1 of 25 Journal of Environmental Law Advance Access published March 11

Abstract This article presents a comparative perspective of the implementation of the Water Framework Directive (WFD). The investigated Member States are the Netherlands, Luxembourg, Belgium, France, Germany, the United Kingdom, Denmark, Romania, Italy, Spain and Portugal. The implementation of the WFD in these Member States was researched with the help of legal experts who completed questionnaires or were interviewed and-limited to five Member States-through interviews with civil servants who were involved with the implemention of the WFD. This research demonstrates that the WFD leaves so much room for discretion that the Member States adopt different approaches concerning the implementation of fundamental parts of the Directive. Although the need for flexibility due to the differences in circumstances is recognised, the new governance approach of the WFD demonstrates a risk that unambitious national practices will lea