The researchers started from a framework first proposed by Edvardsson and Hansson in 2005, which set out four criteria for whether an individual goal is “achievement-inducing”, meaning it effectively contributes to its own achievement: precision, evaluability, approachability and motivity. For large goal systems involving many agents, long time horizons and multiple overlapping objectives, they argue, four criteria are not enough. They add two new ones: completeness, which asks whether the subgoals collectively capture everything needed to achieve the overarching goal, and instrumental flexibility, which asks whether the system allows better methods to be adopted over time without letting ambition erode. The framework extends the familiar management shorthand of SMART goals, specific, measurable, assignable, realistic and time-related, by adding dimensions that SMART neglects, particularly the motivational force of a goal and the architecture of the system it belongs to.

A key conceptual move in the paper is the rejection of the idea that subgoals should be purely instrumental to overarching goals. Decision analysts such as Ralph Keeney have long treated lower-level objectives as mere means to fundamental ends, adding no new information about what must be achieved. Doorn and her colleagues disagree for complex systems. How an overarching goal is subdivided and assigned to responsible agents, they show, can itself embody value-based prioritizations. Different water-quality objectives, hydrological, morphological and chemical, generate different governance requirements, and stakeholders hold divergent views on ambitions, achievements and necessary actions. A subdivision of goals is therefore not a neutral decomposition but a set of political and ethical choices that determine who must do what, and whether the system as a whole can function.

Turning to the Water Framework Directive itself, the authors first explain its structure. Surface waters are assessed on two dimensions: ecological status, which combines biological quality elements such as species composition with physico-chemical factors like nutrient levels and priority substances, and hydromorphological features describing the physical shape and flow dynamics of water bodies; and chemical status, defined by maximum allowable concentrations of specified pollutants set uniformly at European level. A water body’s overall status is the poorer of its ecological and chemical classifications on a five-point scale from bad to high, and compliance requires at least good on both dimensions by 2027. Member states enjoy considerable freedom in operationalizing ecological criteria, particularly the reference conditions that define what an undisturbed water body should look like.

On the criterion of precision, the study finds that the directive points in the right direction but is often strikingly vague about how far and by when. The normative definitions in Annex V rely on phrases such as “no, or only very minor, anthropogenic alterations” and “slight deviations”, without indicating how those qualifiers should be interpreted. More fundamentally, the benchmark of “undisturbed conditions” assumes stable, predictable ecological states, an idea ecologists have long criticized, since ecosystems are inherently dynamic and the notion of an undisturbed baseline has limited utility in the Anthropocene. The authors also highlight a philosophical blind spot: European waters have been transformed by millennia of human intervention, from dams and canals to centuries of cultural landscapes whose biodiversity conservationists actively want to preserve. The directive gives no guidance on which human impacts should be reversed and which should be retained.

Evaluability, the capacity of agents to assess their own progress, fares unevenly. Chemical status, expressed as measurable threshold concentrations comparable across member states, is in principle readily evaluable. Biological and physico-chemical elements of ecological status are also largely quantifiable. But hydromorphological goals are typically formulated as binary end states, undisturbed or altered, leaving no way to register intermediate progress. The most consequential problem, however, is the “one-out, all out” principle, under which a water body’s overall classification is determined by its weakest element. Two bodies scoring equally badly in their weakest dimension receive the same overall rating even if one performs far better everywhere else. Hering and colleagues have argued the principle may increase type I errors, wrongly declaring waters below good status and triggering unnecessary costs, and that it sits uneasily with the ecosystem approach, since no single component can scientifically determine the quality of an entire ecosystem. The authors conclude that the principle should be replaced by a more adequate aggregation method.

On approachability, the authors deliberately substitute a graded criterion for the binary notion of achievability. Experience from Sweden’s Vision Zero road-safety goal shows that unrealistic, even unattainable targets can drive innovation and push outcomes further than goals calibrated to what is currently feasible, and settling for “realistic” sustainability targets that fall short of planetary limits may be morally questionable. The WFD’s 2027 deadline is widely judged unattainable at the current pace, and Dutch water authorities consider it unlikely to be met, yet the authors attribute this largely to delayed implementation rather than inherently impossible goals. The picture differs sharply by pollution type. Point-source pollution from urban and industrial discharges has seen substantial progress, making those goals broadly approachable. Non-point pollution from agriculture, mainly nitrates and pesticides, shows little or no improvement; monitoring has improved even as pesticide concentrations have risen. Technologies exist to cut both fertilizer and pesticide use without harming harvests, but the regulatory tools to deploy them at scale are missing. And a critical caveat hangs over everything: climate change, with northern floods, southern droughts and warming waters, may make achieving the objectives outright impossible in some cases unless mitigation and adaptation succeed.

The motivational dimension reveals a subtler threat. Goal-setting research shows that precise, challenging and reliably evaluated goals elicit greater and more durable effort than vague exhortations, and that “ownership”, the sense among implementers that a goal is relevant, builds commitment. The directive does require stakeholder participation under Article 14, but water management remains largely sectoral in many member states, and weak alignment with agriculture, transport and spatial planning undermines coherence and engagement. Worse, the extensive use of exemptions and derogations under Articles 4.4 to 4.7 risks breeding skepticism about whether the commitment is serious. When aspirational goals routinely go unmet, the authors warn, aspiration fatigue sets in, fostering cynicism and eroding the willingness to sustain effort at all.

Completeness exposes what may be the most striking gaps. Climate change, which one commentator called the directive’s “elephant in the room”, is nowhere explicitly addressed, nor is water scarcity or the promotion of water-efficient technologies. The regulation of chemical pollution covers only substances with known toxic effects, treating untested chemicals, for the vast majority of which toxicity data are lacking, the same as substances tested and found harmless. The authors propose a European program to identify unknown contaminants, a legal mechanism for precautionary limits, and a prioritization system for toxicological testing. Monitoring is another blind spot: in Germany, only 18 of 301 approved pesticides are covered by obligatory monitoring. And because 60 percent of covered waters are transboundary, the absence of any guidance for preventing or resolving water-related conflicts between member states increases both the risk of disputes and of ineffective measures.

Instrumental flexibility, the final criterion, reveals a system whose flexibility flows in only one direction. In principle, the directive sets ends without prescribing means, and mechanisms exist to tighten ambitions, for instance reclassifying heavily modified water bodies as natural ones when restoration becomes feasible, or updating the list of priority substances. In practice, exemption categories, deadline extensions, less stringent objectives, responses to unforeseeable events and new development projects, have mostly been used to lower ambition, with inconsistent methods for justifying “disproportionate costs” across the EU. The authors propose reversing this asymmetry: retain or increase flexibility in the choice of means while reducing flexibility in the goals themselves. More broadly, they argue the six criteria are interdependent lenses rather than independent boxes, and that systematic analysis of goal-system rationality before adoption, whether for water, climate or the Sustainable Development Goals, would give policymakers a structured basis for judging whether proposed goals can actually guide action toward the futures they promise.

Subject of Research: Rationality criteria for evaluating complex environmental policy goal systems, applied to the EU Water Framework Directive

Article Title: Rationality Criteria for Complex Goal Systems: The case of the EU Water Framework Directive

Article References: Doorn, N., Edvardsson Björnberg, K., & Hansson, S. O. (2026). Rationality Criteria for Complex Goal Systems: The case of the EU Water Framework Directive. Environmental Management, 76(10), Article 341. https://doi.org/10.1007/s00267-026-02635-6

Image Credits: AI Generated

DOI: 10.1007/s00267-026-02635-6

Keywords: Water Framework Directive, goal-setting, rationality criteria, EU water policy, sustainability governance, ecological status, chemical status, one-out all-out principle, completeness, instrumental flexibility, motivity, environmental management