We welcome the European Commission’s Proposal for a revised UWWTD. The original directive has succeeded in reducing environmental pollution from waste water and in enhancing the ecological and chemical status of the European water bodies.

You can read our full position here.

The original UWWTD is now 30 years old, and needed to be revised in order to deal with new challenges. The ambition of the Proposal is fourfold: it will allow water operators across Europe to tackle remaining pollution sources, better alignment with the overarching UN Sustainable Development Goals and the European Green Deal, enhance the governance of the wastewater sector and facilitate access to sanitation for more people.

We welcome the reinforcement of control at source as the most effective way to tackle pollution, and specifically micro-pollutants. To this end, we fully support the introduction of Extended Producer Responsibility (EPR), which will enable investments in additional treatment steps if control at source measures are unable to meet wastewater quality thresholds, without jeopardising the affordability of water services. Additionally, to fully implement the ambition of quaternary treatment for micro-pollutants and associated costs, EPR schemes will need to be fully implemented and able to generate sufficient finance well before the requirements for quaternary treatment are in place.

We note that the Proposal will require significant investments in order to fulfil the new requirements. Therefore, it is of the utmost importance to invest first where it brings the greatest benefit to the environment whilst achieving the new objectives of the Proposal.

Furthermore, a revision of the proposed deadlines, as well as their internal coherence, is indispensable to allow our sector to sustainably implement the proposed requirements.

We welcome the will to align the future Directive with other water-related environmental directives and the Green Deal so as to contribute to EU-wide objectives. In particular, we value the benefits of improved wastewater treatment regarding the protection of water bodies intended for human consumption, which will also help to achieve the requirements set out in the Drinking Water Directive. However, we regret that the intention to keep the Proposal straightforward is at the expense of adaptation to local circumstances and to the proportionality achieved in both the Water Framework Directive (WFD) and the Marine Strategy Framework Directive (MSFD). We also regret that the Proposal does not consider the European Parliament’s call to address the interaction between the design, construction and expansion of urban wastewater treatment plants (UWWTPs) and the obligation of non-deterioration to ensure coherence between the UWWTD and the WFD.

The extension of the scope of the Directive may significantly increase the use of energy, treatment chemicals and materials/equipment and, subsequently, greenhouse gas (GHG) emissions. A holistic assessment, taking into account the collecting systems and the wastewater treatment facilities, as well as innovative solutions, is required to ensure future-safe investment decisions and contribute to the development of the potential of the wastewater sector in the circular economy.

We look forward to working with the EU institutions on this vital Directive. You can read our full position here.