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The Programme of Measures of the Water Framework Directive – More than just a Formal Compliance Tool

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This article explores the requirements of the Water Framework Directive with regard to the programme of measures for achieving environmental objectives. It analyses Article 11 of the directive and other legal provisions concerning the content of the programme, and identifies four kind of provisions: provisions for including measures for achieving environmental objectives, provisions for including measures for fulfilling other obligations in the Water Framework Directive, provisions for including measures for fulfilling obligations in other environmental directives, and provisions concerning the legal design of the Member States' water management. This article concludes that a number of the provisions in Article 11 direct the legal design of the Member States' water management in greater detail than that which follows from the obligation to achieve the environmental objectives of Article 4 of the directive, and that the freedom to decide on how to attain the environmental objectives of the directive is limited thereby.


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