As long-term NGO observer, WWF Central and Eastern Europe appreciates the progress that has been made in Danube river basin and flood risk management planning over the past two decades such as moving sturgeon conservation, wetland restoration or climate change adaptation more into the focus. We would also like to highlight our satisfaction with the
numerous opportunities provided to us for engaging in ICPDR discussions and processes and very much hope that such transparent approach will be replicated at national level for this consultation round but also future river basin management processes.

Let me now highlight some specific elements we believe should be strengthened in the Danube River Basin Management Plan towards 2027:

1. focus on integrated solutions that solve several problems at the same time such as flood management, drought mitigation, water quality improvement or biodiversity objectives with a longer term perspective.
2. overcome the blockage by the agricultural sector by providing the right incentives. For example, Hungary is thinking about opening 1st pillar direct payments for water retention on arable land and amend landuse regulations to support water retention on agricultural lands while currently it is obligatory to maintain the status of land use according to the cadaster. From the second pillar, we would need WFD compensation schemes in case there is an obligatory restriction due to restoration or conservation measures according to the WFD.
3. Build capacity for project preparation in authorities.

Fish biodiversity
As the JDS4 has shown, hydromorphological pressures on fish are apparent along the whole Danube and there is no general improvement since the last Plan. However, measures that are likely to improve the status of fish are largely limited to fish passes with various levels of ambition. Romania, to give one example, indicates as current status 116 river continuity interruptions while only 1 fish migration aid is plan. While sturgeon conservation is woven into several chapters of the plan - which we appreciate - we see the need to include identification, restoration and monitoring of habitats of migratory fish species, in particular sturgeons, in the chapter River Morphological Alterations and commit to closer cooperation between water management authorities and authorities responsible for nature protection and biodiversity.

Remarks on the Danube Flood Risk Management Plan towards 2027
Concerning flood risk mitigation, it is not clear from the plan whether the transboundary aspects of flood risk management in the frame of bilateral agreements and commissions take into account future flood risk mitigation plans and measures of upstream countries. 

In some countries implementation of green measures for flood mitigation are lagging behind and interventions go against nature conservation objectives. The Danube flood risk management plan annex 2 lists green measures, but the ratio of traditional, grey measures versus green ones is not shown, leaving a blurry picture.

In general,
we believe an implementation push is possible if the following is being addressed. 

• allocating financial resources e.g. from the National Recovery and Resilience budgets, the Operational Programmes and Common Agricultural Policy funding lines to the Programmes of Measures, 
• building capacity for planning and implementing restoration and conservation measures together with key sector representatives, such as agriculture, flood mitigation, nature conservation, forestry.
• preparing a pipeline of projects including feasibility studies, stakeholder engagement, and agreements with land-owners, technical design and permits and funding allocation.