Resources - Position papers

Removing PFAS from the urban water cycle causes a wide range of problems for water service providers. While technologies exist to remove most PFAS, they are unsustainable, mainly due to their technical complexity, resource intensity (water, energy, treatment chemicals etc.) and the generation of PFAS-containing residues. Reliance on end-of-pipe solutions creates a substantial stumbling block on the water sector’s journey towards climate neutrality. Any emissions of chemicals belonging to this group into the environment need to be avoided, using the Precautionary Principle and the Control-at-Source Principle. This can be best achieved by an EU-level ban of all PFAS uses.

Although the Renewable Energy Directive (RED III) does not specifically address the water sector, the water cycle has renewable energy generation potential, i.e.: the generation of electricity from hydraulic turbines, biogas from sewage sludge, electricity and thermal energy from sewage sludge mono-incineration, electricity from on-site windmills and solar panels, heat pumps and thermal energy from waste water at several stages of the water cycle. Hence, the water sector substantially contributes to the renewable energy targets and climate policies.

EurEau supports the general objective of the Energy Efficiency Directive (EED) which is to promote energy efficiency next to using renewable energies with the overall goal to achieve energy and climate neutrality. The EED and the Renewable Energy Directive (RED) must accompany and support this process, taking into account the GHG emissions as the main indicator.

Waste water treatment plants (WWTP) remove pollutants from domestic waste water through mechanical and chemical processes and the biological activity of the biomass contained in the reactors. Chemicals coming from industrial waste water discharges into sewers can pose threats to waste water treatment, human health and the environment.

Therefore, controlling hazardous industrial discharges into sewers is an essential measure for protecting the environment, for the effective and sustainable operation of WWTPs, and to allow operators to comply with the Urban Waste Water Treatment Directive (UWWTD). Any sustainable policy framework must start from the Precautionary Principle, the Control at Source Principle and the Polluter Pays Principle, according to Article 191.2 of the Treaty on the Functioning of the European Union (TFEU).

EurEau supports the setting of Environmental Quality Standards (EQS) for pharmaceuticals provided several pre-conditions are met to avoid that the water sector will be the first and/or only stakeholder to take the burden for ensuring compliance.

Enabling the circular economy for waste water services requires the alignment of a set of directives regulating the sector. The Urban Waste Water Treatment Directive (UWWTD), the Industrial Emission Directive (IED), the Waste Framework Directive (WFD) and the Sewage Sludge Directive (SSD) are key to the collection and treatment of urban waste water and subsequent treatment and re-use of urban waste water treatment sludge (UWWTS).

Small agglomerations have been identified as a source of pollution in the evaluation of the Urban Waste Water Treatment Directive (UWWTD). Despite that small agglomerations need to be better defined in the UWWTD, this source of pollution needs to be robustly addressed for the protection of biodiversity, ecosystems and for the protection of drinking water resources.

EurEau would like to see more guidance on monitoring and control of small or even individual systems at EU level through a thorough assessment and planning for the registration and monitoring of individual sanitation systems included in River Basin Management Plans. These elements should also be easily accessible to the local drinking water operators so that they can include them in the risk assessment and risk management of the catchment area as required in the recently recast Drinking Water Directive.

This paper explains the technical and practical implications for Urban Waste Water Treatment Plants (UWWTP) regarding the legal problems triggered by the Weser Ruling. It suggests possible solutions to look forward.

Statement on the Climate Action Technical Screening Criteria

The European waste water sector can make a big contribution to reaching climate neutrality objective by reducing Greenhouse Gas emissions and energy consumption. The revision of the Urban Waste Water Treatment Directive can create momentum to build a legal framework to address climate mitigation and the impact of waste water treatment plants. This paper presents how a tailor-made approach could generate the most optimal results.

The current directive is just being implemented, and so there is little or no experience as to how it functions in practice. Instead of revising, should the Commission focus on its effective implementation.

If the European legislators decide to proceed with the revision, they should focus on the further development of a coherent and streamlined regulatory framework for the security of network and information systems, without imposing additional and excessive burdens on industry.

At the same time, any duplication of legislation and inconsistencies with existing sector-specific and digital EU law should be avoided. The revision of the Directive should lead to a further strengthening of the preventive approach. This includes all aspects of detection and recovery by providing more and more detailed information on risks and incidents in the Member States, from national competent authorities to operators of essential services.

In the framework of new Commission policy work to protect public health and the environment, certain sectors, and in particular the chemical industry, are promoting a new ‘Innovation Principle’ next to the Precautionary Principle.

EurEau strongly supports innovation in our sector. However, we do not agree that the approach of BREFs as defined under the Industrial Emissions Directive (IED) suits the context of the UWWTD. Innovation and affordability of water services are best supported by an UWWTD which establishes output requirements with clear indications of enhanced performance requirements to achieve specific protection of the environment and public health, rather than prescribed instruments.

European waste water service providers see the revision of the 1991 Urban Waste Water Treatment Directive (UWWTD) as an opportunity to develop an ambitious, innovative, supportive and straight-forward new policy framework enabling operators to meet the Green Deal goals and make waste water collection, treatment and management fit for the decades to come.

New objectives to be delivered must consider the affordability of water services. This includes the long life-cycle of waste water collection and treatment assets and their inherent inflexibility for adaptation or upgrading.

The aim of this paper is to set our general expectations and point at areas to be covered by the impact assessment. Detailed positions or notes on specific topics will be delivered in due course.

Addressing the pollution of water resources in the context of the European Green Deal with its Zero Pollution Action Plan (ZPAP) is fundamental for the continued provision of safe and affordable drinking and waste water services, whose essential mission is to protect human health and the aquatic environment.

EurEau fully supports the zero pollution ambition and calls on the Commission to put water front and centre of the plan. Industry and agriculture have an important role to play in controlling pollution and rectifying environmental damage as much as possible at the source.

The action plan should propose concrete actions rather than focussing solely on establishing monitoring frameworks and promoting digital tools. 

The water sector strongly supports the Farm-to-Fork Strategy. If fully and ambitiously implemented, it will protect water resources now and for future generations. EurEau calls for stronger policy coordination with the EU’s water-related legislation, the greening of the CAP, the effective implementation of pesticide rules, the drastic reduction of nutrient losses, more support for organic farming and the responsible use of antimicrobials. Water operators stand ready to step up cooperation with farmers in this transition process.

PFAS is a large group of very persistent chemicals that tend to accumulate in the environment and in human and animal bodies. They therefore pose a serious threat to the environment and human health. The emission of this group of chemicals needs to be drastically reduced, using the principles of control-at-source and polluter-pays. An EU-level ban on all non-essential use of PFAS is therefore necessary.

Sewer networks are a vital part of the urban environment. They provide drainage, prevent flooding of property and protect the water environment around urban areas.

We recognise many opportunities to make urban environments more sustainable through the management of waste water flows and storm water. We also acknowledge the significant financial responsibilities that are associated with making changes to the network of collecting systems.

This document provides a short reaction to and additional thoughts on the Deloitte study into Extended Producer Responsibility, accompanied by complementary information on the water services sector.

EurEau largely supports the study’s outcome. The study builds a solid case in favour of mandatory control-at-source measures, complemented, where necessary, by other mitigation measures along the supply chain and financed through mandatory EPR schemes. The study also highlights the need to adjust the relevant EU legislation, conduct a solid cost-benefit analysis of all mitigation measures and set up an inclusive process to develop fair, proportionate and effective EPR schemes

Micropollutants can directly or indirectly enter the water cycle through many means. Once in the water cycle, they can pose a risk to drinking water resources and aquatic ecosystems.
Current technologies used in waste water treatment plants are not entirely capable of removing micropollutants. The most sustainable and preferred solution remains to prevent micropollutants – including microplastics - from entering the water cycle in the first place.
We call on the EU institutions to legislate according to the source control approach, the precautionary principle and the polluter pays principle. EurEau believes that the correct use of the source control approach is instrumental to achieve a truly circular economy.