Miljø- og Fødevareudvalget 2024-25
MOF Alm.del Bilag 291
Offentligt
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EUROPEAN
COMMISSION
Brussels, 4.2.2025
SWD(2025) 34 final
COMMISSION STAFF WORKING DOCUMENT
Third River Basin Management Plans
Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans
Member State: Denmark
Accompanying the document
REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN
PARLIAMENT
on the implementation of the Water Framework Directive (2000/60/EC) and the Floods
Directive (2007/60/EC)
Third River Basin Management Plans
Second Flood Risk Management Plans
{COM(2025) 2 final} - {SWD(2025) 13 final} - {SWD(2025) 14 final} -
{SWD(2025) 15 final} - {SWD(2025) 16 final} - {SWD(2025) 17 final} -
{SWD(2025) 18 final} - {SWD(2025) 19 final} - {SWD(2025) 20 final} -
{SWD(2025) 21 final} - {SWD(2025) 22 final} - {SWD(2025) 23 final} -
{SWD(2025) 24 final} - {SWD(2025) 25 final} - {SWD(2025) 26 final} -
{SWD(2025) 27 final} - {SWD(2025) 28 final} - {SWD(2025) 29 final} -
{SWD(2025) 30 final} - {SWD(2025) 31 final} - {SWD(2025) 32 final} -
{SWD(2025) 33 final} - {SWD(2025) 35 final}
EN
EN
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Denmark
ENVIRONMENT
Country specific staff working document
© Pexels.com | Stepan Vrany
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Content
Content
...................................................................................................................................................................................................
2
SECTION A: WATER FRAMEWORK DIRECTIVE
..........................................................................................................................
3
1. General info, member state characterisation
.............................................................................................................
4
2. Horizontal aspects
...................................................................................................................................................................
10
2.1 Governance
.........................................................................................................................................................................
10
2.2 Characterization of River Basin District
..............................................................................................................
10
3. Policy elements contributing to biodiversity and climate change adaptation
......................................
17
3.1 Surface Water: what is their ecological status or potential
....................................................................
17
3.2 Hydromorphological changes and artificialization (HMWBs and AWBs)
..........................................
19
3.3 Groundwater bodies - have they sufficient water – quantitative status
.........................................
20
3.4 Protected Areas (identification, monitoring, objectives and measures)
...........................................
21
3.5 What is being done to prevent/reduce hydromorphological pressures
............................................
22
3.6 What Denmark is doing for abstractions and water scarcity
.................................................................
22
3.7 Adaptation to climate change
..................................................................................................................................
23
4. Policy elements contributing to zero pollution
........................................................................................................
24
4.1 Surface Water: what is their chemical status
.................................................................................................
24
4.2 Groundwater Bodies: what is their chemical status
....................................................................................
27
4.3 What Denmark is doing to combat pollution from agriculture
.............................................................
29
4.4 What Denmark is doing to combat pollution from other sectors
........................................................
32
4.5 What Denmark is doing to combat significant pressures – overall assessment of the
Programmes of Measures
..................................................................................................................................................
33
5. Exemptions and economics
...............................................................................................................................................
34
5.1 To what extent are exemptions applied in Denmark
..................................................................................
34
5.2 Use of economic analysis and water pricing – cost recovery
................................................................
36
6. WFD recommendations
........................................................................................................................................................
37
SECTION B: FLOODS DIRECTIVE
..................................................................................................................................................
40
7. Flood risk management under floods directive (FD)
............................................................................................
41
7.1 Flood hazard and risk maps
......................................................................................................................................
41
7.2 Flood risk management plans
..................................................................................................................................
42
8. FD recommendations
............................................................................................................................................................
45
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SECTION A:
WATER FRAMEWORK
DIRECTIVE
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1. General info, member state characterisation
Denmark is the southernmost of the Scandinavian countries, lying south-west and south of Sweden,
south of Norway and north of Germany with which it shares a short border. The Kingdom of Denmark
also includes the Faroe Islands and Greenland which will not be considered in this report. Denmark
consists of the larger, northern part of the Jutland peninsula and an archipelago of over 400 islands,
the largest and most populous of which include Zealand, Amager Funen, North-Jutlandic Island and
Lolland. Bornholm is an outlier, as it is an island situated in the middle of the Baltic Sea.
Denmark has almost 6 million inhabitants and a surface of 43,094 km2 with a population density of
about 139 inhabitants per km
2
, higher than the EU average. In general, population density increases
when moving from west to east. About 1 of 2 Danes lives in urban centers with a population of at
least 20 thousand. Almost one in five Danes live in the Copenhagen metropolitan area.
Because of the many islands and fjords, Denmark’s general coastline is much shorter than its tidal
short line (over 1000 and about 8700 km respectively). Hence, there are relatively many coastal
waters which can be roughly divided in those bordering the North Sea, thus with strong tides, and
those at the Baltic Sea where waves and tides are much smaller.
Note:
E-reporting, the source of this map, defines DK4 as a national RBD, whereas the national RBMP PDF defines it as
an international RBD.
The country is flat with little relief. The average height inland is about 30 meters about sea level, and
the highest peak is only 170 meters. There are no long or big rivers in Denmark because of its small
size, low elevation and relatively low rainfall. Instead, the land is drained through relatively short
rivers and streams flowing into lakes or the nearby sea. Only two rivers, both in Jutland, attain more
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than 100 km in length and only five more exceed 60 km. The longest river in Zealand is 83 km, and
the longest in Funen is 53 km.
Denmark has 14.9% of its territory designated as nature protected areas, below the EU average of
26%. Agricultural land covers around 60% of the territory. Danish agriculture is a large net exporter
of agricultural products, and the contribution of agriculture plays an important role in the country’s
economy. Pigmeat and dairy are the most important sectors in terms of production value.
Reporting
The deadline for reporting the 3
rd
RBMPs was in March 2022. The Commission and the EEA together
with Member States developed an electronic reporting system in WISE (Water Information System
for Europe). Its use was voluntary. Some Member States used it to fulfil their obligations, others
reported the plans in pdf format. The cut-off date for the WISE e-reporting was September 2023 and
the MS were assessed based on the datasets available by this date.
By September 2023 Denmark had not submitted full electronic reporting. Therefore, the assessment
is based on the data mining of the pdf RBMPs.
Despite the cut off dates for the production of this report, reporting continued and, for the State of
Water report, the EEA aggregated the results available by July 2024 in their products and dashboards
available at WISE Freshwater web portal.
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Changes in Status, Pressures, Exemptions & Measures
Surface
Water
Bodies
(7812)
Trend (% good
status/potential)
Main Pressures & Changes & Exemptions
The large majority of surface water bodies is not in good or high ecological status. In terms of the number of waterbodies: 29.9% of surface
water bodies have attained good status, while 57.8% are classified with a lower status and 12.3% have unknown status. The absence of good
status concerns 68% of rivers, 84% of lakes and 95% of coastal water bodies. In fact, a high proportion is in poor or bad ecological
status/potential: 34% of rivers, 43% of lakes, and 73% of coastal waters. In addition, 65% of river water bodies and 19% of lakes have unknown
ecological status/potential.
Assessing progress through comparing the 2nd and 3rd RBMPs is complicated by changes in the delineation of water bodies, the changes in
number of quality elements as well as the reduction of the percentage of rivers with unknown status. There seems but little progress: only a
slight increase in the percentage of surface water bodies in good / high status; an increase in the percentages of rivers, lakes and coastal waters
in poor / bad status; and a marked rise in the percentage of rivers failing to attain good status. The confidence in the assessment has on the
whole increased
While almost all rivers are scheduled to have attained good ecological status / potential by 2027, over half of the lakes and almost all coastal
water are expected to achieve this only well after 2027.
Eutrophication caused by nutrients is the major cause of the persistent failure to timely improve the ecological quality: it concerns phosphorus
for lakes and nitrates for the coastal waters. The main pressure is from agriculture's use of manure and fertilisers, while there are also significant
contributions from wastewater plants and aquaculture.
The included measures are insufficient to achieve the stated ecological objectives for 2027. While the baseline assumes 75 % of the estimated
load reductions planned in the 2nd RBMP to be implemented, the planned measures on top of the baseline cover around 80% of the remaining
gap. The included measures on river restoration fall 1650 km short of the required effort. In both cases, the announced revision of the 3
rd
RBMP
is reported to define additional measures to bridge the gaps.
ECOLOGICAL
STATUS
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Only a tiny fraction of surface waters, namely 1.7 %, is in good chemical status, whereas 5.6 % is in poor status and for 92.7% the chemical
status is classified as unknown. While the absence of good status affects the surface water types nearly equally (99% of rivers, 91% of lakes
and 95% coastal waters), it is for a different reason. For almost all coastal waters, the status is known, and 93% of them are in poor chemical
status. In contrast, for 70% of lakes and 97% of rivers, chemical status is unknown. The RBMPs do explain neither this low rate of chemical
status classification nor the lack of classifications made with high confidence, both of which seems at odds with the extension of the monitoring
network now covering 85% of all surface waters.
The comparison between the 2nd and 3rd RBMPs suggests a deterioration, although its extent is hard to ascertain because of the change in the
number of surface waterbodies and of priority substances as well as the reduction of the percentage of lakes and in particular coastal waters
in unknown status (resp. with 25 and 39 %-points). The increased rate of chemical status classification goes together with a fall in the ratio of
good over poor status, namely for all surface water bodies together, from a 1-1 ratio in the 2nd RBMP to a 1-3 ratio in the 3rd RBMP. At least
for coastal waters, this does not merely reflect an observation effect, but also an actual decline: as share in the total of surface waters with a
chemical status classification, the percentage of coastal waters in poor status jumps from 17 to 94.
The chemical status assessment includes only 25 priority substances out of the 45 required by the Environmental Quality Standards Directive,
only a few more than in the 2nd RBMP. This coverage gap is not explained.
The RBMPs do not pronounce clearly to what extent rivers and lakes will attain good chemical status by 2027.xxxxxxxThe rather small sample
of surface water bodies with a status classification suggests a worsening water pollution, the actual size of which remains unclear. In about
one out of two surface water bodies found in poor status, mercury pollution can count as the reason; it concerns a four-fold increase in number
of water bodies. Anthracene pollution is a problem in almost as many water bodies, while nearly absent in the 2nd RBMP. The number of water
bodies affected by cadmium, lead and nonylphenol has also strongly increased.
CHEMICAL
STATUS
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Ground
Water
Bodies
(2050)
Trend (% good
status/potential)
Main Pressures & Changes & Exemptions
As in the 2nd RMBPs, almost all groundwater bodies are in good quantitative status (99.6%); these classifications are on the whole made
with high confidence. In fact, all drinking water comes from groundwater reservoirs with only minimal treatment requirements. Consequently,
out of the total of 2050 groundwater bodies, 1705 are protected for drinking water abstraction.
QUANTITATIVE
STATUS
Only 9 out of 2050 groundwater bodies (0.4 %) have been found in poor quantitative status in the year 2021, due to over-abstraction. This
suggests an emerging (seasonal) scarcity problem, also because 4% of groundwater bodies is at risk to fail good quantitative status in
2027. A comparison with the corresponding number of water bodies in the 2nd RBMP is not meaningful because of a fivefold increase in
the total number of groundwater bodies resulting from a hydrological review that aimed to define entities with more homogenous conditions
(more rigorous separation of shallow, regional or deep groundwater entities).
The groundwater associated aquatic ecosystems have been considered, similarly to the approach followed in the 2nd RBMPs. The main gap
in the assessment methodology is the lack of consideration of groundwater dependent terrestrial ecosystems.
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A large majority of groundwater bodies is in good chemical status (88.8%). The chemical status is poor in 9.4% of groundwater bodies and
unknown in 1.9%. Even when accounting for the fivefold increase in the total number of groundwater bodies due to a comprehensive
hydrological review, this seems an improvement vis-à-vis the 2nd RBMP which reported only 44.3% of total groundwater bodies in good
status with 30.6% in unknown status. The fall in the percentage of waterbodies at risk to fail good status from 25 to 13% also suggests
an improvement.
The chemical monitoring of groundwater has covered the following substances: nitrate, chloride, trace-elements, pesticides and
environmentally dangerous substances. The data foundation for
assessing groundwaters’ chemical status has improved since the 2nd
RBMPs, as it now incorporates data from pesticide monitoring and water utility controls. However, despite the expanded data foundation
and more homogenous water bodies, the 3rd RBMPs report
‘low confidence’ for most of the status assessment, whereas the 2nd RBMPs
reported mostly ‘medium confidence.’
Pesticides are the group of substances most responsible for the failure to attain good status: almost two thirds of groundwater bodies in
less than good status have too high pesticide concentrations (amounting to about 7% of all groundwater bodies). In addition, the drinking
water test has a significant upward effect on the percentage of groundwater bodies in less than good status. Nitrates and trace particles
are less prevalent causes.
To a large extent, the pesticides pollution concerns a legacy effect as most of the pesticides concerned have been banned already. This
implies that overall improvement will be slow as reflected by the small difference between the percentage of groundwater bodies in poor
chemical status and the percentage of those expected to fail good status by 2027.
CHEMICAL
STATUS
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2. Horizontal aspects
The Danish RBMPs have been mainly assessed on the basis of the traditional reporting of RBMPs (the
national document and the reports for the 4 RBDs), which were submitted to the Commission in June
2023, about a half year after the deadline. It has been possible to take account of the information
by electronic reporting only to a limited extent, since many background documents and data have
been submitted only in January 2024, this including apparent corrections and revisions. On top of
this, the Danish authorities indicated in informal comments that they would revise the 3
rd
RBMPs in
the course of 2024. It is likely that the ongoing development of the policy to combat nitrogen
emissions and the recent publication of the new Climate Change Adaptation Plan may also inform
such revised RBMPs.
2.1 Governance
Denmark has a centralised approach to water management. The Danish Ministry of Environment is
the competent authority for all four River Basin Districts. While the main roles are divided between
the Ministry and the Danish EPA (Environmental Protection Agency), the overall responsibility belongs
to the Ministry.
Water councils are a unique Danish feature of water governance at local level. There are 23 water
councils in Denmark, in which local stakeholders are represented. Each of them is responsible for one
specific catchment area. In cooperation with municipalities, each of these water councils have created
a sub-plan for the catchment area, thus incorporating local knowledge into water planning.
In general, the Danish RBMPs do not provide a lot of further information on important governance
issues. As regards public consultation, the authorities have succeeded to elicit a substantial support
from the whole range of stakeholders, because the consultation was widely advertised and had an
appropriate consultation period (December 2021 to June 2022). In addition, stakeholders’ active
involvement was facilitated through advisory groups and even participation in the RBMP drafting
process. However, the RBMPs merely state these activities have had impacts on information base and
measures, but they do not specify how stakeholder recommendations have been taken up.
As regards the management of coastal waters, despite the large area of coastal waters, the RBMPs
do neither include the MSFD objectives nor an account how and where the MFSD is implemented.
While it is reported that the MSFD strategies are coordinated with neighboring countries, they do not
mention the regional maritime conventions, namely OSPAR for the North Sea coast side and HELCOM
as regards the Baltic Sea coast. Yet HELCOM plays an important role in coordinating the monitoring
of the nutrient inputs into to the marine environment (nitrogen and phosphorus) and corresponding
policies.
As regards transboundary cooperation, for the Vidå-Kruså RBD, the only international river basin, the
RBMP does not present measures reflecting coordination with Germany. However, the Danish
authorities have confirmed that such coordination is fully in place.
2.2 Characterization of River Basin District
Denmark has four River Basin Districts (RBDs) which function also as the “Units of Management” in
implementing the Floods Directive. The RBDs are Jutland & Funen; Zealand; Bornholm; and Vidå-
Kruså (an international RBD shared with Germany).
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The first two RBDs cover over 90% of Denmark’s surface. Notably, the first three RBDs are separated
from one another by international waters. Table 1 below reports on the number of surface and
groundwater bodies in these four RBDs, as reported in the 3
rd
RBMPs.
Table 1: Number of delineated surface and groundwater bodies in Denmark according to the 3rd RBMPs
Coastal
Waters
76
Territorial
Waters
9
Groundwater
Bodies
1340
RBD
Name
Rivers
Lakes
DK1
Jutland & Funen
5301
699
DK2
Zealand
Bornholm
Vidå-Kruså
1109
145
148
6703
244
12
31
986
30
2
3*
109
6
1
0
14
667
29
14
2050
DK3
DK4
TOTAL
Note:
* 2 of the waters in question are shared. There are no transitional waters in Denmark.
Delineation
The 3
rd
RBMPs (including the national document) reveal some significant changes in the delineation
of water bodies, although the typology of water body types has reportedly remained largely the same
per RBD and water categories.
The number of groundwater bodies has increased fivefold vis-à-vis the 2
nd
RBMPs, as the result of a
hydrological review of groundwater delineation aiming to define entities with more homogenous
conditions (more rigorous separation of shallow, regional or deep groundwater entities). This large
change hinders in-depth status comparisons between the 3
rd
and 2
nd
RBMPs.
The review of the delineation of surface waters has led to smaller changes. The number of rivers and
of coastal waters have both decreased by roughly ten percent whereas the small number of territorial
waters has remained the same. In contrast, the number of lakes has increased by about fifteen
percent as the net result of adding two hundred new lakes and excluding about fifty smaller lakes
seen as not or no longer meeting the size or other criteria to qualify as a lake.
The RBMP national document does not provide summary information on the percentage of surface
water body types for which type-specific reference conditions have been established for biological,
physico-chemical or hydromorphological quality elements. Neither is it reported whether the
reference conditions for the international Vidå-Kruså RBD have been coordinated with Germany.
It is not clear whether these gaps result from a reporting issue rather than a lack of implementation
since the Danish authorities have submitted the relevant background documents to WISE’s / Eionet’s
central data repository in January 2024 (thus well after the RBMPs’ submission date), and they
mention that they have intercalibrated type-specific reference conditions with other relevant Member
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States as part of the European Commission’s Intercalibration Decisions. However, the intercalibration
of reference conditions is still in progress for macroalgae in coastal waters of both Baltic Sea and
the Atlantic.
Pressures
The RBMPs’ set of documents does not provide a detailed account of the definition of significant
pressures (detailing the relationship with threshold and risk assessment), but they provide
information on the main pressures on water bodies, coming from the assessments based on the
findings from the national monitoring programme NOVANA, authority supervision and special
investigations.
Surface waters
The key impacts on (chemical and ecological) water quality come from nutrient (both nitrate and
phosphorous), organic, and hazardous pollutants as well as morphological changes.
In particular, most coastal water bodies and many lakes have been affected by nutrient pollution,
with wastewater discharges and aquaculture as the key point source pressures and the ammonia
and nutrient emissions from agriculture as the key diffuse source pressure.
Nutrients are the major cause of the persistent failure to timely improve the ecological quality.
Agricultural activities (involving manure and fertilisers) are the main culprit (although there are
significant contributions from wastewater plants and aquaculture as well). Water courses transport
these nutrients loads from the land into lakes and coastal waters, where they accumulate over time
and significantly degrade the aquatic ecosystems. Phosphorus is considered as the main pressure
factor for lakes, and nitrates for the coastal waters. Figure 1 shows the widespread and persistent
impacts from sustained nutrient pollution.
The excess of nutrients causes leads to eutrophication, i.e. the excessive growth of bacteria and
algae.; In combination with higher water temperatures, it causes severe (seasonal) oxygen depletion
and toxic residues on the water floor, killing off entire ecosystems. There appears to be much more
information on the nature and extent of ecological damage in coastal waters than for lakes; the
problem concerns mostly the coastal waters at the Baltic Sea coast (see Figure 3 below). The coastal
water’ s high fish mortality and the increasing occurrence of large marine “dead zones” without hardly
any maritime life has been widely reported in the press
1
, noting that this longstanding problem has
increased to (near)-catastrophic proportions raising questions on the adequacy of the nitrogen
abatement measures.
It has been prominently reported since 2020, in Danish mass media (see as example,
this article
(in Danish) from the
Danish TV2 news) and even beyond (mostly in environmental news outlets, such as
this one,
and generic media, such as
from
France-international).
1
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Figure 1: The impacts of nutrient pollution on the ecological quality of water: the trophic state of Danish surface water
bodies 2016 – 2019
Source: Joint Research Centre of European Commission (n.d.). JRC NITRATES DIRECTIVE - Reporting Period 7 (2016-2019)
Trophic Status. [online] water.jrc.ec.europa.eu.
Available at:
https://water.jrc.ec.europa.eu/portal/apps/dashboards/cb6034c2a75e4df282f8a62f90c16caa
Indeed, since 2020, Aarhus University studies have signalled that, after some improvements in the
previous decade, since 2019 the coastal water’s oxygen depletion issue has rapidly increased in both
proportion and severity. The studies are an important input to the Danish government’s scientific
assessment of the Danish coastal and marine waters. One of their studies already raised the alarm
in 2020, based on the observation that the total coastal sea area affected by oxygen depletion in
that year was about twice as high as in the previous year
2
. Their study from August 2023
3
concludes
that the extent of the oxygen depletion in 2023 was the second largest one ever recorded for
September. It also identifies a worsening trend over the recent years (see Figure 2 below), reflecting
both the shortfall of the reductions so far achieved in the nitrogen inputs into these waters, a
significant part of which originates from agricultural activities in Denmark, and the increasing impact
of climatic factors, specifically a trend towards higher water temperatures in Danish coastal and
marine waters.
See as example of the press attention for this study,
this article
in phys.org.
Aarhus University, “Oxygen depletion in Danish waters 29 August – 25 September 2024,” DCE (Danish Centre for Energy
and Environment) advisory note (in Danish), 4 October 2024.
2
3
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Figure 2: Reported area size of moderate and severe oxygen depletion in Danish coastal waters
Source: see footnote 3
Figure 3: Map on the geographic extent of oxygen depletion in Danish coastal waters
Source: see footnote 3. The red and orange areas are with strong and moderate oxygen depletion respectively.
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As regards the discharge of wastewater from treatment plants, it is a key pollution source, affecting
about 1% of the length of all rivers. Larger wastewater treatment plans (i.e. with capacity over 30
persons equivalents) constitute the largest contributor of nitrogen and phosphorus and the second
largest contributor of organic material. In addition, the discharges from unconnected dwellings show
comparably high discharges of the same pollutants, due to the lower degree of treatment; and the
same applies to the incidental storm water overflows of sewage systems.
In addition, morphological changes (including dams, barriers and locks) alter aquatic habitats and
thus reduce the ecological water quality.
As regards invasive alien species, some species of crayfish are included in the national list of invasive
alien species and efforts are ongoing to map their distribution
4
. This will allow ascertaining to what
extent the populations of invasive crayfish already present in the Danish aquatic environment is
significant or not. Likewise, the floating fern (Azolla
filiculoides)
is an aquatic plant present on the
national invasive alien species list since it has been found in some water bodies in Denmark. These
plants can form very dense mats in favourable habitats, causing many difficulties for boat transport,
water animals and native plant species, and becoming a source of eutrophication.
The RBMPs recognise that climate change impacts can be expected to exacerbate pressures on
surface water bodies, which may contribute to them not achieving good ecological status. The
increased rainfall leading to the acceleration of nutrient run-off from land into inland waters and
then to coastal waters, as well as higher temperatures
5
lead to higher eutrophication and oxygen
depletion resulting in long-term damage.
Groundwater
The main pressures concern pollution, namely soil pollution as point source pressure and agriculture’s
fertiliser and pesticide use as the main diffuse source pressure. While current pressures and impacts
are much less widespread than the pressures on surface waters, the pollution concentration, in
particular in deep groundwater bodies, respond to emission volumes over time with long time lags.
Nitrates concentrations in groundwater exceed the limits established in the Nitrates Directive in a
considerable number of points. See the map in Figure 4 below.
Søren Berg et al., “Mapping the distribution of crayfish and crayfish plague in Danish waters,” DTU Aqua-rapport nr. 401-
2022 (in Danish); available
online.
5
For rainfall and temperature alike, it concerns both average and peak levels. Run-offs can also lead to inflow of pesticides
and sediments, putting further pressure on the ecological status.
4
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Figure 4: Nitrates concentration from agricultural sources in groundwater- report on implementation of
the Nitrates Directive
6
As further discussed in section 3.3, water is mainly abstracted from groundwater, with agriculture
and public water supply as the major user destinations. Similarly to the 2nd RBMPs, Denmark has
not identified water abstraction (understood as consumptive use or net consumption) as a significant
pressure at the RBD level or in significant portions of an RBD for any RBD in Denmark. However, the
3
rd
RBMP’s economic analysis does not seem to explore whether on the longer term, there may be
bottlenecks in water supply to meet the demand for abstracted water by the different user sectors.
It appears that water scarcity is not seen as a significant problem as only 9 groundwater bodies fail
to be in good quantitative status in 2021 and all groundwater bodies are expected to be in good
status by the year 2027.
6
Taken from the
country fiche
for Denmark in the Nitrate Directive Reporting 7: groundwater.
16
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3. Policy elements contributing to biodiversity and
climate change adaptation
3.1 Surface Water: what is their ecological status or potential
Monitoring
The RBMP traditional reporting has a relatively weak coverage on the state of play regarding
monitoring, assessment and classification of ecological status, also because for the factual
corroboration, it refers to missing or late electronic reporting on the relevant aspects. For instance,
the data available to the RBMP assessment do not say anything on monitoring frequency.
The 3
rd
RBMPs claim progress in the monitoring scope, namely a clear increase in the number of
water bodies covered and in their geographical spread. The vast majority of surface water bodies in
all RBDs are monitored on the basis of the national guidelines NOVANA. Reportedly, all water types
have a monitoring programme, and the monitoring is evenly spread out over the country.
Consequently, for each RBD, less than 10 % of the water bodies is in unknown ecological status. All
coastal waters are monitored and classified. Although not mentioned in the RBMPs, grouping has
been used to classify smaller lakes. The remaining unclassified water bodies are mostly small lakes
and watercourses.
The monitoring has also improved through covering more quality elements, although it appears that
for none of the surface waters, the surveillance monitoring has included all required elements.
Notably, it appears that there is no specific information on ecological flows. A clear picture is however
difficult to obtain due to a lack of electronic reporting at the time of RBMP submission and
assessment. With a view of the discussion further below, it merits highlighting that Denmark has not
fulfilled its obligation to monitor all necessary quality elements. Most coastal water bodies have been
monitored for all the required biological quality elements, but not for thermal conditions (neither in
lakes), whereas for rivers, nutrients have not been monitored
7
.
Of note, the Commission has expressed for some time concerns about the significant gaps in the
monitoring systems for surface waters in Denmark, and, relatedly, about the very large number of
unknowns in the status of many surface water bodies. In exchanges with the Danish authorities, it
transpired that they have recognised that several of these monitoring and related knowledge gaps
needed to be addressed. The 3rd RBMPs reflect these efforts, but it appears that many monitoring
deficiencies and number of unknown status aspects remain, seriously hindering the possibility for
Danish surface waters to achieve compliance with the WFD objectives.
Status assessment
The 3rd RBMPs reveal that Denmark faces a huge persistent challenge to improve the overall bad
ecological quality of Danish waters. Overall, in the year 2021, 95% of Danish coastal water bodies,
64% of its lakes and 67% of the rivers are reported to be in less than good ecological status /
potential, and quite a high proportion of them (73% of coastal waters and 43 % for both lakes and
7
Nutrients do not constitute a compulsory monitoring item for rivers.
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rivers) are found to be in poor to bad ecological status / potential. The traditional RBMP reporting
does not discuss the confidence of the ecological status assessments.
Overall, the situation appears to have hardly improved over the 2
nd
RBMP period. 29.9% of all Danish
water bodies are recorded to be in at least good status / potential in the year 2021, versus 28.2 %
in 2015. This is depicted in Figure 5. Nutrients are the major cause of the persistent failure to timely
improve the ecological status.
Unfortunately, the changes in the numbers of water bodies delineated and classified hinder a more
robust comparison. However, as regards the fully classified category of coastal waters, while the
share in good status has increased somewhat, the much larger fall in the share of moderate status
is nearly matched in size by an increase in the share of poor to bad status, strongly suggesting a
significant deterioration
8
.
Figure 5: Ecological status of surface water bodies
The expected ecological status in 2027 varies strongly over the surface water categories. While the
RBMPs expect all rivers will achieve good ecological status by 2027, a clear majority of lakes and
95% of coastal waters are expected to reach good status with the planned measures only well after
2027.
The Danish RBMPs point to an interesting trade-off in nature-based attempts to improve the
ecological quality of surface waters. It is claimed that when properly executed, frequent weed-cutting
contributes to mitigating high levels of nutrients, but at the expense of the diversity and hence
robustness of the involved aquatic ecosystems, both as regards flora and fauna.
Both tendencies need to be interpreted with some care in view of the about ten percent reduction in the number of coastal
waters.
8
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3.2 Hydromorphological changes and artificialization (HMWBs and AWBs)
The relative low share of heavily modified and artificial water bodies (see Table 2 below) suggests
that level of human intervention in the physical aspects of Denmark’s water system is not very high.
Table 2: Number of heavily modified and artificial surface water bodies in Denmark according to the 3rd
RBMPs
Rivers
(% of total
rivers)
5.64%
3.21%
Lakes
(% of total
lakes)
0.00%
0.20%
Coastal
Waters
(% of total
CWs)
3.67%
0.00%
Territorial
Waters
(% of total)
0.00%
0.00%
Total
(% of total
SWBs)
0.00%
0.00%
Modifications
HEAVILY MODIFIED
ARTIFICIAL
Note:
SWB = Surface Water Bodies. There are no transitional waters in Denmark.
Both in absolute numbers and percentages, there are more rivers qualifying as heavily modified and
artificial than is the case for the other surface water categories (see Figure 6). Denmark has no
transitional and territorial waters, and there are only 2 artificial lakes and 4 heavily modified coastal
waters. The low reported number for lakes may be related to the delineation restrictions, such as on
size and specific regulatory use (it concerns lakes that according to the regions’ raw material plans
lakes are located in active digging areas, or lakes that are appointed as wastewater technical facilities
in the municipality’s wastewater plan). Coastal waters can be heavily modified due to the presence
of locks which protect the inland catchment area against high sea levels during severe storms (cf the
lock in Vejle fjord).
Figure 6: Number of heavily modified and artificial surface water bodies in Denmark according to the 3rd
RBMPs
6,00%
5,00%
4,00%
3,00%
2,00%
1,00%
0,00%
Rivers
Lakes
Coastal
Waters
Total
HEAVILY MODIFIED
ARTIFICIAL
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The 3
rd
RBMPs do not indicate the change vis-a-vis the 2
nd
RBMPs. However, when comparing the
reported percentages of HMWBs and AWBs, the percentages reported in the 3
rd
RBMPs appear the
same or a bit smaller than those reported
9
in the 2
nd
RBMPs.
On a positive note, Denmark has defined good ecological potential for all heavily modified and
artificial surface waters. The assessment appears to use more or less the same elements as used in
the assessment of ecological status.
HMWBs and AWBs do not have to reach good ecological status but just good ecological potential,
which reflects a lower level of ambition. Yet only a minority of HMWBs and AWBs appear to be in
good ecological potential. The 3
rd
RBMPs report that about one fifth of the heavily modified and
artificial water courses (“rivers”) have at least good ecological potential. Of the two artificial lakes,
one is reported to have ‘moderate’ ecological status, while the status of the other one is unknown.
None of the four heavily modified coastal waters are in good ecological potential. Due to the lack of
detailed reporting in the traditional RBMP reporting, it is not possible to assess progress vis-à-vis the
situation reported in the 2
nd
RBMP.
3.3 Groundwater bodies - have they sufficient water – quantitative status
Monitoring
All groundwater bodies have been monitored for the 3
rd
RBMP. Municipalities closely monitor the
status of groundwater, as they issue and regularly review abstraction permits as regards the
environmental objectives. Their assessment includes the increase in chloride contents because of
saline intrusion and an increase in the concentration of toxic metals.
Status assessment
Almost all groundwater bodies have been found to be in good status in the year 2021 (99.6% of the
total number of groundwater bodies). The good state of affairs is important because in Denmark,
water is mainly abstracted from groundwater, and 85% of the Danish groundwater bodies are
designated as potential zones for drinking water abstraction.
The assessment has used grouping within a RBD over groundwater bodies of similar sub-type
(shallow, regional or deep groundwater bodies), and the assessment concerns a model-based
approach, including as appraisal elements the water balance, the quality of aquatic ecosystems
associated with groundwater, as well as saline intrusions. The needs of depending terrestrial
ecosystems have not been included because a study found only limited indications or evidence of
the related impacts on the status.
10
As for other status dimensions, the traditional RBMP reporting
does not discuss the confidence of the quantitative status assessments.
However, although the level of precipitation has not fallen over time, there are 9 groundwater bodies
failing to reach good status. They are all located in the larger two RBDs (namely 3 in Jutland & Funen
and 6 in Zealand). Hence over-abstraction seems to be the main cause. Yet, the 3rd RBMPs say that
See Figure 7.1 in the European Commission’s assessment of Denmark’s 2
nd
RBMPs,
SWD(2019) 38,
February 2019.
The study was one of the so-called knowledge increasing measures from the 2
nd
RBMPs. The 3
rd
RBMPs conclude,
however, that more research is needed. Hence, this factor contributes to the uncertainty of quantitative status assessments.
9
10
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all groundwater bodies are expected to maintain or achieve good quantitative status by the year
2027.
The situation overall appears quite similar to the one in the 2
nd
RBMP. However, a precise quantitative
assessment of the progress since the 2
nd
RBMP is difficult due to the five-fold increase in groundwater
bodies due to the new delineation (see section 2.1.2 above).
The 3rd RBMPs introduce as new measure the cross-municipal cooperation on water abstractions in
order to ensure that abstractions are drawing from more groundwater bodies and, thus, a more
sustainable utilisation of each individual groundwater body.
Climate scenarios indicate as key challenge the saline intrusion into coastal wells, due to the rise in
sea level rise. This implies that in the future the groundwater abstractions will have to be limited
accordingly, and hence that the availability and quality of surface water as water supply source will
increase in importance.
3.4 Protected Areas (identification, monitoring, objectives and measures)
There are different types and reasons why certain water bodies are protected under the law. For
surface water bodies, protected areas have been designated under the Drinking Water, Bathing Water,
Habitats and Birds Directives as well as for areas designated for the protection of economically
significant aquatic species (i.e. aquaculture).
The 3
rd
RBMPs contain a register for protected areas, including a map, showing that Denmark has
identified protected areas for all types associated with surface and groundwater. However, due to the
traditional RBMP reporting’s unclear reporting, it has been difficult to form a picture of the current
status and the changes compared to the previous cycle.
The Danish authorities have declared the whole country as a nutrient sensitive area. This implies
there is no differentiation over the country area as regards Nitrate Vulnerable Zones designated under
the Nitrates Directive and sensitive areas under the Urban Waste-Water Treatment Directive, but
there is a single, national Nitrate Action program in place that includes measures such as restrictions
for the spreading of livestock manure as well as permitting and approval requirements for a range
of activities that could affect the drinking water supply.
The 3rd RBMP report 1705 out of the total of 2050 groundwater bodies as protected areas for
drinking water, about 40% of which are registered for active abstraction and thus subject to more
stringent monitoring. These monitoring efforts also appear more focussed as before. While the 2
nd
RBMPs had indicated that all groundwater bodies (402 in total) functioned as drinking water source,
the current 1705 drinking water bodies represent more than 99 % of the total volume of all
groundwater, thus smaller water bodies are no longer subject to the additional monitoring
requirements. The RBMP explains that this is a result of a revised designation process concomitant
to the substantial revision of groundwater delineation (see section 2.1.2 above), but it does not
provide clear details on the drivers of the increase.
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Municipalities are required to develop action plans for groundwater protection in these protected
areas. These plans cover approximately 40 % of Denmark's area and should address the challenges
identified in the national groundwater mapping.
11
In their capacity as abstraction permitting authority,
municipalities can set permit conditions to prevent potential negative effects.
As regards the other types of protected areas, the national 3
rd
RBMP mentions Natura 2000 areas
protecting water-dependent habitats and species, as well as a few shellfish protected areas and
bathing areas, for which specific protection rules from EU legislation apply. The national RBMP PDF
does not explain why the number of habitats protected areas has fallen considerably vis-à-vis the
2
nd
RBMPs, namely
12
from 417 to 269.
As mentioned above, in general, the reporting on the protected areas suffers from two significant
gaps, making it difficult to assess progress. First, the 3rd RBMPs do not present an overview of the
status of the water bodies associated with protected areas. Second, regrettably, despite an explicit
Commission recommendation for Denmark’s in the 2
nd
RBMPs, the report does not clearly identify the
additional objectives and the corresponding additional measures adopted for these areas (while they
may be subsumed in the Programme of Measures’ basic measures).
3.5 What is being done to prevent/reduce hydromorphological pressures
Denmark has a permitting regime controlling abstractions and water impoundments. Each RBD has
a register of impoundments.
River restoration is the main focus of the hydromorphological measures in the PoM, aiming to achieve
good ecological status (or potential) for all rivers at the end of the programming period (thus the
year 2027), despite the backlog in the implementation of measures in the 2
nd
RBMPs and an explicitly
acknowledged lack of impact from the measures defined in the current programme. The expected
benefits come from the planned wastewater measures, the removal of about 750 barriers in the
watercourse system (and other measures to promote free-flowing water courses), and from the
ongoing effects from already completed measures. Jointly, it is expected that these measures will
improve the status of up to 5500 km of rivers falling short in terms of the total kilometres below
good status (and for some river stretches perhaps also as regards the extent of the improvements).
The authorities have stated explicitly that they will define the remainder of the measures in an
updated version of the 3
rd
RBMP foreseen for later this year, but it remains unclear whether this is
related to the measures aimed to reduce nitrates emissions from agricultural activities (mostly via
run-offs from the fields) or also hydromorphological pressures.
As regards measures involving nature-based solutions (NBS), there are prominent NBS measures,
including wetland restoration, and the establishment of wetlands and ponds aimed at capturing
phosphorous and nitrogen. However, the RBMPs do neither present a systematic overview of their
potential and actual implementation, nor do they mention any national or regional strategy.
This mapping from the Environment Agency has identified the specific nitrate-sensitive and pesticide-sensitive abstraction
areas. Municipalities also have the authority to develop additional action plans beyond designated areas and, if necessary,
enforce the action plans’ measures.
12
The 2
nd
RBMP figures are from Table 15.1 in
SWD(2019) 38,
and the 3
rd
RBMP figure is mentioned in Annex 15 of the
national 3
rd
RBMP document.
11
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As regards HMWBs and AWBs, the 3rd RBMPs do not contain much information describing or
assessing whether the hydromorphological modifications could be changed or mitigated. This is a
cause of concern since a large number of such modified water bodies are not reaching good
ecological potential. There is only some information for the four coastal water bodies designated as
HMWB, namely the requirement to operate the installed locks so that it supports the achievement of
good ecological potential.
3.6 What Denmark is doing for abstractions and water scarcity
As said in section 3.3 already, municipalities are responsible for abstraction permits. They regularly
review these permits to ensure that all water bodies can achieve their environmental objectives,
including an assessment of the abstraction activity’s impact on the water flows in rivers (streams).
However, the RBMPs do not appear to indicate the frequency of the review and they do not provide
specific information on ecological flows.
It is important to note that there seems to be no measures proposed to reduce pressures on the 9
ground water bodies which are in bad quantitative status due to over abstractions.
While the RBMPs mention a few measures on droughts and scarcity, they do not discuss a medium
to long planning. Notably, the RBMPs’ economic analysis does not explore either whether on the
longer term, bottlenecks in water supply side could occur to meet the demand for abstracted water
by the different user sectors. The key programme measure concerns water retention through nature-
based solutions for river restoration (promote the free-flowing of water courses and planting trees
along riverbanks). However, it is of note that the water abstraction tax is only paid by households
and industry, but not by agriculture, and that the tax rate is not informed at all by an estimate of the
resource costs of water scarcity.
3.7 Adaptation to climate change
The Danish RBMPs include a general presentation of expected types of impact from climate change
on Danish lakes, rivers and coastal water bodies and the extent to which the impacts of climate
change will be mitigated by the proposed measures, but without providing detailed information. There
are nevertheless background documents that include more detailed climate proofing of the RBMPs.
Specific climate change adaptation measures have not been reported as such in the Programmes of
Measures, however a range of measures are explicitly highlighted as having co-benefits for climate
change adaptation. This includes measures such as river flow restoration efforts that aim to alleviate
the adverse impacts of heavy precipitation in terms of floods risk, or floodplain restoration and
meandering, that are anticipated to positively affect nitrogen retention and reduce nitrous oxide
emissions, while also supporting natural water retention. Furthermore, securing coastal areas
throughout Denmark against floods is an ongoing theme of the RBMPs.
As regards risk of droughts, it should not be noted while the issue was not considered relevant for
Denmark in the 2
nd
RBMPs, in the 3
rd
RBMPs, the potential risk of drought as a climate change impact
is explicitly mentioned even if in generic terms only, without specifically highlighting drought as major
climate change challenge and without presenting specific measures to tackle them. Yet, Denmark
faces the emergence of seasonal droughts spells and corresponding seasonal water scarcity. At first
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sight, climate change does not seem to pose a water availability challenge in Denmark, since climate
scenarios point to a likely increase of the annual precipitation volume. However, it is necessary to
consider the variation in water availability as well as vividly illustrated by the drought spells in 2022
and Spring 2023
13
, with the ensuing water scarcity impacting agricultural production and public water
supply in some regions.
Despite this recent experience, as well as mounting evidence on the increased risk of drought across
Europe
14
, there is no mention of any plan drought management plan in development and the PoMs
of the 3
rd
RBMPs do not include specific measures against droughts, but only provide a cross-
reference to the fact that some of the restoration measures (as mentioned above) also contributes
to climate adaptation. In addition, the underlying economic analysis does not explore whether on the
longer terms there may be bottlenecks in water supply to meet the demand for abstracted water by
the different user sectors (see section 5.2).
As regards floods, fluvial and sea water floods are considered as potentially significant sources of
flooding in Denmark and are expected to become more frequent and severe in the future. The Floods
Directive requires to consider the impacts of climate change on the occurrence of floods, and
therefore in the preparation of Flood Hazard and Risk Maps (FHRMs) and Flood Risk Management
Plans (FRMPs). More information on these can be found in Section B. However, considering the close
relationship between overall water management and floods management and the importance of
climate change effects on both, climate change effects are jointly addressed in this section.
The impacts of climate change on flood risk have been considered in Denmark at the time of the
second preliminary flood risk assessment. The spatial extent of all APSFRs is assessed based on an
extreme event (historic extreme event or 1 000 years statistical event, whichever was more extreme)
plus a climate factor. The climate factor used was determined in a previous study specifically for
Denmark and is for fluvial flooding and storm floods based on the scenario RCP8.5 of IPCC’s 5
th
assessment report.
In the first FHRMs future scenarios were related to the years 2050 and 2100, in the current FHRM
cycle the same time intervals were used, but updated, resulting in future scenarios for 2065 and
2115. Both in the first and second FHRMs the results were used to inform the maps. RCP8.5 emission
scenarios are used in the current modelling to consider climate change, in the first FHRMs it was
unclear which IPCC information/data was used.
Denmark’s two UoM-level FRMPs, as well as the three municipal FRMPs assessed, indicate that the
likely impact of climate change on flood extent and frequency is considered (some plans note that it
is addressed in the FHRMs used to develop the FRMPs). In the second FRMPs, while they refer to
coordination with local adaptation plans, no progress was found concerning coordination between
the FRMPs and the national climate change adaptation strategy, nor how this strategy impacted the
selection of flood risk management objectives and measures. On the other hand, some municipal
FRMPs include measures to address floods in the context of climate change or indicate an intention
to integrate flood and climate change plans more closely in the future.
13
14
These droughts are not a fully new phenomenon given the droughts in 2008 and 2018.
European Drought Risk Atlas, EEA European Climate Risk Assessment
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4. Policy elements contributing to zero pollution
4.1 Surface Water: what is their chemical status
Monitoring
The Danish authorities report that out of the 7812 surface water bodies, there are monitoring data
for 6769 water bodies (87%). The monitoring coverage varies a bit over the various surface water
body types. Almost all coastal water bodies are monitored (99%), more or less in line with the
percentage of coastal waters with a known status. However, the RBMP does not provide a clear
explanation why the high monitoring rates for rivers and lakes (respectively 88% and 79%) do not
result in more status classifications.
Status assessment
The problems to assess and classify chemical status are widespread within and over the various
inland surface water categories: 97.4% of rivers and 70.3% of lakes are reported to be in unknown
status
15
(corresponding to 6532 rivers and 693 lakes). In contrast, this is so for only two coastal
waters (1.8%)
16
. Overall, 92.7% of surface water bodies (excluding territorial waters) do not have a
status. In addition, the traditional RBMP reporting does not discuss the confidence of the chemical
status assessments.
Strangely, the reported high coverage of monitoring starkly contrasts with the widespread lack of
status classification. Two large barriers impede a good view on the chemical state of Denmark’s
surface waters, namely the large share of surface waters without a status classification, despite the
reported increased geographical coverage of the monitoring, and the exclusion of about half of the
priority substances in the chemical status definition or its determination.
With these large gaps, it is far from assured that the RBMP figures on the share of water bodies in
good status are representative, and hence, it cannot be excluded that the actual situation is different
and perhaps less favourable than reported.
The prevalence of surface water bodies in unknown status has been a persistent problem, where only
limited and uneven progress has been made. The 2
nd
RBMPs reported
17
that for 99.7% of rivers,
95.7% of lakes and 41.1% of coastal waters, the status was unknown; for all surface waters, it was
98.5%. Hence, only for coastal waters has this problem be largely solved, with little progress for lakes
and hardly any at all for rivers.
Following difficulties to extract the relevant information from the 3
rd
RBMP PDFs, the Danish authorities kindly provided
for each of the different surface water types, the percentages of water bodies in unknown status as well as those in good
status and less than good status, the latter two both in terms of all surface water bodies of the type in question and of
those with known status. The corresponding percentages were not provided for the total of all surface water bodies
(apparently without terrestrial waters).
The corresponding number of water bodies have been calculated at the hand of the figures from Table 1 above and the
provided percentages. These numbers have a margin of error because the percentages were reported in round numbers
and because of an apparent inconsistency in the percentages reported for lakes (a discrepancy of 10 lakes).
16
This figure is based on the EEA dashboard. Table 6.9 of the national RBMP mentions 3 coastal water bodies in good
status.
17
SWD(2019) 38,
Table 4.1
15
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Of note, the Commission has expressed for some time concerns about the significant gaps in the
monitoring systems for surface waters in Denmark, and, relatedly, about the very large number of
unknowns in the status of many surface water bodies. In exchanges with the Danish authorities, it
transpired that they have recognised that several of these monitoring and related knowledge gaps
needed to be addressed. The 3rd RBMPs reflect these efforts, but it appears that many monitoring
deficiencies and number of unknown status aspects remain, seriously hindering the possibility for
Danish surface waters to achieve compliance with the WFD objectives.
However, even with the current limited knowledge on status, the reported figures on chemical status
are reason for concern (see Figure 7 below). 7% is reported to be in good status and 5.6 % in less
than good status (corresponding to 136 and 435 surface water bodies). For rivers (water courses),
lakes and coastal waters, these percentages are respectively 0.6, 9.3 and 5.5%, for good status
(corresponding to 38 rivers, 92 lakes and 6 coastal water bodies); and 2.0, 20.4 and 92.7% for less
than good status (corresponding to 133 rivers, 201 lakes and 101 coastal water bodies).
18
Figure 7: Chemical status of surface water bodies
As regards (observed) good status, there has been very modest progress since the 2nd programming
cycle for inland surface waters and a marked deterioration for coastal waters The 2
nd
RBMPs
reported
19
a mere 0.1% of rivers (7 in total) and 0.4% of lakes (3 in total) in good status, while about
half of the coastal waters (48.7% amounting to 58 coastal waters) was in good status, whereas for
most of other ones (41%) the status was unknown. The observed deterioration in the Danish coastal
waters’ chemical status matches the overall decline in their ecological status (as reported in section
3.1 above), although there is no information whether this is due to common underlying drivers.
In terms of water bodies with known status, 22 % of rivers is in good status (rather than less than good status), and
31% of lakes, and 7% of coastal waters. For all surface water bodies, it is 23.8%.
19
See footnote 17.
18
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The Danish authorities classify the chemical status of surface waters at the hand of an assessment
that overall includes only 25 priority substances out of the 45 required by the EQSD.
20
The national
RBMP document does not provide the reasons for this assessment gap. Without the necessary
information on the presence and concentrations of the substances ignored, it is not possible to
ascertain as to whether their inclusion would have led to a worse percentage of water bodies failing
to achieve good chemical status.
While the traditional RBMP reporting does not inform how often specific priority substances cause
surface water bodies to fail good status, these data are publicly available.
In decreasing order of occurrence, these chemicals with observed exceedances concern: mercury (280
water bodies), anthracene (205), lead (88), cadmium (64), nonylphenols (36), BDE (23), PFOS (19),
naphthalene (16), octylphenol (1). Two of these substances (mercury and PFOS) are part of the set
of substances considered uPBT.
Above all, mercury pollution ranks first. For about one in three water bodies failing good status,
mercury is (one of) the reason(s)
21
.
A comparison with the most common pollutants in the 2
nd
RBMP and their occurrence, gives reason
for concern. For mercury, in terms of the percentage of all surface water bodies (2.9%), it concerns
a huge four-fold increase since the 2
nd
RBMP, equally worrisome be it an effect of better monitoring
or an increase in pollution.
The 3
rd
RBMP also reports for other priority substances a higher prevalence of causing status failure
than before. The second ranking priority substance, anthracene, is just behind mercury in prevalence
(2.6%), while in the 2
nd
RBMP, it was reported for just one water body. Lead and cadmium lead to
status failure for about 1% of all surface water bodies, and nonylphenol for about 0.5% (with 88, 64
and 32 water bodies respectively ranking 3
rd,
, 4
th
and 6
th
); for all three, this implies a strong increase
in the percentage share of water bodies affected. Just as nonylphenol, the priority substances PFOS
and naphthalene are found to cause status failure for the first time (in 19 and 16 water bodies, which
is about 0.2%). PBDE is found as a cause for status failure for 23 water bodies (about 0.3%). Nickel
and benzopyrene are no longer reported as leading to water bodies failing to attain good status,
whereas nickel was found in eight water bodies in the 2
nd
RBMP.
This increases might be partly due to a more accurate monitoring but regrettably are not reflected in
the status assessment which are largely unknown.
In subsequent communication, the Danish authorities have confirmed they include in the chemical status assessment:
(1) Anthracene, (2) atrazine, (3) benz(a)pyrene, (4) cadmium, (5) chloroform, (6) chlorpyrifos, (7) Di(2-ethylhexyl)phthalate
(DEHP), (8) dioxins and furans, (9) diuron, (10) fluoranthene, (11) HBCDD, (12) hexachlorbenzene, (13) isproturon, (14)
lead, (14) mercury, (16) naphthalene, (17) nickel, (18) nonylphenol, (19) octylphenol, (20) PBDE, (21) perfluorooctane
sulphonic acid (PFOS), (22) simazine, and (23) terbutryn, while assessing (24) DDT and (25) cypermethrin (25) at the hand
of alternative matrices.
21
Mercury would lead to this failure with or without other priority substances crossing the threshold (“one-out-all-out
principle”)
20
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4.2 Groundwater Bodies: what is their chemical status
Monitoring
The regulation of the chemical state of Denmark’s groundwater appears to have improved overall,
both as regards the degree of monitoring and the extent of groundwater bodies in good status.
However, a solid comparison with the situation in the 2
nd
RBMPs is marred by the five-fold increase
in the number of groundwater bodies (see section 2.2) as well as by late or unclear and incomplete
reporting on key aspects in the set of the 3
rd
RBMPs.
The overall assessment of chemical status is based on a more solid and larger data set than before,
incorporating data from pesticide monitoring and water utility controls, and thus including more
substances and tests. The assessment includes nitrates, chloride, trace elements (aluminium, arsenic,
cadmium, lead, mercury, nickel, and, for the first time, also chromium, copper and zinc), pesticides,
environmentally hazardous pollutants (the substance groups BTEXN, chlorinated solvents, cyanides,
PFAS, phenols, MTBE, and water-soluble solvents)
22
as well as the drinking water test. The latter is a
verification whether in a groundwater body, pollution requires increased treatment of the water
abstracted for drinking water or even that abstraction points for drinking water had to be taken out
of service.
The RBMP PDFs do not provide the RBMPs much further detail on the chemical assessments which
hinders to obtain a clear picture on drivers and trends. Importantly, just as for the other status
dimensions, the traditional RBMP reporting does not discuss the confidence of the status assessments
It does not say much either about monitoring, grouping methodology, trend and trend reversal
analysis, despite an explicit Commission recommendation on this point in the 2
nd
RBMPs
23
. E-reporting
of figures on these elements (submitted well after the 3
rd
RBMPs’ publication) cannot replace such a
discussion.
State Assessment
The 3
rd
RBMPs suggest the chemical state of Danish groundwaters has overall improved, but a solid
comparison with the situation in the 2
nd
RBMP is marred by the five-fold increase in the number of
groundwater bodies (due to the overhaul of groundwater body delineation) as well as by late or
unclear and incomplete reporting on key aspects.
As depicted in Figure 8, the national RBMP document reports 1820 out of the 2050 groundwater
bodies (88.8%) are reported to be in good chemical status in 2021, whereas 192 (9.4%) are below
good status and for 38 (1.9%) the chemical status is unknown. As mentioned in the 2
nd
RBMPs
24
, 44.3
% (178 out of 402) of groundwater bodies (as delineated then) were in good status in 2015, 25.1%
were failing and 30.6% in unknown status. Even while the overhaul in groundwater body delineation
This list of substances fully covers the ‘minimum list of pollutants’ from the Groundwater Directive 2006/118/EC, Annex
2, part B, apart from ‘saline intrusion’ which has been discussed in section 3.4 above in the context of protected drinking
water areas.
23
SWD(2019) 38,
pp 19-20
24
SWD(2019) 38
– p 93
22
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stands of a direct comparison of these percentages, these changes indicate an overall improvement,
both as regards the degree of monitoring and the quality of groundwater.
25
Figure 8: Chemical status of groundwater bodies
Pesticides are the group of substances most responsible for the failure to attain good status: almost
two thirds of groundwater bodies in less than good status have too high pesticide concentrations
26
.
It is worth noting that a majority of them concern already banned and phased-out pesticides,
demonstrating the long-time lag between emission and pollution concentrations.
In contrast, the corresponding percentages for nitrates, the group of trace elements and all
environmentally hazardous pollutants combined are only around ten percent. This highlights that the
drinking water test has a significant upward effect on the percentage of groundwater bodies in less
than good status: pushing it up from 7.5 to 9.4%. This underlines the importance attached to
protecting groundwater bodies which are in Denmark the nearly exclusive source of drinking water.
Regrettably, the 3
rd
RBMPs do not inform about the expected date for achieving good chemical status
for all ground water bodies, but the later submitted e-reporting indicates that 86 groundwater bodies
(4.2% of the total) are at risk of failing good chemical status by 2027. Neither do the RBMPs provide
much detail on the chemical assessments which hinders to obtain a clear picture on drivers and
This proportion as well as the one in the next paragraph are derived from Table 1.4 in the national 3
rd
RBMP for Denmark.
To note, to a large extent, this pesticide pollution concerns a legacy issue: the national RBMP notes that the majority of
pesticides found in groundwater bodies, have been banned and phased out already.
26
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trends. They do not say much either about monitoring, grouping methodology, trend and trend
reversal analysis, despite an explicit Commission recommendation on this point in the 2
nd
RBMPs
27
.
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4.3 What Denmark is doing to combat pollution from agriculture
Agriculture is by far the largest contributor to the discharge of nitrates and phosphorus into surface
waters (coastal waters and lakes respectively) and the key source of pesticides pollution.
Measures on nitrates emissions (mainly, but not exclusively from agriculture) have so far not been
sufficient to achieve the reductions necessary to achieve good ecological status. Up to now, Denmark
has enjoyed extensions on its derogation under the Nitrates Directive, which have allowed to spread
abatement measures over time. At the time of the submission of the 3
rd
RBMPs, Denmark had opted
to prolong this derogation which would otherwise expire at the end of July 2024. However, in Spring
2024, well after the submission of the RBMPs, Denmark has decided to relinquish this derogation.
Yet, it has become clear that further substantial reductions are required to stop the built-up
accumulation of nitrates in coastal waters and then have natural forces reduce it over time. Now that
the possibilities for incremental measures appear to have largely been exhausted, more ambitious
measures are needed. The recognition that
inter alia
the required sustained nitrates reduction efforts
in this sector can only be successfully pursued with wide political support, has led to a “broad political
agreement on the green transition of Danish agriculture,” concluded between all major Danish
political parties in October 2021.
28
The 3
rd
RBMPs have taken this 2021 agreement into account, and
the upcoming revised 3
rd
RBMPs are expected to take on board the measures reflecting the so-called
“tripartite” agreement “on a Green Denmark,” concluded in June 2024 between agricultural
associations, nature protection NGOs and municipalities
29
. Reportedly, the agreement includes a focus
on nutrient emission reduction through a conversion of farmland into nature area.
It is welcomed that the RBMPs indicate the ‘distance to target’ for nitrogen reduction, the estimated
or envisaged effects of the various types of measures, indicating, importantly, two remaining gaps,
namely one between the foreseen and required reductions and one indicating the size of the
reductions attributed to hitherto unspecified measures. Figure 9 presents this information in a stack
diagram.
The diagram first shows the shortfall of the 2021 political agreement on nitrate reduction and thus
also the RBMP’s program of measures: by 2027 an annual reduction in nitrogen (mostly nitrates) of
about 13 thousand tonne is required to meet the objective of good ecological status in Danish coastal
water, but the political agreement concerns a commitment to reduce 10.8 thousand tonne only
30
. It
should be noted that these reduction figures are inherently uncertain also because they are
contingent on nitrates reduction assumed to be realized already within the baseline, reflecting
estimations on respectively autonomous trends in agricultural production as well as the impact of
pre-existing policy measures.
See Denmark’s “National
Reform Program 2022”
(Danish Ministry of Finance, April 2022) and the “Second
opinion
on the
need for reduction of nitrogen in the third RBMP for 2021- 2027, Phase I” (COWI for Danish Ministry for the Environment).
The former source focuses much more on the agreement’s carbon reduction dimension in view of the envisaged financial
support from the EU Recovery and Resilience Facility, requiring regular reporting.
29
“Agreement
on a Green Denmark”
(in Danish), June 2024.
30
Two remarks are in order. First, this apparent lack of effort may not qualify as lack of technical feasibility, as ground for
an exemption under WFD article 4(4), which the RBMP only calls on for a minority of coastal water bodies expected to fail
good ecological status in the year 2027; see further section 2.1.8. Second, a modest 0.4 out of the 10.8 Ktonne concerns
the reductions achieved by the measures but occurring outside of catchment areas and thus with an ecological effect on
Danish waters.
28
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Apart from a small reduction related to wastewater plants, these reductions are supposed to take
place in the agriculture sector. The Danish CAP Strategic Plan for 2023-2027 has set out much of
the foreseen measures in the 3
rd
programming period. They allocate 20% of direct payments to
voluntary measures by farmers beneficial for the climate, environment and animal welfare. 19% of
the rural development funds is reserved for farmers taking multi-annual management commitments
benefitting nature and biodiversity, e.g. to double the area for organic farming by 2030 (13% of UAA
in 2022)
31
and by afforestation.
32
However, the diagram reports a further second gap that also need to be addressed with further
measures in the upcoming revised 3
rd
RBMPs. While the policy has set fixed reduction tasks of 6.5
and 1.5 thousand tonne, respectively from
33
“targeted regulation” and “collective measures,” the
additional 2.8 tonne reduction needs to come from “new implementation measures,” that have not
yet been defined. The 2021 political agreement foresees decisions on these measures in the course
of the year 2024, based on a “second opinion” by experts that has now arrived
34
.
Danish authorities have already indicated to come with revised 3
rd
RBMPs that hopefully address
these two gaps in a satisfactory manner.
Figure 9: The stack of nitrate reductions of various measure types vis-à-vis the 2027 reduction objective
File:Organic-area-2022.jpg - Statistics Explained (europa.eu)
At a glance: Denmark’s CAP Strategic Plan (europa.eu)
33
The “targeted regulation” includes measures on cover crops, energy crops, fallow areas, precision agriculture and catch
crops. The “collective measures” concern “voluntary” measures on wetland restoration, set-aside of low lying soils, et cetera,
with a so-called “environmental guarantee” that in case the resulting impact are below expectation, mandatory buy-outs
with financial compensation will be pursued in order to meet.
34
See footnote 28
31
32
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Source: mimeo Danish government
In relation to phosphorus pollution from diffuse agricultural sources, the RBMPs include the
establishment of wetlands capturing phosphorus, the location of which is informed by risk-maps
developed in the previous programming period.
In line with the pesticide strategy 2022-2026, a range of specific measures aims to reduce pesticide
emissions into water, such as a pesticide-fee,
35
a pesticide authorisation scheme related to inter alia
a broad screening for pesticides in the groundwater, and the assignment of water protection areas
around all drinking water supply stations.
4.4 What Denmark is doing to combat pollution from other sectors
In general, the RBMPs do not provide detailed assessments on the gaps in implementation of
measures for the pollution coming from other sources than agriculture. In addition, the corresponding
policy responses tend to be presented through mere references to basic measures.
However, the reduction of nutrient point source pollution with nutrients has been included in an overall
gap assessment of the required nitrogen (and phosphorous) load reductions. There is no reference to
the deposition into water of NOx and ammonia emissions into the air, apart from a mention of
measures to reduce emissions from ships.
As regards the discharge of wastewater from treatment plants, measures to reduce the pollution
from these sources build on the efforts in previous programming cycles. Denmark has a nation-wide
authorisation and permitting regime in place to control wastewater point source discharges. There
are no thresholds in Denmark below which wastewater discharges do not require registration and
permits, while direct discharges to groundwater are prohibited in all RBDs.
For pond farming and aquaculture, the number of facilities and general pollutants are indicated per
water district, however, without indicating the quantity of pollution associated with them. As measure,
the RBMPs mention a buy-out scheme (to be bought and closed down) for aquaculture firms in inland
waters.
While an Annex to the RBMPs lists the measures per priority substances or substance (groups), they
are not linked to KTMs, as requested in a Commission recommendation on the 2
nd
RMBP. In addition,
the main drivers of chemical pollution as well as mitigating measures are explained, but often without
sufficiently concrete indications on the expected effectiveness of the measures, rendering it
impossible to assess the expected reduction of the chemical pollution concentration. To some extent,
this seems a reporting issue as much of this information may be retrieved from the e-reporting
(which became available well after the RBMP transmission). The same seems to be the case for the
information gaps on the type and quantity of pollutants of industrial discharges at local level, and
how they are measured and monitored.
In order to incentivise a change to less harmful pesticides, the fee is differentiated at the hand of the active ingredients’
toxic potential to harm human health and nature.
35
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The RBMPs stresses continuation with the measures in the previous programming period, which has
comprised efforts to extend monitoring, a review in 2020 of the existing permits and licenses for
priority substances
36
where their pollution concentrations exceed the thresholds in water bodies, as
well as a wide array of actions under national and EU chemical and sectoral legislation.
37
The description of the new measures appears to focus on the first half of the programming period:
setting new and revising existing Environmental Quality Standards (EQS) and addressing the large
data knowledge gaps concerning the provenance of the pollution and the chemical status of
waterbodies. Reportedly by 2024, this should lead to a comprehensive inventory of pollution sources,
and, where EQS exceedances are found, to revision of permits, as long as provided for by standing
legislation. The overall ambition level and concrete abatement actions in the second half of the
programming period appear to have been left open, as the RBMP refers to a “partnership for
substances dangerous for the environment” between authorities and stakeholders to contribute to
the development of “an instrument catalogue.”
4.5 What Denmark is doing to combat significant pressures – overall
assessment of the Programmes of Measures
As Denmark’s RBMPs are structured by types of water bodies (coastal, rivers, lakes and groundwater),
rather than according to KTMs, they do not provide a clear comprehensive overview of the
prioritisation of measures, including their timing, and of the mandatory gap analysis, including gap
indicators. The later e-reporting of the relevant descriptive data and figures (submitted well after the
RBMP publication) cannot replace such a discussion in the RBMP.
However, the RBMPs seems to provide a clear account of the intervention logic for key challenges,
also indicating where measures will not fully close the gap:
•
Nitrogen load in coastal waters:
the RBMPs describe the measures to reduce the nitrogen
loads that have led to widespread eutrophication and oxygen depletion in coastal waters.
There is an assessment of the annual loads, an estimation of the maximum load compatible
with good ecological status and of the resulting need for reduction of the loads. The RBMPs
describe a baseline assuming that 75 % of the estimated load reductions planned in the 2nd
RBMP period are expected to be implemented. The planned measures on top of the baseline
cover around 80% of the estimated of nitrogen reduction need. The RBMP refers to the
political commitment to define the additional measures to meet the 2027 nitrogen reduction
target (while good status in coastal waters remains out of reach at that time horizon). See
further section 2.1.11 above.
Wastewater discharge to rivers and lakes:
the RBMPs describe the measures implemented to
improve the wastewater treatment and reduce polluting discharges into water courses and
lakes, and explicitly consider their effect on top of the measures from the 2nd RBMPs that
•
According to section 1.2.2 of the national RBMP document, the environmental authorities have carried out this review
between April and September 2020 with the aim of pursuing any necessary revisions. The scope and outcome of this
exercise are not specified.
37
Annex 5 to the national RBMP document provides a list of actions which unfortunately lacks specific indications as to
whether they concern 2
nd
or 3
rd
RBMP measures, and neither of their date of implementation, stringency, individual and
overall impact.
Section 7.1.1 outlines the new measures.
36
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have not yet been fully implemented. The nitrogen and phosphorous reductions are
considered in the light of the required overall reductions.
•
Water course restoration measures:
the 3rd RBMPs identifies the need to address the
situation in 5,500 km of rivers as contribution to the goal / expectation that all rivers will
attain good ecological status by 2027. However, they present measures to address the
situation in 3,850 km of rivers. The Danish authorities indicate that the remaining gap will
be handled by a planned update of the RBMP in 2024, although they may also reassess the
size of the gap.
Environmentally hazardous chemicals:
While there appear data on discharges, the RBMP does
not appear to base the measures on a specific gap assessment in relation to priority
substances, river-basin-specific pollutants and pesticides, based on reaching good chemical
status by 2027. The widespread lack of chemical status classification appears to constitute
a major barrier for such an assessment. Annex 5 to the national RBMP PDF lists the measures
from the previous and current programming period (mostly the first half), and the RBMPs
propose to further extend the knowledge and monitoring on the pollution sources. This
suggests possibly significant gaps in ambition and implementation vis-à-vis the pressures
and impacts, in particular in lakes and coastal waters.
Groundwater:
Recognising that groundwater pollution poses a long-term challenge (due to
slow natural regeneration), the RBMP refers mostly to existing strategies and regulations as
providing the basis for ultimately achieving good status for groundwater bodies, including
the 2022-2026 Pesticide Strategy as well as basic and supplementary agricultural measures
•
•
The RBMPs also list a number of pressures without accompanying information about any specific
measures to address them. Examples include harbours and associated dredging, and the dumping of
dredging material.
5. Exemptions and economics
5.1 To what extent are exemptions applied in Denmark
Denmark makes a very considerable use of exemptions. The 3
rd
RBMPs report that only 1816 water
bodies out of the total of 9848 (excluding territorial waters) have already attained good status in
2021 (amounting to almost one fifth)
38
. Most of them are groundwater bodies (1801), nearly 90% of
the total number of groundwaters
39
. In view of the WFD’s general obligation of “no deterioration,”
these water bodies do no longer need an exemption, as long as there are no temporary deteriorations
due to natural causes or
force majeure,
or due to structural changes affecting the water body. The
3
rd
RBMPs imply that this is indeed so, because they do not report any corresponding exemptions,
respectively on basis of WFD article 4(6) and 4(7). For the other water bodies, the 3
rd
RBMPs present
8745 targets and deadlines.
National RBMP PDF, Table 6.1.
It has not been possible to verify in the EEA dashboards the provided figures on water bodies without an exemption as
well as those with an exemption or rather the number of exemptions.
The cited figure implies that there are very few surface water bodies for which both good ecological and good chemical
status has been ascertained. A major reason for this is the high percentage of water bodies with unknown chemical status.
38
39
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The RBMPs report that almost all river water bodies have an exemption of the time extension type
(WDF article 4(4)) on the grounds that it is technically only feasible to reach good status (or potential
where applicable in this paragraph or the next ones) by the year 2027, the end of the 3
rd
programming
cycle, and not earlier. As there are 6700 of such exemptions reported for a total of 6703 rivers, one
may infer that many river water bodies have such an exemption (even taking account of multiple
chemical exemption per individual river water body). In the light of the very large share of rivers with
unknown chemical status in 2021, it is not entirely clear on what data and assessment the
expectation is based that good status will be reached by 2027.
As regards lakes, there are 950 article 4(4) exemptions reported
40
, with less than half (423) on the
grounds of technical infeasibility and / or disproportionate costs, with the status condition expected
to become good by the year 2027. The remainder (527) gets such an exemption on the grounds of
natural conditions, as the measures in place are expected to deliver good status only after 2027. The
main pressure comes from the emissions of nutrients (nitrogen and phosphorous) and in some cases
pesticides and hazardous substances from agricultural run-offs, as well as point source pollution of
residential and industrial wastewater discharges and overflows.
Similar to rivers, article 4(4) exemptions are applied for nearly all coastal waters
41
, as only 3 out of
the 109 coastal water bodies have been found in good status in 2021. In line with the widespread
nutrient and oxygen depletion problems as discussed in section 3.1 above, the RBMPs invoke a total
of 120 article 4(4) exemptions, 12 of which on the ground of technical feasibility and disproportionate
costs (which is expected to be no longer necessary by the year 2027), and the remaining 108 on the
grounds of natural conditions (as good status can be attained only well after 2027). Remarkably, only
14 deadline extensions are reported for chemical status, while 101 coastal water bodies are reported
to be in poor status.
Article 4(4) exemptions are called upon for 223 groundwater bodies
42
out of a total of 2050 (thus
for about 10%). For all but one, this is justified for reason of natural conditions. This is understandable
in view of the long-time lags between nutrient and pesticides emission at the source and their filtering
into groundwater bodies, which for the deeper ones can amount to multiple decades, implying an
impact of emissions dating back from even before the entry into force of the European Nitrates and
Pesticides Directives
43
.
Article 4(5) exemptions, i.e. lowering the environmental ambitions for the time being, have been
applied in a much lower degree. It concerns 31 lakes (amounting to only 0.4 % of the total number
of surface water bodies) which have been constructed as the most cost-effective solution to capture
excess nutrients,
44
as well as, at most
45
, 26 groundwater bodies (1.3 % of their total number) where
either contaminated land renders it technically impossible to remove the pollution inflow into
groundwater by 2027 or where natural recharge needs more time to reduce too high concentrations
of trace element caused by over-abstraction.
The Danish authorities have provided the disaggregation of the figure reported in Table 6.7 of the national RBMP PDF.
All figures are from Table 6.9 of the national RBMP PDF.
42
All figures are from Table 6.11 of the national RBMP PDF.
43
Directive 91/676/EEC and Directive 2009/128/EC
44
National RBMP PDF, section 5.3. It is not clear how this related to the definition of “ecological potential” for these water
bodies, which is already lower than ecological status.
45
‘At most’ because there can be more than one exemption concerning chemical status.
40
41
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Apart from the specifications in the previous paragraphs, the RBMPs do not provide a split between
exemptions regarding chemical status (for either groundwater or surface water), ecological status or
quantitative status.
It is a source of strong concern that the RBMPs do not provide a specific justification for the invoked
exemption grounds for individual water bodies. The Danish authorities have pointed out that this
information can be made available by the Danish Environmental Protection Agency, but the reporting
issue remains as the RBMPs do not provide a clear, accessible reference to it as required by the law.
In line with ECJ jurisprudence on the restrictive interpretation of exemptions, the RBMPs should not
give the impression that across-the-board exemptions have been applied for water body categories
in their (near) entirety (in this case rivers and coastal waters).
The national RBMP PDF appears to suggest
46
that further minor modifications of “individual lake or
wetlands rivers, including adjacent rivers” may cause a temporary deterioration requiring an
exemption according to WFD article 4(7). However, it does not provide specific details on the number
of these exemptions and their reasons but provides a general reference to the Environmental
Protection Agency. Hence, it remains unclear how much these exemptions have been applied,
including whether article 4(7) exemptions still apply for ongoing large infrastructure projects.
5.2 Use of economic analysis and water pricing – cost recovery
The economic analysis is provided in a background document to the RBMP(s). It provides a detailed
description of the financial costs of the broad water services (drinking) water supply and sanitation
service and the cost recovery arrangements. Whether publicly owned or privately owned, each water
utility or company is required to set its charges so as to fully recover its costs at municipal level. This
implies that the water service charges vary both within and across RBDs, and that the Danish
authorities do not lower cost recovery for economic and social reasons. These cost recovery
arrangements imply that the RBMPs need not report on the factors mitigating the cost recovery
efforts and can relegate details on costs to a background document.
The (updated) economic analysis seems to have two weaker aspects: the long-term outlook of the
analysis, specifically on water consumption, and the cost-effectiveness assessment.
There is a rough long term forecast on the demand for drinking water until 2035, basically noting
that population growth would increase demand counteracting the ongoing trend of decreasing water
consumption per capita, but without a clear conclusion on the net outcome. In addition, there is no
long-term scenario on total water consumption in the absence of forecasts on water abstraction by
industry and agriculture. It appears that the strong decentralisation in decisions on water services
provision would explain the absence in the RBMPs of fully developed water demand and supply long
term scenarios as well as a comprehensive forecast of investments. Hence, the emergence of future
potential bottlenecks does not seem to have been systematically explored. It also renders the RBMP’s
indication that water scarcity is not an issue for Denmark, a rather short-term notion, not sufficiently
explored for the longer term and the related emerging impacts of climate change in the water sector
and corresponding required investments.
46
National RBMP PDF, section 6.2 “Specific environmental objectives for rivers.”
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The second major flaw in the economic analysis concerns the unclear reporting on the outcomes of
the cost-effectiveness assessment. While the RBMPs declare cost-effectiveness as the guiding
principle for the selection of measures, they do not report on the conclusions of the cost-effectiveness
assessment of either individual measures or the overall set of measures. The background documents
referred to do not clearly identify which measures in the catalogue have been introduced for the first
time, which ones are selected and which ones concern (selected) investments.
The RBMPs do not provide a complete account of water pricing and whether they provide “adequate
incentive” to efficient water use, but the available information suggests that the pricing policy
provides some clear incentives. It concerns full cost recovery at municipal level resulting prices
varying with local cost conditions as well as the large variable element in all water charges. However,
there is no information as to whether prices vary by broad user sectors (households, industry,
agriculture), neither whether unit rates increase with individual water consumption volume, whether
there is a social tariff, and whether the “additional taxes” are included in or put on top of cost recovery.
There is no discussion on whether the (broad) water user sectors (households, industry and
agriculture) provide an adequate contribution to the (full) cost recovery. This is related to the lack of
information on possible sectorial variation in water charges. For example, it is not clear why
agriculture
47
is exempt from the water abstraction tax. A positive element, worth highlighting
however, is the “tax” on water utilities varying on the degree on leakages in water distribution network.
On a related point, the RBMPs reveal a mixed track record on the application of the polluter pays
principle. On the one hand, the reports suggest it is applied because the revenues from (gross) water
prices exceed the financial costs basically because of the water abstraction tax, the leakage tax and
the tax on organic matter and nutrients from treated wastewater. As the destination of these
revenues is not specified, it remains unclear however whether the polluters pay for the broader costs
of water services or rather for a part of the Program of Measures or both. On the other hand, the
green basis of these taxes is rather weak because they are explicitly not based on an estimate of the
environmental and resource costs. The RBMP justifies this some arguments, namely a presumed lack
of agreement on the estimation method; that the environmental costs are equal to the costs of the
abatement measures (leaving the remainder pollution out of the picture), and that there is no water
scarcity and hence no resource costs (not discussing seasonal water stress).
6. WFD recommendations
On the basis of the assessment performed, Denmark should:
1.
2.
Denmark is invited to come as soon as possible with the set of revised 3
rd
RBMPs as announced in the
submitted RBMPs, taking on board already, to the extent possible, the recommendations below.
Address the identified lack of compliance of achieving good status by increasing the level of ambition and
reducing the knowledge and compliance gap as much and as soon as possible until the next reporting
cycle.
47
The RBMPs point out that agriculture covers all the irrigation costs (fed by abstraction from groundwater)
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This means in particular, that:
Denmark is invited to adopt and submit as soon as possible the set of revised 3
rd
RBMPs as announced in
the current RBMPs, taking on board already, to the extent possible, the recommendations included in this
assessment.
Where the objectives of the Directive for a specific water body cannot be met and exemptions are invoked,
Denmark should do so in line with ECJ jurisprudence on the restrictive interpretation of exemptions and
better justify the use of exemptions, providing sufficiently detailed justifications at the level of the water
body and ensure that their application is regularly reviewed. Importantly, they should explain how an
exemption is justified in the case that the status of the water body is not known. This implies:
a) Providing clear, accessible references to the justification for the invoked exemption grounds (for both
time extensions and lowered objectives, according to respectively WFD article 4(4) and 4(5)) as well as
a clear split on the exemptions invoked for attaining, on the one hand, good ecological status (or
potential) or quantitative status, and, on the other hand, good chemical status.
b) Ensuring that the lowering of objectives (Article 4(5) is well documented and justified, in particular as
regards disproportionate cost and unfeasibility taking into account the shortcomings in the
implementation to date.
c)
Recognising that the possibilities for time extensions (Article 4 (4)) are extremely limited and will no
longer be allowed after 2027 (except if duly justified for natural conditions).
d) Much more information on the exemptions under Article 4(7) WFD for new projects, including new dams
and water transfers. This includes better justifications of the use of these exemptions by detailing
cumulative effects, the assessment of better environmental options, and the measures taken to
mitigate the adverse impacts of new developments.
3.
Continue strengthening the economic dimension of the RBMPs:
a) improve the content of or reporting on the economic analysis as regards its long-term outlook,
specifically on water consumption and investments, linking this outlook specifically and extensively
with their recent national Climate Adaptation Strategy;
b) Make more and more clearly use of the cost-effectiveness assessments in the selection and
prioritisation of measures, including investments;
c)
Present in the revised RBMP a long-term planning / forecast of the investments, clearly identifying the
timeline, as well as the funding; more generally, identify the source of financing for implementation of
all measures;
d) Strengthen the application of the ‘polluter-pays principle’ and eliminate environmental harmful
subsidies whilst ensuring affordable, just and fair pricing mechanisms for all water users in line with
Article 9 WFD;
4.
Identify and put in place supplementary and other additional measures to reduce existing persistent
environmental challenges (pressures) preventing the achievement of good status, and based on robust gap
analysis, as those pressures are aggravated by climate change (pollution concentrates in times of less
water availability).
This implies, inter alia:
a) Address the explicit shortfall of nitrate reduction measures in the current Program of Measures, based
on the measures currently under consideration as follow-up to Denmark’s decision to relinquish their
derogation under the Nitrates Directive as well as in the framework of the broad agreement on the
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green transition in Danish agriculture of October 2021 and the “tripartite agreement on a Green
Denmark” of June 2024;
b) Addressing key emerging water pollution issues, such as the observed marked increase of water bodies
failing good status because of exceeding pollution concentration for priority substances: mercury or
other metals, as well as anthracene, nonylphenol, PFOS and naphthalene. Measures should include
adequate permit conditions for industrial installations and addressing the pollution coming from the
sewage sludge, storm overflows and wastewater from unconnected houses;
c)
Addressing diffuse chemical pollution, e.g. including nutrient and pesticide pollution i including through
reducing their use and phasing out unsustainable practices;
d) Take immediate action for pollution problems discovered in water bodies which are currently in
unknown chemical status, and for priority substances that have not yet been included in the
assessment;
e) Expanding the efforts on the deployment of nature-based solutions including renaturalisation and
ecosystem restoration, including the upgrading and expansion of wetland areas as well as measures
that bridge the gap between the river restoration targets and the expected results of the current
measures.
5.
As regards
climate change
start developing a policy response to emerging seasonal droughts and water
scarcity, taking a long-term perspective, and with an explicit Drought Management Plan which includes the
identification of surface water bodies as candidate water abstraction source as well as adaptation
measures in all major water user sectors and further nature-based solutions.
Step up the efforts to meet the requirements set out in the WFD as regards monitoring, assessment, data
management and reporting. In particular, Denmark should:
a) identify the main causes of the widespread lack of chemical status classification for surface waters
and take the appropriate measures to address this lack as much as possible within the current
programming cycle;
b) include all priority substances in the assessment of chemical status (or explain why the substances left
out would not have a material impact on the quality of Danish surface waters);
c)
For the water bodies without a known status, explain the robustness of the reported expected date of
achieving good status, and also why the 31 lakes built for nutrient removal are not included in the
reported number of artificial and heavily modified water bodies.
6.
7.
In cooperation with the Commission and the EEA, ensure timely submission of the RBMPs in line with the
WFD requirements and fully covering all topics. To meet the reporting requirements in a more transparent
manner, the RBMPs should refer more clearly to background documents, to publicly available data, and to
the electronic reporting, coupled with explanations in the RBMPs on the regulatory aspects and
assessments. For future cycles, Denmark should ensure that they make the electronic reporting available
about the same time as the RBMPs and that they are fully consistent with the submitted RBMPs and
provide a more extensive coverage of the important technical details.
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SECTION B:
FLOODS DIRECTIVE
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7. Flood risk management under floods directive (FD)
The Directive requires each Member State (MS) to scan its territory for flood risks, assess the potential
adverse consequences of future floods for human health, the environment, cultural heritage and
economic activity, identify the significant risks, map the flood extent and the potential adverse
consequences, and take measures to reduce the flood risk. These activities are reflected in (a) the
preliminary flood risk assessments, or PFRAs (including the identification of areas of potential
significant flood risk, or APSFRs), (b) the preparation of flood hazard and risk maps, or FHRMs, and (c)
the establishment of flood risk management plans, or FRMPs. The preliminary assessments, mapping
and planning for flood risk are repeated in six-yearly cycles.
There are four Units of Management (UoMs) in Denmark, which are the same as the Water Framework
Directive’s River Basin Districts (RBD). Fluvial and sea water floods are considered as potentially
significant sources of flooding in Denmark. Denmark has designated in two of its UoMs (for which
UoM level FRMPs were prepared) 14 Areas of Potential Significant Flood Risk (APSFRs)
48
.
7.1 Flood hazard and risk maps
Denmark is using a national web-GIS viewer
49
for their FHRMs. FHRMs were prepared at the national
level and show the whole country. Maps for floods with low probability (1/100 years for fluvial and
1/1 000 years for coastal), with medium probability (1/50 years for fluvial and 1/100 years for
coastal) and with high probability (1/20 years) are provided. Flood extent is shown on all maps. Water
depth is shown on all maps. Number of inhabitants is shown on all maps. Likewise, type of economic
activity is shown on all maps. There are neither maps with IED installations available on the national
web-GIS portal nor is this mentioned in the methodology report. However, the information has been
reported to EIONET
50
. Potentially affected protected areas identified in Annex IV(1)(i), (iii) and (v) to
Directive 2000/60/EC are shown in the FHRMs.
In terms of changes of contextual information (i.e. the way in which information about the maps is
conveyed to the public) since the first FHRMs, the following improvements were made: 1) address
level information of critical infrastructure and potentially polluting installations are included instead
of only grid-based information as was the case before, 2) the descriptions and order of data layers
on the web-GIS portal is more concise, i.e. information is easier to find, and 3) additional APSFRs and
expanded APSFR areas were included.
In terms of changes in methodologies used to prepare flood hazard maps since the first FHRMs, the
main differences are: 1) for fluvial floods, since the first FHRMs, the scenario’s probabilities were
changed from 1 000 years (low probability) and 100 years (medium probability) to 100 years for low
probability and 50 years for (medium probability). No explanation for this change was found in the
assessed documents (the FD mentions a 100-year return period as the medium scenario), and 2)
data series used as input were updated to also include recent years since the first FHRMs were
The main observed changes are that additional APSFRs were identified and included and for two exiting APSFR the area
was expanded. This led to additional and expanded FHRMs in the GIS web-viewer. For all FHRMs the same approach was
used to generate the maps, so for all APSFRs, FHRMs of the same quality and detail exist.
49
https://kms.maps.arcgis.com/apps/webappviewer/index.html?id=63f098e64248465abbd7a3283e5e2707
(accessed:
2023.08.18)
50
Denmark clarified that IED and IPPC installations are shown in the web-GIS portal for each APSFR in a layer called
“polluting organisation" (DK:
Forurenende virksomheder).
48
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developed. Scenarios are adapted accordingly i.e., 2019 as base year, 2065 and 2115 for future
scenarios.
In terms of changes in methodologies used to prepare flood risk maps since the first FHRMs, the
methodologies and approaches used were largely the same and are based on an approach developed
by a research project in Germany. The approach was further refined i.e., by considering losses to
airports in the category infrastructure and losses for businesses. The total risk is displayed in the
second FHRMs as economic damage in Danish currency per grid-cell. The input data to calculate
damage costs per unit damaged or per grid cell was updated so that the damage costs are displayed
in 2019 values.
Climate change in the second FHRMs
As regards the consideration of climate change effects in the preparation of flood hazard and risk
maps, reference is made to section 3.7 on ‘adaptation to climate change’.
7.2 Flood risk management plans
Objectives and measures
The UoM-level FRMPs (which are summary documents of the municipal FRMPs) can be downloaded
from a webpage
51
of the Ministry of Environment’s web portal for the FD. The UoM-level FRMPs can
also be found on the front page of the web portal
52
.
Objectives are recommended at national level for inclusion in Denmark’s FRMPs, which are prepared
at municipal level. All three municipal FRMPs assessed incorporate these objectives and set detailed
sub-objectives.
Objectives recommended at national level call for the reduction of potential adverse consequences,
as do more detailed sub-objectives in all three municipal FRMPs assessed. Sub-objectives in all three
municipal FRMPs assessed include non-structural initiatives, such as strengthening emergency
responses for flood events. The general objective recommended at national level refers to the
reduction of adverse consequences of floods for human health, the environment, cultural heritage
and economic activities. Each of the three municipal FRMPs assessed includes objectives related to
the protection of citizens. In terms of the economy, the three municipal FRMPs address this topic
indirectly, for example by making businesses aware of their flood risk and their options to reduce it.
Reduction of adverse consequences for the environment is incorporated in the general objective
recommended at national level and is indirectly addressed by objectives in the FRMPs (e.g. the
Copenhagen FRMP has an objective to address wastewater treatment). While incorporated in the
https://oversvommelse.kyst.dk/planperioder/planperiode-2016-2021/plantrin-3
This website also contains national
templates and guidance to support municipalities in preparing their FRMPs, notably:
- Guide for the preparation of FRMPs
- MS Word template for preparing new FRMPs
- MS Word template for reassessing and updating FRMPs
- Action/measures planning table in Excel
- A risk management plan checklist
- FAQ on FRMPs
52
https://oversvommelse.kyst.dk/
51
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general objective recommended at national level, the protection of cultural heritage is not included
in the objectives of the municipal FRMPs assessed.
Denmark has reported measures to EIONET. Denmark’s reporting to EIONET includes prevention,
protection and preparedness measures, as do the three municipal FRMPs assessed. All three
municipal FRMPs assessed contain tables listing measures and priorities, and the UoM-level FRMPs
list the total number of measures across all municipal FRMPs (these totals do not match the numbers
that Denmark reported to EIONET).
Denmark indicates the priority of all measures reported to EIONET. In its reporting to EIONET,
Denmark’s measures are divided between all five possible categories of priority: critical priority (36
measures, 6 % of the total), very high priority (203 measures, 34 %), high priority (142 measures,
24 %), moderate priority (156 measures, 26 %), and low priority (55 measures, 9 %). All three
municipal FRMPs assessed contain tables listing their measures and the priority of each on a three-
point scale.
Denmark’s two UoM-level FRMPs report on the status of completion of measures in the first FRMPs.
The second FRMPs state that the municipalities will track the progress of their measures; they do not,
however, identify clear targets or indicators for assessing whether measures have been implemented.
None of the FRMPs assessed (either at UoM or municipal level) provide a baseline against which
progress can be monitored and assessed.
Denmark reported (to EIONET) the following categories of completion for its measures: Completed
(170 measures, 29 % of all measures); Ongoing construction (six measures, 1 %); Ongoing recurrent
(e.g. maintenance works) (15 measures, 3 %); In preparation (304 measures, 51 %); Not started (77
measures, 13 %); Abandoned/interrupted (20 measures, 3 %).
The highest share of completed measures is in protection measures, at 46 measures completed
(46 % of protection measures), compared to 24-26 % of the prevention, preparedness and ‘other’
measures. For both prevention and preparedness measures, 60 % were reported in preparation, as
were 51 % of ‘other’ measures. Between three and eight measures of each measure type were
reported as abandoned/interrupted, with the largest number and share in protection measures (eight
measures, 8 % of all protection measures). T
he distribution of progress is similar across the two UoMs. In each, the greatest share of measures
are in preparation (60 % or 193 measures for Jutland and Funen (DK1); 41 % or 111 measures for
Seeland (DK2)). The Seeland UoM has a slightly higher share of completed measures (37 %, 100
measures) compared to Jutland and Funen (22 %, 70 measures).
As noted earlier, Denmark’s two UoM-level FRMPs provide a different number of measures than
reported to EIONET. These plans report on the status of completion of measures in the first FRMPs.
They indicate that 10 % (13 of 30) of measures in the Jutland and Funen UoM (DK1) and 5 % (6 of
125) of the measures in the Seeland UoM (DK2) were cancelled. This information cannot be compared
to Denmark’s reporting to EIONET, which identified only 28 measures for its first FRMPs.
Denmark has not reported the costs of its measures to EIONET. Only one of the three municipal
FRMPs (Odense municipality) provides information on costs, and not for all of its measures. The five
FRMPs assessed do not specify how their measures should be funded. There is an indication in the
Copenhagen FRMP that at least some measures are to be financed by combined public-private
financing.
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Neither the municipal FRMPs that were assessed nor the two UoM-level FRMPs report using CBA.
Both Denmark’s reporting to EIONET and the FRMPs reviewed include natural water retention
measures (NWRMs). FRMPs assessed refer to the WFD objectives, with the Odense FRMP noting
synergies for one measure and the Slagelse FRMP stating that projects will be assessed for potential
impacts. However, they provide few other details on how WFD objectives are considered.
Spatial planning and land-use measures are included in the measures Denmark reports to EIONET,
as well as in the FRMPs assessed.
Nature conservation (especially at Natura 2000 sites) is considered in developing the FRMPs and in
specific measures reported to EIONET and listed in the three municipal FRMPs assessed. The second
FRMPs assessed do not provide detail on progress towards the achievement of the objectives in the
first FRMPs, though they state that such an assessment should be made (in each municipal FRMP it
is at least briefly described the status of objectives set in the first FRMP).
Governance
Denmark reported that neither UoM featured coordination at international level, since Denmark,
although sharing a border with Germany, no APSFR has been identified as being shared with a
neighbouring Member State. The FRMPs assessed do not have any information on transboundary
cooperation.
The two UoM-level FRMPs levels state that ‘all the municipalities have a focus on the fact that risk
management affects many stakeholders, including citizens, and they all plan for involvement during
the implementation of the plan. Furthermore, all municipalities have had their risk management plan
in six months of consultation before it was adopted, where several municipalities held public meetings
etc. along the way’
53
. The three municipal FRMPs assessed state that the draft plans were provided
for consultation for six months. The Copenhagen and Odense FRMPs do not include details on how
the consultation was carried out. The Slagelse FRMP mentions public meetings and dialogue meetings
with relevant stakeholders in the consultation period.
54
Consideration of climate change
As regards the consideration of climate change effects in the preparation of flood risk management
plans, reference is made to section 3.7 on ‘Adaptation to climate change’ above.
Progress identified in the second FRMPs
The second FRMPs assessed followed a similar structure based on national guidance. While the first
FRMPs presented FHRMs only for 100-year return floods, the second FRMPs assessed provide more
maps, including some related to flash floods.
Nearly all of Denmark’s second municipal FRMPs explicitly address the reduction of adverse
consequences and more generally the risk of flooding, an issue found in the objectives of only some
of the first FRMPs assessed.
53
54
UoM-level FRMPs, p. 4.
Slagelse FRMP, p. 26.
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The second FRMPs provide details on the process to monitor measures.
On coordination with RBMPs, the second FRMPs provide more information. Two of three municipal
second FRMPs assessed (Copenhagen and Odense) state that the effects of some measures were
assessed for their WFD objectives, while the third plan assessed (Slagelse) indicates that this will be
done.
Also, the second FRMPs assessed provide further information on how nature protection is addressed
by measures. In addition, it appears from Denmark’s reporting that there is greater attention to
nature-based solutions in the second FRMPs.
It continues to be unclear in two of the three municipal FRMPs assessed how stakeholder input was
used – the exception is the Odense FRMP, which describes how consultation responses were
addressed. Some municipal FRMPs include measures to address floods in the context of climate
change or indicate an intention to integrate flood and climate change plans more closely in the future.
8. FD recommendations
On the basis of the assessment performed, and in addition to the progress already achieved, Denmark should:
•
link the flood risk maps for pluvial and sewerage flooding produced by the municipalities to the national
web-GIS portal;
provide detail on how the FHRM was used in the choice of objectives and measures of the FRMP;
set more specific objectives in the FRMP and where possible linked to quantitative indicators and be
timebound. An assessment of the progress made towards the achievement of the objectives should
be included in the FRMP;
provide information on the costs, budgets and funding sources for measures
provide more information on the prioritisation of measures in the FRMP;
provide information on the role of insurance in flood risk management, since provisions appear to be
in place;
depending on the nature of the measures, the subject the FRMP to a Strategic Environmental
Assessment, next to the screenings carried out at the municipal level;
set out a clear overview of the use of Cost Benefit Analysis and the methodology behind it in the FRMP;
better coordinate the discussion on the impact of climate change between the various FRMPs and
national/sub-national adaptation plans or strategies;
include information on transboundary cooperation in the FRMP in view of potentially worse future flood
risk conditions even if the cooperation is basic for the time being;
•
•
•
•
•
•
•
•
•
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•
provide detail on the public consultation and active stakeholder involvement in the FRMP, in particular,
the comments received, and how they were taken into account;
where appropriate, consider flow velocity or relevant water flow in the FHRM and flood conveyance
routes in the FRMP, as these are relevant to emergency response.
•
47