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Document 52015SC0053
COMMISSION STAFF WORKING DOCUMENT Report on the implementation of the Water Framework Directive River Basin Management Plans Member State: CROATIA Accompanying the document COMMUNICATION FROM THE EUROPEAN COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Actions towards the 'good status' of EU water and to reduce flood risks
COMMISSION STAFF WORKING DOCUMENT Report on the implementation of the Water Framework Directive River Basin Management Plans Member State: CROATIA Accompanying the document COMMUNICATION FROM THE EUROPEAN COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Actions towards the 'good status' of EU water and to reduce flood risks
COMMISSION STAFF WORKING DOCUMENT Report on the implementation of the Water Framework Directive River Basin Management Plans Member State: CROATIA Accompanying the document COMMUNICATION FROM THE EUROPEAN COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Actions towards the 'good status' of EU water and to reduce flood risks
SWD/2015/53 final
COMMISSION STAFF WORKING DOCUMENT Report on the implementation of the Water Framework Directive River Basin Management Plans Member State: CROATIA Accompanying the document COMMUNICATION FROM THE EUROPEAN COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Actions towards the 'good status' of EU water and to reduce flood risks /* SWD/2015/0053 final */
TABLE
OF CONTENTS 1. General
information.. 4 2. Status
of River Basin Management Plan reporting and compliance. 6 3. Governance. 7 3.1. Timeline
of implementation. 7 3.2. Administrative
arrangements. 8 3.3. RBMPs
- Structure, completeness, legal status. 9 3.4. Consultation
of the public, engagement of interested parties. 9 3.5. Cooperation
and coordination with third countries. 9 3.6. Integration
with other sectors. 9 4. Characterisation
of river basin districts. 10 4.1. Water
categories in the RBD.. 10 4.2. Typology
of surface waters. 10 4.3. Delineation
of surface water bodies. 10 4.4. Identification
of significant pressures and impacts. 11 4.5. Protected
areas. 12 5. Monitoring.. 12 5.1. Monitoring
of surface waters. 13 5.2. Monitoring
of groundwater. 18 5.3. Monitoring
of protected areas. 19 6. Overview
of status (ecological, chemical, groundwater) 19 7. Assessment
of ecological status of surface waters. 24 8. Designation
of heavily modified water bodies (hmwb) and assessment of good ecological
potential 27 9. Assessment
of chemical status of surface waters. 29 10. Assessment of groundwater status. 30 10.1. Groundwater
quantitative status. 30 10.2. Groundwater
chemical status. 30 10.3. Groundwater
trend assessment. 31 10.4. Groundwater-dependent
terrestrial ecosystems. 31 10.5. Groundwater
protected areas. 31 11. Environmental objectives and exemptions. 32 12. Programmes of measures. 33 12.1. Programme
of measures – general. 33 12.2. Measures
related to agriculture. 34 12.3. Measures
related to hydromorphology. 35 12.4. Measures
related to groundwater. 35 12.5. Measures
related to chemical pollution. 36 12.6. Measures
related to Article 9 (water pricing policies) 36 12.7. Additional
measures in protected areas. 37 13. Climate change adaptation, water scarcity and droughts, flood
risk management and other emerging and linked issues as part of the rbmp. 38 13.1. Adaptation
to Climate Change. 38 14. Recommendations. 38
1.
General information
Figure 1.1: Map of River Basin Districts || || || International River Basin Districts (within EU) || || || International River Basin Districts (outside EU) || || || National River Basin Districts (within EU) || || || Countries (outside EU) || || || Coastal Waters Source: WISE,
Eurostat (country borders) Croatia
has a population of 4.4 million and a surface area of 56.6 thousand square km[1]. Its geography ranges
from the lowlands of the Pannonian basin to the Dinaric Alps and the Dalmatian
coastline, over 1700 km long. In addition, Croatia has over 1 200 coastal
islands. The Dinaric Alps, coastal areas and islands have a predominantly
karstic geology. Croatia
has two river basin districts (RBDs): the Danube RBD and the Adriatic RBD (see
Table 1.1). Croatia’s Danube RBD (HRC) is part of the international Danube
river basin district, which covers 14 Member States and third countries. Among
these, HRC borders on Slovenia, Hungary, Serbia and Bosnia and Herzegovina. The
Adriatic RBD (HRJ) includes Croatia’s coastal islands. Moreover, due to these
islands, many of them small in size, and Croatia’s long coastline, this RBD
also covers extensive coastal waters. RBD || Name (English / Croatian) || Size (km2) * || Countries sharing borders Mainland || Islands || Coastal Waters || Total HRC || Danube / Dunav || 35 101 || || || 35 101 || Bosnia and Herzegovina, Hungary, Serbia, Slovenia HRJ || Adriatic / Jadransko || 18 185 || 3 262 || 13 842 || 35 289 || Bosnia and Herzegovina, Montenegro, Slovenia Table 1.1: Overview of Croatia’s
River Basin Districts Source: RBMP Note: * Area in Croatian territory Croatia
is part of the Danube international RBD (all of HRC) and the Sava river basin,
a sub-basin of the Danube international RBD. The Sava River is the largest
tributary of the Danube by volume of water, and about one-quarter of the
basin’s total surface area lies in Croatia. International river basin || National RBD || Surface area in Croatia (km2) || Croatia’s share of total basin surface area (%) || Co-ordination category Danube || HRC || 35 100 || 4.4% || 1 Sava * || HRC || 25 370 || 26.0% || 1 Table 1.2: Transboundary river
basins by category (see CSWD section 8.1) and % share in Croatia[2]. Category 1: Co-operation agreement,
co-operation body and RBMP in place. Category 2: Co-operation agreement,
co-operation body in place. Category 3: Co-operation agreement in
place. Category 4: No co-operation formalised. Source: International Commission for the Protection of the
Danube River; International Sava River Basin Committee; WISE/EC Comparative
study of pressures and measures in the major river basin management plans in
the EU. Notes: Data on surface
areas differ slightly among sources; * the Sava is a sub-basin of the Danube
IRBD. In
addition, Croatia’s Adriatic river basin district (HRJ) shares four smaller
river basins with Bosnia and Herzegovina: Cetina (the basin’s surface area in
Croatia is 1 531 km2 while the entire surface area is 2 614 km2);
Neretva (surface area in Croatia is 280 km2
while the basin’s full surface area is 10 520 km2); Trebišnjica (in
Croatia Trebišnjica appears as a series of underwater springs and as the Ombla
river, which is only 30 m long but with a relatively large discharge, 24 m3/sec);
and Krka (the source of the river is located on the border between Croatia and
Bosnia and Herzegovina). As of 2014, according to the
Croatian authorities, joint management plans had been not prepared for any of
these river basins. Cooperation for the preparation of joint management plans
is on the agenda of the Bilateral Commission of Bosnia and Herzegovina and
Croatia for Water Management Issues. Finally,
Croatia’s HRJ river basin district shares three small river basins with
Slovenia: Dragonja (the basin area in Croatia is 55.6 km2); Mirna
(494 km2 in Croatia and 47 km2 in Slovenia); and
Rječina (300 km2 in Croatia and 50 km2 in Slovenia).
The coordination of respective national plans in these basins is carried out
under the framework of the Bilateral Commission of Croatia and Slovenia for
Water Management Issues.
2.
Status of River Basin Management Plan reporting
and compliance
In June 2013, Croatia’s government adopted a single river basin
management plan (RBMP) that covers both the Danube and the Adriatic RBDs.[3] Information on the RBMP
was reported to the European Commission in February 2014 (see table 2.1). RBD || RBMP Date of Adoption || RBMP Date of Reporting HRC and HRJ || 26 June 2013 || 18 February 2014 Table 2.1: Adoption and reporting
to the Commission of Croatia's RBMPs Sources: RBMP, EIONET Prior
to the RBMP, Croatia had prepared pilot management plans for two sections of
the Danube RBD and two small river basins in the Adriatic RBD. The
RBMP is to be revised in 2015, on the same time frame as those in other Member
States. The current plan represents a preliminary exercise, undertaken without
a number of key methodologies and approaches in place; these are under development
and are being put in place for the 2015 plan. Key
strengths include the following: ·
The RBMP was prepared in time for Croatia’s
accession to the EU. The RBMP provides a key step forward for river
basin management. ·
Croatia has recently put in place new
legislation to support water management, including the transposition of EU
legislation. The new legislation includes government regulations on water
quality and on minimum fees for water service utilities (though implementation
of some key legislation was only starting at the time that the RBMP was
published). ·
Monitoring has been carried out for chemical
status based on almost all priority substances. Information is well
developed for transitional and coastal waters. However, some methodological
elements still need to be developed, including monitoring of biota and
sediment. ·
Protected areas have
been identified across the country, including drinking water protected areas,
bathing water areas, Natura 2000 sites (the latter on a preliminary basis), and
fish and shellfish areas. ·
Croatia is engaged in international
cooperation for water management with neighbouring countries in
multilateral forums and through bilateral agreements (Art. 13 of the WFD). The
RBMP cites international work on the Danube, along with the work for its
tributary, the Sava, as well as agreements with neighbouring Member States and
third countries. The RBMP, however, provides relatively little information on
cooperation related to its preparation, an important issue for HRC in particular.
Key
weaknesses include the following: ·
The RBMP does not provide justification on exemptions
for specific water bodies (Art. 4(4)), even though it notes that some water
bodies will not attain good status by 2015. ·
There is no systematic review of the existing
water permits to ensure that they are consistent with the achievement of the
WFD environmental objectives. ·
While potential HMWB and AWB have been
identified and preliminary data on their attainment of good ecological
potential is presented, the designation of these bodies will be made in the
second RBMP (Annex II). Moreover, the current RBMP does not provide information
on a methodology for identifying HMWBs, nor one for establishing GEP (Annex II
and Annex V). ·
The monitoring and assessment of ecological
status (as per Annex V of the WFD) was not developed for the first RBMP. In
particular, WFD-compliant assessment methods and reference conditions for
rivers and lakes were not in place at the time the RBMP was prepared. The RBMP
refers to ongoing scientific work to develop these. Monitoring data and
assessment methods have been further developed for coastal and transitional
waters. ·
Groundwater operational monitoring has not been
established. The assessment of groundwater status is not fully developed.
Groundwater dependent ecosystems appear not to have been considered in HRC. ·
The current Programme of Measures only
includes basic measures and not supplementary measures (e.g. hydromorphological
measures), though these appear to be needed as not all water bodies will
achieve good status by 2015. The costs for some measures are provided,
including those requiring major investments such as wastewater treatment
plants. While potential sources of finance are indicated, further detail is not
provided. ·
Croatian legislation provides a broad definition
of water uses, but a restrictive definition of water services:
the latter focuses on municipal water utilities. National legislation contains
provisions for cost recovery for water services (Art. 9). These provisions,
however, are still in the process of being implemented. A preliminary
assessment of cost recovery was carried out for the RBMP, which
underlines that further work is needed. Methods to calculate environmental and
resource costs have not yet been put in place. The
RBMP indicates in a number of places the intention to address shortcomings in
the next RBMP, to be adopted by December 2015, including via ongoing scientific
projects.
3.
Governance
3.1.
Timeline of implementation
The
RBMP was adopted in June 2013, just before Croatia joined the EU on 1 July
2013. The draft RBMP was presented in December 2010. RBD || Timetable || Work programme || Statement on consultation || Significant water management issues || Draft RBMP || Final RBMP Due dates* || 22/06/2006 || 22/06/2006 || 22/06/2006 || 22/12/2007 || 22/12/2008 || 22/12/2009 HRC || 01/08/2010 || 09/09/2010 || 03/12/2010 || 03/12/2010 || 03/12/2010 || 26/06/2013 HRJ || 01/08/2010 || 09/09/2010 || 03/12/2010 || 03/12/2010 || 03/12/2010 || 26/06/2013 Table 3.1.1: Timeline of the
different steps of the implementation process Source: WISE (Summary 1.3.2 for each RBD) except for Final
RBMP Note: * Due dates refer to those set in the
Water Framework Directive. Croatia acceded to the EU on 1 July 2013. The
Accession Agreement does not set different due dates for Croatia, and thus the
requirements take force from the date of accession. According
to information reported to WISE, a single period for consultation was provided
for both the significant water management issues and the draft RBMP; however, a
separate document indicating the significant water management issues has not
been found. The period for written comments lasted 20 months.
3.2.
Administrative arrangements
The
RBMP was prepared by Hrvatske vode (Croatian Waters), the national body
responsible for water management under the Ministry of Agriculture. A single,
national approach is followed for both RBDs. A
range of government bodies are responsible for policy areas that affect water
use and water management (see Figure 3.2.1). Permitting – notably for IPPC
facilities – is carried out by the Ministry of Environment and Nature
Protection in coordination with other authorities, including the Ministry of
Agriculture, while reporting by IPPC facilities is done to the Croatian
Environment Agency, the Ministry of Environment and Nature Protection, Hrvatske
vode and competent county authorities. The Ministry of Construction and
Physical Planning is responsible for Spatial Planning, along with regions and
local authorities. Nature Conservation is under the Ministry of Environment and
Nature Protection and the State Institute for Nature Protection. The Ministry
of Maritime Affairs, Transport and Infrastructure is responsible for navigation
in both marine and inland waters (both the Danube and the Sava rivers have
significant navigation). The Ministry of Economy is in charge of energy. The
Ministry of Agriculture is in charge of fisheries and aquaculture. The Ministry
of Culture leads on policy for the protection of historic monuments. Figure 3.2.1 Key authorities for water management and
the RBMP in Croatia
3.3.
RBMPs - Structure, completeness, legal status
The
RBMP refers to the work underway for the Danube international RBMP and the Sava
international RBMP – however, it does not provide details on the relationship
between these international actions and river basin planning in Croatia’s HRC
river basin district. The
RBMP was approved by a regulation of the national government: as such, it is
binding on government bodies but not on individuals or enterprises.
3.4.
Consultation of the public, engagement of
interested parties
Public
consultation on the RBMP was carried out via the Internet, written comments and
also a series of public consultation meetings that involved academia, water
service companies, energy, industry, agriculture, inland navigation and nature
protection stakeholders. According
to the RBMP, two-thirds of the 172 written comments were accepted in the plan.
Discussions at workshops also had an influence. The plan does not, however,
specify the changes that were introduced due to comments. No
information was found on transboundary aspects of public participation for the
Croatian RBMPs.
3.5.
Cooperation and coordination with third
countries
As
noted in Section 1, Croatia is part of the Danube international RBD and also
the Sava international basin, a sub-basin of the Danube. Both the Danube and
the Sava have permanent bodies that oversee cooperation and the preparation of
their RBMPs: Croatia is a full member of the International Committee for the
Protection of the Danube River, and also of the Sava River Commission. An
international RBMP was adopted for the Danube international RBD in 2009, and a
revision is currently in preparation for 2015 as part of the second RBMP cycle.
A draft RBMP for the Sava has been prepared; public consultation was carried
out from 21 December 2011 through 21 April 2012. While
Croatia’s current RBMP mentions both the Danube and Sava processes, it does not
explain how it is linked to these international RBMPs. Although Croatia provided
information for the Danube and Sava processes, the timetables for the
development of Croatia’s first RBMP were not aligned with those of the
international RBMPs (to be completed in 2015); the harmonisation of Croatian
and international processes is expected to be on track for the second RBMP,
also to be completed in 2015. Croatia
has signed bilateral agreements on water management with its two neighbouring
Member States and with two of its three neighbouring third countries: Hungary
(1994); Bosnia and Herzegovina (1996); Slovenia (1997), Montenegro (2008).
3.6.
Integration with other sectors
The
RBMP does not describe integration with other sectors or sectoral plans. It
does not, for example, refer to possible links with spatial and land use
planning (the 1997 Spatial Planning Strategy of the State and the 1999 Spatial
Planning Programme of the State provide a framework for land use planning).
4.
Characterisation of river basin districts
4.1.
Water categories in the RBD
Croatia
contains all four water categories; however, its Danube RBD (HRC) is
land-locked and thus does not include transitional or coastal waters (see Table
4.1.1). RBD || Rivers || Lakes || Transitional || Coastal HRC || 29 || 10 || 0 || 0 HRJ || 27 || 4 || 6 || 5 Table 4.1.1: Surface water body
types at RBD level Source: WISE
4.2.
Typology of surface waters
The
typology of surface waters is contained in Annex 12 of the Regulation on the
Standard of Quality of Waters[4]:
this annex contains a list of river types, lake types, transitional water types
and surface water types. The Regulation entered into force on the same day as
the RBMP was adopted (26 June 2013). According to the Croatian authorities, the
typology was tested against biological data and was used for the RBMP.
4.3.
Delineation of surface water bodies
In
total, Croatia has delineated over 1 300 surface water bodies; over 90% of
these are river water bodies. The RBMP indicates that a future process may
redefine some water bodies[5].
RBD || Surface Water || Groundwater Rivers || Lakes || Transitional || Coastal Number || Average Length (km) || Number || Average Area (sq km) || Number || Average Area (sq km) || Number || Average Area (sq km) || Number || Average Area (sq km) HRC || 897 || 12 || 29 || 4 || 0 || 0 || 0 || 0 || 20 || - HRJ || 334 || 7 || 5 || 8 || 28 || 5 || 22 || 625 || 12 || - Total || 1231 || 10.6 || 34 || 4.6 || 28 || 5 || 22 || 625 || 32 || 1942 Table 4.3.1: Surface water bodies,
groundwater bodies and their dimensions, as reported in WISE Source: WISE
The
RBMP refers to small water bodies. These are defined by their catchment area
(less than 10 km2) for river water bodies and by their surface
for lakes (less than 0.5 km2). Small water bodies make up a
significant share of rivers: about 80% of the total length of rivers in HRC are
small water bodies. For
small water bodies, analysis and typology is not carried out: where needed,
these water bodies are treated in accordance with criteria applicable to the
connected larger surface water bodies. The
RBMP outlines the criteria for the delineation of transitional water bodies:
this was done on the basis of ecoregions, salinity, tides and composition of
the substrate.
4.4.
Identification of significant pressures and
impacts
According to the
Croatian authorities, pressures and impacts were analysed at the water body
level. Criteria for determining the level of a significant pressure were not
developed. Pollution pressures and impacts were analysed using a model
balancing nutrient and pollution inputs with their transport measured at
surrounding monitoring stations as well as the interpolation of water status
for water bodies lying between those with monitoring stations. The following
pressures were analysed: ·
point source pollution
(in particular, discharges of urban wastewater systems and industrial
wastewater systems) and ·
diffuse pollution from
farms and agricultural land and settlements without a sewerage system The analysis was
carried out for organic pollution parameters (BOD5 and COD) and
nutrients (N and P) as well as some of the parameters on the list of dangerous
and priority substances. The pressures
and impact analysis of morphological and hydrological modifications was carried
out according to available data on existing modifications as well as through
expert assessments of the sensitivity of individual water body types to certain
changes and the impact magnitude of specific hydromorphological elements on
water status. Water abstraction
and its impact on the status of water bodies was also considered for the RBMP.
According to the Croatian authorities, legislation is in place prescribing that
records must be kept of groundwater abstractions for public water supply and
for commercial use. RBD || No pressures || Point source || Diffuse source || Water abstraction || Water flow regulations and morphological alteration || River management || Transitional and coastal water management || Other morphological alterations || Other pressures No. || % || No. || % || No. || % || No. || % || No. || % || No. || % || No. || % || No. || % || No. || % HRC || 27 || 2.9 || 276 || 29.7 || 893 || 96.2 || 8 || 0.9 || 312 || 33.6 || 372 || 40.1 || 0 || 0.0 || 187 || 20.2 || 0 || 0 HRJ || 16 || 4.3 || 36 || 9.8 || 320 || 87.0 || 8 || 2.2 || 81 || 22.0 || 157 || 42.7 || 22 || 6.0 || 72 || 19.6 || 0 || 0 Total || 43 || 3.3 || 312 || 24.1 || 1213 || 93.6 || 16 || 1.2 || 393 || 30.3 || 529 || 40.8 || 22 || 1.7 || 259 || 20.0 || 0 || 0 Table 4.4.1: Significant pressures affecting water bodies (by
number of water bodies and per cent of RBD total) Source: Information provided to the Commission by Croatian authorities on 3
November 2014. The information was provided as a follow up to the bilateral
meeting with Croatia concerning the implementation of the Water Framework
Directive in Croatia, which took place on 3 July 2014. Table
4.4.1 indicates the number of water bodies affected by significant pressures.
Pressures were attributed to water bodies: ·
in which a point of discharge for point sources
of pollution was located; ·
whose direct catchment includes the area from
which diffuse pollution originates; and ·
those in which a morphological alteration is
located. This
approach was adapted to assess the cumulative effect of a large number of
smaller pressures and also the relationship between point and diffuse loads,
particularly on smaller watercourses. According
to the Croatian authorities, a similar analysis will be undertaken for the
second planning cycle; however, the inclusion of additional pressures, such as
diffuse pollution from transport, is planned, with the aim of providing fuller
coverage of the list of pressures in Guidance Document No 3 on Analysis of
Pressures and Impacts.
4.5.
Protected areas
In
Croatia, over 2 700 protected areas have been designated (see Table 4.5.1):
over 900 areas are designated for drinking water abstraction under Art. 7 of
the WFD and a similar number are designated as bathing protected areas. Nearly
700 areas were designated under the Habitats Directive. RBD || Number of PAs Article 7 Abstraction for drinking water || Bathing || Birds || European Other || Fish || Habitats || Local || National || Nitrates || Shellfish || UWWT HRC || 649 || 2 || 12 || || 21 || 263 || || 69 || 10 || || 1 HRJ || 254 || 905 || 4 || || 21 || 428 || || 77 || 1 || 18 || 55 Total || 903 || 907 || 16 || || 42 || 691 || || 146 || 11 || 18 || 56 Table 4.5.1: Number of protected
areas of all types in each RBD and for the whole country, for surface and
groundwater[6] Source: WISE According
to the RBMP, Hrvatske vode is establishing an electronic register of protected
areas: protected areas for drinking water will be included. Croatia has
developed an ecological network of protected sites, providing the basis for
proposed Natura 2000 sites. Areas for bathing, for the protection of freshwater
fish and for shellfish have been designated.
5.
Monitoring
Croatia
has a single national approach to monitoring. National legislation includes a
requirement to put in place a monitoring programme. According to the RBMP, the
plan was being harmonised with the WFD’s approach during the preparation of the
RBMP. Croatia has established programmes which provide both operational and
surveillance monitoring. Figure 5.1: Maps of surface water (left) and
groundwater (right) monitoring stations || • || || River monitoring stations || • || || Lake monitoring stations || • || || Transitional water monitoring stations || • || || Coastal water monitoring stations || • || || Unclassified surface water monitoring stations || • || || Groundwater monitoring stations || || || River Basin Districts || || || Countries outside EU Source: WISE, Eurostat (country borders)
5.1.
Monitoring of surface waters
According
to information provided by Croatia in WISE, most of the required biological
quality elements are being monitored in rivers and lakes. However, in terms of
the supporting hydromorphological quality elements, only the hydrological
regime is reported to be monitored in rivers and not the morphological
conditions. Hydromorphology is not monitored in lakes, transitional and coastal
waters. In
transitional waters several biological quality elements were not monitored.
Those missing are: macroalgae; angiosperms and benthic invertebrates. In
coastal waters all expected biological quality elements were reported to be
monitored. General
physico-chemical QEs are reported to be monitored, but it is not clear whether
or not all the expected determinants associated with the physico-chemical
elements have been monitored. In
addition, the RBMP states that surveillance monitoring of rivers used for the
plan only provided data for the “saprobic index”, using macrozoobenthos.
Moreover, as noted also below, the preliminary ecological assessment of rivers
and lakes only considered available physico-chemical and hydromorphological
parameters. In
2014, the Croatian authorities were in the process of adopting two supporting
documents for the monitoring programmes: the Methodology of sampling,
laboratory analyses and determination of the ecological quality ratio for
biological quality elements; and the Methodology for monitoring and assessment of
hydromorphological indicators. According
to the Croatian authorities, monitoring of hydromorphological quality elements
in surface waters will be carried out in the period 2014 to 2018 (based on the
new Methodology). Monitoring of hydromorphological elements for transitional
and coastal waters was in development and testing in mid-2014, whereas for
natural lakes monitoring will be developed only for the third RBMP cycle. According
to the Croatian authorities, the monitoring of fish in natural lakes was carried
out in 2012 and 2013 (see Table 5.1 below). In the period 2015–2018,
surveillance and operational monitoring of fish will be performed in all lakes
and reservoirs and the Regulation on the Standard of Quality of Waters is
planned to be supplemented with a classification system for fish in lakes and
reservoirs only in 2018. A
review of the methodologies for the monitoring of physico-chemical and chemical
quality elements were in preparation as of mid-2014. RBD || Rivers || Lakes QE1.1 Phytoplankton || QE1.2 Other aquatic flora || QE1.2.3 Macrophytes || QE1.2.4 Phytobenthos || QE1.3 Benthic invertebrates || QE1.4 Fish || QE1.5 Other species || QE2 Hydromorphological QEs || QE3.1 General Parameters || QE3.3 Non priority specific pollutants || QE3.4 Other national pollutants || QE1.1 Phytoplankton || QE1.2 Other aquatic flora || QE1.2.3 Macrophytes || QE1.2.4 Phytobenthos || QE1.3 Benthic invertebrates || QE1.4 Fish || QE1.5 Other species || QE2 Hydromorphological QEs || QE3.1 General Parameters || QE3.3 Non priority specific pollutants || QE3.4 Other national pollutants HRC || || || || || || || - || || || || - || || || || || || || - || || || || - HRJ || || || || || || || - || || || || - || || || || || || || - || || || || - RBD || Transitional || Coastal QE1.1 Phytoplankton || QE1.2 Other aquatic flora || QE1.2.1 Microalgae || QE1.2.2 Angiosperms || QE1.3 Benthic invertebrates || QE1.4 Fish || QE1.5 Other species || QE2 Hydromorphological QEs || QE3.1 General Parameters || QE3.3 Non priority specific pollutants || QE3.4 Other national pollutants || QE1.1 Phytoplankton || QE1.2 Other aquatic flora || QE1.2.1 Macroalgae || QE1.2.2 Angiosperms || QE1.3 Benthic invertebrates || QE1.4 Fish || QE1.5 Other species || QE2 Hydromorphological QEs || QE3.1 General Parameters || QE3.3 Non priority specific pollutants || QE3.4 Other national pollutants HRC || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - || - HRJ |||| || || || || || - || |||| || - || || || || || || - || - || |||| || - Table 5.1: Quality elements monitored || QE Monitored || QE Not monitored - || || Not Relevant Source: WISE RBD || Rivers || Lakes || Transitional || Coastal || Groundwater Surv || Op || Surv || Op || Surv || Op || Surv || Op || Surv || Op || Quant HRC || 107 || 32 || 3 || 1 || 0 || 0 || 0 || 0 || 225 || 0 || 102 HRJ || 10 || 6 || 3 || 4 || 0 || 52 || 0 || 87 || 39 || 0 || 42 Total by type of site || 117 || 38 || 6 || 5 || 0 || 52 || 0 || 87 || 264 || 0 || 144 Total number of monitoring sites[7] || 132 || 10 || 52 || 87 || 371 Table 5.2: Number of monitoring
sites by water category Surv = Surveillance, Op = Operational,
Quant = Quantitative Source: WISE Note: Some sites are used for both surveillance and
operational monitoring Croatia
reported to WISE that there are 281 surface water monitoring sites (see Table
5.2). According
to Croatia’s RBMP, biological quality elements in operational monitoring are
chosen in relation to existing pressures. However, no information was found on
which BQEs have been selected to monitor which significant pressures. The RBMP
also states that operational monitoring is only carried out in relation to
point source pressures, not diffuse sources. Operational
monitoring of chemical status appears to cover most priority substances (not
covered, according to information provided on WISE, are trifluralin and
pentabromodiphenylether compounds). According to the latest information
available, surveillance monitoring of PAHs (polycyclic aromatic hydrocarbons)
and all relevant priority substances is planned to be carried out at 117
monitoring stations. Croatia’s
2013 Regulation on the Standard of Quality of Waters incorporates the WFD’s
requirements as regards monitoring substances in sediment and biota; however,
neither the information reported on WISE nor in the RBMP indicate whether this
monitoring was carried out for the first RBMP. As of mid-2014, Croatia reported
to the Commission that it has started monitoring in sediments and will ensure
that trends are monitored in sediments and/or biota according to Article 3(3)
of the EQS Directive. Design
of the operational monitoring was adapted to financial and organisational
capacities. During the
development of first RBMP, a need was identified to carry out a more detailed
assessment and also modify water body typology. In this process, it was decided
to keep the original monitoring network to maintain historical data for the new
classification to be established for the development of the second RBMP. Croatia’s
monitoring programmes are linked to the Trans National Monitoring Network
(TNMN), which coordinates monitoring across the international Danube River
Basin District, as well as to the bilateral monitoring programme with Slovenia
and bilateral agreements with Hungary.
5.2.
Monitoring of groundwater
Croatia
has established quantitative and chemical surveillance monitoring programmes
for groundwater. It appears that chemical operational monitoring was not
carried out for the RBMP. The expected core parameters are reported to be
monitored for surveillance monitoring of chemical status. Croatia
differentiates monitoring of groundwater in karst and Pannonian (alluvial)
geological areas (HRJ contains mostly karst areas, but also some Pannonian
areas; HRC contains mostly Pannonian areas but also some karst). According
to the RBMPs, chemical surveillance monitoring in karst areas will in the
future be expanded in terms of the monitoring network and will include the core
parameters under the WFD, additional parameters under the Groundwater Directive
and supplementary parameters relevant for establishment of the state of water
(for example, free CO2, temperature, orthophosphates, iron,
turbidity, manganese and mineral oils). Surveillance
monitoring of the quantitative status of groundwaters in karst areas will
encompass in the future abstraction sites for public water supply. The
RBMP states that operational monitoring will be organised in karst areas for
all grouped groundwater bodies which are under risk. In the Pannonian area, the RBMP states that surveillance monitoring will include sites of existing and planned hydropower plants. The RBMP states that the operational monitoring of the Pannonian area will be carried out for all grouped groundwater water bodies which are at risk and that the monitoring should be carried out once a month for a number of specified parameters (NO3; pesticides; pH-value; EC; saturated oxygen; NH4; As; Cd; Pb; Hg; Fe; Mn; Cl; SO4; trichlorethylene and tetrachlorethylene). In the
future, in the Pannonian area, groundwater quality monitoring will be aligned
with the need to monitor the status of water in relation to nitrate pollution
from agriculture. The
RBMP and WISE do not indicate how the groundwater chemical status monitoring
programmes will be designed in order to detect significant and sustained upward
trends in pollutants. In
terms of the results of groundwater monitoring in the first RBMP, one of the
problems identified is saline intrusion in some coastal areas (HRJ). In some of
these areas, higher water abstraction during summer months results in an
increase of chloride; in addition, in some points saline intrusion is the
result of entirely natural conditions. The Croatian authorities have confirmed
that the reasons for salt water intrusion caused by water abstraction will be
further investigated under the second RBMP. The
Danube TNMN, which has focused on surface waters, is starting to address
groundwater monitoring, focusing on groundwater bodies of basin-wide
importance. The relationship between this and national monitoring in Croatia,
however, is not indicated in the RBMP or WISE.
5.3.
Monitoring of protected areas
Croatia
did not report to WISE information on monitoring programmes for drinking water
protected areas or other protected areas. This is not indicated in the RBMP
either; however, Croatia’s Law on Waters[8]
specifies that monitoring should be carried out for surface water and
groundwater bodies supplying more than 100 m3 of drinking water a
day.[9] Croatian authorities
indicated in 2014 that the monitoring of water status in protected areas is
carried out as per the Law on Waters and the Regulation on the Standard of
Quality of Waters.
6.
Overview of status (ecological, chemical,
groundwater)
In
WISE, Croatia has reported information on the ecological status/potential and
chemical status of its water bodies (see tables 6.1 to 6.6 and figure 6.1 to
6.6)[10].
RBD || Total || High || Good || Moderate || Poor || Bad || Unknown No. || (%) || No. || (%) || No. || (%) || No. || (%) || No. || (%) || No. || (%) HRC || 682 || 144 || 21.1 || 214 || 31.4 || 143 || 21.0 || 90 || 13.2 || 91 || 13.3 || 0 || 0 HRJ || 335 || 132 || 39.4 || 130 || 38.8 || 39 || 11.6 || 18 || 5.4 || 14 || 4.2 || 2 || 0.6 Total || 1017 || 276 || 27.1 || 344 || 33.8 || 182 || 17.9 || 108 || 10.6 || 105 || 10.3 || 2 || 0.2 Table 6.1: Preliminary assessment
of Ecological status of natural surface water bodies Source: WISE RBD || Total || High || Good || Moderate || Poor || Bad || Unknown No. || (%) || No. || (%) || No. || (%) || No. || (%) || No. || (%) || No. || (%) HRC || 92 || 5 || 5.4 || 12 || 13.0 || 19 || 20.7 || 36 || 39.1 || 20 || 21.7 || 0 || 0 HRJ || 2 || 0 || 0.0 || 1 || 50.0 || 0 || 0.0 || 0 || 0.0 || 1 || 50.0 || 0 || 0 Total || 94 || 5 || 5.3 || 13 || 13.8 || 19 || 20.2 || 36 || 38.3 || 21 || 22.3 || 0 || 0 Table 6.2: Preliminary assessment
of Ecological potential of candidate artificial and heavily modified water
bodies Source: WISE RBD || Total || Good || Poor || Unknown No. || % || No. || % || No. || % HRC || 682 || 667 || 97.8 || 15 || 2.2 || 0 || 0.0 HRJ || 335 || 330 || 98.5 || 3 || 0.9 || 2 || 0.6 Total || 1017 || 997 || 98.0 || 18 || 1.8 || 2 || 0.2 Table 6.3: Chemical status of
natural surface water bodies Source: WISE RBD || Total || Good || Poor || Unknown No. || % || No. || % || No. || % HRC || 92 || 90 || 97.8 || 2 || 2.2 || 0 || 0.0 HRJ || 2 || 2 || 100.0 || 0 || 0.0 || 0 || 0.0 Total || 94 || 92 || 97.9 || 2 || 2.1 || 0 || 0.0 Table 6.4: Chemical status of
candidate artificial and heavily modified surface water bodies Source: WISE RBD || Good || Poor || Unknown No. || % || No. || % || No. || % HRC || 18 || 90.0 || 2 || 10 || 0 || 0.0 HRJ || 10 || 83.3 || 2 || 16.7 || 0 || 0.0 Total || 28 || 87.5 || 4 || 12.5 || 0 || 0.0 Table 6.5: Chemical status of
groundwater bodies Source: WISE RBD || Good || Poor || Unknown No. || % || No. || % || No. || % HRC || 19 || 95.0 || 1 || 5.0 || 0 || 0.0 HRJ || 8 || 66.7 || 2 || 16.7 || 2 || 16.7 Total || 27 || 84.4 || 3 || 9.4 || 2 || 6.2 Table 6.6: Quantitative status of
groundwater Source: WISE Croatia’s
RBMP indicates the number of river water bodies that are expected to achieve
good ecological and chemical status in 2015 (although ecological status
assessment method is not fully WFD compliant). It does so for two ‘scenarios’,
depending on the schedule and transition periods for meeting key water
legislation such as the Directive on Urban Wastewater Treatment. For lakes, an
estimate of good chemical status in 2015 is provided. For transitional and
coastal waters, there is an expert assessment of the number of water bodies
expected to fail objectives in 2015. The
RBMP reports that in both scenarios, all rivers are expected to attain good
chemical status by 2015 (all rivers in HRJ already attain good chemical
status). The
RBMP indicates that exemptions are expected to be needed as some water bodies
will likely not achieve good status by 2015. The plan does not, however, set
out these exemptions as it states that further information and assessment are
required; it indicates that the exemptions will be presented in Croatia’s next
RBMP. Figure 6.1: Map of preliminary assessment of ecological status of
natural surface water bodies, 2009 Figure 6.2: Map of preliminary assessment of
ecological potential of candidate artificial and heavily modified water bodies,
2009 || || || Good or better || || || Moderate || || || Poor || || || Bad || || || Unknown || || || River Basin Districts || || || Countries outside EU Source: WISE, Eurostat (country borders) Note: Standard colours based on WFD Annex V,
Article 1.4.2(ii). Figure 6.3: Map of chemical status of natural surface
water bodies, 2009 || || || Good || || || Failing to achieve good || || || Unknown || || || River Basin Districts || || || Countries outside EU Source: WISE, Eurostat (country borders) Note: Standard colours based on WFD Annex V,
Article 1.4.3. Figure 6.4: Map of chemical status of candidate
artificial and heavily modified water bodies 2009 || || || Good || || || Failing to achieve good || || || Unknown || || || River Basin Districts || || || Countries outside EU Source: WISE, Eurostat (country borders) Note: Standard colours based on WFD Annex V,
Article 1.4.3. Figure 6.5: Map of chemical status of groundwater
bodies 2009 || || || Good || || || Poor || || || Unknown || || || River Basin Districts || || || Countries outside EU Source: WISE, Eurostat (country borders) Note: Standard colours based on WFD Annex V,
Article 2.4.5. Figure 6.6: Map of quantitative status of groundwater
bodies 2009 || || || Good || || || Poor || || || Unknown || || || River Basin Districts || || || Countries outside EU Source: WISE, Eurostat (country borders) Note: Standard colours based on WFD Annex V,
Article 2.2.4.
7.
Assessment of ecological status of surface
waters
Croatia
has a single, national approach to the assessment of ecological status.
However, the approach for assessment was still in development at the time that
the RBMP was prepared. The
assessment of rivers for the RBMP used a prior approach, the “saprobic” method,
which is not compliant with WFD requirements. For the RBMP, a preliminary
assessment of the ecological status of rivers was made using only
physico-chemical[11]
and hydromorphological quality elements – but these could not have been linked
to BQEs as the latter had not been established. The required biological quality
elements are reported to be monitored in rivers but are not used in ecological
status classification indicating that WFD compliant biological assessment
methods are not yet available. The
assessment of the hydromorphological status is reported in WISE as being based
on an expert analysis of hydromorphological pressures. In
terms of overall classification of status reported to WISE, often a worse
overall class is reported than indicated by either the physicochemical or
hydromorphological QEs: the reasons for this are not known. The
classification of ecological status of lakes is also only based on
physico-chemical QEs and hydromorphological QEs even though BQEs are reported
to be monitored, again indicating the lack of appropriate biological assessment
methods for lakes. Also as for rivers the overall status classification for
lakes is often worse than indicated by the supporting QEs. The
RBMP cites a scientific project underway on biological assessment for
ecological status of rivers and lakes: this project will work on reference
conditions and class boundaries for several BQEs (fish, macroinvertebrates,
macrophytes and phytobenthos). On the basis of this information, it appears
that biological assessment methods were not available for rivers and lakes at
the time the RBMP was prepared. Most
transitional water bodies were classified according to phytoplankton, fish,
physico-chemical and hydromorphological QEs and a few also using
macroinvertebrates. In
terms of coastal waters, all water bodies are classified according to
phytoplankton, physico-chemical and hydromorphological QEs and a few also using
macroinvertebrates. Angiosperms and macroalgae are also reported to be
monitored but are not used in the classification. Hydromorphological QEs are
used in the classification but are not reported to be monitored. For
coastal and transitional waters, the RBMP reports that methods are being developed,
also taking into consideration methods in other Member States (see Table
7.2.1). There appear to be methods and at least preliminary reference
conditions for phytoplankton and macroinvertebrates but those for fish,
macroalgae and angiosperms are only partly developed at best. The
RBMP does not refer to the use of the one-out-all-out principle for assessing
ecological status of rivers and lakes. However, the description of the
assessment of coastal and transitional waters for HRJ indicates that this
principle was followed. Moreover, Croatia’s 2013 Regulation on the Standard of
Quality of Waters cites this approach, which thus could be expected to be used
in future RBMPs. The
RBMP notes that the assessment of the status of rivers and lakes (general
physico-chemical and hydromorphological status and general chemical status) is
affected by uncertainties stemming from the current system of monitoring and
assessment. To address this, water bodies were split into three groups,
depending on the estimated degree of certainty of the assessed status of water
bodies: first, water bodies which meet the environmental objectives (with high
degree of certainty); second, water bodies for which there is a uncertainty
whether they meet the environmental objectives; and third, water bodies which
do not meet the environmental objectives (with high degree of certainty). The
WISE Summary does not, however, explain how uncertainties themselves are
addressed in the three categories. According
to the information provided in WISE, intercalibration results had been
implemented in Croatia for the first RBMP. According to the Croatian
authorities, the Carlit method (macroalgae of coastal waters) and POMI
(Posidonia oceanica method) used in Croatia are intercalibrated in the framework
of the EU process (specifically, the MED GIG group), and the limit values for
biological quality elements for macrozoobenthos and chlorophyll a (for
transitional and coastal waters) have been adopted from the results obtained
during the intercalibration process in MED GIG. Croatia is also undertaking
initiatives for the intercalibration of methods for assessment of biological
quality elements with neighbouring countries: this is planned as an initiative
in cooperation with Slovenia. According
to the latest information available, Croatia intends to review its list of
River Basin Specific Pollutants in the light particularly of a study on
pollutants from agriculture, and will also review the EQS set for the RBMPs
according to the 2011 Technical Guidance Document on Deriving EQS. Croatia’s
2013 Regulation on the Standard of Quality of Waters (Annex 2B and Annex 2C)
includes all quality elements required according to Annex V of the WFD, with
the exception of fish in lakes and hydromorphological indicators in lakes,
transitional and coastal waters. This will be used for the second RBMP. The
Regulation on the Standard of Quality of Waters[12] is planned to be
amended as the database of biological and other
environmental data grows. In addition, Croatia plans to adopt a methodology of sampling, laboratory analyses and determination of
the Ecological Quality Ratio for Biological Quality Elements and a methodology
for monitoring and assessment of hydromorphological indicators, to fill key
gaps in the setting of reference conditions. RBD || Rivers || Lakes || Transitional || Coastal Phytoplankton || Macrophytes || Phytobenthos || Benthic invertebrates || Fish || Physico-Chemical || Hydromorphological || Phytoplankton || Macrophytes || Phytobenthos || Benthic invertebrates || Fish || Physico-Chemical || Hydromorphological || Phytoplankton || Macroalgae || Angiosperms || Benthic invertebrates || Fish || Physico-Chemical || Hydromorphological || Phytoplankton || Macroalgae || Angiosperms || Benthic invertebrates || Physico-Chemical || Hydromorphological HRC |||||||||||||||||||||||||||||| - || - || - || - || - || - || - || - || - || - || - || - || - HRJ |||||||||||||||||||||||||||||||||||||||||||||||||||||| Table 7.2.1: Availability of biological assessment
methods || Assessment methods fully developed for all BQEs || Assessment methods partially developed or under development for all or some BQEs || Assessment methods not developed for BQEs, no information provided on the assessment methods, unclear information provided - || || Water category not relevant Source: RBMPs
8.
Designation of heavily modified water bodies
(hmwb) and assessment of good ecological potential
The
RBMP indicates that HMWBs and AWBs have not been designated in Croatia, though
a preliminary identification has been made. These candidate water bodies were
identified on the basis of expert judgement; the RBMP states that further
research is needed for designation. In
HRC, 92 potential AWBs have been identified (70 RWBs and 22 LWBs), according to
information provided on WISE, and 2 potential AWBs were identified in HRJ. The
RBMP indicates 206 potential HMWBs, although this has not been reflected in the
WISE reporting (see Tables 8.1.1a and 8.1.1b). Also, information contained in
Tables 8.1.1a and 8.1.1b differs slightly concerning AWB for rivers and lakes
in HRC. Neither
the RBMP nor recent water legislation sets out a clear methodology and criteria
for the designation of HMWBs and AWBs. Figure 8.1: Map of the percentage of candidate heavily
modified and artificial water bodies by River Basin District || || || 0 – 5 % || || || 5 – 20 % || || || 20 – 40 % || || || 40 – 60% || || || 60 – 100 % || || || No data reported || || || River Basin Districts || || || Countries outside EU Source: WISE, Eurostat (country borders) HMWB or AWB || RBD || Water category Rivers || Lakes || Transitional water || Coastal water || All water bodies Number || % of category || Number || % of category || Number || % of category || Number || % of category || Number || % HMWB || HRC || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 HRJ || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 Total || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0 AWB || HRC || 70 || 7.8 || 22 || 75.9 || 0 || 0 || 0 || 0 || 92 || 9.9 HRJ || 2 || 0.6 || 0 || 0 || 0 || 0 || 0 || 0 || 2 || 0.5 Total || 72 || 5.85 || 22 || 64.7 || 0 || 0 || 0 || 0 || 94 || 7.1 Table 8.1.1a: Number and percentage of candidate HMWBs and AWBs, according to information on WISE Source: WISE HMWB or AWB || RBD || Water category Rivers || Lakes || Transitional water || Coastal water || All water bodies Number || % of category || Number || % of category || Number || % of category || Number || % of category || Number || % HMWB || HRC || 150 || 16.6 || 2 || 7.1 || 0 || 0 || 0 || 0 || 152 || 16.4 HRJ || 42 || 12.5 || 0 || 0 || 8 || 29.6 || 4 || 17.3 || 54 || 13.8 Total || 192 || 15.5 || 2 || 6 || 8 || 29.6 || 4 || 17.3 || 206 || 15.6 AWB || HRC || 71 || 7.8 || 21 || 75 || 0 || 0 || 0 || 0 || 92 || 9.9 HRJ || 2 || 0.6 || 0 || 0 || 0 || 0 || 0 || 0 || 2 || 0.5 Total || 73 || 5.9 || 21 || 63.6 || 0 || 0 || 0 || 0 || 94 || 7.1 Table 8.1.1b: Number and percentage of candidate HMWBs and AWBs, according to information provided in the
RBMP Source: RBMP The
RBMP does not provide information regarding whether the definition of a
methodology for good ecological potential (GEP) has been defined in Croatia.
According to Article 18(1) of the Regulation on the Standard of Quality of
Waters, the ecological potential for an artificial or heavily modified surface
water body is established on the basis of monitoring results of BQEs, as well
as physico-chemical, chemical and hydromorphological QEs. According
to the Croatian authorities, a methodology for assessment of GEP will be
developed during the second RBMP cycle, and it should be ready only in 2017. A
scientific research project will develop GEP for rivers and lakes. A
classification system for ecological potential of transitional and coastal
waters is being developed in the framework of the Programme of systematic
testing of transitional and coastal water quality. The
preliminary assessment of ecological potential reported to WISE indicates that
92 of the 94 candidate AWBs reach good ecological potential. These results,
however, are preliminary as a final designation of HMWBs and AWBs hasn’t been
made and further analysis is needed. Moreover, the method used for these
results is not explained.
9.
Assessment of chemical status of surface waters
According
to the RBMP, the assessment of chemical status was carried out on the basis of
annual average concentrations of priority substances. Priority substances
are reported to be monitored in all four surface water categories. The RBMP
indicates that the following priority substances were not considered in the
assessment of chemical status: trifluralin compounds and brominated
diphenylethers. It can
be noted that Annex 3.A of the 2010 Regulation[13],
cited in the RBMP, provided a first transposition of Part A of Annex I of the
EQS Directive. However, one difference was observed: no values were provided
for Cadmium and its compounds for MAC-EQS in other waters. This omission was
corrected in Annex 5.B of the 2013 Regulation on the Standard of Quality of
Waters, which replaced the 2010 Regulation. The
RBMP does not refer to standards for biota or sediment. The 2013 Regulation
provides EQS for biota (this was not found in the previous, 2010 Regulation),
and according to the latest information, biota EQS or equivalent protective
water EQS will be applied where relevant. Information
was not found in the RBMP or national legislation on whether mixing zones are
used, on how background concentrations are considered, or on the
bioavailability of metals. Substances
causing exceedances have been identified for a small share of water bodies in
both HRC and HRJ (Table 9.1.1). Substance causing exceedance || Exceedances per RBD || HRC || HRJ Heavy Metals - aggregated || 8 || Mercury || 5 || Chlorpyriphos || 2 || Chlorvenfinphos || 1 || Endosulfan || 10 || C10-13-chloroalkanes || || 3 Di(2-ethylhexyl)phthalate (DEHP) || 4 || Aldrin || 3 || Dieldrin || 3 || Endrin || 3 || Isodrin || 3 || Pentachlorophenol || 1 || Tributyltin compounds || || 1 Table 9.1.1: Substances responsible for exceedances Source: WISE
10.
Assessment of groundwater status
10.1.
Groundwater quantitative status
There
is a single national methodological approach in Croatia for the assessment of
groundwater quantitative status, based on Guidance Document No. 18 on
Groundwater Status and Trend Assessment. Further
work is planned on the methodology. For example, in the karst areas, monitoring
will include all significant springs, so that a better water balance could be
made of groundwater bodies. This monitoring will be implemented at the
beginning of 2015. In addition, by the end of 2014, a final plan for monitoring
of groundwater levels in aquifers with intergranular porosity will be
completed. Due to the high costs of establishing this monitoring, its full
implementation is planned over a period of several years. The results
provided in the first RBMP show that one groundwater body in HRC and two in HRJ
are assessed to be of poor quantitative status (Table 10.1). For the
groundwater body in HRC, located in the vicinity of Zagreb, abstraction is
reportedly the main pressure leading to poor status. In HRJ, two groundwater
bodies are in poor quantitative status related to high water abstraction during
summer months which produce saline intrusions. A
comparison of annual average groundwater abstractions against ‘available
groundwater resource’ in the groundwater body has been reported to be
calculated for a subset of groundwater bodies. For
number and percentage of groundwater bodies and their quantitative status,
please see Tables 6.5 and 6.6. RBD || Good || Failing to achieve good || Unknown HRC || 733 || 0 || 0 HRJ || 291 || 0 || 0 Total || 1024 || 0 || 0 Table 10.3.1: Status of groundwater
drinking water protected areas Source: WISE
10.2.
Groundwater chemical status
According
to the Croatian authorities, the assessment of chemical status follows the
methodology of Guidance Document No. 18 on Groundwater Status and Trend
Assessment. Threshold values were established at the
national level. These were determined according to
water use criteria: values were determined based on the maximum allowable
concentrations for individual parameters pursuant to regulations on health and
safety of drinking water. All substances of Annex II
Part B of the Ground Water Directive were taken into account. Also, all
pollutants posing risk were considered. According to information provided on
WISE, parameters include iron, manganese and zinc, as well as the temperature,
pH value, dissolved oxygen and transparency. Also according to WISE, a method
for determining background levels has been established.
Croatian
legislation now requires monitoring of groundwater quality for all abstraction
sites used for public water supply as well as in protection zones of larger
abstraction sites. It is
not clear, however, whether a complete chemical status assessment was performed
for the first RBMP. The RBMP reports that two groundwater bodies in HRC and two
in HRJ do not meet good chemical status. However, the pollutants causing poor
status are not described. For HRC, information on background levels was only
provided in a few areas and only related to nitrates. For HRJ, information
reported to WISE indicates that background levels were established only for
some parameters due to a lack of information. Croatian
authorities indicate that more complete monitoring data will be used for the
assessment of chemical status of groundwater bodies in the future RBMPs.
10.3.
Groundwater trend assessment
For
the first RBMP, trends have not been assessed due to a
lack of historical data: according to the RBMP, national groundwater data are
available from 2007, and only in two areas (monitoring sites near Zagreb and
Varazdin in HRC) are longer time series available. The RBMP states that for
most sites in HRC, groundwater data are only available for the years 2007 and
2008 and thus do not provide a sufficient time series to make trend
assessments. Longer time series are available at a few locations, but
changes in monitoring methods make trend assessment difficult. In HRJ, trends
were noted but were not characterised as significant or continuous. For HRJ,
there is a reference to monitoring from 2000 to 2007. According
to the Croatian authorities, groundwater monitoring has been designed to detect
trends, and trend assessment will be carried out for the second RBMP. It is not
clear, however, if a methodology for trend reversals has been established as of
mid-2014, nor on the extent to which the approach in Guidance Document No. 18
on Groundwater Status and Trend Assessment has been implemented.
10.4.
Groundwater-dependent terrestrial ecosystems
For
HRC, the RBMP does not indicate whether associated surface waters and
groundwater dependent terrestrial ecosystems are considered in the assessment
of either chemical or quantitative status of groundwater. For HRJ, on the other
hand, it is indicated that associated surface waters and groundwater dependent
terrestrial ecosystems are considered in the assessment of quantitative status.
10.5.
Groundwater protected areas
There
are 30 groundwater bodies associated with Article 7 protected areas, all of
which are of good status. There are a further 12 groundwater bodies protected
under the Habitats Directive, all of which are of good status.
11.
Environmental objectives and exemptions
No
exemptions were reported to WISE. Nonetheless, it appears that some water
bodies will not attain good status by 2015. The RBMP states that there are two
sets of reasons for this (RBMP, section 3.3): transitional periods granted by
Croatia’s Accession Treaty with the EU (in particular, deadlines for the
Wastewater Treatment Directive, Drinking Water Directive, and Industrial
Emissions Directive); and technical reasons, in terms of a lack of data and
insufficient time at the time of the preparation of the RBMP. Croatia’s
RBMP does not indicate, however, the total number of water bodies that will not
attain good status by 2015, though an estimate is provided for river water
bodies. The
RBMP does not provide information on methodologies to establish exemptions,
such as for the estimate of disproportionate costs, reasons of technical
feasibility or natural conditions that would make it impossible to achieve the
environmental objectives on time. The plan notes that preliminary work has been
prepared by the Zagreb Economic Institute on economic and financial analysis
related to the WFD. Although
the RBMP does not refer to the application of Article 4(7), new hydropower
projects are under consideration in Croatia[14].
It is not clear if there has been effective coordination of these project
proposals with WFD requirements. All new infrastructure projects that are
liable to cause deterioration of status of water bodies or prevent the
achievement of good status should only be authorised is they fulfil the
conditions under WFD article 4(7). With
regard to objectives, the RBMP indicates that additional objectives have been
established for drinking water protection areas and for bathing water areas. For
drinking water, Article 5 of the Law on Water Intended for Human Consumption[15] contains provisions on
what is considered water suitable for consumption including reference to a
by-law containing more detailed requirements. Article 7 of the Law stipulates
that all water intakes must be protected from pollution impacting the quality
of water. Article 90 of the Law on Waters stipulates that the area around water
intakes for water supply (including water intended for human consumption) must
be protected from pollution and other impacts on the quality of water. Bathing
water issues are governed by the Regulation on the Quality of Bathing Water[16], which transposes the
Bathing Water Directive. The Regulation sets microbiological quality standards
for bathing waters and obligatory measures for the management of bathing
waters. Local authorities are the responsible authorities for bathing waters.
The Regulation also contains an obligation to pass a decision establishing
bathing water areas; monitoring of bathing water; and relevant activities for
management of bathing water. Further provisions for the protection of surface
waters intended for bathing are set out in the Ordinance on wastewater emission
limit values. According to the Ordinance, after treatment, urban wastewater
must additionally meet specific requirements if it is discharged into surface
waters which are used for bathing and recreation: limit values of
microbiological parameters (intestinal enterococci and Escherichia coli)
are proscribed separately for discharges into inland surface waters and for
discharges into coastal waters. No
additional objectives have been set for water-dependent protected habitats and
species. The assessment of quantitative and qualitative requirements of these
habitats and species to achieve favourable conservation status has not been
done.
12.
Programmes of measures
12.1.
Programme of measures – general
The
RBMP underlines that the Programme of Measures (PoM) only contains basic
measures; supplementary measures will be presented in Croatia’s second RBMP in
2015. The
RBMP does not state that status assessments have been used for the planning of
the Programme of Measures. The description of some measures does, however,
refer to emissions or other pressures. At the same time, as noted above, the
basic measures indicated in the PoM should be implemented irrespective of the
status assessment. Croatia’s
RBMP cites the 2009 Danube River Basin District Management Plan and the draft
international Sava River Basin Management Plan on several occasions. It is not
clear, however, whether the PoMs have been coordinated among these plans.
Measures have not been coordinated with neighbouring MS and third countries. In
terms of geographical scale, nearly all the measures indicated in the RBMP are
applicable on the entire territory of Croatia; a few, however, refer to action
in specific areas, such as drinking water protection areas and vulnerable zones
in Croatia in accordance with Article 5 of the Nitrates Directive. The
RBMP contains some information on the authorities and stakeholders responsible
for implementing the PoM. The government of Croatia, the Ministry of
Agriculture, Hrvatske vode and water supply providers (local authorities) are
responsible for implementation of measures aimed at ensuring recovery of
operational costs for public water supply and encouragement of efficient use of
water supplied for public use. These authorities as well as local authorities
also have roles in the implementation of the UWWT Directive[17] (the enterprises
running UWWT plants are under local governments or in concession). Under
Croatia’s Accession Treaty[18],
there are specific deadlines for agglomerations according to the number of PE
and the sensitivity of the area of water. The RBMP notes that, consequently,
the prioritisation of the relevant agglomerations should be carefully
considered, as well as supplementary measures under the WFD. Furthermore, Croatia will need to also
comply with other relevant directives (Bathing Water Directive[19], Drinking Water
Directive[20],
MSFD[21],
Groundwater Directive[22],
Industrial Emissions Directive[23]
and others) and this needs to be considered together with the requirements of
the UWWT Directive with the aim to achieve good water status in accordance with
the WFD. The
Ministry of Agriculture, Ministry of Environment and Nature Protection,
Hrvatske vode, and IPPC installation operators are responsible for measures
aimed at reducing pressures on water from IPPC installations. The Ministry of
Agriculture, Hrvatske vode, producers of fertilisers and plant protection
products, custom authorities and farmers are responsible for measures aimed at reducing
pollution from nutrients, especially nitrates. The
RBMP provides some information on costs related to basic measures. For example,
the RBMP states that estimated costs for total investment concerning wastewater
treatment in Croatia is estimated at 23.2 billion HRK (approx. 3 billion EUR)
for the period 2010 – 2023, with investments of 8.5 billion HRK (1.1 billion
EUR) foreseen to 2015. Investments for drinking water supply should amount to
5.4 billion HRK (700 million EUR) through the end of 2015. Furthermore, the
Plan gives estimates of total costs for the implementation of the IPPC
Directive (over 2 billion EUR for all aspects, not only water) and Nitrates
Directive (50.2 million EUR).
12.2.
Measures related to agriculture
The
RBMP refers in particular to agricultural pressures on water quality, due to
the use of manure and mineral fertilisers as well as pesticides; runoff from
livestock grazing is also noted. Water use for agriculture is not indicated as
a pressure. The RBMP cites a range of measures to address these pressures (as
noted above, the RBMP only contains basic measures). An overview of the
measures is set out in Table 12.2.1. Measures || HRC || HRJ Technical measures Reduction/modification of fertiliser application || ü || ü Reduction/modification of pesticide application || ü || ü Change to low-input farming || ü || ü Hydromorphological measures || || Measures against soil erosion || || Multi-objective measures || ü || ü Water saving measures || ü || ü Economic instruments Compensation for land cover || || Co-operative agreements || || Water pricing || ü || ü Nutrient trading || || Fertiliser taxation || ü || ü Non-technical measures Implementation and enforcement of existing EU legislation || ü || ü Controls || || Institutional changes || || Codes of agricultural practice || || Advice and training || || Awareness raising || || Measures to increase knowledge for improved decision-making || || Certification schemes || || Zoning || || Specific action plans/programmes || || Land use planning || || Technical standards || ü || ü Specific projects related to agriculture || || Environmental permitting and licensing || ü || Table 12.2.1: Types of WFD measures addressing agricultural
pressures, as described in the PoM Source: RBMPs Specific
measures include: ·
the development of "ecological agricultural
production" in drinking water protection areas, and construction of
storage capacities for manure in these areas; ·
control and reduction of use of nutrients,
especially nitrogen; ·
the establishment of vulnerable zones and the
adoption of an action programme for protection of water from agricultural pollution
under the Nitrates Directive; ·
a water protection fee on fertiliser producers,
depending on the amount of fertiliser placed on the market; ·
establishment of maximum permitted levels of
pollution of soil; and ·
issuance of water abstraction permits for irrigation. It is not clear,
however, whether measures related to diffuse pollution from agriculture address
problems outside nitrate vulnerable zones, which only
account for 9% of the territory. The RBMP does
not provide information on the cost of these measures. It refers to EU funds as
well as state, regional and local budgets and the proceeds from water fees as
funding sources for the programme of measures, but does not specify sources of
funding for individual measures. The RBMP does not refer to the use of the
Rural Development Programme (RDP) to implement measures that contribute to the
achievement of the WFD. According to Croatian officials, the second RBMP will
incorporate measures from the RDP.
12.3.
Measures related to hydromorphology
The
RBMP states that it does not include measures for existing hydromorphological
pressures; it does, however, include a reference to a future measure to
establish rules for the “maintenance of water flows”, with the goal of limiting
hydromorphological changes by water construction.
12.4.
Measures related to groundwater
The
RBMP mentions few pressures on groundwater bodies. It notes that abstraction of
groundwater is a potential risk in the Zagreb area. A
range of measures are reported to WISE as relevant for groundwater protection.
These include: ·
controls over the abstraction of fresh surface
water and groundwater; ·
the prohibition of direct discharge of
pollutants to groundwater: only treated waters can be discharged; and ·
a range of general measures on water discharges
are noted: issuing authorisations for exploitation; water evaluation within the
environmental conditions, whereby the conditions for the emission of
wastewaters are determined; the obligation to request a renewable permit to
release wastewaters (valid for six years), obligation to report any emission of
wastewaters with limit values determined, and determination of limit values. Croatia’s
RBMP does not provide information on the international coordination of measures
related to groundwater.
12.5.
Measures related to chemical pollution
The
RBMP does not specify that Croatia has an inventory of sources of chemical
pollution to water bodies. Croatia nonetheless has created an EPRTR, which
provides an inventory of pollutant releases (including to water) for large
facilities. While the RBMP does not refer to the EPRTR, it does provide
information on total loads of several pollutants and sectors, including
households and enterprises for several pollution indicators: BOD5, COD, total
nitrogen and total phosphorus. It states that discharges from large facilities
are monitored for these as well as additional pollutants: Zinc, Copper,
Cadmium, Chromium, Nickel, Lead, Mercury, Arsenic, Iron, Manganese, Aluminium
and Phenols. In addition, diffuse pollution from households and agriculture,
including livestock grazing, is estimated. This information suggests that
Croatia has data available for an inventory of chemical pollution sources. The
RBMP cites the following measures to address chemical pollution: ·
water permits for discharge of waste waters; ·
production, placing on the market and use of
chemicals requiring prior registration and in certain cases approval; many
specific substances, including certain pesticides, have been prohibited or
limited; ·
a water fee for the production and import of
plant protection products; and ·
limiting the use of certain pollutants in
agricultural land in accordance with the Ordinance on Protection of
Agricultural Land from Pollution. Croatian
authorities have indicated that a first inventory of emissions will be included
in the second RBMP.
12.6.
Measures related to Article 9 (water pricing
policies)
Law on Waters defines water use as including water
services, general use of water, free water use and any other type of human
activity on water which may significantly impact water status. Croatia thus has
a broad definition of water use. The RBMP then refers
to a range of water uses, including abstractions for households, industry and
agriculture; water supply and wastewater treatment; navigation and ports; and
flood protection. Water services, in contrast, are
currently defined in the same Law only as public water supply and public
sewage. According to Croatian authorities, national
water pricing policy reflects the principle of cost recovery for water services
and the polluter pays and user pays principles: these are incorporated in
several pieces of legislation, including the Law on Waters and the Law on
Financing of Water Management. A 2010
Regulation[24]
establishes a methodology for setting the minimum charges for municipal water
utilities. The Regulation identifies costs that should be included in the
prices of water supply and wastewater treatment. These include: operational
costs, financial costs and long-term depreciation. Water charges are calculated
on the basis of water consumption, as measured by a meter, as well as the
quality of water discharged. The Law on Waters (Article 212) requires that all
new buildings have individual meters for apartments. In existing buildings, a
single shared water meter is common. Information was not found in the RBMP,
however, on the extent to which individual users actually have meters. The
RBMP does report that minimum charges for public water supply were raised in
January 2013 0.8 HRK (app. 0.1 EUR) to 1.35 HRK (app. 0.17 EUR) per cubic metre
of water; and the minimum charge for discharge of waste water from 0.90 HRK
(app. 0.1 EUR) to 1.35 HRK (0.17 EUR) per cubic metre.[25] The
Law on Financing of Water Management[26]
establishes charges for the direct abstraction of water by households and
enterprises, including for industry and for power generation. Agricultural
users are required to pay charges on water they abstract directly or use from
irrigation systems or municipal water systems. The charges for direct
abstractions by farmers should include environmental and resource costs;
charges for water from irrigation systems, however, only include operational
and maintenance costs. Charges for irrigation water are based on volume where
there is a water meter; otherwise, a lump sum is paid according to the area of
irrigated land. All users of irrigation systems are required to have a
concession, which should include an obligation to install a meter. Information
is not available, however, on the extent to which existing irrigation schemes
currently have meters. The Law on Financing of Water Management also
establishes charges for water protection that are placed on plant protection
products and fertilisers. The RBMP does not provide information on the implementation
of these legal provisions or on the extent of incentive water pricing policy
across sectors. It does not discuss whether current policy provides adequate
incentives for users to use water resource efficiently. The RBMP provides initial information on cost recovery for
municipal water supply and wastewater treatment for households and enterprises,
based on a study prepared by the Zagreb Economic Institute. The results are,
however, incomplete due to challenges related to collection of information from
the municipal water service providers. The study does not provide information
on recovery rates, though it contains a proposal for a methodology to calculate
such rates. The RBMP does not provide information on cost recovery for other
sectors. According
to the Croatian authorities, work for the second RBMP will include economic
analysis of all water uses under Art. 5 of the WFD. The economic analysis will
calculate cost recovery levels, including environmental and resource costs, as
per national definitions. A methodology to determine environmental and resource
costs, including for diffuse pollution, was in preparation in 2014.
12.7.
Additional measures in protected areas
The
RBMP does not provide information on additional measures in protected areas.
13.
Climate change adaptation, water scarcity and
droughts, flood risk management and other emerging and linked issues as part of
the rbmp
The
RBMP makes few references to water scarcity or drought. Data on total annual
water consumption and water availability are provided at a national level
(sectoral and regional data are not provided). For HRC, there is one reference
to a minor mention related to groundwater quantity in the Zagreb area: this
issue is indicated as a risk that requires further monitoring. For HRJ, tourism
demand is noted as an occasional, local issue in periods of “hydromorphological
minimum” (e.g. certain summer periods), tied to water consumption in the
tourism sector. The
RBMP provides little information on floods. The international Danube RBMP from
2009 mentions the issue of floods throughout the Danube basin and also cites a
recommendation by the ICPDR to monitor flow of water during drought periods in
relation to floods. The draft RBMP for the Sava River basin discusses floods
and refers to the middle course of the Sava from Zagreb to Županja in Croatia
as one of the areas prone to flooding. The draft RBMP contains several
recommendations, including one on land use zoning in Croatia.
13.1.
Adaptation to Climate Change
The RBMP for HRC
and HRJ contains very little information on climate change. Croatia has
prepared a draft of the National Strategy for Implementation of the UNFCCC and
Kyoto Protocol in the Republic of Croatia with the Action Plan. Though not yet
adopted, this draft Strategy addresses both mitigation and adaptation. The
draft Strategy is not cited in the RBMP. The Plan does not identify any
adaptation measures related to water bodies, nor does it indicate whether a
climate check of the Programme of Measures has been carried out.
14.
Recommendations
Croatia should:
Review all existing permits and where necessary, amend them to
ensure that they are compatible with the WFD objectives.
Coordinate the preparation of the next RBMPs with the
preparation of the international Danube RBMP and the Sava RBMP and ensure
that cooperation with the neighbouring countries extends to all shared
catchments. Coordination of measures in internationally shared karstic
aquifers should be established.
Review the pressures and impact analysis and status assessment
in the 2nd RBMPs and ensure that the measures are based on the
updated pressures and impact analysis and status assessment of water
bodies. Besides basic measures, supplementary measures that are necessary
to achieve the objectives set should also be included in the 2nd
RBMPs.
Ensure that the RBMPs clearly identify the gap to good status,
and that the PoMs are designed and implemented to close that gap.
Exemptions should be adequately justified at water body level.
Complete the development of methods for the status assessment
of water bodies and determination of reference conditions and apply them
through the implementation of robust monitoring programmes (start
monitoring hydro-morphological parameters in lakes and transitional and
coastal waters and fish in lakes). An adequate WFD-compliant assessment
and monitoring framework is a necessary pre-requisite to design effective
PoMs and ultimately to achieve the WFD objectives.
Make improvements to groundwater monitoring, investigate and
address reasons for saline intrusions.
Determine effectiveness of basic measures and what needs to be
done in addition. Based on this gap analysis Croatia should take measures
in addition to the action programme for nitrates and the use of plant
protection products, if necessary. Those measures should be part of the
next RBMPs.
Review existing controls to ensure that agriculture practices
do not cause hydro-morphological pressure and update controls where
necessary for inclusion in the PoM of the 2nd RBMPs.
Include hydro-morphological measures in the PoM of the 2nd
RBMPs.
Ensure that an ecological flow consistent with good status is
established and review the existing permits where relevant.
Ensure the appropriate designation of heavily modified water
bodies and develop a methodology for establishing good ecological
potential. These methodologies should be documented in the RBMPs.
Justify adequately new hydro-morphological modifications, such
as navigation projects or new hydropower plants. They should be supported
by a proper strategic assessment of cumulative effects, an assessment of
alternative options and include all necessary mitigation measures.
Consider and prioritise 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.
Establish an improved and harmonised approach to exemptions in
the 2nd RBMPs. The methodology should include calculations of
disproportionate costs, assessment methods for adverse effects and better
environmental options.
Review and update the list of river basin specific pollutants.
Ensure that abstraction controls are in place by the time of
the 2nd RBMPs.
Provide in the 2nd RBMPs all the information on the
level compliance and timing to reach compliance of agglomerations,
including information on funding, in accordance with Directive 91/271/EEC
(article 15 and following).
Prioritize the agglomerations with more than 2.000 PE in terms
of the WFD principles and of financing in the 2nd RBMPs but
should also assess the pressures due to waste water from small
agglomerations (less than 2.000 PE) in the 2nd RBMPs cycle.
Ensure the compliance of Article 5 UWWTD for more stringent
treatment, especially in big cities.
Assess the need to take additional measures on point source
pollution beyond the requirements of the UWWTD and IED to fulfil the WFD
objectives.
Croatia should set additional objectives for protected areas,
monitor them and assess what additional measures are required to achieve
those additional objectives (Species and Habitats, Drinking Water, Bathing
Water).
Develop fully the economic analysis of water use, including the
calculation of Environmental and Resource Costs and ensure that the water
tariff and the water fees lead to adequate recovery of the costs of water
services. Measures that foster introduction of individual metering, where
shared metering is in place should be proposed.
[1] http://europa.eu/about-eu/countries/member-countries/croatia/index_en.htm
[2] Categorisation determined under the EC Comparative study of
pressures and measures in the major river basin management plans in the EU
(Task 1b: International co-ordination mechanisms). [3] "O.G.", No. 82/13 [4]“O.G.”, No. 73/13 [5] The RBMPs reports 2 additional surface water bodies (total 1317)
which are water bodies DSRI115004 (ecotype T03B) and
DSRI115003 (ecotype T04C), located on the Croatian – Serbian border. Their
position is such that the watercourses with a catchment area larger than 10 km2
are situated in the Republic of Serbia, and a part of the watercourses with a
catchment area smaller than 10 km2 are situated on the territory of
the Republic of Croatia. [6] This information corresponds to the reporting of protected areas
under the WFD. More/other information may have been reported under the
obligations of other Directives. [7] The total number of monitoring sites may differ from the sum of
monitoring sites by type because some sites are used for more than one purpose. [8] “O.G.“, No. 153/09, 63/11, 130/11, 56/13 and 14/14 [9] Art. 88(2) [10] Data reported to
WISE is slightly different from that presented in the RBMP [11] The RBMP reports that four physico-chemical QEs are currently used:
biochemical oxygen demand; chemical oxygen demand; total nitrogen; and total
phosphorus. [12]“O.G.”, No. 73/13 [13] “O.G.”, No. 89/10 [14] For example, Hrvatske elektroprivreda, a national power company in Croatia, plans investments for the
Senj-Kosinj Energy-Water protection Project (the project consists of creation
of two water reservoirs, construction of two hydropower plants, reconstruction
of an existing hydropower plant, construction of a feeding tunnel, and other
actions). [15] “O.G.“, No 56/13 (Articles 5 and 7) [16] “O.G.“, No. 51/10 [17] Urban Waste Water Directive (91/271/EEC) [18] Annex V, section 10, OJ L 112, 24.04.2012, p. 1 [19] Bathing Water Directive (2006/7/EC). [20] Drinking Water Directive (98/83/EC). [21] Marine Strategy Framework Directive (2008/56/EC). [22] Ground Water Directive (2006/118/EC) [23] Industrial Emissions Directive (2010/75/EU) [24] The Regulation on the Lowest General Price of Water Services and
Type of Costs which are Included in Water Services Price (“O.G.“, No. 112/10) [25] This is as stipulated in the Regulation on amendment to the Decree
on Fees for Use of Water and the Decree on Fees for Protection of Waters
(“O.G.“ No, 83/12). [26] “O.G.“, No. 153/09, 90/11 and 56/13