CONTENTS 1 INTRODUCTION 1 1.1 THE URBAN WASTEWATER TREATMENT DIRECTIVE (91/271/EEC) 1 1.2 THE NITRATES DIRECTIVE (91/676/EEC) 3 1.3 APPROACH AND METHODOLOGY 4 2 THE OFFICIAL GREEK DESIGNATION PROCESS 9 2.1 OVERVIEW OF THE CURRENT SITUATION IN GREECE 9 2.2 OFFICIAL DESIGNATION OF SENSITIVE AREAS 10 2.3 OFFICIAL DESIGNATION OF VULNERABLE ZONES 14 1 INTRODUCTION This report is a review of the areas designated as Sensitive Areas in conformity with the Urban Waste Water Treatment Directive 91/271/EEC and Vulnerable Zones in conformity with the Nitrates Directive 91/676/EEC in Greece. The review also includes suggestions for further areas that should be designated within the scope of these two Directives. Although the two Directives have different objectives, the areas designated as sensitive or vulnerable are reviewed simultaneously because of the similarities in the designation process. The investigations will focus upon: • Checking that those waters that should be identified according to either Directive have been; • in the case of the Nitrates Directive, assessing whether vulnerable zones have been designated correctly and comprehensively. The identification of vulnerable zones and sensitive areas in relation to the Nitrates Directive and Urban Waste Water Treatment Directive is carried out according to both common and specific criteria, as these are specified in the two Directives. 1.1 THE URBAN WASTEWATER TREATMENT DIRECTIVE (91/271/EEC) The Directive concerns the collection, treatment and discharge of urban wastewater as well as biodegradable wastewater from certain industrial sectors. The designation of sensitive areas is required by the Directive since, depending on the sensitivity of the receptor, treatment of a different level is necessary prior to discharge. According to the Directive, discharges into sensitive areas require more stringent treatment than secondary treatment Specifically, the designation of certain areas as sensitive is followed by the requirements that: • Collection systems should have been provided at the latest by 31 December 1998 for agglomerations of more than 10,000 p.e. (population equivalent) (Article 3 (1)).; • Discharge into sensitive areas be subject to more stringent treatment that that described in Article 4, by 31 December 1998 at the latest for all discharges from agglomerations of more than 10,000 p.e.; Under the terms of Article 5(5), more stringent standards than those required by Article 4 are also to be applied to discharges situated in the relevant catchment of sensitive areas and which contribute to the pollution of those ENVIRONMENTAL RESOURCES MANAGEMENT EUROPEAN COMMISSION - DG ENVIRONMENT I - 1 areas. Article 4(1) of the Directive specifies secondary treatment as the norm for receiving waters which have not been identified as a sensitive area. Sensitive areas are identified in accordance with certain criteria laid down in Annex II. The identification process should have been completed by 31 December 1993 and reviewed at intervals of no more than four years. The criteria set by the Directive for the identification of sensitive areas are given in Annex II, as follows: a) Natural freshwater lakes, other freshwater bodies, estuaries and coastal waters which are found to be eutrophic or which in the near future may become eutrophic if protective action is not taken. The following elements might be taken into account when considering which nutrient should be reduced by further treatment: (i) lakes and streams reaching lakes/reservoirs/closed bays which are found to have a poor water exchange, whereby accumulation may take place. In these areas, the removal of phosphorous should be included unless it can be demonstrated that the removal will have no effect on the level of eutrophication. Where discharges from large agglomerations are made, the removal of nitrogen may also be considered; (ii) estuaries, bays and other coastal waters which are found to have a poor water exchange, or which receive large quantities of nutrients. Discharges from small agglomerations are usually of minor importance in those areas, but for large agglomerations the removal of phosphorous and/or nitrogen should be included unless it can be demonstrated that the removal will have no effect on the level of eutrophication; b) surface freshwaters intended for the abstraction of drinking water which could contain more than the concentration of nitrate laid down under the relevant provisions of Council Directive 75/440/EEC concerning the quality required of surface water intended for the abstraction of drinking water in the Member States, if action is not taken; c) areas where further treatment than the prescribed in Article 4 of this Directive is necessary to fulfil the Council Directives. For the purpose of this Directive eutrophication is defined as “the enrichment of water by nutrients, especially compounds of nitrogen and/or phosphorous, causing an accelerated growth of algae and higher forms of plant life to produce an undesirable disturbance to the balance of the organisms present in the water and to the quality of the water concerned”. ENVIRONMENTAL RESOURCES MANAGEMENT EUROPEAN COMMISSION - DG ENVIRONMENT I - 2 1.2 THE NITRATES DIRECTIVE (91/676/EEC) The Directive concerns the protection of water against pollution caused by nitrates from agricultural sources. The Directive has the dual objective to reduce water pollution caused or induced from agricultural sources and to prevent further such pollution. Since certain zones, draining into waters vulnerable to pollution from nitrogen compounds, require special protection, the Directive requires (Article 3) all Member States to identify waters that are affected or could be affected by pollution and designate as vulnerable zones all known areas of land which drain into these waters. The designation process should had been completed within two years following the notification of the Directive and reviewed whenever necessary, or at last every four years, to take into account changes and factors unforeseen at the time of the previous designation. For the purpose of realising the objectives set by the Directive, Member States are requested to establish action programmes in respect of the designated vulnerable zones and which may be related to all vulnerable zones in the territory or may be different for different zones or parts of zones. Action programmes should be established within a two-year period following the initial designation or within one year of each additional designation. The criteria for identifying nitrate-polluted waters, referred to in Article 3(1), are given in Annex I, as follows: 1) “whether surface freshwaters, in particular those used or intended for the abstraction of drinking water, contain or could contain more than 50mg nitrate/l (if action pursuant to article 5 is not taken); 2) whether groundwaters contain more than 50mg/l nitrates or could contain more (if action pursuant to article 5 is not taken); 3) whether, natural freshwater lakes, other freshwater bodies, estuaries, coastal waters and marine waters are found to be eutrophic or in the near future may become eutrophic (if action pursuant to article 5 is not taken)” For the scope of the Directive “pollution” is defined as “the discharge, directly or indirectly, of nitrogen compounds from agricultural sources into the aquatic environment, the results of which are such as to cause hazards to human health, harm to living resources and to aquatic ecosystems, damage to amenities of interference with other legitimate uses of water”. Article 6 of the Directive describes the requirements for the monitoring programme that should be established for the measurement of nitrate concentrations in surface and groundwaters, as well as the assessment of the eutrophic state of freshwaters. ENVIRONMENTAL RESOURCES MANAGEMENT EUROPEAN COMMISSION - DG ENVIRONMENT I - 3 1.3 APPROACH AND METHODOLOGY 1.3.1 Methodology The methodology adopted for the development of the report consisted of three main phases: Phase 1: Preparatory phase The preparatory phase consisted mainly of contacting key people in charge of the implementation of both Directives, in order to assess the progress made by the Greek Authorities and collect relevant information. Information regarding the designation process and any other additional data needed were obtained from: • the authorities, • environmental agencies/institutions, • research institutions, universities etc. • any other organisation susceptible to have information. Additionally, the consultants’ own files contributed substantially to the verification effort. Discussions on the procedures adopted and problems encountered, enabled the consultant to fully understand the methodology used by the authorities to designate both vulnerable zones and sensitive areas. Upon completion of this phase all primary data was collected and priority areas were identified to allow for collection of further information. Phase 2: Data Analysis During this phase the data collected during Phase 1, following consultation with relevant organisations, was analysed. For methodological purposes, data from both inland (surface and groundwaters) and coastal waters was analysed together for every Water Region. This is an Official Division of Greece introduced by Law 1739/87 (GG 201A/20-11-87), and is defined as “an area limited by watersheds, or insular areas, which includes completed hydrographic networks with as far as possible identical hydrological characteristics”. Each water region consists of