Screening of drafts of the second River Basin …ec.europa.eu/environment/water/2015conference/pdf...March 2015 1 Screening of drafts of the second River Basin Management Plans for

March 2015

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Screening of drafts of the second River Basin Management Plans for evidence of action on Commission's recommendations for improvements in Member States’ implementation of the WFD

Member State: France (FR)

Disclaimer The views expressed are purely those of the assessors and may not in any circumstances be

regarded as stating an official position of the European Commission

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1. River Basin District: Artois Picardie

1.1 Headlines

The following passage summarises the main changes made in the draft second RBMP compared to the first RBMPs, for example, as

required in annex VII B.

There is no summary list given. In terms of the general approach of the River Basin Management Plan (RBMP), 3 stages are

explained in the development of the 2nd

RBMP:

1. Identification of the important questions to which the RBMP will need to respond

2. Overview of the status and where we are in the Programme of Measures (PoM) implementation (based on the earlier mid-term

review)

3. Elaboration of the RBMP and the PoMs

This resulted in a list of fundamental orientations and their dispositions (provisions), where more detail is given on the issue and scale

of the problem, how this relates to the assessment and significance of the pressure and the established measures.

Regarding classification issues, France will use other indicators to show progress and will take into account uncertainties in biological

assessment methods.

In the 2nd

RBMP, for rivers and lakes, France is considering using new assessment methods for benthic fauna, fish fauna and

macrophytes in order to better capture various pressures like morphology degradation.

For coastal waters: methods are developed but they have to be completed and intercalibrated.

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Waters in overseas areas are more difficult to assess. Having re-analysed the ecological status of the water bodies, it will be possible

to estimate the number that will achieve „good‟ status in 2015, 2021 and 2027, after validation from the Schema Directeur

d‟Aménagement et de Gestion des Eaux (SDAGE) Project River Basin Committees, which was scheduled for September 2014.

Revision of the surface freshwater monitoring network is under way to integrate the networks of the Nitrates Directive and the WFD (in

France, the Surveillance Control Network or the Operational Control Network), in order to optimise monitoring over time (at the

frequency defined in the WFD, rather than once every four years, as recommended by the Nitrates Directive), which will allow for

better assessment of trends in the level of nitrates.

River Basin Specific Pollutants (RBSP) were selected at basin scale and nine RBSP at national scale (continental France). The list of

RBSP will be revised for the 2nd

cycle.

Heavily Modified Water Bodies (HMWB) and Artificial Water Bodies (AWB) will be reviewed: their designation as modified / artificial

bodies will be reassessed and the 1st cycle non-designated HMWB will be compared to neighbouring Member States (MS). As new

analysis will be performed on small Water Bodies (WB), new HMWB are expected. Besides, changes in Biological Quality Elements

(BQEs) parameters will imply some changes in designation of AWB and HMWB.

For the 2nd

cycle, the methodology for justification of exemptions will be consolidated. Therefore, a guide for the 2nd

cycle is being

finalised. France is expecting more deadline extensions (more measures needed, natural conditions-).

Regarding the article 9 of the Directive (recovery of costs for water services), a harmonised analysis will be set up as a national study.

For ground water status assessment, a new method will be used to assess the balance between groundwater abstraction and

recharge. Furthermore, there will be a national methodology for trend assessment and reversal established and applied in the 2nd

cycle. Eventually, a National guidance document about groundwater threshold values (TVs) was finalised in October 2012. There will

be more TVs established in the 2nd

cycle than in the first: not only TVs based on risks will be considered.

Regarding the PoM, a new national Methodological Guide on these is being finalised.

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For measures related to hydromorphology, there will be new legislation to give new legal competence on river management at a local

level (if voted for by parliament), for better implementation of measures. Mandatory works for river continuity restoration will also be

imposed. The mandatory minimum ecological flow will be increased by 2014.

For industries, results of extensive discharge monitoring of substances allowing better pressure identification and measures will be

used.

For Agriculture, new mandatory measures will concern abstraction measures (modification in water abstraction authorisation, set up

of collective management of water abstraction for irrigation (Organisme unique de gestion collective des prélèvements d'eau pour

l'irrigation: OUGC)) and taxation (gradual increasing of fees related to pesticides, new tax on nitrates). Regarding voluntary measures,

articles 29 and 38 of the RDP will be used. The agro-industry will be involved.

In cases where the expectations of the first plan have not been achieved or are not expected to be achieved, there is a description of what

expectations have not been achieved and an explanation of why not.

For groundwater, 2011 quantitative status is in line with expectations (2015 objectives) of the RBMP 2010-2015. The chemical status

changed little.

The objectives for surface water bodies have not been achieved yet. Given the gap between the current state (2011-2012) and 2015 targets,

objectives may not be attained. The media reacts slower than expected to measures implemented. In addition, changes in the monitoring

program has led to additional difficulties to achieve good status (for example the assessment of fish index downgraded water bodies status).

Some measures were not implemented as far as expected. Different causes have been highlighted in the background document.

Due to the economic crisis, resources for the implementation of measures were more limited than expected in the first RBMP.

Regarding the hydromorphological restoration of watercourses, two difficulties have been under estimated in the first cycle. First, the

technical complexity of works, secondly, the legal difficulties to intervene on a private property. Furthermore, there was a lack of

acceptability of these actions.

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Measures addressing agricultural diffuse pollution were not fully implemented. One cause is the uncertainty related to the agri-

environmental measures (MAE). Farmers sign a 5 years contract without knowing if the aid will be renewed afterwards. Furthermore,

financial compensations are considered insufficient and do not cover all the investment and loss of productivity induced by the MAE.

Besides, these compensations are not modulated according to the variation of agricultural prices.

The MAE are not flexible enough to allow a sector based approach. For example, the organic farming sector is not well organised

(procurement and retail).

There is a fear that the administrative requirements related to MAE are burdensome

It is not always proven or clear that MAE are leading to a better environmental efficiency. Furthermore, due to the necessary delay in

response in the environment, especially for groundwater, actions are not leading to rapid tangible results.

1.2 Screening of progress on recommendations made in the Commission Staff Working Document (2015)

For each of the recommendations made in the Commission Staff Working Document (CSWD), which was published in March 2015, Table 2

shows:

A baseline against which to assess progress, and the actions required to solve the issue and fully address the recommendation;

An evaluation (key provided in Table 1); and

Justification for the evaluation of progress.

Table 1 Description of the evaluation criteria used in the screening of progress

Evaluation Description

Strong evidence that actions taken are likely to address the COM recommendation.

All the actions relating to the recommendation have clearly been taken in the second plans. The

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actions are defined in relation to the “baseline” situation in the first RBMPs.

Evidence found that good progress has/is being made

There has been good progress on the actions associated with the recommendation but not all

actions have been taken, some may be on-going with a clear timetable which will solve issues in a

reasonable timeframe (1 year for simple things, 2-3 years for more complex issues).

Some evidence of progress.

Some (but not all) of the actions proposed in the recommendations are mentioned and described

but not in enough detail to be certain that they have been fully taken. Some of the actions required

by the recommendation may not have been taken or mentioned at all.

?

No information could be found on the actions associated with the recommendation.

There is no information in the plan that any of the actions associated with the recommendation have

been considered or taken. The justification must describe the documents that have been screened.

No progress, or implementation of the WFD has worsened

The same inadequate processes, approaches and/or methods used in the first plan have been

reported in the second plan, and/or implementation has worsened in relation to the subject of the

recommendation.

Table 2 Assessment of progress on recommendations made in the CSWD (2015)

Recommendation made in CSWD (March 2015)

Baseline for assessment of progress and actions required to solve the issue and fully

address the recommendation

Evaluation Justification for evaluation of progress

Improve knowledge about the link

between pressures and impacts in

designing and making operational the

measures for the second cycle, in order

to:

1. Refine the significance of the

pressures by quantifying those

which are likely to prevent the

For the first cycle, the link between the status

and the measures was generally unclear.

The measures were planned but there was no

assessment or judgment as to how much the

measures would contribute to the

achievement of WFD objectives.

The main sectors responsible for the different

type of pressures have been identified in all

For item (1):

A new assessment method has been used to

evaluate the risk of not achieving the WFD

objectives. For each water body, the causes

of risk of failure were identified (e.g. risk of

failing good ecological status due to

hydromorphological pressures / water

treatment / industrial pressures / agricultural

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achievement of environmental

objectives

2. Assess the reduction in pressures

required to achieve the

environmental objectives

3. Apportion pressures by their

sources and identify the

responsible sectors/areas.

RBMPs. However, for most of the RBDs, there

is no clear explanation or definition on point

sources, diffuse sources and other pressures.

Fully meeting this recommendation would

mean that the gap that needs be filled for the

achievement of WFD objectives is quantified

in terms of the reductions needed in the

pressures causing water bodies to be failing,

or being at risk of failing, objectives.

Quantification of reductions in pressure

may be in terms of:

• loads of pollutants/contaminants to be

reduced;

• number of barriers to continuity to be

removed or adapted;

• length/area of water bodies to be remediated

or restored;

• volume of abstracted water to be reduced.

It should be clearly described how a source

apportionment has been undertaken that

gives a clear picture of the most important

sources for all identified significant

pressures or impacts. In this context a

source might be considered as a combination

of a pressure type (e.g. diffuse or point source

pressures).

For item (2):

There is no information on whether the

reduction in pressures required to achieve the

environmental objectives has been quantified

or not.

For item (3):

From the summary of the characterisation

document reported in the background

document, one can say that a quantitative

apportionment of each pressure by its source

has been carried out in the form of flow

diagrams for :

Macro-pollutants: loads of organic matter,

nitrogen, phosphorus in kT/year from each

contributory source are given (e.g. for

industry – discharge from connected

industries or industry – discharge from non-

connected industries);

Volume of water being abstracted and

consumed by each sector (industrial,

domestic, agricultural).

For chemical substances, the methodology

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pollution) with the responsible sector or driver

(e.g. diffuse – agriculture, diffuse – forestry).

used to assess the pressure is explained but

there is no result available. It seems that the

flow of pesticides and other micro-pollutants

have been quantified.

However, the sources generating

hydromorphological alterations have been

identified (qualitative) but not apportioned in a

quantitative way.

Different models have been used for the

source apportionment:

NOPOLU for calculating nutrient surpluses

from agricultural origin.

SYRAH for hydromorphological

assessment.

A model from INRA for agricultural

phosphorus.

Mercat‟eau and ARPEGES for agricultural

pesticides.

Enhance measures to tackle pollution

by nutrients (nitrogen and phosphorus),

considering their impact on ecological

status. Full consideration of the basin-

wide impact is needed in this respect

No clear baseline was found in the bilateral

meeting or in the 2012 MS Summary.

One orientation of the RBMP, named “A-3

Reduce pressure from agricultural nitrogen on

the whole territory”, contributes to the

achievement of objectives for groundwater

and transitional water.

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(local and downstream up to transitional

and coastal waters).

In addition, it is stated that a full consideration

of the basin wide impact has been taken into

account in the definition of vulnerable zones.

The following measures are addressing

pollution by nutrients:

ND national action programme (came into

force in 2013) completed by regional action

programme in mid-2014;

Fertilisation management outside of Nitrate

Vulnerable Zones (NVZ) areas;

Use of alternative practices to plant

protection products;

Promoting sustainable practices (organic

farming, grassland);

Action plan for priority catchments;

Erosion control measures.

Check that their nutrient standards are

consistent with biological requirements

for the achievement of good status and

provide a more coherent strategy

encompassing WFD with:

In the first RBMPs, it was unclear what the full

range of measures were and more importantly

how far these measures would go in

addressing agriculture's impact on water. For

the Commission, France should make this

In the RBMP, there is a reference to the

national nitrates action programme and to the

regional nitrates action programmes both

implemented under the ND. Regional action

programmes include reinforced or additional

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The Nitrates Directive (ND) and

Common Agricultural Policy (CAP) in

agriculture

much more transparent in the preparation of

the second RBMP. A coherent strategy for

agricultural action is needed encompassing

ND, WFD and CAP measures.

measures to control nitrate pollution in critical

zones (reinforced actions areas).

In the RBMP, under the orientation “Reduce

pressure from agricultural nitrogen on the

whole territory”, the disposition A-3.2 is called

“make consistent the vulnerable areas with

the RBMP‟s objectives”.

The ND and the CAP are both mentioned as

part of the basic measures (defined at

national level), and specific measures are

listed.

One of those is the conditionality of “support

by the Politique Agricole Commune” based

amongst others on the respect of the action

programme under the ND.






The Urban Waste Water Treatment

Directive (UWWTD) in urban areas



For the 1st cycle, basic measures under

UWWTD were reported to be not enough for 8

RBDs due to point source pressure.

The UWWTD is mentioned as part of the

basic measures.

The UWWTD in urban areas was transposed

into French law. For sensitive areas,

requirements are defined on a best effort

basis and not on results. There is no evidence

that basic measures taken under the UWWT

Directive are sufficient to achieve good

ecological status.

In the Scheldt and Somme RBMP, the

Orientation A-1 “Continue to reduce point

source discharge of classic pollutants” makes

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reference to the UWWTD. The disposition A-

1.1 foresees that any project leader has to

adjust the waste water discharge of his

installation/activities subject to authorisation to

meeting the objective of good status (non-

deterioration of water quality and physico-

chemicals objectives).

There is no specific information on standards.

In particular, it is expected that RBMPs,

based on the necessary reduction in

nutrient load, clearly identify the extent

to which the measures already taken

under the implementation of ND and

UWWTD contribute to the achievement

of WFD objectives and which additional

measures should be taken to actually

achieve these objectives. A clear

identification of basic (mandatory)

measures is expected to be made

transparent both to the sectors and the

general public.

The ND and the UWWTD were implemented

in the national legislation across all 13 RBDs,

including overseas territories.

In the first RBMP‟s, there is no indication (as

there is no specific information available) on

the effectiveness of the measures included in

the ND, and of any of the additional measures

implemented.

It must be clear that the effectiveness of

measures taken under the ND or UWWTD

have been reviewed since the first plan. It

must be explicitly described how the

measures taken under the ND are expected to

contribute to the achievement of WFD

objectives (i.e. how much of the gap they will

fill) and also those relating to the UWWTD.

See above, this is included in the overall table

of basic measures.

There is no explanation on the effectiveness

of measures taken under the ND and

UWWTD.

Regarding the ND, the following

supplementary measure is defined:

Limit agricultural inputs, transfers and

erosion beyond the requirements of the ND

(implementation of measures preventing

erosion and pollutants transfers: hedges,

land cover in winter outside vulnerable

zones, etc.)

Review the regulation of the use of

pesticides in order to effectively reduce

current levels of contamination of rivers

For the first cycle, basic measure in the PoM

referred to the regulation on pesticides put on

the market (Decree of the 12 September

?

The RBMP, the PoM and the background

document were consulted.

There is no reference to the Directive itself but

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and groundwater, making clear linkages

with the implementation of the Directive

on the Sustainable Use of Pesticides.

2006). However, some more measures are

implemented within the context of the

Ecophyto plan which started in 2009.

to the regulation on the use of pesticides

(Decree of the 12 September 2006).

In the RBMP, Ecophyto plan (“Disposition A-

11.5”) is indicated as one of the main plans

that will help to reduce diffuse pollution.

Other supplementary measures defined at

RBD or sub-basin level are addressing the

use of pesticides:

Reduce agricultural pesticides and / or use

alternative practices than phytosanitary

treatment.

Implement sustainable practices

(grasslands, organic, etc.).

However, these measures do not concern the

regulation of the use of pesticides.

The conditionality of the assistance by the

CAP is also mentioned.

Define measures targeted to agriculture

at an appropriate level of detail to

ensure their uptake by farmers and

their inspection by relevant agencies.

In the 1st plans, there was no detailed

information on the different stakeholders

involved in the preparation of the measures

for agriculture and the extent of their

contributions (even if the farming sector were

consulted). Regarding the control of

implementation of the agricultural measures,

in most RBMP‟s it was mentioned that a

A specific program was put in place in the

basin Artois-Picardie: “Programme Water and

Agriculture”. The goal is to protect water

resources by encouraging farmers to

consume less pesticides and nitrogenous

fertilisers. For the period 2010-2011, 12 M€

were allocated to 605 farms.

In addition, technical support and additional

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control mechanism was in place or would be

further developed, but no further details were

provided.

communication tools are being developed.

Conditionality of the assistance by the CAP is

also mentioned.

The RBMPs are expected to make a

clear distinction between mandatory

measures and voluntary ones that will

be funded under the European

Agricultural Fund for Rural

Development (EAFRD).

For the first cycle, some voluntary measures

were based on actions under the EAFRD.

In the RBMP, the only reference to voluntary

measures is related to the voluntary schemes

implemented in Areas with Environmental

Restrictions (AER). Even if it concerns a

voluntary action programme, this programme

can become compulsory if the expected

results are not reached.

Reference to the EARDF is made in the

impact assessment study.

There is no distinction in the PoM between

mandatory measures and voluntary ones.

Ensure that ecological flow is

considered wherever existing and

planned abstractions may jeopardise

the achievement of environmental

objectives. This is particularly crucial

when considering the review of water

allocations and permits and the

construction of new dams and

reservoirs.

An important issue that was not clearly

defined in the first plan was the ecologically

based flow regime. The flow regime and

authorisation was considered as a measure to

tackle the overexploitation of groundwater but

not to ensure a sufficient ecological flow.

As part of the basic measures, the

Environmental code Article L.214-18

addresses this issue. When the administrative

authority shall issue an authorisation or

concession (even for existing construction

from 01/01/14), it is required to set a minimum

flow downstream of the works that must

contribute to the environmental objectives of

the rivers and take into account the ecological

characteristics and the biological quality of

rivers.

Ensure that the RBMPs clearly identify

the gap to good status, and that the

There was no information in the 1st plans on

how the gap required to meet WFD objectives ?


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PoMs are designed and implemented to

close that gap.

had been quantified in terms of the required

reduction of pressures and the respective

contribution to the pressures from the

responsible sectors/activities. There was also

no information on how much of the gaps were

expected to be filled by the different

measures.





or not. There is no information on how much

of the gaps are expected to be filled by the

different measures.

The plan is developed in the form of a series

of orientations with different specific

objectives for each orientation, from which

measures are set out.

France is expected to provide a more

consolidated methodology for

justification of exemptions to the


objectives (in particular as regards the

assessment of affordability and

disproportionate costs).

In the 1st RBMP‟s, there were a relatively high

number of exemptions under Article 4(4) and

4(5) based on disproportionate costs, for

which there was no clear justification (even if

the national guidelines on exemptions

mentioned that alternative financing has to be

sought).

It has to be clear in the 2nd

plan that a

consolidated methodology has been set for

justification of exemptions (which included

harmonised analysis from a national study).

The methodology to assess the costs and

search for funding should be detailed.

?



There is no clear mention to the methodology

used for justification of exemptions to the

achievement of environmental objectives.

The disposition E-5.1 “develop economic

decision aid tools” foresees the development

of an economic analysis and environmental

benefit assessment to help defining works

programmes and contractual funding.

There is one specific paragraph on projects

for which an Art 4.7 exemption needs to be

requested.

An exemption under the article 4.7 is required

for 2 projects (Canal Seine-Nord Europe and

Harbour of Calais 2015).

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Provide a more complete definition of

water services and a proper recovery of

cost to contribute to the objectives,

especially when fully accounting for

environmental and resource costs for

services creating a pressure on water

bodies.

For the 1st cycle, water services have been

interpreted differently across the French

RBDs. Some RBDs had a broad approach,

which took into account all possible

abstraction, storage, treatment, impoundment,

etc. In other RBDs, the approach had been

narrower, taking into account public and

private water abstraction and wastewater

treatment for all sectors, as well as irrigation.

Finally, in some RBDs, the approach had

been even more limited, taking into account

only abstraction and wastewater treatment for

households, industry and abstraction for

agriculture.

There is a specific chapter on water pricing

and cost recovery in the background

document.

A distinction is made between water use and

water services:

Water use includes water intakes,

discharges and all activities which have an

impact on water.

Water services include infrastructures for

water storage, surface or groundwater

abstraction, treatment and distribution,

sewage collection and wastewater

treatment.

The way that the recovery of costs is

established is defined on a case by case

basis.

The recovery of cost is calculated but it is not

clear to what extent environmental costs are

included.

A brief case study is presented, as an

example: pricing system in progressive bands

based on water consumption in Dunkerque.

Consider restoration measures as well Those measures were not explicitly described Five main focuses have been defined in the

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as 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.

in the first plan. The development of the

second RBMPs should be coordinated with

the development of flood risk management

plans and the use of this type of measure is

seen as a win-win situation in achieving the

objectives of both plans.

Scheldt and Somme RBMP. One of them is

defined as the following “rely on the natural

functioning of the environment to prevent and

limit the negative effects of floods”.

Several “key directives” are then defined. Two

of them are:

Orientation C-3: Give priority to a natural

functioning of the watersheds.

Orientation C-4: Preserve and restore the

natural dynamic of watercourses

In addition, one of the two measures against

the flood focus considers the development of

expanding flood areas.

However, there is no mention of a specific

process leading to alternative solution to a

grey infrastructure.

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1.3 Water services excluded from the requirement of WFD Article 9 “Recovery of costs for water services”

Table 3 Water services explicitly included in/excluded from cost recovery and Article 9.4 exemptions applied

Water service

Explicitly included in cost recovery

(yes/no/no information/not

clear)

Explicitly excluded from cost recovery


clear)

Article 9.4 exemptions

applied (yes/no/no

information/not clear)

Drinking water abstraction (surface and/or groundwater), treatment and distribution

Yes No information

Sewage collection and wastewater treatment Yes No information

Drinking water abstraction (surface and/or groundwater), treatment and distribution AND sewage collection and wastewater treatment (when considered together)

Yes No information

Irrigation water abstraction, treatment and distribution Yes No information

Self-abstraction Yes No information

Impoundment and storage of water Yes No information

Impoundment for flood protection No No information

Impoundment for navigation No No information

Other (please describe in text box below) Yes No information

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2. River Basin District: Loire

2.1 Headlines



There is no summary list given.

There are three stages that are explained in the development of the 2nd

River Basin Management Plan (RBMP),:

1. identification of the important questions to which the RBMP will need to respond

2. overview of the status and where we are in the Programme of Measures (PoM) implementation (based on the earlier mid-term

review)

3. elaboration of the RBMP and the PoMs



Further on, climate change adaptation is taken into account.


assessment methods.

In the 2nd



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Revision of the surface freshwater monitoring network is under way to integrate the networks of the Nitrates Directive (ND) and the

WFD (in France, the Surveillance Control Network or the Operational Control Network), in order to optimise monitoring over time (at

the frequency defined in the WFD rather than once every four years, as recommended by the Nitrates Directive), which will allow for


River Basin Specific Pollutants (RBSP) were selected at basin scale and 9 RBSP at national scale (continental France). The list of


cycle.



analysis will be performed on small Water Bodies (WB), new HMWB are expected. Besides, changes in Biological Quality Elements


For the 2nd


cycle is being

finalised. France is expecting more deadline extensions (more measures needed, natural conditions).

Regarding the article 9 of the Directive (recovery of costs for water services), a harmonised analysis will be set up as a national

study.





cycle than in the first: not only TVs based on risks will be considered


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In 2011, 31% of surface WB (rivers, lakes, estuaries and coastal waters) are in good ecological status. Over the last five years (2007

to 2011), the ecological status remained broadly stable for two main reasons:

1. Ecological status summarises a set of quality elements (invertebrates, fish, physical chemistry, etc.) and parameters

(phosphorus, organic matter, nitrates, etc). If even one of these quality constituent elements is measured in a state of "less than

good" then the whole ecological status is classified as "less than good". Thus, good ecological status can only improve when

actions are carried out and have effect on all elements/parameters.

2. The implementation of the actions in the PoM 2010-2015 have been delayed, including operations associated with the two

major issues of the basin that are: improving morphology of rivers and reducing agricultural pollution. Barriers to

implementation may have been undervalued: stakeholders, technical difficulties in the design and implementation of the work,

lack of visibility in terms of sustainability and the efficiency of the agri-environmental measures on the levels of quality

parameters measured in WB.

Therefore, the achievement of the objective in 2015 to reach good ecological status for 39% of the water bodies, as was set in the

2010-2015 Sdage (RBMP) seems difficult.

The following interpretation is given in the RBMP: This negative finding, however, needs a careful interpretation and it actually hides

the progress made since the validation of Sdage 2010- 2015: the ecological status changes little because all the component

indicators do not all move simultaneously.

However, significant progress can be demonstrated when the analysis on the elements of quality or settings are examined

individually.

For example, in river quality, improvements are noted on the parameters "Total phosphorus" and "organic matter". They are

linked to the continuation of efforts undertaken on treatment and collection of urban and industrial wastewater. In the interim

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PoMs 2010-2015 established in late 2013, the large majority of actions planned in relation to sanitation were already scheduled

or implemented.

The evolution of the chemical status of groundwater is another interesting figure: 10% of ground water bodies (GWB) are

classified as good status due to the reduction in nitrates and pesticides loadings. This improvement is to the credit of the

application of regulatory measures.

On the difficulties of implementing actions to improve the morphology and reduce diffuse pollution, the 10th action

programme of the water agency Loire-Bretagne (2013-2018) includes a number of actions that raise some difficulties observed in the

balance sheet through the 2010-2015 PoM, such as, for example: increased resources for aquatic environments, support for project

leaders of local operations, strengthening project management, individual support for farmers, etc. Nevertheless, it should be stressed

that the interventions of the water agency alone cannot solve all the difficulties of implementing the actions. Improving the status of

water bodies depends also on the orientation of other sectoral policies, which sometimes prioritise mobilising resources to serve

different purposes and even those that are contradictory with the WFD objectives.

In the section on Rethinking the management of watercourses, it is indicated that physical alterations are the main cause of

difficulties for reaching good ecological status for watercourses in 2015. They refer to (1) physical modifications and (2)

modifications to water flow/flow regime. These modifications are related to several activities such as hydro-electricity, agriculture,

navigation, water tourism, gravel extraction, transport infrastructure development, and climate change. Further on, reference is made

to erosion problems.

For that reason, the management plan has four principal orientations:

1. Preventing degradation;

2. Restoration of degrading watercourses;

3. Awareness raising for inhabitants and developers; and,

4. Ensuring better knowledge on the effects of certain actions.

March 2015

22



shows:

















?







March 2015

23

recommendation.










to:





objectives.

2. Assess the reduction in

pressures required to achieve

the environmental objectives.






















may be in terms of:

loads of pollutants/contaminants to be

reduced;

In the background documentation to the

RBMP (Presentation Synthetique relative a la

gestion de l‟eau du basin), It is indicated that

the analysis of risk is based on improved

methods and elements than the earlier one in

2004.

For item (1):

In 2004, little data were available. Numerous

meetings have been organised with technical

and local partners. With that information, it

could be seen that (1) diffuse pollution of

nitrates, phosphorous and pesticides still

remain a problem and the PoMs need to

prioritise actions in vulnerable zones, such as

drinking water zones where algae blooms still

occur, and combating erosion (phosphorus

fertilisers). Nitrate and phosphorus data are

used. Further on, it is indicated that

morphology still remains an issue (no data are

given). Water abstraction data are used to

identify pressures due to irrigation. For each

GWB, it is identified if it is at risk as a

March 2015

24





number of barriers to continuity to be

removed or adapted;

length/area of water bodies to be

remediated or restored;

volume of abstracted water to be

reduced.










qualitative or quantitative assessment and the

specific cause is noted. Similarly for protected

areas the pressures are detailed.

For item (2):

For specific pollutants (chapter 45 of the

RBMP) objectives for reductions of

emissions are given (as % reduction) for

each individual pollutant on the list of specific

pollutants. Similarly, in chapter 2, a reduction

objective has been formulated for nitrate, (with

one value per sub-basin).

For item (3):

Apportion pressures by their sources: have

been carried out per orientation in a

qualitative way but not in a quantitative way,

except for dangerous substances, but there is

still a lot of uncertainty involved.










For the Loire river basin, the domain

“agriculture” comprises actions against

pollution from diffuse origin. This is around

23% of the amount (in euros) of the total PoM

2016-2021. This part of the plan focuses on

measures to reduce diffuse pollution from

nitrogen, phosphorus and pesticides. The link

is made to the water bodies at risk from each

of these pressures. 615 M Euro will be spent.

March 2015

25





It is indicated that there is a significant change

in relation to the 2010-2015 programme.

There has been a request from the Ministry of

Ecology for an evaluation of two particular

actions under the establishment of Nitrate

Vulnerable Zones (NVZ), (1) the

establishment of cultivation for trapping

nitrates and (2) grass strips along

watercourses. If these are carried out across

the basin it would correspond to

approximately € 110 million per year. The

other change is that the PoM 2016-2021 are

defined for priority target areas which are the

catchment areas of WB subject to

eutrophication

It is mentioned in the RBMP 2016-2021 that

the framing of the PoM

2010-2015 was more general and applied

certain actions indiscriminately across the

whole territory. For the 2016-2021 plan the

actions appear to be set out in more detail

and are more focused.

It is indicated that a threshold of 11.5 mg/l of

nitrates (annual mean) is needed in order to

have an acceptable level for the coastal

environment. This will need to be taken into

account by all actors and based on that, a

reduction of effluent nitrate load of between

March 2015

26





10% and 40% is planned for the Lore sub-

basins.

There is a specific orientation included

which is preserve the coastal area and

reduce significantly the eutrophication in

coastal and transitional waters.

As a summary, one can conclude actions are

more focused towards the area where they

need to be applied, and that it is taken into

account that stricter nutrient standards need

to be applied in order to ensure good status in

the coastal zone.






The Nitrates Directive (ND) and

Common Agricultural Policy (CAP) in

agriculture










No information given. Reference is made to

the national and regional nitrate action

programme.

The RBMP is structured alongside the

pressures, the objectives to be reached and

the need to take action. On the standards etc.,

no specific information is included. The

background documentation gives a synthesis

of the assessment results and the monitoring

programme for the Loire basin. It cannot be

seen that the nutrient standards for the 2nd

RBMP are now more aligned to biological

requirements. A link with the rural

development programme is given when the

financing of the measures is discussed.

March 2015

27





In the RBMP, under the orientation “Reduce

pressure from agricultural nitrates on the

whole territory”, the disposition A-3.2 is called

“make consistent the vulnerable areas with

the RBMP‟s objectives.

CAP is also part of the basic measure table.






The Urban Waste Water Treatment

Directive (UWWTD) in urban areas






No information is given.

On the standards etc., no specific information

is included.

It cannot be seen that nutrient standards for

the 2nd

RBMP are now more aligned to

biological requirements or not.

On the UWWTD measures, no specific

information was found except in the table on

basic measures.




















implemented.




In relation to the ND and the UWWTD, basic

measures are related to each directive. See

PoMs ANNEXE. Liste des mesures de base

(Guide DCE Programme de mesures – Guide

pour l‟élaboration, la mise en oeuvre et le

suivi du programme de mesures en

application de la directive cadre sur l‟eau) .

No clear distinction between those for the ND

and UWWTD, as for example measures from

ND are also included in the Table with

measures on specific disposition. The

assessment on how the ND and the UWWTD

March 2015

28





general public. must be explicitly described how the





contribute to achieving the objectives is not

been made. Furthermore, in the PoM,

measures to reduce nitrate pollution all refer

to the Nitrate Directive (basic measures).













?

The RBMP, the PoM and its accompanying

documents were consulted.

No reference is made to the Directive on the

Sustainable Use of Pesticides.

The only measure related to the regulation of

the use of pesticides (national basic measure)

is the same as in the first cycle (Decree of the

12 September 2006). Reductions on

emissions are detailed for the pesticides

included in the list of specific pollutants.















provided.

It is indicated in the RBMP that all actions on

nitrate reduction (Nitrate Action Programme)

are reinforced following stipulations in the

code de l‟environnement. It is indicated that

regulatory approaches are mainly possible in

the NVZ that are delineated. It is indicated

that a threshold of 11.5 mg/l of nitrates

(annual mean) is needed in order to have an

acceptable level for the littoral (coastal)

environment. This will need to be taken into

account by all actors and based on that, a

reduction in nitrate load from effluents of

March 2015

29





between 10% and 40% is planned for the

Lore sub-basins. Therefore, a link is made

with coastal quality. Further on, there is a

specific chapter on “preserver le littoral” where

the objective is to significantly reduce

eutrophication in coastal and transitional

waters.

Further on, one of the chapters within the

RBMP is on facilitating local governance and

reinforcing the consistency of territories and

public policy. There is also a specific chapter

on mobilising all sectors and making them

aware of the RBMP.












Restrictions (AER). Even if it concerns a

voluntary action programme, this programme

can become compulsory if the expected

results are not reached.













In the RBMP there are two actions set out:

(1) To maintain a minimum flow in the river the

administrative authority shall issue an

authorisation or concession and it is required

to set a minimum flow downstream of the

March 2015

30








reservoirs.

not to ensure a sufficient ecological flow. works by taking into account the objective of

achieving good status of rivers, in accordance

with Article L.214- 18 of the Environmental

Code. The aim is to integrate the local and

cumulative impacts of works by ensuring that

there is a consistency of instream flow. In

order to verify the effectiveness of the value

adopted, the administrative authority may

determine, in accordance with Article R.214-

16 of the Environmental Code, the effects of

monitoring on aquatic environments to

monitor the ecological quality of the rivers

concerned. This monitoring can lead to a

readjustment of the minimum flow set to

achieve the objectives of good state;

(2) Reducing the effects of non-natural

variations in aquatic environments. Based on

research/experiments, the administrative

authority may prescribe the requirements

needed to reduce non-natural fluctuations in

flow.




close that gap.


how the gap required to meet WFD objectives





?






or not (except for specific pollutants where %

March 2015

31







measures.

reduction is specified in order to assess

progress against the objective).

There is no information on how much of the

gaps are expected to be filled by the different

measures.














sought).


plan that a








There is no clear mention of the methodology



In the glossary, two guidance documents

developed in 2013 on methodologies in

relation to justifications of exemptions are

mentioned: Le guide national de décembre

2013 (ministère de l'Ecologie, du

Développement durable et de l‟Énergie

(2013), Guide méthodologique de justification

des dérogations prévues par la directive cadre

sur l'eau, décembre 2013, 40 p.).

On disproportionate costs, there is a specific

section as part of the cost recovery chapter.

There is one specific chapter on projects for

which an Art 4.7 exemption needs to be

requested. There are no projects that fulfil the

criteria in order to require exemption.

Provide a more complete definition of For the 1st cycle, water services have been There is a specific chapter on water pricing

March 2015

32










bodies.

interpreted differently across the French RBD.

Some RBDs had a broad approach, which

took into account all possible abstraction,

storage, treatment, impoundment etc. In other

RBDs, the approach had been narrower,

taking into account public and private water

abstraction and wastewater treatment for all

sectors, as well as irrigation. Finally, in some

RBDs, the approach had been even more

limited, taking into account only abstraction

and wastewater treatment for households,

industry and abstraction for agriculture.


document.

Users and services are defined. It is then (for

each user) defined how much the

recuperation of the costs are established. In

the next period, it is explained that it will be

necessary to develop methods and data for

better determining the environmental cost.

This is not included yet. The analysis will also

look into the aspect of disproportionate cost

when looking into environmental cost.

A brief case study is included on the coastal

environmental and resource cost, but this is

given as an example and is not included as an

actual cost-recovery methodogy.

Consider restoration measures as well









infrastructure.

Those measures were not explicitly described







When looking into the measures and the

green infrastructure measures proposed, it

was found that measures are focused on

restoring natural flow and hydromorphological

restoration, restoring ecological connectivity,

management of humid zones, etc. No details

are given, except for the measures regards

riparian forest plantation.

There is no specific information included on

the enhanced use of green infrastructure

instead of the grey infrastructure.

March 2015

33



Water service



clear)



clear)


applied (yes/no/no



Yes No information



Yes No information



Impoundment and storage of water No No information



Other (please describe in text box below) No information

March 2015

34

3. River Basin District: Rhone

3.1 Headlines



There is no summary list given regarding changes of methodology between the 1s River Basin Management Plan (RBMP), and the

draft 2nd

one.

In the background document, it is stated that the water bodies have been re-defined. The number of groundwater bodies has then

changed from 180 in 2009 to 240 in 2013.

In terms of the general approach of the RBMP, Three stages are explained in the development of the 2nd

RBMP:

1. Identification of the important questions to which the RBMP will need to respond.

2. Overview of the status and where we are in the Programme of Measures (PoM) implementation (based on the earlier mid-term

review).

3. Elaboration of the RBMP and the PoMs.




assessment methods.

March 2015

35

In the 2nd




Waters in overseas areas are more difficult to assess. Having re-analysed the ecological status of the water bodies, it will be possible

to estimate the number that will achieve „good‟ status in 2015, 2021 and 2027, after validation from the SDAGE Project River Basin

Committees, which is scheduled for September 2014.



the frequency defined in the WFD rather than once every four years, as recommended by the ND), which will allow for better

assessment of trends in the level of nitrates.



cycle.



analysis will be performed on small Water Bodies (WB),new HMWB are expected. Besides, changes in Biological Quality Elements


For the 2nd


cycle is being





March 2015

36





For measures related to hydromorphology, there will be new legislation to give new legal competence on river management at a local

level (if voted for by parliament), for a better implementation of measures. Mandatory works for river continuity restoration will also be

imposed. The mandatory minimum ecological flow will be increased by 2014.

For industries, results of extensive monitoring of substances in discharge effluents will be used, allowing better pressure and measure

identification.

For Agriculture, new mandatory measures concerning abstraction measures (modification in water abstraction authorisation, set up of

collective management of water abstraction for irrigation (Organisme unique de gestion collective des prélèvements d'eau pour

l'irrigation: OUGC)) and taxation (gradual increasing of fees related to pesticides, new tax on nitrates) will be used. Regarding

voluntary measures, articles 29 and 38 of the Rural Development Programme (RDP) will be used. In addition, the agro-industry will be

involved.



For groundwater, the objective of reaching 100% of groundwater bodies (GWB) at good quantity status as planned in the first plan will

not be attained. Otherwise, the chemical status of GWB evolved as expected.

For surface water, the ecological status of WB has not changed significantly from 2009 (for transitional waters, the acquisition of new

monitoring data is leading to a higher number of WB at risk). Surface WB at good ecological status are not necessarily those

predicted to be in the 1st plan. For example, only 65% of water bodies for which the RBMP 2010-2015 set a target of good ecological

status by 2015 reached this status. In contrast, about 20% of water bodies for which the RBMP 2010-2015 set a target of good

ecological status by 2021 or 2027 are already at good status.

March 2015

37

The chemical status of WB remains stable compare to 2009.

The main causes of deterioration of water status are: ecological morphology and continuity, pesticide pollution, abstractions and

pollution from oxidisable and organic matter.

Some measures were not implemented as far as expected. Different causes have been highlighted in the background document:

Due to the economic crisis, resources for the implementation of measures were more limited than expected in the first RBMP.

This is especially the case for territorial authorities which are the main project leaders for actions related to drinking water,

waste water treatment and hydromorphological restoration of watercourses.

There is a lack of interest for hydromorphological restoration. Others measures are then considered to be in competition, for

example those addressing floods or enhancing the landscape.

There are technical and legal complexities (property law) to implement measures related to hydromorphological restoration.

It was difficult to mobilise the agricultural sector against nitrates and phosphorus pollution, mainly because actions are not

leading to rapid tangible results and it was complicated to implement new actions in times of economic crisis.



shows:




March 2015

38














?







recommendation.














documentation were consulted.

In the background document, the dangerous

March 2015

39





to:





objectives

2. Assess the reduction in pressures

required to achieve the

environmental objectives



















may be in terms of:


reduced;


removed or adapted;


remediated or restored; and,

volume of abstracted water to be reduced.

substances leading to a risk of failure were

identified for each WB. This is not the case for

other pressures.




or not.

The annual flow of each specific dangerous

substance (41) has been quantified in terms

of g/year.

There is no source apportionment.

In the documents consulted, there is no

evidence that pressures were apportioned by

their sources. There is no identification of the


March 2015

40























The orientation 5B “address eutrophication in

aquatic environments” focuses on nutrients

reduction. It is clearly stated that

eutrophication has to be tackled by acting in a

coordinated manner at watersheds level.

Furthermore, actions should not be limited to

areas where eutrophication occurs but should

address all inputs of pollutant in the

watershed.






the Nitrates Directive (ND) and Common Agricultural Policy (CAP)










The ND and the CAP are both mentioned as

part of the basic measures (defined at

national level), and specific measures are

listed.

One of those is the conditionality of “support

by the Politique Agricole Commune” based

amongst others in respect to the action

programme under the ND.

In the RBMP for Rhone, the orientation 5B

March 2015

41





makes a specific reference to the ND.

There is a specific disposition to reduce inputs

of phosphorus and nitrogen in aquatic

environments.

For phosphates, guide values that go beyond

the requirements of the national regulation are

defined: 0.2 mg/l for watercourses; 0.15 mg/l

for lagoons and 0.07 mg/l for sensitive areas

(legal standard is set between 0.1 mg/l and

0.5 mg/l for good status).

There is no information available on how

these standards have been set.

These values should serve to identify effective

measures to reduce phosphorus inputs:

source reduction, tertiary treatment, reduce

diffuse pollution (reducing emissions from

fertilising crops, farms and greenhouses,

reducing runoff and erosion, etc.).






the Urban Waste Water

Treatment Directive (UWWTD) in

urban areas.






The UWWTD is mentioned as part of the

basic measures.

There is no evidence that basic measures

taken under the UWWT Directive are sufficient

to achieve good ecological status.

In the RBMP for Rhone, the orientation 5A

“continue to address domestic and industrial

pollution” makes a specific reference to the

UWWTD.

March 2015

42





The implementation of the Urban Wastewater

Directive (ERU) has reduced organic pollution

throughout the Rhone-Mediterranean Basin

by increasing the levels of water treatment

from 67% to 93% over the last twenty years.

The RBMP intends to clarify the conditions

under which it is necessary to strengthen the

measures provided in the regulations

(Directive ERU legislation on classified

installations) where it is locally needed (for

example in sensitive areas).

The disposition 5A-02 plans to adapt

discharge conditions based on the notion of

allowable flows for particularly sensitive

environments (to address eutrophication for

example).

It is stated that progress has to be made in

the identification and quantification of

pollutants flows taking into account the

different sources of pollution.















See above, this is included in the list of basic

measures and under orientations 5A and 5B.

It is stated that further measures than those

under the UWWTD could be needed when

this is required by local conditions (for

example in sensitive receptors like lagoons).

March 2015

43










general public.

implemented.









There is no quantification of the effectiveness

of measures taken under the ND and

UWWTD.














document were consulted. There is no

reference to the Directive on the Sustainable

Use of Pesticides (2009/128/EC).

A set of dispositions is defined under the

orientation 5D “Address pollution from

pesticides by substantial changes in current

practices”. One of them is named “Establish

local regulations regarding the use of

pesticides in sensitive areas”. It refers to the

national regulation on the use of pesticides

(Decree of the 12 September 2006) which

allow the “préfet” to limit or even forbid the

use of specific pesticides.


CAP is also mentioned.





The disposition 5D-02 “Encourage more

environmentally friendly farming practices by

March 2015

44















provided.

mobilising actors and financial tools” aims to

involve the farmers more by implementing

technical support through different plans /

organisations (regional plans, environmental

and economic interest groups, Water

Development and Management Scheme

(SAGE)).

No more information was found.









There is no distinction in the PoM or in the

RBMP between mandatory measures and

voluntary ones.









reservoirs.






not to ensure a sufficient ecological flow.

One measure is to implement a strategy to

ensure a minimum water flow or to increase

the “minimum flow downstream” beyond legal

requirements. It refers to hydroelectric

schemes and to Article L.214-18 of the

Environmental Code. When the administrative

authority shall issue an authorisation or

concession (even for existing construction

sites from 01/01/14), it is required to set a

minimum flow downstream of the works that

must contribute to the environmental

objectives of the river and take into account

March 2015

45





the ecological characteristics and the

biological quality of rivers.




close that gap.









measures.

?






or not. There is no information on how much

of the gaps are expected to be filled by the

different measures.

The plan is developed in orientations with

different specific objectives per orientation,

from which measures occur.














sought).


plan that a






?



There is no clear mention of the methodology



In the glossary, there are some more

clarifications on disproportionate costs and

economic analysis.

There is one specific chapter on projects for

which an Art 4.7 exemption needs to be

requested. There are no projects that require

exemption under this article.

Provide a more complete definition of For the 1st cycle, water services have been There is a specific chapter on water pricing

March 2015

46










bodies.














document.

Both water use and water services are

considered in the water recovery calculation.

Water services include infrastructures for

water storage, surface or groundwater

abstraction, treatment and distribution,

sewage collection and wastewater treatment.

Rhone has carried out an elaborate

calculation integrating environmental costs.

The disposition A “know and understand

better the economic and social impacts” sets

out the adjustment of tariffs on basis of the

cost recovery level (disposition 3-05).










infrastructure.







objectives of both plans

In the RBMP from Rhone, there is a specific

orientation (n°8) related to flood protection. It

is clearly stated that natural water retention

measures should be preferred. Prior to any

retention work, an analysis of alternative

solutions has to be carried out. This refers to

a specific process: “PAPI-PSR”.

Two dispositions aim to preserve and

implement expanding flood areas.

March 2015

47



Water service



clear)



clear)


applied (yes/no/no



Yes No information



Yes No information



Impoundment and storage of water Not clear No information



Other (please describe in text box below)

The calculation of recovery of costs for water services takes into account:

The funding and pricing in the water sector.

Contributions of key economic sectors (households, industry and agriculture) to finance water services (public water distribution and

water treatment, self-abstraction, irrigation, etc.).

March 2015

48

The concept of environmental costs.

March 2015

49

4. River Basin District: Adour Garonne

4.1 Headlines



Lessons learned from the first cycle management helped to set more realistic goals for the River Basin Management Plan

(RBMP) 2016-2021.

For some water bodies (WB), the RBMP 2010-2015 aimed to achieve good status in 2015, but in view of current knowledge, a later

deadline seems more feasible and an extension of the deadline has been requested.

For 127 WB a postponement had been included in the RBMP 2010-2015 although good ecological status could be achieved by 2015.

Similarly, for 191 WB a postponement was listed as good chemical status could be reached in 2015. For groundwater bodies (GWB),

a postponement was listed as good quantitative status could be reached as early as 2015. And for four GWB, a delay was listed as

the good chemical status could be achieved by 2015.

Better knowledge on the status of the WB and difficulties experienced in mobilising multiple stakeholders for measures in

relation to the field of agricultural pollution, quantitative management or hydromorphological restoration.

This RBMP integrates this knowledge to update good objectives for each WB in 2021 and in 2027.

There was also a lack of ownership for certain measures. They are also based on the assumption of effective basic measures and

the benefit of two PoMs successively by 2021.These goals are no less ambitious if we take into account uncertainties related to

general economic conditions and the likely institutional slowdowns related to the implementation of local government

reform.

March 2015

50

In terms of the general approach of the RBMP three stages are explained in the development of the 2nd

RBMP:

1. Identification of the important questions to which the RBMP will need to respond.

2. Overview of the status and where we are in the PoM implementation (based on the earlier mid-term review).

3. Elaboration of the RBMP and the PoMs.

This resulted in a list of fundamental orientations and their dispositions (provisions), where more detail is given on the issue and

scale of the problem, how this relates to the assessment and significance of the pressure and the established measures.

Furthermore, climate change adaptation is taken into account.


assessment methods.

In the 2nd






the frequency defined in the WFD rather than once every four years, as recommended by the Nitrates Directive), which will allow for




cycle.

March 2015

51



analysis will be performed on small WB, new HMWB are expected. Besides, changes in Biological Quality Elements (BQEs)

parameters will imply some changes in designation of AWB and HMWB.

For the 2nd


cycle is being











For all the riverine WB (measured and modelled), the percent at good ecological status decreases slightly (42% against 48% in 2009).

The difference is explained by the use of a new national model that seems more conservative (status downgraded more often) than

the method used in 2009. However the indicators that assess the content of material organic (Biological Oxygen Demand (BOD5),

Chemical Oxygen Demand (COD) and nutrients) have improved. The reference years of data used are from 2009 to 2010.

The chemical status of the rivers remains generally good (94% of WB in good condition). Cadmium, mercury and hydrocarbons

(PAHs) are the most responsible parameters for downgrading. Pesticides are responsible for the downgrading of only two WB (it

should be remembered that almost all phytosanitary products as part of the chemical status are banned from sale and of use). For

mercury, it should be noted that the majority (68%) of WB downgraded by this metal are located on the upstream basin of the

Garonne (15 WB out of 22).

March 2015

52

The percentage of WB in good condition is almost identical to that in 2009, that is 61%. Three WB had a reduction in quality and four

have better quality than in 2009). The presence of pesticides and nitrates is the main cause of the downgrading of chemical status for

these WB.

Regarding the quantitative status of groundwater, the percentage of GWB in good status increased compared to 2009, but this

increase is mainly due to the decision to classify as good condition all GWB for which no evidence (lacking data) of degradation

exists.

Other reasons given for the reported delays:

Reaction time of the environment.

Delay in the design and implementation of the river restoration actions.

Restoration cannot ensure good functioning of ecosystems in only one planing cycle.

Delay in the implementation of actions in order to reduce diffuse pollution.



shows:




March 2015

53














?







recommendation.













In the background documentation, there is a

presentation given on the plan for water

management.

March 2015

54





to:





objectives

2. Assess the reduction in

pressures required to achieve

the environmental objectives



















may be in terms of:


reduced;


removed or adapted;


remediated or restored;

volume of abstracted water to be

This chapter provides further details regarding

the inventory of dangerous substances, which

leads to a refinement of pressures.

Further on, the measures are included in a

table, and the implementation of the

measures to reach the objectives is followed

by a set of indicators. This receives specific

attention in the chapter in the background

document “Dispositif de suivi destine µa

évaluer la mise en oeuvre du SDAGE 2016-

2012 (RBMP).

The RBMP is structured according to four

orientations that are seen as important for the

2nd

cycle in terms of the management of

water:

Orientation A: create the conditions of

favourable governance in order to reach the

objectives.

Orientation B: reduce pollution.

Orientation C: improve the quantitative

management.

Orientation D: preserve and restore the

functionalities of the aquatic environment.

For each of these orientations, in the

chapters, there is a part on “better knowledge

on the environment to manage the issue” and

“sustainable management” and “manage the

March 2015

55





reduced.










crisis”

The detail is not extensive, but the part on

dangerous substances includes a more

detailed assessment on the significance of the

pressure.

There is a list of dangerous and priority

substances established at the national level

which gives emission reduction targets for

each of the substances. This is neither a list

for the specific pollutants nor source

apportionment.

In the background document there is a table

included that evaluates the fluxes of each

substance for each type of emission (kg/year).

Summary: refinement by quantitative

analysis is done in a limited way; source

apportionment is not carried out for any

pressures/parameters, and reduction of

pressures required to achieve objectives

has not been carried out.










Orientation B “reduce pollution” specifically

focuses on the reduction of nutrients through

agriculture. There is also an orientation that

contains several measures. It is called “Better

know and make known to better manage”.

This orientation focuses on basin-wide

approaches. There is also one specific set of

March 2015

56





measures that focuses on small water bodies

that have to be protected. Further on, there is

a measure on the protection of fish with a link

to estuarine and marine zone management.






the Nitrates Directive (ND) and

Common Agricultural Policy

(CAP) in agriculture

In the first RBMP‟s, it was unclear what the full








both ND, WFD and CAP measures.

Orientation B “reduce pollution” specifically

focuses on the reduction of nutrients through

agriculture and it is noted that better

understanding of the key parameters is

needed. In the PoMs document, it is noted

that the measure on reduction of nitrogen is

included as part of ND implementation for all

sub-basins as well as in the Rural

Development programme with the agri-

environmental measures. The ND is also

mentioned as part of the basic measures, and

supplementary measures for specific WB are

listed.

In addition, the conditionality of “support by

the Politique Agricole Commune [CAP]” is

included in the chapter on diffuse pollution

specific to pesticide usage. CAP is also

included in the basic measure table.











The UWWTD is included as part of the basic

measures, and supplementary measures for

specific WB are listed. In addition, in order to

reduce pollution (one of the thematic

orientations) the UWWTD is referenced.

March 2015

57





the Urban Waste Water

Treatment Directive (UWWTD) in

urban areas













general public.








implemented.









See above, this is included in the overall

tables of measures and is clearly described.

The assessment on how the ND and the

UWWTD contribute to achieving the

objectives is not been made. Furthermore, in

the PoM, measures to reduce nitrate pollution

all refer to the Nitrate Directive (basic

measures).













?

The Ecophyto plan is noted as one of the

main plans that will help to reduce diffuse

pollution. In addition, it is indicated that there

will be regulations for the use of pesticides.

The Directive on the Sustainable Use of

Pesticides. itself is included under the PoMs

Basic Measures table.

March 2015

58





Furthermore, the conditionality of the

assistance by the CAP.















provided.


CAP is referenced. There is an orientation in

the plan which is called “creation of better

conditions for the governance in order to

reach the objectives”; but no specific details

are given on agriculture, farmers or farm

inspections.












Restrictions (AER).

A voluntary action programme can become

compulsory if the expected results are not

reached.













Article L.214- 18 of the Environmental Code of

the basic measures.

Specific attention is paid to the effects of

hydropower (hydropeaking and downstream

March 2015

59








reservoirs.

not to ensure a sufficient ecological flow. low flows).

The adaptation of the minimum flow values

maintained downstream of works,

including those intended for the production of

hydroelectricity (Article L. 214-18 of the

Environment Code), must contribute to the

environmental objectives of the rivers and

take into account the ecological

characteristics and the biological quality of

rivers




close that gap.









measures.

The gap to good status is more or less clear

but the projected objectives that should be

reached have been changed for the WB in the

Garonne river basin. The plan is set out as a

series of orientations with different specific

objectives, from which measures are

produced. This is all included in a Table

alongside the implementation of the measures

and the indicators.














sought).


plan that a

There is not a specific chapter on the

methodology. France reports that for three

more water bodies derogations have been

requested - to a lower objective. In the

chapter on objectives, there is a box with

information on the derogation for extending

the time to reach the objective, but this is

lacking in details. Although there is new

March 2015

60










national guidance there is no specific

reference to it within the RBMP.

Provide a more complete definition of






bodies.

For the 1st cycle, water services have been













The treatment, distribution, abstraction and

stocking of water, as well as collection and

treatment of used water as water services is

well defined. The water users are categorised

as households, public services, industries,

and agriculture. Furthermore, a distinction is

made between collective and individual

services (e.g. industry treating their own

wastewater is an individual service). There

was a specific study carried out by Ernst &

Young on cost recovery estimating that there

is 1395 million on costs on top of the budget

for the basin Adour Garonne. The

environmental costs are reported to be more

difficult to estimate.















No specific green infrastructure measures are

referred to but they are included in the several

orientations. For example, erosion reduction

measures such as planting herbs that retain

the soil.

March 2015

61







infrastructure.



Water service



clear)



clear)


applied (yes/no/no



Yes No information



Yes No information



Impoundment and storage of water No information



Other (please describe in text box below) No No information

Documents

Screening of drafts of the second River Basin …ec.europa.eu/environment/water/2015conference/pdf...March 2015 1 Screening of drafts of the second River Basin Management Plans for