Munich study shows governance gaps, not missing data, stall urban groundwater management

Urban groundwater is becoming one of the quiet pressure points of European city life, and a new study argues that the biggest obstacle to managing it is not a shortage of data but the way institutions handle it. Their conclusion is blunt. In the two Munich processes examined, the main barrier lay not in technical knowledge but in institutional governance, with fragmented responsibilities, disconnected data systems and limited coordination undermining otherwise substantial monitoring investment.

The methodology, called the Data-Governance Diagnostic for Urban Groundwater Management, was developed within the MARGIN project, an Alpine Space initiative that carried out integrated assessments in four pilot cities: Linz, Ljubljana, Milan and Munich. It draws on research traditions from spatial data infrastructure and digital information governance, which established that governing distributed public data is an organisational problem rather than a technical one. The diagnostic proceeds through four sequential steps. First, structured stakeholder engagement maps the actor landscape using a standardised multilingual questionnaire, semi-structured expert interviews and, where appropriate, participatory workshops. Second, a systematic data inventory and gap assessment catalogues available datasets by content, responsible institution, format, temporal coverage, update frequency and accessibility. Third, governance workflow analysis reconstructs the relevant planning and implementation processes step by step and translates them into interdepartmental flow charts. Fourth, a triangulated relevance assessment combines data gaps, governance gaps and stakeholder priorities into a prioritised diagnostic with written justifications for each score.

In Munich, the questionnaire was completed by five respondents out of 21 across the six participating cities, and five semi-structured interviews were conducted with the main departments and authorities responsible for groundwater management. These included RKU, the city’s climate and environment department; MSE, the municipal wastewater utility; BAU/LBK, the construction and building authority; PLAN, the spatial planning department; and WWA, the regional water management authority. Additional stakeholders included the Bavarian Environment Agency LfU, the municipal utility SWM, the urban renewal company MGS and TUM. Because the diagnostic characterises institutional and data-handling arrangements rather than testing statistical hypotheses, it follows a plausibility-based logic: findings are established through triangulation across the questionnaire, interviews and the data-availability analysis, and treated as robust once these sources converge, rather than through statistical inference.

The data assessment revealed a paradox at the heart of Munich’s groundwater information system. The city has a comparatively strong technical basis for monitoring core hydrogeological parameters. Groundwater level time series, temperature data and key spatial datasets, including contour lines, permeability and thickness maps and temperature layers, were consistently reported as measured and digitally available. Climate and precipitation data from the German Weather Service were the only category assessed as fully high, reflecting open online access in machine-readable format. Yet ecosystem data were classified as low, having been collected only once, never digitised and left without an identified institution responsible for continuous monitoring. Water abstraction and use data, although measured, were not accessible online, and groundwater recharge data were reported as modelled rather than directly measured and not openly accessible.

The data inventory extended this picture at dataset level. Groundwater level time series are provided daily by the GKD Bayern portal managed by LfU, but only through a rolling 12-month window with CSV download. The City of Munich maintains over 2000 official monitoring wells accessible through its groundwater data page, yet none of these sources provide a unified, open, long-term archive. Aquifer geometry datasets, produced through the GEPO project at TUM between 2012 and 2016 based on over 48,000 borehole logs, are held at LfU and TUM, accessible internally on request, but remain static, last updated between 2014 and 2016, and not openly downloadable. Infrastructure data, including the municipal sewage network and SWM’s district heating network, are maintained institutionally but not openly accessible. Groundwater quality monitoring is conducted regularly but reported in PDF format with partial accessibility, while ecosystem and microbiological data exist only as isolated academic studies with no systematic institutional monitoring programme. A further notable finding was the absence of a clearly recognised city-wide coordination mandate for groundwater data, pointing to a structural leadership gap in Munich’s data governance system.

The planning phase is anchored in the statutory Bebauungsplan procedure, the binding land-use planning instrument under German spatial planning law, led by PLAN through five steps encompassing scoping, public participation, technical review, public authority consultation and final resolution. The installation phase splits into two tracks. In public spaces, BAU and MSE lead from a joint technical kick-off through construction supervision, testing and final approval. On private parcels, three parallel permitting tracks run through MSE, LBK and RKU independently, without formal orchestration. Nine governance gaps were identified, including the absence of end-to-end standard operating procedures, fragmented workflows relying on email and PDF exchange without a common data environment, no unifying departmental sub-strategy for Sponge City implementation, and no post-implementation oversight in the form of an asset registry, inspection cadence or performance indicators. Seven data gaps directly constrain implementation, among them no city-wide groundwater depth map, hydrogeological capacity data static since 2014 to 2016 and available only on restricted internal request, and no dataset of installed infiltration measure locations. The assessment assigned rainwater infiltration a relevance score of 2, or medium, reflecting its salience under the Sponge City strategy alongside a recognised but not top-ranked stakeholder prioritisation and moderate governance and data gaps.

Thermal groundwater use presented a contrasting institutional configuration. Munich manages it within a two-tier strategic framework: the city-wide Municipal Heating Plan defines strategic suitability and technology criteria, while the Quartier Strategy translates these into neighbourhood-level Integrated Neighbourhood Concepts. With over 3000 registered groundwater heat pump systems generating approximately 300 gigawatt-hours annually, Munich represents one of the most institutionally advanced European examples of thermal groundwater governance. The city-scale Heating Plan process proceeds through four analytical and political steps, with RKU serving as single data coordinator and integrator, consolidating inputs into a city-wide heat demand model, producing the official suitability map, converting suitability into implementable spatial options and delivering a 2045 city-wide target scenario for City Council approval. Yet five governance gaps were identified, concentrated in the Quartier phase, including upstream data quality vulnerability, unclear role division between RKU and PLAN, structural over-reliance on the external contractor MGS creating institutional knowledge loss risk, and no structured monitoring and iteration framework. Six data gaps constrain the thermal domain, including fragmented and outdated groundwater temperature data, with the most recent comprehensive city-wide map dating from 2014, no openly accessible comprehensive registry of existing geothermal installations, no operational tool for mapping thermal plumes and identifying conflicts between installations, and data protection barriers limiting sharing of operational data from private installations. Thermal groundwater use was assigned a relevance score of 1 to 2, high to medium, reflecting strong stakeholder prioritisation together with residual data deficiencies even though its governance framework is comparatively well structured.

A central analytical finding is that these governance and data gaps are mutually reinforcing rather than independent. In the rainwater infiltration case, the absence of a common data environment reinforces data fragmentation and prevents update triggers, while the absence of post-implementation oversight is directly coupled to the absence of an asset location dataset: without a registry there is no institutional basis for performance tracking, and without performance data there is no evidence base to justify investment in monitoring. In the thermal case, the absence of an installation registry undermines the quality of the Heating Plan potential analysis, while the absence of a post-implementation monitoring framework prevents systematic collection of the operational data that would update temperature datasets and the registry. The result is a self-reinforcing cycle in which data deficiencies undermine governance and governance gaps prevent data improvement. The authors argue that resolving either gap in isolation is insufficient and that these gaps must be addressed simultaneously.

The study also surfaces a key unresolved scientific question: whether rainwater infiltration measures produce measurable effects on groundwater recharge at city scale. It remains unclear both how much these measures actually contribute to recharge and whether this contribution is large enough to be relevant for groundwater management. Resolving this requires dedicated city-scale monitoring and quantitative assessment, which the current absence of post-implementation monitoring in the Sponge City strategy directly prevents. The authors are careful to note the limitations of their approach. The workflow analyses are based on stakeholder interviews and reconstructed processes, which may not fully capture informal practices or unrecorded workarounds, and the paper presents an in-depth application in Munich rather than a systematic comparative validation across the four pilot cities, which remains future work. The three-level relevance scoring system prioritises operational usability over analytical precision, and the methodology diagnoses governance and data conditions rather than quantitatively evaluating environmental outcomes.

The novelty is threefold: a practitioner-friendly step-by-step diagnostic applicable directly by municipalities, including in workshop settings; a structured output making principal data and governance gaps explicit and actionable; and the demonstration that these gaps are mutually reinforcing. An interactive workshop-based tool is currently under development to support application in observer cities. Future research should validate the methodology across cities of varying size, institutional capacity and stage of urban development outside the Alpine context. For practitioners, the implications are concrete: improving urban groundwater management requires targeted interventions at operational interfaces rather than broad institutional reforms, prioritising shared data environments, clearly defined procedural links between responsible actors, and monitoring systems that enable feedback into planning processes. Groundwater data, the study concludes, can only deliver practical value when embedded in governance systems that enable coordination, accessibility and effective use in decision-making.

Subject of Research: A workflow-based diagnostic methodology for identifying data and governance gaps in urban groundwater management, demonstrated in Munich

Article Title: Diagnosing governance and data gaps in urban groundwater management with a transferable workflow based methodology evidenced in Munich

Article References: Astudillo, C., de Vries, W. T., Gondhalekar, D., & Zosseder, K. (2026). Diagnosing governance and data gaps in urban groundwater management with a transferable workflow based methodology evidenced in Munich. Discover Water, 6(1), Article 127. https://doi.org/10.1007/s43832-026-00466-4

Image Credits: AI Generated

DOI: 10.1007/s43832-026-00466-4

Keywords: urban groundwater, data governance, Munich, Sponge City, rainwater infiltration, thermal groundwater use, Municipal Heating Plan, governance workflow, MARGIN project, stakeholder engagement, data gaps, institutional fragmentation