Assessment of the third river basin management plans under water framework directives : Poland
Date: 2025-10-30
Institutions: Directorate-General for Environment
Subjects: Poland, directive (EU), groundwater, international cooperation, plan, sustainable development, water policy, water pollution, watercourse

Assessment of the third River Basin
Management Plans under the Water
Framework Directive
Poland

Consultants’ assessment study for the European Commission

June 2025

EUROPEAN COMMISSION

Directorate-General for Environment
Directorate: Zero Pollution
Unit: Sustainable Freshwater Management

Contact: ENV WATER

E-mail: Env-Water@ec.europa.eu

European Commission
B-1049 Brussels

Assessment of the third
River Basin Management Plans
under the Water Framework
Directive

Poland

Consultants’ assessment study for the European
Commission

June 2025

Manuscript completed in June 2025

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PDF

ISBN

978-92-68-25459-2

doi 10.2779/1251939

KH- 01-25-088-EN-N

Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

Contents

Acronyms .................................................................................................................... 6

Foreword ..................................................................................................................... 9

General Information .................................................................................................. 11

Status of third river basin management plan reporting ......................................... 14

Executive summary .................................................................................................. 15

Recommendations .................................................................................................... 25

1.

Governance and public participation ............................................................. 29

1.1. Assessment of implementation and compliance with WFD requirements ...... 29

1.1.1. Administrative arrangements – river basin districts ................................. 29
1.1.2. Administrative arrangements – competent authorities ............................. 30
1.1.3. RBMPs – structure and Strategic Environmental Assessment ................. 31
1.1.4. Coordination with the Floods Directive .................................................... 31
1.1.5. Coordination with the Marine Strategy Framework Directive ................... 33
1.1.6.
International coordination and cooperation .............................................. 33
1.1.7. Public consultation .................................................................................. 40

1.2. Main changes in implementation and progress with recommendations ......... 42

1.3. Conclusion on gaps in implementation .......................................................... 44

2.

Characterisation of the River Basin District .................................................. 45

2.1. Assessment of implementation and compliance with WFD requirements ...... 45

2.1.1. Delineation of water bodies and designation of heavily modified and artificial

water bodies ........................................................................................... 45
2.1.2.
Identification of transboundary water bodies ........................................... 48
2.1.3. Typology of surface water bodies ............................................................ 48
2.1.4. Establishment of reference conditions/type-specific conditions for surface water

bodies ..................................................................................................... 49
2.1.5. Characteristics of groundwater bodies .................................................... 49
2.1.6. Significant pressures and impacts on water bodies ................................. 50
2.1.7. Definition and assessment of significant pressures on surface and groundwater

 51

2.1.8. Groundwater bodies at risk of not meeting good status ........................... 51
2.1.9. Quantification of the gap and apportionment of pressures ...................... 52
2.1.10.Inventories of emissions, discharges and losses of chemical substances 52

2.2. Main changes in implementation and progress with recommendations ......... 53

2.3. Conclusions on gaps in implementation ........................................................ 53

3.

Monitoring, assessment and classification of ecological status/potential in
surface water bodies ....................................................................................... 54

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

3.1. Assessment of implementation and compliance with WFD requirements ...... 54

3.1.1. Monitoring of ecological status / potential in surface waters .................... 54
3.1.2. Assessment of ecological status / potential for surface water bodies ...... 57
3.1.3. Classification of ecological status/potential of surface water bodies ........ 59

3.2. Main changes in implementation and progress with recommendations ......... 61

3.3. Conclusions on gaps in implementation ........................................................ 63

4.

Monitoring, assessment and classification of chemical status in surface water
bodies ............................................................................................................... 65

4.1. Assessment of implementation and compliance with WFD requirements ...... 65

4.1.1. Monitoring of chemical status in surface waters ...................................... 65
4.1.2. Assessment of chemical status for surface water bodies ........................ 67
4.1.3. Classification of chemical status of surface water bodies ........................ 70

4.2. Main changes in implementation and progress with recommendations ......... 71

4.3. Conclusions on gaps in implementation ........................................................ 73

5.

Monitoring, assessment and classification of quantitative status of groundwater
bodies ............................................................................................................... 74

5.1. Assessment of implementation and compliance with WFD requirements ...... 74

5.1.1. Monitoring of quantitative status in groundwater ..................................... 74
5.1.2. Assessment of quantitative status for groundwater bodies ...................... 74
5.1.3. Classification of quantitative status of groundwater bodies ..................... 75

5.2. Main changes in implementation and progress with recommendations ......... 77

5.3. Conclusions on gaps in implementation ........................................................ 77

6.

Monitoring, assessment and classification of chemical status of groundwater
bodies ............................................................................................................... 78

6.1. Assessment of implementation and compliance with WFD requirements ...... 78

6.1.1. Monitoring of chemical status in groundwater ......................................... 78
6.1.2. Assessment of chemical status for groundwater bodies .......................... 79
6.1.3. Classification of chemical status of groundwater bodies .......................... 81

6.2. Main changes in implementation and progress with recommendations ......... 82

6.3. Conclusions on gaps in implementation ........................................................ 83

7.

Designation of heavily modified and artificial water bodies and definition of good
ecological potential ......................................................................................... 84

7.1. Assessment of implementation and compliance with WFD requirements ...... 84

7.1.1. Designation of heavily modified and artificial water bodies ...................... 84
7.1.2. Definition of good ecological potential for heavily modified and artificial water

bodies ..................................................................................................... 85

7.2. Main changes in implementation and progress with recomendations ............ 86

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

7.3. Conclusions on gaps in implementation ........................................................ 87

8.

Environmental objectives and exemptions .................................................... 88

8.1. Assessment of implementation and compliance with WFD requirements ...... 88

8.1.1. Environmental objectives ........................................................................ 88
8.1.2. Exemptions ............................................................................................. 88

8.2. Main changes in implementation and progress with recommendations ......... 93

8.3. Conclusions on gaps in implementation ........................................................ 95

9.

Programme of measures ................................................................................. 96

9.1. Assessment of implementation and compliance with WFD requirements ...... 96

9.1.1. General issues ........................................................................................ 96
9.1.2. Mapping of national measures to Key Types of Measure ...................... 102
9.1.3. Pressures for which gaps to be filled to achieve WFD objectives and the Key

Types of Measure planned to achieve objectives .................................. 105
9.1.4. Transboundary cooperation .................................................................. 108

9.2. Main changes in implementation and progress with recommendations ....... 108

9.3. Conclusions on gaps in implementation ...................................................... 110

10. Measures related to abstractions and water scarcity.................................. 111

10.1. Assessment of implementation and compliance with WFD requirements .....111

10.1.1.Water exploitation and trends .................................................................111
10.1.2.Main water uses .................................................................................... 112
10.1.3.Measures related to abstractions and water scarcity ............................. 113
10.1.4.International cooperation ....................................................................... 114

10.2. Main changes in implementation and progress with recommendations ....... 116

10.3. Conclusions on gaps in implementation ...................................................... 116

11. Measures related to pollution from agriculture ........................................... 118

11.1. Assessment of implementation and compliance with WFD requirements .... 118

11.1.1. Use of measures to address agricultural pollution ................................. 118
11.1.2. Implementation of measures ................................................................. 118
11.1.3. Funding of measures ............................................................................ 119
11.1.4. Gaps and distance to target .................................................................. 119
11.1.5. Nutrient management and transboundary cooperation .......................... 119

11.2. Main changes in implementation and progress with recommendations ....... 119

11.3. Conclusions on gaps in implementation ...................................................... 120

12. Measures related to pollution from sectors other than agriculture ............ 122

12.1. Assessment of implementation and compliance with WFD requirements .... 122

12.1.1.Key Types of measure to tackle pollution from non-agricultural sources 122
12.1.2.Basic measures for the control of point source discharges .................... 122

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

12.1.3.Measures for chemical substances causing failure of objectives ........... 122
12.1.4.Measures for all drivers causing chemical pollution ............................... 123

12.2. Main changes in implementation and progress with recommendations and progress
with recommendations ................................................................................. 123

12.3. Conclusions on gaps in implementation ...................................................... 123

13. Measures related to hydromorphology ........................................................ 125

13.1. Assessment of implementation and compliance with WFD requirements .... 125

13.1.1.KTMs to tackle pressures ...................................................................... 125
13.1.2.General measures to tackle hydromorphological pressures .................. 125
13.1.3.Indicators on the gaps to be filled for hydromorphological pressures .... 125
13.1.4.Measures for achieving objectives of the WFD and Floods Directive and drought
management ......................................................................................... 125
13.1.5.Ecological flows .................................................................................... 126
13.1.6.Nature-based solutions ......................................................................... 126

13.2. Main changes in implementation and progress with receommendations ..... 126

13.3. Conclusions on gaps in implementation ...................................................... 127

14. Economic analysis and water pricing policies ............................................ 128

14.1. Assessment of implementation and compliance with WFD requirements .... 128

14.1.1.Water services and water uses ............................................................. 128
14.1.2.Economic analysis update .................................................................... 129
14.1.3.Incentive function of water pricing ......................................................... 130
14.1.4.Calculation of cost recovery and adequate contributions ....................... 130
14.1.5.Environmental and resource costs ........................................................ 131
14.1.6.Information provided on Polluter Pays Principle .................................... 132

14.2. Main changes in implementation and progress with recommendations ....... 132

14.3. Conclusions on gaps in implementation ...................................................... 133

15. Considerations specific to protected areas (identification, monitoring, objectives
and measures) ............................................................................................... 135

15.1. Assessment of implementation and compliance with WFD requirements .... 135

15.1.1.Monitoring sites for protected areas ...................................................... 136
15.1.2.Status of protected areas ...................................................................... 137
15.1.3.Additional objectives ............................................................................. 137
15.1.4.Additional measures ............................................................................. 137

15.2. Main changes in implementation and progress with recommendations ....... 137

15.3. Conclusions on gaps in implementation ...................................................... 138

16. Adaptation to drought and climate change .................................................. 139

16.1. Assessment of implementation and compliance with WFD requirements .... 139

16.1.1.Measures .............................................................................................. 139

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

16.1.2.Assessment of implementation and compliance with WFD requirements – climate
change adaptation ................................................................................ 139
16.1.3.Assessment of implementation and compliance with WFD requirements in the 3rd
RBMPs – droughts ................................................................................ 141

16.2. Main changes in implementation and progress with recommendations ....... 142

16.3. Conclusions on gaps in implementation ...................................................... 142

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

Acronyms

AWB

BDS

BQE

DrWPA

E-flow

Artificial water body

Biodiversity Strategy for 2030

Biological Quality Elements

Drinking water protected areas

Ecological flow

EIONET 3rd RBMPs pdf
reporting

Member State’s 3rd RBMPs pdf reporting submitted to
EIONET

EIONET 3rd RBMPs e-reporting

Member State’s 3rd RBMPs e-reporting submitted to
EIONET

EQS Directive

Environmental Quality Standards Directive

ERC

FD

GIS

GEP

GES

GWB

GWD

GWAAE

GWDTE

HMWB

HD

IED

IRBD

IRBD

IRBMP

Environmental and Resource Cost

Floods Directive

Geographic Information System

Good Ecological Potential

Good Ecological Status

Groundwater Body

Groundwater Directive

Groundwater Associated Aquatic Ecosystem

Groundwater Dependant Terrestrial Ecosystem

Heavily Modified Water Body

Habitats Directive

Industrial Emission Directive

International River Basin District

International River Basin District

International RBMP

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

km2

KTM

LOQ

MSFD

MEP

NbS

NWRM

NGO

PAH

PBT

PBDE

PFOS

PoM

PPP

Square Kilometre

Key Type of Measure

Limit of Quantification

Marine Strategy Framework Directive

Maximum Ecological Potential

Nature-based Solutions

Natural Water Retention Measures

Non-Governmental Organisation

Polycyclic Aromatic Hydrocarbons

Persistent, Bioaccumulative, and Toxic chemical

Polybrominated diphenyl ethers (flame retardants)

Perfluorooctane Sulfonates

Programme of Measures

Polluter Pays Principle

QA/QC Directive

Directive 2009/90/EC (the QA/QC Directive) on the
quality and comparability of chemical monitoring
specifies minimum performance criteria to ensure the
quality of the analytical results.

RBD

RBMP

RBSP

RDP

SWB

SWMI

UWWTD

UWWTP

uPBT

River Basin District

River Basin Management Plan

River-basin-specific pollutant

Rural Development Programme

Surface Water Body

Significant Water Management Issues

Urban Waste Water Treatment Directive

Urban Waste Water Treatment Plant

Ubiquitous PBT

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

WFD

WISE

WSS

Water Framework Directive

Water Information System for Europe

(drinking) Water Supply and Sanitary services

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

Foreword

The European Union’s Water Framework Directive (2000/60/EC, WFD) established a
framework for the management of water in Europe. Article 4 of the WFD describes the
environmental objectives of the WFD that must be achieved in all Member States’ surface
waters, groundwater, and protected areas (i.e., ecological status, quantitative status, chemical
status, and protected area objectives). River Basin Management Plans (RBMPs) are an
operational element of the WFD, providing an integrated water management approach
focused on the river basin level. The RBMPs provide a detailed account of how the WFD
objectives are achieved within the set timeline of the reporting cycle. As a step-by-step
procedure, each plan builds on the previous plan. After a period of public consultation on draft
plans, the final RBMPs are drawn up as final outcome of the planning process by taking into
consideration comments and suggestions by stakeholders.

The WFD requires all Member States to prepare and publish RBMPs for each River Basin
District (RBD) lying within their territory. For international river basins (e.g. Danube; Rhine; 
Elbe etc.), Member States must co-ordinate with each other to produce a single international
RBMP. If international river basins reach beyond the EU, Member States should aim to
produce a single RBMP, or at least cover the portion lying in their own territory.

RBMPs are updated every six years. Article 15 of the WFD requires that each Member State
reports its RBMP(s) to the European Commission. WFD Article 18 also requires that the
Commission reports to the Council and the European Parliament on the implementation of the
Directive.

The 1st RBMP covered the period 2010-15. The 2nd RBMP covered the period 2016-21. The
3rd RBMP, covering the period 2022-2027, were due to be adopted by the Member States in
December 2021 and reported to the European Commission in March 2022. Poland completed
the submission of its 9 RBMP documents for the 3rd RBMPs to the Commission on 16 March
2023.

The structure of this assessment study follows a common assessment template used for all
Member States. This assessment provides background to an EU Overview (a European
Commission Staff Working Document) that is published separately.

Whereas a key role of the Commission is to check compliance with EU legislation, the
Commission also seeks information to issue recommendations to Member States and to
determine whether existing policies are adequate. The individual Member State assessment
studies, such as this one, aim at strengthening water management in the EU based on good
practice, as it emerges from the implementation of the WFD.

Basis for the assessment

This Member State assessment study has been drafted on the basis of information in Poland’s
RBMPs. No submission was made through the Water Information System for Europe (WISE)
electronic reporting in time to be taken into account in this analysis. The RBDs selected for the
in-depth analysis of PDF RBMPs are the Oder (PL6000) and the Vistula (PL2000). Together,
these RBDs cover approximately 97% of Poland. Some gap filling of quantitative data has

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

been undertaken using data from the RBMPs and supporting documents to enable this
assessment report to include quantitative information, charts and figures and to provide a
more complete view of compliance in the Member State. This information is labelled as ‘data
mining’.

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

General Information

Poland joined the European Union in 2004.

Poland has a population of 36.7 million1 and a total land area of 307,236 km² (Map A). Its
territory stretches from the Baltic Sea in the north to the Carpathian Mountains in the south.
The northern part of the country is mainly lowlands with lake districts, whilst the most southern
part is mountainous. The lowest point in Poland is at 1.8 metres below sea level at Raczki
Elblaskie in the Vistula delta. The highest part of the Carpathians is the Tatra Mountains with
the highest peak Rysy at 2,499 metres above sea level.

Map A  Map of River Basin Districts

Source: 2nd RBMP e-reporting, Eurostat (country borders)
Note: RBD PL6700 (Ucker) is now part of RBD PL6000 (Oder) in the 3rd RBMPs

1 European Commission https://european-union.europa.eu/principles-countries-history/key-facts-and-
figures/life-eu_en

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

Poland shares its borders with Germany (west), the Czech Republic and Slovak Republic
(south), Ukraine, Belarus and Lithuania (east) and the Baltic Sea and the Russian region of
Kaliningrad Oblast (north).

Poland has nine RBDs (Table A). They are all international. The longest Polish rivers are the
Vistula and Oder and their RBDs cover almost 97% of the country surface area. Both rivers
flow into the Baltic Sea.

Information on areas of the international RBDs, including sharing countries, is provided in
Table A. Poland’s percentage share of each international RBD is shown in Table B. This
information is from the 2nd RBMPs, as the 3rd RBMPs e-reporting is not available at the time of
this assessment.

Table A

Overview of Poland’s River Basin Districts

RBD

RBD Name

Size (km2)
(% of RBD in Poland)

Countries sharing RBD

PL1000

Danube

385 (less than 1%)

DE, SK, UA, AT, BG, CZ, HR, HU, RO, IT, MD, ME,
RS, SI, BA, AL, CH, MK

PL2000

Vistula

183,492 (app. 59%)

BY, RU, UA, SK

PL3000

Świeża

161 (less than 1%)

PL4000

PL5000

Jarft

Elbe

210 (less than 1%)

238 (less than 1%)

CZ, DE, AT

RU

RU

PL6000

Oder

118,499 (app. 38%)

PL7000

Pregoła

7,522 (app. 2.5%)

PL8000

Nemunas

2,515 (less than 1%)

PL9000

Dniester

233 (less than 1%)

CZ, DE

RU

BY, LT (RU)

UA (MD)

Source: 2nd RBMPs e-reporting
Notes: The RBD sizes may have changed since the 2nd RBMPs but the 3rd RBMPs electronic data is not available
to confirm this. The 2nd RBMPs also included RBD PL6700 (Ucker) which now forms part of PL6000 (Oder) in the
3rd RBMPs. 2

2 Poland subsequently provided data to show that the values from the 2nd and 3rd RBMPs are almost
identical. With the actual values being: 185,090 km2 for the Vistula RBD and 118,030 km2 for the Oder
RBD.

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

Table B

Transboundary river basins by category and percentage share in Poland

Name
internation
al

river basin

National
RBD

Danube

PL1000

Countries
sharing
RBD

DE, SK, UA,
AT, BG, CZ,
HR, HU, RO,
IT, MD, ME,
RS, SI, BA,
AL, CH, MK

Co-ordination category

1

2

3

km²

%

km²

%

km²

%

385

<0.1

Elbe

Oder

Dniester /
Dnistr/ Nistru

Nemunas/
Nieman/
Neman/
Nyoman

PL5000

CZ, DE, AT

238

0.2

PL6000

CZ, DE

118,365

86.4

PL9000

UA (MD)

233

0.3

PL8000

BY, LT (RU)

2,515

2.1

Vistula

PL2000

BY, RU, UA,
SK

Bug (Sub--
basin Vistula)

183,492

86.8

19,284

48.9

Source: 2nd RBMPs e- reporting

Category 1: International agreement, permanent co-operation body and international RBMP in place.
Category 2: International agreement and permanent co-operation body in place.
Category 3: International agreement in place.
Category 4: No co-operation formalised.

Poland designated a total of 4,240 surface water bodies and 174 groundwater bodies in its 3rd
RBMP.

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

Status of third river basin management plan reporting

A total of nine Polish RBMPs (Danube, Vistula, Świeża, Jarft, Elbe, Oder, Pregoła, Nemunas,
Dniester) were published between 23 December 2022 and 23 February 2023. The number of
RBMPs has changed since the 2nd RBMPs from 10 to 9. Documents are available from the
European Environment Agency EIONET Central Data Repository https://cdr.eionet.europa.eu/.

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

Executive summary

Topic 1: Governance and public consultation

Poland has several layers of water governance, including Ministries, health authorities and
authorities for water management and maritime affairs at the national level; voivodeships
(provinces) as the competent authorities at the regional level for enforcement of regulation
and implementation of measures; and municipalities also for implementation.

All nine of Poland's RBDs are part of international RBDs. This includes Poland's sections of
the Danube, Elbe and Oder RBDs: for these three international RBDs, an international
agreement, permanent cooperation body and international RBMP are in place (designated as
category 1 cooperation). Poland did not prepare an international RBMP for the Vistula RBD
(90% of which is located on Poland’s territory) but has bilateral agreements with neighbouring
countries (designated as category 3 cooperation).

The Oder and Vistula RBMPs include Floods Directive (FD) objectives, but not Marine
Strategy Framework Directive (MSFD) objectives.

The work programme, timetable, consultation plan, overview of the significant water
management issues, and the draft RBMPs have been submitted to a public consultation for
six months.

Topic 2: Characterisation of the RBD

The RBMP documents for the 3rd RBMPs indicate that type-specific reference conditions have
been established for all surface water types. It is stated that the RBMPs contain a list of water
bodies and information on their types and whether reference conditions are established. This
is provided separately in the regulation of the Minister of Infrastructure of June 25, 2021,
concerning the classification of ecological status, ecological potential, chemical status, and
the method of classifying the uniform parts of surface waters, as well as environmental quality
standards for priority substances3. In the 2nd RBMPs, reference conditions were established
for all relevant quality elements for all water body types across all water categories. There
have been additional surface water types in the 3rd RBMPs, and it is stated that reference
conditions have been established for the new types. A background document detailing the
methodology used to determine typology was not identified in the RBMPs but information on
typology is provided in the text of the RBMPs.

In the Vistula and Oder RBMPs, which were analysed in greater detail for the purposes of this
assessment, the main pressures on river water bodies are river bed straightening, dams and
other hydrotechnical structures, bridges, regulatory structures (edge strips, groynes,
longitudinal dams), flood embankments, water management facilities, mining, diffuse pollution
from atmospheric deposition, and rainwater discharged from urban areas and industrial and
urban sources. The main pressures and impacts on lakes are nutrient pollution from
agriculture, diffuse pollution from atmospheric deposition and run-off from forest areas. For

3 Available at: https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20210001475

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

transitional and coastal water bodies, the Vistula and Oder RBMPs highlight the main sources
of pressures as pollutants entering from the inflow of rivers. Point source discharges of
sewage are also highlighted as a key pressure on transitional and coastal water bodies in the
Vistula RBD. In the 2nd RBMPs, the significant pressures affecting the most surface water
bodies were anthropogenic pressures from unknown sources, diffuse pressures from
discharges not connected to the sewerage network and diffuse pressures from agriculture. In
the 2nd RBMPs, the significant impacts affecting the most surface water bodies were unknown
impact type and nutrient pollution.

In groundwater, the pressures linked to the risk of failing chemical objectives are municipal,
industrial and other landfills; discharge of municipal and industrial sewage into water and land; 
pollution from agriculture and the impact of urban-industrial agglomerations and road
transport. The pressures linked to the risk of failing quantitative objectives are mining
drainage, land improvement, and the impact of urban-industrial agglomeration. In the 2nd
RBMPs, the significant pressures affecting the most groundwater bodies were diffuse
pressures from mining, alteration of level or volume of groundwater, and diffuse pressures
from agriculture. In the 2nd RBMPs, the significant impacts affecting the most groundwater
bodies were lowering of the water table (abstraction), diminution of quality of associated
surface waters and damage to groundwater dependent terrestrial ecosystems.

Topic 3: Monitoring, assessment and classification of ecological status/potential
in surface water bodies

Some changes and progress have been made with recommendations since the 2nd RBMPs.
Surveillance monitoring has been established. Both surveillance and operational monitoring
have new criteria for the selection of surface water bodies to be monitored. Additionally,
surveillance and operational monitoring covers a large portion of water bodies.

Since the 2nd RBMPs, there is a worsening of overall ecological status / potential of surface
water bodies in Poland. The percentage of surface water bodies between the 2nd  and 3rd
RBMPs at high ecological status or maximum ecological potential decreased from 0.3% to
0.1%, for good ecological status/potential from 11.7% to 10.4%, for moderate ecological
status/potential there is an increase from 51.1% to 53.6%, for poor ecological status/potential
it decreased from 25.4% to 20.0%, and lastly there was an increase in poor ecological
status/potential from 11.5% to 15.9%. There is no data available on the expected proportion of
water bodies in good ecological status/potential by 2027.

Topic 4: Monitoring, assessment and classification of chemical status in surface
water bodies

The 3rd RBMPs for Poland state that the spatial scale of the monitoring network to support the
chemical status assessment has been expanded by 16% since the 2nd RBMPs. The
monitoring network now spans 45% of all water bodies in Poland, including 42% of all river
water bodies, 60% of all lake water bodies, and 100% of coastal and transitional water bodies.
Monitoring is also included in territorial waters (based on the sub-set of priority substances in
the surveillance list). The 3rd RBMPs also confirm that the monitoring programme covers all 45
priority substances The frequency of monitoring is monthly for the majority of priority

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

substances, but some substances are monitored less frequently, depending on risk and non-
exceedance of EQS.

For the 3rd RBMPs, a national implementing act to water regulations was adopted in 2019,
addressing the need for monitoring in biota and sediment for hexachlorobenzene,
hexachlorobutadiene, and mercury4. portal. No information is provided about long-term trend
assessments.

The 3rd RBMPs report that 28% of all surface water bodies are in good chemical status, 47%
are in poor chemical status, and 25% are in unknown status. In particular, it is noted that the
number of water bodies in unknown status has increased from 15% in the 2nd RBMPs to 25%
in the 3rd RBMPs. In terms of the reasons for failing to achieve good chemical status, the
majority of substances are categorised as uPBT. In particular polyaromatic hydrocarbons
(PAHs) and mercury look problematic, but additionally polybrominated diphenyl ethers
(PBDEs), perfluorooctane sulphonic acid (PFOS), fluoranthene, hexabromocyclododecane
(HBCDD), and heptachlor (and heptachlor epoxide) also have EQS exceedances.

Topic 5: Monitoring, assessment and classification of quantitative status of
groundwater bodies

In the 3rd RBMPs, the total number of delineated groundwater bodies in Poland is 174,
increasing from 172 in the 2nd RBMPs (1.2% increase). In the 3rd RBMPs, 15 out of 174
groundwater bodies (i.e., 8.6% of total groundwater bodies) have been in poor quantitative
status by 2021. In the 2nd RBMPs, 13 out of 172 groundwater bodies (i.e., 7.6% of total
groundwater bodies) were in poor quantitative status by 2015. In the Oder and Vistula RBDs,
classification with medium confidence has been conducted for 89.4% of the assessments, and
with low confidence for the remaining 10.6% of the assessments. The main methodological
gap in the groundwater quantitative status assessment is the lack of consideration of
GWAAEs. It is noted that the 3rd RBMPs e-reporting for Poland was pending at this
assessment’s cut-off date, causing significant limitations in the availability of (aggregated)
information for the 3rd RBMPs.

Topic 6: Monitoring, assessment and classification of chemical status of
groundwater bodies

In the 3rd RBMPs, the total number of delineated groundwater bodies in Poland is 174,
increasing from 172 in the 2nd RBMPs (1.2% increase). This was a result of splitting two
aquifer complexes that were reported as single GWBs in the 2nd RBMPs.

The number of groundwater bodies subject to surveillance monitoring has increased from 160
out of 172 groundwater bodies (i.e., 93.0% of total groundwater bodies) in the 2nd RBMPs to

4 While it is unclear in the 3rd RBMPs whether monitoring in sediment and biota takes place, Poland has
subsequently confirmed that all 20 priority substances in biota and sediment are monitored, with
the first set of data provided in 2022 via the Report Net 3 portal.

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

174 out of 174 groundwater bodies (i.e., 100.0% of total groundwater bodies) in the 3rd
RBMPs.

The number of groundwater bodies subject to operational monitoring has increased from 395
out of 172 groundwater bodies (i.e., 22.7% of total groundwater bodies) in the 2nd RBMPs to
43 out of 174 groundwater bodies (i.e., 24.7% of total groundwater bodies) in the 3rd RBMPs.
In the 3rd RBMPs, 9 out of 174 groundwater bodies (i.e., 5.2% of total groundwater bodies)
have been in poor chemical status by 2021. In the 2nd RBMPs, 14 out of 172 groundwater
bodies (i.e., 8.1% of total groundwater bodies) were in poor chemical status by 2015. The
main methodological gap identified in the groundwater chemical status assessment is the lack
of coordination with neighbouring countries on threshold values. It is noted that the 3rd RBMPs
e-reporting for Poland was pending at this assessment’s cut-off date, causing significant
limitations in the availability of (aggregated) information for the 3rd RBMPs.

Topic 7: Designation of heavily modified and artificial water bodies and
definition of good ecological potential

Heavily modified river water bodies comprise 25% of all river water bodies in the Oder RBD
and 15% in the Vistula RBD. While there are 6% lakes designated as heavily modified in the
Vistula RBMP, the Oder RBMP has designated 20% of its lakes as heavily modified. In the
Oder RBD, 2% of rivers are designated as artificial while in the Vistula RBD 1% of rivers have
been designated as such. There has been a decrease in number and percentage of artificial
and heavily modified water bodies since the 2nd RBMPs, owing to overall changes in water
body numbers and delineation. Dams are mentioned as physical alterations, with the
associated use being hydropower or flood protection. Both the designation methodology and
the designation have been reviewed, however little information is provided on some of its
aspects, such as the significant adverse effect of restoration measures on use and the wider
environment as well as the assessment whether the beneficial objectives can be served by
other means which are significantly better environmental options, technically feasible, and not
disproportionately costly.

The methodology for defining good ecological potential has been updated to include the river
hydromorphological index (and its equivalent for lakes) that links it to good ecological status.

There are still gaps in the assessment of significant adverse effects of restoration measures
and in the identification and assessment of better environmental options at the water body
level.

Topic 8: Environmental objectives and exemptions

In the 3rd RBMPs, Article 4(4) exemptions are applied extensively:

5 It is noted that Poland reported 0 groundwater bodies subject to operational monitoring to 2nd RBMPs
e-reporting. The country subsequently clarified that the total number of groundwater bodies subject to
operational monitoring was 39 in the 2nd RBMPs.

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Assessment of the third River Basin Management Plans under the Water Framework Directive
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● In the Oder RBD, 343 surface water bodies (19.9% of all SWBs in the Oder RBD) have

been exempted in the 3rd RBMP on the grounds of technical feasibility and / or
disproportionate costs and 1322 (77% of all SWBs in the Oder RBD) on the grounds of
natural conditions (see page 194 of the 3rd Oder RBMP). For groundwater, 7
groundwater bodies (10.6% of all GWBs in the Oder RBD) have been exempted on the
grounds of natural conditions.

● In the Vistula RBD, 426 surface water bodies (18.9% of all SWBs in the Vistula RBD)
have been exempted on the grounds of technical feasibility and / or disproportionate
costs and 1709 on the grounds of natural conditions (76% of all SWBs in the Vistula
RBD). For groundwater, 2 groundwater bodies (2.1% of all GWBs in the Vistula RBD)
have been exempted on the grounds of natural conditions.

All Article 4(4) exemptions have been justified based on technical feasibility, disproportionate
costs and / or natural conditions with detailed, water body specific justifications reported in the
Annexes to the 3rd RBMPs.

In total 825 SWBs (19%) have been exempted under Article 4(4) on grounds of technical
infeasibility and / or disproportionate costs and 3,210 SWBs (76%) on grounds of natural
conditions. Furthermore, 10 GWBs (6%) have been exempted on grounds of natural
conditions.

Also, a significant number of Article 4(5) exemptions have been applied:

● In the Oder RBD, 892 surface water bodies (51.8% of all SWBs in the Oder RBD have
been exempted on the grounds of infeasibility and / or disproportionate cost) and 239
(13.9% of all SWBs in the Oder RBD) for reason of natural conditions. For
groundwater, 6 groundwater bodies (9% of all GWBs in the Oder RBD) have been
exempted on the grounds of infeasibility and / or disproportionate cost and 7
groundwater bodies (10.6% of all GWBs in the Oder RBD) have been exempted on the
grounds of natural conditions.

● In the Vistula RBD, 1216 surface water bodies (54% of all SWBs in the Vistula RBD)

have been exempted on the grounds of infeasibility and / or disproportionate cost, and
259 (11.5% of all SWBs in the Vistula RBD) on the grounds of natural conditions. For
groundwater, 7 groundwater bodies have been exempted in the Vistula RBD on the
grounds of infeasibility and / or disproportionate cost (7.4% of all GSWBs in the Vistula
RBD) and 2 on the grounds of natural conditions (2.1% of all GWBs in the Vistula
RBD).

In Poland as a whole, 2,209 SWBs (52%) have been exempted under Article 4(5) on grounds
of other means and / or disproportionate costs and 503 SWBs (12%) on grounds of natural
conditions. Furthermore, 9 GWBs (5%) have been exempted on grounds of natural conditions.

Information has been provided at the water body level, including detailed water body specific
justification on how these exemptions have been applied. This includes an assessment of
socioeconomic needs served by such human activity that cannot be achieved by other means,
which are a significantly better environmental option, not entailing disproportionate costs
(including an assessment of the disproportionate character of measures needed to achieve
good status). However, no explicit definition/criteria appear to be reported in the 3rd RBMPs of

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

Vistula and Oder RBDs (Chapter 8.4) for “technical feasibility” (Article 4(4)/”infeasibility”
(Article 4(5) and “disproportionate costs”6.

Article 4(7) exemptions have been applied in the 3rd RBMPs. The Annex to the RBMP
provides detailed information for individual projects in each water body detailing the impact on
the status of the water body, mitigation measures and the assessment of overriding public
interests and better environmental options.

No exemptions according to Article 4(6) WFD and Article 6(3) of the Groundwater Directive
have been applied in the 2nd or 3rd RBMPs.

Topic 9: Programme of Measures

The 3rd RBMPs include a total of 171 national measures, of which 115 (67%) are basic
measures, and 56 (33%) are supplementary measures. In Poland, measures have been
reported   for each water body in all RBMP documents for the 3rd RBMPs. The 3rd RBMPs also
report on KTMs used per water body while indicating the type of pressures (e.g. chemical
pressures on groundwater and surface water bodies). However, there is no clear allocation of
KTMs to priority substances and groundwater pollutants causing failure in the 3rd RBMPs. The
3rd RBMPs, however, do report KTM15 that aims to address priority substances for some
water bodies. The 3rd RBMPs also report on a catalogue of measures that groups measures to
mitigate identified significant pressures.

There is no explicit reporting on the prioritisation of measures in the 3rd RBMPs, despite the
main drivers of the measures being mentioned. The 3rd RBMPs state that all planned
measures have been assessed on their feasibility, effectiveness, and cost-effectiveness but
the reporting does not provide sufficient details on the approach used for prioritisation and it is
not entirely clear how exactly costs are taken on board and how exactly the outcomes of the
cost-effectiveness analysis support the selection of measures.

The 3rd RBMPs report on the estimated funding of the PoMs identifying the sources of funding
and share of the funding secured by 2024 and 2027.

In the 3rd RBMPs, no quantitative gap assessment has been reported for 2021 and 2027
quantifying the necessary scale of additional action to achieve the WFD objectives. The lack
of a gap analysis to 2027 (though not mandatory) weakens the assessment of which
pressures will be addressed and how much progress is anticipated till 2027 in reducing
significant pressures.

Topic 10: Measures related to abstractions and water scarcity

Water abstraction (understood as consumptive use or net consumption) is not identified as a
significant pressure at the RBD level or in significant portions of an RBD for any RBD in

6 Poland subsequently clarified that methodology of the assessment and application of Article 4(4) and
4(5) exemptions will be available via electronic reporting and that Poland has developed a detailed
methodology for both types of exemptions with clear distinction between them.

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

Poland in the 3rd RBMPs. As the 3rd RBMPs e-reporting for Poland was pending at this
assessment’s cut-off date, there have been significant limitations in the available information
for the 3rd RBMPs, such as significant pressures affecting groundwater bodies in poor
quantitative status and surface water bodies in less than good ecological status/ potential.
Therefore, relevant information on pressures cannot be provided on the basis of 3rd RBMPs e-
reporting. In the 3rd RBMPs, 15 out of 174 groundwater bodies (i.e., 8.6% of total groundwater
bodies) have been in poor quantitative status by 2021. In the 2nd RBMPs, 13 out of 172
groundwater bodies (i.e., 7.6% of total groundwater bodies) were in poor quantitative status
by 2015. The groundwater bodies in poor quantitative status are located in the Oder RBD
(PL6000) and Vistula RBD (PL2000). In the 3rd RBMPs, water abstraction is mainly addressed
with supplementary measures, which are applied to individual water bodies, as identified from
the status assessment. Basic measures addressing water abstraction are limited in number
and scope. Measures related to control of abstractions (permitting and review of permits) were
implemented in the 2nd RBMPs and they are also planned for the 2021-2027 period. Measures
related to water efficiency were implemented in the 2nd RBMPs but they are not planned for
the 2021-2027 period. Relevant measures on defining and implementing e-flows are ongoing.
The 3rd RBMPs also include measures to increase water supply. Specifically, these measures
relate to natural water retention, rainwater harvesting, water reuse, water reservoirs and water
transfers. International cooperation on water abstraction / scarcity issues varies significantly
among the international RBDs. In some cases (e.g. Danube, Elbe), there is an established
international cooperation based on international agreements, coordination bodies, and
RBMPs addressing -inter alias- water abstraction / scarcity aspects. However, in other cases
(e.g. Oder), the established international cooperation focuses mostly on different issues than
water abstraction / scarcity, with the exception of some international research projects
reported in place. Relevant international cooperation is not reported in various cases (e.g.
Vistula or small RBDs with very low proportion out of the total international RBD).

In the Danube, international cooperation includes joint monitoring, planning and stakeholder
engagement. Consultation between involved national authorities and other stakeholders is
regular (e.g. discussions within international river commissions or bilaterally). Furthermore, the
international RBMP of the Danube includes hydrological, hydrogeological, and climate change
adaptation assessments, but without particular elaboration, specifically on water abstraction /
scarcity7.

In the Elbe, there is international cooperation on hydrological monitoring, information
exchange on national approaches and data sharing. Furthermore, the international RBMP of
the Elbe defines water scarcity related objectives at the international level and impacts of
climate change on water scarcity, but without particular elaboration specifically on water
abstraction.8

7 However, water scarcity is included -among others- in the Significant Water Management Issues and
water scarcity considerations are reflected in the ICPDR (International Commission for the Protection of
the Danube River) guidance document on sustainable agriculture, which promotes smart irrigation
techniques for water saving.

8 Due to water scarcity concerns in the Elbe, a joint hydrological evaluation was attempted, but it was
inconclusive due to monitoring gaps.

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

In the Oder, international cooperation specifically on water abstraction / scarcity is limited to
international projects focusing on sustainable water use under climate change9.

In the Vistula, international cooperation specifically on water abstraction / scarcity is not
reported.

Topic 11: Measures related to pollution from agriculture

There is no detailed description of the agricultural measures even though agriculture is a
major pressure on both surface waters and groundwaters in Poland. The RBMPs inform only
about the measures in very general terms. It means that the available information only
concerns the measures addressing nutrients and pesticides.

There is no description of gaps in terms of a need for the reduction of nutrients or pesticides
from agricultural diffuse pollution to achieve the WFD objectives. Accordingly, the expected
progress towards the objectives cannot be assessed.

Topic 12: Measures related to pollution from sectors other than agriculture

The RBMPs do not present data on the gaps in terms of how much pollution needs to be
reduced in order to achieve the WFD objectives. There are measures listed in the RBMPs
which are generally addressing wastewater and stormwater. They also address pollution from
wastewater from non-connected dwellings. There are no details on what these measures are
expected to achieve.

There is no information either about measures to address specific chemical pollutants apart
from mentioning measures on permits.

Overall, the level of information does not allow any assessment of the expected progress and
effect of the measures for pollution from other sectors than agriculture.

Topic 13: Measures related to hydromorphology

The RBMPs report that significant hydromorphological pressures are present in the RBDs and
measures have been identified to respond to these. KTM reporting is not available due to the
lack of electronic reporting.

The review of the PoM has identified examples of measures including fish ladders and other
measures related to longitudinal continuity, as well as habitat restoration, building spawning
and breeding areas. On the other hand, no measures are indicated regarding floodplain
restoration and improvement of lateral connectivity. Restoration of natural hydromorphological
processes in coastal areas is also planned.

9 NEYMO project (Lausitzer NEiße/NYsa Łużycka - Klimatische und hydrologische MOdellierung, 2012
- 2015): The project analysed recent (1971 - 2010) and future (up to 2100) climatic and hydrological
conditions in the Lausitzer Neiße region in order to enable sustainable management of water
resources.

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

There is no specific mention of periodical review and update of the permits related to
hydromorphological alteration, and it remains unclear if the implementation of e-flows is
included in the review of permits.

Topic 14: Economic analysis and water pricing policies

The Polish RBMPs recognise the broad water services public water supply and sanitation
services. Water uses have been identified as well.

With regards to the economic analysis, no clear information is provided on what has been
improved. References to forecasts of water supply and demand are made, but without
providing actual figures. Estimates of investments and future investment needs are missing.

A single price is charged for the joint provision of public water supply and sanitation services.
Other information on tariffs and water related charges appears scarce. The adequateness of
water pricing to provide incentives for a more efficient water use has not received an explicit
discission, but the available information on the WSS tariffs suggest some incentives, which
appear fully absent for agriculture.

Revenue and cost figures for public WSS are given as national totals for one year. Financial
cost recovery rates have also been calculated as national totals for public water supply,
industry, and agriculture.

Two cost recovery figures are presented: one considers only financial costs, the other one –
called “economic rate of return” also includes environmental costs. However, as further details
on methodology and calculations are missing, it is unclear how far the latter corresponds to
the broad cost recovery rate in the sense of the WFD.

Environmental costs are estimated based on the cost-based approach. The terminology used
is unclear and it remains somewhat uncertain whether a broad cost recovery rate in the sense
of the WFD has been calculated. There is no clear discussion regarding the adequate
contributions from different water uses to financial and environmental cost recovery, but the
agricultural sector is apparently allowed to not pay fees in a significant proportion. It is unclear
if these unpaid fees are legally allowed under certain conditions or not. With regards to the
PPP, only a general assurance of its application is provided in the RBMP.

Topic 15: Considerations specific to protected areas (identification, monitoring,
objectives and measures)

Poland has designated a range of protected areas including Drinking Water Protection Zones,
Bathing Waters, Natura 2000and shellfish protection areas, totalling over 9,000 designated
protected areas within the country. Poland uses a whole country approach to the identification
of nitrates vulnerable zones and sensitive areas.

Very little information is identified on protected areas, in the absence of electronic reporting,
no data on monitoring sites was identified apart for groundwater drinking water protected
areas in one of the RBD assessed in detail.

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

Additional objectives have been set for areas intended for drinking water abstraction however
they do not appear to be different from the main objectives of the WFD. For Natura 2000 sites,
the objective of reaching good condition was included which also does not appear to be
additional to the requirements of the legislation10.

Topic 16: Adaptation to drought and climate change

According to the in-depth review of the 2 largest RBMPs, climate change adaptation
measures (and proofing thereof) have been included in the Vistula RBMP and the Oder
RBMP, in a dedicated chapter. The national climate change adaptation strategy is integrated
into the RBMPs- which use models formulated in the national adaptation strategy to project
potential impacts of climate change on water bodies. No definition of water scarcity has been
proposed, but drought is defined in both RBMPs. Analysis on the impacts of drought upon
water management is limited, and operational measures to tackle drought and water scarcity
issues throughout the various phases of drought events have not been included in the
RBMPs. No Article 4(6) exemptions have been identified in the RBMPs. A Drought
Management Plan was prepared by the National Water Management Authority Polish Waters
under the supervision of the Ministry of Infrastructure and adopted with an Executive Order of
the Council of Ministers in July 2021. However, the plan lacks essential components of a
drought management plan. While it provides a high-level catalogue of measures and strives to
also provide guidelines on good agricultural practices, it apparently does not yet include
concrete operational, organisational or follow-up measures proper to drought event
management.11

10 Poland subsequently indicated that information on additional objectives is reported in the electronic
reporting which indicate additional objectives are set for other types of protected areas.  This
information was not available at the time of this assessment.

11 Report “Stock-taking analysis and outlook of drought policies, planning and management in EU
Member States”, section 9.2.22.

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

Recommendations

The main recommendations for Poland are as follows:

● Poland should adopt and publish its RBMPs in accordance with the WFD timetable.

● Poland should complete its electronic reporting on time.

● Poland should clarify how its RBMPs contribute to address the MSFD’s objectives12

and the overall coherence in the implementation of the WFD and MSFD.

● Poland should work to improve the understanding of pressures on transitional and

coastal water bodies as the RBMP states that these water bodies are mainly exposed
to pressures from unknown (and diffuse) sources.

● Poland should report monitoring sites for transitional and coastal waters in the RBMPs;

● Poland should clearly report which quality elements are monitored as part of

surveillance or operational monitoring in the RBMPs;

● Poland should ensure appropriate monitoring of benthic invertebrates or fish in lakes;

macrophytes or phytoplankton in rivers; fish, angiosperm, or macroalgae in transitional
waters; and angiosperm or macroalgae in coastal waters;

● Poland should clearly report in the RBMPs how the various surface water categories

are monitored for hydromorphology;

● Poland should ensure a comprehensive monitoring of physico-chemical quality

elements as in the 3rd RBMPs thermal conditions, oxygenation conditions are not
monitored in any of the surface water bodies; there is no monitoring of salinity in rivers,
transitional and coastal waters; there is no monitoring of acidification in lakes and
rivers; there is no monitoring of transparency in transitional and coastal waters;

● Poland should provide information on transboundary surface water body monitoring;

● Poland should clearly report any changes to the assessment methods of biological

quality elements in the RBMPs (if applicable);

● Poland should ensure that the selection of biological quality elements for the

operational monitoring programme to respond to different pressures covers all surface
water categories and impacts (in the 3rd RBMPs it does not cover all surface water
categories and only one type of impact, which is nutrient pollution in rivers and lakes);

12 The objectives stated are the following:

(a) protecting and preserving the marine environment, prevent its deterioration or, where practicable,
restore marine ecosystems in areas where they have been adversely affected;

(b) preventing and reducing emissions in the marine environment, with a view to phasing out
pollution…, so as to ensure that there are no significant impacts on or risks to marine biodiversity,
marine ecosystems, human health or legitimate uses of the sea (Article 1 of the MSFD (2008/56/EC)).

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

● Poland should provide information on the intercalibration of biological assessment

methods and national classification systems in the RBMP including any changes made
since the 3rd RBMPs;

● For the assessment methods of hydromorphological and physico-chemical quality

elements, Poland should report on the links between the assessment methodology,
established reference conditions and standards to class boundaries for sensitive
biological quality elements;

● Poland should provide information regarding how RBSPs have been identified,

whether all EQS for RBSPs are according to Technical Guidance Document No. 27,
and whether the ecological status of surface water bodies have been downgraded due
to an exceedance of EQS of RBSPs in the RBMPs.

● Poland should make it clear whether grouping has been applied to the classification of

ecological status / potential in the RBMPs.

● Poland should report information on the confidence of ecological status/ potential

classification in the RBMPs;

● Poland should provide information on the application of the one-out, all-out principle for

the classification of ecological status / potential in the RBMPs.

● Poland should take steps to reduce the number of surface water bodies in unknown

chemical status in the next RBMPs.

● Poland should provide information on trends or trend analysis for chemicals.

● Poland should consider GWAAEs in the assessment of quantitative status.

● Poland should coordinate threshold values with neighbouring countries.

● Poland should present in the RBMPs the thresholds for the substantial change in
character, assessment of significant adverse effects of restoration measures and
identification, and assessment of better environmental options at the water body level.

● Poland needs to complete the definition and implementation of e-flows, also in

cooperation with neighbouring countries.

● Poland should explicitly link the authorisation process and / or review of permits to

control water abstractions and impoundments to the implementation of e-flows, also
considering the increasing water abstraction trends in certain sectors and further
impacts from climate change.

● Poland should become more proactive in addressing the impacts of climate and socio-
economic change on water resource availability and hydrologic extremes. Poland may
need to improve data collection on all water uses, and especially consumptive water
uses, as well as their trends. This includes extending water metering and improving
national water statistics and reporting to WISE SoE Water Quantity.

● Poland should develop sub-plans on Water Scarcity and Droughts which are fully

coordinated with the RBMPs and the climate change adaptation plans already in place.

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

● Poland should clearly report on the definition and criteria applied for defining “technical

feasibility” (Article 4(4)/”infeasibility” (Article 4(5) and “disproportionate costs”13.

● Poland should report measures mapped to the KTMs and show a clear link between

significant pressures and KTMs for priority substances and groundwater pollutants.

● Poland should provide more information on how it has prioritised measures including

through the use of cost-effectiveness analysis.

● Poland should report quantitative gap indicators for all significant pressures to enable
the understanding of the necessary scale of additional action to achieve the WFD
objectives.

● Poland should complete a comprehensive gap assessment for diffuse pollutant loads
from agriculture (nutrients, agri-chemicals, sediment, organic matter) across all waters
in all RBDs and describe how the proposed measures will help to close the gaps and
thereby achieving the WFD objectives.

● Poland should complete a comprehensive gap assessment for pollution from sectors
other than agriculture across all waters in all RBDs and describe how the proposed
measures will help to close the gaps and thereby achieving the WFD objectives.

● Poland should describe how the proposed measures address identified priority

substances and River Basin Specific Pollutants cause failure of the WFD objectives.

● Poland should provide an account of the items included in Annex III of the WFD, in

particular long term water scenarios and investment forecasts.

● Poland should provide a more transparent account of water tariff structure and rates,
as well as on whether, and how, existing pricing arrangements provide an adequate
incentive for a more efficient water use.

● Poland should justify all uses of the “established practice” exemption to cost recovery
(using Article 9(4)), as well as explain the mitigation factors to cost recovery (as listed
in Article 9(1)) underlying the low-cost recovery rate for some water user sectors.

● Poland should provide a more transparent account of water user sectors’ contribution
to financial and environmental cost recovery, as well as on the application of the
polluter-pays principle.

● Poland should provide information on objectives for drinking water protection areas

and for Natura 2000.

● Poland should provide further information on additional objectives for shellfish

protected areas.

● Poland should provide information on operational measures to tackle drought and

water scarcity issues throughout the various phases of drought events in their drought
management plan.

● Poland should consistently include climate change adaptation measures which relate

to the preservation of water bodies in all RBMPs.

13 Poland subsequently clarified that methodology of the assessment and application of Article 4(4) and
4(5) exemptions will be available via electronic reporting and that Poland has developed a detailed
methodology for both types of exemptions with clear distinguish between them.

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Assessment of the third River Basin Management Plans under the Water Framework Directive
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● Poland should consider using the outputs of climate models formulated for the national

climate change adaptation strategy that project climate change impacts on water
bodies for informing climate proofing of planned measures.

● Poland should avoid including climate change maladaptation measures (such as lake

reclamation) in the PoMs.

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

1.  Governance and public participation

1.1.  Assessment of implementation and compliance with

WFD requirements

1.1.1.  Administrative arrangements – river basin districts

Poland has nine RBDs, all of them international. The longest Polish rivers are the Vistula and
Oder; their combined RBDs cover almost 97% of the country.

Poland has prepared nine RBMPs. Poland completed the submission of its RBMP documents
for the 3rd RBMPs to the Commission on 16 March 2023. Poland has not completed the 3rd
RBMP e-reporting. Therefore, Poland did not adopt and publish the 3rd RBMPs in accordance
with the timetable stipulated in the Water Framework Directive14.

14 Section 10.2 of the Oder RBMP provides a summary of the reasons for delays in implementing the
activities outlined in the second cycle of RBMPs, which are as below. However, the link to further
delays in adopting the third cycle are not explicit.

‘The actions outlined in the PWŚK (Update of the Water Management System Implementation
Programme) were implemented to varying degrees. Initiatives were commenced or continued across all
key activities, especially in the field of municipal management in urban agglomerations, in connection
with the implementation of the KPOŚK (National Programme for Municipal Wastewater Treatment). The
introduced legislative changes aimed to fully implement EU regulations, particularly the WFD. The
consolidation of responsibilities under one authority (the PGW WP: Regional Water Management
Boards) allowed for more effective monitoring of action implementation while ensuring the verification of
their validity. The legislative changes constituted a comprehensive alteration of legal regulations,
shifting the competencies of authorities responsible for water management, including those overseeing
the review of water permits. Moreover, these legislative changes invalidated the justification for further
actions involving the development of water use conditions. Consequently, the modifications made it
impossible to fully realize the planned activities outlined in the aPGW.

According to the findings of the progress assessment report, the main obstacles reported by entities in
action implementation were the lack of funding assurance and implementation mechanisms. Among
other obstacles cited were staffing shortages, a lack of awareness regarding the need for action
implementation, infrastructural barriers, issues with procurement procedures, and administrative
changes. Detailed information regarding individual actions is included in the progress assessment
report as well as the effectiveness assessment of actions from the PWŚK category of municipal
management.’

The RBMP also concludes with the following: ‘To ensure comprehensive information about the status of
actions being implemented under the IIaPGW (3rd RBMP), it is essential to effectively inform the entities
responsible for action implementation about the planned activities within the framework of the IIaPGW,
along with effective enforcement of reporting requirements on implementation progress.’

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

1.1.2.  Administrative arrangements – competent authorities

Poland has a broad range of Competent Authorities at different tier levels, a number of which
have roles in enforcement of regulations and implementation of measures. The following
national ministries are identified:

● The Ministry of Environment has main roles in enforcement of regulations,

implementation of measures and coordination of implementation;

● The Ministry of Agriculture and Rural Development and the Ministry of Maritime

Economy and Inland Navigation have main roles in enforcement of regulations and
implementation of measures;

● The Ministry of Development has a main role in the enforcement of regulations.

National environmental and health authorities are identified as Competent Authorities:

● The General Director for Environmental Protection has main roles in enforcement of

regulations and the implementation of measures.

● The Chief Inspector of Environmental Protection has main roles in monitoring and

assessment of status of groundwater and surface water, along with the enforcement of
regulations and the implementation of measures.

● The Chief Sanitary Inspectorate has main roles in enforcement of regulations and the

implementation of measures.

Authorities for water management and maritime issues are identified:

● The National Water Management Authority15 has main roles in enforcement of

regulations, pressure and impact analysis, economic analysis, preparation of the
RBMPs and PoM, public participation, implementation of measures, coordination of
implementation and reporting to the European Commission.  Since January 1st 2018,
the National Water Management Authority also implements the tasks of the former
Directors of Amelioration and Water Structures Authorities, which were abolished due
to changes in the Water Law Act. Those institutions had main roles in enforcement of
regulations and implementation of measures.

● The Directors of the Regional Water Management Boards16 (11 in total) each have
main roles in enforcement of regulations, pressure and impact analysis, economic
analysis, public participation and implementation of measures. Many RBD areas are
managed by multiple Regional Water Management Boards, depending on the location
(e.g. Bialystok: Vistula RB, Pregola RB and Nemunas RB). For example, the Vistula

15 Polskie Gospodarstwo Wodne Wody Polskie (PGW WP)

16 Regionalny Zarząd Gospodarki Wodnej in Poland (RZGW – organizational unit of the State Water
Holding Polish Water).

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

River Basin is within the jurisdiction of 7 different boards, while the Oder River Basin is
managed by 5 boards17.

● The Directors of Inland Waters Navigation Offices (eight are listed) have main roles in

enforcement of regulations.

● The Directors of Maritime Offices (two are listed, linked to 3 RBDs that have the

transitional and coastal waters18) have main roles in enforcement of regulations and in
implementation of measures (except for the Director of the Maritime Office in Slupsk,
who does not have a main role in the enforcement of regulations).

Competent Authorities at regional level are identified:

● The Marshals of the Voivodships, the Voivodes, and the Governors of the districts all
have main roles in enforcement of regulations and implementation of measures.

● The Voivodship Inspectorates for Environment Protection and Voivodship Sanitary

Inspectorates have main roles in enforcement of regulations and the implementation of
measures.

Finally, the municipalities also have main roles in the implementation of measures.

1.1.3.  RBMPs – structure and Strategic Environmental

Assessment

Poland's RBMPs do not have sub-plans.

Poland carried out Strategic Environmental Assessments for all of its RBMPs19.

1.1.4.  Coordination with the Floods Directive

The Oder and Vistula RBMPs refer to the Floods Directive (FD)20 and take into account
instruments supporting the updating of the Flood Risk Management Plans (FRMPs) in the
PoM. For instance, the Oder RBMP refers to a task used that is “ensuring protection and
increase of natural retention and restoration of natural flow conditions” with regards to

17  List of other RBDs and their links with the relevant boards: Jarft – PGW WP Gdansk; Nemunas –
PGW WP Bialystok; Danube – PGW WP Krakow, PGW WP Gliwice; Świeża – PGW WP Gdansk; Elbe
– PGW WP Wroclaw; Pregoła – PGW WP Bialystok; Dniester – PGW WP Rzeszow

18 The Directors of Maritime Offices are relevant to the below RBDs: Jarft – Maritime Office in Gdynia;
Oder – Maritime Office in Gdynia and Maritime Office in Szczecin; Vistula – Maritime Office in Gdynia.
There used to be three maritime offices, but the Maritime Office in Slupsk has been abolished in 2020.
Its territorial scope was divided between the other two Maritime Offices: in Gdynia and in Szczecin.

19 Sources: Vistula RBMP p.402-404 ; Oder RBMP p.400 ; Pregoła RBMP p.264

20 Directive 2007/60/EC on the assessment and management of flood risks entered into force on 26
November 2007 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32007L0060

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

establishing the PoM21. In the Vistula RBMP, coordination with the FD appears in the following
sections22:

Improvement of the hydromorphological conditions of rivers and streams (Hydromorphological
Pressures_03: Actions aimed at protecting and restoring natural hydromorphological
processes in the riverbed to meet environmental objectives of protected areas regarding the
maintenance of the natural character of the channel.)

Climate change adaptation (Cumulative Pressures_01: Actions aimed at climate change
adaptation and improving conditions for protected areas, with the goal of developing and
implementing initiatives aimed at improving retention in forested and agricultural areas.)

Chemical Pressures_06: Actions focused on water management control and reviews of water
permits.

Poland carried out joint consultations with the Flood Risk Management Plans under the
Floods Directive.

The Oder international RBMP’s (called “Water Management Plan for the International Odra
River Basin”) main focus is water quality/pollution control, more than flood risk protection
(more details about the scope of the Oder international cooperation can be found in the next
section). However, it refers to the FD directly in regard to the scope of activities relevant to
one implementation body (International Commission for the Protection of the Odra River
against Pollution). The following is stated in the Water Management Plan for the International
Odra River Basin:

‘In parallel with the implementation of the Framework Water Directive, the International
Commission for the Oder (ICPO) is also involved in the implementation of the European
Floods Directive (2007/60/EC). As part of these efforts, in 2018, an update of the preliminary
flood risk assessment for the international Oder RBD was conducted at the ICPO level, and in
2019, an update of the flood hazard and risk maps for areas with significant flood risk was
prepared. Based on this, a project for the update of the flood risk management plan for the
international Oder RBD was developed in 2021.’

Additionally, one of the supplementary actions listed in this document is ‘The reconstruction
and reclamation of wetland areas’ which also contributes to flood risk prevention.

The Danube international RBMP describes the connection between the internation RBMP and
the Danube international Floods Risk Management Plan, which has been updated in 202123.

21 Oder RBMP, p.251-252; p.256 : “The catalogues of measures take into account the European
Commission's recommendations and comments for 2nd RBMP, including: Report from the Commission
to the European Parliament and the Council on the implementation of the Water Framework Directive
and the Floods Directive, the 2nd RBMP, the 1st FRMPs and their annexes”

22 Vistula RBMP, Chapter 12

23 Danube international RBMP, p.278

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

1.1.5.  Coordination with the Marine Strategy Framework

Directive

The Oder and Vistula RBMPs mention the National Marine Water Management Plan, which is
the plan at the national scale for the implementation of the Marine Strategy Framework
Directive (MSFD)24. However, no explicit link is made between this plan and the objectives or
measures of the RBMPs.

Joint consultations have not been carried out for the MSFD25.

1.1.6.  International coordination and cooperation

All nine of Poland's RBDs are part of international RBDs. This includes Poland's sections of
the Danube, Elbe and Oder RBDs: for these three international RBDs, an international
agreement, permanent cooperation body and international RBMP are in place (designated as
category 1 cooperation). The cooperation on the Oder international RBD is carried under the
International Commission for the Oder (ICPO). On the Danube international RBD, the
cooperation takes place under the International Commission for the Protection of the Danube
River (ICPDR). On the Elbe international RBD, the cooperation takes place under the
International Commission for the Protection of the Elbe River (ICPER), however Poland is not
a member of this commission, but does  hold an observer status26.

There has not been an international RBMP and PoM prepared for the Vistula RBD, (90% of
which is located on Poland’s territory). The Vistula international RBD is designated as
category 3 cooperation. The cooperation with Slovakia on the Vistula RBD takes place under
the framework of the bilateral commission (detailed in the tables below). In addition, Poland
has signed a range of bilateral agreements with neighbouring non-Member States. These
include the following27:

  Poland-Belarus: Agreement between the Government of the Republic of Poland and

the Government of the Republic of Belarus on cooperation in the field of protection and
rational use of transboundary waters, signed in Białowieża on February 7, 2020
(Journal of Laws of 2021, item 119). The RBMP stipulates this agreement was signed
after nearly 20 years of negotiation work.

24 Oder RBMP, p.385; Vistula RBMP, p.389

25 Directive 2008/56/EC of the European Parliament and of the Council of 17 June 2008 establishing a
framework for community action in the field of marine environmental policy (Marine Strategy Framework
Directive) http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008L0056

26 Elbe RBMP, Section 22, p 257: ‘The Republic of Poland and the Republic of Austria are not members
of the Elbe Commission; however, they hold observer status.’

27 According to the Vistula RBMP and the 2012 Pressures & Measures study available at:
http://ec.europa.eu/environment/archives/water/implrep2007/pdf/Governance-
Transboundary%20Fact%20Sheets.pdf)

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

Other agreements with Belarus that were described in the 2nd RBMP28 are no longer
mentioned in the 3rd Vistula RBMP, such as:

Poland-Former Union of Soviet Socialist Republics (USSR): Agreement between the
Government of the Polish People’s Republic and the Government of the Union of Soviet
Socialist Republics Concerning the Use of Water Resources in Frontier Waters, 1964. This
agreement does not apply anymore in the cooperation between Poland and Belarus, due to
the Agreement from 2020 mentioned above.

However, the agreement from 1964 still applies for the cooperation of Poland with the Russian
Federation, however it is not actively implemented.

The cooperation agreement with the Kaliningrad region mentioned in the 2nd RBMP is no
longer mentioned in the 3rd Vistula RBMP29. Cooperation with the Russian Federation on
water management was carried out under the 1964 agreement between Poland and the
USSR; however, joint activities are currently suspended.

The Vistula RBMP states that, currently, the cooperation with the Russian side in the field of
transboundary waters requires re-formalisation, the establishment of a new legal framework
and cooperation bodies. Since 1992, talks have been held on agreeing on a new
intergovernmental agreement, but unfortunately the negotiations failed and as a result were
suspended due to the Russian side's refusal to include the sea border waters in the
agreement30.

Poland-Ukraine: Agreement between the Government of Ukraine and the Government of
Poland on Cooperation in the Field of Water Management in Frontier Waters, 1996 (a
Ukrainian-Polish Commission works under this Agreement).

Poland and Ukraine have set up the following working groups covering:

● Planning on transboundary waters;

● Protection of border waters against pollution;

● Flood control regulation and drainage; combating extraordinary pollution, and;

● Hydrometeorology and hydrogeology.

In addition, two regional cooperation agreements have been signed with Ukraine during the
2nd RBMPs:

28 Namely: Agreement on Cooperation between the Hydrometeorology Department of the Ministry of
Natural Resources and Environmental Protection of the Republic of Belarus and the Institute of
Hydrometeorology and Water Resources of Poland, 2003; Agreement between the Government of the
Republic of Poland the Government of the Republic of Belarus on cooperation in the field of
environmental protection, 2009

29 Agreement on cooperation in the north-eastern provinces of the Republic of Poland and Kaliningrad
oblast (region) of the Russian federation (only relating to environmental protection and monitoring of
transboundary coastal waters), 1992.

30 Vistula RBMP, p.416

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

● On 14 August 2019, a cooperation agreement was signed between the Regional

Water Resources Authority of the Bug and San rivers in Lviv and the Regional Water
Management Board in Lublin;

●  On 19 February 2021, a cooperation agreement was signed between the Regional

Water Management Board in Rzeszów and the Regional Water Resources Authority of
the Bug and San River of the Republic of Ukraine.

The main objectives of cooperation are the exchange of data and information in the field of
water resources management, assessment of the water environment and the need to
coordinate the implementation of the provisions of the WFD and the European Union Floods
Directive31.

The Vistula RBMP also mentions the implementation of obligations arising from:

● (1) The Convention on Wetlands of International Importance, especially as a habitat for
waterfowl, drawn up in Ramsar on February 2, 1971 (Journal of Laws of 1978, items
24 and 25);

● (2) The Convention on the protection and use of transboundary watercourses and

international lakes, drawn up in Helsinki on 17 March 1992 (Journal of Laws of 2003,
items 702 and 703);

● (3) Agreements for the Conservation of Small Cetaceans of the Baltic, North-East
Atlantic, Irish and North Seas, done at New York on 17 March 1992. [ASCOBANS]
(Journal of Laws of 1999, items 1108 and 1109).

An elaborate summary of international cooperation is provided in section 22 of both the Oder
and Vistula RBMPs32.

The scope of the agreements signed by Poland on its international RBDs is detailed in the
tables below:

31 Vistula RBMP, p.416

32 Oder RBMP, Vistula RBMP, Section 22 3International Cooperation”

Oder RBMP, p. 413/414: ‘As part of fulfilling the obligations arising from the WFD, the task of the ICPO
is to create a coordinated Water Management Plan for the International Odra River Basin Area. In the
2nd RBMPs implementing the Water Management Plan for the International Odra River Basin Area, the
ICPO participated in the process of delineating uniform bodies of water, in accordance with the
methodology applicable in individual countries and international agreements concerning the uniform
characteristics of water bodies (boundaries, categories, status assessment, setting objectives to be
achieved). Significant progress has been made, particularly regarding the localization and designation
of WFD as artificial and heavily modified water bodies, as well as the assessment of their status.’

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

Table 1.1    International agreements and joint bodies in place on international RBDs

Convention
on the
International
Commission
for the
Protection of
the Oder
against
Pollution

Agreement
between the
Government of
Slovakia and the
Government of
Poland on the
management of
transboundary
Waters

Agreement
between the
Government of
Ukraine and the
Government of
Poland on
cooperation in
the field of water
management in
frontier waters33

Date of
signature of the
agreement

April 11th
1996

1997

October 10th1996

 Member States
sharing the
IRBD

Czechia,
Germany,
Poland

Poland, Slovakia

Poland

The Helsinki
Convention
(cooperation for
the protection of
the marine
environment of
the Baltic Sea34

Originally 1974,
updated in 1992.
Last amendment
on July 1st 2014

Denmark, Estonia,
Finland, Germany,
Latvia,
Lithuania, Poland,
Sweden,

Non-EU States
sharing the
IRBD

-

Belarus, Ukraine
and Russia

Ukraine, Belarus,
Russia

Russia

33 The Vistula RBMP mentions that temporary agreements were also signed recently (respectively on
August 14th 2019 and February 19th 2021) on the Bug and San rivers (Vistula tributaries) between the
regional water authorities of Poland and Ukraine as the expression of their will for mutual cooperation,
in order to enhance the implementation of the tasks and activities carried out in the border region. Thus,
neither of those agreements (on Bug and San rivers) is signed on the national level.

Both those river agreements were signed for the period of three years, and both already expired
(agreement for Bug river expired on August 11th 2022; agreement for San expired on February 19th
2024). None of the signatory local entities ever proceed the extending of the agreement effectiveness.

Furthermore, neither of those agreements underwent the procedures of the concluding and
implementing international agreements, in accordance with the Polish legal order. Under Polish law, it
does not constitute an international agreement.

The decision on the conclusion and implementation of the above agreements was issued by the
President of the National Authority for Water Management (State Water Holding Polish Waters). The
role of the minister responsible for water management of the Republic of Poland was to provide the
opinions on their drafts in terms of compliance with the agreement between the governments of Poland
and Ukraine (of October 10, 1996).

34 https://helcom.fi/about-us/convention/

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

Convention
on the
International
Commission
for the
Protection of
the Oder
against
Pollution

International
Commission
for the
Protection of
the Oder
(ICPO)

Agreement
between the
Government of
Slovakia and the
Government of
Poland on the
management of
transboundary
Waters

Agreement
between the
Government of
Ukraine and the
Government of
Poland on
cooperation in
the field of water
management in
frontier waters33

The Helsinki
Convention
(cooperation for
the protection of
the marine
environment of
the Baltic Sea34

Polish-Slovakian
Transboundary
Waters Commission

Ukrainian-Polish
Commission

Helsinki
commission

Yes

Yes

No information

No information

Yes

Yes

No information

No information

Joint body (JB)
in place under
agreement

Agreement
addresses
cooperation on
WFD

Agreement
addresses
cooperation on
FD

Work
Group(s)/Expert
Group(s)/Task
Group(s) in
place under
agreement

Flood
protection,
accidental
pollution,
legal issues,
monitoring
and data
management

-Flood control,
regulation of border
watercourses,
water supply, land
rehabilitation,
planning and
hydrogeology;
-Hydrology and
flood protection in
border waters; 
-Protection of
border waters
against pollution,
and; 
-Implementation of
tasks under the
WFD.

-Planning on
transboundary
waters; 
-Protection of
border waters
against pollution; 
-Flood control
regulation and
drainage; 
combating
extraordinary
pollution; 
-
Hydrometeorology
and hydrogeology.

No information

Do the
WGs/EGs/TGs
meet on a
regular basis?

Yes

Yes

No information

No information

Source: extracted from RBMP documents for the 3rd RBMPs

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

Table 1.2    Key cooperation activities addressed by the agreements in international
RBDs

Convention
on the
International
Commission
for the
Protection
of the Oder
against
Pollution

Agreement
between the
Government
of Slovakia
and the
Government
of Poland on
the
management
of
transboundary
waters

Agreement
between the
Government of
Ukraine and the
Government of
Poland on
cooperation in
the field of water
management in
frontier waters

Cooperation
for the
protection
of the
marine
environment
of the Baltic
Sea

Yes

Yes

Yes

Yes

Yes

Key Cooperation
Activities

(1) Joint SWMIs

(2) Joint visions
and management
objectives

(3)
Characterisation
(e.g.,
intercalibration)

(4) Joint
monitoring
(surface waters
and/or
groundwater)

(5)
Hydromorphology

Yes

(6) HMWB
designation (e.g.,
joint approach)

(7) Exemptions
(e.g., joint
approach)

(8) Water
abstraction / Water
scarcity (e.g., joint
approach)

Yes

Yes

Yes

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Assessment of the third River Basin Management Plans under the Water Framework Directive
Poland

Convention
on the
International
Commission
for the
Protection
of the Oder
against
Pollution

Agreement
between the
Government
of Slovakia
and the
Government
of Poland on
the
management
of
transboundary
waters

Agreement
between the
Government of
Ukraine and the
Government of
Poland on
cooperation in
the field of water
management in
frontier waters

Cooperation
for the
protection
of the
marine
environment
of the Baltic
Sea

Yes

Yes

Yes

Yes

Yes (action
plan35)

Yes

Yes

Yes

Key Cooperation
Activities

(9) Pollution
(pressures /
measures
assessment point
source pollution
and/or diffuse
source pollution)

(10) Joint PoM

(11) Economic
analysis / water
pricing

(12) Climate
change

(13) Protected
Areas inventory

(14) Coordinated /
shared databases
and / or GIS

(15) Joint financial
resources

(16) Joint
communication
strategy and public
participation
activities

35 https://helcom.fi/wp-content/uploads/2021/10/Baltic-Sea-Action-Plan-2021-update.pdf

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Assessment of the third River Basin Management Plans under the Water Framework Directive
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Convention
on the
International
Commission
for the
Protection
of the Oder
against
Pollution

Agreement
between the
Government
of Slovakia
and the
Government
of Poland on
the
management
of
transboundary
waters

Agreement
between the
Government of
Ukraine and the
Government of
Poland on
cooperation in
the field of water
management in
frontier waters

Cooperation
for the
protection
of the
marine
environment
of the Baltic
Sea

Yes (joint
projects,
experience
exchange)

Yes

Yes

Yes

Source: extracted from RBMP documents for the 3rd RBMPs

Key Cooperation
Activities

(17) Future water
demand (e.g., joint
approach)

(18) Joint
management of
navigation

(19) Other
cooperation
activities

(20) Cooperation
activities regarding
flood risk
management

The 3rd Oder international RBMP can be downloaded from the Oder Commission website36.

The 3rd Danube international RBMP can be downloaded from the ICPDR website37.

1.1.7.  Public consultation

The work programme, timetable, consultation plan, significant water management issues, and
the draft RBMPs were submitted to a public consultation for six months, in accordance with
Article 14 of the WFD.

The public participation process of RBMPs was centralised, thus the same dates apply to all
RBMPs (14/04/2021 to 14/10/2021). Comments could be sent via an online form, email, mail
to the Ministry of Infrastructure, or directly at the headquarters of the Ministry of Infrastructure

36 https://mkoo.pl/index.php?mid=40&aid=908&lang=PL

37 https://www.icpdr.org/sites/default/files/nodes/documents/drbmp_update_2021_final_lores.pdf

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Assessment of the third River Basin Management Plans under the Water Framework Directive
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in Warsaw. The procedure is explained on the website of the Ministry of Infrastructure, and the
treatment of personal data is detailed38.

The website of the National Water Management Board indicates that during this time, a total
of 1,529 comments were submitted. The National Water Management Board states that out of
the 1529 collected comments, 344 were taken into account. For the 105 remaining comments,
an explanation was given for the reasons why they were not taken into account.

During the period of public consultations, 15 online consultation meetings were organised in
the following cities: Szczecin, Warsaw, Łódź, Kielce, Olsztyn, Gdańsk, Białystok, Lublin,
Rzeszów, Kraków, Gliwice, Wrocław, Bydgoszcz, Poznań and Zielona Góra. On November
17-18, 2021, an online conference was organised to summarise the update in the preparation
of the RBMPs and the FRMPs39.

The results of the consultation are gathered in a specific report called “Report on Public
Consultation for the 2nd update of the RBMPs”. This report includes a summary of the
comments received and the responses provided to them for each of the RBDs40.

The content of the draft RBMPs followed the same outline as the final RBMP.

The Oder and Vistula RBMPs both mention that as a result of the comments submitted during
consultation, editorial corrections were made to the content of the RBMP, supplementing
Annex 3 with a clarification regarding the limit values of ecological potential in terms of
physicochemical indicators and verification of sets of measures. The Oder RBMP states that
82 measures were removed, 62 measures added and 37 were modified41. The Vistula RBMP
reports removing 214 measures, adding 219 measures, and modifying two42. The changes in
the Vistula RBMP also concern the listing of protected areas; some protected areas had not
been identified at the draft stage (e.g. protected areas for aquatic species). Lastly, changes
have been made in the PoM of the Vistula RBMP: in the draft Vistula RBMP, a large part of
the measures were research and development projects (18.5% of the measures of the PoM)
or organisational, legal, information and educational activities (22.2%), while in the final
version these types of measures represent respectively 2.3% and 5.2% of the total amount of
measures. In parallel, measures on hydromorphology, measures targeting municipal utilities
and industries have significantly increased between the draft and final version of the Vistula
RBMP (from 1.6% to 11.6% for measures shaping natural hydromorphological conditions; 
from 10.1% to 20.3% for measures targeting municipalities and from 9% to 25.6% for
measures targeting industries). A new category of measures has also been added in the final

38 https://www.gov.pl/web/infrastruktura/konsultacje-spoleczne-projektow-drugiej-aktualizacji-planow-

gospodarowania-wodami-na-obszarach-dorzeczy

39 Source: https://www.apgw.gov.pl/pl/news/show/480

40 This report is available online: https://www.gov.pl/web/infrastruktura/projekty-ii-aktualizacji-planow-
gospodarowania-wodami-na-obszarach-dorzeczy---raport-z-konsultacji-spolecznych

41 Oder RBMP, p.400

42 Vistula RBMP, p.402

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Assessment of the third River Basin Management Plans under the Water Framework Directive
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version of the Vistula RBMP: protection of habitats and species (11% of the total amount of
measures)43.

In the Oder RBD, the main participants in the consultation were the Chief Inspector of
Environmental Protection, a scientific institute, 13 business entities, seven representatives of
communes, municipal offices and starosties, two provincial offices, 10 associations, and 13
NGOs.

In the Vistula RBD, the main participants in the consultation were the Chief Inspector of
Environmental Protection, Regional Directorates for Environmental Protection, three scientific
institutes, 18 business entities, eight communes, 12 voivodeship (province) offices and
marshals, 16 associations, and 15 NGOs.

The features of the consultation process indicate a sufficient level of transparency.

Tables summarizing the types of stakeholders involved and the mechanisms for stakeholder
involvement for each RBD could not be generated due to the absence of e-reporting.

1.2.  Main changes in implementation and progress with

recommendations

Poland published nine RBMPs for the 3rd cycle, whereas 10 RBMPs were published for the 2nd
cycle. This is due to the new division specified in the updated Water Law from 201744. This
change is described in both the Oder and Vistula RBMPs45.

International cooperation is progressing, specifically with non-EU countries, with a new
agreement signed in 2020 with Belarus in the field of “protection and rational use of
transboundary waters, and two new agreements with the Lviv regional authority (Ukraine) on
Vistula’s tributaries.

The Commission recommendations based on the 2nd RBMPs analysis were:

43 Comparison of Figure 12-1 in the draft and final Vistula RBMP.

44 “The update of water management plans in river basin areas, implemented within the current cycle,
should take place by December 22, 2021. Draft plans are being developed for 9 river basin areas, i.e.
Vistula, Oder, Dniester, Danube, Banówka, Elbe, Niemen, Pregoła and Świeża, in accordance with the
division specified in the Act of July 20, 2017” - Water Law

45 Vistula RBMP, Chapter 23: “Change in river basin areas – water management plans were developed
for 9 river basin areas, instead of the previous 10. In the case of the Vistula River basin area, there was
also a change in the water regions of the basin area. As a result of dividing the Upper Vistula water
region into the Upper-Western Vistula water region and the Upper-Eastern Vistula water region, and
dividing the Middle Vistula water region into the Middle Vistula, Narew, and Bug water regions, the
Vistula River basin area (RBD) covers 7 water regions.”

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● Recommendation: Poland needs to ensure that the preparation of the next cycle of

RBMPs is carried out in accordance with the WFD timetable, to ensure the 3rd RBMPs
are adopted on time.

● Assessment: Poland did not adopt and publish its RBMPs in accordance with the
WFD timetable46. Furthermore, at this assessment’s cut-off date, the electronic
reporting was not completed47.

● Recommendation: Clear information should be included in national RBMPs on

international coordination efforts.

● Assessment: The RBMPs assessed (Oder and Vistula) contain clear information
about international cooperation, including on the coastal and marine aspects. The
scope of the different international commissions is described, as well as the bilateral
cooperation with the neighbouring countries48.

● Recommendation: Poland should continue to improve international cooperation,
including coordinated assessments of the technical aspects of the WFD such as
ensuring a harmonised approach for status assessment and a coordinated PoM in
order to ensure the timely achievement of the WFD objectives.

● Assessment: The bilateral commission with Slovakia has working groups on

characteristics of water bodies (e.g. typology, status assessment, identification of
HMWBs); joint monitoring is carried out, along with data exchange and harmonisation,
and there is coordination of measures. On the Oder IRDB, the ICPO participated in the
process of delineating uniform water bodies, following the methodology applicable in
individual countries and international agreements concerning uniform characteristics of
Surface Water Bodies (boundaries, categories, status assessment, setting objectives).
Significant progress has been made, particularly regarding the delineation and
designation of surface water bodies as artificial and heavily modified water bodies, as
well as the status assessment.

A new agreement has also been signed in 2020 with Belarus in the field of “protection and
rational use of transboundary waters”. Cooperation with Russia is on hold.

46 Poland has informed subsequently that the delay was due to unforeseen circumstances during the
elaboration of the 3rd RBMPs: due to the prolonged and complicated procurement procedure, which
was influenced by e.g. tightened sanitary regime caused by the COVID-19 pandemic, the start of work
on the 3rd RBMPs has been delayed. In addition, the procedure of one of the project stages was
extended, which was also not dependent on National Water Management Authority, and affected the
deadline of next stages completion. Therefore, Poland could not adopt and publish the 3rd RBMPs in
accordance with the WFD timetable.

47 Poland has subsequently informed subsequently that Poland kept the EC informed about delays in
reporting and their causes - by e-mail and by letter. Detailed explanations for the reporting were given
by letter dated April 24, 2023, which was forwarded to Mr. Virginijus Sinkevičius member of the EC.
Representatives of Poland also participated in meetings of the Data and Information Sharing Working
Group (WG DIS)

48 Oder RBMP, p.413

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1.3.  Conclusion on gaps in implementation

Poland did not adopt and publish its RBMPs in accordance with the WFD timetable.
Furthermore, the 3rd RBMP e-reporting was not completed.

Coordination with the MSFD is not ensured: the RBMPs assessed mention the National
Marine Water Management Plan, however no explicit link is made between this plan and the
objectives or measures of the RBMPs49.

49 Poland subsequently indicated that the lack of connection between the 3rd RBMPs and update of the
Marine Waters Protection Programme (the 2nd MWPP) is due to the fact that, in March 2024, the
procedure for adopting the 2nd MWPP by way of a regulation of the Council of Ministers is still ongoing
(draft measures under the 2nd MWPP were still under discussion when the 3rd RBMPs were drafted).
Thus, cross-references between those two documents were not included in the 3rd RBMPs.
Nevertheless, coordination between MSFD and RBMPs was ensured on the operational level i.e. by
having a single unit coordinate the making of documents regarding both Directives.

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2.  Characterisation of the River Basin District

2.1.   Assessment of implementation and compliance with

WFD requirements

2.1.1.  Delineation of water bodies and designation of heavily

modified and artificial water bodies

The numbers of the different types of surface water bodies are shown in Table 2.1. There has
been an overall decrease in the number of river water bodies from 4,586 to 3,161 (31%
decrease) in eight out of nine RBDs. The number of transitional water bodies has decreased
from 9 to 7 (22% decrease). The number of coastal water bodies has decreased from 10 to 4
(60% decrease). The increase in the number of lake water bodies, namely from 1,044 to 1,068
(2% increase), is attributable to three RBDs. The changes are a result of the verification and
update of water body area catchment boundaries. Poland has not reported any territorial
water bodies.

The numbers of groundwater bodies are shown in Table 2.2. There is an overall increase of
two groundwater bodies from 172 to 174 (1.2% increase). The two new groundwater bodies
are located in the Świeża RBD and in the Banówka sub-basin of Jarft RBD. A change that has
been made since the 2nd RBMPs is that no groundwater body cross multiple RBDs.

From the information in the RBMP documents for the 3rd RBMPs, 753 (17.8% of total surface
water bodies) are designated as heavily modified and 74 (1.7% of total surface water bodies)
are designated as artificial.  In the Vistula and Oder RBDs, according to a table provided in the
RBMP documents for the 3rd RBMPs, all transitional and coastal water bodies are natural.

Table 2.1 
3rd (2021) RBMP

Number of delineated surface water bodies in Poland in 2nd (2015)  and

Year

RBD

2021

PL1000

2021

PL2000

2021

PL3000

2021

PL4000

2021

PL5000

Lakes

Rivers

Transitional
waters

Coastal
waters

Number of
water
bodies

Number of
water
bodies

Number of
water
bodies

Number of
water bodies

5

2

499

1

5

1,745

3

1

8

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Lakes

Rivers

Transitional
waters

Coastal
waters

Number of
water
bodies

Number of
water
bodies

Number of
water
bodies

Number of
water bodies

Year

RBD

2021

PL6000

2021

PL7000

2021

PL8000

2021

PL9000

427

105

36

1,291

2

82

24

2

2

4

6

4

10

2021

Total

1,068

3,161

2016

PL1000

2016

PL2000

2016

PL3000

2016

PL4000

2016

PL5000

2016

PL6000

2016

PL7000

2016

PL8000

2016

PL9000

484

1

422

101

36

11

2,660

4

6

8

1,735

120

39

3

2016

Total

1,044

4,586

Source: 3rd RBMPs e-reporting

7

5

4

9

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Table 2.2 
(2021)

Number of delineated groundwater bodies in Poland in the 3rd RBMP

Year

RBD

Groundwater

Number of
water bodies

2021

2021

2021

2021

2021

2021

2021

2021

2021

2021

PL1000

PL2000

PL3000

PL4000

PL5000

PL6000

PL7000

PL8000

PL9000

Total

2

94

1

1

5

66

2

2

1

174

Source: 3rd RBMPs e-reporting.
Note: Data from 2nd RBMPs not presented as the reported data used in the assessment of the 2nd RBMPs did not
represent the actual number of groundwater bodies. It was reported as 178, but Poland clarified that the actual
number was 172 following the assessment of the 2nd RBMPs.

The table below shows the evolution in the numbers / delineation of water bodies between the
2nd and 3rd RBMPs. Under ‘wiseEvolutionType’ in the e-reporting data, for river water bodies,
the main evolution types are reported as aggregation, splitting, creation and change in code.
For lake water bodies, the evolution types are reported as change and creation. For
groundwater, the evolution types are reported as change, aggregation and change in code.
For transitional water bodies the evolution types are reported as aggregation and change in
code. For coastal water bodies, the evolution types are reported as aggregation and
aggregation and splitting.

Table 2.3 
in Poland in the 3rd RBMP (2021) compared to the 2nd RBMP

Type of change in delineation of groundwater and surface water bodies

Type of water body
change in 2021

Change

Aggregation

Splitting

Aggregation and
splitting

Number of water bodies

Groundwater

Rivers

Lakes

Transitiona
l

Coastal

1012

0

0

0

0

1

0

0

0

2

0

2

168

3

1

263

198

117

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Number of water bodies

Groundwater

Rivers

Lakes

Transitiona
l

Coastal

35

3

2547

56

0

0

6

0

0

Source: 3rd RBMPs e-reporting

Type of water body
change in 2021

Extended area

Reduced area

Creation

Deletion

Change in code

No change

Small water bodies

The WFD (2000/60/EC) protects all waters independently of their size, but for operational
purposes it defines a water body as a ‘discrete and significant’ element of water. The water
body is the scale at which status is assessed.

No exact information on the approach to small water units has been found in the 3rd RBMPs.

2.1.2.  Identification of transboundary water bodies

The numbers of transboundary surface water and groundwater bodies have not been found in
the RBMP documents for the 3rd RBMPs of the Vistula and Oder RBDs50. These RBMPs do
acknowledge the presence of transboundary water bodies and discuss the approaches to
bilateral cooperation. For the Oder RBD, the International Commission for the Protection of
the Oder River against Pollution (MKOOpZ) was established between Poland, Czechia and
Germany in 1996. For transboundary and border water bodies, uniform characteristics could
not be agreed in some cases. These water bodies will continue to be presented on the maps
of the Water Management Plan for the International Oder River Basin District in different ways,
according to the methodology and classification applicable in individual countries.

2.1.3.  Typology of surface water bodies

In the 3rd RBMPs, there have been changes to the numbers of surface water types. The
numbers of surface water types in the 3rd and 2nd RBMPs are shown in the table below. The
number of rivers, lakes and coastal surface water types has decreased. The number of
transitional water types has remained the same. The changes are due to a verification and
update of water typology.

Typology is determined in line with system A in Annex II of the WFD. The RBMPs state that an
abiotic typology classification system is used. A background document detailing the

50 Poland subsequently clarified that this information will be available as part of the electronic reporting.

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methodology used to determine typology was not identified in the RBMPs but information on
typology is provided in the text of the RBMPs.

Table 2.4 
and 3rd RBMP (2021)

Number of surface water body types in Poland in the 2nd RBMP (2015)

RBD

2021

2016

Rivers

Lakes

Transitional

Coastal

20

25

7

13

5

5*

2

3

Source: extracted from RBMP documents for the 3rd RBMPs
* In the previous assessment on the 2ndRBMPs, in the country-specific assessment for Poland, it states that there
were four transitional types in 2016, however Poland subsequently clarified that there were 5 types of transitional
water types in 2026.

2.1.4.  Establishment of reference conditions/type-specific

conditions for surface water bodies

The RBMPs indicate (but do not state explicitly) that type-specific reference conditions have
been established for all surface water types. The RBMP documents for the 3rd RBMPs state
that the RBMPs contain a list of water bodies and information on their types and whether
reference conditions are established. However, the RBMPs do not provide a reference to the
list. Therefore, the list that contains the extent to which reference conditions have been
established could not be found in the RBMP documents for the 3rd RBMPs. The RBMPs
inform that reference conditions have been established for new surface water types. In the 2nd
RBMPs, reference conditions have been established for all relevant quality elements for all
water body types across all water categories. From the information presented in the RBMP
documents for the 3rd RBMPs, it seems that this continues to be the case for the 3rd RBMPs,
i.e. the existing surface water types still have reference conditions established, and they have
also been established for the new types.

Coordination of reference conditions

The RBMPs provide examples of transboundary cooperation between neighbouring Member
States and non-Member States. This does not, however, inform on whether the coordination
of type-specific reference conditions takes place.

2.1.5.  Characteristics of groundwater bodies

In Poland, nearly 75% of groundwater resources are located in quaternary aquifers. They are
located at a depth of several to nearly 200 metres below the surface, and in some locations
even at greater depths. The Vistula and Oder RBDs contains aquifers that are porous, porous-
fissured, karst-fissured and fissured.

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2.1.6.  Significant pressures and impacts on water bodies

The information in this section is taken from the Vistula and Oder RBMP documents for the 3rd
RBMPs. The following significant pressures are described in the RBMPs as ‘significant
pressures identified’ in the RBDs. The significant pressures highlighted in the Vistula RBMP
are point source pressures from industry and wastewater, diffuse pollution pressures mainly
from agriculture, hydromorphological changes, and pollution related to tourism and recreation.
The significant pressures highlighted in the Oder RBMP are point source pressures from
municipal and industrial sewage, diffuse pollution, dewatering of mines, disruption of the
hydrological regime, morphological and hydrological change and pollution related to tourism
and recreation.

94% of river water bodies in the Vistula RBD and 95% in the Oder RBD are subject to such
significant changes caused by anthropogenic pressures that they are at risk of failing to
achieve the environmental objectives. The reasons listed are river bed straightening, dams
and other hydrotechnical structures, bridges, regulatory structures (edge strips, groynes,
longitudinal dams), flood embankments, water management facilities, mining, diffuse pollution
from atmospheric deposition, rainwater discharged from urban areas, and industrial and urban
sources. 61% of lake water bodies in the Vistula RBD and 71% in the Oder RBD are at risk of
not achieving the environmental objectives. The listed reasons are nutrient pollution from
agriculture, diffuse pollution from atmospheric deposition and run-off from forest areas. All
transitional and coastal water bodies are at risk of failing to achieve environmental objectives
in the Vistula and Oder RBDs, mainly due to pollution flowing into them from rivers throughout
the river basin area.

In transitional and coastal water bodies in the Vistula RBD, the dominant sources of pressure
are pollution from the inflow of river water bodies containing pollutants and point source
discharges of sewage. The chemical status in transitional and coastal waters depends on the
presence of pressure sources present in other parts of the Vistula RBD. Significant loads of
heavy metals and organic compounds (including pesticides) are introduced to transitional and
coastal water bodies from rivers. The Oder RBMP also states that transitional and coastal
waters are mainly exposed to area pressures from diffuse and unknown sources, which come
from the related direct catchments and river water bodies. It further notes that the chemical
status in transitional and coastal waters depends on the occurrence of pressure sources
present in other parts of the Oder RBD and is most often determined by exceedances of
PAHs, PFOS, mercury and cadmium.

21% of groundwater bodies in the Vistula RBD and 32% in the Oder RBD are at risk of failing
to achieve environmental objectives. The pressures linked to the risk of failing chemical
objectives are listed as municipal, industrial and other landfills; discharge of municipal and 
industrial sewage into water and land; pollution from agriculture; the impact of urban-industrial
agglomerations and road transport. The pressures linked to the risk of failing quantitative
objectives are listed as mining drainage, land improvement and the impact of urban-industrial
agglomerations.

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2.1.7.  Definition and assessment of significant pressures on

surface and groundwater

The information in this section is taken from the Vistula and Oder RBMP documents for the 3rd
RBMPs.

The RBMPs provide a detailed account of the pressure assessments that have been
undertaken. For surface water, the RBMPs inform that the purpose of these assessments is to
obtain the necessary quantitative and qualitative data characterising each water body, the
analysis of anthropogenic pressures for each water body (monitored and unmonitored),
identify water bodies affected by significant and cumulative pressures, identify the source of
significant pressures and identify water bodies at risk of failing to achieve the environmental
objectives. Analyses have been undertaken for all water categories in terms of the following
types of pressures: pressures on the hydromorphological state, pressures on biological quality
elements; pressures on physicochemical elements, pressures on chemical status and
pressures on surface water resources. The tools used in the assessment of pressures on
surface water are:

● Using the properties of the catchment area of each water body and presenting them as

sorption potential51.

● Use of data resources on the hydromorphological status of surface waters; and

● Use of data resources on existing anthropogenic pressures. The key data used for

point source pressures are surface water intakes, underground water intakes, water
transfers, municipal sewage discharges, domestic sewage discharges and industrial
sewage discharges. The key data used for diffuse sources are the use of mineral
fertilisers, production of organic fertilisers, urban outflow, road transport, population not
connected to the sewerage system, atmospheric deposition and input loads.

In the Vistula and Oder RBDs, the following pressures on groundwater have been analysed:
point sources, diffuse sources and water intakes. Point sources of pollution have been
analysed mainly in terms of their impact on the chemical status of the groundwater body. The
distribution and potential impact of point source pollution hotspots in areas where the natural
protective properties of aquifers are weak has been analysed in detail.

2.1.8.  Groundwater bodies at risk of not meeting good status

In the Oder RBD, there are 21 out of 66 (32%) groundwater bodies at risk of failing to achieve
environmental objectives, namely 5 at risk of failing to meet chemical objectives, 6 at risk of
failing to meet quantitative objectives and 10 at risk of failing to meet both chemical and
quantitative objectives. In the Vistula RBD, there are 20 out of 94 (21%) groundwater bodies

51 Sorption potential is a quantitative description of the natural conditions in which the circulation of
water and chemical substances in the catchment takes place. It is described through a strictly defined,
quantitative classification of the properties of the physico-geographical environment determining the
quantitative conditions of water circulation and the association with anthropogenic activities. It
determines the vulnerability to anthropogenic pressure based on quantitative conditions of water
circulation.

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at risk of failing to achieve environmental objectives. This comprises 10 at risk of failing to
meet chemical objectives, 2 at risk of failing to meet chemical objectives, and 8 at risk of
failing to meet both chemical and quantitative objectives.

In both the Oder and Vistula RBDs, the main indicators of chemical pollution contributing to
the risk are listed as nutrients (nitrogen and phosphorus), chlorides, sulphates, boron,
potassium and pesticides. They also note that the monitoring shows that organic compounds
from other groups are also present in agricultural areas, such as mono- and polycyclic
aromatic hydrocarbons (PAHs); tri- and tetrachloroethene; benzo(a)pyrene and benzene,
toluene, and xylenes (BTX). For industrial and urbanisation pressures, the main pollution
indicators are metals such as lead; zinc; mercury; barium; chromium; nickel; arsenic;
cadmium; but also sodium; chlorides; ammonium ion and organic compounds; tri- and
tetrachloroethene; PAHs and BTX.

2.1.9.  Quantification of the gap and apportionment of pressures

The RBMPs present both the number of water bodies not at risk and at risk of failing to meet
environmental objectives. It provides a breakdown of pressures exerted on the various quality
elements at the water body level. A detailed annex is included in the RBMPs that shows the
water body, whether it is at risk or not at risk, the pressure that is being exerted (shown at the
quality element level) and the driver or source of the pressure.

2.1.10. Inventories of emissions, discharges and losses of

chemical substances

Article 5 of the Environmental Quality Standards Directive (2008/105/EC52) requires Member
States to establish an inventory of emissions, discharges, and losses of all priority substances
and the eight other pollutants listed in Part A of Annex I EQS Directive for each RBD, or part
thereof, lying within their territory. This inventory should allow Member States to further target
measures to tackle pollution from priority substances. It should also inform the review of the
monitoring networks, and allow the assessment of progress made in reducing (or
suppressing) emissions, discharges, and losses for priority substances.

Emissions inventories have been established for 55 chemical substances. This is consistent
across RBDs. In the 2nd RBMPs, benzo(g,h,i)perylene and indeno(1,2,3-cd) pyrene were not
included in the inventories but are now included in the inventories established in the 3rd
RBMPs. The RBMPs state that the emissions inventory has been developed in accordance
with the guidelines set out in the Common Implementation Strategy Guidance Document
n°2853.

52 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

53  CIS Guidance N° 28 - Preparation of Priority Substances Emissions Inventory
http://ec.europa.eu/environment/water/water-framework/facts_figures/guidance_docs_en.html

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2.2.  Main changes in implementation and progress with

recommendations

The main changes in the 3rd RBMPs concern the number of water bodies. There have been
decreases in the number of rivers, coastal and transitional water bodies and an increase in
the number of lake water bodies. This is a result of undertaking a verification and update of
the water body catchment area boundaries. The number of groundwater bodies has increased
by two, this is a result of the change no groundwater body will cross multiple RBDs.

There have been changes to the number of surface water types. This is a result of the
verification and update of water typology. Reference conditions have been established for the
new surface water types.

The Commission recommendation based on the 2nd RBMPs analysis was:

● Recommendation: Poland has made significant progress in the characterisation of
water bodies. However, further work is still needed on the significance of pressures
and on clarifying impacts which are currently reported as unknown.

● Assessment: In the absence of the 3rd RBMP e-reporting data, a direct comparison of
the number of water bodies affected by unknown impacts between the 2nd and 3rd
RBMPs cannot be undertaken. The information on unknown impacts is limited in the
PDFs of the RBMPs. The RBMPs do state that transitional and coastal waters are
mainly exposed to pressures from diffuse and unknown sources54.

2.3.  Conclusions on gaps in implementation

In the Oder RBD, in some cases, uniform characteristics could not be agreed between the
countries sharing the RBD. There may be further work needed to better harmonise the
characteristics of transboundary and border water bodies55.

54 Poland subsequently provided further information stating that the 3rd RBMPs took a different
approach to identification of anthropogenic pressures. Compared to the 2nd RBMPs, more causative
factors were identified, resulting in reduction in the number of pressures identified as unknown. A more
detailed approach was adopted, especially for pressure from diffuse sources, and more source data
was obtained and analysed. As for the transitional and coastal water bodies in the 3rd RBMPs, the main
identified pressures came from diffuse sources (urban development) and point sources (wastewater).

55 Poland subsequently clarified that every effort is made to ensure that agreements regarding water
management plans for watershed areas are made at the level of international working groups within the
International Commission for Protecting the Oder River Against Pollutions. These agreements are
aimed at harmonising efforts and cooperation in water management. The work results in common River
Basin Management Plan for International Oder River Basin District and its updates available at:
https://www.mkoo.pl/index.php?mid=40&aid=1151&lang=PL

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3.  Monitoring, assessment and classification of
ecological status/potential in surface water bodies

3.1.  Assessment of implementation and compliance with

WFD requirements

3.1.1.  Monitoring of ecological status / potential in surface waters

Article 8(1) of the WFD requires Member States to establish monitoring programmes to
assess the status of surface water and groundwater, in order to provide a coherent and
comprehensive overview of water status within each RBD. The WFD distinguishes between
surveillance and operational monitoring. Surveillance monitoring is carried out for one year,
once per six-year cycle, and is mainly aimed at assessing impacts and long-term changes in
natural conditions or resulting from anthropogenic pressures and is used for the purpose of
designing future monitoring programmes. Operational monitoring is carried out throughout the
cycle and aims mainly at establishing the status of water bodies identified as being at risk of
failing to meet their environmental objectives and assessing any changes in status resulting
from the programmes of measures. All water bodies have been classified for ecological status
or potential.

Overall, the lack of detailed information about monitoring in the RBMPs makes the
assessment difficult, and therefore it is not possible to assess whether Poland is compliant
with the WFD.

Monitoring programmes

The monitoring programmes in the 3rd RBMPs take into account the changes related to
establishing a new methodology for the classification, changes in typology and changes in
water body status. The network of monitoring sites and the type of monitoring in surface
waters have been planned, and for the following categories: rivers, reservoirs, lakes,
transitional and coastal waters, they also include heavily modified and artificial water bodies
which are at risk of failing to achieve the environmental objectives. As a result, both
surveillance and operational monitoring at the national level in the 3rd RBMPs cover 96.9% of
river and reservoir water bodies (increasing by 45.7% from the 2nd RBMPs), 79.3% of lake
water bodies (34%). Both in the 2nd and 3rd RBMPs, 100% of coastal and transitional waters
have been covered by monitoring.

Surveillance and operational monitoring for ecological status/potential of
surface water bodies

In the 3rd RBMPs, new criteria for the selection of surface water bodies to be monitored as
part of surveillance monitoring includes all representative rivers of the RBDs and all lakes over
50 ha or 10 million cubic metres of volume with the addition of water bodies on the state
border. There are no criteria specified for coastal or transitional waters.

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In the 3rd RBMPs, for the selection of surface water bodies to be monitored as part of
operational monitoring new criteria are that water bodies which have been shown to be at risk
from surveillance monitoring, or water bodies which have an impact from pressures such as
pollution, including priority substances, and water bodies where there is a hydromorphological
impact.

In the 3rd RBMPs, the number of sites has not been reported separately for the operational
and surveillance monitoring. Monitoring sites have been reported for river water bodies, lakes
and reservoirs, but not for transitional and coastal waters. The number of sites is reported for
both surveillance and operational monitoring combined. Within the Oder RBD, there are 1238
monitoring sites in rivers, 388 in lakes and 19 sites in reservoirs. The Vistula RBD has 1663
monitoring sites in rivers, 363 sites in lakes and 26 sites in reservoirs. Lastly, for the Pregoła
RBD, there are 75 monitoring sites in rivers and 59 sites in lakes. For other RBDs, there was
no information provided.

Regarding the coverage of monitoring in each RBD, information has been provided separately
for both surveillance and operational monitoring for all surface water categories, except for
transitional and coastal waters, where the percentages are combined for both monitoring
types. Within the Oder RBD, surveillance monitoring includes 52.7% of river water bodies,
100% of reservoirs, and 77.1% of lake water bodies; and operational monitoring includes
98.5% of river water bodies, 100% of reservoirs, and 77.3% of lake water bodies. The Vistula
RBD surveillance monitoring includes 53.8% of river water bodies, 100%  of reservoirs, and
73.8% of lake water bodies, whereas operational monitoring includes 98.9% of river water
bodies, 100% of reservoirs, and 78.8% of lake water bodies. For the Pregoła RBD,
surveillance monitoring includes 56% of river water bodies and 86.4% of lake water bodies;
and operational monitoring includes 96% of rivers water bodies, and 94.9% of lake water
bodies. With the surveillance and operational monitoring combined for transitional and coastal
waters, for both the Oder and Vistula RBDs, the monitoring includes 100% of transitional and
coastal waters. For other RBDs, there was no information provided.

Selection of quality elements monitored

Based on information that was provided regarding which quality elements are monitored, it is
not clear whether the information available refers to surveillance or operational monitoring; 
however, it seems that the information most likely refers to operational monitoring.

Biological quality elements that are monitored include phytoplankton and macrophytes in
lakes, phytobenthos, benthic invertebrates, and fish in rivers; phytoplankton and benthic 
invertebrates in transitional and coastal waters. There are gaps in monitoring of biological
quality elements:

● Benthic invertebrates and fish in lakes; the missing phytobenthos is an alternative for

macrophytes in lakes;

● Macrophytes and phytoplankton in rivers;

● Fish, angiosperms and macroalgae in transitional waters;

● Angiosperms and macroalgae in coastal waters.

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Hydromorphological quality elements monitored are morphological condition, river continuity
and hydrological regime. The RBMPs do not reveal how various water categories are
monitored for hydromorphology.

For general physico-chemical quality elements, transparency and nitrogen conditions are
monitored in lake water bodies, salinity conditions in river water bodies, and nitrogen and
phosphorous conditions are monitored in coastal water bodies. Other parameters for nutrient
conditions are monitored in all surface waters, but the water categories are not specified. In
addition to the gaps in the available information regarding nutrient conditions, there are other
gaps in monitoring of general physico-chemical quality elements56:

● Thermal conditions, oxygenation conditions, in lakes, rivers, transitional and coastal

waters

● Salinity in rivers, transitional and coastal waters

● Acidification in lakes and rivers

● Transparency in transitional and coastal waters

Monitoring frequency

Annex V to the WFD provides guidance on the frequency of monitoring of the different quality
elements. Surveillance monitoring should be carried out for each monitoring site for a period
of one year during the period covered by RBMPs i.e., six years. For phytoplankton this should
be done twice during the monitoring year and for the other biological quality elements once
during that year. As a guideline, operational monitoring should take place at intervals which do
not exceed once every six months for phytoplankton and once every three years during the
six-year cycle for the other biological quality elements. Greater intervals may be justified
based on technical knowledge and expert judgement.

The RBMPs state that surveillance monitoring is carried out annually at least once every 6
months, and at least once during the period of an RBMP. The monitoring frequencies for
surveillance monitoring are in line with the WFD.

Operational monitoring is carried out twice in a six-year cycle (every 3 years). The frequency
is also different for hydromorphological elements, there is a single measurement in a six-year
cycle to determine the morphological conditions, river continuity and hydrological regime for
transitional and coastal water bodies and monthly measurements for the hydrological regime
for lake water bodies.

Surveillance and operational monitoring for river basin specific pollutants
(RBSPs)

In the 3rd RBMPs, there was no information provided regarding the monitoring of RBSPs, i.e.,
water body coverage by monitoring programmes, number of monitoring sites or frequency of

56 Electronic reporting was not available at the time of the analysis, Poland subsequently indicated that
data will be available on this topic in WISE.

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monitoring. According to the Reporting Guidance for the 2nd RBMPs, the register of river basin
specific pollutants includes 24 synthetic and non-synthetic RBSPs.

Transboundary surface water body monitoring

In the 3rd RBMPs, the sections on international cooperation do not provide any specific
information about monitoring in transboundary surface water bodies. In the 2nd RBMPs,
Poland reported transboundary river water bodies in eight of its ten RBDs. Most were in the
Oder (67) and Vistula (49) RBDs. Transboundary coastal, lake and transitional water bodies
were also reported.

3.1.2.  Assessment of ecological status / potential for surface

water bodies

Intercalibration of biological assessment methods and national classification
systems

The WFD requires the Member States to collect, as appropriate, the necessary information for
the sites included in the intercalibration network, in order to enable the assessment of the
consistency of the national monitoring system classifications with the normative definitions for
biological quality elements (BQEs) set out in Section 1.2 of Annex V. The purpose is to
establish harmonised boundary values between ‘high’ and ‘good’ (H/G) and between ‘good’
and ‘moderate’ (G/M) status. In order to carry out the intercalibration exercise Member States
are organised in Geographical Intercalibration Groups (GIG), consisting of Member States
and Norway sharing particular surface water body types. The Commission has adopted the 4th
intercalibration decision (Commission Decision (EU) 2024/27157) in 2024 which replaced the
Commission Decision (EU) 2018/229.

Poland did not provide any information on the intercalibration exercise of biological
assessment methods and national classification systems for the 3rd RBMPs, this includes any
changes made since the 2nd RBMPs. The reference conditions have been established for the
new types of water bodies following delineation and changes in typology. But no exact
changes are specified and there is no information whether the methodology has changed.

According to the results of the intercalibration exercise in the CIS working group ECOSTAT,
the phytobenthos quality element method for very large rivers has not been intercalibrated. All
other assessment methods for the national classification system have been intercalibrated
with fixed class boundaries. No information is provided whether national types are linked to
common intercalibration types.

Assessment methods and classification of biological quality elements

No information has been provided about the sensitive biological quality elements (BQEs) to
different pressures and assessment methods to define the class boundary values. There is no

57 Available at: https://eur-lex.europa.eu/eli/dec/2024/721/oj

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information on status of various BQEs. The classification of water bodies is based on both 
surveillance and operational monitoring in all RBDs. It is unclear whether grouping has been 
applied to the classification of ecological status / potential, as information on grouping remains 
unclear and little information is provided.

Regarding the classification of ecological status / potential of surface water bodies, all 
transitional water bodies have been classified using data from monitoring sites (19 
sites). For rivers on the other hand, 68% of water bodies (3315 sites) are classified 
using data from monitoring sites, with 32% not being classified, and similarly for lakes, 
67% are classified with monitored data from sites (713 sites), and 33% are not 
classified. 

Figure 3-1 Percentage of surface water bodies which have a classification of ecological
status / potential through monitoring data

Source: Data mining from 3rd RBMPs pdf reporting 

Assessment methods for hydromorphological quality elements

In the 2nd RBMPs, hydromorphological methods were developed for all quality elements in all 
water categories. In the 3rd RBMPs, there is no information provided on the assessment 
methodologies for hydromorphological quality elements; this includes information on 
methodology, reported gaps, reference conditions, and whether standards have been linked to 
class boundaries for sensitive biological quality elements.

Assessment methods for general physico-chemical quality elements

In the 2nd RBMPs, physico-chemical standards were set for all general physico-chemical 
quality elements for all water categories required by the WFD; however, in the 3rd RBMPs, 
there is limited information provided on general physico-chemical quality elements; this 

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includes, information on methodology, reported gaps, reference conditions, and whether
standards have been linked to class boundaries for sensitive biological quality elements. The
RBMPs do state that the number of assessed physico-chemical and chemical elements as
well as class boundaries have changed.

Selection of river basin specific pollutants (RBSPs) and use of environmental
quality standards (EQS)

There was no information provided regarding how RBSPs have been identified, whether all
EQS for RBSPs are according to Technical Guidance Document No. 27, and whether the
ecological status of surface water bodies have been downgraded due to an exceedance of
EQS of RBSPs.

3.1.3.  Classification of ecological status/potential of surface water

bodies

The application of the ‘one-out, all-out’ principle

Whether Poland has applied the one-out, all-out principle for the classification of ecological
status / potential remains unclear. There is no information provided in the 3rd RBMP.

Ecological status / potential of surface water bodies

The classification of ecological status / potential has been done for all RBDs.

Since the 2nd RBMPs, there is a worsening of overall ecological status / potential of surface
water bodies in Poland (see Figure 3-2 below). The percentage of surface water bodies
between the 2nd and 3rd RBMPs at high ecological status or maximum ecological potential
decreased from 0.3% to 0.1%, for good ecological status/potential from 11.7% to 10.4%, for
moderate ecological status/potential there is an increase from 51.1% to 53.6%, for poor
ecological status/potential it decreased from 25.4% to 20.0%, and lastly there was an increase
in poor ecological status/potential from 11.5% to 15.9%. There is no data available on the
expected proportion of water bodies in good ecological status/potential by 2027.

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Figure 3-2 Ecological status or potential of surface water bodies in Poland in the 2nd
(2015) and 3rd (2021) RBMPs

Source: Data mining from 3rd RBMPs pdf reporting

Note: status assessment results for the reported surface water bodies in Vistula, Oder and Pregoła RBDs

The more detailed insight in the water categories (see Figure 3-3) shows that none of the 
transitional and coastal water bodies are in good or better ecological status/potential. Lake, 
transitional and coastal water bodies have the most water bodies in bad ecological 
status/potential, followed by river water bodies; 48.88%, 27.27%, and 8.06% respectively. 
Transitional water bodies have the highest proportion of water bodies in poor ecological 
status/potential, followed by river, reservoir, and lake water bodies (63.64%, 24.00%, 23.08%, 
and 2.25% respectively). Rivers have the most water bodies in moderate ecological 
status/potential, followed by lake, reservoir, transitional and coastal water bodies (59.29%, 
32.96%, 28.21%, and 9.09% respectively). Regarding good ecological status/potential, most 
of reservoirs are in good ecological status/potential, next lake and river water bodies in good 
ecological status/potential (46.15%, 15.92%, and 8.52% respectively). Lastly, only small 
proportion of reservoirs and river water bodies are in high ecological status or maximum 
ecological potential (2.56% and 0.14% respectively).

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Figure 3-3 The percentage of surface water bodies ecological status or potential by
type (i.e. lakes, rivers, reservoirs, and transitional and coastal water combined)

Source: Data mining from 3rd RBMPs pdf reporting

Confidence in ecological status assessment

Whilst the 2nd RBMPs showed that the confidence in the classification of ecological status / 
potential was with high confidence for coastal and transitional waters, and the majority of 
rivers and lakes were classified with low confidence, in the 3rd RBMPs, there was limited 
information provided on the confidence in the classification. The 3rd RBMPs state that there is 
more complete monitoring data compared to the 2nd RBMPs, which translates into a better 
confidence for a larger number of water bodies.

3.2.  Main changes in implementation and progress with

recommendations

Some changes and progress have been made with recommendations since the 2nd RBMPs. 
Surveillance monitoring has been established. Both surveillance and operational monitoring 
have new criteria for the selection of surface water bodies to be monitored. Additionally, 
surveillance and operational monitoring covers a large portion of water bodies.

Regarding any other changes or progress made since the 2nd RBMPs, information is not 
provided and not transparent. There is no information on whether methodologies for 
biological, hydromorphological, or physico-chemical quality elements have improved.

The Commission recommendations based on the 2nd RBMPs analysis were:

● Recommendation: Poland should strengthen the monitoring of surface waters by

covering all relevant quality elements in all water categories.

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● Assessment: Whilst monitoring has increased and surveillance monitoring has

improved, Poland still does not cover angiosperms, macroalgae, nor other aquatic
flora, as well as any hydromorphological quality elements for neither surveillance nor
operational monitoring. Additionally, there are still very few general physico-chemical
quality elements monitored as well58.

● Recommendation: An increased level of monitoring should lead to a lower

dependence on expert judgment and on grouping for the classification of ecological
status / potential, and consequently to an increased confidence in the assessment of
ecological status.

● Assessment: As there is no information provided on the dependence of expert

judgement or grouping for the classification of ecological status / potential, it is difficult
to assess; however, monitoring has improved, therefore this should have a positive
impact for confidence in classification.

● Recommendation: Poland should provide a complete assessment of ecological
status for all categories of water, including assessments of all relevant quality
elements. The methods developed for classification of ecological status for
hydromorphological and physico-chemical quality elements should be WFD compliant,
in particular concerning their links to good status for the relevant biological quality
elements.

● Assessment: There was limited information provided on the assessment of ecological
status/potential, nor for the assessment of relevant quality elements. There was no
information provided on the methods developed for the classification of ecological
status for hydromorphological and physico-chemical quality elements, and whether
they are compliant with the WFD or linked to good status for the relevant biological
quality elements59.

● Recommendation: Poland should continue to progress in the transfer of the results of

intercalibration into all national types, and provide clear information on the class
boundaries that are used for the status classification of different national types.

● Assessment: There was no information addressing the progress on the transfer of
results from intercalibration into all national types, nor was there any information
provided on intercalibration for the 3rd RBMPs at all. There was no information
provided on class boundaries that are used for the status classification of different
national types60.

58 Electronic reporting was not available at the time of the analysis, Poland subsequently indicated that
data will be available on this topic in the e-reporting.

59 Poland has stated that information on methodology developed for the assessment of ecological
status/potential is provided in the regulation of the Minister of Infrastructure of June 25, 2021,
concerning the classification of ecological status/potential.

60 Poland has stated that as it is stated in Commission‘s decision of 27.2.2024, establishing pursuant of
Directive 2000/60/EC of the European Parliament and of the Council, the values of the Member State
monitoring system classifications as a result of the intercalibration exercise and repealing Commission
Decision (EU) 2018/229, Poland has no substantial gaps in intercalibrated methods. There are some
minor gaps only with phytobenthos in very large rivers, but this is the same method as intercalibrated

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● Recommendation: Strengthen monitoring of surface waters by covering all relevant

quality elements in all water categories.

● Assessment: The monitoring has been strengthened by improving coverage of

monitoring. The coverage of monitoring regarding relevant quality elements were not
provided61.

● Recommendation: Provide a complete assessment of ecological status for all
categories of water, including assessments of all relevant quality elements.

● Assessment: An ecological status assessment has been completed for all water
categories; however, this assessment is not broken down into relevant quality
elements. Only an overall classification of ecological status/potential is provided62.

3.3.  Conclusions on gaps in implementation

Poland has not achieved the good ecological status/potential for all water bodies and
expectations to achieve this objective by 2027, although unknown, seem ambitious. There is
also much room for improvement for Poland, as there are many gaps in implementation and
methodologies. It is difficult to determine whether there has not been much undertaken by
Poland for the 3rd RBMPs, or whether the information just was not provided. Therefore, it is
difficult or impossible to conclude on whether progress is being made from the information
available63.

The gaps in implementation and other missing information for Poland include:

● Monitoring sites have not been reported for transitional and coastal waters;

● From the information that was provided regarding which quality elements are

monitored, it is not clear whether the information available refers to surveillance or
operational monitoring; however, it seems that the information most likely refers to
operational monitoring;

● There are no benthic invertebrates or fish monitored in lakes; no macrophytes or

phytoplankton monitored in rivers; no fish, angiosperm, or macroalgae monitored in
transitional waters; no angiosperm or macroalgae monitored in coastal waters64.

methods for general rivers. A few methods in coastal and transitional waters are not intercalibrated but
it is justified and included in the decision as well.

61 Electronic reporting was not available at the time of the analysis, Poland subsequently indicated that
data will be available on this topic in e-reporting.

62 Poland has stated that data relating to the classification of ecological status/potential is available on
the Polish website: https://wody.gios.gov.pl/pjwp/

63 Poland has indicated that due to the delay in3rd RBMP e-reporting, this information was not ready
before the assessment of RBMPs from EC. As of March 2024, the report is validated and completed.

64 Poland has stated that these quality elements are present in the regulation of the Minister of
Infrastructure as of July 13, 2021 on the forms and methods for the monitoring of surface water bodies.

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● There are very few physico-chemical quality elements monitored. There are no thermal
conditions, oxygenation conditions monitored in any of the surface water bodies; there
is no monitoring of salinity in rivers, transitional and coastal waters; there is no
monitoring of acidification in lakes and rivers; there is no monitoring of transparency in
transitional and coastal waters; information on RBSPs monitoring was not provided65;

● Information on transboundary surface water body monitoring was not provided66;

● As for the assessment methods of biological quality elements there were no exact
changes specified and there is no information on whether the methodology has
changed;

● The selection of biological quality elements for the operational monitoring programme
to respond to different pressures is minimal and does not cover all surface water
categories, and is only done for one type of impact, which is nutrient pollution in rivers
and lakes;

● Poland did not provide any information on the intercalibration of biological assessment

methods and national classification systems for the 3rd RBMP, this includes any
changes made since the 2nd RBMPs;

● According to the results of the intercalibration exercise in the CIS working group

ECOSTAT, the phytobenthos quality element method for very large rivers has not
been intercalibrated;

● For the assessment methods of hydromorphological and physico-chemical quality

elements, there is no new information provided for either, whether this is information
on methodology, reported gaps, reference conditions established, or if standards have
been linked to class boundaries for sensitive biological quality elements;

● There was no information provided regarding how RBSPs have been identified,

whether all EQS for RBSPs are according to Technical Guidance Document No. 27,
and whether the ecological status of surface water bodies have been downgraded due
to an exceedance of EQS of RBSPs;

● It is unclear whether grouping has been applied to the classification of ecological

status / potential, as information on grouping remains unclear and little information is
provided;

● There was no information provided on the confidence of classification for the 3rd

RBMPs;

● Whether Poland has applied the one-out, all-out principle for the classification of

ecological status / potential remains unclear. There is no information provided for the
3rd RBMPs.

65 Poland has stated that all physico-chemical quality elements required by WFD are monitored and
data are reported to EEA on a regular basis.

66 Electronic reporting was not available at the time of the analysis, Poland subsequently indicated that
data will be available on this topic in the 3rd RBMP e-reporting.

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4.  Monitoring, assessment and classification of
chemical status in surface water bodies

4.1.  Assessment of implementation and compliance with

WFD requirements

4.1.1.  Monitoring of chemical status in surface waters

Monitoring sites and monitored water bodies used for monitoring of chemical
status

According to the WFD, Member States have to establish and maintain monitoring
programmes for both ecological status (see Topic 3) and chemical status. For chemical status
this includes surveillance monitoring programmes and operational monitoring to determine
chemical status. Ultimately, the evidence base developed from monitoring (and determination
of chemical status) supports the work on where intervention is needed and what should be
included in the programmes of measures (PoM) to achieve good chemical status in all water
bodies.

The assessment of the 2nd RBMPs stated that as of 2015, the monitoring network in Poland to
support the chemical status assessment spanned around 29% of all water bodies in Poland.
This included 27% of all rivers, 38% of all lake water bodies, 50% of coastal water bodies, and
67% of all transitional water bodies. The 3rd RBMPs provide a statement that the monitoring
network has subsequently been increased by a further 16%, so that nationally, this means
45% of all water bodies are included in the monitoring programme or 42% of all rivers, 60% of
all lake water bodies, and 100% of all coastal and transitional water bodies. As a further
comment, the assessment of the 2nd RBMP states that no monitoring or status assessment
was completed for territorial waters in Poland. The 3rd RBMP refers to surveillance monitoring
(MD) for investigative purposes, which includes tracking releases of pollutants into the sea.
Specific mention of operational monitoring and status assessment for territorial waters is
missing.

The 3rd RBMPs state that all 45 priority substances are included in the monitoring programme
along with the eight other substances listed in the annexes of the EQSD. In terms of
frequency of monitoring, things are slightly more complex. The 3rd RBMPs comment that
Poland has effectively three tiers of monitoring that are in place, which are identified as
‘surveillance (MD)’, ‘Operational (MO)’ and ‘Investigative (MB)’. All substances on the
operational monitoring programme are included in sampling and analysis once every three
years. For those substances with known EQS exceedances, where there are direct
discharges or where a high risk is identified on the basis of pressures are included in the
surveillance monitoring programme. This includes sampling and analysis on a monthly basis.
Further, the surveillance monitoring programme includes territorial waters. This means that for
priority substances with EQS exceedances, or identified as being at high risk, Poland does
conduct monitoring in territorial waters on a monthly basis, with data made available through

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the ICES data base67. The investigative monitoring programme is a separate body of work to
provide targeted additional monitoring on an ad-hoc basis dependent on any specific issues
that arise.

Based on an understanding of these monitoring programmes it can be concluded that the
majority of the priority substances are on the surveillance list and monitored on a monthly
basis. However, for priority substances deemed low risk, or where no exceedances have been
identified to date, they will be on the operational list with monitoring once every three years.
Specific details of which list the 45 priority substances are assigned to is not provided.

Long-term monitoring of priority substances sediment and biota for status
assessment

Requirements: Article 3.6 of the EQSD requires Member States to monitor 20 priority
substances68 that tend to accumulate in sediment and / or biota, for the purpose of long-term
trend assessment. Monitoring should be carried out at least every three years, unless
technical knowledge and expert judgment justify another interval.

Information on monitoring in biota and sediment for the 20 priority substances is very limited,
and unfortunately the 3rd RBMPs e-reporting is unavailable at time of analysis. The
assessment of the 2nd RBMPs commented that no biota monitoring had been undertaken, but
that plans were in place to commence monitoring in sediment. In 2019 Poland issued an
implementing act which includes the requirements for monitoring in sediment and biota. The
implementing act only mentions hexachlorobenzene, hexachlorobutadiene, and mercury, with
confirmation that it will be included, but no further details of actual implementation. The
sections on monitoring comment that the operational monitoring programme (MO) conducts
sampling and analysis once every three years. However, there is no details on whether this
covers only water, or other matrices such as biota and sediment69.

Monitoring of priority substances that are discharged in each RBD

Member States are required to undertake monitoring for all priority substances which are
discharged into the river basin or sub-basin. This information is supported in part by the
reporting requirements of the pollutant release and transfer register (PRTR) (EC 166/2006) on
industry where environmental permitting applies. The information from both this monitoring
and the PRTR is intended to support the obligations around establishing an inventory of

67 https://dome.ices.dk/browse/

68 Anthracene, brominated diphenylether, cadmium, C10-13 chloroalkanes, Di(2-ethylhexyl)phthalate
(DEHP), fluoranthene, hexachlorobenzene, hexabutadiene, hexachlorocyclohexane, lead, mercury,
pentachlorobenzene, PAH, Tributyltin, dicofol, perfluorooctanesulphonic acid (PFOS), quinoxyfen,
dioxins and furans, hexabromocyclododecane (HBCDD), and heptachlor and heptachlor epoxide.

69 Poland has subsequently clarified  that monitoring in both biota and sediment has commenced with
full compliance against the EQSD (i.e., the monitoring covers all 20 substances). The first round of this
monitoring was submitted in 2022 using the Reportnet 3 portal. Where monitoring has only recently
commenced further details on trend analysis are not yet available.

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releases, discharges, and losses (as per Article 5 of the EQSD) (see also the information
under Topic 2, 2.1.10).

The 3rd RBMPs comment that emission inventories are in place for Poland. Furthermore, 31
priority substances have been identified as releasing / potentially releasing discharges into
surface water. All 31 substances are included as part of the surveillance monitoring list (MD)
which includes monitoring on a monthly basis.

Performance of analytical method used

Monitoring networks established to support compliance with the WFD should also be in
compliance with the Directive on technical specifications for chemical analysis and monitoring
of water (2009/90/EC).

The assessment of the 2nd RBMPs commented that all 33 priority substances either met the
minimum standards for analysis or were fully compliant with the Directive on chemical analysis
and monitoring of water. This included techniques not incurring excessive cost and Article 5 of
the Directive around limits of quantification (LOQs) and EQS thresholds. Since this time a
further 12 substances have been added to the EQSD. The 3rd RBMPs states only that all
analysis conducted is compliant with the Directive for chemical analysis and monitoring of
water (2009/90/EC) without any detail.

4.1.2.  Assessment of chemical status for surface water bodies

Member States are required to report the year on which the assessment of chemical status is
based. This may be the year that the surface water body was monitored. In the case of
grouping this may be the year in which monitoring took place in the surface water bodies
within a group where the results are extrapolated to non-monitored surface water bodies
within the same group. For the 3rd RBMPs the chemical assessments were carried out based
on the monitoring regime from 2016 to 2020 in all RBDs70.

Figure 4-1 provides the proportions of water bodies in good, failing to achieve good and
unknown status per RBD, whilst Table 4.1 provides the numerical data in terms of total
numbers of water bodies. This illustrates that nationally 28% of water bodies are in good
status, 47% in poor status, and the remaining 25% are in unknown status (including 62 water
bodies with no data confirming status). The assessment of the 2nd RBMPs reported only 15%
were in unknown status. The reasons behind this increase in unknown status are not
provided.

70  Section 9.1.2. for each RBMP provides tables detailing the chemical status, including rows to
indicate where water body status has remained poor, remained good, deteriorated into poor, or
improved from poor status into good status.

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Figure 4-1

Percentage (%) of surface water bodies in each chemical status class

Source: Data mining from 3rd RBMPs pdf reporting

Table 4.1
in monitoring in the 3rd RBMPs

Results of the chemical status assessment for Poland by RBD included

RBD

Danube

Vistula

Świeża

RBD code

Good status

Failing to 
achieve good 
status

Unknown 
status

Total water 
bodies

PL
1000

0

2

3

5

PL
2000

620

1112

519

2251

PL
3000

0

4

0

4

Jarft

PL
4000

Elbe

PL
5000

0

1

0

1

1

4

3

8

Oder

PL
6000

482

799

441

Pregoła

Nemunas

Dniester

PL
7000

83

63

41

PL
8000

PL
9000

No data

No data

No data

No data

No data

No data

1722

187

60

2

Source: Data mining from 3rd RBMPs pdf reporting

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Ubiquitous persistent, bioaccumulative and toxic priority substances

According to Article 8(a) of the EQS Directive71, eight priority substances and groups of priority
substances are behaving like ubiquitous, persistent, bioaccumulative and toxic substances72.
These substances are generally expected to cause widespread exceedances, and their
emissions can be challenging to tackle (e.g. due to long-range atmospheric transport and
deposition). In order to show the progress made in tackling other priority substances, Member
States have the possibility to present the information related to chemical status separately for
these substances.

The majority of the substances which prevent water bodies from achieving good chemical
status fall into the category of uPBTs. The assessment of the 2nd RBMPs highlighted
polyaromatic hydrocarbons (PAHs) and mercury as being particularly problematic. This still
remains the case for the 3rd RBMPs. Additionally, polybrominated diphenyl ethers (PBDEs),
hexabromocyclododecane, heptachlor and heptachlor epoxide, and perfluorooctane sulphonic
acid (PFOS) all have widespread exceedances. Further information on the number of specific
water bodies with exceedances per substance is not provided beyond the information in chart
6.1 for each RBMP, which details the percentage of water bodies that fail for key priority
substances in water and biota (heptachlor, mercury, PAHs, PFOS and PBDEs).

Application of alternative environmental quality standards for water, biota and
sediment

According to the EQSD, Member States may opt to apply EQS for another matrix than the one
specified in the Directive for a given substance (e.g., if the Directive sets an EQS in biota, a
water EQS can be set instead). If they do so, they have to ensure that the EQS they set in the
alternative matrix (or matrices) offers at least the same level of protection as the EQS
established in the Directive.

The 3rd RBMPs for Poland do not mention using the approach described above to assess
status using EQS for alternative matrices.

Use of mixing zones

Article 4 of the EQS Directive provides Member States with the option of designating mixing
zones adjacent to points of discharge in surface waters. Concentrations of priority substances
may exceed the relevant environmental quality standard within such mixing zones if they do
not affect the compliance of the rest of the surface water body with those standards. Member
States that designate mixing zones are required to include within their RBMPs a description of
the approaches and methodologies applied to define such zones, and a description of the
measures taken to reduce the extent of the mixing zones in the future.

71 Amended by Directive 2013/39/EU

72 Brominated diphenylether, Mercury and its compounds, Polyaromatic hydrocarbons (PAH),
Tributyltin,  PFOS, dioxins, hexabromocyclodecane and heptachlor

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No information has been identified to confirm that Poland have made use of mixing zones.

Background concentrations and bioavailability

The EQS Directive stipulates that Member States have the possibility, when assessing the
monitoring results against the environmental quality standard, to take into account:

(a) natural background concentrations for metals and their compounds, if they prevent
compliance with the environmental quality standard, and;

(b) hardness, pH or other water quality parameters that affect the bioavailability of
metals.

The assessment of the 2nd RBMPs comments that seven of the ten RBDs took into account
natural background concentrations for metals where such concentrations prevented
compliance, and that a further nine of the ten RBDs took into account bioavailability when
assessing compliance for metals. No information on these topics could be found in the 3rd
RBMPs.

4.1.3.  Classification of chemical status of surface water bodies

Classification

Figure 4-2 provides an overview of the chemical status for surface water bodies in Poland in
the 1st, 2nd and 3rd RBMPs. This illustrates that under the 1st RBMPs the majority (92%) of all
the water bodies in Poland were in unknown status. For the 2nd RBMPs, the proportion of
unknown status has decreased to 15%. As of the 3rd RBMPs this has increased to 25%,
despite the monitoring network being further expanded. It is unclear why this is the case.

The other major change between the 2nd and 3rd RBMPs is that the number of water bodies in
good chemical status has fallen from 59% to 28%. This large change in chemical status is
associated primarily with uPBT substances, particularly PAHs, but also PBDEs and PFOS.

The 3rd RBMPs state that the assessment was done based on the results of monitoring and
on expert judgement. The 3rd RBMPs comment that grouping approaches have not been used
in Poland. The 3rd RBMPs explain that grouping approaches should only be used where water
bodies are sufficiently similar across a range of different contextual metrics (e.g., levels of
urbanisation), in this case a lack of such information meant that the authority determined it
was inappropriate to use grouping for chemical status assessment.

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Figure 4-2

Chemical status of surface water bodies in Poland in the 1st (2009), 2nd

(2015) and 3rd (2021) RBMPs

Source: Data mining from 3rd RBMPs pdf reporting and 2nd RBMPs assessment.

Confidence in classification

No information has been identified within the 3rd RBMPs to provide an update on the 
confidence in chemical status classification.

Reasons for failing to achieve good chemical status of surface water bodies

The 3rd RBMPs do not provide specific details for the number of water bodies failing good 
chemical status per substance. Instead, the RBMPs provide a narrative for the substances 
which cause the most frequent EQS exceedances. This includes a chart 6.1 in each RBMP 
displaying the proportion of water body types with poor chemical status / EQS exceedance 
based on a sub-set of named substances, primarily uPBT substances. 

As indicated, the majority of the substances causing failure to achieve good chemical status 
are uPBT (as already indicated), particularly PAHs and mercury. Aside from uPBT substances, 
one non-uPBT substance is also identified as being key to exceedances of the EQS. This is 
another member of the PAH family, fluoranthene, which is managed separately within the 
EQSD.

4.2.  Main changes in implementation and progress with

recommendations

The 3rd RBMPs comment that the spatial scale of the monitoring network in Poland has been 
expanded by 16%, now covering 45% of all water bodies. Additionally, Poland states that the 
monitoring programme now covers all 45 priority substances. 

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The 3rd RBMPs do comment that monitoring in biota to support chemical status assessment
has been started but work for long-term trends and surveillance monitoring is not providing
any detailed explanation.

The Commission recommendations based on the 2nd RBMPs analysis were:

● Recommendation: Confidence in the assessment of status for all water categories
should continue to be improved (including territorial waters, whose status should be
assessed), and the proportion of unknown status further reduced. In particular,
monitoring should be performed in a way that provides sufficient temporal resolution
and spatial coverage to classify all water bodies (in combination, if necessary, with
robust grouping / extrapolation methods), in the relevant matrix. If a different matrix or
reduced frequencies are used, the corresponding explanations should be provided, as
required by the Directive.

Assessment: The proportion of water bodies in unknown status has increased in the
3rd RBMPS even though the monitoring network has also been expanded. It should be
noted that between the 2nd and 3rd RBMPs a re-organisation of water bodies has been
undertaken (5649 water bodies in the 2nd RBMP reduced to 4240 water bodies in the
3rd RBMP), which may have caused some disruption and makes direct comparison
more challenging. However, based on the evidence, the number of water bodies in
unknown status at the 2nd RBMP was 847, which increases to 1069 in the 3rd RBMPs.
A reason for why this is the case has not been provided.

A risk-based approach is used to determine the frequency of monitoring. This means
that for priority substances known to exceed EQS or identified as high risk, the specific
substance/s is included in a ‘surveillance (MD)’ monitoring programme with monitoring
undertaken on a monthly basis. For low-risk priority substances or where
concentrations are known not to exceed the EQS the substance/s is included in the
operational (MO) monitoring programme with monitoring once every three years.

Monitoring in territorial waters is now included on a risk-based basis, with substances
included on the surveillance monitoring programme also monitored in territorial waters.
This means that monthly monitoring is conducted in territorial waters for some of the
priority substance list. Information on the confidence of chemical status classification
has not been provided. It is concluded that this recommendation has been partially
fulfilled.

● Recommendation: Poland should further improve trend monitoring to ensure that all
the relevant substances specified in Directive 2008/105/EC are monitored in a way
that provides sufficient spatial coverage and temporal resolution.

● Assessment: The 3rd RBMPs provide only limited information on this topic. The

RBMPs do comment that the operational monitoring (MO) programme is based on a 3
year frequency. But does not specifically mention biota or sediment. There is a

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regulatory implementing act from 2019 regarding biota and sediment, but that relates
to only 3 substances73. This recommendation has been fulfilled.

4.3.   Conclusions on gaps in implementation

The 3rd RBMPs highlight that the spatial scale of monitoring has been expanded, and now
covers 45% of all water bodies nationally. They also comment that monitoring is undertaken
for all 45 priority substances. Monitoring in territorial waters is now also included for those
priority substances in the surveillance monitoring programme (MD). These are all positive
aspects and reflect good progress towards overall compliance of the WFD. However, key
gaps exist :

● The number of water bodies in unknown chemical status has increased between the

2nd and 3rd RBMPs.

  There was no information in any of the 3rd RBMPs about the confidence in

classification of chemical status of water bodies and also trend analysis for priority
substances.

73 Subsequently Poland has confirmed that monitoring in biota and sediment takes place for all 20
substances identified in the EQSD. The first round of reporting was submitted in 2022 via the ReportNet
3 portal. Additional information on trend analysis is not yet available.

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5.  Monitoring, assessment and classification of
quantitative status of groundwater bodies

5.1.  Assessment of implementation and compliance with

WFD requirements

5.1.1.  Monitoring of quantitative status in groundwater

In the 3rd RBMPs, the total number of delineated groundwater bodies in Poland is 174,
increasing from 172 in the 2nd RBMPs74 (1.2% increase). This was a result of splitting two
aquifer complexes that were reported as single GWBs in the 2nd RBMPs. According to the 3rd
RBMPs there is 1 transboundary groundwater body in Poland.

The number of groundwater bodies subject to quantitative monitoring could not be identified
for the 3rd RBMPs, as relevant 3rd RBMPs e-reporting is currently lacking. In the 2nd RBMPs,
167 out of 172 groundwater bodies (i.e., 97.1% of total groundwater bodies) were subject to
quantitative monitoring.

The number of monitoring sites with quantitative monitoring could not be identified for the 3rd
RBMPs, as relevant 3rd RBMPs e-reporting is currently lacking. The number of monitoring
sites for quantitative monitoring was 836 in the 2nd RBMPs.

The number of groundwater bodies identified as drinking water protected areas is 174 in the
3rd RBMPs. In the 2nd RBMPs, 168 groundwater bodies were identified as drinking water
protected areas.

5.1.2.  Assessment of quantitative status for groundwater bodies

The methodology for groundwater quantitative status assessment is described in the 3rd
RBMPs and considers the assessment of water balance, long-term groundwater level trends
and pressure head, as well as the assessment of impacts on GWDTEs and the assessment of
saline or other intrusions.

74 It is noted that Poland reported 178 groundwater bodies to 2nd RBMPs e-reporting. The country
subsequently clarified that the total number of delineated groundwater bodies was 172 for the 2nd
RBMPs.

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Consideration of groundwater associated surface waters and/or groundwater
dependent ecosystems

GWAAEs are reported, but they are not considered in the groundwater quantitative status
assessment in the Vistula RBD (PL2000) and the Oder RBD (PL6000), whose 3rd RBMPs
have been assessed. 75

GWDTEs are reported, and they are considered in the groundwater quantitative status
assessment in the Vistula RBD (PL2000) and the Oder RBD (PL6000), whose 3rd RBMPs
have been assessed.

However, it is noted that no Natura 2000 area has been reported as associated with any
groundwater body (see Topic 15 - Considerations specific to protected areas), which would
imply that none of the reported GWDTEs is part of a designated Natura 2000 area.

Grouping of groundwater bodies

According to the 3rd RBMPs, grouping of groundwater bodies is not used in the assessment of
the quantitative status of groundwater bodies.

5.1.3.  Classification of quantitative status of groundwater bodies

Classification

In the 3rd RBMPs, 159 out of 174 groundwater bodies (i.e., 91.4% of total groundwater bodies)
have been in good quantitative status and 15 groundwater bodies (i.e., 8.6% of total
groundwater bodies) have been in poor quantitative status by 2021 (Figure 5-1). In the 2nd
RBMPs, 13 out of 172 groundwater bodies (i.e., 7.6% of total groundwater bodies) were in
poor quantitative status by 2015.

The above information comes from data mining from 2nd and 3rd RBMPs documents.

75 Poland subsequently informed that the reason for not taking into account GWAAEs in the
assessment of the quantitative status of water bodies is the lack of data on environmental flows for
rivers, which are necessary to perform the relevant test.

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Figure 5-1    Quantitative status of groundwater bodies in 2015 and 2021

Note: The number in parenthesis indicates the total number of groundwater bodies.
Source: Data mining from 3rd RBMPs pdf reporting and 2nd RBMPs assessment

Confidence in classification

The confidence in the classification of quantitative status of GWBs could not be identified, as 
3rd RBMPs e-reporting for Poland is lacking. Therefore, an assessment of the 3rd RBMPs of 
the Oder RBD (PL6000) and Vistula RBD (PL2000) has been conducted, as they cover 97% 
of Polish territory.

According to the assessment of the 3rd RBMPs of the Oder RBD (PL6000) and Vistula RBD 
(PL2000), covering 97% of Polish territory, classification with medium confidence is conducted 
for 143 out of 160 assessments in these two RBDs (i.e. 89.4% of assessments in Oder and 
Vistula RBD). Classification with low confidence is conducted for the remaining 17 out of 160 
assessments (i.e. 10.6% of assessments in Oder and Vistula RBD).

Reasons for failing to achieve good quantitative status of groundwater bodies

The shares of the reasons for failing to achieve good quantitative status of GWBs could not be 
identified, as 3rd RBMPs e-reporting is lacking for Poland.

According to the 3rd RBMPs of the Oder RBD (PL6000) and Vistula RBD (PL2000), which 
cover 97% of Polish territory, the main reason for the failure of good quantitative status is 
lowering of groundwater tables as a result of drainage for mining or as a result of water 
abstraction for public water supply and industry (especially in the Little Vistula region). There 
are also cases where drainage and over-abstraction lead to negative impacts on GWDTEs, as 
well as to saline intrusion, due to ingress or upwelling of saline waters from drained 
groundwater layers.

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5.2.  Main changes in implementation and progress with

recommendations

There are significant changes in the way the WFD is implemented in Poland regarding
groundwater quantitative status.

The total number of delineated groundwater bodies in Poland increased from 172 in the 2nd
RBMPs to 174 in the 3rd RBMPs (1.2% increase). This was a result of splitting two aquifer
complexes that were reported as single GWBs in the 2nd RBMPs.

The number and proportion of groundwater bodies in poor quantitative status has increased
from 13 out of 172 groundwater bodies (i.e., 7.6% of total groundwater bodies) in the 2nd
RBMPs to 15 out of 174 groundwater bodies (i.e., 8.6% of total groundwater bodies) in the 3rd
RBMPs.

No recommendation was included in the 2nd RBMPs regarding monitoring, assessment and
classification of groundwater quantitative status. Therefore, there is no relevant follow-up.

5.3.  Conclusions on gaps in implementation

In the 3rd RBMPs, 15 groundwater bodies (i.e., 8.6% of total groundwater bodies) have been in
poor quantitative status by 2021.

In the Oder and Vistula RBDs, classification with medium confidence has been conducted for
89.4% of the assessments, and with low confidence for the remaining 10.6% of the
assessments.

GWAAEs are not considered in the groundwater quantitative status assessment.

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6.  Monitoring, assessment and classification of
chemical status of groundwater bodies

6.1.  Assessment of implementation and compliance with

WFD requirements

6.1.1.  Monitoring of chemical status in groundwater

As noted previously under Topic 5, in the 3rd RBMPs, the total number of delineated
groundwater bodies in Poland is 174, increasing from 172 in the 2nd RBMPs76 (1.2% increase).
This was a result of splitting two aquifer complexes that were reported as single GWBs in the
2nd RBMPs.  According to the 3rd RBMPs, there is 1 transboundary groundwater body in
Poland.

All groundwater bodies in Poland (i.e. 100.0% of total groundwater bodies) are subject to
chemical monitoring in the 3rd RBMPs. The number of groundwater bodies subject to chemical
monitoring was unclear in the 2nd RBMPs, due to reporting errors77.

The number of groundwater bodies subject to surveillance monitoring has been reported as
174 out of 174 groundwater bodies in the 3rd RBMPs (i.e., 100.0% of total groundwater
bodies). This is an increase since the 2nd RBMPs, when 160 out of 172 groundwater bodies
(i.e., 93.0% of total groundwater bodies) were subject to surveillance monitoring.

The number of monitoring sites with surveillance monitoring could not be identified for the 3rd
RBMPs, as relevant 3rd RBMPs e-reporting is currently lacking. In the 2nd RBMPs, the number
of surveillance monitoring sites was 1172.

76 It is noted that Poland reported 178 groundwater bodies to 2nd RBMPs e-reporting. The country
subsequently clarified that the total number of delineated groundwater bodies was 172 for the 2nd
RBMPs.

77 According to the 2nd RBMPs compliance assessment (p. 103): ”Not all groundwater bodies were
covered by chemical monitoring. There was no chemical monitoring in the Świeża or Ucker RBDs.
Poland subsequently clarified that due to the small area of the Świeża river basin district, the inclusion
of the groundwater monitoring station in its area was planned at a later stage of monitoring works. The
assessment of the basin was carried out as part of the status assessment GWB no. 20 (PLGW700020).
In the area of the Ucker river basin district, there was a fragment of one groundwater, PLGW60003 that
is located on the territory of two river basin districts: the vast majority (97.66%) of the groundwater
body's area was within the Odra river basin district, and 2.34% within the Ucker river basin district. Due
to the small area of the Ucker river basin district, consideration of the groundwater monitoring station in
its area was planned in subsequent stages of monitoring works. The chemical status assessment of
this groundwater body was carried out on the basis of monitoring stations located in the Odra river
basin districts”. It is noted that in the 3rd RBMPs, the Ucker RBD (PL6700) has been merged into the
Oder RBD (PL 6000).

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The number of groundwater bodies subject to operational monitoring has been reported as 43
out of 174 groundwater bodies in the 3rd RBMPs (i.e., 24.7% of total groundwater bodies).
This is an increase since the 2nd RBMPs, when 3978 out of 172 groundwater bodies (i.e.,
22.7% of total groundwater bodies) were subject to operational monitoring.

The number of monitoring sites with operational monitoring could not be identified for the 3rd
RBMPs, as relevant 3rd RBMPs e-reporting is currently lacking. The number of monitoring
sites with operational monitoring was unclear also in the 2nd RBMPs, due to reporting errors.

According to the assessed 3rd RBMPs of the Vistula RBD (PL2000) and the Oder RBD
(PL6000), all substances causing risk of deterioration in chemical status are subject to
monitoring in the 3rd RBMPs. However, it is not clear if all GWD Annex I and Annex II (Part B)
substances and all WFD core parameters (nitrates, ammonium, pH, electrical conductivity and
oxygen) are included in monitoring in all RBDs, as relevant 3rd RBMPs e-reporting is currently
lacking79.

Application of Article 6(3) of the Groundwater Directive on exemptions from
prevent and limit clause

The exemption from the requirement to implement measures to prevent or limit inputs of
pollutants into groundwater, pursuant to Article 6(3) of the GWD, is not applied.

6.1.2.  Assessment of chemical status for groundwater bodies

The methodology for groundwater chemical status assessment is described in the 3rd RBMPs
and considers the assessment of general quality, as well as the assessment of impacts on
GWAAEs, the assessment of impacts on GWDTEs, the assessment of saline or other
intrusions and the assessment of impacts on drinking water protected areas.

General Chemical Assessment

The assessment of the general chemical situation of a groundwater body is conducted based
on the proportion of the total area of the groundwater body represented by monitoring sites
exceeding a groundwater quality standard or threshold value compared to the total area of the
whole groundwater body. Where this is less than 25%, then the GWB is in good chemical
status.

78 It is noted that Poland reported 0 groundwater bodies subject to operational monitoring to 2nd RBMPs
e-reporting. The country subsequently clarified that the total number of groundwater bodies subject to
operational monitoring was 39 in the 2nd RBMPs.

79 Poland subsequently clarified that all GWD Annex I and Annex II (Part B) substances and all WFD
Annex V core parameters (nitrate, ammonium, pH, electrical conductivity and oxygen content) are
included in the monitoring in all RBDs.

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Threshold values

According to the 3rd RBMPs of the Vistula RBD (PL2000) and the Oder RBD (PL6000), which
have been assessed, threshold values have been set for the assessment of chemical status
of groundwater bodies for all substances leading to risk of not meeting environmental
objectives. Furthermore, all GWD Annex II (Part B) substances are included. The threshold
values have not been coordinated with neighbouring countries. Background levels for
naturally occurring substances are considered in the development of the respective threshold
values and in the chemical status assessment.

Trend assessment

A trend assessment and a trend reversal methodology are available, and relevant
assessments have been performed. The starting point for trend reversal has been reported
(75%).

Consideration of groundwater associated surface waters and/ or groundwater
dependent ecosystems

The establishment of threshold values considers the assessment of impacts on GWAAEs and
GWDTEs in the Vistula RBD (PL2000) and the Oder RBD (PL6000), whose 3rd RBMPs have
been assessed.

GWAAEs and GWDTEs are considered in the groundwater chemical status assessment in the
Vistula RBD (PL2000) and the Oder RBD (PL6000), whose 3rd RBMPs have been assessed.

However, it is noted that no Natura 2000 area has been reported as associated with any
groundwater body (see Topic 15 - Considerations specific to protected areas), which would
imply that none of the reported GWDTEs is part of a designated Natura 2000 area.

Consideration of saline or other intrusions

Saline or other intrusions are considered in the groundwater chemical status assessment in
the Vistula RBD (PL2000) and the Oder RBD (PL6000), whose 3rd RBMPs have been
assessed.

Consideration of drinking water protected areas

The assessment of chemical status of groundwater bodies considers the assessment of
impacts on drinking water protected areas in the Vistula RBD (PL2000) and the Oder RBD
(PL6000), whose 3rd RBMPs have been assessed.

Grouping of groundwater bodies

According to the 3rd RBMPs, grouping of groundwater bodies is not used in the assessment of
the chemical status of groundwater bodies.

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6.1.3.  Classification of chemical status of groundwater bodies

Classification

In the 3rd RBMPs, 165 out of 174 groundwater bodies (i.e., 94.8% of total groundwater bodies) 
have been in good chemical status and 9 groundwater bodies (i.e., 5.2% of total groundwater 
bodies) have been in poor chemical status by 2021 (Figure 6-1). In the 2nd RBMPs, 14 out of 
172 groundwater bodies (i.e., 8.1% of total groundwater bodies) were in poor chemical status 
by 2015.

The above information comes from data mining from 2nd and 3rd RBMPs documents.

Figure 6-1 

Chemical status of groundwater bodies in 2015 and 2021

Note: The number in parenthesis indicates the total number of groundwater bodies.
Source: Data mining from 3rd RBMPs pdf reporting and 2nd RBMPs assessment

Confidence in classification

The overall confidence in the assessment of the chemical status of groundwater bodies could 
not be identified for the 3rd RBMPs, as relevant 3rd RBMPs e-reporting is currently lacking.

Reasons for failing to achieve good chemical status of groundwater bodies

The shares of the reasons for failing to achieve good chemical status of GWBs could not be 
identified, as 3rd RBMPs e-reporting is lacking for Poland.

According to the assessment of the 3rd RBMPs of the Oder RBD (PL2000) and Vistula RBD 
(PL6000), which cover 97% of Polish territory, the main reason for the failure of good chemical 
status is the impairment of general water quality as a result of diffuse pollution from urban and 
mining activities, as well as due to saline intrusion, caused by ingress or upwelling of saline 
waters from drained groundwater layers.

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Pollutants causing failure to achieve good chemical status

Based on data mining from the 3rd RBMPs of the Danube RBD (PL1000), Oder RBD (PL6000)
and Vistula RBD (PL2000), the top 5 pollutants causing failure to achieve good chemical
status of groundwater bodies in these RBDs are potassium (2.9% of total groundwater bodies
in these RBDs), nitrate (2.4%), chloride (2.4%), sodium (2.4%) and iron (2.4%).

Pollution with chloride and sodium are indicators of saline intrusion, which is a result of salt
mining activities especially in southern Poland. Pollution with potassium and nitrate originates
from agricultural activities in the plains. Pollution with iron is associated with mining and
industrial activities.

Significant and sustained upward trends were detected for total organic carbon, nitrate,
sulphate, calcium and potassium in the Oder RBD (PL6000), and for potassium, arsenic and
sulphates in the Vistula RBD (PL2000).

6.2.  Main changes in implementation and progress with

recommendations

There are significant changes in the way the WFD is implemented in Poland regarding
groundwater chemical status.

The total number of delineated groundwater bodies in Poland increased from 172 in the 2nd
RBMPs to 174 in the 3rd RBMPs (1.2% increase). This was a result of splitting two aquifer
complexes that were reported as single GWBs in the  2nd RBMPs.

The number and proportion of groundwater bodies in poor chemical status has decreased
from 14 out of 172 groundwater bodies (i.e., 8.1% of total groundwater bodies) in the 2nd
RBMPs to 9 out of 174 groundwater bodies (i.e., 5.2% of total groundwater bodies) in the 3rd
RBMPs.

The Commission recommendations based on the 2nd RBMPs analysis were:

● Recommendation: Further work is required to make the monitoring, assessment and

classification of groundwater status fully compliant with the requirements of the
Groundwater Directive. [The work on aligning national types with those intercalibrated
at the EU level should be completed].

● Assessment: There is significant progress in groundwater monitoring. The number of
groundwater bodies subject to surveillance monitoring has increased from 60 out of
172 groundwater bodies (i.e., 93.0% of total groundwater bodies) in the 2nd RBMPs to
174 out of 174 groundwater bodies (i.e., 100.0% of total groundwater bodies) in the 3rd
RBMPs. The number of groundwater bodies subject to operational monitoring has

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increased from 3980 out of 172 groundwater bodies (i.e., 22.7% of total groundwater
bodies) in the 2nd RBMPs to 43 out of 174 groundwater bodies (i.e., 24.7% of total
groundwater bodies) in the 3rd RBMPs. According to the assessed 3rd RBMPs of the
Vistula RBD (PL2000) and the Oder RBD (PL6000), all substances causing risk of
deterioration in chemical status are subject to monitoring in the 3rd RBMPs. However, it
is not clear, if all GWD Annex I and Annex II (Part B) substances and all WFD core
parameters (nitrate, ammonium, pH, electrical conductivity and oxygen) are included in
the monitoring in all RBDs.81 Threshold values have been set for the assessment of
chemical status of groundwater bodies for all substances leading to risk of not meeting
environmental objectives. Thresholds have been set for all GWD Annex II (Part B)
substances. The assessment of the general chemical situation of a groundwater body
is conducted based on the proportion of the total area of the groundwater body
represented by monitoring sites exceeding a groundwater quality standard or threshold
value compared to the total area of the whole groundwater body. The exemption from
the requirement to implement measures to prevent or limit inputs of pollutants into
groundwater, pursuant to Article 6(3) of the GWD, is not applied.

● Recommendation: On groundwater, a methodology for trend reversal should be in

place.

● Assessment: A trend assessment and a trend reversal methodology are available and
relevant assessments have been performed. The methodologies are described in the
3rd RBMPs and they build upon CIS guidance 18 on groundwater status and trend
assessment. The trends show an upward trends for total organic carbon, nitrate,
sulphate, calcium and potassium in the Oder RBD (PL6000), and for potassium,
arsenic and sulphates in the Vistula RBD (PL2000).

6.3.  Conclusions on gaps in implementation

In the 3rd RBMPs, 9 groundwater bodies (i.e., 5.2% of total groundwater bodies) have been in
poor chemical status by 2021.

The threshold values have not been coordinated with neighbouring countries.

GWAAS, GWDTEs, and saline intrusions have not been considered in the status assessment
of all RBDs.

80 It is noted that Poland reported 0 groundwater bodies subject to operational monitoring to WISE
electronic reporting for the 2nd RBMPs. The country subsequently clarified that the total number of
groundwater bodies subject to operational monitoring was 39 in the 2nd RBMPs.

81 Poland subsequently clarified that all GWD Annex I and Annex II (Part B) substances and all WFD
Annex V core parameters (nitrate, ammonium, pH, electrical conductivity and oxygen content) are
included in the monitoring in all RBDs.

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7.  Designation of heavily modified and artificial water
bodies and definition of good ecological potential

7.1.  Assessment of implementation and compliance with

WFD requirements

7.1.1.  Designation of heavily modified and artificial water bodies

Heavily modified water bodies (HMWBs) are bodies of water which, as a result of physical
alterations by human activity, are substantially changed in character and cannot, therefore,
meet "good ecological status" (GES). Artificial water bodies (AWBs) are water bodies created
by human activity. Instead of "good ecological status", the environmental objective for HMWBs
and for AWBs is good ecological potential (GEP).

Because lack of electronic reporting, this section is covering information provided in the Oder
and Vistula RBMPs.

The Oder RBMP informs that 25% of river water bodies and 20% of lake water bodies are
heavily modified. The Vistula RBMP mentions 15% river water bodies as heavily modified and
informs that 6% of lake water bodies are heavily modified. Information regarding changes
from the 2nd RBMPs has not been found in the reviewed plans, though e-reporting from the 2nd
RBMPs suggests that there were 32% river and 24% lakes heavily modified in the Oder RBD,
and 18% rivers and 4% lakes in the Vistula RBD. In either RBMP, there are no coastal or
transitional HMWBs designated (there weren’t any in the 2nd RBMPs of Oder, while there were
17% coastal water bodies designated as heavily modified in the Vistula RBD). There are 2%
water bodies designated as artificial in the Oder RBD and 1% in the Vistula RBD in the 3rd
RBMPs, which is also a decrease since the 2nd RBMPs. There is no information identified to
explain this change however there is an overall significant change in the number of water
bodies resulting from their re-delineation. Dams are mentioned as physical alterations behind
the designation, with associated use as hydropower or flood protection. Other
hydromorphological pressures include straightening, etc.

Approach for the designation of heavily modified water bodies and artificial
water bodies

The methodology for the designation of heavily modified water bodies is developed on the
national level and includes the assessment of other means to achieve the benefits of the
modifications and significant adverse effects of measures on the use and the wider
environment, where a reference to the relevant CIS guidance is made. This methodology is
based on the analysis of methodological proposals developed in previous planning periods
and experience in their implementation. The purpose of the changes is to take advantage of
simplified assessment of SWB status where possible, and to reduce the scope of experts’
judgement. For designation of river HMWBs, Poland uses the hydromorphological index for

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rivers which measures the degree of deformation from the natural conditions with respect to
hydrological and morphological alteration. Similar indices exist for lakes, transitional, and
coastal water bodies. Information on thresholds of substantial changes in character was not
found in the 3rd RBMPs. An initial part of the designation process is a screening phase which
has been added in the 3rd RBMPs. There is a reference to the methodology document,
however a link is not provided, and no results were found through internet search. It does not
appear from the reviewed documents that Poland uses clear-cut cases to identify HMWBs.

Criteria for the significant adverse effects and if specific thresholds have been
specified

Information has been provided on how the significant adverse effects of restoration measures
on the use and the wider environment (Article 4(3)a). The thresholds have not been found in
the RBMPs.

Checking the beneficial objectives served by the modifications of the heavily
modified water bodies could be achieved by other means

In the RBMP documents for the 3rd RBMPs, beneficial objectives served by modification of the
heavily modified water bodies have been checked to be achieved by other means which are
significantly better environmental option, technically feasible and not disproportionately costly,
though other means were not identified.

7.1.2.  Definition of good ecological potential for heavily modified

and artificial water bodies

The approach used to assess good ecological potential

Good ecological potential (GEP) is defined at a water body level. A method for GEP has been
developed at a national level. For rivers, the GEP boundary value depends on the value of
hydromorphological index for rivers, which describes the degree of hydromorphological
alteration. If there is no alteration, the GEP lower boundary value is equal to the GES lower
boundary value (or the upper value for the moderate ecological status). If the value of the
index is one (maximum alteration), the GEP lower boundary value is equal to the GES
moderate status lower boundary value. For values of index between 0 and 1, the GEP
boundary value is between the upper and lower boundary of the moderate ecological status,
in proportion to the value of the index.  For lakes, a similar parameter sensitive to
hydromorphological alteration is used, equivalent to the hydromorphological index for rivers,
and the GEP value is determined using the same approach as for the rivers. For determining
the hydromorphological index, modelling of possible mitigation and restoration measures is
applied, including an expert judgement of the significance of pressures on each biological
quality elements. Refences to the relevant CIS guidance documents were not found in the
reviewed documents.

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Physico-chemical elements reference values in relation to GEP are prescribed by the national
regulation82.

Biological assessment

Good ecological potential has been defined in terms of biology. The BQEs for defining
maximum ecological potential and good ecological potential include macrophytes and fish for
lakes.

The comparison between good ecological potential and good ecological status

The approach to define GEP makes a direct reference to GES, with the difference between
the two defined by the degree of hydromorphological alteration, as explained above.

Mitigation measures for defining good ecological potential

GEP is a less stringent objective than GES because it allows for the ecological impacts
resulting from those physical alterations that (i) are necessary to support a specified use or (ii)
must be maintained to avoid adverse effects on the wider environment. GEP therefore reflects
the requirement to address other pressures, including physical pressures, not associated with
the specified use, while ensuring that the adverse ecological effects of the physical alteration
can be appropriately mitigated without undermining the benefits they serve.

Mitigation measures for defining good ecological potential have been included in the definition
of hydromorphological alteration as explained in the definition of the GEP. Information on
ecological benefits resulting from these measures has not been found in the reviewed
documents

7.2.  Main changes in implementation and progress with

recommendations

No clear information on the change in the number or percentage of HMWBs has been
found in the reviewed documentation. With respect to the methodology for the
designation, it appears that a screening phase has been added to the methodological
approach.

The relation between the GEP and GES is now quantified through the hydromorphological
index for rivers (and its equivalent for lakes), which as we understand was introduced in 2017,
and therefore is new in the 3rd RBMPs.

82 Journal of Laws from 2021 item 1475:
https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20210001475

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The Commission recommendations based on the 2nd RBMPs analysis were:

● Recommendation: Further efforts are needed to develop a consistent methodology
for the designation of heavily modified water bodies for all relevant water categories
based on WFD compliant monitoring. The assessment of significant adverse effects of
a comprehensive set of mitigation measures on their use or the wider environment and
the lack of significantly better environmental options at water body level needs to be
specifically mentioned in the RBMPs. This will ensure the transparency of the
designation process. Further efforts are needed to define ecological potential in terms
of relevant biological quality elements for all water categories.

● Assessment: The methodology for the designation has been reviewed and improved

in 2019, along with the approach for ecological potential. Information about the
thresholds used in the assessment of significant adverse effects of a comprehensive
set of mitigation measures have not been found. There still appears to be lack of
identification and reporting of significantly better environmental options at the water
body level, although the underlying methodology is now in place. With respect to the
ecological potential, there is now a clear and quantifiable relation to the ecological
status.

7.3.  Conclusions on gaps in implementation

There are gaps with respect to the thresholds for the substantial change in character,
assessment of significant adverse effects of restoration measures and identification and
assessment of better environmental options at the water body level, which needs to be
specifically explained in the RBMPs.

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8.  Environmental objectives and exemptions

8.1.  Assessment of implementation and compliance with

WFD requirements

8.1.1.  Environmental objectives

Environmental objectives are defined in Article 4 of the WFD: it prohibits the deterioration of
status or potential of all water bodies and obliges Member States to take all measures
required with the aim of achieving good water status or potential by 201583. The aim is long-
term sustainable water management based on a high level of protection of the aquatic
environment.

Member States are also required to specify additional environmental objectives and standards
for water bodies in protected areas where these are needed to ensure that the requirements
of the Directives applicable to those protected areas are met. An assessment of such
additional objectives is provided in Topic 15 of this document.

8.1.2.  Exemptions

Where environmental objectives have not yet been achieved, Article 4 exemptions can be
applied if the respective conditions are met, and the required justifications are provided in the
RBMPs.

Article 4(4) allows for time exemptions for two subsequent RBMP cycles, i.e. until the 22nd of
December 2027 at the latest (date by which the 4th RBMPs should be adopted) with the
exception of exemptions which are put forward on the grounds of natural conditions, which
can run beyond 2027. For compliance with the Environmental Quality Standards established
or amended by Directive 2013/39/EC (amending Directive 2008/105/EC or EQSD), time
extensions can run beyond 2027.

Article 4(5) allows for a ‘lowering of objectives’ for certain water bodies so affected by
sustainable human development activity or with natural conditions such as to make it
infeasible or disproportionately costly to achieve good status or good potential. This is subject
to demonstrating compliance with the criteria set out in that provision, no further deterioration
below the lowered objective, and a six yearly revision of the objectives.

Article 4(6) allows for temporary deterioration in the status of bodies of water if this is the
result of circumstances of natural cause or force majeure which are exceptional or could not
reasonably have been foreseen and all conditions set out in that provision have been met.

83 For priority substances newly introduced by Directive 2013/39/EU, good status should be reached by
2027, and for the 2008 priority substances, for which the Environmental Quality Standards were revised
by Directive 2013/39/EU, good status should be reached in 2021.

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Article 4(7) allows for new projects / modifications to result in deterioration of status or
potential or to prevent the achievement of good status or good potential. This is subject to
demonstrating compliance in the RBMPs, with the criteria set out in this provision.

Article 4(4) exemptions may be justified by disproportionate cost, technical feasibility or
natural conditions, and Article 4(5) by disproportionate cost or infeasibility.

Application of Article 4(4)

In the 3rd RBMPs, a significant number of Article 4(4) exemptions have been applied.

In Poland, 825 SWBs (19%) have been exempted under Article 4(4) on grounds of technical
infeasibility and / or disproportionate costs and 3,210 SWBs (76%) on grounds of natural
conditions. Furthermore, 10 GWBs (6%) have been exempted on grounds of natural
conditions.

Based on an assessment of the Oder and Vistula RBMPs84, the following conclusions can be
drawn as regards the implementation of Article 4(4) exemptions in these RBDs:

● In the Oder RBD, 343 surface water bodies (19.9% of all SWBs in the Oder RBD) have

been exempted in the 3rd RBMP on the grounds of technical feasibility and / or
disproportionate costs and 1322 (around 77% of all SWBs in the Oder RBD) on the
grounds of natural conditions (see page 194 of the 3rd Oder RBMP);

● In the Oder RBD, 7 groundwater bodies (10.6% of all GWBs in the Oder RBD) have

been exempted  on the grounds of natural conditions;

● In the Vistula RBD, 426 surface water bodies (18.9% of all SWBs in the Vistula RBD)
have been exempted on the grounds of technical feasibility and / or disproportionate
costs and 1709 on the grounds of natural conditions (around 76% of all SWBs in the
Vistula RBD) (see page 201 of the 3rd Vistula RBMP); and

● In the Vistula RBD, 2 groundwater bodies (around 2.1% of all GWBs in the Vistula

RBD)  have been exempted  on the grounds of natural conditions.

In general, the exemptions under Article 4(4) have been applied where timely achievement of
good status / potential could not be ensured for reasons of technical feasibility,
disproportionate cost, or natural conditions. Section 8.4 of both the Oder and Vistula 3rd RBMP
reports that exemptions under Article 4(4) that postpone the deadline for achieving the
environmental objectives of the WFD have been applied only if any of the following conditions
are met:

● Due to technical barriers, the scale of required improvements can only be achieved in

stages which extend over the prescribed time;

● The completion of improvements would be disproportionately expensive; and

● The natural conditions of the water body do not allow the condition of the water body to

improve over time.

84 in the absence of electronic reporting, it has not been possible to draw conclusions for all RBDs

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Except for cases where the exemption is due to natural conditions, the exemptions have an
explicit time-limit and can only be extended two times, for the last time in the (current) 3rd
RBMPs. Section 8.4 of both the Oder and Vistula 3rd RBMP reports that the time horizon is
different for listed substances under Directive 2013/39/EU amending the WFD and the EQSD.
12 new substances have been added to the list of environmental quality standards, and for
them the environmental objective can be postponed until 2039 on the basis of any of the three
conditions listed above.

The assessment of the fulfilment of the conditions for applying exemptions has been carried
out for water bodies with below good status / potential. For the water bodies that were
classified without monitoring data, or using a combined approach, an analysis of the
significance of pressures has been carried out, which allowed for the identification of those
water bodies whose environmental objectives are highly likely to be threatened. Consequently,
if the assessment of the ecological status / potential shows less than good status, the water
body has been selected as a candidate for time limited exemption.

The approach explained above to the implementation of Article 4(4) exemptions is set out in
Section 8.4 of the 3rd RBMPs along with the number of water bodies exempted under Article
4(4). The section also presents a decision diagram that the RBDs applied to decide which
water bodies would need an exemption and whether this exemption should be provided under
Article 4(4) or Article 4(5). The diagram explains that if a programme/set of actions could
eventually lead to the achievement of good status, exemptions under Article 4(4) should be
applied. More specifically, if the programme including associated costs and the natural
conditions of the water body allow for a timely achievement of good status, the diagram points
to setting an Article 4(4) exemption until 2027. If achieving the goals of the actions/programme
would be disproportionately costly, technically infeasible during the timeframe, and/or the
natural conditions of the water body do not allow to achieve good status, the diagram also
points towards Article 4(4) exemptions. However, the diagram specifies that exemptions
beyond 2027 are only possible when natural conditions make it infeasible to reach
environmental objectives within the timeframe or when the reason for failure to achieve the
environmental objectives is pollution from priority substances as introduced by Directive
2013/39/EU (for which the cut-off date of achieving the environmental objectives is 2039).

The justifications for the exemption per individual water body are provided in more detail in
Annex 18 of the RBMPs (with long paragraphs describing the exemption for each water body).

Application of Article 4(5)

In the 3rd RBMPs, a significant number of Article 4(5) exemptions have been applied.

In Poland, 2,209 SWBs (52%) have been exempted under Article 4(5) on grounds of other
means and / or disproportionate costs, and 503 SWBs (12%) on grounds of natural
conditions. Furthermore, 9 GWBs (5%) have been exempted on grounds of natural conditions.

Based on an assessment of the 3rd RBMPs of the Vistula and Oder RBDs, the following
conclusions on the implementation of Article 4(5) exemptions can be drawn:

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● In the Oder RBD, 892 surface water bodies (51.8% of all SWBs in the Oder RBD have
been exempted on the grounds of infeasibility and / or disproportionate cost), and 239
SWBs (13.9% of all SWBs in the Oder RBD) for reason of natural conditions being
such as to make it infeasible or disproportionately costly to achieve good status (p. 194
of the 3rd RBMP);

● In the Oder RBD, 6 groundwater bodies ( 9% of all GWBs in the Oder RBD) have been

exempted on the grounds of infeasibility and / or disproportionate cost and 7
groundwater bodies (10.6% of all GWBs in the Oder RBD) have been exempted on the
grounds of natural conditions;

● In the Vistula RBD, 1216 surface water bodies (54% of all SWBs in the Vistula RBD)

have been exempted on the grounds of infeasibility and / or disproportionate cost, and
259 (11.5% of all SWBs in the Vistula RBD) on the grounds of natural conditions
(p.201 of the 3rd RBMP); and

● 7 groundwater bodies have been exempted in the Vistula RBD  on the grounds of

infeasibility and / or disproportionate cost (7.4% of all GWBs in the Vistula RBD), and 2
on the grounds of natural conditions 2.1% of all GWBs in the Vistula RBD).

As reported in Section 8.4 of the 3rd RBMPs for both the Oder and Vistula RBMP, exemptions
under Article 4(5) in Poland have been applied in water bodies where natural conditions or
human activities:

● do not allow the achievement of good status / potential; or

● where there is no technically feasible alternative to an anthropogenic pressure that
satisfies the current socio-economic needs (or if there is, its implementation would
create disproportionally high costs in relation to the expected benefits).

The water bodies where this type of exemption has been applied include:

● those whose condition has been assessed as poor but, due to the projected

effectiveness of the action programmes (as per the decision diagram explained below),
forecasts show the possibility of achieving set environmental objectives by 2027 (or
2039 considering the priority substances introduced by Directive 2013/39/EU); or

● those which are unmonitored and are under pressure but the projected effectiveness

of the action programmes assumes that the achievement of the environmental
objectives will take place after 2027.

And for which it has been found that:

● there are natural conditions that permanently prevent the achievement of good status;

or

● there is a lack of desired effectiveness in past remedial actions applied to the water
body or a lack of alternative to human activities that meet important socio-economic
needs.

The approach to the implementation of Article 4(5) exemptions is set out in Section 8.4 of the
3rd RBMPs along with the number of water bodies exempted under Article 4(5). The section
also presents a decision diagram that the RBDs applied to decide which water bodies would
need an exemption and whether this exemption should be provided under Article 4(4) or

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Article 4(5). The diagram explains that if a programme/set of actions could not lead to the
achievement of good status within the required timeframe, exemptions under Article 4(5) could
be put in place. More specifically, the diagram specifies that:

● if human activity or natural conditions prevent the achievement of good status or would

create disproportionately large costs;

● if the socio-economic needs of the human activities cannot be met with other means

that are a significantly better environmental option or if those means result in
disproportionately large costs; and

● if there are impacts that cannot reasonably be avoided as a result of human activity or

pollution that prevents the achievement of good status;

then exemptions under Article 4(5) can be applied.

The justifications for the exemption per individual water body are provided in more detail in
Annex 18 of the RBMPs (with long paragraphs describing the exemption for each water body).

This assessment covers the analysis of technical feasibility/ infeasibility and/or
disproportionate costs for individual water bodies. 85

Application of Article 4(6)

No exemptions according to Article 4(6) have been applied in the 2nd and 3rd RBMPs.

Section 8.5 of the 3rd RBMPs lists a detailed set of criteria for the future application of this
exemption, including specific definitions of prolonged drought, extreme flood, unforeseen
failure (of an installation / plant) and force majeure.

Application of Article 4(7)

Article 4(7) was applied in the 1st and 2nd RBMPs and has also been applied in the two 3rd
RBMPs assessed, namely for the Vistula and Oder RBDs. Section 16 of these RBMPs (see p
363 in the Oder RBMP and p. 368 in the Vistula RBMP) provides a summary of new
investment projects assessed in compliance with national laws and with Article 4(7) of the
WFD. In the Oder and Vistula 3rd RBMPs, 124 and 120 investment projects respectively have
been reported as those meeting all the conditions, allowing for exemptions from the set
environmental objectives. Most new development projects in both RBDs are planned until
2026, but in Oder, there is an investment project planned until 2043. Annex 10 to the Oder
and Vistula 3rd RBMPs present the final list of investments with justifications for meeting the
requirements set out in Article 4(7) of the WFD. The Annex provides detailed information for
each project in each water body detailing the impact on the status of the water body,
mitigation measures, the assessment of overriding public interests, and the possible presence

85 Poland subsequently clarified that methodology of the assessment and application of Article 4(4) and
4(5) exemptions will be available via electronic reporting and that Poland has developed a detailed
methodology for both types of exemptions with clear distinction between them.

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of better alternative environmental options. Further 10 projects are subject to the Article 4(7)
exemption in the Pregola RBD.

Application of Article 6(3) of the Groundwater Directive

No exemptions according to Article 6(3) of the Groundwater Directive86 were applied in the 2nd
RBMPs and have also not been applied in the 3rd RBMPs.

8.2.  Main changes in implementation and progress with

recommendations

In the 3rd RBMPs (of the Oder and Vistula RBDs), Article 4(4) exemptions have continued to
be applied extensively as well as Article 4(5) and 4(7) exemptions. The absence of 3rd RBMP
e-reporting prevents comparison of the numbers of exemptions applied in the 2nd and 3rd
RBMPs. However, the reporting on exemptions in the 3rd RBMPs has improved with
information detailed at the water body level included in Annexes 10 and 18 of the RBMPs.

The Commission recommendations based on the 2nd RBMPs analysis were:

● Recommendation: Poland should continue to further improve the methodology and
justifications for the assessment and application of Article 4(4) and 4(5) exemptions.
The approach for the application of these exemptions needs to be described in more
detail and made transparent in the RBMPs. Criteria for the application of Article 4(4)
need to be clearly distinguished from the criteria applied for Article 4(5) in relation to
technical feasibility and disproportionate costs.

● Assessment: Section 8.4 of the 3rd RBMPs sets out the approach to granting

exemptions in accordance with the Article 4(4) and 4(5) distinguishing between the two
types of exemptions. Annex 18 of the 3rd RBMPs reports the results of the assessment
for individual water bodies and provides water body-specific and detailed explanation
of each exemption applied. This includes the assessment of socioeconomic needs
served by such human activity that cannot be achieved by other means, which are a
significantly better environmental option not entailing disproportionate costs for Article
4(5). This assessment also covers the analysis of technical feasibility/ infeasibility
and/or disproportionate costs for individual water bodies, but the methodology defining

86 Directive 2006/118/EC of the European Parliament and of the Council of 12 December 2006 on the
protection of groundwater against pollution and deterioration
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02006L0118-20140711

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the criteria for “technical feasibility/infeasibility” and “disproportionate costs”  does not
appear to be reported in the RBMPs87 of the Vistula and Oder RBDs88.

● Recommendation: A significant number of projects has been reported to meet all the
requirements as outlined in WFD Article 4(7). Poland needs to ensure that the use of
exemptions under Article 4(7) is based on a thorough assessment of all the steps as
required by the WFD, in particular an assessment of whether the project is of
overriding public interest and whether the benefits to society outweigh the
environmental degradation, and the absence of real alternatives that would be a better
environmental option. Furthermore, these projects may only be carried out when all
practicable measures are taken to mitigate the adverse impact on the status / potential
of the water bodies.

● Assessment: Article 4(7) exemptions have been applied in the 3rd RBMPs. The

RBMPs report on the new modifications exempted with detailed, and water body-
specific information presented in  Annex 10 to the 3rd RBMPs. The Annex provides
detailed information for individual projects in each water body detailing the impact on
the status of the water body, mitigation measures and the assessment of overriding
public interests and better environmental options89.

87 Poland subsequently clarified that methodology of the assessment and application of Article 4(4) and
4(5) exemptions will be available via electronic reporting and that Poland has developed a detailed
methodology for both types of exemptions with clear distinction between them.

88 Poland has provided additional information explaining that Article 4(4) justification criteria include:
technical feasibility – information from the analyses accompanying the development of the PoM;
disproportionate cost – information from the economic analyses accompanying the development of
the PoM; and natural conditions do not allow for timely improvement of the status of water bodies–
expert assessment based on literature data on temporal variability in the transformation of
environmental elements, effectiveness of restoration, reversibility of negative impacts, etc.; risks
associated with climate change. For Art 4(5) criteria include: infeasibility & disproportionate costs -
information obtained on the basis of technical and economic analyses accompanying the
development of the PoM. The assessment also considers whether ecological or socio-economic
needs satisfied by such human activity cannot be achieved by other means, which are a much
more favourable environmental option, not causing disproportionate costs – information obtained
on the basis of technical and economic analyses accompanying the development of the PoM. And
lastly, for surface waters, whether the best possible ecological and chemical status is achieved
under the influences that could not be rationally avoided as a result of the nature of human activity
or pollution; for groundwater, whether the smallest possible changes in the good status of
groundwater occur, under the influences that could not be rationally avoided as a result of the
nature of human activity or pollution – information based on the assessment of the effectiveness of
implementation.

89 Poland has subsequently explained that every new investment or action in Poland that may impact
environmental goals undergoes a water law assessment procedure as established by the Water
Law Act. According to these regulations, if the competent authority determines that a planned
investment or action negatively affects the possibility of achieving environmental goals, it imposes
an obligation, through a decision, to submit documents confirming compliance with the conditions
specified in Water Law Act. These conditions include: 1) taking all necessary actions to mitigate the
effects of negative impacts on the state of uniform water bodies. 2) justification of the reasons for

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8.3.  Conclusions on gaps in implementation

Article 4 exemptions have been applied extensively in the 3rd RBMPs with rather complete
and detailed analysis reported for individual water bodies (Annex 18). However, no explicit
definition/criteria appear to be reported in the 3rd RBMPs of Vistula and Oder RBDs (Chapter
8.4) for “technical feasibility” (Article 4(4)/” infeasibility” (Article 4(5) and “disproportionate
costs”90.

changes based on overriding public interest, where positive effects related to health protection,
safety, and sustainable development outweigh the benefits to society and the environment
resulting from achieving environmental goals; and 3) ensuring that the anticipated benefits arising
from the changes and actions described in points 1 and 2 cannot be achieved through significantly
more favourable alternative measures from an environmental perspective due to technical
feasibility constraints or disproportionately high costs. If the analysis of the submitted documents
does not confirm compliance with these conditions, the competent authority responsible for water
assessments refuses to issue a water law assessment. In such cases, the investment or action
cannot be carried out.

90 Poland subsequently clarified that methodology of the assessment and application of Article 4(4) and
4(5) exemptions will be available via electronic reporting and that Poland has developed a detailed
methodology for both types of exemptions with clear distinction between them.

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9.  Programme of measures

The Key Types of Measure (KTM) referred to in this section are groups of measures identified
by Member States in the programmes of measures (PoM), which target to tackle the same
pressures, or which have the same purpose. The individual measures included in the PoM
(being part of the RBMP) are grouped into KTMs for the purpose of reporting. The same
individual measure can be part of more than one KTM because it may be multi-purpose, but
also because the KTMs are not completely independent silos. KTMs have been introduced to
simplify the reporting of measures and to reduce the very large number of supplementary
measures reported by some Member States (WFD Reporting Guidance 2022).

‘Basic measures’ - listed in Article 11(3)(a) WFD - are the minimum measures to be complied
with, while ‘supplementary measures’ - referred to in Article 11(4) WFD - are those measures
designed and implemented in addition to the basic measures, with the aim at achieving the
objectives established pursuant to Article 4.

A KTM may be one national measure, but it would typically comprise more than one national
measure. The 26 predefined KTMs (including KTM99) are listed in the WFD Reporting
Guidance 202291.

The KTMs should be fully implemented and made operational within the RBMP planning
period to address specific pressures or chemical substances and achieve the environmental
objectives.

9.1.  Assessment of implementation and compliance with

WFD requirements

9.1.1.  General issues

An indication as to whether or not measures will be fully implemented and made operational is
when they have been reported to tackle significant pressures (at the KTM level). Significant
pressures are also reported at the water body level. It would therefore be expected that there
would be measures planned in the RBMP to tackle all significant pressures.

3rd RBMPs for Poland report measures for each water body. The 3rd RBMPs also report on
KTMs used per water body while indicating the type of pressures (e.g. chemical pressures on
groundwater and surface water bodies). However, there is no clear allocation of KTMs to
priority substances and groundwater pollutants causing failure in the 3rd RBMPs. Based on
RBMP document mining of the Vistula and Oder RBMPs, Poland has not defined any

91 WFD Reporting Guidance:
https://cdr.eionet.europa.eu/help/WFD/WFD_715_2022/Guidance%20documents/WFD%20Descriptive
%20Reporting%20Guidance.pdf

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quantitative indicators on the expected gaps to achieve good status by 2021 or 2027,
although all pressures have been clearly linked to their measures. It should, however, be
noted that 3rd RBMPs (e.g. Chapter 9 for Vistula RBD) reports an assessment of progress i.e.
for each water body type (e.g. rivers) it presents a table with changes of status during the 2nd
RBMP and a table with the expected progress for the 3rd RBMP.

In the 3rd RBMPs, Poland has assigned 171 various national measures for surface and
groundwater bodies which are applied in both selected RBMPs for in-depth assessment
(Vistula and Oder RBDs). The key sectors for which national measures have been applied are
industries (25.6% of all national measures); municipal economy (20.3% of all national
measures); agriculture (14.5% of all national measures); hydromorphological pressures
(11.6% of all national measures); habitat protection (11% of all national measures); restoring
hydrological conditions (9.9% of all national measures); monitoring and evaluation (9.3% of all
national measures); control and supervising activities (5.2% of all national measures);
organisational and educational activities (2.3% of all national measures); research and
development projects (1.2% of all national measures); and improving  water body connectivity
(1.2% of all national measures).

Qualitative cost-effectiveness analysis of measures

Cost-effectiveness analysis is an appraisal technique that provides a ranking of alternative
measures on the basis of their costs and effectiveness, where the most cost-effective has the
highest ranking. Poland appears to use the same approach for their cost-effectiveness
analysis in all their 3rd RBMPs (Chapter 11 of the RBMPs). Although, the significant
assumptions of the analysis are not highlighted, the analysis appears to score each measure
on a 5-point scale as regards the following qualitative criteria the effectiveness of actions
(Ks)92; the feasibility of implementation of the measure until 2027 (Kr); the number of
pressures to be reduced; and the time it takes for the action to be effective.

Measures are compared against these qualitative criteria above (see Figure 11-1).  The
scores are then combined to an aggregate score for an individual measure (or set of
measures) represented by the efficiency index (Ke) on a 5-point scale, with ‘1’ being very low
efficiency, to ‘5’ being a very high efficiency (see Chapter 11 of the 3rd RBMPs). The results
are then shown in a table highlighting the results of the “cost-effectiveness analysis” for both
surface water and groundwater measures (Chapter 11). The approach to cost-effectiveness
analysis is set out in the Figure 11-1 of the 3rd RBMPs – implementability index (Kw is
calculated as Kw=KsxKr (technical effectiveness x feasibility to implement measure by 2027)
and efficiency index (Ke) is calculated taking into account the implementability index (Kw) and
number of pressures the measure addresses and time expected to achieve the result. In the
next step, the costs of measures are calculated, and a combined cost-effectiveness matrix is
developed. However, no specific details are provided, and the description is not clear how

92 The effectiveness of actions in relation to the implementation of WFD objectives (Ks1), environmental
objectives of protected areas and species (Ks2), and the impact of the measure on mitigating the
effects of climate change (Ks3)

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costs are taken on board in the method; and how exactly the outcomes support the selection
of measures.

Financing of measures

A critical factor in the success of the implementation of the PoM is the availability of funding to
support the investments required. Funding has been spread across all RBDs in Poland. Table
9.1 reports on the funding in each of the 3rd RBMPs.

For example, the costs of measures in the Vistula RBD total to 14,611.7 million PLN, and in
the Oder RBD the costs are estimated at 7,714.23 million PLN.

Table 9.1 shows the estimated funding for measures in Poland93.

Table 9.1 Estimated funding of measures in Poland

RBD

Estimated
funding
(PLN)

National
funding
from
own
budget
(%)

EU
funding /
other
national
funds
(%)

% of
funding
that is
secured
for
measures
to be
achieved
by 2024

% of
funding
that is
secured
for
measures
to be
achieved
by 2027

PL1000

70.28
million
(16.16
million EUR)

29%

71%

21%

0%

PL2000

(Vistula)

14.6 billion
PLN (3.4
billion EUR)

42%

58%

34%

1%

Name of EU programme /
other national funds

LIFE programme / National
Fund for Environmental
Protection and Water
Management / voivodeship
fund for environmental
protection and water
management

LIFE programme / National
Fund for Environmental
Protection and Water
Management / voivodeship
fund for environmental
protection and water
management

93 as of the 14th of December 2024 1 PLN=0.23 EUR

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RBD

Estimated
funding
(PLN)

National
funding
from
own
budget
(%)

EU
funding /
other
national
funds
(%)

% of
funding
that is
secured
for
measures
to be
achieved
by 2024

% of
funding
that is
secured
for
measures
to be
achieved
by 2027

PL3000

0.24 million
PLN
(0.06 million
EUR)

50%

50%

10%

0%

PL4000

n/a

n/a

n/a

n/a

n/a

PL5000

5.79 million
PLN
(13.3 million
EUR)

44%

56%

22%

0%

99

Name of EU programme /
other national funds

LIFE programme / National
Fund for Environmental
Protection and Water
Management / voivodeship
fund for environmental
protection and water
management

There are two measures to
be funded, this depends on
the time and scope but
could come from own
funds, EU funds: European
Regional Development
Fund (ERDF), European
Agricultural Fund for Rural
Development (EAFRD),
LIFE

Programme, National Fund
for Environmental
Protection and Water
Management / voivodeship
fund for environmental
protection and water
management or the EEA
Financial Mechanism /
Norwegian Financial
Mechanism.

LIFE programme / National
Fund for Environmental
Protection and Water
Management / voivodeship
fund for environmental
protection and water
management

Assessment of the third River Basin Management Plans under the Water Framework Directive
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National
funding
from
own
budget
(%)

EU
funding /
other
national
funds
(%)

% of
funding
that is
secured
for
measures
to be
achieved
by 2024

% of
funding
that is
secured
for
measures
to be
achieved
by 2027

31%

69%

38%

1%

51%

49%

23%

1%

31%

69%

54%

0.3%

RBD

Estimated
funding
(PLN)

PL6000

(Oder)

7.71 billion
PLN
(1.8 billion
EUR)

PL7000

238.5
million PLN
(55.0 million
EUR)

PL8000

44.19
million PLN
(10.2 million
EUR)

Name of EU programme /
other national funds

LIFE programme / National
Fund for Environmental
Protection and Water
Management / voivodeship
fund for environmental
protection and water
management

LIFE programme / National
Fund for Environmental
Protection and Water
Management / voivodeship
fund for environmental
protection and water
management

LIFE programme / National
Fund for Environmental
Protection and Water
Management / voivodeship
fund for environmental
protection and water
management

PL9000

The RBMP uploaded to Eionet had an error leading to the information on financing to not
have been uploaded.

Total funding

22.7 billion PLN (5.22 billion
EUR)94

Source: extracted from RBMP documents for the 3rd RBMPs

In all of the 3rd RBMPs, information is provided on when measures should be achieved under
the assumption that funding becomes available on time. However, the table above indicates
that while the source of funding has been identified, it has not necessarily been fully secured
in all cases.

94 Not including PL9000 or PL4000 costs.

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Co-ordination with the other Directives

For the Floods Directive, Poland has explicitly reported that it has used the recommendations
and comments of the European Commission to update and improve their measures when
developing their catalogues of measures.

For the Marine Strategy Framework Directive, Poland has developed the ‘National Marine
Water Protection Programme’, which has been developed as part of the planning cycle of the
MSFD. However, no further information can be found on the inclusion of the MSFD objectives
for coastal measures under the WFD, with only a brief mention that the mutual relationship
between requirements of the WFD and MSFD being defined to avoid duplications of
measures. Therefore, without explicitly mentioning the MSFD/WFD, the main actions of the
‘National Marine Water Protection Programme’ to protect coastal and transitional waters
include: Improvement of sewage management systems;

● Implementation of the “KPOÿK” (National Municipal Wastewater Treatment

Programme) in areas adjacent to coastal and transitional waters;

● Limiting the spread of pollution;

● Restoring hydrological conditions, and protecting ecosystems/biodiversity;

● Improving the water conditions and protecting ecosystems that are dependent on
water, including improving morphological conditions and maintaining the biological
conditions, and improving fish migration; and

● Implementation of measures resulting from the plans for the upholding of protected

areas.

The indirect actions to protect the coastal and transitional waters include:

● Limiting nitrogen and phosphorus loads from agriculture from entering surface waters;

● Carrying out legal and educational activities for both the analysis of land development

on coastal areas, and the potential land purchases needed in areas at risk of
landslides.

Prioritisation of measures

In Poland, there is no explicit reporting on the prioritisation of measures in the 3rd RBMPs,
despite the main drivers of the measures being mentioned.

The planning of measures in the 3rd RBMPs lists the following aspects of the overall set of
measures, without clear priority indication, partly because it concerns basic measures, and
partly because the listed items do not explicitly indicate the relative priority overall:

● Flood risk management plans/ The instruments supporting the updating of FRMPs

● Surface water restoration programmes;

● Plans to counteract/mitigate the impacts of drought / The implementation of activities

from the 2020 draft of the Act on investments for counteracting drought/water scarcity;

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● Municipal sewage treatment programmes95;

● The action programme aimed at reducing nitrate pollution from agricultural sources,
and preventing further pollution / Recommendations of good agricultural practices
against nitrate pollution / Reports on the implementation of the Nitrates Directive;

● Marine water protection programme and its updates / Marine Waters Monitoring
Programme / Update of the preliminary assessment of the state of the marine
environment / Evaluation of the degree of achievement of environmental objectives for
coastal and transitional water bodies / Report to the European Commission on the
progress in the implementation of the National Marine Water Protection Programme;

● Water maintenance plans developed by Regional Water Management Boards;

● Areas of protection for habitat and species where maintenance / improvement of water

status is an important factor in their protection;

● The analysis of significant anthropogenic impacts and their risk of not achieving

environmental goals;

● Evaluation of progress in the implementation of action programmes for surface and
groundwater resulting from the update of the National Water and Environmental
Programme;

● National Environment Monitoring Programme;

● The Evaluation of the  National Municipal Wastewater Treatment Programme;

● Planned activities on land reclamation from lakes (with water permits) / materials and
information from maritime offices / the register on water use and fees for permit
holders; and

● The Pollutant Release and Transfer Register.

The 3rd RBMPs state that all planned measures have been assessed on their feasibility (Kr),
effectiveness (Ke) and cost-effectiveness, and defined based on these factors (see Chapter
11 of the 3rd RBMPs), but it is not entirely clear how exactly costs are taken on board and how
exactly the outcomes of the cost-effectiveness analysis support the selection of measures.

Measures related to other significant pressures

When looking at the measures planned in Poland, none of them cover measures related to
other significant pressures. The measures have been planned for river, lake, coastal and
transitional surface water bodies and groundwater bodies, but the measures applied to them
do not cover other significant pressures. There is mention of measures related to factors such
a species protection, but this is not described in detail.

9.1.2.  Mapping of national measures to Key Types of Measure

The KTMs are expected to deliver the bulk of the improvements through reduction in
pressures required to achieve WFD environmental objectives. Member States are required to

95  The information used for planning the measures of the 3rd RBMPs is based on the materials
submitted for public consultation as part of the Strategic Impact Assessment on the environment in the
sixth update of the National Municipal Wastewater Treatment Programme

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report on the national measures associated with the KTMs, and whether the national
measures are basic (Article 11(3)(a) or Article 11(3)(b-l)) or supplementary (Article 11(4)).

In Poland, out of the 171 national measures, 115 (67%) are basic measures, and 56 (33%)
are supplementary measures. 97 (56%) are extensions to previous measures, and 74 (44%)
are new measures96. The national catalogue of measures includes a description of the action,
the legal basis for the action, indication of the units responsible for its implementation,
determination of the type of action (basic measure, supplementary measure) along with the
specification of the implementation schedule for a given measure. 91.9% of national
measures are ongoing. Table 9.2 shows the number of the measures in each RBMP.

The Annexes to the 3rd RBMPs report on measures planned for each water body while
indicating the type of pressures (e.g. chemical pressures on groundwater and surface water
bodies) and KTM code.  Further details will be available in the accompanying 3rd RBMP e-
reporting.

Table 9.2 The number of basic and supplementary measures as well as new
measures by water body type in the 3rd RBMPs of Poland

RBMP

Water body type

No. of basic
measures

No. of
supplementary
measures

No. of new
measures

Rivers

20

12

Not mentioned

Reservoirs

Not applicable

Not applicable

Not applicable

PL1000

Lakes

Not applicable

Not applicable

Not applicable

Coastal /
transitional

Not applicable

Not applicable

Not applicable

Groundwater

8

28

34

Rivers

6,264

3,839

Not mentioned

PL2000

Reservoirs

48

Lakes

1,241

47

698

Not mentioned

Not mentioned

96 This is not comparable to the 2nd RBMP due to the number of applications of the national measures
not being specified. In the 2nd RBMP, there were 1,549 national basic and supplementary measures.
The electronic reporting will provide further clarification on changes in applied national measures.

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RBMP

Water body type

No. of basic
measures

No. of
supplementary
measures

No. of new
measures

Coastal /
transitional

Groundwater

Rivers

26

92

20

24

164

12

Not mentioned

194

Not mentioned

Reservoirs

Not applicable

Not applicable

Not applicable

PL3000

Lakes

9

15

Not mentioned

Coastal/transitional

Not applicable

Not applicable

Not applicable

Groundwater

Rivers

0

20

0

12

0

Not mentioned

Reservoirs

Not applicable

Not applicable

Not applicable

PL4000

Lakes

Not applicable

Not applicable

Not applicable

Coastal /
transitional

Groundwater

Rivers

Not applicable

Not applicable

Not applicable

0

20

0

12

0

Not mentioned

Reservoirs

Not applicable

Not applicable

Not applicable

PL5000

Lakes

Not applicable

Not applicable

Not applicable

Coastal /
transitional

Groundwater

Rivers

Reservoirs

Not applicable

Not applicable

Not applicable

9

20

6

28

12

9

34

Not mentioned

Not mentioned

PL6000

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RBMP

Water body type

No. of basic
measures

No. of
supplementary
measures

No. of new
measures

Lakes

Coastal /
transitional

Groundwater

9

3

9

Rivers / reservoirs

20

Lakes

9

15

9

28

12

15

Not mentioned

Not mentioned

0

Not mentioned

Not mentioned

PL7000

Coastal /
transitional

Groundwater

Rivers

Not applicable

Not applicable

Not applicable

9

20

28

12

34

Reservoirs

Not applicable

Not applicable

Not applicable

PL8000

Lakes

9

15

Not mentioned

Coastal /
transitional

Not applicable

Not applicable

Not applicable

Groundwater

0

0

0

PL9000

The RBMP uploaded to Eionet had an error which meant the relevant information
on measures were not uploaded.

Total measures

7,891

5,046

Overall: 12,397

Source: extracted from RBMP documents for the 3rd RBMPs

Note: Not applicable=no measures were applied to that water body type in the RBMP.

9.1.3.  Pressures for which gaps to be filled to achieve WFD
objectives and the Key Types of Measure planned to
achieve objectives

Member States are required to report the gaps that need to be filled to achieve WFD
environmental objectives in terms of all significant pressures on surface waters and

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groundwaters, in terms of priority substances causing failure of good chemical status and in
terms of river basin specific pollutants causing failure of good ecological status / potential.
Member States were asked to report predefined indicators of the gaps to be filled or other
indicators where relevant. Values for the gap indicators were required for 2015 and 2021 and
were optional for 2027.

Member States are required to report which KTMs, or measures are to be made operational to
reduce the gaps to levels compatible with the achievement of WFD environmental objectives.
A number of indicators were predefined for each KTM. Values of the indicators for the 2nd and
subsequent planning cycles were also to be reported to give an indication of the expected
progress and achievements: the values for 2027 could be optionally reported.

In Poland, specific measures with accompanying KTM code have been reported for each
water body in each RBMP to fill the gaps to achieve WFD objectives. However, these have not
been reported electronically.

Furthermore, the layout of the RBMP describes the pressure type on a water body level (e.g.
cumulative pressures, chemical pressures), and mentions the number of measures assigned
to the pressure. This does not give enough information as to what the type of pressure
actually is. The Annexes to the 3rd RBMPs further report on KTMs used per water body while
indicating the type of pressures (e.g. chemical pressures on groundwater and surface water
bodies). However, the significant pressures are not mapped explicitly in the 3rd RBMPs to the
list of pressures provided in the WFD reporting guidance.

The RBMPs provide a section on the most significant pressures by water body type, but these
have not been linked to the measures (apart from the detailed water body scale information in
the Annexes that list all measures applied to a water body with accompanying KTM code and
own categories of pressures. The 3rd RBMP e-reporting should provide more clarity for the
pressures and how they are linked to the KTMs.

By mining the RBMP documents for the 3rd RBMPs, the measures to tackle identified
significant pressures has been gathered and listed in Table 9.3 below for different water body
types.

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Table 9.3 Measures to tackle the pressures for which gaps need to be filled to achieve
WFD objectives by water body type in Poland

Water body
type

List of categories of measures associated with
significant pressures

RBDs applicable to

  Measures to reduce pressure from diffuse
pollution from agriculture and atmospheric
deposition

  Measures to reduce pressure from diffuse

pollution from urban areas, tourism and transport

Rivers

  Measures to reduce pollution from point source
including industrial and municipal sources.

  Measures to reduce inflow of pollution from

agricultural, municipal and industrial sources.

  Measures to ensure habitat protection

  Measures to reduce pressures from agriculture,

municipal and industrial sources

  Measures to improve morphological conditions

  Measures to improve fish migration

  Measures to ensure habitat protection

  Measures to Pressures from agriculture, municipal

and industrial sources

Lakes

PL1000, PL2000,
PL3000, PL4000,
PL5000, PL6000,
PL7000, PL8000

PL2000, PL3000,
PL6000, PL7000,
PL8000

Reservoirs

  Measures to improve fish migration

 PL2000, PL6000

  Measures to fulfil requirements for habitat

protection

Coastal /
Transitional

There is a lack of information for the pressures linked
to coastal and transitional water bodies and
associated measures.

  Measures to reduce pressures related to industry

and urbanisation

Groundwater

  Measures to reduce pressures related to

agriculture and municipal management

PL1000, PL2000,
PL3000, PL4000,
PL5000, PL6000,
PL7000, PL8000,
PL9000

Source: extracted from RBMP documents for the 3rd RBMPs

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9.1.4.  Transboundary cooperation

Poland shares a number of their water bodies with other countries. For the Oder, Vistula and
Danube an international RBMP has been produced for the international RBDs. For the Oder
RBD, the international RBMP mentions the significant water management problems in the
Oder river. However, in the Danube and the Vistula RBMPs, significant water management
issues are only mentioned in general aspects instead of addressing them in coordination with
other countries.

In all three RBMPs, the cooperation and working groups between Poland and the other
countries are mentioned, however, the joint programme of measures has not been mentioned.
Poland does transcribe relevant findings from international relations into their law where
applicable.97

9.2.  Main changes in implementation and progress with

recommendations

In the 3rd RBMPs, some information on links between pressures and measures have
continued to be provided (see Table 9.3). Specific measures with accompanying KTM code
have been reported for each water body in each RBMP to fill the gaps to achieve WFD
objectives. The Annexes to the 3rd RBMPs further report on KTMs used per water body while
indicating the type of pressures (e.g. chemical pressures on groundwater and surface water
bodies). However, the significant pressures are not mapped explicitly in the 3rd RBMPs to the
list of pressures provided in the WFD reporting guidance and reported electronically.

Like in the 2nd RBMPs, the 3rd RBMPs state that all planned measures have been assessed
on their feasibility, effectiveness, and cost-effectiveness but the reporting does not provide
sufficient details on the approach used for prioritisation of measures. While the 2nd RBMPs
reported some information on the scale and progress with implementation of measures with
the majority of measures leading to the achievement of WFD objectives by 2027, the 3rd
RBMPs do not provide a quantitative gap assessment for 2021 and 2027 quantifying the
necessary scale of additional action. It should, however, be noted that 3rd RBMPs (Chapter 9
of the RBMPs) report an assessment of progress i.e. for each water body type (e.g. rivers) it
presents a table with changes of status during the 2nd RBMP and a table with the expected
progress for the 3rd RBMP towards the achievement of environmental objectives.

The Commission recommendations based on the 2nd RBMPs and 2nd PoM reports were:

● Recommendation: Poland should ensure that KTMs are reported to address

identified priority substances causing failure of objectives.

● Assessment: The 3rd RBMPs report on KTMs  used per water body while indicating
the type of pressures (e.g. chemical pressures on groundwater and surface water
bodies) . However, there is no clear allocation of KTMs to priority substances causing
failure. The 3rd RBMPs, rather, report on a catalogue that groups measures to mitigate

97 It could be possible that this information is found in the iRBMPs.

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identified significant pressures by reducing the emissions and discharges of priority
substances. Furthermore, KTM15 that aims to address priority substances is reported
for some water bodies. The recommendation has been partially fulfilled98.

● Recommendation: Poland should consider how supplementary measures (designed
to be implemented in addition to basic measures) can contribute more effectively to
achieving the WFD objectives and quantify the total area to be covered by each
measure.

● Assessment: The 3rd RBMPs report the number of basic and supplementary
measures planned, but there is no explicit reporting on the prioritisation of
supplementary measures. The 3rd RBMPs discuss a list of considerations on planning
measures, and state that all planned measures have been assessed on their
feasibility, effectiveness and cost-effectiveness but the reporting does not provide
sufficient details on the approach used for prioritisation. No quantitative gap
assessment is reported quantifying the necessary scale of additional action. The
recommendation has not been fulfilled.

● Recommendation: Poland should provide more information on how it has selected

measures, including in relation to combatting pollution by priority substances and other
chemical pollutants. More consideration should be given to pollutants arriving via the
atmosphere, which could be relevant in all RBDs, and to identifying measures specific
to individual Groundwater pollutants.

● Assessment: There is no explicit reporting on the prioritisation of measures in the 3rd
RBMPs, despite the main drivers of the measures being mentioned. Instead, the 3rd
RBMPs discuss a list of considerations when planning measures and state that all
planned measures have been assessed on their feasibility, effectiveness and cost-
effectiveness but the reporting does not provide sufficient details on the approach used
for prioritisation. Regarding measures to address priority substances and groundwater
pollutants, the 3rd RBMPs do not provide a clear link between chemical pollutants and
KTMs. The 3rd RBMPs report on a catalogue of measures that includes a group of
measures aiming at reducing the emissions and discharges of priority substances, but
does not provide details on how these measures have been specifically selected. This
recommendation has not been fulfilled99.

98 Poland has subsequently clarified that the 3rd RBMPs measures are divided into Key Types of
Measures, consistent with the codification indicated by the European Commission, assigning individual
measures an appropriate code (according to the EC). In the Polish version of the 3rd RBMPs, in the files
contained in legal acts – 'KTM' appears as an abbreviation of 'GRŚ' (GRŚ1, GRŚ2, ... etc - expansion
of the abbreviation in Polish: „Główne Rodzaje Środków”) – plus an explanation of the codes, due to the
fact that the river basin management plans are documents prepared in Polish. Electronic reporting will
provide clear information about mapping the measures to relevant KTM.

99 Poland has subsequently clarified that the 3rd RBMPs measures are divided into Key Types of
Measures, consistent with the codification indicated by the European Commission, assigning individual
measures an appropriate code (according to the EC). In the Polish version of the 3rd RBMPs, in the files
contained in legal acts – 'KTM' appears as an abbreviation of 'GRŚ' (GRŚ1, GRŚ2, ... etc - expansion
of the abbreviation in Polish: „Główne Rodzaje Środków”) – plus an explanation of the codes, due to the
fact that the river basin management plans are documents prepared in Polish. Electronic reporting will

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9.3.  Conclusions on gaps in implementation

In Poland, measures have been reported for each water body in all 3rd RBMPs. The 3rd
RBMPs also report on KTMs used per water body while indicating the type of pressures (e.g.
chemical pressures on groundwater and surface water bodies). However, there is no clear
allocation of KTMs to priority substances and groundwater pollutants causing failure in the 3rd
RBMPs. This is exacerbated by the lack of 3rd RBMP e-reporting that should provide
information on significant pressures and KTMs identified to respond to these. The 3rd RBMPs,
however, do report KTM15 that aims to address priority substances for some water bodies.

There is no explicit reporting on the prioritisation of measures in the 3rd RBMPs, despite the
main drivers of the measures being mentioned. The 3rd RBMPs state that all planned
measures have been assessed on their feasibility, effectiveness and cost-effectiveness but
the reporting does not provide sufficient details on the approach used for prioritisation.

In the 3rd RBMPs, no quantitative gap assessment has been reported for 2021 and 2027
quantifying the necessary scale of additional action to achieve the WFD objectives. The lack
of a gap analysis to 2027 (though not mandatory) weakens the assessment of which
pressures will be addressed and how much progress is anticipated till 2027 in reducing
significant pressures.

Further work should be done in relation to setting clear gap indicators for all significant
pressures and to provide further details on the prioritisation of measures including cost-
effectiveness analysis.

provide clear information about mapping the measures to relevant KTM. Additionally, each measure in
the PoM is mapped to significant pressure which was identified in each Water Body. Thus, KTMs are
mapped to relevant pressure, however direct table with this mapping is not present in RBMPs

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10.  Measures related to abstractions and water scarcity

10.1. Assessment of implementation and compliance with

WFD requirements

10.1.1. Water exploitation and trends

Water abstraction (understood as consumptive use or net consumption) is not identified as a
significant pressure at the RBD level or in significant portions of an RBD for any RBD in
Poland in the 3rd RBMPs. As water abstraction is not identified as a significant pressure at the
RBD level or in significant portions of an RBD for any RBD, the country is not required to
report data on Water Exploitation Index+ at the national or RBD level for any RBD under the
WFD.

The current estimation of the annual Water Exploitation Index+ for the country is 6.4-10.5% for
the period (2016-2019)100, with seasonal Water Exploitation Index+ reaching 15.0% in the
third quarter of 2019101. In general, the 3rd RBMPs show a low focus on water abstraction /
scarcity issues, the same as in the 2nd RBMPs. In the 3rd RBMPs, there is no specific chapter
addressing water scarcity or droughts under climate change, but some references to drought
risks are included, as part of the analysis of quantitative pressures. In addition, Poland did not
report the use of sub-plans relevant to Water Scarcity and Droughts, accompanying the 3rd
RBMPs.

Poland has recently developed a national “Plan for counteracting drought impacts” (Plan
przeciwdziałania skutkom suszy, PPSS)102. This plan has been prepared by the National
Water Management Authority “Polish Waters” under the supervision of the Ministry of
Infrastructure and adopted with an Executive Order of the Council of Ministers in July 2021.
Although this plan provides a high-level catalogue of preparation measures, including -inter
alias- organisational and operational actions for promoting natural water retention measures,
guidelines on good agricultural practices and education / training, it does not include concrete
organisational, operational and follow-up measures for drought event crisis management (e.g.
water allocation priorities, relief / response measures)103. It is also unclear if this plan has

100 https://data.europa.eu/data/datasets/byobiw86oozdduikcwmlxg?locale=en

101 https://www.eea.europa.eu/en/analysis/indicators/use-of-freshwater-resources-in-europe-1

102 Plan for counteracting drought impacts, Official Gazette of Laws of Polish Republic, Warsaw, 3
September 2021, item 1615, available at: https://dziennikustaw.gov.pl/D2021000161501.pdf

103 Schmidt et al., (2023). Stock-taking analysis and outlook of drought policies, planning and
management in EU Member States. Final report under contract “Technical and scientific support to the
European Drought Observatory (EDO) for Resilience and Adaptation - Lot 2: In-depth assessment of
drought management plans and a report on climate adaptation actions against drought in different
sectors”

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informed or has been coordinated with the 3rd RBMPs before their adoption, at least at the
final stages of their development104.

Moreover, Poland has developed a national climate change adaptation plan, which was
published in 2013, but has not been updated since then. Poland has also developed specific
climate change adaptation plans for Warsaw and 43 other major cities of the country, as part
of an EU-funded project that lasted between 2017-2019105. The level of coordination of these
plans with the 3rd RBMPs is also unclear.

In the 3rd RBMPs, 15 out of 174 groundwater bodies (i.e., 8.6% of total groundwater bodies)
have been in poor quantitative status by 2021. In the 2nd RBMPs, 13 out of 172 groundwater
bodies (i.e., 7.6% of total groundwater bodies) were in poor quantitative status by 2015. The
groundwater bodies in poor quantitative status are located in the Oder RBD (PL6000) and
Vistula RBD (PL2000) (in central and southern Poland mostly). As 3rd RBMP e-reporting for
Poland is lacking, there are significant limitations in the availability of information for the 3rd
RBMPs, such as significant pressures affecting groundwater bodies in poor quantitative status
and surface water bodies in less than good ecological status / potential. According to the
review of the 3rd RBMPs of Oder and Vistula RBDs, the drainage in mining sites (i.e. alteration
of groundwater level) causes significant pressure to GWBs in both RBDs. Other significant
pressures in both RBDs are water abstraction for public water supply and water abstraction
for industry.

10.1.2. Main water uses

As water abstraction is not identified as a significant pressure at the RBD level or in significant
portions of an RBD for any RBD, the country is not required to report data on consumptive
uses of water, as well as the relevant estimation methods under the WFD. Furthermore,
Poland is not required to report relevant data to WISE SoE reporting on Water Quantity106.
However, Poland has voluntarily reported relevant data to WISE SoE reporting on Water
Quantity for the period 2015-2021. In specific, Poland has reported data on water abstraction
from groundwater at the RBD level for all national RBDs, as well as water abstraction from
groundwater for mining and quarrying at the RBD level only for the Vistula RBD (PL2000) and
the Oder RBD (PL6000). Furthermore, Poland has reported water use for households,
agriculture and industry, expressed as totals107 at the national level. However, online

104 Poland subsequently clarified that PPSS is a document with the rank of a regulation of the Ministry
of Infrastructure. RBMPs are documents of the same rank, so they do not repeat the content of any
other regulation and may only refer to its crucial parts.

105 Schmidt et al., (2023). Stock-taking analysis and outlook of drought policies, planning and
management in EU Member States. Final report under contract “Technical and scientific support to the
European Drought Observatory (EDO) for Resilience and Adaptation - Lot 2: In-depth assessment of
drought management plans and a report on climate adaptation actions against drought in different
sectors”

106 WISE-3: https://cdr.eionet.europa.eu/help/WISE_SoE/wise3

107 without distinguishing further surface water from groundwater

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statistics108,109 for the country include national data for more water uses, such as services,
mining and quarrying, energy cooling, and construction.

The 3rd RBMPs refer to various users of water, without further elaboration on the share of
consumptive uses or their trends. However, based on online statistics110, the major users in
Poland are (in descending order): electricity generation including cooling water (59.4%),
households and services (24.2%), agriculture (10.7%), industry (5.2%), mining and quarrying
(0.5%), construction (0.03%). Since 2016, total water abstraction has decreased (-11.5%), due
to decreases in all water uses, except for households and services where water abstraction is
increasing (2.3%).

According to the 3rd RBMPs, water abstraction is mainly estimated based on available permit
data. However, the extensive use of this method causes uncertainty on the actual pressure to
the environment. On the one hand, it may cause overestimation of abstraction volumes,
where the permitted volume is not abstracted by permit holders. On the other hand,
abstractions in excess of the permit or without a permit are not captured, causing
underestimation of abstracted volumes. The 3rd RBMPs do not discuss any issue of over-
abstraction, and they do not include water metering as a measure in the PoMs.

10.1.3. Measures related to abstractions and water scarcity

As 3rd RBMPs e-reporting for Poland is lacking, there are significant limitations in the available
information on measures from the 3rd RBMPs. The assessment of the 3rd RBMPs documents
of the Vistula RBD (PL2000) and the Oder RBD (PL6000), has covered the relevant gap
partly.

Water abstraction is addressed mainly with supplementary measures, which are applied to
individual water bodies, as identified from the status assessment. Basic measures addressing
water abstraction are limited in number and scope (i.e. focusing only on abstraction control
through the permitting process).

Regarding basic measures to control abstraction from surface and groundwater (referred in
Article 11(3)(e)), there is a concession, authorisation, and / or permitting regime to control
surface and groundwater abstractions and impoundments. Furthermore, there is a register of
abstractions from surface water and groundwater, but not a register of  all impoundments.
Small abstractions are defined with certain thresholds and those under the threshold are
exempted from controls. The value of the threshold is not mentioned in the RBMPs. Permits
are issued by state authorities for a limited time period, and they can be extended before they
expire, upon new application. Furthermore, permits can be refused or revised under specific
conditions, in order to maintain or achieve the environmental objectives in the RBMPs. E-
flows were defined and implemented by 2021, based on a hydrological method, and relevant
work is still on-going to update this method and include biological aspects (see Topic 13 –
Measures related to hydromorphology). From the assessed 3rd RBMPs, it is not clear if there

108 https://stat.gov.pl/en/topics/environment-energy/environment/

109 https://ec.europa.eu/eurostat/databrowser/view/env_wat_abs__custom_8401102/default/table

110 https://ec.europa.eu/eurostat/databrowser/view/env_wat_abs__custom_8401102/default/table

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is an explicit link between the implementation of e-flows and the authorisation process and / or
review of permits to control water abstractions and impoundments111. National authorities
conduct relevant sample checks after authorisation or targeted checks after complaints to
prevent cases of unauthorised abstractions or violation of permit conditions.

Basic measures related to controls on water abstraction (e.g. through the permitting process)
are planned for the 2021-2027 period in all assessed 3rd RBMPs112.

Basic measures related to groundwater recharge (referred in Article 11(3)(f)) were not planned
in the 2nd RBMPs, and new measures are not planned for the 2021-2027 period.

Basic measures related to water efficiency (referred in Article 11(3)(c)) were not planned in the
2nd RBMPs, and new measures are not planned for the 2021-2027 period.

Supplementary measures required to achieve environmental objectives (referred in Article
11(4)) and related to improvements in flow regime and / or establishment of ecological flows
are planned for the 2021-2027 period (e.g. review of water permits for individual water bodies
identified from the status assessment).

Supplementary measures required to achieve environmental objectives (referred in Article
11(4)) and related to water efficiency, are not planned for the 2021-2027 period.

The 3rd RBMPs include measures to increase water supply. In specific, these measures relate
to natural water retention measures, rainwater harvesting, water reuse, water reservoirs, and
water transfers. The development of new reservoirs and water transfers could be considered a
maladaptation issue, if not properly justified with exemptions under Article 4(7) (see Topic 16 –
Maladaptation measures) and consistent with the water scenarios, investment planning, cost
recovery and pricing policies, as (should be) laid down in the RBMP’s economic analysis.

10.1.4. International cooperation

In Poland, all 9 RBDs are international, as they are shared with other countries. International
cooperation is well-established in the Danube for Danube RBD (PL1000) (with Albania,
Austria, Bosnia and Herzegovina, Bulgaria, Croatia, Czechia, Germany, Hungary, Italy,
Moldova, Montenegro, North Macedonia, Romania, Serbia, Slovakia, Slovenia, Switzerland
and Ukraine), in the Elbe for the Elbe RBD (PL5000) (with Austria, Czechia and Germany)
and in the Oder for the Oder RBD (PL6000) (with Czechia and Germany). For these three
cases of RBDs, there is in place an international agreement, a permanent coordination body,

111 Poland subsequently clarified that e-flows are part of the 3rd RBMPs in the context of water bodies
located on protected areas (in situation when e-flow is an environmental goal for the area). Instream
flows are determined as an element of the permission process (i.e. the minimum flow which needs to be
preserved). Nevertheless, instream flows are not a part of an environmental goal. However, some
Water Bodies have their environmental goal corresponding to the protection areas requirements).
Designation of environmental flows will be a part of the process of designation of environmental goals
for the 4th RBMPs. The methodological details will be a part of analytical process for the 4th RBMPs.

112 The sources of funding for these measures are provided in Topic 9 - Programmes of Measures, but
the securing of the funding is unknown.

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an international RBMP and PoM including explicit links to the national RBMPs, as well as an
international co-ordination on public participation. International cooperation is also in place in
the Vistula for Vistula RBD (PL2000) (with Belarus, Slovakia, Russia and Ukraine), which is
exercised mainly through bilateral agreements with neighbouring countries. However, there is
no international RBMP and PoM. In the rest of the national RBDs, international cooperation is
not  practicality in place, as Poland covers only very small parts of the respective international
RBDs. Except for the Ucker RBD (PL 6700), where no bilateral agreement has been signed
with Germany, the rest of the RBDs are covered by the previously mentioned bilateral
agreements signed with neighbouring countries: Świeża RBD (PL3000), Jarft RBD (PL4000),
Pregoła RBD (PL7000) with Russia; Nemunas RBD (PL8000) with Belarus; Dniester RBD 
(PL9000) with Ukraine.

In the Danube, international cooperation includes joint monitoring, planning and stakeholder
engagement. Consultation between involved national authorities and other stakeholders is
regular (e.g. discussions within international river commissions or bilaterally). Furthermore, the
international RBMP of the Danube includes hydrological, hydrogeological, and climate change
adaptation assessments, but without particular elaboration specifically on water abstraction /
scarcity113.

In the Elbe, there is international cooperation on hydrological monitoring, information
exchange on national approaches and data sharing. Furthermore, the international RBMP of
the Elbe defines water scarcity related objectives at the international level and impacts of
climate change on water scarcity, but without particular elaboration specifically on water
abstraction.114

In the Oder, international cooperation specifically on water abstraction / scarcity is rather
limited to international projects focusing on sustainable water use under climate change115.

In the Vistula, international cooperation specifically on water abstraction / scarcity is not
reported.

113 However, water scarcity is included -among others- in the Significant Water Management Issues and
water scarcity considerations are reflected in the ICPDR (International Commission for the Protection of
the Danube River) guidance document on sustainable agriculture, which promotes smart irrigation
techniques for water saving.

114 Due to water scarcity concerns in the Elbe, a joint hydrological evaluation was attempted, but it was
inconclusive due to monitoring gaps.

115 NEYMO project (Lausitzer NEiße/NYsa Łużycka - Klimatische und hydrologische MOdellierung,
2012 - 2015): The project analysed recent (1971 - 2010) and future (up to 2100) climatic and
hydrological conditions in the Lausitzer Neiße region in order to enable sustainable management of
water resources.

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10.2. Main changes in implementation and progress with

recommendations

There are not significant changes in the way the WFD is implemented in Poland regarding
water abstraction and water scarcity management since the 2nd RBMPs.

No recommendation was included in the 2nd RBMPs regarding monitoring, assessment and
classification of groundwater quantitative status. Therefore, there is no relevant follow-up.

10.3. Conclusions on gaps in implementation

Reported water abstraction / use data to WISE SoE reporting on Water Quantity and relevant
data available in online statistics have significant differences in terms of water uses addressed
(e.g. missing data on services, mining and quarrying, energy cooling and construction).
Furthermore, the 3rd RBMPs do not elaborate on the share of consumptive uses and their
trends, for all those uses where data are available.

Reported water abstraction / use data are mainly estimated based on available permit data,
which causes uncertainty on the actual pressure to the environment. Water metering is not
foreseen as a measure in the PoM.

E-flows were defined and implemented by 2021, based on a hydrological method, and
relevant work is still on-going to integrate biological aspects. From the assessed 3rd RBMPs, it
is not clear if there is an explicit link between the implementation of e-flows and the
authorisation process and / or review of permits to control water abstractions and
impoundments.116

It is unclear if the 3rd RBMPs have been coordinated with the “Plan for counteracting drought
impacts” (Plan przeciwdziałania skutkom suszy, PPSS), the national climate change
adaptation plan, and the climate change adaptation plans for Warsaw and 43 other major
cities of Poland, already in place, and which KTMs in the 3rd RBMP serve the reduction of
water scarcity risks. In the 3rd RBMP for the Vistula River, drought is mentioned several times,
in most occurrences as a risk factor or a pressure in the context of quantitative analysis of
water availability. However, there is no specific section devoted to drought management in the
RBMP.117

116 Poland subsequently clarified that e-flows are part of the 3rd RBMPs in the context of water bodies
located on protected areas (in situation when e-flow is an environmental goal for the area). Instream
flows are determined as an element of the permission process (i.e. the minimum flow which needs to be
preserved). Nevertheless, instream flows are not a part of an environmental goal. However, some
Water Bodies have their environmental goal corresponding to the protection areas requirements).
Designation of environmental flows will be a part of the process of designation of environmental goals
for the 4th RBMPs. The methodological details will be a part of analytical process for the 4th RBMPs.

117 Poland subsequently clarified that PPSS is a document with the rank of a regulation of the Ministry
of Infrastructure. RBMPs are documents of the same rank, so they do not repeat the content of any
other regulation and may only refer to its crucial parts.

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The annual Water Exploitation Index+ for the country is 6.4-10.5% for the period (2016-2019),
with seasonal Water Exploitation Index+ reaching 15.0% in the third quarter of 2019.
Furthermore, the number and proportion of groundwater bodies in poor quantitative status has
increased from 13 out of 172 groundwater bodies (i.e., 7.6% of total groundwater bodies) in
the 2nd RBMPs to 16 out of 174 groundwater bodies (i.e., 8.6% of total groundwater bodies) in
the 3rd RBMPs. As the number and proportion of groundwater bodies in poor quantitative
status are worsening and considering the likely impact of climate change on (seasonal and
structural) water scarcity in Poland, the low focus on water abstraction / scarcity issues in the
3rd RBMPs is not justified. No water allocation priorities are in place, nor does Poland identify
specific drought management relief and response measures118, 119.

118 Report ”Stock Taking analysis and outlook of drought policies, planning and management in EU
Member States”, 2023 page 11.

119 Poland subsequently informed that the main administrative measure to tackle the issue of water
abstraction is provided in the catalogue of national measures as “Review of water permits for water
abstraction, as well as the implementation of these permits, at least once every 4 years”. Additionally, a
number of measures related to limitation of water abstraction on the areas with significant pressure
from water abstraction is also included in PoM as implementation of Best Available Techniques

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11.  Measures related to pollution from agriculture

11.1. Assessment of implementation and compliance with

WFD requirements

11.1.1. Use of measures to address agricultural pollution

The RBMPs inform that there are measures to address agricultural pollution. The RBMPs
refer to the action plan defined by the Nitrates Directive. There are very limited details on the
use of agricultural measures.

The descriptions of measures are organised by type of water body, river, lake, coastal etc.
Under measures for river water bodies, the following specific measures are listed:

● Reduction of diffuse pollution from agriculture (RWrP_02): control activities;

● Education and information (RWrP_04): educational and advisory activities for farmers;

and

● Control activities of agriculture: control activities related to the implementation of the

Nitrate Programme and related to the use of plant protection products.

For lake water bodies, the following measures are listed:

● Educational and advisory activities for farmers (LWP_01); and

● Reducing pesticide pollution from agriculture (LWP_02).

● The control and monitoring activities might include agriculture, but it is not explicitly

described in the RBMPs.

● For groundwater bodies, the following measures are listed:

● Voluntary application of actions from the Set of Recommendations for good agricultural

practice (GWPA); and

● Training in the voluntary use of a set of recommendations of good agricultural practice

aimed at protecting water against nitrate pollution from agricultural sources.

The above listed measures are very general and do not give any details about what is being
done at the water body level. The RBMPs describe that there is a list of national measures
applied in all RBD and there are specific RBD programmes with measures for each type of
water body. For agricultural measures, there are no more details than presented in the above
examples of measures. There is no further description of what specific measures are
implemented, ongoing or are planned for the 3rd RBMPs.

11.1.2. Implementation of measures

There is only a description of the implementation of measures for all types of measures. By
type of water body, the RBMPs describes the number of measures by types of measure.

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Measures to reduce diffuse pollution from agriculture is one type of measure. Information only
on the number of measures does not provide any understanding of what the measures are or
can be expected to achieve. That would require more detailed descriptions of each measure
and the expected effectiveness of the measure.

It is therefore not possible to describe the implementation of measures that address pollution
from agriculture.

The general description lists that there are both basic and supplementary measures. It is
described that not all measures from the 2nd RBMPs have been implemented due to financial
constraints and lack of knowledge.

11.1.3. Funding of measures

There is no description of the funding of agricultural measures. There are cost estimates that
include agricultural measures, but the information about funding is only at the aggregated
level. See Table 9.1 for details on the funding. For example, in the Vistula RBMP, it is stated
that about 35% of all measures are ready to be implemented and have secured funding. The
rest lack funding or require legal or competence changes.

11.1.4. Gaps and distance to target

There is no gap assessment in terms of the need for reduction of nutrient loads or reduction of
the use of pesticides. There is also no assessment or description of what the planned
agricultural measures will achieve in relation to the WFD objectives.

11.1.5. Nutrient management and transboundary cooperation

There is a reference to transboundary cooperation, but there is no detailed information about
the cooperation. Hence, it is not possible to assess how the issues on up and downstream
nutrient management are dealt with.

11.2. Main changes in implementation and progress with

recommendations

There is no detailed information about the changes in implementation of measures that
address diffuse agricultural pollution. There is only very general information about
implementation of measures.

The Commission recommendations based on the 2nd RBMPs analysis were:

● Recommendation: Poland should complete the adoption of measures to improve

manure handling and recycling on farms, decrease nutrient discharges (fertiliser and

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pesticide applications), perform more controls and monitoring, etc, and identify
financing sources to fund these measures.

● Assessment: The RBMPs do not include any details of the agricultural measures. It is
therefore not possible to assess whether such measures have been adopted. The
recommendation has been partially fulfilled.120

● Recommendation: Poland should complete a comprehensive gap assessment for
diffuse pollutant loads from agriculture (nutrients, agri-chemicals, sediment, organic
matter) across all waters in all RBDs and link it directly to mitigation measures in the
3rd RBMPs (as per WFD Article 11(3)(h)), to facilitate the achievement of WFD
objectives.

● Assessment: There is no gap assessment for diffuse pollution from agriculture. The

recommendation has been partially fulfilled.121

● Recommendation: Poland should continue to review and develop the strategy for the

delivery of WFD objectives, in cooperation with the farming community and the
authorities in charge of CAP in Poland to ensure the 3rd RBMP is technically feasible
and that all relevant policies and instruments (e.g. RDP, CAP Pillar 1, ND, etc.)
contribute significantly to RBMPs.

● Assessment: There is no detailed information about the agricultural measures and
how they have been developed. The recommendation has been partially fulfilled.122

● Recommendation: Poland should implement and report specific measures to address
the hydromorphological impacts from agriculture, in line with the requirement of Article
11(3) WFD.

● Assessment: There is no detailed information about the agricultural measures to
address the hydromorphological pressures123. The recommendation has not been
fulfilled.

11.3. Conclusions on gaps in implementation

There is no detailed description of the agricultural measures. The RBMPs inform only about
the measures in very general terms. It means that the only information is that there are
measures addressing nutrients and pesticides. There is no description of gaps in terms of a

120 Poland subsequently provided information on the applied methodology used for agricultural
measures which was not clearly referenced in the 3rd RBMPs. Therefore, this recommendation is
partially fulfilled.

121 Poland subsequently provided information on the methodology used for the analysis of pressures
and impacts which was not clearly referenced in the 3rd RBMPs. Therefore, this recommendation is
partially fulfilled.

122 Poland subsequently provided information on the methodology used for cooperating with farmers
and developing measures which was not clearly referenced in the 3rd RBMPs. Therefore, this
recommendation is partially fulfilled.

123 The MS has subsequently clarified that agriculture was not identified as a main hydromorphological
pressure.

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need for the reduction of nutrients from agricultural diffuse pollution or for the reduction of
pollution with pesticides. Accordingly, the expected progress towards the objectives cannot be
assessed. 124

124 Poland subsequently provided information on the methodology used the analysis of pressures and
impacts which was not clearly referenced in the 3rd RBMPs. Therefore, this recommendation is
partially fulfilled.

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12.  Measures related to pollution from sectors other than
agriculture

12.1. Assessment of implementation and compliance with

WFD requirements

In the context of this topic, pollution is considered in terms of nutrients, organic matter,
sediment, saline discharges and chemicals (priority substances, RBSPs, groundwater
pollutants and other physico-chemical parameters) arising from all sectors and sources apart
from agriculture.

12.1.1. Key Types of measure to tackle pollution from non-

agricultural sources

The RBMP documents for the 3rd RBMPs do not report on the KTMs.

There is general information about the type of measures relevant for pollution from other
sources than agriculture. Examples include the following:

● Reduction of pollution from point sources: industrial and municipal; and

● Reduction of diffuse pollution from urban areas, tourism and transportation.

There is a description of the number of measures by these broad categories. Measures for
wastewater is the type that has the largest number of measures.

12.1.2. Basic measures for the control of point source discharges

The RBMPs describe that there are basic measures in place. No details are provided, but
data from the implementation of the Urban Waste Water Treatment Directive (UWWTD)
indicates that there is almost compliance with the UWWTD. For collection of wastewater, the
gap is of around 0.3% of total load that still need to be subject to collection, then 1.2% of the
collected load is without the required biological treatment and finally 4% of the collected load
requires additional removal of nitrogen and phosphorus125.

12.1.3. Measures for chemical substances causing failure of

objectives

As with other pressures, there is limited information about measures to reduce chemical
pollution. Examples of measures that would reduce the pollution with priority substances and
other pollutants include:

125 https://water.europa.eu/freshwater/countries/uwwt/poland  (Based on data from 2018).

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● Activities in the field of wastewater management; and

● Activities focused on water management inspections and review of water law permits.

12.1.4. Measures for all drivers causing chemical pollution

There is not enough information to assess whether all drivers causing chemical pollution are
subject to relevant measures.

12.2. Main changes in implementation and progress with

recommendations and progress with recommendations

There is no detailed information about the changes in implementation of measures that
address pollution from other sources than agriculture. There is only very general information
about implementation of measures.

The Commission recommendations based on the 2nd RBMPs analysis was:

● Recommendation: Poland should ensure that KTMs are reported to address identified

priority substances causing failure of objectives.

● Assessment: There is no specific information about measures for the priority

substances that causes failure of objectives. Only very general information about
measures is provided. The recommendation has not been fulfilled126.

12.3. Conclusions on gaps in implementation

The RBMPs do not present data on the gaps in terms of how much pollution needs to be
reduced in order to achieve the WFD objectives. There are measures listed in general terms
addressing wastewater and stormwater that also include wastewater from non-connected
dwellings. There are no details about the measures and on what the measures are expected
to achieve. There is no information about measures to address specific chemical pollutants
apart from mentioning of measures on permits. Overall, the level of information does not allow

126 Poland subsequently noted that the 3rd RBMPs provide a clear link between significant pressures
and KTMs. The catalogues of measures are divided into Key Types of Measures, consistent with the
codification indicated by the European Commission, assigning individual measures an appropriate code
(according to the EC). In the Polish version of the 3rd RBMPs, in the files contained in legal acts –
'KTM' appears as an abbreviation of 'GRŚ' (GRŚ1, GRŚ2, ... etc - expansion of the abbreviation in
Polish: „Główne Rodzaje Środków”) – plus an explanation of the codes, due to the fact that the river
basin management plans are documents prepared in Polish. Electronic reporting will provide clear
information about mapping the measures to relevant KTM.

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any assessment of the expected progress and effect of the measures for pollution from other
sectors than agriculture.127

127 Poland subsequently provided information stating that a gap analysis had taken place. This

information was not clearly referenced in the 3rd RBMP.

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13.  Measures related to hydromorphology

13.1. Assessment of implementation and compliance with

WFD requirements

13.1.1. KTMs to tackle pressures

Significant hydromorphological pressures have been identified in the reviewed RBMPs, the
Oder and Vistula. Due to the lack of 3rd RBMP e-reporting, information on KTMs could not be
found for this assessment.

The types of specific hydromorphological measures planned for rivers include fish ladders and
habitat restoration, building spawning and breeding areas. On the other hand, no measures
are indicated regarding floodplain restoration and improvement of lateral connectivity. There
are some measures planned for lakes and coastal zones related to restoring natural
hydromorphological processes, though further details can be not found.

Objectives in terms of restoring river continuity are reported in the Vistula and Oder RBDs
where measures relevant to restoring river continuity are reported.

13.1.2. General measures to tackle hydromorphological pressures

In terms of basic measures, there is no specific mention of periodical review and update of the
permits related to hydromorphological alteration, but there is a general principle set out in the
RBMPs that permits might be revoked for water bodies at risk of not meeting the
environmental objectives. There is also a register of transverse structures.

13.1.3. Indicators on the gaps to be filled for hydromorphological

pressures

In the Vistula RBMP, there is information regarding the progress with hydromorphological
measures planned in the 2nd RBMP at the level of “groups of measures”. The groups of
measures related to hydromorphology are reported as completed (verification of GEP method; 
development of good practices and rules for implementation for river works; development of
national surface water renaturalisation programme). For the Oder RBMP, there is no
information provided regarding gap analyses of hydromorphological pressures.

13.1.4. Measures for achieving objectives of the WFD and Floods

Directive and drought management

Win-win measures in terms of achieving the objectives of the WFD and Floods Directive have
been included in the reviewed RBDs.

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13.1.5. Ecological flows

Specific information on e-flows was not found in the reviewed RBMPs. However, according to
an overview of the e-flow methods in EU Member States128, Poland has a national method for
e-flows developed and implemented. The method is merely hydrological and does not
consider biological aspects. Nevertheless, this is an improvement over the 2nd RBMPs where
e-flows were not derived nor implemented.

Also, basic and supplementary measures include “improvement of morphological (habitat)
conditions in the channel and flow conditions”, though no further detail is provided.

13.1.6. Nature-based solutions

The RBMPs describe measures for the retention and management of rainwater and snowmelt
in urban and rural areas. There is a national policy plan with an objective of renaturation and
increased retention. There is clear information that priority is given to the use of NWRMs and
green infrastructure measures in the planning process on a national level. The Oder RBMP
specifically presents results from a qualitative assessment of socio-economic impacts, in
which NWRMs are reported to be positive or very positive i.e. in the highest two ranks out of
four ranks.

13.2. Main changes in implementation and progress with

recommendations

In the Oder RBMP, Poland introduced the methodology of ranking measures according to
socio-economic impacts, which can be considered an outstanding approach.

The Commission recommendation based on the 2nd RBMPs analysis was:

● Recommendation: Ecological flows also need to be derived and implemented during

the second cycle.

● Assessment: There is no detailed information on this aspect in the reviewed RBMPs,
however from an overview of the e-flow methods in EU Member States, it appears that
e-flows have been derived and implemented. It remains unclear if the implementation
of e-flows is included in the review of permits77.

● Recommendation: Poland should continue prioritising the use of green infrastructure

and/or natural water retention measures that provide a range of environmental
(improvements in water quality, flood protection, habitat conservation etc.), social and
economic benefits which can be in many cases more cost-effective than grey
infrastructure.

128 Summary of the main results and questions for discussion for the ECOSTAT workshop (Brussels, 30
June - 1 July 2022): https://circabc.europa.eu/sd/a/063e62a8-e4b0-4d87-817d-
5dbd4e7c5a33/2023_12_07_Eflows_Workshop_background_document_revised_final.pdf

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● Assessment: There is information identified on NbS, with some measures NbS

specific and recognise their social and economic benefits, which can be considered an
outstanding approach. One of the measures indicated in the 3rd RBMPs, is National
Surface Water Restoration Programme with a set of recommendations contained in a
separate manual. These tasks are already being implemented, but will also continue in
the next planning cycles.

13.3. Conclusions on gaps in implementation

Due to the absence of 3rd RBMP e-reporting, an assessment of progress with measures could
not be completely made, although it is recognised that a large number of measures to ensure
the biological and morphological continuity and to improve hydromorphological conditions in
rivers are included in the PoMs as basic measures. No information about periodic review of
permits to address hydromorphological pressures in accordance with the WFD article 11(3)(e)
and 11(3)(i) was found, nor information of measures to generally tackle the
hydromorphological pressures. Information on gaps is very limited which prevents effective
development of measures to achieve good hydromorphological status. While ecological flows
appear to be derived and implemented, this is not appropriately reported in the RBMPs. It
remains unclear if the implementation of e-flows is included in the review of permits129.

129 Subsequently PL clarified that the environmental flows are part of the 3rd RBMPs for water bodies
located in protected areas (where e-flow is an environmental goal for the area). Instream flows are
determined as an element of a permission process (the minimum flow which needs to be preserved).
Otherwise, instream flows are not a part of an environmental goal as yet and their derivation will be a
part of the process of the designation of environmental goals in the 4th RBMPs which will also include
the methodological details.

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14.  Economic analysis and water pricing policies

14.1. Assessment of implementation and compliance with

WFD requirements

14.1.1. Water services and water uses

Information provided in the present chapter is based on the assessment of the two largest
RBDs in Poland (Vistula and Oder RBD) and does not consider the 7 remaining, smaller
RBDs. The RBMPs define water services as the municipal water management, which refers
to the broad water services (collective) water supply and the collection and treatment of
(waste)-water. Hence, the municipalities are reported to be the main actors in the provision of
WSS (water supply and wastewater services). The information on WSS is often disaggregated
into the water user sectors industry, households and agriculture in the examined RBMPs. With
regards to water supply services, impoundment and storage are reported as distinct individual
water services with this broad water service. Self-services and water reuse, however, are not
defined as water services (albeit for the former cost recovery rates are reported).

With regards to “other” water uses and water user sectors, the following have been
identified in both RBMPs: self-abstraction, agriculture, manufacturing industry, households,
self-service wastewater treatment diffuse pollution from agriculture as well as point source
pollution from industry and from domestic uses. In addition, hydropower and mining have
each been identified as water uses / water user sector in one of the two RBDs each. A
summary of water services and water uses identified in the Polish RBMPs is provided in the
following table.

Table 14.1 Water services and water uses identified in the Polish RBMPs

Water services

Identified in the Polish Oder
and Vistula RBMP

Water supply

Wastewater services

Impoundment and storage

Self-services

Water reuse

Other water uses

Diffuse pollution from agriculture

Point source pollution from industry

Point source pollution from domestic sources

Water user sectors

Agriculture

128

yes

yes

yes

no

no

yes

yes

yes

yes

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Water services

Identified in the Polish Oder
and Vistula RBMP

Industry

Households

Hydropower

Mining

yes

yes

Only Vistula RBMP

Only Oder RBMP

Source: Data mining from 3rd RBMPs pdf reporting

14.1.2. Economic analysis update130

Information on the progress made in the economic analysis is presented in the RBMPs.
However, regarding the implementation of Article 9 of the WFD, it is not clearly stated what
has been done since the 2nd RBMPs.

No details are provided in the Oder and the Vistula RBMPs on where progress has been
made and what exactly has been improved. The Oder RBMP specifies that the above
provisions for economic analysis are reflected in national legislation: “According to Art. 324
sec. 6 r.c. for the purposes of drawing up water management plans, economic analyses
related to the use of water are carried out, taking into account the principle of reimbursement
of water services costs and long-term forecasts regarding the possibility of meeting the needs
for the use of water resources in the river basin”. However, no actual figures are provided. A
footnote in the Oder RBMPs indicates that environmental costs were calculated on the basis
of the methodology included in a separate study. The reference of this study is included in the
RBMP (“Cost recovery analysis for water services with development forecast and analysis of
environmental and resource cost recovery in water regions and river basins (conclusions),
Gliwice 2019”), but neither the study itself nor its results are included in the RBMP nor in any
background documents. These national provisions do, however, not include estimates of
relevant investments and forecasts of such investments, estimates of potential costs of
relevant measures, nor judgements about the most cost-effective combination of measures.

In one of the RBMPs examined (Oder), reference is made to the information required by
Annex III of the WFD (without providing the actual data):

● long term forecasts of water supply, differentiated over source type;

● long term forecasts of water demand, differentiated over user types / sectors;

● volume estimates associated with the various water services for 2019, differentiated

over surface water abstraction, groundwater abstraction, wastewater input, drainage of

130 The economic analysis was a part of the expertise entitled ‘Analysis of cost recovery for water
services along with development forecast and analysis of environmental cost recovery and resources in
water regions and river basin areas. The main conclusions of the study were taken into account while
drafting chapter on economic analysis in the 3rd RBMPs. The Water Law Act introduced new rules for
the tariffication of water and wastewater fees, so the analysis applies until 2018. Thus, the detailed
conclusion is outdated for the validity period of the document, because relevant changes to the system
were implemented to the Polish Law before publication of the 3rd RBMPs.

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rainwater or meltwater into waters, abstraction of water for the needs of fish farming
and extraction of stones, gravel and sand from water and cutting plants.;

● cost estimates associated with the various water services, if possible, differentiated

over surface water abstraction, groundwater abstraction, sewage discharge, discharge
of water from land drainage to waters, drainage of rainwater or meltwater into waters,
extraction of groundwater for energy generation, extraction of surface water for energy
generation, abstraction of water for the needs of fish farming an extraction of stones,
gravel and sand from water and cutting plants; and

● price estimates associated with the various water services, if possible, differentiated

over surface water abstraction, groundwater abstraction, sewage discharge, discharge
of water from land drainage to waters, drainage of rainwater or meltwater into waters,
extraction of groundwater for energy generation, extraction of surface water for energy
generation, abstraction of water for the needs of fish farming an extraction of stones,
gravel and sand from water and cutting plants.

14.1.3. Incentive function of water pricing

With regards to the presence of pricing instruments, the RBMPs report a joint tariff for Water
Supply and Sanitary services (WSS) in place, i.e. there is one price per unit of water
consumed which accounts for both the drinking water supply and the sanitation service. A
different rate is applied to households and industry, respectively; agriculture is not mentioned.
No other tariffs or charges are reported in the RBMP and no further details on the water
pricing schemes are provided. However, revenues for water services are reported are split into
two parts respectively related to fixed fees and variable fees, suggesting that the (final) water
tariff may be composed of a fixed and a variable component (the latter varies with the volume
of water used). The reference to ‘municipal water management’ suggests that pricing can vary
across Poland, taking account of local cost factors.

Furthermore, the RBMPs do not provide an explicit account that the pricing policy provides
“adequate incentives” to use water efficiently.  There is no discussion of the effects of
pricing instruments on their own or in combination with other measures. However, from the
available bits of information one can make some inferences. The full cost recovery of the WSS
services (see the next sub-section) as well as the tariff structure and the possibility to adapt to
local factors imply that pricing provides efficiency incentives. However, the large disparity in
pricing between, on the one hand, the WSS users, and, on the other hand, agriculture, raises
some questions on the overall incentives to efficiency (see for this the next sub-section); the 
same may hold for the large share of local water service providers that reportedly are loss-
making (also next sub-section). The reported lack of metering (and thus volumetric pricing) in
water abstraction falls in the same category.

14.1.4. Calculation of cost recovery and adequate contributions

Financial information is provided as totals for the whole country. Revenue figures (as well as
total costs) from water tariffs are given for the year 2018. The cost recovery rate of financial
costs of public WSS is actually presented as a profit rate, because country wide 5.12% more
revenues have been generated from tariffs for water and sewage services than incurred

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financial costs. Regarding this national average, it is further specified that about 37% of the
water service entities have reported a loss and 63% have reported a profit (out of 1,899
entities in total). Of note, the RBMPs do not provide much information on the methodology
and calculations of the reported recovery rate(s). Among other things, it is not clear whether
the cost definition includes the capital costs corresponding to financial investment support in
the form of grants.

The RBMPs indicate that enterprises in the industrial sector bear the full costs of water
abstraction and wastewater discharge activities (the latter both as self-service and when
relying on the collective sanitation service). The financial cost recovery rate for the industrial
sector is therefore 100%.

A separate cost recovery rate is provided for the agriculture sector for the year 2017. It
amounts to 19.5%. The much lower recovery rates suggests that this sector gets water at a
much more favourable tariff than the other two water use sectors, even when corrected for the
differences in the cost structure in the water provision. As already indicated in the previous
sub-section, this does not reflect positively on the adequacy of the water pricing structure as a
whole to give incentives to an efficient use of water. The RBMPs do not give any justification
based on the factors that allow to mitigate the cost recovery efforts (as listed in article 9(1) of
the WFD), such as socio-economic factors.

In fact, both the loss-making water services providers, and the low water services cost
recovery in agriculture raises questions on whether water user sectors and water uses (as
well as those responsible for ‘pollution,’ including water uptake / abstraction in times of
scarcity) have provided an adequate contribution to the recovery of water services’ costs.
Unfortunately, the RBMPs do not discuss the adequate contribution aspect at all.

No information on revenues from water abstraction and pollution charges is provided (the
RBMP informed that there is “no data”). Furthermore, no explicit information on subsidies is
provided. Hence, it remains unclear how the reported losses on WSS provision in some areas
in Poland as well as the lower cost recovery for agriculture are addressed: the extent this is
done through debt accumulation or via financial transfers, geographically or across sectors, or
from spending out of the national public budget.

14.1.5. Environmental and resource costs

The environmental costs for the public WSS providers (water utility sector) have been
estimated based on the costs of measures for environmental protection (the so-called “cost-
based approach”). The RBMPs do not give further details on the method applied and remain
unclear on how “resource costs” have been considered. The environmental costs seem to be
used as input to the calculation of the so-called economic rate of return of water services.
Only the total national average is provided, which is 97.4%. However, as calculation details
are not provided, it is not completely clear from the RBMP in how far environmental and
resource costs as defined by the WFD are actually included in this rate – or not.

A separate rate has been calculated for the agricultural sector. When taking environmental
costs and unpaid fees for water abstraction into account, the cost recovery level is only 2.7%.

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With regards to industry, environmental costs are estimated as well, which resulted in an
economic cost recovery rate of 82.6% for the year 2017.

14.1.6. Information provided on Polluter Pays Principle

As follows from the lack of attention for the issue of the adequate contributions from different
water uses to financial and environmental costs, the RBMPs pay scant attention to the
application of the Polluter Pays Principle (PPP). Only a general assurance of its application is
provided in the RBMPs.  No further details on how the polluter or user pays principle is
defined are provided.

14.2. Main changes in implementation and progress with

recommendations

The Commission recommendation based on the 2nd RBMPs analysis was:

● Recommendation: Poland should apply cost recovery for water use activities having a
significant impact on water bodies or justify any exemptions using Article 9(4). Poland
should continue to transparently present how financial; environmental and resource
costs have been calculated and how the contribution of the different users is ensured.
It should also continue to transparently present the water-pricing policy and provide a
transparent overview of estimated investments and investment needs.

● Assessment: Information on the progress made in the economic analysis is presented
in the RBMPs, but no details are provided on where progress has been made and
what exactly has been improved. Financial cost recovery rates are provided for public
WSS as well as for the agricultural and industrial sector. Factors mitigating efforts of
different sectors to cost recovery are not mentioned. The RBMPs do not detail the link
between the PPP and the cost recovery either. The cost-based approach has been
applied to estimate the environmental costs for public WSS providers. The reporting on
the actual environmental (and resource) costs and cost recovery do not provide
enough information to understand the methodology applied and the calculations made.
A so-called “economic rate of return” is provided for public WSS, agriculture and
industry, which seems to include these environmental costs. However, as further
explanations are missing, it is unclear in how far this rate corresponds to a broad cost
recovery rate in the sense of the WFD. No information is provided on revenues
received from water abstraction and pollution charges, but reportedly unpaid fees from
agriculture’s water abstraction are explicitly mentioned as part of the environmental
costs related to agriculture, implying thus revenue loss and thus implicit subsidy to
agricultural water consumption. Only the tariff structures for water supply to
households and industry are reported, while tariffs for agriculture are not mentioned.
No investment forecasts and investment needs estimates are provided, so probably
not taken into account. Hence, overall, the recommendation has only been partially
taken up.

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14.3. Conclusions on gaps in implementation

Water services are clearly defined in RBMPs, and “other” water uses as well as water user
sectors have been identified.

No clear information on what exactly has been improved in the economic analysis: neither the
data itself on these items is not provided in the RBMP nor the calculation methods. Reference
is made to requirements of Annex III WFD (e.g. regarding forecasts of water supply and
demand) which is reflected in national legislation; estimates of investments and future 
investment needs are mentioned nowhere. The same applies to cost-effectiveness-analysis.

The adequateness of water pricing to provide incentives for a more efficient water use has not
received an explicit discission, but the available information on the WSS tariffs suggest some
incentives, which appear fully absent for agriculture.

Revenue and cost figures for public WSS are given as national totals for one year. Financial
cost recovery rates have been also calculated as national totals for public water supply,
industry and agriculture.

Environmental costs are estimated based on the cost-based approach. The terminology used
is unclear and it remains somewhat uncertain whether a broad cost recovery rate in the sense
of the WFD has been calculated. There is no clear discussion regarding the adequate
contributions from different water uses to financial and environmental cost recovery, but the
agricultural sector is apparently allowed to not pay fees in a significant proportion. It is unclear
if these unpaid fees are legally allowed under certain conditions or not. With regards to the
PPP, (only) a general assurance of its application is provided in the RBMP.

The table below summarises the status of the implementation of Article 9 requirements in
Polish RBMPs in the 3rd RBMPs.

Table 14.2 Overview of the implementation status of Article 9 requirements – Poland
(economic analysis and cost recovery arrangements)

Element of
economic
analysis

Water uses
and water
services

Major gaps

Limited progress

Partial
progress

Major
strengths

Reporting of
water services
other than WSS

Identification of
water uses

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Element of
economic
analysis

Major gaps

Limited progress

Partial
progress

Major
strengths

Transparency of the
reporting on
complying with
Annex III
requirements.

The differentiation
in investment
(needs) forecast /
planning and the
cost-effectiveness
assessment

Link with CC
adaptation
scenarios (long-
term perspective
lacking)

Justification and
implementation:

Recovery mitigation
factors and art. 9(4)
exemptions

Assessment of
environmental and
resource costs and
the application of
the Polluter Pays
Principle

Adequate
contribution of
water users and
water uses;  

Economic
analysis of
water use

Incentive
function of
water pricing

Financial cost
recovery

Environmental
and resource
costs and the
application of
Polluter Pays
Principle

Update of the
economic analysis

Transparent
account of water
pricing

Justification and
implementation:

Adequate
incentives for a
more efficient
water use and
justifications

Differentiation of
cost recovery
rates over
individual water
services

134

Reporting of
financial cost
recovery rates
for WSS

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15.  Considerations specific to protected areas
(identification, monitoring, objectives and measures)

15.1. Assessment of implementation and compliance with

WFD requirements

Protected areas associated with surface water bodies include WFD Article 7 drinking water
protected areas, areas intended for recreational usage managed under the Bathing Waters
Directive, Natura 2000 areas including the Birds and Habitats Directives, and areas intended
for the protection of species of economically important aquatic species under the Shellfish
Directive. In addition, 174 groundwater bodies are associated to drinking water protected
areas.

A whole territory approach has been designated for Nitrate Vulnerable Areas protected under
the Nitrates Directive. Similarly, Poland has used a whole territory approach to the designation
of nutrient sensitives areas under the Urban Waste Water Treatment Directive.

No information has been found within the RBMPs regarding information about protected areas
associated with lakes, transitional, and coastal waters. The RBMPs only state whether the
protected area is surface water or groundwater.

Since the 2nd RBMP, Natura 2000 sites have increased significantly by 3600 from 189 sites to
3789 protected areas. The number of sites designated for the protection of Bathing Waters
has also increased considerably from 123 to 517. However, areas designated for the
protection of Drinking Water has decreased slightly from 368 in the 2nd RBMP to 353 in the 3rd
RBMP. The RBMP documents for the 3rd RBMPs assessed in detail do not include information
to explain the changes in protected areas.

Table 15.1 Number of water bodies associated with protected areas in Poland by
2022, per type of protected area and type of associated water body

Protected Area type

Drinking Water Protection
Zones

Bathing Waters

Natura 2000

Number of Water Bodies Associated with protected areas in

Surface water bodies

Groundwater bodies

174

0

0

179

517

3789

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Protected Area type

Number of Water Bodies Associated with protected areas in

Surface water bodies

Groundwater bodies

Nitrate Vulnerable Zones

Whole territory approach
applied

Shellfish Directive

180

0

0

Source: Data mining from 3rd RBMPs pdf reporting

The RBMPs assessed in detail refer to a register of protected areas that has been created
and updated since 2003. However, none of the two RBMPs assessed in detail have
mentioned whether the register is online or the location of the register.

15.1.1. Monitoring sites for protected areas

Monitoring of protected areas is established in order to verify whether the additional
requirements of the set objectives for protected areas are achieved. The RBMPs have
explained that monitoring of protected areas associated with surface waters has been
established within the 3rd RBMP, however, they do not specify the frequency of monitoring
sites across rivers, lakes, coastal or transitional water bodies within the country. It is also
unclear whether protected areas associated with surface water bodies are monitored only
through the WFD monitoring network.

Groundwater monitoring sites have been established across all the assessed RBMPs, the
details of which can be seen within table 15.2 below. Monitoring has been outlined within the
RBMPs for Bathing waters and Shellfish protection areas, however no information on the
number of monitoring sites has been identified. The information in the table below has been
derived from the 3rd RBMPs.

Table 15.2 Number of protected areas monitoring sites in Poland by 2022, per type of
protected area and type of associated water body

Protected area type

Number of monitoring sites associated with protected areas in Poland

Surface water bodies

Groundwater bodies

Drinking water protection
area

N/A

Natura 2000 protected site

N/A

Total

N/A

703

64

767

Source: Data mining from 3rd RBMPs pdf reporting

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15.1.2. Status of protected areas

No information has been provided or could be extracted from the RBMPs regarding the status
of water bodies associated with protected areas. There has also been no electronic reporting
reported.

15.1.3. Additional objectives

Additional objectives have been set in the updated 3rd RBMPs only for areas that are intended
for drinking water abstraction and for Natura 2000 designated areas.

For Drinking Water Abstraction Areas, the objectives indicate that the quality of the water
should not deteriorate.

For protected areas designated for the protection of habitats or species, Natura 2000 sites,
environmental objectives for waters have been assigned on the basis of the requirements for
these areas. A total of 1885 Natura 2000 sites have had environmental objectives set across
the RBMPs assessed in detail. However specific details on the objectives applied have not
been reported in the RBMPs.

The RBMPs note the importance of maintaining and improving the status of water bodies
associated with protected areas. It also notes the need to further update the Central Register
of Forms of Nature Conservation (CRFOP) kept by the General Directorate for Environmental
Protection to a format that enables practical use of the data contained therein. It is unclear
whether this is being taken onboard as a measure for the next reporting cycle and no details
are included on what practical use of data is considered suitable.

No further information has been provided or found within the RBMPs regarding additional
objectives set for other protected areas in Poland.

15.1.4. Additional measures

No information has been reported or found within the RBMPs assessed in detail regarding the
additional measures set for protected areas.

15.2. Main changes in implementation and progress with

recommendations

While the RBMPs do not include information on main changes, the following were observed:
Since the 2nd RBMP Natura 2000 sites have increased significantly by 3600 sites, from 189 to
3789 protected areas. The number of sites designated for the protection of Bathing Waters
has also increased considerably from 123 to 517. However, areas designated for the
protection of Drinking Water has decreased slightly from 368 in the 2nd RBMP to 353 in the 3rd
RBMP. Within the 3rd RBMP, Poland has not e-reported any monitoring sites for rivers, lakes,

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transitional or coastal waters. However, groundwater monitoring sites have been identified
within the 3rd RBMP with a total of 676 sites identified.

The Commission recommendation based on the 2nd RBMPs analysis was:

● Recommendation: Poland has reported additional objectives only for surface water
protected areas related to Birds and Habitats Directives. Therefore, Poland should
work on the additional objectives for groundwater related protected areas. Finally.
Poland should also ensure that all relevant protected areas are properly monitored
during the 2nd RBMPs. Poland should complete the designation of a sufficient number
of Nitrate Vulnerable Zones in the 3rd RBMP cycle and adopt measures to effectively
combat nitrate pollution in these zones as required by the Nitrates Directive and Article
11.(3)(a) of the WFD.

● Assessment: Poland has stated that additional objectives for areas intended for the

abstraction of drinking water and for Natura 2000 sites have been set and
implemented. Information is lacking in regard to the specific measures implemented to
meet the set objectives. The lack of 3rd RBMP e-reporting makes it difficult to assess
whether the protected areas monitoring network has increased. The numbers of
monitoring sites were only identified in one pdf RBD and for groundwater bodies.
Poland has a whole territory approach to Nitrate Vulnerable Zones in line with the
recommendation from the 2nd RBMPs. The lack of 3rd RBMP e-reporting and lack of
information within the RBMPs regarding monitoring sites does not allow for a
comprehensive assessment of the recommendation from the 2nd RBMP of properly
monitoring protected areas 131.

15.3. Conclusions on gaps in implementation

There are several gaps in the assessment of the implementation of the 3rd RBMPs due to the
lack of 3rd RBMP e-reporting and the lack of details included in the RBMPs on protected
areas. No information was identified on additional measures set, nor on surface and
groundwater status update provided in the 3rd RBMPs. No information is included on
objectives for drinking water protection areas nor on objectives for Natura 2000.

 For Shellfish protected areas there are designated areas but no information reported
electronically or within the RBMPs on additional objectives to protect and enhance these
areas. The same can be concluded for monitoring information which is severely lacking any
information. 132

131 Poland subsequently clarified that Poland has addressed this recommendation through the
application of the action programmes from Article 5 of the Nitrates Directive applied throughout the
whole country. Poland added that this information is being included in the 3rd RBMP e-reporting now
finalised.

132 Poland subsequently added that the 3rd RMBP e-reporting completed in March 2024 includes
relevant information on these topics.

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16.  Adaptation to drought and climate change

16.1. Assessment of implementation and compliance with

WFD requirements

16.1.1. Measures

Climate change adaptation measures

95 climate change adaptation measures have been assigned in the Vistula RBMP, accounting
for 19% of all measures taken included in the RBMP. Adaptation measures have been
grouped into specific action areas, including (order in descending order in number of
measures included per action area): protection of habitats / species; wastewater 
management; control of fish migratory measures; reduction of pollutant runoff. In the Oder
RBMP, measures also account for 19% of all measures taken.

Climate proofing measures

It remains unclear if climate proofing of measures has taken place. An overview of the impacts
of climate change has been presented throughout the RBMPs, but no details on the impacts
of climate change on measures has been identified.

Maladaptation measures

Maladaptation measures have been identified within the Oder RBMP, whereby lake
reclamation is included within the PoM. However, no details on the nature of the measures are
included, therefore an analysis of potential impacts of such measures is not possible. As noted
in Topic 12, a register of transverse structures (i.e. dams) is included in RBMPs- such
structures can be classified as potentially negatively impacting climate change adaptation
ability.

16.1.2. Assessment of implementation and compliance with WFD

requirements – climate change adaptation

Climate change considerations

A dedicated chapter on climate change has been included in the RBMPs, focussing on both
short-term and long-term (>50 year) impacts through the use of the KLIMADA 2.O (which was

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developed as part of the Polish National Adaptation Strategy, 2013133) and CHASE-PL 2017
climate models developed. The Oder and Vistula RBMPs project insignificant changes to
surface and groundwater resource availability in the short (2050) or long term (2100).

National climate change adaptation projects (stemming from the national adaptation strategy)
are listed in the RBMPs, including actions such as afforestation to counteract drought impacts
and increasing the retention capacity of rivers.

Assessment of water scarcity

There has been no definition of ‘water scarcity’ included in the reviewed RBMPs. The climate
modelling noted in the section above offers limited information on water scarcity-related
aspects, other than indicating that water resource availability will be largely unaffected by
climate change. Both RBMPs that have been reviewed state that ‘changes in resources
(groundwater) are the results of ‘their exploitation for economic purposes’- which potentially
indicates an analysis of water use (and scarcity) has been conducted, but no information on
such analysis has been included in the RBMPs.

Climate change adaptation overview

As noted above, limited information on the impacts of climate change on water management
has been included in the RBMPs. No climate change specific indicators for monitoring and
reporting on the impacts of climate change for water management have been identified.

Water bodies failing to achieve objectives due to climate change exemptions

There has been no analysis identified in the RBMPs which outlines the number of water
bodies failing to achieve objectives due to climate change. No Article 4(6) exemptions have
been identified in the RBMPs.

Climate change impacts on existing pressures

Measures listed in the Vistula RBMP are categorised against their relevance to addressing
‘cumulative water pressures’, yet this aggregation does not allow an analysis of whether
climate change is a contributing factor for water bodies failing to achieve environmental
objectives. Furthermore, the dedicated risk assessment chapters in both RBMPs have not
included climate change as a pressure category for analysis.

National strategies on climate change adaptation

As noted in the sections above, a Polish National Climate Adaptation Strategy was adopted in
2013, but no further updates have been published. An EU-funded project to prepare

133 Ministry of Environment (2013) Polish National Strategy for Adaptation to Climate Change (NAS
2020)

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adaptation plans for 44 cities in Poland was completed in 2019134, yet no further information of
their potential integration into RBMPs has been identified.

Impact of climate change on failure to achieve good ecological status

The dedicated chapter on risk assessment in both RBMPs has not included a specific analysis
of the climate change impacts on environmental objectives.

16.1.3. Assessment of implementation and compliance with WFD

requirements in the 3rd RBMPs – droughts

Drought adaptation overview

Poland has experienced several drought events in recent years (2015, 2018, 2019), with
impacts affecting agricultural production, energy production (hydropower and thermal), public
water supply and inland navigation135. Recent modelling by the JRC suggests a potentially
substantial reduction in the yield of crops in Western parts of the country during extreme
drought events (1-in-50-year drought events), whilst negative impacts on the transportation
(via rivers) of goods are also projected to be higher than the EU average136.

A definition of ‘prolonged drought’ has been included in both the Vistula and Oder RBMPs137,
but no specific section dedicated to drought management has been included in the RBMPs.
However, a Drought Effects Counteracting Plan (DECP138) has been developed by Poland,
which includes an overview of water retention-related investments and maps of drought
threats.

Impact of drought at chemical and ecological level

An analysis of the impacts of drought on the ecological / chemical status of water bodies has
been included in the Oder RBMP. The analysis shows that droughts could potentially lead to
the deterioration of 13.4% of water bodies to below good condition. However, no information is
available on how the analysis was conducted. No information has been included on the
impacts of droughts within the Vistula RBMP.

134 http://44mpa.pl/miejskie-plany-adaptacji/

135 Blauhut and Stahl (2023) Drought Impact Database, Deliverable 1.4, Confidential report.

136 Rossi et al., (2023) European Drought Risk Atlas.

137 “.. a phenomenon consisting of the occurrence of a hydrological or hydrogeological drought at the

local, subregional or regional level… which may result in limitations in the possibility of using water,
access to water services or the possibility of agricultural or forestry production”

138 https://dane.gov.pl/en/dataset/2784,plan-przeciwdzialania-skutkom-suszy-ppss

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Presence of drought management plans

A Drought Management Plan has been developed by the National Water Management Authority
(Polish  Waters),  focusing  on  water  retention  infrastructure  measures139.  The  plan  includes
indicators for the utilisation rate of water resources (surface water), which is translated to three
scale  measurements:  normal  (water  exploitation  does  not  deplete  available  resources),
intensive  (pressure  on  water  sustainability,  water resources exploited  at the maximum  water
resource availability), and very intensive (exploitation exceeds the amount of water resources).
Overall, the Drought Management Plan lacks critical components such as solutions to address
water scarcity/ drought in a proactive manner, or procedures for emergency situations.

Drought measures in POM

The prescribed measures within the aforementioned drought management plan include
measures which have led to the development of guidelines for agriculture and education, but
no operational or organisation measures are included to manage drought events.

16.2. Main changes in implementation and progress with

recommendations

The Commission recommendations based on the 2nd RBMPs analysis was:

● Recommendation: Poland should consider ensuring that all its areas susceptible to
drought are covered with appropriate drought management plans and measures.

● Assessment: A drought management plan has been developed but lacks some

essential elements. The plan predominantly focusses on preparedness measures to
increase water storage and retention capacity. However, the plan lacks essential
components of a drought management plan. While it provides a high-level catalogue of
measures and strives to also provide guidelines on good agricultural practices, it does
not yet include concrete operational, organisational or follow-up measures proper to
drought event management.

16.3. Conclusions on gaps in implementation

Climate change adaptation measures which relate to the preservation of water bodies have
been included in the Vistula RBMP, but no such measures have been identified in the Oder
RBMP. Potential maladaptation measures have been identified in the Oder RBMP, where lake
reclamation is listed within the PoMs. Both RBMPs have used climate models formulated for
the national climate change adaptation strategy to project climate change impacts on water
bodies but is it not clear if such analysis informed any climate proofing of measures. A drought
management plan was developed in 2021, which includes a definition of ‘drought’ (no
definition of ‘water scarcity’) and indicators to assess the use of water resources. However,

139 https://dziennikustaw.gov.pl/D2021000161501.pdf

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the RBMPs nor the drought management plan contain operational measures to tackle drought
and water scarcity issues throughout the various phases of drought events.

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Getting in touch with the EU

In person

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via the following form: european-union.europa.eu/contact-eu/write-us_en.

Finding information about the EU

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EU open data

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144

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