably, although in some RBDs justifications are provided at water body 
level,  these  are  quite  generic  and  many  RBMPs  do  not  provide  specific  information:  i.e.  do  not 
sufficiently  explain  the  type  of  technical  issues,  why  costs  are  disproportionate,  do  not  consider 
challenges faced by each water body, nor alternative financing mechanisms, often provide the same 
justification  for  multiple  water  bodies,  do  not  provide  timelines  and  budget  or  simply  do  not 
specifically mention the use of Article 4(4) exemptions despite these being reported electronically. 
Overall, it is evident that the main drivers causing the need to apply exemptions to water bodies are 
related  to  various  pressures  such  as  pollution  from  agriculture,  urban  waste  water,  industry  and 
mining; agriculture and public water supply; and hydromorphological and physical alterations. 

As in the previous reporting cycle, Spain continues to prioritise the postponement of deadlines under 
Article 4(4), while limiting the application of exemptions setting less stringent objectives under Article 
4(5). However, the available data for the new reporting cycle clearly shows a shift in terms of the 
reasons invoked to justify Article 4(4) exemptions. In the 2nd RBMPs, this was mainly justified for 
reason  of  technical  feasibility  and  disproportionate  costs,  while  technical  feasibility  and  natural 
conditions are currently appearing as the main justification grounds in the 3rd RBMPs. This prompts 
to believe that a large share of water bodies previously exempted under Article 4(4) for reason of 
disproportionate costs have now been inappropriately justified by natural conditions. An outstanding 
example  of  this  could  be  the  justification  under  natural  conditions  of  GWBs  which  are  actually 
suffering from saline intrusion as a consequence of the water imbalance caused by abstractions or 
from the great inertia of nitrates contamination. 

Article 4(6) exemption has been applied only to 1 surface water body as a result of an accident in 
the Eastern Cantabrian RBD.63 Yet, the national authorities are developing a common repository to 
collect information regarding Article 4(6) exemptions and to allow the justification of a temporary 
deterioration when control networks detect non-compliance. This leads to conclude that there may 
have been more than one. 

It is worth noting that the application of Article 4(7) exemptions has been reduced from at least 40 
SWBs in the 2nd RBMPs to a total of 10 SWBs and 2 GWBs in the 3rd RBMPs. Justification is provided 
for  each  project  at  water body  level  and  detailed  supporting  technical  sheets  are  included  in  the 
appendix of the corresponding RBMPs. The reporting covers mitigation measures, overriding public 
interests and processes to ensure that preventive and corrective measures are linked to each impact 
detected.  In  the  3rd  RBMPs,  no  exemptions  have  been  granted  pursuant  to  Article  6(3)  of  the 
Groundwater Directive. 

61 Background document 14: Exemptions provided in the WFD for compliance of the environmental objectives in water 
bodies. 
62 Recomendaciones para incorporar la evaluación de efectos sobre los objetivos ambientales de las masas de agua y 
zonas protegidas en los documentos de evaluación de impacto ambiental de la A.G.E., 2019. 
63 The 2020 collapse of the Zaldibar (Vizcaya) landfill. 

33 

 
 
Figure 10: Type of exemptions reported to be applied to SWBs and GWBs for the 3rd RBMPs in Spain. 

Note:  ecological  status  and  groundwater  quantitative  status  exemptions  are  reported  at  water  body  level.  Chemical 
exemptions for groundwater are reported at the level of each pollutant causing failure of good chemical status, and for 
surface waters for each Priority Substances that is causing failure of good chemical status. For the purposes of this Figure 
the number of water bodies exempted for chemical status is used. Please note that while the WISE reporting uses a label 
“Article 4(5)- Technical feasibility” it should be read as “Article 4(5)- Infeasibility”.  

Source: 3rd RBMPs e-reporting.  

5.2 Use of economic analysis and water pricing – cost recovery 

In Spain, the state offers most of the gross supply of water services and the regulation of the natural 
hydrological regime to increase and favour the availability of water that is ultimately captured and 
used by different types of users according to certain conditions. There appears to be a clear distinction 
between  water  services,  understood  as  all  water  supply  and  wastewater  treatment  services,  and 
water uses, which are in turn disaggregated into three main water user sectors: industry, households 
and agriculture. Most of the 3rd RBMPs contain an annex containing the economic analysis with unit 
cost estimates as part of the information on water tariffs. Although most obligations from Annex III 
WFD  are overall included, not all 3rd RBMPs include estimates of relevant investments (including 
forecasts)  differentiating  over  water  services  or  estimations  about  the  most  cost-effective 
combination of measures. In addition, as the revenues from the water tariffs do not yield a high-cost 
recovery rates, it should be expected some proper incentives to an efficient water use. However, there 
is missing information on the type and structure of tariffs applied for individual water services and 
other  services,  i.e.  whether  they  are  fixed,  volumetric  or  part  of  an  overarching  structure.  This,  in 
conjunction  with  the  lack  of  an  explicit  justification,  hinders  the  assessment  of  the  incentivising 
effects of the water pricing policies in place. It is worth noting that as part of the Strategic Guidelines 
for Water and Climate change, the authorities recognise the need to review the system establishing 
water tariffs. 

34 

 
 
Background  documents  are  available  describing  the  methodology  for  the  cost  recovery  of  water 
services.64,65 As acknowledged by the Spanish authorities, the current system applied only recovers 
from the users the 70% of the costs incurred. This cost-recovery gap has been identified, in all RBDs, 
as a significant barrier to fund the necessary measures to achieve the environmental objectives. 

In Spain, there is a wide variety of cost recovery instruments linked to water services, including taxes, 
levies and rates that are the responsibility of different agents to collect, given that the different tax 
figures can be state, regional or local competence, depending on the administration that directly or 
indirectly provides the service. In the 3rd RBMPs, the total cost of water services in Spain, expressed 
in terms of equivalent annual cost, is estimated at MEUR 14 392. Differentiating cost recovery rate 
by water user sectors this would be: 80% for industry, 73% for households and 67% for agriculture. 
All  RBMPs  apply  cost  recovery  to  drinking  water  abstraction/treatment/distribution,  sewage 
collection/wastewater treatment, irrigation water abstraction/treatment/distribution, self-abstraction 
and impoundment/storage of water (except for impoundments for flood protection and navigation). 
In  many  RBMPs, it is  clearly  mentioned that  one  consequence  of  low-cost  recovery is the lack  of 
financial  availability  to develop the Programme of Measures. However, it is not clear whether the 
reported methodology for the calculation of water services costs and cost recovery rates is based on 
national guidance. 

Most of the 3rd RBMPs report financial costs, distinguishing investments from operation/maintenance 
costs for the various water services; as well as environmental and resource costs, though considering 
different methodologies for their calculation. Most of the plans also report on water supply prices and 
revenues distinguishing between the different water user sectors. However, 3rd RBMPs do not include 
information on the adequacy of the contribution by different water user sectors to the costs of water 
services. The plans lack information on the practical application of the Polluter Pays Principle in the 
calculations of costs and do not report mitigation factors to justify  cost recovery rates which are 
below 100%. 

6. WFD recommendations 

It is worth noting that a number of recommendations included hereafter have also been identified by the Spanish 
authorities themselves as areas to be improved in the Strategic Guidelines for Water and Climate Change.  

Recommendations - Spain should: 

1.  Spain needs to accelerate efforts and elevate its ambitions to minimize the compliance gap as much as 

possible by 2027. This entails the following actions: 

a)  ensure comprehensive reporting on the consumption of both surface water and groundwater across all 
users. The RBMPs should provide clear estimates on consumptive uses, their proportions, and trends. 
Additionally, Spain needs to more effectively address illegal water abstractions in agriculture and other 
sectors through closer monitoring and stricter penalties. 

b)  fully comply with WFD provisions regarding the periodic review of permits and controls for all relevant 
impoundment,  discharges,  and 

activities  affecting  water  bodies,  such  as  abstraction, 

64 Background document 35: Cost recovery of water services. 
65 Background document 36: Tools for the cost recovery of water services. 

35 

 
 
hydromorphological works. An effective, dissuasive, and proportionate sanction regime should be in 
place.  Spain  should  consider  revising  existing  legislation  that  exempts  small  abstractions  from 
permitting to better manage cumulative impacts. 

c)  harmonize the gaps analysis of various river basin management plans to enhance transparency for 
stakeholders, ensure comparability among regions, and better target measures needed to close the 
gap by 2027. Specifically, Spain should clearly identify types of pollutants and the specific amounts 
found in water bodies, estimate targets for reducing nutrient and pesticide pollution and put in place 
effective measures for the remediation of ubiquitous substances and heavy metals. 

d)  ensure  an  effective  coordination  with  authorities  responsible  for  the  Marine  Strategy  Framework 
Directive  and  Nitrates  Directive  to  accelerate  progress  in  meeting  status  requirements  for  both 
freshwater and marine environments by leveraging potential synergies. 

e) 

tackle decisively the main reported obstacles to progress in the achievement of Program of Measures 
objectives, in particular insufficient funding, administrative resources and governance. 

2.  As regards existing persisting pressures, Spain should identify and put in place, as appropriate, additional 

measures to reduce such environmental challenge. In particular, it should: 

a)  step up action to reduce diffuse nutrient pollution, including quantitatively assessing how much the 
load of nutrients from agriculture sources needs to be reduced to achieve the objectives of WFD, MSFD 
and Nitrates Directive, and providing information on the area where the measures are being applied 
and whether the necessary funding is being secured. 

b)  further reduce point source pollution by identifying the main cause of this pollution and to what extent 
the measures identified will tackle the pollutants which cause the failure. Furthermore, Spain should 
take into account the new obligations under the revised IED and UWWTD and provide more exhaustive 
information on the measures planned to better control discharges; address waste water discharges 
from scattered households and unconnected small settlements, and improve wastewater management 
throughout its territory. 

c)  continue and extend work on a control and registry of the morphological modifications of water bodies 
and the inventory of barriers in all RBDs, and step-up efforts to improve river continuity to improve the 
general hydrological situation and increase fish protection. This should be coupled with an enhanced 
and more integrated management of aquatic invasive alien species. 

d)  continue the ongoing work in defining ecological flows and effectively implementing them in all water 
bodies.  All  RBDs  should  establish  an  explicit  link  between  the  implementation  of  e-flows  and  the 
authorisation process and/or review of permits to control water abstractions and impoundments. Peaks 
in hydropower generation should be taken into account in the revision of water permits. 

e)  more clearly identify the progress in the implementation of measures on water metering, the extent of 
water metering across all water uses, as well as the extent of unauthorised water abstractions (either 
without a permit or in excess of the permit conditions), all these of utmost importance to understand 
and improve the confidence in water abstraction/consumption estimations. 

36 

 
f)  should  continue  improving  the  work  to  establish  the  additional  needs  for  protected  areas,  defining 
additional objectives, implementing appropriate monitoring and improving the measures that apply to 
such protect areas as their state has not really improved. 

g)  more systematically consider the needs of groundwater dependent ecosystems (both terrestrial and 
aquatic),  and  the  impacts  on  saline/other  intrusions  and  drinking  water  protected  areas  in  the 
assessment of all RBDs. This is of particular importance given the rich biodiversity that is present in 
Spain. 

3.  On the use of economic tools, Spain should continue improving its economic analysis, addressing gaps as 
regards key items, including on long term supply and demand forecasts, defining water services, reporting 
of cost recovery rates (including costs for private actors), and investment needs. In particular, Spain should: 

a)  provide more detailed information on relevant investments and estimates about the most cost-effective 

combination of measures for all RBDs, while including prioritisation of measures. 

b) 

include an explicit and systematic account on the adequacy of the incentives of water pricing to water 
use efficiency. 

c)  Step up the efforts to fully apply the cost recovery principle to all water use activities that have an 

impact on water bodies. 

d)  systematically  provide  more  information  on  the  mitigating  factors  to  cost  recovery,  the  sectorial 
adequacy of the contribution to the costs of water services, exemptions under Article 9(4) WFD as well 
as subsidies, and on the Polluter Pays Principle application. This is also partly linked to the national 
system of historical rights that would merit to be reviewed. 

4.  As regards the water scarcity challenge and adaptation to climate change, it is recommended that Spain: 

a)  provides,  regularly  update  and  monitor  accurate  water  balances  for  all  river  basins,  that  take  into 
account all inputs and abstractions and natural losses. In this context, it would be appropriate to register 
all abstractions or at least lower the level above which abstractions need to be registered, in order to 
have  a  full  control  of  the  resource  and  account  for  the  cumulative  effect  of  a  myriad  of  small 
abstractions impacting the GW quantitative status. 

b) 

c) 

improves water management to better address the adaptation to present and future effects of climate 
change and ensure long-term economic, social and environmental resilience. 

improves  coordination  among  all  levels  of  government  and  administration  while  adapting  existing 
solutions  for  sustainable  water  management  in  agriculture,  water  efficiency  and  infrastructure 
investments. 

d)  Continues to prioritise implementation of nature-based solutions and green infrastructure for more 
sustainable water storage across soils and ecosystems, and ensures that grey infrastructure (i.e. dams 
and  reservoirs)  are  part  of  coherent  water  resilience  strategies  that  consider  long-term  climate 
scenarios. 

e)  provides detailed analysis on the impacts of climate change on water abstraction. 

37 

 
f)  Provides more detailed information on specific climate change adaptation measures and the analysis 

of how these measures will alleviate water scarcity or drought related issues. 

g) 

improves climate proofing of measures included in the PoMs and develop adequate measures or plans 
for climate resilience and drought management to ensure the preservation of water bodies and the 
objectives of the WFD. 

5. 

To more effectively achieve the objectives of the WFD and enhance water resilience, Spain should further 
enhance transboundary cooperation, in particular by establishing joint Programmes of Measures in the 
framework of the cooperation agreements with Portugal and France, as well as reinforcing the cooperation 
on water abstraction issues addressing water scarcity risks under climate change. 

6.  Spain should ensure continued efforts to transparently justify every exemption in all RBDs, in line with ECJ 

jurisprudence on the restrictive interpretation of exemptions. In particular, Spain should: 

a)  provide a higher the level of detail for justifications under Article 4(4) and 4(5) exemptions for all RBDs 
at individual water body level. Given the different nature of both exemption types, there should be a 
clear  distinction  of  justifications  and  related  criteria  between  technical  feasibility,  disproportionate 
costs and natural conditions. 

b)  Continue to work towards a harmonised information sheet for all RBDs regarding justifications under 

Article 4(6) exemptions and how these exemptions are applied to individual water bodies. 

c)  make better use of Article 4(7), by providing specific details on cumulative effects, the assessment of 
better  environmental  options  and  the  measures  taken  to  mitigate  the  adverse  impacts  of  new 
developments.  In  particular,  the  concept  of  ‘overriding  public  interest’  continues  to  be  insufficiently 
addressed/justified as a result of the use of a mere ‘declaration of general interest’ allowed under the 
Spanish legislation. 

7.  As  regards  monitoring,  assessment,  data  management  and  reporting,  Spain  has  made  important 

improvements in several aspects but should: 

a)  continue progressing on setting type-specific reference conditions where these have not yet been set, 
in particular as regards hydromorphological quality elements for lake, transitional and coastal water 
body types. 

b) 

improve the selection of RBSPs to ensure consistent monitoring and appropriate coverage, identifying 
exceedances and how such exceedances have been taken into account in the assessment of ecological 
status. 

c)  address significant gaps in monitoring of biological, hydromorphological, and physico-chemical quality 
elements; extend quantitative monitoring to all RBDs (i.e. Ceuta and Melilla); include in the chemical 
monitoring  all  substances  causing  risk  of  deterioration;  increase  frequency  of  monitoring  in 
biota/sediment and extend such biota monitoring to all relevant priority substances (in particular for 
mercury). 

d)  further improve the level of confidence for status assessment, both for water bodies classified without 
confidence rating and for classifications with low confidence overall. This could be done by improving 
the in-situ coverage and the monitored parameters thus limiting the reliance on expert judgement. 

38 

 
e) 

include all priority substances in the monitoring programs of all RBDs and for status assessment. This 
would need to be coupled with clearer information for each RBD on priority substances and groundwater 
pollutants included in the inventories and actually being discharged in the water. The monitoring of 
discharges and links to the pressure assessment/emission inventory needs to be improved. 

39 

 
 
 
SECTION B: 
FLOODS DIRECTIVE 

40 

 
 
 
7. Flood risk management under floods directive (FD) 

The Directive requires each Member State (MS) to scan its territory for flood risks, assess the potential 
adverse  consequences  of  future  floods  for  human  health,  the  environment,  cultural  heritage  and 
economic  activity,  identify  the  significant  risks,  map  the  flood  extent  and  the  potential  adverse 
consequences, and take measures to reduce the flood risk. These activities are reflected in (a) the 
Preliminary  Flood  Risk  Assessments    (PFRAs)  (including  the  identification  of  Areas  of  Potential 
Significant Flood Risk (APSFRs)), (b) the preparation of flood hazard and risk 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 25 Units of Management (UoMs) in Spain, which are the same as the Water Framework 
Directive’s  River  Basin  Districts  (RBDs).  A  selection  of  5  UoMs  and  FRMPs  have  been  reviewed  in 
further depth and details. These are: Eastern Cantabrian, Guadiana, Júcar, Andalusian Mediterranean 
Basins,  La  Gomera.  The  potentially  significant  sources  of  flooding  in  Spain  are:  fluvial,  pluvial, 
groundwater, and sea water floods.  

Spain designated 1 451 Areas of Potential Significant Flood Risk (APSFRs). 

It  is  noted that  considerable  efforts  have  been made  by  Spain  to better integrate  the impacts  of 
climate change on flood risk. This has built on a number of initiatives: a new climate change national 
study,  a  pilot  methodology  for  fluvial  and  pluvial  floods  published  in  2019,  and  an  extended  and 
improved methodology drafted in 2018 and applied in the second PFRA. For coastal flooding, there is 
a national study assessing the impacts of sea level rise. Pilot studies have been undertaken for five 
river  stretches  as  regards  the  quantitative  flow  changes  due  to  climate  change  effects  on 
precipitation, resulting generally in larger flow volumes, depth and velocity. 

7.1 Flood hazard and risk maps 

The methodology used to prepare flood hazard risk maps seems to be largely the same as in the 
previous  cycle.  The  guidance  document66  published  at  national  level  aims  to  harmonise  the  work 
being developed in the UoMs. 

Spain is using a national map viewer,67 largely targeted to professionals, for fluvial and pluvial floods. 
Maps for other flood types are also available in other formats and different scales (regional or UoM 
scale) The national website68 also refers to the specific websites of the individual UoMs. 

FHRMs were prepared at the national level and cover the whole country and all 25 UoMs. Maps for 
floods  with  low  probability  (1/500  years),  with  medium  probability  (1/100  years)  and  with  high 
probability  (1/10  years)  are  provided.  The  maps  also  cover:  flood  extent,  water  depth,  number  of 
inhabitants potentially affected, the type of economic activity and the industrial installations covered 
by  the  Industrial  Emissions  Directive.  All maps,  except  for  Catalan  Basins  (ES100),  also  show  the 
potentially affected protected areas identified in the WFD. 

66 https://www.miteco.gob.es/es/agua/temas/gestion-de-los-riesgos-de-inundacion/propuesta-de-minimos-realizacion-
mapas-deriesgo-2ciclo_tcm30-511333.pdf page 35 and following 
67 https://sig.mapama.gob.es/geoportal/ 
68https://www.miteco.gob.es/es/agua/temas/gestion-de-los-riesgos-de-inundacion/mapa-peligrosidad-riesgo-
inundacion/Mapas-peligrosidad-segundo-ciclo-2019.aspx 

41 

 
 
It  is  worth  noting  that  there  is  an  improved  identification  of  the  Points  of  Special  Importance. 
Previously, there were four types of points: installations covered by the Industrial Emissions Directive, 
wastewater treatment plants, cultural heritage and civil protection. In this second cycle, all categories 
have been retained but providing more information to better equip civil protection authorities when 
managing a flood event. 

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

7.2 Flood risk management plans 

Objectives and measures 

The FRMPs are available online.69 All five FRMPs assessed set nine common, general objectives. Four 
of the five FRMPs also cite a common, overarching objective, to ensure that current flood risk does 
not increase, as well as sub-objectives. One general objective refers to managing exposure to flooding 
and another to improving resilience and reducing vulnerability. The objectives also call for reducing 
flood risks, of which adverse consequences are a component.  

The general objectives call for i) raising awareness to support self-protection by the economic actors, 
ii) improving administrative coordination, iii) enhancing knowledge and forecasting, and iv) improving 
land-use  planning  and  v)  reducing  flood  risk  for  human  health,  for  economic  activities,  for  the 
environment, and for cultural heritage. Moreover, one of the general objectives calls for improving or 
maintaining the good status of water bodies via improvement of their hydromorphological conditions, 
thus addressing the WFD’s environmental objectives. It is worth noting that as part of the general 
objectives,  as  well  as  a  sub-objective  for  three  FRMPs,  there  is  a  call  for  natural  water  retention 
measures (NWRMs). All five FRMPs highlight the importance of NWRMs and include them both as 
groups of measures and as single measures. 

All five FRMPs assessed have Programmes of Measures (PoMs), listing both clusters of measures as 
well as individual ones, all amount to 3 681 measures. Out of those, 998 prevention measures, 1 
170 protection measures and 894 preparedness measures. The PoMs present the benefits of groups 
of measures in qualitative terms and importance is given to ensure that flood risk management goes 
hand-in-hand with the protection and restoration of ecosystems. 

The  FRMPs  include  measures  for  land-use  planning  and  for  the  reduction  of  the  vulnerability  of 
existing buildings in flood risk zones. The FRMPs briefly present the methods for prioritisation and 
provide a common list of indicators to monitor the progress of their measures and their objectives 
including some target values. As part of this prioritisation methodology, one of the criteria considered 
is the synergies with other legislation, including the EU Birds and Habitats Directives. 

69https://www.miteco.gob.es/es/agua/temas/gestion-de-los-riesgos-de-inundacion/planes-gestion-riesgos-
inundacion/planes-gestion-riesgos-inundacion-segundo-ciclo.html  

42 

 
 
Figure 11: Prioritisation of measures using the five priority categories set out in the reporting guidance, 
from critical to low priority. 

Source: 2nd FRMPs e-reporting 

As regards the progress achieved so far in implementing the measures:  

completed (357 measures)  

•  a significant proportion of measures were reported as not started (1 403 measures)  
•  abandoned/interrupted (1 162 measures) 
• 
•  ongoing or recurrent (e.g. maintenance works, 291 measures) 
• 
•  undergoing construction (195 measures) 

in preparation (273 measures), 

It has been noted that the prevention measures have the highest percentage of completed measures 
(15% of all prevention measures), while only 3% of recovery and review measures were reported as 
completed.  55%  of  all  recovery  and  review  measures  (341  measures)  were  reported  as 
abandoned/interrupted, the highest across all measure aspects; 26% of prevention measures were 
abandoned/interrupted, as were 20% protection measures, and 38% of preparedness measures. 

Four  of  the  five  FRMPs  note  that  some  measures  under  the  first  FRMPs  either  have  not  been 
completed yet, or have not even started due to various reasons.70 Two of the five plans – the FRMPs 
for the Júcar and Guadiana UoMs – state that a higher share of measures where regional and local 
authorities are responsible have not been initiated. This includes regional departments of land use 
planning and urbanism, regional departments of environment, regional civil protection agencies, and 
municipalities. The FRMPs state that progress in implementation has been greater in actions within 
the competence of RBD authorities and national authorities. Additionally, there has been low level of 
implementation  of  measures  involving  the  approval  of  agreements  or  requiring  enhanced 
coordination. The two plans do not, however, describe the reasons for these trends. 

70 Chapter 11.3 of the FRMPs for ES017, ES040, ES060 and ES080. 

43 

 
 
 
In other areas of progress, the second FRMPs provide more information on measures, including their 
costs. A greater emphasis is placed on the role of land use and spatial planning in addressing flood 
risks. The second FRMPs have a new, general objective for emergency planning, raising the profile of 
work in this area. They also provide further information on the national approach and institutions for 
flood insurance. 

As regards funding, all FRMPs provide total budgets and the PoMs indicate the costs of each measure 
for  97%  of  them.  The  five  FRMPs  assessed  use  a  common  text  to  refer  to  the  funding  of  their 
measures: a mix  of funding from EU  and national  sources is planned. Next to public funding, the 
plans also mention private sources of funding, stating that the private sector can be involved through 
social corporate responsibility actions, and they indicate that owners should also bear the costs of 
measures to protect their buildings and properties. All five FRMPs describe the use of quantitative 
cost-benefit analysis (CBA) for structural measures. 

Governance 

As  regards  public  participation,  Spain  reported  that  a  wider  range  of  stakeholders  were  actively 
involved in the preparation of the second FRMPs. The four FRMPs assessed in mainland Spain each 
has a brief section in the main text describing the process for public information and consultation 
and provides further details in an annex. The exception is the FRMP for La Gomera, which mentions 
the  public  information  and  consultation  process  but  does  not  provide  details  on  it.  During  the 
consultation period, the draft FRMPs were available online.71 

As  regards  transboundary  cooperation,  the  Guadiana  FRMP  refers  to  the  Albufeira  Convention  of 
1998, as the main instrument for transboundary cooperation in water management between Spain 
and  Portugal.  The  Eastern  Cantabrian  FRMP,  which  includes  basins  shared  with  France,  cites  the 
Toulouse Agreement of 2006 on transboundary cooperation in water management between Spain 
and France. 

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 

In  the  second  FRMPs  the  objectives  are  linked  to  both  measures  and  to  indicators,  which  should 
provide a clearer picture as to how objectives are achieved. 

The second FRMPs have improved a number of aspects compared to the previous cycle, namely: 

• 
• 

• 
• 

they provide much more information on the measures than in the past. 
they place a greater emphasis on the role  of land use and spatial planning in addressing 
flood risks and a stronger emphasis on nature-based solutions. 
they refer to public awareness in their objectives and their measures 
they all include a new, general objective for emergency planning, raising the profile of work 
in this area. 

71 For the Andalusian Mediterranean Basins, on the website of the Andalusia Autonomous Community, and for the Eastern 
Cantabrian, Guadiana, and Júcar FRMPs, on the website of the UoM/RBD authorities. 

44 

 
 
• 

they  provide  more  information  on  flood  insurance  and  on  the  impacts  of  climate  change 
(including indications of the existing uncertainties).  

8. FD recommendations 

Based on the reported information and the FHRMs and FRMPs assessed, in addition to the progress made, Spain 
should: 

render the FHRM portal more user friendly for non-expert users; 

take into account climate change in the development of FHRMs; 

provide detail on how the FHRMs were used in the choice of objectives and measures in the FRMP; 

• 

• 

• 

• 

•  make clear to what extent the objectives would be achieved with the implementation of the measures. 
An assessment of the progress made towards the achievement of the objectives should be included 
in the FRMP; 

• 

provide information on the methods used to prioritise measures in the FRMP; 

•  although some FRMPs describe the use of quantitative CBA for structural measures, provide a clear 

overview of its use and the methodology behind it; 

• 

describe in more detail the public information and consultation process in all FRMPs and consultations 
should aim to last six months; 

•  where appropriate, consider flow velocity (or relevant water flow) in the FHRM and flood conveyance 

routes in the FRMP, as these are relevant to emergency response. 

• 

include more information on the investment needs and funding sources (e.g. public -including EU funds 
-and private). 

45