COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal for a Directive of the European Parliament and of the Council concerning urban wastewater treatment (recast)

EN EN
EUROPEAN
COMMISSION
Brussels, 26.10.2022
SWD(2022) 541 final
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT
Accompanying the document
Proposal for a Directive of the European Parliament and of the Council
concerning urban wastewater treatment (recast)
{COM(2022) 541 final} - {SEC(2022) 541 final} - {SWD(2022) 544 final}
Offentligt
KOM (2022) 0541 - SWD-dokument
Europaudvalget 2022
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Table of contents
1. INTRODUCTION: POLITICAL AND LEGAL CONTEXT...................................13
2. PROBLEM DEFINITION ........................................................................................15
2.1 What are the problems and their drivers?............................................................15
2.1.1 Remaining pollution from urban sources – problem and drivers............. 15
2.1.1.1 Non-compliant agglomerations..................................................................... 16
2.1.1.2 Storm water overflow (SWO) and urban runoff ........................................... 17
2.1.1.3 Individual appropriate systems (IAS) ........................................................... 18
2.1.1.4 Small agglomerations.................................................................................... 18
2.1.1.5 Remaining releases from Nitrogen and Phosphorus ..................................... 19
2.1.1.6 Micro-pollutants and Micro-plastics............................................................. 20
2.1.1.7 Non domestic releases................................................................................... 22
2.1.2 Alignment with Green Deal, new societal challenges - problems and
drivers....................................................................................................................... 23
2.1.2.1 Green House Gas emissions.......................................................................... 23
2.1.2.2 Energy use..................................................................................................... 23
2.1.2.3 Sludge and water re-use ................................................................................ 24
2.1.2.4 Health and wastewaters................................................................................. 25
2.1.3 Modernisation and Governance - problem and drivers ............................. 25
2.1.3.1 Operators’ performances and transparency................................................... 26
2.1.3.2 Uneven application of the ‘polluter pays’ principle...................................... 26
2.1.3.2 Not adapted monitoring and reporting.......................................................... 27
2.1.3.2 Insufficient access to sanitation .................................................................... 28
2.2 How likely is the problem to persist?..................................................................28
3. WHY SHOULD THE EU ACT? ..............................................................................29
3.1 Legal basis...........................................................................................................29
3.2 Subsidiarity: Necessity of EU action...................................................................29
3.3 Subsidiarity: added value of EU action...............................................................30
4. OBJECTIVES: WHAT IS TO BE ACHIEVED? .....................................................31
4.1 General objectives ...............................................................................................31
4.2 Specific objectives...............................................................................................31
5. WHAT ARE THE AVAILABLE POLICY OPTIONS? ..........................................34
5.1 What is the baseline from which options are assessed? ......................................34
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5.2 Description of the policy options ........................................................................36
5.2.1 Storm water overflows (SWO) and urban runoff............................................. 37
5.2.2 Small Agglomerations...................................................................................... 38
5.2.3 Loads from individual or other appropriate systems (IAS) ............................. 39
5.2.4 N and P releases and eutrophication ................................................................ 39
5.2.5 Micro-pollutants............................................................................................... 40
5.2.6 Non-domestic emissions .................................................................................. 41
5.2.7 Energy .............................................................................................................. 41
5.2.8 Sludge management and water re-use.............................................................. 44
5.2.9 Wastewater and health ..................................................................................... 44
5.2.10 Transparency and Governance....................................................................... 45
5.2.11 Monitoring and reporting............................................................................... 45
5.2.12 Access to sanitation........................................................................................ 46
5.3 Options discarded at an early stage .....................................................................46
6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS, HOW DO THEY COMPARE
AND WHAT ARE THE PREFERRED OPTIONS? .......................................................................... 49
6.1 Storm water overflows and urban runoff.............................................................50
6.2 Individual or other appropriate systems (IAS) ....................................................53
6.3 Small Agglomerations.........................................................................................53
6.4 N and P releases and eutrophication....................................................................54
6.5 Micro-pollutants ..................................................................................................55
6.6 Non-domestic Emissions.....................................................................................57
6.7 Energy neutrality and GHG emissions................................................................58
6.8 Governance – transparency .................................................................................60
6.9 Wastewater and health.........................................................................................60
6.10 Access to sanitation...........................................................................................61
6.11 Reporting...........................................................................................................61
7. PREFERRED OPTION ...................................................................................................................... 64
7.1 Preferred Option – summary ...............................................................................64
7.2 REFIT and “One in, One out”.............................................................................73
8. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?.................................. 75
ANNEX 1: PROCEDURAL INFORMATION............................................................................................ 77
1. LEAD DG, DECIDE PLANNING/CWP REFERENCES.................................................................. 77
2. ORGANISATION AND TIMING...................................................................................................... 77
3. CONSULTATION OF THE RSB....................................................................................................... 77
4. EVIDENCE, SOURCES AND QUALITY......................................................................................... 81
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT)................................................ 83
1. CONSULTATION STRATEGY & ACTIVITIES................................................................................... 83
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2. STAKEHOLDER GROUP....................................................................................................................... 85
3. METHODOLOGY AND TOOLS USED TO PROCESS THE DATA ................................................... 86
4. OPC – GENERAL VIEW......................................................................................................................... 87
5. STAKEHOLDERS’ VIEWS ON THE DIFFERENT AREAS ............................................................... 88
6. POSITION PAPERS ............................................................................................................................... 96
ANNEX 3: WHO IS AFFECTED AND HOW? .......................................................................................... 98
1. PRACTICAL IMPLICATIONS OF THE INITIATIVE..................................................................... 98
2. SUMMARY OF COSTS AND BENEFITS ..................................................................................... 102
3. RELEVANT SUSTAINABLE DEVELOPMENT GOALS............................................................. 105
ANNEX 4: ANALYTICAL METHODS ................................................................................................... 106
ANNEX 5: SUMMARY OF MEMBER STATE SITUATION................................................................. 129
ANNEX 6: ASSESSING COMPLIANCE ................................................................................................ 133
ANNEX 7: ADDITIONAL DETAILED INFORMATION...................................................................... 135
ANNEX 8: MAIN RELATIONS BETWEEN ONGOING INITIATIVES AND THE PRESENT
INITIATIVE ..................................................................................................................................... 144
ANNEX 9: ACTORS INVOLVED IN AN EPR SCHEME AND THEIR RESPECTIVE ROLES .......... 146
ANNEX 10: LITERATURE REFERENCES............................................................................................. 148
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Glossary
Term Explanation
Agglomeration
According to the Urban Wastewater Treatment Directive (UWWTD):
‘Agglomeration’ means an area where the population and/or economic
activities are ‘sufficiently concentrated’ for urban wastewater to be
collected and conducted to an urban wastewater treatment plant or to a
final discharge point. (Article 2(4)).
An agglomeration can be a city or municipality, but it can also be a
number of smaller cities or towns clustered together.
Anti-microbial
Resistance
(AMR)
AMR occurs when e.g. fungi and bacteria transform over time and no
longer respond to medications (WHO, 2022). The main drivers of the
development of drug-resistant pathogens are misuse and overuse of anti-
microbials e.g. antibiotics, antivirals, antifungals and antiparasitics.
AMR has been declared as one of the top 10 global public health threats
facing humanity by the World Health Organization (WHO).
Biochemical
oxygen
demand
(BOD)
According to the UWWTD: in the wastewater discharge, biochemical
oxygen demand (BOD) needs to be reduced to 25mg/l of Oxygen or a
minimum reduction of 70-90% needs to be achieved. (Annex I).
BOD is ‘the amount of dissolved oxygen used by micro-organisms in the
biological process of metabolising organic matter in water. The more
organic matter there is (e.g. in sewage and polluted bodies of water), the
greater the BOD. And the greater the BOD, the lower the amount of
dissolved oxygen available for higher animals such as fishes. The BOD
is therefore a reliable gauge of the organic pollution of a body of water.
One of the main reasons for treating wastewater prior to its discharge is
to lower its BOD — i.e., reduce its need of oxygen and thereby lessen its
demand from the streams, lakes, rivers, or estuaries into which it is
released.’ (Britannica, 2019a).
BOD is most commonly expressed as milligrams of oxygen consumed
per litre of samples over 5 days of incubation at 20°C – this is called
BOD5 (Sawyer et al., 2003). In this text “BOD” means “BOD5”.
Chemical
oxygen
The UWWTD states that chemical oxygen demand (COD) in the
wastewater discharge needs to be reduced to 125mg/l O2. Alternatively,
a minimum reduction of 75% needs to be achieved.
COD ‘is a second method of estimating how much oxygen would be
depleted from a body of receiving water as a result of bacterial action.
While the BOD test is performed by using a population of bacteria and
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demand other micro-organisms to attempt to duplicate what would happen in a
natural stream over a period of five days, the COD test uses a strong
chemical oxidising agent (potassium dichromate or potassium
permanganate) to chemically oxidise the organic material in the sample
of wastewater under conditions of heat and strong acid.’ (Woodard &
Curran, 2006).
Collecting
system
The UWWTD defines this as a system of conduits which collects and
conducts urban wastewater. (Article 2(5)).
Combined
sewers
Combined sewers are defined as ‘Systems that carry a mixture of both
domestic sewage and storm sewage’. Combined sewers typically consist
of large-diameter pipes or tunnels, because of the large volumes of storm
water that must be carried during wet-weather periods. They are very
common in older cities but are no longer designed and built as part of
new sewerage facilities.’ (Britannica, 2019b).
Contaminants
of emerging
concern
The UWWTD does not include a reference to contaminants of emerging
concern. According to the Organisation for Economic Co-operation and
Development (OECD) “Contaminants of emerging concern” (CECs)
comprise a vast array of contaminants that have only recently appeared
in water, or that are of recent concern because they have been detected at
concentrations significantly higher than expected, or their risk to human
and environmental health may not be fully understood. Examples include
pharmaceuticals, industrial and household chemicals, personal care
products, pesticides, manufactured nanomaterials, and their
transformation products’ (OECD, 2018).
The Environmental Quality Standards Directive explains pollutants of
emerging concern. Recital 26 states that ‘emerging pollutants … can be
defined as pollutants currently not included in routine monitoring
programmes at Union level but which could pose a significant risk
requiring regulation, depending upon their potential eco-toxicological
and toxicological effects and on their levels in the aquatic environment.’
Dilution rate
In the context of this IA, the dilution rate refers to the ratio between the
flow of released wastewater from a treatment plant and the flow of the
receiving body (river). A dilution rate of 10 means that 1 litre of released
wastewater from the treatment plant is diluted in less than 10 litres in the
river. Lower dilution rates represent more risks for the environment but
also for potentially for public health.
Distance to
target
‘Distance to target’ reflects the remaining efforts to be made to collect
and treat the load generated in accordance with the requirements of the
Directive. For instance, in 2018, 98% of the generated load is collected,
across all Member States, in line with Article 3 of the Directive, meaning
that, for this goal, the EU average distance to target is 2 %.
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Eutrophication
UWWTD definition: The enrichment of water by nutrients, especially
compounds of nitrogen and/or phosphorus, causing an accelerated
growth of algae and higher forms of plant life to produce an undesirable
disturbance to the balance of organisms present in the water and to the
quality of the water concerned. (Article 2(11)).
E. coli
Indicators of faecal contamination are commonly analysed in treated
wastewater prior to discharge or reuse. Escherichia coli (E. coli) is one
of the most commonly adopted indicators for the determination of the
microbiological quality in water and treated wastewater since it is
considered a good indicator of this type of contamination. It is also
easily detectable, almost exclusively of faecal origin and its presence is
linked to the presence of pathogens. Due to this, E. coli is used in most
regulations regarding the microbiological quality of treated municipal
wastewater (Vergine et al, 2017; Annex 10, report 1).
Fourth
treatment
Fourth treatment consist of micro-pollutant removal notably via
ozonation and/or filtering with activated carbon or advanced techniques
like nano-filtration, membranes. It comes after tertiary treatment
(Nitrogen treatment in particular) – which is a pre-requisite to ensure an
optimal functioning of the 4th
treatment. So far there is no obligation in
the UWWTD to treat micro-pollutants.
Individual or
other
appropriate
systems
(IAS)
The UWWTD states that ‘where the establishment of a collecting system
is not justified either because it would produce no environmental benefit
or because it would involve excessive cost, individual systems or other
appropriate systems which achieve the same level of environmental
protection shall be used.’ (Article 3(1)). This covers simple facilities
such as sceptic thanks up to more sophisticated small facilities.
Micro-
pollutants
Emerging micro-pollutants are defined as synthetic or natural
compounds released from point and nonpoint resources and end up to the
aquatic environments at low concentration - typically µg/L or less
(Barbosa et al., 2016)
Pollutant which exists in very small traces in water (Source: EEA).
Most micro-pollutants are considered as “Contaminants of emerging
concern” (see above). In this IA and in the context of the study on EPR,
a more specific definition focusing on organic substances was used (See
report 2, Annex 10).
Micro-plastics
According to the European Chemicals Agency (ECHA), ‘the term
“micro-plastic” is not consistently defined, but is typically considered to
refer to small, usually microscopic, solid particles made of a synthetic
polymer. They are associated with long-term persistence in the
environment, if released, as they are very resistant to (bio)degradation.’
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Population
equivalent
(p.e.)
UWWTD definition: ‘1 p.e. (population equivalent)’ means the organic
biodegradable load having a five-day biochemical oxygen demand
(BOD5) of 60 g of oxygen per day.’ In this IA, one p.e. includes on
average 11.18 g/day for total Nitrogen, and 1.68 g/day for Phosphorus. It
also includes a range of micro-pollutants (around 1.300 chemicals were
considered in this IA) each having a specific load – see Annex 4.
In summary, 1 p.e. describes the average pollution load release by one
person in one day.
PRO –
Producer
Responsibility
Organisation
‘PRO’ are organisations set up by the sectors subject to a producer
responsibility. Their role is to implement the legal obligation in the name
of their Members. PRO’s are usually requested by law to establish self-
control mechanisms controlled by regular independent audits for both
their financial management and the quality of collected and reported
data. In the case of micro-pollutants, PRO would collect the required
funds based on their members’ declaration (quantities placed on the EU
market and toxicity). They would then finance wastewater operators for
more stringent treatment.
Primary
treatment
According to the UWWTD, ‘Primary treatment’ means treatment of
urban wastewater by a physical and/or chemical process involving
settlement of suspended solids, or other processes in which the BOD of
the incoming wastewater is reduced by at least 20% before discharge and
the total suspended solids of the incoming wastewater are reduced by at
least 50% (Article 2(7)).
Secondary
treatment
UWWTD definition: ‘Secondary treatment’ means treatment of urban
wastewater by a process generally involving biological treatment with a
secondary settlement or other processes in which the requirements
established in Table 1 of Annex I are respected (Article 2(8)).
Tertiary
treatment
More stringent treatment or tertiary treatment is the third stage of
treatment and can consist of nutrient removal, chemical or physical
disinfection. In the UWWTD, table 2 in Annex I lays down the
thresholds for nutrient reduction.
Toxic load
In the context of this IA an indicator of the toxic load was built on the
basis of a set of micro-pollutants found on the wastewaters (pollutant
quantity weighted by toxicity of individual substances more details are
provided in Annex 4.
PFAS
Per- and polyfluoroalkyl substances (PFAS) are a large family of
thousands of synthetic chemicals that are widely used throughout society
and found in the environment. They all contain carbon-fluorine bonds,
which are one of the strongest chemical bonds in organic chemistry. This
means that they resist degradation when used and also in the
8
environment. Most PFAS are also easily transported in the environment
covering long distances away from the source of their release.
PFAS have been frequently observed to contaminate groundwater,
surface water and soil. Cleaning up polluted sites is technically difficult
and costly. If releases continue, they will continue to accumulate in the
environment, drinking water and food (Source: ECHA).
PNEC
The ‘Predicted No Effect Concentration’ is the concentration of a
substance, below which exposure is not expected to cause adverse
effects. E.g., a concentration of a pharmaceutical for which no
pharmacological effect is expected to occur for a specific organism.
Separate
sewers
The UWWTD allows for the use of combined and separate sewers.
Separate systems: “New wastewater collection facilities are designed as
separate systems, carrying either domestic sewage or storm sewage but
not both. Storm sewers usually carry surface runoff to a point of disposal
in a stream or river. Small detention basins may be built as part of the
system, storing storm water temporarily and reducing the magnitude of
the peak flow rate. Sanitary sewers, on the other hand, carry domestic
wastewater to a sewage treatment plant. Pre-treated industrial
wastewater may be allowed into municipal sanitary sewerage systems,
but storm water is excluded.” (Britannica, 2019c).
Storm Water
Overflows
(SWO)
A footnote in Annex I to the UWWTD states ‘…during situations such
as unusually heavy rainfall, Member States shall decide on measures to
limit pollution from storm water overflows. Such measures could be
based on dilution rates or capacity in relation to dry weather flow or
could specify a certain acceptable number of overflows per year.’
As mentioned under combined sewers, these systems carry wastewater
and storm water. According to Britannica, ‘because wastewater
treatment plants cannot handle large volumes of storm water, sewage
must bypass the treatment plants during wet weather and be discharged
directly into the receiving water. These combined sewer overflows,
containing untreated domestic sewage, cause recurring water pollution
problems and are very troublesome sources of pollution.’ (Britannica,
2019b).
Surface water
Water Framework Directive definition: inland waters, except
groundwater; transitional waters and coastal waters, except in respect of
chemical status for which it shall also include territorial waters. (Article
2(1)).
(Total)
nitrogen
Total nitrogen is defined in the UWWTD as ‘the sum of total Kjedahl
nitrogen (organic and ammoniacal nitrogen), nitrate-nitrogen and nitrite-
nitrogen’. The UWWTD requires a reduction of total nitrogen in
9
wastewater discharges to concentrations of 15 mg/1 N (in
agglomerations with 10.000 – 100.000 p.e.) and 10 mg/1 N (in
agglomerations with more than 100.000 p.e.) (Annex I of the Directive).
Nitrogen is, together with phosphorus, one of the main nutrients in
wastewater. Nitrogen becomes ammonia/ammonium, creating an
additional oxygen demand. This can lead to excessive plant and algae
growth, which can then prevent other organisms from living and
growing.
(Total)
phosphorus
The UWWTD requires a reduction of total phosphorus in wastewater
discharges to concentrations of 2 mg/1 P (in agglomerations with 10.000
– 100.000 p. e.) and 1 mg/1 P (in agglomerations with more than
100.000 p.e.) (Annex I).
Together with nitrogen, phosphorus is one of the main nutrients in
wastewater. Phosphorus becomes ortho-phosphate, creating an additional
oxygen demand. This can lead to excessive plant and algae growth,
which can then prevent other organisms from living and growing.
Urban runoff
Urban runoff consist of storm water from city streets and private or
commercial properties that contains litter, as well as organic and
bacterial waste (EEA glossary). Depending on local conditions, urban
runoff can be collected in combined or separate networks.
Urban
wastewater
The UWWTD defines ‘urban wastewater’ as domestic wastewater on its
own or domestic wastewater mixed with industrial wastewater and/or
runoff rain water. (Article 2(1)).
Water
resilience
‘Resilience’ is the quality of being able to return quickly to
a previous good condition after problems. (Source: Cambridge
Dictionary). ‘Water resilience’ refers to those characteristics in a water
system (droughts, floods, water pollution).
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Abbreviations
Term or abbreviations Meaning or definition
AMR Antimicrobial resistance
BWD Bathing Water Directive
BOD Biochemical oxygen demand
COD Chemical oxygen demand
CJEU Court of Justice of the European Union
CSO Combined sewer overflow
DWD Drinking Water Directive
ECA European Court of Auditors
ECHA European Chemicals Agency
EEA European Environment Agency
E-PRTR European Pollutants Release and Transfer Register
EED Energy Efficiency Directive
EPR Extended Producer Responsibility
EQS Environmental quality standards
EU European Union
GHG Greenhouse gas
GWh Gigawatt hour
11
Term or abbreviations Meaning or definition
IAS Individual or other appropriate system
IED Industrial Emissions Directive
IPCC Intergovernmental Panel on Climate Change
JRC European Commission Joint Research Centre
MSFD Marine Strategy Framework Directive
N Nitrogen
ND Nitrates Directive
NVZ Nitrates vulnerable zones
OECD Organisation for Economic Cooperation and
Development
OPC Open Public Consultation
P Phosphorus
PFAS Perfluoroalkyl chemicals
p.e. Population equivalent
PNEC Predicted No Effect Concentration
PRO Producer Responsibility Organisation
RBMP River basin management plan
REACH Registration, evaluation, authorisation and restriction of
chemicals
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Term or abbreviations Meaning or definition
REDII Proposal of revision of the Renewable Energy Directive
RTC Real time control
SME’s Small and medium-sized enterprises
SSD Sewage Sludge Directive
SWO Storm water overflow
UWWTD Urban Wastewater Treatment Directive
WFD Water Framework Directive
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1. INTRODUCTION: POLITICAL AND LEGAL CONTEXT
The European Union adopted in 1991 the Urban Wastewater Treatment Directive
(UWWTD). The objective of this Directive is to “protect the environment from adverse
effects of wastewater discharges from urban sources and specific industries”. Member
States (MS) are required to ensure that wastewater from all agglomerations above 2.000
inhabitants is collected and treated according to minimum EU standards. Stricter
standards apply for ‘sensitive areas’ which have to be identified by MS according to
criteria included in the Directive – for instance in case of risk of eutrophication.
MS report every two years on the implementation of the Directive. This information is
published by the Commission in biennial reports. Across the EU, 21.708 agglomerations
generating wastewater equivalent to the pollution from 517 million population
equivalents (p.e.)1
are treated in centralised systems. Wastewater operators are either
private companies operating for a public competent authority or public companies owned
by the public competent authorities (around 60%) or mixed companies. Collection and
treatment of urban wastewater have improved over the last decade: 98% of the generated
load is appropriately collected, 92% meet the primary and secondary treatment standards
(basic treatment of organic pollution – see glossary), while another 92% meet more
stringent treatment standards (tertiary treatment removing Nitrogen and Phosphorus).
There are differences between MS – a limited number of MS still having difficulties to
reach compliance (Annex 7, Table 1).
The 2019 UWWTD REFIT Evaluation (hereby referred to as ‘the Evaluation’), which
entailed a comprehensive stakeholder consultation, confirmed that the Directive’s
implementation has caused a significant reduction of pollutant releases. The effects on
the quality of the EU lakes, rivers and seas are visible and tangible. The Evaluation also
identified remaining challenges which served as a basis for the definition of the problem
for this impact assessment (IA). MS supported the main findings of the Evaluation during
an Environment Council meeting as well as the European Parliament through a
Resolution focusing on the need to improve the energy balance of the sector. There is a
large consensus in the Council and the Parliament, as well as within the stakeholder
community, on the need to modernise the Directive and to better link it with the
European Green Deal (EGD) ambitions. Similarly, the European Committee of the
Regions agreed with the Evaluation findings, pushing for a revision of the UWWTD to
adapt it to new societal needs and urging the Commission to better apply the “polluter
pays” principle.
Since the publication of the Evaluation, the EU took important steps to set out its
ambitions with the adoption of the European Green Deal. The review of the Directive is
included as one of the actions of the Zero Pollution Action Plan (ZPA), in close
connection with a sound implementation of the Chemicals Strategy for Sustainability and
the Pharmaceuticals Strategy. There are direct connections with the Biodiversity Strategy
as reducing water pollution has a direct beneficial effect to ecosystems. Actions to green
the cities, such as those stemming from the upcoming Nature Restoration Law, can not
1
In this impact assessment, the standard unit to measure pollution is the ‘population equivalent’ (p.e.) – see
Glossary. For some pollutants (N, P and BOD) it is possible to convert p.e. into tons. The wastewater
treatment plants treat water mainly from inhabitants, but also from small enterprises or rain waters, which
explains why total number of covered p.e. is higher than the total number of EU27 citizens.
14
only create a good habitat for pollinators, birds and other species, but also directly help to
control rain water and related pollution, while improving the overall quality of life. Better
management of water quality and quantities in the urban areas will also contribute to
climate adaptation. The new Circular Economy Action Plan sets out that a better
integration of the urban wastewater sector with the circular economy is needed. This is
particularly relevant for the Sewage Sludge Directive (currently being evaluated), which
regulates the use of sewage sludge in agriculture and has implications for the Soil Health
proposal announced in the EU Soil Strategy for 2030.
Furthermore, the EU climate neutrality objective as included in the EU Climate
Regulation, combined with the Effort Sharing Regulation, requires MS to reduce their
GHG emissions according to national objectives from the sectors such as the wastewater
treatment sector which are not covered by the EU Emission Trading Scheme.2
At the
same time, the recent recast proposal of the Energy Efficiency Directive (EED) requires
MS to reduce their overall energy consumption by 9% by 2030 compared to 2020, while
including a specific target of 1,7% reduction each year of the energy consumption of all
public bodies. The EED also includes the obligation to achieve energy audits for
enterprises consuming large amounts of energy. As detailed in section 2.1.2.2, a large
part of the UWWT facilities would be excluded from this obligation. The 2021 proposal
for a revision of the Renewable Energy Directive (“REDII”) includes an objective of
40% of renewable energy in the energy mix by 2030. The Evaluation showed that the
wastewater sector has specific potential not only to reduce its own energy consumption,
currently amounting to around 0.8% of the overall EU energy use, but also to produce, in
a steady and reliable manner not dependent on weather variations, renewable biogas out
of sewage sludge next to offering well-suited locations for the production of renewable
energies (wind and solar). This sector-specific potential should be untapped, in line with
the recently adopted Repower EU Communication insisting on the need to accelerate
action for more affordable, secure and sustainable energy, including from biogas.
Over the past months it has become apparent that surveillance of different health related
parameters in wastewaters can provide useful information for public health purposes.
This was the case with SARS-CoV-2 virus and its variants monitoring in wastewaters,
used as a complementary approach to public health measures. To support the use of this
tool and enhance the early detection capacities across all MS the Commission published a
Recommendation and provided in 2021 financial support to 26 MS. Also in line with the
“A Europe fit for the Digital Age” Communication, the potential benefits of digitalisation
should be further explored as they are particularly relevant in the water sector.
The revision of the UWWTD is linked to the revision of the pollutants lists under the
Environmental Quality Standards Directive and the Groundwater Directive – two
‘daughter’ Directives of the Water Framework Directive (WFD), regulating the
acceptable levels of pollutants in surface and ground water bodies. It is also connected to
the revision of the Industrial Emissions Directive (IED) and the related review of the E-
PRTR Regulation, as some industrial emissions are collected in public collection
networks. It will have a positive impact on the ongoing review of the Marine Strategy
Framework Directive (MSFD) and on the review of the Bathing Water Directive (BDW).
These parallel revisions and reviews help to ensure that any coherence issues can be
resolved. N emissions to the environment are regulated both by the UWWTD (urban
2
The main interactions of this initiative with other ongoing initiatives are summarised in Annex 8.
15
pollution) and by the Nitrates Directive (N from agriculture) and, as recalled in the ZPA,
the revision of the UWWTD will support the concrete implementation of the future
Nutrient Management Action Plan. Over the last decades, the UWWTD has contributed
to achieving the Sustainable Development Goals (SDGs), in particular SDG 6 on access
to adequate and equitable sanitation and hygiene for all. Most MS have signed the 1999
UN Protocol on Water and Health, setting out requirement on access to sanitation. As
such, it contributes to achieving the commitments made under the European Pillar of
Social Rights Action Plan on access to essential services.
2. PROBLEM DEFINITION
2.1 What are the problems and their drivers?
In the Evaluation, three main sets of problems were identified, which are discussed in
more depth below together with their drivers:
1) Remaining pollution from urban sources (section 2.1.1);
2) Insufficient alignment of the Directive to new societal ambitions and the Green
Deal objectives (section 2.1.2);
3) Insufficient/uneven level of governance of the sector (section 2.1.3).
The stakeholder consultation3
showed a broad consensus on (1) the necessity to
undertake a revision of the Directive, and (2) the list of problems to be tackled in a
possible review. No other important issue emerged during the different consultations.
Overall, no major problems of coherence with other legislation were found in the
Evaluation, even if some adjustments might be needed as several Directives were
adopted after the UWWTD. This is further detailed in the ad hoc sections below.
2.1.1 Remaining pollution from urban sources – problem and drivers
The Evaluation provided a first quantification of the remaining sources of pollution not
optimally addressed by the Directive. This quantification was updated and fine-tuned
using the same model developed by the JRC for the Evaluation (see Annexes 1 and 4).
The Evaluation also pointed to the new types of pollutants requiring more attention (such
as micro-pollutants) having emerged since the adoption of the Directive.
At the time of its adoption the focus of the Directive was on organic pollution from
domestic sources emitted in usual (‘dry weather’) conditions and collected and treated in
centralised facilities, for which the requirements are clear and precise. Less attention was
given to rain waters, smaller agglomerations and individual appropriate systems for
which the requirements were kept more generic. The emissions from these sources have
progressively become equivalent to the releases from centralised facilities. This is
illustrated in modelling results presented in Table 1 and Figure 1 below showing the
remaining load of pollutants rejected in the environment from different sources. The total
initial load generated amounts to 708,8 p.e. Of this, 517 million p.e. is sent to centralised
wastewater treatment plants and 191,8 million p.e. is not collected and thus not treated in
centralised facilities (49,3 million p.e. is generated in small agglomerations, 16,5 million
in IAS and 126 million are coming from SWO/urban runoff.)
3
More details on stakeholder views are provided in Annex 2 and in Appendix F of the report 1 (Annex 10).
When divergent views amongst stakeholders were expressed, they are reported in the main text of this IA.
16
Figure 1: Remaining loads from urban sources (p.e./year) - Source JRC - see Annex 4.
Breakdown per MS is provided in Table A7.5 in Annex 7
The remaining load sent to the environment varies from one pollutant to another (from
66,2 million p.e. for BOD to 264 million p.e. for micro-pollutants). Part of this pollution
could be avoided. However, as shown in Table 1, with the maximum feasible scenario4
,
there are limits to what can be technically achieved: with the current techniques, it is
indeed impossible to remove and treat 100% of the load from the wastewaters (between
48% for BOD to 92% for E. Coli – could be removed - see line (5) in Table 1).
BOD (p.e.) Nitrogen
(p.e.)
Phosphorus
(p.e.)
E. coli
(p.e.)
Micro
pollutants
(p.e.)
(1) Remaining load from 191,8
million p.e. from SWO/urban
runoff, small agglo., and IAS
39.395.928 57.159.194 54.993.361 51.224.149 105.766.283
(2) Remaining load from 517
million p.e. sent to centralised
facilities after treatment
26.752.894 133.967.530 93.607.423 19.886.613 158.360.974
(3)Total remaining load (1) + (2) 66.148.823 191.126.725 148.600.784 71.110.762 264.127.257
(4) Remaining load if maximum
feasible treatment is applied
34.239.042 88.219.608 47.658.013 5.736.591 130.837.224
(5) % of the remaining load
which is ‘treatable’((3) –(4))/(3)
48,24% 53,84% 67,93% 91,93% 50,46%
Table 1: Remaining loads sent to the environment (p.e./year) - source JRC - see Annex 4.
More details are provided in Annex 7, Table A7.2 and Table A7.5 (details per MS)
2.1.1.1 Non-compliant agglomerations
Discharges from non-compliant agglomerations above 2.000 p.e. represent around
6,7% of the remaining load for BOD, 1,9% for Nitrogen (N), 7,78 % for Phosphorus (P)
and 7,4% for bacteria (E. coli). The Evaluation pointed out that the deadlines set in the
4
This scenario was built as a reference using all the available treatment techniques without taking into
account costs – see Annex 4 for more details.
- 50.000.000 100.000.000 150.000.000 200.000.000 250.000.000 300.000.000
BOD
Nitrogen
Phosphorus
E.Coli
Micro pollutants
Population equivalent per year
SWO Urban run off Non Compliant IAS
Compliant IAS Small Agglo Non compliant load
Remaining compliant treated load
17
Directive might have been overly ambitious for some MS. As explained in the
Evaluation, effective legal actions were taken by the Commission to ensure timely and
correct implementation of the Directive. More than 40 CJEU rulings were issued against
nearly all MS and 30 horizontal cases are still open today. Despite significant progress
accomplished by MS, implementing the Directive remains challenging in a limited
number of them (see Annex 7, Table 1).
The Evaluation showed that this is mainly due to the lack of institutional/administrative
capacity, combined to a lesser extent with insufficient financing capacities. At the same
time, some MS have managed to fully implement the Directive in a rather short time,
particularly MS having joined the EU after 2004. Such better performances are mainly
due to a proper organisation and planning of the required investments combined with a
sound financing strategy and the support of EU funds. These MS have also benefitted
from newest and more effective technologies compared to MS having invested in their
infrastructures after the adoption of the 1991 Directive.
2.1.1.2 Storm water overflow (SWO) and urban runoff
During rainfall events, storm water overflows (SWO- see Glossary) and urban runoff
represent a sizeable remaining source of loads sent to the environment: 19% of the
remaining load for BOD, 7,2% for Nitrogen, 9,5% for Phosphorus, 29,77% for E. coli
and 25,7% for micro-pollutants (see Figure 1). These emissions are expected to increase
due to the combined effects of urbanisation and progressive change of the rain regime
due to climate change. Most of this pollution takes place during a relatively short period
of time bringing suddenly, in the receiving water body, a peak of untreated pollutants
including waste and litters from the streets, such as plastics and micro-plastics (‘flushing
effect’). The Evaluation showed that part of this pollution is due to a lack of detailed
provisions in the Directive: in case of heavy rain, MS have indeed the possibility to send
directly to the environment part of SWO and urban run-off without any need for previous
treatment.5
Reporting under the WFD showed that at least 15% of UWWTPs above 10.000 p.e. are
in waterbodies failing to meet the WFD ecological status due to SWO pressure.6
According to a report from the EEA, the absence of proper management measures for
SWO and urban run-off combined with the increasing number of heavy rains events due
to climate change are the main reasons why the limit values of the BWD for bacteria are
exceeded in several EU bathing areas. The situation differs from one agglomeration to
another depending on the local conditions (rainfall patterns, density of population,
urbanisation green spaces), but also according to the performance of the
collecting/treatment system.
The Evaluation also showed that the lack of specific provisions in the Directive has led to
an uneven management of the issue across the MS (see Annex 5). Only very few MS
have put in place systematic integrated water management approaches in their cities: the
division of competences between services in charge of wastewater collection and/or
5
Annex I to the Directive states ‘during situations such as unusually heavy rainfall, MS shall decide on
measures to limit pollution from SWO. Such measures could be based on dilution rates or capacity in
relation to dry weather flow or could specify a certain acceptable number of overflows per year.’
6
it was not possible to assess the status of another 15% of UWWTPs.
18
treatment, urban planning, monitoring of water bodies quality, often represents an
obstacle for designing integrated, optimal and cost effective solutions.
2.1.1.3 Individual appropriate systems (IAS)
As seen in Figure 1 and Table A7.2 in Annex 7, the use of IAS contributes to 15,7% of
the remaining load for BOD, 7% for N, 8,6% for P, 16,1% for E. coli and 4,7% for
micro-pollutants. The Directive allows the use of these individual systems where
building a collecting system comes at disproportionate costs, and as long as these
systems achieve the ‘same level of environmental protection’ as in a centralised plant.
However, in the absence of more precise requirements, it is difficult to verify whether
IAS are conform or not. Also, some MS report high and non-justified use of IAS (Figure
2) in their agglomerations above 2.000 p.e. (more than 21% of the total load in Croatia).
Figure 2: Percentage of reported generated load treated by IAS in agglomerations above 2.000
p.e. in 2018, Source: Annex 10, report 7
There is a variety of requirements for IAS set at national level, with a few MS applying
best practices in terms of design, maintenance, monitoring and reporting (see Annex 5 for
more details). Some MS (such as AT, DE, NL, BE and FR) have put in place their own
national environmental standards to complete or replace the standards laid down under
the Construction Product Regulation (CPR) for smaller facilities below 50 p.e. The
multiplication of national standards has resulted in some degree of disruption of the
internal market – but also in some confusion, as the ‘CE marking’ under the CPR does
not relate to the environmental performances of the installations (source: Annex 10,
report 16).7
Under the March 2022 proposal for reviewing the CPR, wastewater treatment
would be excluded from the CPR scope. This will contribute to clarify the situation while
increasing the importance of developing environmental standards under the UWWTD.
7
The main reports used for this IA are referenced in the first part of Annex 10.
19
2.1.1.4 Small agglomerations
Small agglomerations are covered by the Directive only in a very general manner8
and
yet constitute a significant pressure on 11% of the EU’s surface water bodies (EEA): as
shown in Figure 1, around 24,9% of the remaining load for BOD, 15,8% for N, 18,9% for
P, 26,2% for E. coli and 9,7% for micro-pollutants. The situation varies across MS: some
MS like AT, DE, SE and FR have established in their legislation that all urban
wastewater needs to be treated. Other MS have set standards for smaller agglomerations
with a few, like EE, IE and PT, going beyond the requirements set out in the Directive.
2.1.1.5 Remaining releases from Nitrogen and Phosphorus
Despite the significant reduction of emissions achieved with the existing Directive for
Nitrogen and Phosphorus9
, wastewater treatment plants remain an important point
source of both N and P (see Figure 3). Released wastewater is a more important source
of P than fertilizers used in agriculture. N from urban wastewater is the second most
significant source of inputs into rivers and seas after agriculture.
Figure 3: Loads of N (tonnes/year) to EU regional seas by source (JRC).
As shown during the stakeholder consultation (see Annex 2), the problem is due to a
combination of two factors: (1) not enough areas were designated by the MS as
‘sensitive’ for eutrophication, and (2) the standards of the Directive for N/P are outdated.
Under Article 5.1 of the Directive, MS are required to designate ‘sensitive areas’ subject
to eutrophication and apply either more stringent standards for N/P for each facility or an
overall load reduction rate for N/P. The Evaluation showed that MS have applied the
Directive in different ways (see Figure 4) leading to some inconsistencies: for the same
river the designation might not be the same. It means that the efforts made by some MS
to reduce N/P are undermined by the lack of efforts by others. On the contrary, in the
Baltic Sea basin, for instance, coordination is ensured at regional level: the same more
stringent standards for N/P is applied for all incoming waters.
8
MS have to ensure ‘appropriate treatment’ from agglomerations of less than 2.000 p.e. (Article 7).
9
Emissions from treatment plants are reduced from 517 to 134 and 94 million p.e. for N and P.
20
From MS current practices10
, it appears that emission limit values in the Directive for
N/P could be reinforced: several MS (DE, AT, NL, HU and DK) are achieving better
performances than those prescribed by the minimum requirements of the Directive.
N and P releases are directly contributing to eutrophication (see Glossary) which
remains an important problem in several rivers, lakes and seas in the EU. According to
the EEA assessment, there are significant impacts from nutrient pollution on 426.267 km
of rivers and 19.460 km2
of lakes across the EU. According to a recent report on the
implementation of the MSFD, eutrophication occurs in the Baltic and the Black Seas,
along the North-western coast of France within the North-east Atlantic Ocean and along
coastal areas mainly in the vicinity of riverine outflows within the Mediterranean Sea.
Figure 4: Overview of sensitive areas and their catchments in the EU (2016) - Article 5(2-3):
more stringent treatment > 10.000 p.e.; Article 5(4): 75% removal of N and P; Article
5(8): more stringent treatment on the whole country, Source: Annex 10, report 7.
2.1.1.6 Micro-pollutants and Micro-plastics
As shown in the Evaluation, the scientific community, policy makers and general public
consider the growing evidence of micro-pollutants and micro-plastics in water bodies
10
More details on the starting position of each MS are provided in Annex 5 but also in Annex 4, Table
A4.5 and Annex 7, Table A7.5
21
an increasingly important issue. The need for action was also highlighted in the
Commission’s recent strategies.11
Micro-pollutants arise from the use of many products in households. Pharmaceuticals
and to a lesser extent Personal care products (PCP) represent a large share of the
potentially harmful substances found in wastewater (see report 2, Annex 10). The toxic
load (see glossary) corresponding to 264 million p.e. is emitted to the environment, part
of it (158 million p.e.) coming from centralised treatment plants, the rest being emitted
by other sources (see Table 1 and Figure 1). Part of these emissions are taking place in
rivers with a relatively low dilution rate, leading to higher risk of toxicity: the outlet of
around 115 million p.e. are emitted in rivers with a dilution rate lower than 5 (Source:
JRC, Annex 10, reports 13 and 14). Their accumulation in the environment and the
creation of ‘hot spots’ with low dilution rates are becoming a serious environmental and,
in some instances, public health concern, notably where the downstream waters are used
for bathing or for extracting and producing drinking waters.12
As shown in the Evaluation and in Figure 5, micro-pollutants are now detected in all EU
waters. The cumulative effects of these substances, notably in fish communities, were
already shown on several occasions: fish exposed to micro-pollutant residues may change
their behaviour, harming their survival abilities, or even change sex, harming their
reproduction abilities and fertility rates.
Figure 5: Number of pharmaceuticals detected in surface, ground or drinking water. Source:
Aus der Beek et al., 2015
These findings were confirmed by a 2022 study on pharmaceutical pollution (US
National Academy of Science) based on samples from 1.052 locations in 104 countries
from all continents. 25.7% of the samples included at least one pharmaceutical in
concentration higher than what is considered safe for aquatic organisms. According to
this study, ‘pharmaceutical pollution poses a global threat to environmental and human
health, as well as to the delivery of the United Nations Sustainable Development Goals’.
Plastics and Micro-plastics: Most of the micro-plastics found in the domestic
wastewaters directly stem from the use of textiles (micro fibres emitted during the
washing of clothes). They also come from the degradation of tyres on the roads or from
the uncontrolled use of plastic pellets in plastic production, when wastewaters are mixed
11
Including the Plastics Strategy, the Strategic Approach to Pharmaceuticals in the Environment, the
Chemical Strategy, the Zero Pollution Action Plan.
12
Additional treatment is applied for the production of drinking water. In line with the revised Drinking
water Directive, all efforts should be done to reduce sources of pollution at source
22
with rain waters (source Annex 10, report 3). The recently adopted Textile strategy as
well as the upcoming EU initiative on Micro-plastics are expected to reduce micro-
plastics emissions from these sources. As a result, less micro-plastics from these sectors
should over time be found in incoming waters of the urban wastewaters treatment plants.
Currently, when collected and sent to centralised treatment facilities, nearly all large
pieces of plastics are removed at the beginning of the treatment process. Also micro-
plastics are relatively well captured in the treatment plants – 80,5% with a primary
treatment, 97,5% with a secondary treatment and 99,2% with a tertiary treatment (Annex
10, report 8). Significant amounts of (micro) plastics can be released in the environment
in case of heavy rains (see previous section 2.1.1.2). It thus remains crucial to secure that
appropriate measures are put in place in order to cater for SWO/urban run offs.
The captured micro-plastics are partly degraded in the treatment plants. A recent Swedish
study show that about 40-60% of the micro-plastics in the incoming wastewater were
found in the sludge. This is confirmed by another recent Norwegian study: over 500
billion micro-plastic pieces are released each year into the environment via sludge use on
the soils. As half of the sludge is used agriculture in the EU (see Figure 8 below),
attention should be given to the presence of micro-plastics in the sludge and then in the
soils.
Micro-plastics biomedia (micro pieces of plastics used in very specific treatment
process) are also used in a limited number of wastewater treatment plants (0,1% in
France in 2016). According to a report from the Surfrider foundation, significant amount
of micro-plastics were found under the stream of such wastewater plants.13
2.1.1.7 Non domestic releases
Treatment plants covered by the UWWTD, although designed to treat ‘domestic
wastewaters’, also receive other types of waters including industrial wastewaters, mainly
from SMEs. These wastewaters can include a range of pollutants not targeted by the
Directive such as heavy metals, micro-pollutants or other chemicals. Wastewater
operators are in the first line when harmful releases are not controlled enough.
Under Article 11 of the Directive, industrial releases in the public network are subject to
pre-authorisation and, if required pre-treatment. Releases to water from the larger
installations regulated by the Industrial Emission Directive (IED) are already subject to
authorisation requirements. As detailed in the Impact Assessment (adopted by the
College on 5 April 2022) on the review of the IED, there is a need to better align the IED
and the UWWTD to avoid the release of pollutants not abated in urban treatment plants
into the public network. When it comes to releases from smaller installations not covered
by the IED, the consultation showed that the regulatory approach, the level of control as
well as the degree of involvement of wastewater operators in the permitting process
differ from one MS to another (see Annex 5).
Since the UWWTD entails no requirement for monitoring and reporting on such non-
domestic pollution entering the wastewater treatment plants, it is difficult to provide a
quantification of this issue. The current lack of understanding prevents additional actions
13
notably in FR, PT, ES but also in Switzerland.
23
to reduce pollution at source notably through stricter permits and better control of
industries connected to the public network.
2.1.2 Alignment with Green Deal, new societal challenges - problems and drivers
Since the adoption of the Directive, new societal challenges have emerged. The European
Green Deal (EGD) sets ambitious policy objectives to fight climate change and
environmental degradation. The below listed topics are the most relevant aspects of the
EGD to which the UWWTD needs to align.
2.1.2.1 Green House Gas emissions
In 2018, wastewater treatment was responsible for 34,45 million tons CO2e/year - around
0,86% of the total GHG emissions of the EU including 4% of methane (CH4) and 3% of
Nitrous Oxide (N2O) emissions (source: Annex 10, report 9). GHG emissions are specific
to each facility and the type of treatment applied. As shown in Figure 6, 14,1 million
tons CO2/year are due to carbon footprint of the infrastructures (mainly sewer networks).
Another 3,98 million tons is due to rejected effluents and further degradation of the
remaining load. A last part – 3,34 million tons - is linked with the use of inputs produced
by other industries, such as chemicals used for the treatment. These emissions cannot be
avoided with measures in the wastewater sector.
The remaining and avoidable GHG emissions (13,03 million tons) are related to
operational activities: use of energy (electricity) for the collection and treatment of
wastewaters (4,6 million tons) and emissions linked with the treatment process (8,4
million tons – diffuse emissions of N2O in the process). The potential impacts of the
existing or forthcoming EU legislations on GHG emissions is discussed in section 5.1 on
the baseline.
Figure 6: Breakdown of GHG emission from wastewater sector – EU 27, source JRC 2022, ref
in Annex 10, report 9
2.1.2.2 Energy use
As shown in Figure 7, there are large differences between operators in terms of energy
use depending on the size of the facilities and the technologies in place. Overall, the
wastewater sector is using about 0,8% of the total EU energy consumption. This comes at
high expenses: around €2 billion per year representing between 25% and 56% of the
- 5.000.000 10.000.000 15.000.000
Infrastructures
Effluents
Process
Energy use
GHG emissions - Waste Water (EU 27, tons
CO2e/year)
24
operational costs (source: Annex 10, report 1). Despite the significant potential, there is a
poor uptake of energy efficiency and renewable technologies in the sector. The
Evaluation showed that, apart from some advanced MS (see Box 1), there is a lack of
understanding of the potential to reduce energy use or even produce energy partly due
the absence of systematic energy audits for the wastewater treatment plants but also at
the level of the collecting networks.
Figure 7: Annual electricity used vs size of treatment plants, source: Ganora et al, 2019
The recent proposal to revise the EED, tabled by the Commission as part of the “Fit for
55” package, entails the requirement, for large enterprises consuming more than 10 tera-
joules/year, to be subject to energy audits. Most of the wastewater treatment plants would
however not be covered by this new obligation, as the average energy consumption of
large wastewater facilities of 100.000 p.e. amounts to 7,2 terajoules/ year (or 2Mw/h).
The REFIT evaluation has shown the lack of understanding of the sector on the potential
energy savings in the treatment facilities and to a certain extent in the collecting systems.
2.1.2.3 Sludge and water re-use
Sludge reuse in agriculture is governed by the Sewage Sludge Directive (currently under
evaluation). The UWWTD contains limited provisions on sludge reuse or recovery14
. The
Evaluation concluded that, currently, sludge management is not optimal and not aligned
with the principles of the circular economy: today about half of the sludge is reused in
agriculture while another large part is being incinerated or landfilled representing a clear
loss of valuable resources, including Phosphorus (see Figure 8).
A joint seminar was organised on sludge management in the context of the ongoing
Evaluation of the SSD and of this IA. It confirmed that, over the past years, some MS
have heavily restricted the use of sludge in agriculture on public health grounds (DE, AT,
NL, BE), while others do use it extensively. Without additional action to limit pollution
at source and improve sludge control before its use in agriculture, there is a risk that this
trend increases in the coming years. Phosphorus could also be easily recovered from the
ashes of mono-incinerated sludge, but this is not yet current practice in most MS.
14
MS are ‘incentivised’ to re-use sludge and ‘minimise the adverse environmental effects’ (Article 14).
25
Figure 8: Sewage sludge reuse in EU-28 in the period 2012-2016 (% of sewage sludge reused
in soil and agriculture – source: Annex 10, report 7)
Water reuse after treatment in wastewater facilities should also be better incentivised: in
2015, according to the impact assessment on the Water Reuse Regulation, only 2,4% of
the treated wastewater was reused. In the aggravating climate change context leading to
more frequent instances, across the EU, of droughts and water scarcity, the entry into
application, in 2023, of that new Regulation creates further incentives to reuse water.
2.1.2.4 Health and wastewaters
Today there is lack of understanding of the added value of accurate monitoring of public
health relevant parameters in urban wastewaters. This is partly due to the absence of
systematic dialogue and coordination between public health and wastewater authorities.
The COVID-19 pandemic has revealed the added value of tracking the virus and its
variants in wastewaters. Such surveillance helps to anticipate and follow the
dissemination of the virus into the population. Today, with the financial support of the
EU and in line with the 2021 Commission Recommendation on Covid 19, 26 MS have a
surveillance infrastructure in place. Other types of health parameters could be monitored
in the wastewaters as a complementary and reliable indicator of the public health state of
the population.
Antimicrobial Resistance (AMR – see glossary) is a major human-health threat
aggravated by the fact that, for the time being, there are no alternatives to antibiotics.
Wastewater treatment plants are a potential entry point of antimicrobial-resistant genes
and organisms in the environment. Treatment plants may contribute to the removal of
AMR from the effluents. There is no obligation to monitor and remove AMR, neither at
the outlet of the treatment facilities nor in the receiving water bodies.
2.1.3 Modernisation and Governance - problem and drivers
Like drinking water operators, wastewater operators are part of a ‘captive’ market: both
citizens and businesses connected to the public network cannot choose their operators.
The Evaluation and the consultation process confirmed that the wastewater sector is
mainly reactive to legal requirements. Most competent authorities are implementing
only the minimum requirements of the Directive. There are indeed few incentives to ‘do
26
better’ beyond such legal requirements, as doing more usually entails additional costs, to
be covered by water tariffs or further budgetary expenditures. Some MS apply more
stringent standards, for instance when it is necessary to meet the objectives of other
relevant legal obligations such as the Bathing, Drinking and Water Framework
Directives, but this is not systematic (see Annex 5).
2.1.3.1 Operators’ performances and transparency
A recent OECD analysis (Annex 10, report 6) showed differences in terms of
performances between operators in relation to energy efficiency, GHG emissions, social
and economic governance, operational aspects (see Figure 9). Some of these differences
can be explained by different operating conditions (facilities size, climatic/geographical
conditions). Others can only be explained by a sub optimal management due to lack of
real incentives (‘captive’ market) and/or a lack of technical skills in fragmented utilities.
Figure 9: Operational costs – EU wastewater operators – OECD (2022), Annex 10, report 6
The level of transparency also differs from one operator to another: some operators are
providing detailed information either on the bills, on their web sites or via apps not only
on their level of performance but also on the main elements included in the water bills.
This uneven level of access to information prevents an equal empowerment amongst EU
citizens. Respondents to the OPC indicated the need for receiving more information.
2.1.3.2 Uneven application of the ‘polluter pays’ principle
The lack of the application of the “polluter pays” principle in the water sector was raised
in a recent report for the Court of the Auditors. In order to cover the costs related to the
implementation of the Directive, MS are using a mix of public budget and water tariffs.
27
Many relied, and some still rely, on EU funding to build up the initial infrastructure.15
As shown in Figure 10, public budget covers around 30% of the expenses for water
supply and sanitation – the rest (70%) is covered by water tariffs. Water tariffs are
usually covering both water supply and sanitation: on average wastewater collection and
treatment account for about 60% of the water bill although drinking water represents
40%.
There are large differences between MS: some MS like DK or FI are nearly at full cost
recovery through water tariffs. In these MS, the ‘polluter pays’ principle can be
considered as respected for households connected to the public network. This is however
not the case in other MS, such as IE, LU or CY, where less than 22% of the overall costs
is covered by water tariffs (source: OECD, see Annex 10, report 5). According to OECD
(see also Figure 19), affordability is not a major issue in the EU. The effects of
additional requirements set at EU level should nevertheless be carefully analysed.
Contrary to households, the ‘polluter pays’ principle is not applied for non-domestic/
industrial pollution gathered in public networks: so far there is no mechanism to make
industrial producers financially responsible for the water pollution generated by the
products they place on the EU market. This is the case for instance for pollutants of
emerging concern such as micro-pollutants or micro-plastics partly collected and treated
in the wastewater treatment plant without any support from the producers/importers.
Figure 10: Sources of financing for water supply and sanitation services – EU 28, Source:
OECD (2020) – ref in Annex 10, report 5
2.1.3.2 Not adapted monitoring and reporting
Monitoring requirements set in Article 15 of the Directive have proven effective to drive
compliance. However, technological advances allow today for more efficient and
accurate monitoring of both existing and emerging pollutants. Information gathered from
MS in the context of this IA (Annex 5) shows that there are large divergences among MS
in terms of monitoring. Most MS are already collecting more frequent and broader
information on more pollutants than what is required by the Directive.16
Yet, the
knowledge on the quality and quantity of wastewaters is insufficient in many instances.
Several cases of over dimensioning of facilities but also storage capacities to reduce
SWO and urban runoff, leading to excessive costs and inefficient water collection and
treatment, could have been avoided with a better understanding of the actual load to be
treated.
15
Since 2000, € 38.8 billion of cohesion policy funding was allocated to wastewater
16
For example, the Directive requires only a very limited number of samples even for large facilities.
0% 20% 40% 60% 80% 100%
EU-13
EU-15
EU-28
Public budget Revenues from water tariffs
28
Reporting requirements17
set by the Directive could be improved and modernised to
ensure a better enforcement of the Directive. Some provisions are by now outdated. This
is the case for the bi-annual Commission report required under Article 17: while today
most data are accessible in real time, these reports are published few years after the
actual monitoring. Also, precise data with the numerical values are available in all MS
although only ‘passed/failed’ values are reported. At the same time, the Directive does
not request reporting on some key data for instance on remaining sources of pollution.
The bi-yearly requirement to produce national implementation programs under Article 17
might be excessive for those MS which have reached 100% compliance with the
Directive. This information remains on the contrary indispensable for the other MS:
having a proper investment planning combined with a financing strategy is key to
achieve full compliance. Also, the information requested under Article 17 is not fully
consistent with the ‘enabling condition’ for EU funding under the Cohesion Policy.18
2.1.3.2 Insufficient access to sanitation
Access to sanitation remains an issue preventing the EU to fully implement SDG 6 and
its objective of ensuring ‘access to adequate and equitable sanitation and hygiene for all’:
the Directive does not require MS to guarantee access to sanitation. In the EU, according
to Eurostat, approximately 2% of the population have no access to an indoor flushing
toilet. Around 10 million people living in the EU still lack access to sanitation services
(EC, 2020). According to EU statistics, 10 to 12 million Roma people are living in
Europe, 2.6 million refugees, and 700.000 people sleeping in the rough every night.
During the consultation it appeared that the problem can be split in 3 parts: 1) vulnerable
and marginalised people such as homeless ones having no or poor access to sanitation; 2)
people living in rural areas with a lack of flush toilets and other sanitation facilities; and
3) cities with insufficient access to public sanitation facilities.
2.2 How likely is the problem to persist?
The Evaluation has shown that the ‘carrot and stick’ (combination of enforcement and
support notably with Regional funds) approach followed by the Commission to ensure
the implementation of the Directive has paid off. It had helped to progressively ensure
high levels of compliance with the Directive. Yet, in the absence of EU rules combined
with possible renewed ways of funding the necessary measures, only poor progress can
be expected at EU level in controlling remaining pollution from remaining urban sources,
such as SWO and urban runoff, releases from smaller agglomerations, N/P or micro-
pollutant releases. Information collected for this IA (see Annex 5) shows that only
limited or uneven progress were achieved to limit pollution from these sources.
Urbanisation is expected to progressively modify the needs of wastewater collection and
treatment: in line with OECD predictions, the trend of urbanisation - people leaving rural
areas to move in urban areas - will continue in the coming years which will have an
effect on soil sealing, in turn potentially inducing more urban floods and SWO. These
impacts might be mitigated by the implementation of the Biodiversity and the Soil
Strategies. Ageing population will lead to an increased use of pharmaceutical products
17
According to the Directive, MS have to notify to the Commission every two years ‘situation reports’
(Article 16) but also their national ‘programme for the implementation of the Directive’ (Article 17).
18
Enabling conditions for water consist in establishing national investments plans for the water sector.
29
but also to a higher demand for security and control of health risks. With the effects of
climate change already seen on rainfall regimes, more frequent heavy rains are expected
which will exacerbate the problems linked with SWO and urban runoff.
No major new technological developments are expected in the coming years for the
‘classical’ treatment processes of wastewater. However, digitalisation, permanent
automated monitoring and instrumentation, control and automation (ICA) are
expected to help in better managing the collection, storage and treatment of wastewater,
notably for what relate energy use and related GHG emissions. It could also help to avoid
building larger infrastructures, for instance to tackle the issue of SWO and urban runoff,
by optimising the infrastructures in place. Digitalisation will also help rationalise and
simplify reporting from the local/national authorities to the EU. New testing techniques
have the potential to change monitoring and assessment practices and costs in the future.
Instead of testing for the presence of hundreds of potentially harmful substances, effect-
based monitoring would allow for more targeted monitoring and control measures. This
might be particularly relevant, for instance, for micro-pollutants.
In the absence of obligation of energy audits, the lack of understanding of potential for
implementing energy saving measures and, to a lesser extent, for producing renewable
energies and biogas is expected to persist. Technological developments and experience
gained across some MS (see Box 1 below) show that there is a potential for the
wastewater treatment sector to become ‘energy neutral’ (see section 5.2.7).
3. WHY SHOULD THE EU ACT?
3.1 Legal basis
The current UWWTD is based on Article 192(1) of the Treaty on the Functioning of the
European Union (TFEU), which states that “Union policy on the environment shall aim
at a high level of protection taking into account the diversity of situations in the various
regions of the Union. It shall be based on the precautionary principle and on the
principles that preventive action should be taken, that environmental damage should as a
priority be rectified at source and that the polluter should pay”. Action in the field of
wastewater management must therefore be taken according to these key provisions and in
the respect of the shared competence with the MS. This means that the EU can only
legislate with due consideration for the principles of necessity, subsidiarity and
proportionality.
3.2 Subsidiarity: Necessity of EU action
The Evaluation confirmed the added value of the Directive and found that EU action was
and is necessary to achieve a high level of environmental and human health protection
via a sound wastewater management, as the vast majority of MS would have not
achieved the same results on their own. This is confirmed by the results of the OPC
suggesting that continued action from the EU is considered necessary to ensure further
progress. The incentive to reinforce and improve the level of environmental and health
protection linked to wastewater management is indeed limited as it is directly linked with
additional costs for operators, users and/or national budgets. As explained above, the
wastewater sector is mainly responsive to EU legislation on which national legislation is
based. Without EU intervention, only modest new progress is expected.
30
Transboundary rivers cover 60% of the EU – the impacts of discharges in one MS will
directly affect the environment in other MS. It is therefore indispensable to ensure
simultaneous efforts in all MS with a same level of standards for wastewater collection
and treatment. That will avoid that efforts made by some MS are partly jeopardised by
the lack of investments in others MS. Such an approach cannot be ensured at MS level
alone.
The Evaluation also confirmed that the EU action has ensured and has a potential to
further ensure an equal level of environmental and human health protection across all
Member States. More than half of respondents to the OPC across all stakeholder
categories rated the risk perception of pollution from untreated wastewater as a
significant concern. There was consensus among respondents on addressing all
contaminants listed in the survey (corresponding to the pollutants addressed in this IA).
Over the last 30 years of implementation of the UWWTD, the quality of bathing water
sites (hence tourism and recreation), raw water used for the production of drinking water
and of water bodies in general has been either preserved or, in several instances,
improved (see section 5.1 of the Evaluation of the Directive). Similarly, making sure that
key health parameters are tracked in wastewaters will increase the health protection of
all EU citizens. Improving access to sanitation but also empowering all EU citizens by
ensuring an equal access to information should be ensured: the Evaluation has shown
large differences among EU citizens, from that perspective. All MS are facing the
consequences of climate change notably on their hydrological regimes and urban micro-
climate. Similarly, pollutants of emerging concern such as micro-pollutants or micro-
plastics are present in all MS. This is also the case for most of the remaining loads from
urban sources which affect water quality in all MS. Also, the drivers for the identified
problems are very similar from one MS to another.
3.3 Subsidiarity: added value of EU action
As shown in the Evaluation, EU action remains essential to ensure that benefits from
improved water quality of the EU rivers, lakes, ground-waters and seas are optimised.
Experts consulted as part of the evaluation agreed on the decisive role that the UWWTD
had in establishing collection and treatment infrastructures. EU action ensures that water
bodies benefit from the same level of protection at the same time. Without EU action,
part of the efforts made by some MS at national and local level could be overridden by
lack of progress of the others. This is valid not only for transboundary water bodies but
also inside MS as, for most of them, the Directive was the key driver for investing in the
required infrastructures.
The Evaluation showed that EU standards were a crucial driver for the development of a
globally competitive EU water industry. Since the adoption of the Directive, several
major worldwide leaders in the field of wastewater treatment have been created and are
exporting their services all around the world. Further modernising the EU standards, for
instance with new requirements on micro-pollutants or energy use would further
stimulate innovation and ultimately economies of scale. This is also the case if, in line
with the objectives of the Green Deal and the EU Climate Law, common efforts are taken
to improve energy efficiency, develop renewables and produce more biogas in the sector.
Establishing new rules in application of the “polluter pays” principle particularly for
micro-pollutants should be done at EU level to avoid market distortion. Also, given the
multiplication of national standards (see section 2.1.1.3), adopting EU standards for IAS
31
will limit barriers to the internal market. Ensuring harmonised approaches for the
remaining loads identified in section 2.1 will help develop common approaches, favour
the development of new skills and new markets. For instance, applying best practices at
EU level for storm water overflows and urban runoffs would lead to better urban
planning, the development of nature-based solutions, full use of digitalisation and
optimisation of existing infrastructures. This will require new competences and create
new market opportunities. This is also the case for other aspects such as energy and GHG
reduction.
The recent pandemics has shown the interdependence of the MS in terms of virus
circulation. Ensuring an effective, rapid, and harmonised tracking of pathogenic factors
in wastewaters can benefit the whole EU. Without EU harmonised and integrated action,
the possibilities of tracking new types of viruses but also of surveying other relevant
health parameters in wastewaters would only be achieved in a few, most advanced MS.
4. OBJECTIVES: WHAT IS TO BE ACHIEVED?
4.1 General objectives
The main objective of the initiative is to contribute, in an effective and efficient way, to
protecting the environment and human health from the adverse effects of urban
wastewater discharges. The aim is to modernise the legislation by adapting it to current
and future societal needs while adapting it to the objectives of the European Green Deal
and of a Europe fit for the Digital Age. There was a broad consensus amongst the
stakeholders regardless their background on the key objectives for this review. The
Evaluation highlighted that, according to business and WWTP operators, the Directive
does not sufficiently deal with resource recovery and emerging pollutants. Stakeholders
also insisted on the necessity to give predictability to the sector with clear legal
requirements for the next decades – so that the necessary investments can be planned on
due time.
The planned EU intervention would have two main general objectives:
1. To protect EU citizens and ecosystems from the remaining sources of insufficiently
treated wastewater;
2. To provide a predictable framework for the sector, improve its transparency and
governance and align it to “a Europe fit for the Digital Age”;
and two complementary objectives:
3. To align the sector to the objectives of the Green Deal and the recently adopted
Communication ‘Repower EU’, regarding in particular the 2050 goal of climate
neutrality in synergy with the ESR, transition to circular economy, zero pollution and
a restoration of biodiversity;
4. To use wastewater health related parameters as a support for public health and to
improve ‘adequate and equitable sanitation and hygiene for all’ in line with SDG 6.
4.2 Specific objectives
The following achievements should be met in an effective and efficient way:
In relation to objective 1:
32
 Contribute to identifying and then preventing pollution reaching wastewater
treatment plants with particular attention to pollutants difficult to treat in these plants;
 Further reduce pollution from the ‘remaining sources’ (storm water overflows, urban
runoff, smaller agglomerations and IAS);
 Further reduce nutrient (N and P), micro-pollutants and micro-plastics pollution from
urban sources;
 Reinforce the coherence with key EU water legislations (such as the Bathing Water,
Water and Marine Framework Directives and the Drinking Water Directive);
 Encourage investment and innovation in wastewater management.
In relation to objective 2:
 Ensure high level of transparency and access to information;
 Ensure that investments are taking place ‘where it makes sense’ for environmental or
health reasons (based on clear criteria);
 Promote a solid financing strategy while ensuring affordability of water tariffs and
better applying the ‘polluter pays’ principle besides household users;
 Modernise, simplify and adapt monitoring and reporting obligations.
In relation to objective 3:
 Move towards energy neutrality of wastewater sector;
 Create the conditions for increasing water reuse and better managing sludge and
waste, in close synergy with the new Water Reuse Regulation, the Sewage Sludge
Directive and the EU waste acquis.
In relation to objective 4:
 Improve access to sanitation particularly for vulnerable and marginalised people;
 Ensure that health relevant information from wastewaters is fully used;
 Improve the dialogue between health and wastewater competent authorities;
 Better monitor the spreading of AMR in wastewaters and prevent its dissemination.
Two main trade-offs between these objectives will require particular attention: (1)
additional treatment for micro-pollutants will require more energy and, if this energy is
coming from non-renewable sources, this will entail more GHG emissions; (2) increasing
our understanding on some key sources of pollution as well as on some key indicators
will require additional efforts and might increase the administrative burden related to
monitoring and reporting. At the same time, there is a potential to simplify some of the
current requirements. These aspects are further discussed in sections 5 and 6.
Respondents to the OPC provided clear indications on the main objectives and topics the
revised legislation should address. Better implementing the polluter pays principle
was indicated as the most important topic, followed by promoting the monitoring of
industrial releases into urban wastewater, reducing nutrient discharge into water bodies,
and dealing with SWO and urban run-off through an integrated approach. All are
addressed in the specific objectives set for the intervention.
33
The relation between the problems, their drivers, the objectives and the options are
summarised in Figure 11 below although more details on the relation between the
problems, drivers, options and their contribution to specific objectives is provided in
Figure 14 below.
34
Figure 11: Links between drivers, problems, objectives and options
Drivers Problems Objectives Options
Climate change and
urbanisation
Increasing pollution from
SWO/urban runoff To protect EU citizens
and ecosystems from
the remaining sources
of insufficiently
treated wastewater
To align the
wastewater sector to
the objectives of the
Green Deal (climate
neutrality in 2050,
transition to circular
economy, zero
pollution and
restoration of
biodiversity)
To provide a
predictable
framework for the
sector, improve its
governance and full
use of digitalisation
To improve access to
sanitation and to use
wastewater health
related parameters to
prevent and manage
public health issues
SWO and urban runoff
 Set of measures applied from large agglomerations above 100.000 pe
(low ambition) to lower agglomerations 10.000 pe (high ambition)
 Measures includes integrated management plans and monitoring
Small agglomerations
 Review of the threshold (from 500 to 1.000 pe)
Individual Appropriate System
 Better control of the IAS combined with EU clear standards
Nutrients
 Set of options from low ambition (N/P removal applied only to facilities above 100.000 pe) to
high ambition (N/P removal above 10.000 pe combined with stricter standards for N/P removal)
 Clarified criteria for designating sensitive areas
Micro-pollutants
 Set of options from low ambition (micro-pollutant removal applied only to facilities above
100.000 pe) to high ambition (all facilities >10.000 pe)
 Medium option based on risk assessment (dilution rates)
 Application of the Extended Producer Responsibility
Non domestic emissions
 Improved monitoring of incoming waters in the treatment plants
GHG and Energy
 Energy audits and monitoring
 Energy neutrality by 2040 leading to GHG emission reduction
Governance
 Monitoring performance indicators
 Increased transparency for water users
Monitoring & Reporting
 Digital monitoring/reporting
 Adaptation of monitoring requirements to remaining sources of pollution
 Simplified reporting
Access to sanitation
 Identification of marginalised and vulnerable people
 MS to improve access to sanitation
Health
 Sampling & analysis COVID-19 and its variants/AMR
Small agglo out of the
Directive, unclear requirements
and unjustified use of IAS in
large agglo
Remaining pollution from
small agglo and non-
compliant IAS
Unclear criteria for ‘sensitive
areas’ and outdated standards
for N & P
High level of N & P releases
leading to Eutrophication
Ageing population and
Increasing use of
pharmaceuticals and personal
care products
Increasing releases of micro-
pollutants
Insufficient control of non-
domestic pollution
Poor actions to reduce
pollution at source, limited
sludge/water reuse
Poor awareness/understanding
on GHG emissions and energy
potential savings
High energy use with high
costs and high GHG
emissions
Captive market, no incentives
to ‘do better’
Diverging operator
performances
No tradition of producer
responsibility schemes for
water pollution
Insufficient application of the
‘polluters pays principle‘
Inadequate monitoring Lack of knowledge on
remaining sources of
pollution, poor data on actual
performances
Non digitalised reporting Outdated reports, admin
burden
Access to sanitation not in the
scope of the Directive
Poor access to sanitation for
some EU citizens contradict
SDG 6
Poor coordination between
public health and wastewater
competent authorities
Under use of health
indicators (notably on Covid
and Anti- Microbial
Resistance - AMR)
35
5. WHAT ARE THE AVAILABLE POLICY OPTIONS?
5.1 What is the baseline from which options are assessed?
The baseline scenario implies the progressive achievement of full compliance by all MS.
In designing the baseline, it is assumed that the identified problems would remain,
although their scale would be impacted by external trends such as urbanisation, changes
in demographics, changes due to climate impacts (e.g. more intense rains and storms), the
development of new technologies (see section 2.2). The ‘domestic’ pollution (BOD, N
and P, E. coli) is expected to remain globally stable as it is mainly linked to the evolution
of the population connected to the network: EU population is expected to slightly
increase (0,2%) by 2035 and then decrease (1,36%) by 2050.19
These changes do not
require a significant adaptation of the usually slightly oversized infrastructure. At the
local scale, though, there might be needs for adjustment.
EU actions to limit pollution at source might have an effect on the other (‘non domestic’)
pollutants reaching treatment plants and on the quality of the sludge produced afterwards.
The impacts might be significant for some substances in case they are fully banned from
the EU market.20
Progress is also expected from the implementation of the 2020
Chemical, Pharmaceutical Strategies and the 2021 Zero Pollution Action Plan. This
progress is however difficult to quantify at this early stage. In any event, actions will be
required both at source and in wastewater treatment plants, for instance to prevent micro-
pollutants to reach receiving waters. Several measures are also envisaged to reduce
micro-plastics at source – see Annex 10, report 3. In the absence of final decisions, at this
stage, on their exact extent, it has not been possible to quantify their possible effects.
In the baseline, for wastewater treatment in centralised facilities, full compliance was
assumed with differentiated dates according to the distance to target of each MS (Table
A7-1, Annex 7)21
. On top of the key support from regional funds, some MS are
benefiting from the Technical Support Instrument for their water sector. The Commission
with the OECD is also providing tailored support to MS (see Annex 10, report 5).
For Individual and other Appropriate Systems (IAS), the effects of full implementation
were included in the baseline: it was assumed that all IAS would have an equivalent level
of treatment as required by the Directive. Additional initiatives further discussed in
sections 5.2 and 6 would be needed to ensure full implementation. According to the data
gathered in the context of this IA (see Annex 4 and 5), today 67% of MS are treating
wastewaters from small agglomerations below 2.000 p.e. to the level of secondary
treatment, 26% to the level of primary treatment and 7,4% is considered as not treated.
The effects of the baseline are summarised in Table 2 below and illustrated in Figure 1.
Full compliance with the existing legislation would reduce the remaining loads emitted to
the environment by 21,4% for BOD, 6,3% for N, 13,4% for P, 21,9% for E. coli and
19
According to Eurostat, total EU population is expected to increase from 447.319.916 (2020) to
448.233.662 (2035) and then decline to 441.220.961 by 2050
20
This might be the case for some harmful substances such as PFAS, intentionally-added micro-plastics in
some products such as paints, PCP’s, or mercury in dental amalgams
21
8 MS are fully compliant today (with less than 1% distance to target), 15 other MS are expected to
become fully compliant within the next 3 years. Full compliance was assumed by 2028 for RO, SI, MT and
by 2031 for BG (Annex 10, report 1).
36
4,2% for micro-pollutants. The bulk of the effects of the baseline scenario would appear
by 2025 (when 23 MS are expected to become fully compliant), with full effects by 2031.
BOD N P E. coli Micro-
pollutants
Current (p.e.) 66.148.823 191.126.725 148.600.784 71.110.762 264.127.257
Baseline (p.e.) 51.966.775 179.087.499 128.621.614 55.510.146 252.954.625
Current situation
(Tons/year)
1.448. 659 779.711 91.122 - -
Baseline
(Tons/year)
1.138.072 730.802 78.871 - -
Table 2: Summary of the of the baseline scenario (full compliance) – remaining loads per year
emitted to environment – A breakdown per MS is provided in Annex 7, Table A7.6
In terms of energy use and GHG emission reduction, progress could be expected from the
combined application of the Fit for 55 package, the EED, the RED II, the ESR and the
very recently adopted RePowerEU package (see Annex 8). In the context of this IA,
efforts were made to build a dynamic scenario taking into account the potential effects of
these legislations and policy packages on energy use and GHG emission reductions:
 The recently adopted RePowerEU Plan aims at rapidly reduce dependence on
Russian fossil fuels and fast forward the green transition. Several actions are included
in the Plan notably to promote renewables including the production of biogas. No
specific quantifies targets per sector are included in the Plan making it impossible to
quantify its possible effects on the wastewater sector;
 Under the Fit for 55 package, the EED, the RED II and the ESR, MS have to meet
national targets (see Annex 8 for more details) and can choose in which sector efforts
will be made to meet these targets. There is no sufficiently detailed data on how MS
intends to meet these targets with a sufficient level of disaggregation to identity to
what extent the wastewater sector would be included or not in MS efforts. It is
therefore not possible to quantify the effects of national based targets on the
wastewater treatment sector. A few MS (like DK and NL – see Box 1 below) have
well understood the high potential of the sector but so far they remain an exception.
The starting position of the other MS is largely unknown in absence of any reporting
obligations on energy use and production of renewables from this sector. The
potential impacts of these uncertainties are summarised in Table 18. In summary,
those MS using more energy today for their wastewater operations will
proportionally benefit more from systematic energy audits and the related
investments in energy efficiency and production of renewables. These investments
will be more significant in these countries but also more profitable.
 Nevertheless, as detailed in the recast EED, the public sector should lead by example,
and therefore a specific mandatory target was introduced for all public bodies
which covers the wastewater sector (1.7% per year reduction of energy use starting
by 2025).
In the baseline, this mandatory target was therefore applied. As shown in Table 3 below,
a reduction of energy use of 1,7% per year from 2025 was included in the Baseline. This
would represent a reduction of 25,5% of the energy used by 2040 compared to 2025.
This will have a direct effect on GHG emission reduction, which was taken into account
in the baseline: around 1,19 million tons of GHG would be avoided thanks to the
implementation of the EED. This represents 11,89% of the ‘avoidable emissions’ and
will generate a monetised benefits of 118,9 million € per year by 2040. This assumption
37
is based on a (future) legal obligation which is the most solid basis to build a dynamic
baseline, but as explained above, there are uncertainties which are further discussed in
section 7.1, Table 17.
Emissions
of GHG
(million tons
CO2e/year
per year)
Expected
energy
savings
(based on
1,7%
reduction per
year)
GHG
emission
reduction
(million tons
CO2e/year)
% of
avoidable
GHG
emissions
Monetised
benefits
(million
€/year)
Current situation 34.6 - - - -
Baseline 33.34 25,5% 1.188.477 11,85% 118,9
Table 3: Baseline scenario – impacts of the EED on the energy use and GHG emissions
5.2 Description of the policy options
Several policy measures addressing each identified problem have been retained for
further analysis. For each problem, different solutions were envisaged, ranging from soft
approaches - mainly based on non-binding guidance to MS - up to stricter regulatory
measures. There are limited interactions among the proposed solutions, which will be
clearly identified in the following sections.
The measures detailed below are based on what is already in place in the most advanced
MS22
. As shown in the Evaluation, having in place enforceable measures was a key
element for the success of this Directive. Therefore, too complex measures difficult to
control were avoided. Also, in the initial screening, measures which were not broadly
supported by stakeholders or identified as good practice were discarded.
For some problems, the analysis and experience confirmed also by a consensus across the
stakeholders groups show that only a limited set of measures is available without real
alternatives. This is the case for non-domestic waters, some aspects of governance such
as transparency, access to sanitation or public health indicators. For other problems,
different options from low to high level of ambition were tested to find optimal
solutions. This is the case for SWO and urban runoff, small scale agglomerations,
nutrients and micro-pollutants abatement. The lowest ambition options would apply only
to a limited number of large facilities or agglomerations although the highest ambition
options would apply to more and smaller facilities and agglomerations.
To fix adequate thresholds for the different options, the share of the treated load amongst
the different sizes of facilities and agglomerations is an important factor: 81% of the
load is treated in 9% of the EU facilities and agglomerations above 10.000 p.e. – see
Figure 12 (and Tables A7.3 and A7.4 in Annex 7 for more details). Around 47% of the
load is treated in 1.3% of facilities and agglomerations above 100.000 p.e. There are
22
A lot of information on the practices in place was gathered: detailed pre-filled questionnaires were sent
to all MS summarising their starting position and the data used in the model. All MS provided additional
data (see Annex 5). Specific technical seminars on each problem identified were organised (see Annex 2).
38
minor differences between the number of facilities and agglomerations23
which was taken
into account when designing the options and assessing their impacts.
A description of the options considered for the individual problems is provided below.
Figure 12: Treated load, number of treatment plants per category (JRC 2022, Annex 4)
5.2.1 Storm water overflows (SWO) and urban runoff
The choice of effective measures to control pollution from SWO and urban runoff during
rainfall events depends on the local conditions.24
Therefore, in line with the principle of
subsidiarity and proportionality, imposing detailed EU standards constraining the design
of solutions would not be appropriate.
Results of the stakeholder consultation identified ‘integrated urban water management
plans’ established at local level as the right instrument to identify and implement the
most cost-effective local combination of measures. This approach is already applied in
some MS (such as FI, DE, AT or FR).
Different levels of ambition were tested to reduce emissions from SWO and urban runoff
in terms of agglomerations that would be covered:
- A low ambition - Option 1, with measures only in agglomerations >100.000 p.e. with
a focus on agglomerations ‘at risk’;25
- A high ambition - Option 3 applied to all agglomerations above 10.000 p.e.;
- Several ‘in between’ options were modelled of which a representative Option 2 will
be presented in section 6 where measures are applied to all ‘at risk’ agglomerations
above 10.000 p.e.
23
An agglomeration can include more than one facility although a facility can cover more than one
agglomeration. The differences are nevertheless marginal – see Annex 7.
24
Including climatic and geographical conditions, separate or combined collection, storage capacity in the
network, capacity of the treatment plants to treat rain waters
25
Agglomeration where due to SWO and urban run-off there is a risk of not achieving the objectives of
other legislation and notably the DWD, the BWD or the WFD – see section 2.1.1.2
0
5.000
10.000
15.000
20.000
25.000
30.000
35.000
0
50.000.000
100.000.000
150.000.000
200.000.000
250.000.000
Below
1.000
1001 -
2000
2001 -
10.000
10.001 -
100.000
100.001 -
1.000.000
Above 1
M
Treated Load, Number of facilities
Treated load (pe) Number of facilities
39
The plans would include an analysis of the initial conditions, a definition of the
objectives, an analysis of different scenarios to meet the objectives based on an
optimisation of the measures to be taken and defined in the plan. The introduction of the
plans was generally supported by stakeholders, especially based on the views expressed
during the workshops and in the OPC. In the targeted consultation, where respondents
had to rate propositions on a scale of 1 to 5, the strategic planning approach was rated
high - academia (4.4), citizens (4.2), NGOs (4.7), businesses (4.3), public authorities
(3.6). Moreover, there was a consensus amongst stakeholders (academia (4.7), citizens
(4.4), NGOs (5.0), businesses (4.5), public authorities (4.1)) on the following
combination of measures to be considered in the plans:
- Taking all possible measures to prevent the entry of ‘unpolluted rain waters’ in
the wastewater collection network via actions aimed at infiltrating the runoff directly
onto pervious surfaces, at removing soil sealing and at increasing the runoff retention
also through nature-based solutions (e.g. green roofs, green urban surfaces);
- Measures to buffer polluted storm water flows within the existing treatment
infrastructure, by optimizing the use of existing storage volumes e.g. through RTC
of their operation and, when necessary, by building additional storage volume;
- Measures to mitigate the impacts from untreated water discharges, such as further
treatment through nature-based or mixed systems, including constructed wetlands.
Effective monitoring of the network, linked with a modelling of urban water systems is
key in order to optimise new investments, and indispensable for RTC. Very recent
information (see Annex 10, reference 21) based on an analysis of several case studies
shows that significant costs savings (on average 21,4%) can be made with a combination
of real time control and digitalisation of water management in the cities.
Mixed views were expressed by stakeholder on the added value of setting an EU based
objective. At least an indicative objective is nevertheless indispensable to give
consistency and added values to the integrated management plans. Based on the
experiences and objectives in place in MS, but also on expert judgement on what is “as
low as reasonably achievable” (see Annex 10, reports 17 and 18 for more details), a
maximum load of 1% of the total sewage produced in a catchment served by combined
sewers (or 1% of the annual total ‘dry weather’ load) was applied as an EU objective for
the model calculations detailed in section 6.1.
5.2.2 Small Agglomerations
To better tackle the pollution from smaller agglomerations, the scope of the Directive
could be expanded to include agglomerations below 2.000 p.e. Two different options
based on lower thresholds for the agglomerations were assessed (1.000 – Option 1 and
500 p.e. – Option 2).
The thresholds to be tested were identified on the basis of the share of the remaining load
according to the size of the agglomerations – see Figure 14: below 500 p.e., the load is
relatively low for a high number of agglomerations, and above 1.000 p.e. the potential
pollution reduction would not be too limited in comparison to the baseline.
40
Figure 13: Agglomerations below 2.000 p.e. and population (P), source JRC, ref in Annex 10,
report 10
18 MS have already decided to impose collection and treatment for smaller
agglomerations although others are less active in these areas (ref in Annex 10, report 1).
As explained in section 5.1, this was taken into account in the baseline. Stakeholders
were broadly in favour of covering smaller agglomerations in the Directive.
5.2.3 Loads from individual or other appropriate systems (IAS)
There was a broad consensus among stakeholders on the need to take the following
additional measures (without real alternatives) to ensure a full application of the existing
Directive (ensuring the ‘same level of treatment’ in IAS compared to centralised
facilities):
 Establish clear standards in relation to emissions from IAS compatible with the
Directive’s requirements and supplementing the standards defined in the Construction
Product Regulation which was specifically supported by academia (4.8). This
measure was rated 3.8 by businesses, 4.2 by citizens and NGOs and 3.5 by public
authorities);
 Improve the control of IAS at local level, including through a systemic inventory of
the IAS, regular inspections of the larger ones, an obligation of maintenance. This
measure was rated 4.5 by academia, 3.6 by businesses, 3.8 by citizens, 4.1 by NGOs
and 3.2 by public authorities.
5.2.4 N and P releases and eutrophication
Different options to reduce Nitrogen and Phosphorus releases were tested:
- A low ambition (Option 1) in which N/P removal would be systematically imposed
only in larger facilities above 100.000 p.e.;
- A high ambition (Option 5) in which N/P removal would be systematically imposed
in all facilities above 10.000 p.e. while N/P removal efficiency would be increased;
41
- A set of medium ambition (Options 2, 3 and 4) in which N/P removal would be
imposed to different areas (from the whole territory to only ‘sensitive’ areas subject
to eutrophication) for different size of facilities and with different levels of N/P
efficiency. The most representative options are discussed in section 6 and more detail
can be found in report 15, Annex 10.
These options are in line with the measures identified in the most advanced MS. Also,
there was a consensus across the different stakeholder groups on the fact that current N/P
standards could be adopted to the performance actually achieved in well operating
facilities (data from the MS shows that well-functioning facilities can reach 85%
reduction for N and more than 90% for P - see report 15 in Annex 10). In many cases, the
plants can be upgraded with limited additional costs or only through better operation
achieved with instrumentation, control and automation (ICA). In some limited cases, it
would require infrastructural overhauls (all included in the cost assessment - see section
6.4).
Overall, stricter N/P emission requirements were supported by stakeholders. Introducing
the obligation to remove N/P to a larger range of UWWTPs was supported by NGOs
(4.0), academia (4.0), and businesses (3.1). However, businesses noted that such
obligations should only be placed for plants above a certain threshold. Public authorities
seemed least in favour of such an option (3.5), and generally showed more support for
options on providing EU-level guidance on how to designate sensitive areas (3.8).
Stakeholders also supported more clarity on the criteria for the designation of ‘sensitive’
areas subject to eutrophication but also more coherence with the Nitrate and the WFD.
This measure was rated 4.5 by academia, 4.1 by citizens and businesses, 4.2 by NGOs,
and 3.6 by public authorities.
5.2.5 Micro-pollutants
Based on the share of the load between the different facility sizes and on the dilution
rates of the receiving bodies (see Annex 4), the following options were defined:
 a “low ambition” Option 1 requiring treatment only for large plants (> 100.000 p.e.);
 a “high ambition” Option 3 requiring treatment for all plants above 10.000 p.e. when
the dilution ratio is 100 or less;
 other ‘in between’ options combining size and dilution rates (Option 2 in section 6).
There was a broad consensus amongst stakeholders on the necessity to address the issue
of micro-pollutants from wastewaters. Contrary to some business (PCP’s,
Pharmaceuticals), citizens (4.0), NGOs (4.1), academics (3.8), public authorities (3.4)
and water-related business support the requirement for larger UWWTPs to remove
micro-pollutants based on EU-set performance standards.
Stakeholders were also insisting on the importance of measures to be taken at source but
also on the need to better apply the ‘polluter pays’ principle by making the producers
financially responsible for the costs linked to the additional treatment required to treat
micro-pollutants. The EPR approach received a broad support (regarding feasibility and
effectiveness) from the majority of stakeholders (academia (4.5), citizens (4.5), NGOs
4.8), public authorities (4.2), including businesses (3.9) except from the pharmaceutical
42
and chemical industries globally not in favour of such a system, notably on the grounds
that the financial responsibility should be either shared by all actors involved in the chain
(from industry to consumers) or taken by the public authorities. The feasibility and
impacts of a system of producer responsibility was assessed through a specific study (see
Annex 10, report 2). To be noted that such a system will de facto lead to a shared
financial responsibility as - depending on the decision to be taken by responsible industry
- part of the costs will be supported by consumers (see section 6.5).
5.2.6 Non-domestic emissions
As detailed in section 2.1.17, the lack of knowledge of the quality of the incoming waters
of the wastewater treatment plants prevents competent authorities to take additional
actions to limit pollution at source. To improve the understanding of non-domestic
emissions sent in the wastewater collection systems, the following actions were identified
based on the consultation and best practices identified in MS:
 Expand the scope of pollutants to be regularly monitored at the inlet and outlet of the
wastewater treatment facilities to improve the understanding on the presence of
potentially harmful pollutants; the list of pollutants should be aligned with the
existing and soon to be revised EQSD and with relevant parameters listed in the
upcoming revision of the IED and E-PRTR Regulation;
 Incentivise competent authorities to better ‘track’ pollution at source based on
improved monitoring, particularly when sludge and treated water are re-used;
 Ensure the involvement and access to information for wastewater operators in
relation to the discharge permits given to business facilities connected to the
treatment plants via the public collection network, and ensure full coherence between
the IED and the UWWTD to prevent releases of not abated pollutants in the public
network.
Stakeholders independently from their category, supported these measures and
particularly as regards the necessity to better monitor/understand non-domestic pollution
entering the treatment plants (one of the top ranked concerns that needs to be addressed).
5.2.7 Energy
Based on the experience of the most advanced MS (see Box 1) and the inputs provided
during the stakeholder consultation, moving toward energy neutrality was identified as a
promising avenue for the sector. The wastewater sector has indeed specific
characteristics which would justify a specific sectoral target:
 The sector today accounts for 0.8% of the overall energy used in the EU and offers
the potential to significantly reduce its own energy consumption, but also to
produce renewable energy;
 Wastewater treatment plants are indeed producing a constant flow of sludge which
after digestion are producing renewable biogas which can be used as a substitute to
natural gas;
 Wastewater treatment plants occupy large surfaces which could be made easily
available for the production of renewable energy (notably solar and in a number of
locations, wind and hydropower); this is highlighted in the recent RePowerEU
43
package, in which wastewater facilities are identified as good candidates as “go-to-
areas”;26
 As shown in the Evaluation, due to its public/semi-public nature, the sector is mainly
if not only reacting to (EU) legal requirements;
Fixing an EU energy neutrality sectoral target in the revised UWWTD ensures that the
huge potential of this sector in terms of energy efficiency gains and self-production is
effectively captured, in particular considering that this sector is mainly reacting to (EU)
legal requirements. It will help MS to ensure that this potential is effectively captured
even if this sectoral target, like targets decided for other specific sectors (including for
instance car industry or buildings), will partly reduce the flexibility left to the MS to
choose the sectors in which efforts should be accomplished. Nevertheless, the
cost/benefit analysis displayed in section 6.7 shows that reaching energy neutrality in this
sector is particularly relevant. Also, in compliance with the principles of subsidiarity and
proportionality, the proposed energy neutrality target would be applied at national level
but not for each facility: flexibility would indeed be left to the MS on the choice of the
facilities where investments will take place so that an optimisation of the efforts could be
achieved. The large facilities can indeed be net producers of energy which is not always
the case for smaller facilities.
This specific target would complement and support the attainment of the objectives of the
ongoing recast of the EED and revision of the RED (see below section 6.7 and 7.1). As
shown in Table 3 in section 5.1, without a specific target, part of the sector potential in
terms of energy efficiency and of production of clean energy is expected to stay under-
exploited over the next decades: in the baseline scenario it was assumed that energy use
from the sector would be reduced by 25,5% by 2040 which is far below the potential of
the sector. By encouraging the self-production of EU based biogas, it would also
contribute to reduce energy dependency, one of the objectives of the recently adopted
‘REPowerEU’ Plan. This sectoral target would also help moving towards the EU
objective of climate neutrality by 2050 and contribute to the implementation of the ‘Fit
for 55’ and the ESR (see section 6.7 for more details). In that sense, there is no direct
overlap between the existing and forthcoming legislations and this sectoral target, but on
the contrary the energy neutrality target will complement the existing or planned
legislation.
In practice, energy neutrality can be met through a specific mix of actions combining
enhanced energy efficiency (new energy efficient pumps and aeration process,
optimization of the process, energy recovery from water falls in the plants), production of
renewable energy on site (“go to” areas for solar/wind energy production), and
production of biogas from the digestion of residual sludge. The proposed target combined
with the obligation of energy audits would push wastewater operators first to better
assess their potential in terms of cost-effective energy savings and overall better energy
management and then to develop tailored made solutions. As shown in section 2.1.2.1
and 2.1.2.2 each wastewater treatment facility is specific and therefore the optimal path
to reach energy neutrality has to be defined for each wastewater treatment facility having
regard to its specific process and opportunities.
26
In the RePower EU Communication, “go-to areas” are limited and clearly defined land and sea areas
available for renewable energy projects that do not have (as much as possible) environmental value.
44
Denmark intends to reach energy and climate neutrality by 2030. This will be
accomplished through several actions agreed in an overall strategy:
 Investments in energy efficiency and sludge digestion – since 2006, € 22,65 million
are invested each year to reach energy neutrality by 2030.
 Introduction of limit values for N2O emissions from treatment above
30.000 p.e. (covering 65% of the wastewater volume and 75% of N2O emissions from
the process). The 30.000 threshold will be regularly reviewed.
 Monitoring, reporting and benchmarking of all wastewater companies on their
energy consumption and production, GHG emissions and targets.
Under the Klimaatakkoord signed in 2010 (and confirmed by IBP in 2018 with the water
competent authorities), the Netherlands intends to progressively reach energy neutrality
already by 2025. To do this renewable energy sources (solar/wind) will be used but also
measures to save and recover energy. 8 treatment plants have already become new
producers of energy and another nine will follow soon. This is also the case in Bulgaria
with the main facility of Sofia. Scotland intends to reach net zero emissions by 2040.
GHG emissions from operations were already cut by 45% by using more efficient
equipment, reducing leaks from pipes and using renewables.
Box 1 – Actions agreed to meet Climate/Energy neutrality by the wastewater and waste sector
in Denmark, the Netherlands, Sofia (Bulgaria) and Scotland – see Annex 10, report 19
The impacts of following measures were therefore explored in section 6.7:
 Improve the sector’s understanding of the level of energy use through new
monitoring obligations and the requirement of regular energy audits (which are not
required under the revised EED – see section 2.1.1.2). This can help wastewater
operators to better understand the potential savings they can achieve and to identify
cost effective measures for each facility;
 Progressively moving towards an EU energy neutrality objective (to be applied at
national level) for the sector with interim targets up to 2040 to ensure regular
progress towards the final objective of energy neutrality. The interim targets would
start by 2030 to leave enough time to all MS to make the required investments. They
would be identical for all MS as those MS having a less advantageous starting
position would gain more benefits than the others. The potential financial direct
savings are indeed more important in MS using more energy today for their
wastewater sector (see section 6.7 for more details).
As mentioned in section 2.1, the avoidable part of GHG emissions of the sector amounts
to 13.03 million tons of which around 46,45% is related to energy use.
The OPC results as well as inputs received during the specific workshops showed that all
stakeholder categories broadly support the generalisation of energy audits. There was a
general recognition on the necessity to better understand and monitor energy use of the
treatment plants so that measures can be taken to reduce energy use and where possible
produce energy. On average, the highest rated measure was related to introducing an
obligatory energy audit in larger plants (average 3.8), academia (4.2), citizens (4.0),
NGOs (4.2), businesses (3.6) and public authorities (3.6). Citizens, NGOs and to a lesser
extent academia were supportive on introducing energy related targets while mixed views
were expressed by public authorities and business. In terms of stakeholder response
45
patterns, academics (4.3) indicated the most support for the measure relating to setting
energy use reduction targets based on UWWTP sizes. This was, on the other hand,
businesses least rated option (2.6), with a generally negative perception. Public
authorities rated this measure 3.1, citizens 3.5 and NGOs 3.7. More recent contacts with
the most important water industry representatives were clearly showing a willingness to
improve energy efficiency for all wastewater treatment facilities above 10.000 p.e. and to
reach climate neutrality targets for all facilities above 100.000 p.e. by 2035 et for all
facilities above 10.000 p.e. by 2040. Some representatives from MS and business pointed
out that these targets should be introduced for large UWWTPs only without specifying a
specific size of the facilities. Targeting only facilities above 10.000 p.e. seems therefore
reasonable and would partly answer to these comments. Most advanced MS were clearly
supporting an EU wide target similar to their own target.
5.2.8 Sludge management and water re-use
Several actions considered in this IA will have an effect on sludge management. This is
the case with the objective of climate and energy neutrality which will incentivise sludge
digestion and production of biogas. Beyond this effect, the proposed actions to better
monitor, track and reduce pollution at source (see section 5.2.6) will favour a safe use of
treated water (water re-use) but also of sludge in line with the waste hierarchy.
Particular attention should be given to the possible presence of micro-plastics/pollutants
and genes/bacteria promoting AMR in sludge, when used in agriculture. This aspect is
being specifically tackled in the ongoing Evaluation - and possible subsequent legislative
revision - of the Sewage Sludge Directive and in the announced Healthy Soil Directive.
Finally, in line with the principle of circular economy, when sludge is incinerated, a
minimum level of P recovery should be ensured.
The concept of source control, i.e. targeting substances such as micro-plastics and micro-
pollutants at source, was widely supported by stakeholders in order to improve circularity
in the wastewater treatment sector. As such, if sludge and/or water is to be reused,
stakeholders highlighted that there is a need for tracking and preventing pollution at
source.
5.2.9 Wastewater and health
Based on best practices in place in advanced MS notably for COVID-19 surveillance (see
Annex 5) and on the March 2021 Recommendation by the Commission, the following
measures would be taken:
 Ad-hoc surveillance of COVID-19 and its variants in larger wastewater treatment
plants (representing a significant share of the population); the surveillance should be
adapted according to the local but also timely needs of the health authorities;
 Regular monitoring of other pathogens with a view to define most effective actions to
limit their dissemination;
 Regular monitoring of AMR and when relevant, actions to limit AMR dissemination.
A structural dialogue between health and wastewater competent authorities should also
be setup with the aim to (1) ensure a timely transmission of the information to the
national health competent authorities; and (2) define the health relevant parameters to be
temporarily or permanently followed in wastewaters. Enough flexibility should be left to
46
MS so that health competent authorities together with wastewater competent authorities
can decide together the parameters to be monitored, the frequency and the location of the
samples to be taken depending on the public health situation in each MS.
Stakeholders stated that if wastewater surveillance were to take place, additional costs
associated with it should be covered by several entities, for example health authorities.
The preferred manner in which surveillance of wastewater should be incorporated in the
Directive is through the means of guidelines for collaboration between UWWTPs and
health authorities, as well as establishing EU-wide binding standards on implementation.
5.2.10 Transparency and Governance
Different measures are available to ensure a better transparency of the sector but also to
improve the understanding on the actual performances of the operators:
 In line with the best practices already in place in some MS, require from the operators
to monitor some key performance indicators in relation to their economic, social,
environmental, energy and climate performances; these indicators would be included
in the revised Directive on the basis of the OECD work (reference 6 in Annex 10);
 Make this information accessible to the public either via online access or for the most
essential information, on the invoices sent to the consumers.
These measures are aligned to similar requirements recently adopted under the revised
Drinking Water Directive. They will also help to better implement the principles of the
Aarhus Convention notably on access to information and public participation. While
expressing concerns regarding the administrative burden for authorities, stakeholders
consider that the current provisions on public information and transparency do not reflect
current desirable levels of public engagement.
5.2.11 Monitoring and reporting
While improved and simplified monitoring and reporting are one of the objectives of the
revision of the UWWTD, the actual measures depend on the selections made under the
other options discussed in this impact assessment. As further explained in sections 6.11
and 8, additional monitoring activities will be necessary to ensure compliance with the
new proposed requirements: this is the case for instance for micro-pollutants, non-
domestic pollution, GHG emissions or SWO/urban runoffs. The existing obligation
would be also aligned to the current practices notably in terms of monitoring frequency:
continuous monitoring of key parameters needed to check compliance should be
envisaged for the larger facilities.
Reporting could be improved and where possible simplified by:
 Removing the obligation for all MS to report every two years to the Commission and
for the Commission to publish bi-yearly reports, by replacing it with the requirement
for MS to host national standardised data sets which would be regularly updated (at
least annually) and to provide access to those by the EEA/Commission. This
approach is similar to what was decided under the recently reviewed Drinking Water
Directive but also with the recent efforts of the EEA and the Commission to
automatize and simplify reporting. During the consultation it was mentioned that
some MS are already using databases directly filled by operators;
47
 Adapt the existing reporting obligation to include actual releases on top to
information on compliance (pass/fail) from wastewater treatment plants. To limit
administrative burden, this new requirement would apply only for facilities above
10.000 p.e., representing 81% of the total EU load (see Figure 12);
 Include in the reporting obligations information on energy use, measures taken to
reduce SWO/urban runoff, and to improve access to sanitation;
 Require MS to report if more than 2% of their load is collected/treated in IAS in their
agglomerations, and to notify to the Commission summary information on the actions
taken to respect the standards and ensure proper inspection of such IAS;
 Ensure a full coherence between the UWWTD and the revised Industrial Emissions
Portal (former E-PRTR) Regulation to ensure best possible use of the same data, as
well as full transparency;27
 Exempt compliant MS from reporting under current Article 17. For the others, ensure
synergies and coherence between Article 17 and the ‘water enabling condition’ for
EU funding under Cohesion Policy 2021-2027.
New monitoring obligations were clearly supported by NGOs, citizens and academics
and to a certain extent by businesses and public authorities. NGOs noted that many of the
substances urgently require monitoring (e.g. micro-pollutants). The importance of
aligning new reporting requirements with other EU policies such as the new Industrial
Emissions Portal (former E-PRTR) was highlighted. Generally, the pursuit for simpler
and more harmonised reporting was supported by all stakeholder groups.
5.2.12 Access to sanitation
In order to improve access to sanitation, and in full synergy with existing measures to
improve access to water under the revised Drinking Water Directive, the following
measures are considered in this IA:
 Identify vulnerable and marginalised people and require MS to take action to improve
their access to sanitation
 In line with the subsidiarity principle, encourage MS to take appropriate measures to
improve access to sanitation in large cities based on local conditions and constraints.
The extension of the scope of the Directive to smaller agglomeration is expected to
improve access to sanitation in rural areas (see section 5.2.2). In the OPC, stakeholders
indicated that access to sanitation for vulnerable and marginalised groups should be
required. Part of the respondents felt that flexibility should be left to MS on the way to
improve access to sanitation.
5.3 Options discarded at an early stage
The Evaluation and stakeholder consultation results support the argument that
withdrawing the UWWTD would have negative consequences. EU citizens would no
longer enjoy the same level of protection, as MS would no longer apply the same high
standards. Given the overall objective of protecting the environment and public health as
well as the reasoning regarding subsidiarity provided in section 3, this option was
27
E-PRTR includes an obligation for treatment plants above 100.000 p.e. to report their annual mass
releases and transfers. It also requires other large industrial facilities to report their releases into UWWTP.
48
abandoned at the very beginning of the process. There was also no stakeholder support
for this option.
Based on the stakeholder consultation, several options were considered at an early stage
but rejected as either too vague or too prescriptive. Generally speaking, options based on
guidance documents and soft approaches were not further considered in this IA. Their
effects would be too limited and would not allow reaching the objectives described in
section 4. As explained in the REFIT Evaluation, because of its specific market
condition, this sector mainly adjusts to EU legal requirements. The clarity and relative
simplicity of the Directive making it highly enforceable was recognised as one of its
main success factors and this feature should be kept in the future.
Some flexibility should nevertheless be kept in order to ensure an optimal use of
resources - including EU funding - to reach the objectives. In that sense, the option of
banning IAS was rejected at an early stage, because this technique, if well used, might
still be justified, depending on local circumstances. Similarly, and as explained in
section 5.2.1, imposing detailed EU standards constraining the design of solutions for
SWO and urban runoff was considered as not appropriate.
Imposing individual energy efficiency targets for each collection and treatment system
was also discarded as this option would not lead to optimising investments at sector
level. Similarly, imposing resource efficiency objectives such as minimum
percentages of sludge use in agriculture or mandatory anaerobic digestion was rejected
as well as the option of introducing minimum rates of water reuse. This is also in line
with the subsidiarity and proportionality principles, since the conditions are varying from
one MS to another and even from plant to plant. To better apply the ‘polluters pays’
principle, different types of pollutants and related products were considered (see Annex
10, report 2). Possible Extended Producer Responsibility schemes were rejected for all
other pollutants than micro-pollutants. Contrary to micro-pollutants, there are indeed at
this stage no available technologies to better capture these pollutants in the treatment
plants.
Imposing access to sanitation for all and everywhere seems unrealistic and too costly
particularly in remote areas. The current scientific knowledge and technological
capabilities for wastewater treatment do not support the definition of science-evidence-
based threshold for AMR (ref in Annex 10, report 11), hence such an option was
discarded too.
49
Figure 14: Links between drivers, problems, objectives, specific objectives and the main
options
Drivers Problems Objectives Operational
Objectives
Contribution of the main options to the main specific
objectives
Climate
change and
urbanisation
Increasing
pollution
from
SWO/urban
runoff
To protect
EU citizens
and
ecosystems
from the
remaining
sources of
insufficient
ly treated
wastewater
Further reduce
pollution from
the ‘remaining
sources’
(SWOs)
SWO and urban runoff
Reduction of the pollution sent to the environment from
untreated water in case of heavy rains by:
 Integrated management plans based on improved
monitoring
 Actions to be decided at local level to prevent rain water
in the network (green infrastructures), optimise existing
infrastructures (storage, treatment plants) and when
needed new infrastructures
Small agglomerations and Individual Appropriate
System
Reduction of the pollution sent to the environment by:
 Review of the thresholds above which the Directive
applies (from 2.000 p.e. today to 500 or 1.000 p.e.)
 Requiring MS to put in place systematic control of IAS
combined with EU clear standards
Nutrients
Further reduction of N/P pollution sent to the environment
by:
 Establishing clear criteria where N/P treatment is
required
 Stricter standards for N/P removal
Micro-pollutants
Reduction of micro-pollutants sent to the environment by:
 Establishing new standards for micro-pollutants emitted
by wastewater treatment plants
 Establish an EPR scheme to incentive producers to put
less toxic substances on the market
For all options: improved monitoring and application of a
‘risk based’ approach
 Integrated management plans for SWO/urban run-off to
identify areas at risk and focus investments in areas at
risk
 Investments only required for large facilities and for
smaller facilities based on an identification of areas ‘at
risk’ for micro-pollutants and N/P (eutrophication)
 Application of the Extended Producer Responsibility to
cover new investments needs to treat micro-pollutants
 Innovation and investments encouraged by new
standards for micro-pollutants, reinforced standards for
N/P, improved management of SWO and urban run-off
 Digitalisation/RTC needed for SWO/urban run-off
management, N/P management and energy neutrality
 New technologic development expected to reach energy
neutrality while reinforcing water treatment
Small
agglomeratio
ns out of the
Directive,
unclear
requirements
and overuse
of IAS
Remaining
pollution
from small
agglo and
non-
compliant
IAS
Further reduce
pollution from
the ‘remaining
sources’
(smaller
agglomerations
and IAS)
Unclear
criteria for
‘sensitive
areas’ and
outdated
standards for
N & P
High level of
N & P
releases
leading to
Eutrophicati
on
Further reduce
nutrient (N and
P), pollution
from urban
sources
Ageing
population
and
Increasing
use of
pharmaceuti
cals and
personal
care
products
Increasing
releases of
micro-
pollutants
Further reduce
micro-
pollutants
pollution from
urban sources
Inadequate
monitoring,
lack of
incentives to
‘do better’
Lack of
monitoring/u
nderstanding
of some
remaining
sources and
their impacts
Ensure that
investments are
taking place
‘where it makes
sense’
No tradition
of producer
responsibilit
y schemes
for water
pollution
Insufficient
application
of the
‘polluters
pays
principle‘
Better apply the
‘polluter pays’
principle
Encourage
investment and
innovation in
wastewater
management.
50
6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS, HOW DO THEY COMPARE AND
WHAT ARE THE PREFERRED OPTIONS?
As the policy options are quite different according to the identified problems, their
potential impacts, their comparison and the choice of the preferred options are discussed
together in this section. The assessment of impacts focuses primarily on the economic
(costs) and environmental impacts (emission of pollutants). The social impacts, beyond
access to sanitation, were addressed from the perspective of affordability of the
wastewater services for the low-income households (see section 7).
When alternative options were available, several criteria were used to identify ‘optimal’
(preferred) options: on top of costs/benefits and costs/effectiveness, the contribution to
the achievement of the main objectives, the enforceability as well as the potential
administrative burden were considered. A summary of the selection criteria applied for
each option is provided in Table 12, at the end of the present section whereas Figure 14
above displays the main options, their contribution to solve the problems and their
drivers while delivering on the specific objectives.
The costs and benefits were assessed and presented with a 2040-time horizon: this is
indeed the time needed for a realistic implementation of the measures considered in this
IA and for a sound planning of the underlying, required investments. Beyond 2040, there
would be too many uncertainties on the expected costs and benefits of the envisaged
measures. As detailed in section 4, the main objective of this initiative as well as the
majority of its expected costs and impacts are related to water collection and treatment
and to a lesser extent energy neutrality. This 2040 horizon takes into account the time
required for the water-related investments. It also takes into account the lessons learnt
from the application of the 1991 Directive (over ambitious deadlines leading to a
multiplication of infringement cases – see the Evaluation for more details).
The time needed to achieve energy neutrality was also taken into account: most advanced
MS (see Box 1) are indeed expecting to reach energy neutrality by 2025/2030, meaning
10 to 15 years before the proposed EU deadline which therefore would be realistic in the
light of the potential gains and incentives related to better energy management but also
the available technologies to move towards energy neutrality. The recent evolution of
energy prices is providing another powerful incentive for the sector to accelerate its
efforts toward energy neutrality. It is also in line with the REPowerEU Communication
objective to become less dependent for its energy production. For all these reasons, the
2040 deadline appears to be both realistic and desirable. As detailed below (sections 6.7
and 7.1), reaching energy neutrality by 2040 will contribute to reduce GHG emission
from the sector (around 33% of the ‘avoidable emissions) which is compatible with the
objectives of the Fit for 55 initiative and the 2050 objective of carbon neutrality.
For comparison purpose, a maximum feasible scenario was built showing what would
be the effects of all technically feasible measures without taking into account their cost
(see Annex 4). The effects on emissions in waters are summarised in Figure 15 below
and in Table 1 above.
51
Figure 15: Impacts of the current situation, baseline, and maximum feasible scenario on the
remaining load
As detailed in Annex 4, the costs were estimated based on reference cost functions
(FEASIBLE functions). For the quantification of the benefits, the following shadow price
were assumed: GHG emissions € 100 per t CO2e, and for 1 kg of BOD removed from the
effluents € 0.05, € 20/kg for N and € 30/kg for P. Additional estimates of the benefits
based on willingness to pay were used in the case of SWOs and urban run-off (see Annex
4). The cost and benefit methodologies were reviewed and improved by OECD (Annex
10, report 4).
6.1 Storm water overflows and urban runoff
The expected pollution reduction as well as the costs and benefits of the different options
are summarised in Table 3 and Table 4 below. The costs and impacts of the additional
investments needed will depend on the local conditions of each urban area. Nevertheless,
the costs and effects of different measures were estimated using European hydrological
and cost models (see Annex 4 for more details).
Two types of costs were estimated: (1) costs of establishing the urban water management
plans including monitoring costs; (2) costs of actual measures included in the plans to
limit untreated releases to 1% of the dry weather load (see section 5.2.1).
The average cost of establishing an integrated urban water management plan was
estimated at € 0.09/year/p.e. (source: Annex 10, report 1).28
These plans would allow
optimising existing and planned infrastructures leading to potentially significant savings
in terms of new investments. Such integrated plans are already in place in some MS (see
Annex 5), therefore it was estimated that around 80% of the concerned agglomerations
would have to establish such plans. Annual monitoring costs are estimated at € 0.05 per
p.e. (including RTC).
28
The actual cost will depend on the complexity of the systems, the pre-existence of relevant information
and the size of the considered area.
-
50
100
150
200
250
300
BOD N P E. Coli Micro pollutants
Maximium Feasible Scenario (million pe/year)
Current Baseline Maximum feasible
52
The costs of actual measures were estimated assuming that overflows are treated in a
constructed wetland before discharge. The effects of the greening of urban areas
according to the objectives of the Biodiversity Strategy (Nature Restoration targets) were
also taken into account in the modelling (see Annex 4). Potential savings (on average
21,4%) due to real time control, digitalisation and better planning/management of waters
in the cities (see Annex 10, reference 21) were applied to the costs estimates.
Options N removal t/year P removal
t/year
BOD
t/year
Removal of
Micro-pollutants
(p.e./year)
1 - Low ambition – 30% of
agglo >100.000 p.e.
3,476 512 17.262 3.826.925
2 - As above + 30% agglo >
10.000 p.e.
5,938 876 29.483 6.558.744
3 - High ambition - all
agglo> 10.000 p.e.
19.795 2,919 98.276 21.862.481
Table 4: Annual pollution reduction by 2040 of actions to reduce urban runoff and SWOs –
source JRC, ref in Annex 10, report 17
Options 1 and 2 include measures for all agglomerations respectively above 100.000 p.e.
(Option 1) and 10.000 p.e. (Option 2) in areas ‘at risk’ where SWO releases represents a
risk for the environment. For the calculations of the impacts of these Options, it was
assumed that 30% of the agglomerations would require additional investments – which –
according to available data from the WFD and the BWD appears to be a conservative
approach (see section 2.1.1.2 and Annex 4 for more details).
Options Costs
€/year
Plans and
monitoring
€/year
Monetised
benefits –
water only
€/year
10% of
benefits –
willingness to
pay €/year
Total
assumed
benefits
€/year
1 - Low ambition –
30% of agglo
>100.000 p.e.
218.979.413
43. 100.000 85.753.164 365.537.530 451.290.694
2 - As above + 30%
agglo > 10.000 p.e. 372.472.648
57.600.000 146.509.339 639.071.811 785.581.149
3 - High ambition -
all agglo> 10.000 p.e.
1.241.575.494 77.200.000 488.364.462 2.130.239.369 2.618.603.831
Table 5: Annual costs and benefits by 2040 of actions to reduce urban runoff and SWOs –
source JRC, ref in Annex 10, report 17
Like for the other options, a partial monetisation of the benefits was achieved on the
basis of the avoided N, P and BOD pollution. In absence of credible shadow price for
micro-pollutants and for micro-plastics (see Annex 4), the benefits related to water
quality are nevertheless under-estimated, knowing that SWO and urban run-off are a
significant source of these pollutants. Moreover, the monetisation does not account for
the short duration, acute effects of pollution due to SWO/urban run-off, which may lead
to fish die-off and temporary impairment of the aesthetics and safety of the receiving
waters.
A recently published study (April 2022 – see Annex 10, reference 22) quantifies the
willingness to pay (WTP) for improved ecosystem services due to a better management
of SWO/urban run-off in the city of Berlin (around 100 €/year/person). Based on this,
another estimate of the benefits was achieved for all options (more details in Annex 4).
53
In order to account for the fact that in many cases the perceived benefits can be smaller
than in the Berlin case study, and to stay on a very conservative side in the estimation, it
was assumed that the benefits would amount to 10% of the WPT as estimated in Berlin.
Alternative extrapolation based on the GDP per inhabitant would also lead to an over-
estimation of the benefits.29
The results of both methods are displayed in Table 4 above. In the context of this IA and
to compare the different options, the benefits linked to water quality were added to the
estimations of the willingness to pay.
Preferred option:
Requiring all agglomerations above 100.000 p.e. to produce an integrated plan and carry
out proper monitoring should be done in any case: it would concern only a limited
number of agglomerations (914) representing a significant part of the load. As for the
agglomerations between 10.000 and 100.000 p.e., regular monitoring should be in place
to identify whether additional action would be needed.
As shown in Table 12, the three options have similar benefits-costs ratios even if Options
2 and 3 performs slightly better than Option 1. More pollution would be captured with
Option 3 but not always in areas where there is an actual risk for the environment.
Administrative burden would be higher for Option 3 as more agglomerations would be
covered. Option 1 has a slightly lower benefit/cost ratio than Option 2 and 3, while its
administrative burden would be lower than for Options 2 and 3. The contribution of
Option 1 to the main objectives of this initiative would be lower than with the other
Options.
It is therefore proposed to consider Option 2 as the preferred Option. This Option offers
the best combination between benefit/cost ratio, with limited administrative burden
(around 2.966 agglomerations would be concerned - mainly where there is a real risk for
the environment compared to 7.754 with Option 3). Option 3 entails significant
investments in all agglomerations above 10.000 p.e. which might be excessive
particularly when the receiving water bodies are not ‘at risk’. With Option 2, investments
would take place only in areas where there is a risk for the environment as identified by
the integrated water management plans leading to optimised measures to be decided at
local level. Criteria to define the areas at risk would be included in the revised Directive30
as well as an indicative target for the water management plans (1% of dry weather loads
– see section 5.2.1). Applying an indicative (not legally binding) target would leave
enough flexibility at local level on the decisions on actual actions to be taken depending
on their local cost/benefit analysis and the local estimates of the ‘willingness to pay’
which differs from one city to another.
29
According to Eurostat, the average GDP per inhabitant in the EU amounts to 27.830 €/year compared to
35.290 €/year in Germany. Based on the GDP/inhabitant, an extrapolation of the Berlin case would lead to
WTP of 79 € per person which is considered by JRC experts as an over-estimation of the benefits. The
same extrapolation in the MS having the lowest GDP/inhabitant (BG - 6.690 €) would lead to a WTP of
18,9 € per person which is still about the double of the WTP used in the context of this IA (10 € per
person). In that sense the assumption used in this IA appears to be prudent but reasonable.
30
Criteria would be linked to risks to the environment notably when monitoring results shows high levels
of loads (more than 1% of dry weather loads) leading to risk of not achieving the objectives of other
legislations such as the DWD, the BDW and the WFD.
54
With the preferred option, around 9% of micro-plastics released in case of heavy rains
would be further captured in treatment plants and as well as potentially significant
additional number of larger pieces of plastic (see Annex 4 and report 8 in Annex 10).
Finally, these measures are also aligned with the rationale underpinning the EU Climate
Adaptation Strategy, the Biodiversity Strategy and the Zero Pollution Action Plan.
6.2 Individual or other appropriate systems (IAS)
The proposed measures are designed to ensure the full implementation of the existing
Directive’s requirements. An estimate of the additional administrative costs related to
performing regular inspections of IAS and complying with new reporting obligations was
based on the Austrian advanced experience: the annual cost of ensuring a regular
inspection is estimated at € 82.6 million per year for the EU 27 (see in Annex 10, report
1). The Austrian system is considered as one of the most advanced, meaning that with
this level of costs a real performant inspection would be in place in all MS.
As 26 MS have already a legislation in place on IAS and some form of inspection, the
total additional cost of improving inspection was estimated at between 20 to 60% of €
82,6 million. Reporting costs would amount to 126.000 €/MS per year. To limit
administrative burden, reporting obligation could be limited to MS reporting a high level
of IAS in their agglomerations of above 2.000 p.e.: it would concern 13 MS reporting
more than 2% (see Figure 2). Overall reporting costs would then amount to 1.64
million/year.
BOD
reduction
(Tons/year)
N reduction
(Tons/year)
P reduction
(Tons/year)
Micro-
pollutants
reduction
(p.e./year)
E. coli
reduction
(p.e./year)
Administrative
costs
(million/year)
Monetised
Benefits
(million/year)
75.738 23.2820 32.480 4.900.263 4.190.288
16,52 to 49,56
+1.64 reporting
566,9
Table 6: Costs and benefits by 2040 of measures to ensure full implementation for IAS
As explained in section 5.1, the potential pollutant emission reduction was included in
the baseline. Additional emission reductions can be expected if EU standards are
developed for IAS, as theses would apply for all smaller facilities placed on the EU
territory. As shown in Table 5, the monetised benefits are estimated at € 566,9 million
which is exceeding the additional costs due to additional efforts on inspection and
reporting.
6.3 Small Agglomerations
The impacts of reducing the existing threshold of 2.000 p.e. are summarised in Table 6.
Options Number
of
Agglom
erations
BOD
reductio
n
Tons/y
N
reductio
n
Tons/y
P
reductio
n
Tons/y
Micro-
pollutant
s
(million
p.e.)
Adminis
trative
Million
€/year
Costs
Million
€/year
Benefits
Million
€/year
Option 1 -
1.000 p.e.
19.138 75.531 8.928 1.397 2,61 0,472 140,4 224,24
Option 2 -
500 p.e.
30.354 143.266 16.822 2.642 4,9 0,748 284,3 415,7
Table 7: Cost and benefits by 2040 of expanding the scope of the Directive to agglomerations
of 500 and 1.000 p.e.
55
As shown in Table 6, for all options, the costs are lower than the monetised benefits.
According to the MS answers to the questionnaire (see Annex 5), in 18 MS the majority
of the small agglomerations are already connected to wastewater treatment plants –
which was taken into account in the baseline. Therefore, additional reporting work would
be needed only for around 40% of the agglomerations or € 747.923 per year31
at EU level
if the threshold is changed to 500 p.e. and € 471.560 for 1.000 p.e. (Annex 10, report 1).
Preferred option: As shown in Table 13, the benefit/cost ratio is slightly better if the
thresholds are reduced to 1.000 p.e. (1,6 compared to 1,46) while administrative costs
would be reduced by half. It is therefore proposed to consider this Option 1 as the
preferred Option even if Option 2 would have delivered slightly higher pollution
reduction. In terms of enforceability, the preferred option scores better as even if the
thresholds are very clear for both options, targeting less agglomerations will ease
compliance checking and limit administrative burden.
6.4 N and P releases and eutrophication
The impacts of several combinations of measures based on removal efficiency applied to
different sizes of facilities were modelled (see Annex 4 and Annex 10, report 15). The
impacts of the main following options are summarised in Table 7 below.
Preferred option: As shown in Table 12 and in Table 7, the benefit/cost ratio is positive
for all options. Options 2 and 4 are nevertheless scoring better than the others. Option 4
will bring more N/P but also GHG reduction. In that sense, the coherence with the Green
Deal as well as the effectiveness in terms of reduced water pollution is higher. Compared
to other less ambitious Options, Option 4 will bring limited additional administrative
burden as facilities above 10.000 p.e. are already subject to reporting while better
contributing to the objectives.
It is therefore proposed to consider Option 4 as the preferred option. With this Option,
the obligation to install additional tertiary treatment to remove N/P will be limited to
areas subject to eutrophication or at risk of eutrophication as it is the case today but with
more clarity and coherence with the WFD, the MSFD and the Nitrates Directive on the
criteria to designate sensitive areas. Some areas incontestably subject to eutrophication
consistently with the data generated by the MSFD, the WFD but also the Nitrates
Directive could be included in the annex of the Directive.32
31
0.5 day/operator based on cost of a FTE of 123,2 €/day – source: Eurostat – see Annex 10, report 1
32
Parts of the North Sea, Black Sea, North of the Adriatic Sea, Baltic Sea
56
Options N
reduction
(t/year)
P
reduction
(t/year)
GHG
reduction
(t/year)
Costs (€
million)
Benefits
N/P
removal in
water (€
million)
Benefits
GHG
reduction
(€ million)
1. Low ambition - N/P
removal - all facilities
above 100.000 p.e.
54.817 9.359 692.842 801 1.377 69,842
2. Medium – as above +
N efficiency to 85% and
P to 90%
168. 228 16.964 922.063 1.420 3.873 92,206
3. N/P removal for all
facilities > 10.000 p.e.
84.603 15.288 1.228.372 1.395 2.151 122,84
4. N/P removal - all
facilities > 100.000 p.e.
+ facilities between 10
and 100.000 in sensitive
areas + N/P increased
efficiency33
215.133 28.130 1.391.487 2.008,5 5.147 139,149
5. High ambition - As
above + N efficiency to
85% and P to 90%
282.524 29.054 1.662.634 2.598 6.523 166,263
Table 8: Summary of the main impacts by 2040 of measures to reduce N/P
6.5 Micro-pollutants
Table 8 below summarises the model results for a selection of different options as regards
the treatment of micro-pollutants (see Annex 4 for details).
Options Costs
(Million
€/year)
Toxic load
avoided
(p.e.)
Avoided toxic
load in areas
at risk (p.e.)
Additional
GHG (Million t
CO2e/year)
1. Low ambition - all plants >
100 k p.e.
841 59.236 32.875 0 to 4,33
2. All plants >100 k p.e. +
plants 10 k to 100 k in areas
at ’risk’ 34
1.185,51 68,198 41.836 0 to 4,97
3. High ambition - all plants >
10k p.e.
2.651,82 103,431 41.836 0 to 7,58
Table 9: Impacts by 2040 of measures to reduce micro-pollutants, source JRC - Annex 4 and ref
in Annex 10, report 13 and 14
As explained in the glossary, the lower the dilution rate, the higher the risks for the
environment. Additional energy would be needed to treat micro-pollutants. In Table 8 an
estimate of the related GHG emissions is provided. These additional emissions could be
neutralised when energy neutrality will be met in the sector.
33
For Option 4, it was estimated that around 50% of the facilities between 10.000 and 100.000 p.e. not yet
equipped with N/P removal equipment are in sensitive areas and should be equipped by 2040
34
In this IA, it was assumed that 70% of facilities between 10.000 and 100.000 p.e. with a dilution rate of
10 or less would be considered as ‘at risk’- see Annex 4.
57
Preferred option:
As shown in Table 8 and Table 12, there is a direct correlation between the reduction of
the toxic load and the costs. Compared to Option 1, Option 2 delivers better results in
terms of avoided load in areas ‘at risk’, where the dilution rate is below 10. Compared to
Option 3, Option 2 is more cost effective as it will allow prioritising the efforts where the
risk for the environment is higher.35
The administrative burden of Options 2 and 3 is slightly higher than Option 1 – which
nevertheless delivers less reduction of the toxic load (both in and outside the areas ‘at
risk). All Options are similar in terms of enforceability even if Option 2 will require
slightly additional efforts to check that MS did properly identify the areas at risk.
Requiring an unconditional advanced treatment for facilities between 10.000 and 100.000
p.e. as in Option 3 would lead to disproportionally high cost when compared to expected
reduction of polluting emissions. Balancing all the criteria, it is proposed to consider
Option 2 as the preferred Option. With the preferred option, the toxicity of the released
waters would be reduced by 44% against the current situation, of which more than 60%
would happen in areas ‘at risk’.
To give enough time to plan the required investments, advanced equipment would be
installed within a sufficient time period by 2035 (more than 10 years) for all facilities
above 100.000 p.e. and 5 additional years would be given for the others. These deadlines
are realistic based notably on the experience from Switzerland.36
Monitoring costs for the preferred option are estimated around €11 million/ year based on
monthly samples (Annex 10, report 1). Reporting costs are considered as negligible as all
facilities above 10.000 p.e. are already subject to reporting obligations.
Producer responsibility, application of the ‘polluters pays’ principle:
The feasibility and impacts of covering the additional cost for advanced treatment
through a system of producer responsibility was assessed (report 2 in Annex 10).
According to the best available data today, and recognising uncertainties on the data
gathered37
, substances used in pharmaceuticals and personal care products (PCPs)
represent the majority of micro-pollutants inputs and toxicity in wastewater treatment
plants justifying additional investments in advanced treatment for micro-pollutants (see
Annex 10 reports 2, 15 and 16). Pharmaceuticals represent 59% of input quantities to
wastewater treatment plants (14% for PCPs), 48% of the toxic chronic load (17% for
PCPs) and 66% of the total toxic load PNEC- see Glossary (26% for PCPs).
In compliance with the “polluter pays” principle included in Article 191 of TFEU, these
sectors should be financially responsible for the additional costs related to additional
treatment needed to treat the pollution they generate (€ 1.186 million/year for all micro-
pollutants). In practice, and similarly to the EPR schemes in place for several waste
35
On the basis of the outcomes of a risk assessment based on simple criteria such as low dilution rate,
presence of bathing areas and/or where raw water is extracted for the production of drinking water.
36
In Switzerland 100 ‘priority’ facilities will be equipped with advanced treatment by 2040.
37
There are uncertainties on the concentration of substances found in the treatment plants and on the
toxicity of the substances – see also Table 1. As it was the case at the beginning of most EPR schemes,
these uncertainties are expected to be rapidly limited with the introduction of the declaration on products
placed on the EU market by the producers/importers.
58
streams, those placing PCPs/pharmaceuticals on the EU market would have to pay fees to
a central organisation (PRO) based on the quantities and toxicity of their products. The
funds would then be used mainly to finance the additionally required treatment through
contracts with wastewater operators but also to cover the additional administrative costs.
Such system will be in line with the concept of Extended Producer Responsibility as
defined under Article 8 of the Waste Framework Directive. More details on the practical
organisation, the responsibilities and roles of the different involved actors and their
interactions is provided in Annex 9. On top of deciding on whether a producer
responsibility system should be applied or not, the main choice to be done at this stage
and in the EU legislation are related to the scope of the EPR scheme, the cost coverage of
the scheme, the principles on how the fees to be paid will be applied and the level of
transparency of the system. In this impact assessment it was assumed that:
 The scope of the EPR schemes would cover pharmaceuticals and PCPs. A
review clause could be included in case new knowledge and understanding
become available on the products placed on the market generating micro-
pollutants and treated with the new advanced treatments.31
 The same principles in terms of fee modulation/transparency as defined in Article
8 of the Waste Framework Directive would be applied. In other terms, the fees to
be paid by those placing PCPs and pharmaceuticals on the market would be
linked to the quantities of the products they placed on the market and the potential
toxicity of the related residues. This modulation of the fees paid by the
producers/importers would be established so that substitution to most toxic
substances could be incentivised.
 Similar requirements to those included in the Waste Framework Directive in
terms of transparency would be requested from the producers/importers and for
their PRO. These costs (administrative costs related to the EPR scheme but also
to regular external independent audits were assesses in this IA – see below).
The additional costs related to an EPR scheme is due to administrative costs. These
costs were estimated at € 16.6 million per year (less than 1.4%) mainly for the Producer
Responsibility Organisation - PRO (€ 11.2 million) and to a lesser extent for the sectors
(€ 5 million – declaration of what is set on the EU market). Costs for MS (control of the
system – 0.06 million) and for wastewater operators (contracts with PRO – 0.34 million)
are more modest. Depending on the decisions taken by each company in the two sectors,
the additional costs due to the fees paid to the PRO would be covered either by an
increase of products price (estimated at maximum 0,6%, of the annual expenses for PCPs
and Pharmaceuticals) or by a reduction of the profit margins (estimated at maximum 0,6
to 0,9%) – see report 2 in Annex 10.
There are several advantages of an EPR scheme including:
 A better application of the polluter pays principle (in line with the
recommendation of a recent Court of Auditor report), entailing an incentive for
industrial producers to develop less toxic products;
 Reduced pressure on public budgets and water tariffs while ensuring a stable and
reliable financing of the required investments needed to treat micro-pollutants;
59
 Expected gains in governance through new dialogue and contractual relations
between wastewater operators and relevant industrial producers.
The alternative to an EPR scheme would consist in a ‘classical’ financing of the
required investments: 1.186 € bn/year by 2040 would have to be covered by water tariffs
(€ 0.83 bn/year38
) and public budgets (€ 0,37 bn/year). These increases of water tariffs
and public budget contribution would come on top of the expected increase due to the
other measures identified in the preferred option (see section 7.1). Most of the advantages
identified above linked with an EPR scheme would then be lost (incentives for less toxic
products, gains in governance) while an occasion to better apply the ‘polluters pays’
principle would be missed despite the obligations included in the Treaty and the
recommendation of the Court of Auditors (see section 2.1.3.2.).
6.6 Non-domestic discharges
The average cost of taking samples and make analysis of a large spectrum of substances
in the inlets and outlets of the wastewater facilities is estimated at € 5.000 per sample (ref
in Annex 10, report 1). At least two samples would be taken each year for the facilities
above 100.000 p.e. and one every two years for the facilities between 10.000 and 100.000
p.e. – this would give an overview of the type of pollution coming in and going out the
facilities, while keeping the number of samples proportional to the purpose of the
exercise. This information can be used then to better ‘track’ non desirable pollution
entering the plants and take further measures to limit at source this pollution. The total
costs at EU level would amount to € 25,695 million per year.
The additional costs of ensuring more transparency and when required consultation of the
wastewater operators on the permits given to facilities connected to the public network is
difficult to assess in absence of data on the number of permits. The impact assessment for
amending the IED concludes that a better alignment between the IED and UWWTD
would result in reduced releases of polluting substance to water and may require a
limited number of IED operators to invest into treatment equipment on site.
The benefits of this measure are multiple (but not quantifiable): (1) reducing pollution at
source will improve the quality of the sludge but also of the treated water making it
available for reuse notably in agriculture; (2) the functioning of the wastewater treatment
could also be improved; (3) less pollutants will be released into the environment and
more coherence will be ensured with the EQSD. This would help to achieve the
objectives of preventing pollution at source and improving the ‘circularity’ of the whole
sector. In order to improve the knowledge on micro-plastics releases, regular monitoring
should be progressively put in place based on harmonised sampling and analytical
methods.
6.7 Energy neutrality and GHG emissions
The estimated costs and benefits to move towards energy neutrality are summarised in
Table 9: below. The average cost of establishing energy audit every 5 years was
estimated at 4.000 € per audit (ref in Annex 10, report 1). In a first period (by 2030), the
audits would be imposed only on the larger facilities above 100.000 p.e. (total costs at
38
Assuming that ‘historical’ ways of funding water infrastructures would continue: 70% would be covered
by water tariffs, the 30% remaining by public budgets – see Figure 10
60
EU level of € 0.74 million per year). Average monitoring yearly costs are estimated at €
12 million at EU level (between 8.3 and 15,8 million per year).39
To meet the 2040
energy neutrality target, audits and monitoring would also be needed by 2035 for all
facilities above 10.000 p.e.: 81.4% of the total load (and energy use) would then be
covered with 7.527 facilities. The total annual cost by 2035 for all audits would then
amount to € 6 million per year and the monitoring costs would reach an average of € 98,7
million (between € 67,5 and 130 million per year). Imposing audits and systemic
monitoring on facilities below 10.000 p.e. would be disproportionate (large number of
facilities for a limited treated load and related energy use – see Figure 12).
Costs
(million
€/year)
Expected
savings
(million
€/year)
GHG
emission
reduction
(tons
CO2e/year)
% of
avoidable
GHG
emissions
Monetised
benefits
(million
€/year)
Baseline 410 510 1.188.477 11,85% 118,9
Energy neutrality 1.560 2.000 4.660.695 45,46% 466,07
Energy neutrality target
compared to baseline
1.150 1.490 3.472.218 33.61% 347,22
Table 10: Costs and benefits by 2040 associated to energy neutrality in comparison with the
baseline - € million by 2040
In this IA, an estimate of the costs needed to move towards energy neutrality was
calculated based on the solid experience of Denmark (annual cost of 22,65 million € per
year to cover investments with between 10 and 40 years of amortization time). An
extrapolation of the DK figures at EU level would lead to an annual cost of € 1,561
billion (EU capacity of 517 million p.e. compared to 7,5 million p.e. in DK). The main
investments in Denmark were devoted to biogas production from sludge (around 85% of
the investments) complemented by intelligent control and management, renew of heat
pumps and aeration. No investments in other renewables like solar or wind production
were included in the calculation. Reaching energy neutrality would represent a direct
financial saving of 2 billion € per year for the whole sector – which is the actual costs of
the energy used in wastewater treatment facilities. (ref in Annex 10, report 1). The
potential net saving linked with an energy neutrality target would therefore amount
to € 0,439 billion per year for the sector.
The data on the costs to reach energy neutrality provided by Denmark are based on a
successful and concrete experience. Their extrapolation to the whole EU is most
probably leading to an over estimation of the costs as digestion of the sludge would not
always represent the most cost-effective solution to produce renewable energy: the
potential for wind or mainly solar production could be more significant in other MS. At
the same time, the potential savings (2 billion € per year) were calculated before the
recent events in Ukraine having led to a significant increase in energy prices.
In the context of this IA, and in the light of the uncertainties mainly related to the
evolution of the energy markets, a very prudent and conservative approach was taken:
39
Annual operational and investment costs are estimated between € 12 and 21.000 per facility. It is was
estimated that 75% of the facilities have already monitoring in place - see Annex 5.1
61
it was assumed that the costs of additional investments and related administrative costs to
reach energy neutrality would be compensated by the financial savings due to increased
energy efficiency and the production of renewables. By doing so, it can be assumed that
potential savings are under-estimated with energy prices expected to increase in the
short/mid- term. These potential savings will contribute to limit the potential increases of
water tariffs and public budget intervention (see section 7.1).
Similarly, extrapolating the DK experience shows that the equivalent of around 16.000
GW/h of biogas (similar to the consumption of SE for instance) could be produced in the
EU thanks trough sludge digestion. This biogas can be used as natural gas and substitute
EU imports of gas which is one of the objectives of the REPower EU Plan.
Other advantages of such a target are summarised in Table 10 below. The contribution of
this target to the objectives of this IA (objective 3) but also to the implementation of key
EU policies related to climate change, energy including EU independence are
compensating the additional administrative burden mainly due to increased energy audits
in the sector.
Contribution to
Objective 3
(EGD)
Contribution to
RePower
EU/energy
independence
Contribution to
ESR, REDII and
EED targets
Administra
tive burden
No action (baseline scenario) + + + 0
Energy neutrality target ++++ ++++ ++++ --
Table 11: Comparison of the pros and cons of an energy neutrality target
The added value of the energy neutrality target is clearly demonstrated in Table 10 and
Table 11. Compared to the baseline, reaching energy neutrality by 2040 would lead to a
reduction of GHG of 3.472.218 tons of CO2eq – representing a monetised benefit of €
347,22 million which compared to the baseline without an energy neutrality target
represents a clear improvement. The costs to reach energy neutrality would be more than
compensated by the expected financial savings due to energy savings and production of
renewables. And the production of renewables in particular biogas would contribute to
the independence of the EU in terms of energy production.
6.8 Governance – transparency
According to the OECD (see Annex 10, reports 5 and 6), additional costs can be expected
at the beginning for operators not having in place a systematic monitoring of their key
performance indicators. On the longer run, regularly monitoring of key performance
indicators will provide a better understanding on potential operating improvements and
savings. Making these key indicators publically available by digital means and on the
water bills is expected to increase public willingness to pay but also collective awareness.
A better empowerment of citizen might also lead to additional pressure on wastewater
operators to improve their performances. The potential concrete effects are difficult to
quantify, but as shown in Figure 9, the margins of progress might be significant.
In the absence of better estimates, it was assumed that the additional costs linked with the
regular performance monitoring and with ensuring transparency would be more than
compensated by the expected savings for wastewater operators. These new requirements
will be fully aligned with the new requirements of the recently adopted Drinking Water
62
Directive in terms of transparency and follow-up of key indicators. This coherence is
needed as water bills cover, in most MS, both water supply and sanitation.
The implementation of a possible EPR scheme for micro-pollutants will have a direct
effect on governance: wastewater operators will be requested to negotiate and implement
service contracts with PRO with clear objectives and performance requirements.
6.9 Wastewater and health
Ensuring a permanent dialogue between public health authorities and competent
authorities for wastewater will bring multiple benefits in terms of public health. New
pathogens could detected at early stage as well as the spread of different diseases but also
other public health relevant parameters.
The potential costs for the establishment of a wastewater surveillance of SARS-CoV-2
virus was calculated on a basis of regular sampling and analyse (twice a week) for around
70% of the population. For the EU 27, the total cost would amount to 20 million € per
year (JRC 2020 – estimate made in the context of the Recommendation to the MS). In
2021, the Commission has provided a financial support of € 20 million to MS having
applied for a support (26 MS) to accelerate or intensify wastewater monitoring. In all
cases, these costs would be by far exceed by the benefits for the society linked with an
improved prevention and management of the pandemic.
The same reasoning would apply for other health related parameters including AMR
surveillance. For the later, the cost of bi-annual sampling and analyse of AMR in larger
water treatment facilities above 100.000 p.e. representing around 46% of the EU
population would amount to € 9,74 million per year (€ 5.000 par sample/analyse).
6.10 Access to sanitation
Similarly to the requirements of the revised Drinking Water Directive, MS would be
required to first identify marginalised and vulnerable people not having access to
sanitation and then take measures to ensure/improve access to sanitation. MS would also
be encouraged to ensure/improve access to public toilets in cities for all. The
identification of the marginalised and vulnerable people lacking access to sanitation
would be very similar to the requirements already in place under the revised Drinking
Water Directive. Therefore, no additional major costs are expected.
The costs of the actual measures to improve access to sanitation would have to be defined
at local level depending on local conditions. No EU target would be fixed, but just an
obligation to take measures based on a proper identification of the concerned people. MS
would also be ‘encouraged’ to improve access to public toilets in their cities including for
vulnerable and marginalised people, but again without any specific EU target.
In order to enforce the new requirements on access to sanitation, MS would be required
to regularly report (every 5 years as in the DWD for access to water) on the actions taken
to improve access to sanitation. No estimate of actual benefits could be calculated,
however it is likely that the benefits in terms of both public health and welfare would be
higher than the costs.
63
6.11 Reporting
Compared to the baseline, and taking into account all preferred options, the yearly costs
and savings related to reporting obligation are summarised in Table 11 and detailed in the
report in Annex 10, report 1.
Whilst the overall process of data gathering will be simplified, the revised UWWTD will
require that MS collect more data. This would allow assessing compliance for the new
requirements regarding SWOs and urban runoff, energy, GHG emissions.
At EU Commission and EEA levels, no major changes are expected: the savings linked
with the abandonment of the two years reporting would be compensated by the efforts to
regularly verify the national databases and the additional efforts to ensure compliance for
the smaller facilities (between 1.000 and 2.000 p.e.).
Commission
and EEA
Member
States
Operators Municipalities EPR
Costs of € 10
million – once
Minor
savings
expected
from
reduced
reports
under
Article 17
E-PRTR/UWWTD: limited
savings
Reporting small agglo: € M
0,471
GHG/Micro-pollutants
monitoring: € 109,7 million
SWO/Urban
runoff: € 57,7
million
Cost for PRO of €
11,2 million and
for the concerned
sectors € 5 million
Table 12: Reporting costs and potential savings by 2040
Adapting the existing reporting system using a common format would nevertheless imply
a one-off IT cost – estimated at € 10 million for the EU. The EEA is already working on
improving its reporting system following this approach. This is also the line taken in the
revised Drinking Water Directive – which will increase the synergies and coherence
between the reporting obligations, ultimately providing more accurate data for the overall
Environmental Monitoring Framework as set up under the 8th
Environmental Action
Programme, and more specifically feeding the bi-yearly Zero Pollution Monitoring
Report.
At MS level, the potential savings due to the simplification of the system (national
databases directly accessible to operators combined with the abandonment of the 2 year
reporting obligations) would be compensated by the additional reporting obligations on
micro-pollutants, energy neutrality. 13 MS having less than 5% distance to target would
not be obliged to report under Article 17 – representing another limited saving of €
32.032 per year; additional savings can be expected by better aligning Article 17 to the
enabling condition under the Multiannual Financial Framework 2021 – 2027.
At Municipal level, additional costs will arise from the obligation to establish integrated
plans on SWO/urban runoff (€37,03 million) plus costs of monitoring (€ 20,57 million).
Part of these costs could be shared with operators. As explained in section 6.1, adequate
planning and monitoring could save major investments.
At Operators level, additional administrative costs are expected for small
agglomerations not currently covered by the Directive (€ 0,471 million). Reporting work
for operators above 2.000 p.e. will broadly remain similar to the current work – gains in
terms of digitalisation would compensate the additional efforts required to report more
data notably on GHG, energy, micro-pollutants and other parameters. Enhanced
64
coherence between reporting obligations under the E-PRTR and the UWWTD may result
in limited savings in administrative burden. Monitoring costs are expected to increase for
operators: € 11 million will be necessary to monitor micro-pollutants, € 98,7 million for
energy and GHG. Assuming that (1) the monitoring costs for micro-pollutants would be
covered by the EPR scheme; (2) 40% of the operators are either mixed or private
companies (the others being 100% public), the addition administrative costs for the
mixed/private sector would amount to € 39,29 million per year. These additional costs
will be in any case passed on the competent public authorities having contracts with these
operators and be compensated by the gains expected from the application of the energy
neutrality target (see section 6.7).
Additional administrative costs of € 16.6 million per year are associated with the new
EPR scheme (see section 6.5) mainly for the PRO (€ 11.2 million) and to a lesser extent
for the sectors (€ 5 million – declaration of what is set on the EU market).
65
Costs €
million/year
Benefits €
million/year Benefits/Costs
Effectiveness -
water pollution
Coherence
with the Green
Deal Enforceability
Admin. burden
- number of
facilties/agglo
Admin. burden
- Costs €
million/year
Strom Water Overflow/Urban run off
1. All agglomerations at risk > 100.000 p.e. 219 451,3 2,06 + + +++ 914 43,1
2. All agglomerations at risk > 10.000p.e. 372,5 785,6 2,11 ++ +++ ++ 2.966 57,6
3. All agglomerations > 10.000 p.e. 1.241 2.618,6 2,11 +++ +++ +++ 7.754 77,2
Small Scale Agglomerations
1. All agglomerations > 1.000 pe 140 224 1,60 ++ + +++ 19.138 0,472
2. All agglomerations above 500 pe 284 416 1,46 +++ + + 49.492 0,748
Nitrogen and Phosphorus Removal
N avoided
(tons/year)
1. Low ambition - N/P removal only for all
facilities above 100.000 pe 801 1.447 1,81 54.817 + +++ 917 -
2. Medium – as above + N efficiency to 85% and
P to 90% 1.420 3.965 2,79 168. 228 +++ +++ 917 -
3. N/P removal for all facilities > 10.000 pe 1.395 2.274 1,63 84.603 ++ +++ 7527 -
4. N/P removal for all facilities above 100.000
pe + facilities between 10 and 100.000 in
sensitive areas + N/P increased efficiency 2.009 5.286 2,63 215.133 ++++ +++ 4.222 -
5. High ambition - All facilities 10 kp.e. + N
efficiency to 85% and P efficiency to 90% 2.598 6.689 2,57 282.524 +++++ +++ 7527 -
Micro Pollutants
(Total Toxic
load avoided
p.e.)
(Toxic load
avoided - areas at
risk p.e.)
1. Low ambition - all plants > 100 k pe 841 59.236 32.875 + +++ 917 -
2. All plants >100 k pe, + plants 'a risks'
between 10 k and 100 k 1.186 68.198 41.836 +++ ++ 5.544 -
3. High ambition - all plants > 10k pe with
dilution < 100 2.652 103.431 41.836 +++++ ++++ 7.527 -
Table 13: Summary of the selection criteria applied for each option – the preferred Options are in green – all costs and benefits are estimated by 2040
66
7. PREFERRED OPTION
7.1 Preferred Option – summary
The main actions included in the preferred option are summarised in Table 14 below,
which includes indicative deadlines. On top of the actions included in the Table, by 2025
additional monitoring activities would be in place: this concerns non-domestic releases
(section 6.6), COVID-19 and AMR (section 6.9), key performance operator indicators
together with actions to improve transparency (section 6.8). National and EU databases
should be in place (section 6.11) and ‘vulnerable and marginalised people’ should be
identified together with actions to improve access to sanitation (section 6.10).
2025 2030 2035 2040
SWOs and Urban
Runoff
Monitoring in place Integrated Plans for
agglo. > 100.k p.e.
+ areas at risk
identified
Integrated Plans in
place for
agglomerations at
risk between 10 and
100k p.e.
Indicative EU target
in force for all
agglomerations >
10.000 p.e.
Individual
Appropriate
Systems
Regular inspection in
all MS + Reporting
for MS with high IAS
EU standards for
IAS
Small scale
Agglomerations
New thresholds of
1.000 p.e.
All agglo.> 1.000
p.e. compliant
Nitrogen and
Phosphorus
Identification of areas
at risk (agglomerations
10 to 100k p.e.)
Interim target for
N/P removal
facilities > 100.000
p.e. + New
standards for N/P
N/P removal in all
facilities above
100k p.e. + Interim
target for areas at
risk
N/P removal in
place in all areas at
risk (between 10
and 100k p.e.)
Micro-pollutants Setting up Extended
Producer
Responsibility
Schemes
Areas at risk
identified (facilities
10 to 100k p.e.) +
Interim target for
facilities above
100.k p.e. (50% of
the facilities
equipped)
All facilities > 100k
p.e. equipped +
interim targets for
areas 'at risk'(50%
of the concerned
facilities between
10 and 100 k p.e.
equipped)
All facilities at risk
equipped with
advanced treatment
Energy Energy audits for
facilities above 100k
p.e.
Audits for all
facilities above 10k
p.e. (50% of the
energy neutrality
target met)
Interim target for
energy neutrality
(75% of the energy
neutrality target
met)
Energy neutrality
met and related
GHG reduction met
Table 14: Summary of the key actions included in the preferred option
By 2040, the impacts of the preferred options are summarised in Figure 16 and in Table
15 below. Compared to the baseline, the total pollution would be reduced by 4,8 million
p.e. (or 105.014 tons) for BOD, 56,4 million p.e. for N (or 229.999 tons), 49,6 million
p.e. (or 29.678 tons) for P, 77,4 million p.e. for toxic load of micro-pollutants and 24,8
million p.e. for E. coli. These reductions represent 27% of what is ‘technically feasible’
for BOD, 62% for N, 61% for P, 63% for the toxic load of micro-pollutants and 50% for
67
E. coli. Micro-plastics emissions would be reduced by 9% mainly through actions on
SWO and urban run-off.
Figure 15: Preferred option – impacts on emissions (p.e. per year in 2040) – a breakdown per
MS is provided in Annex 7, Table A7.7
BOD N P E. coli Micro-
pollutants
GHG
reduction
Storm water and
urban runoff
1.346.247 1.455.249 1.427.839 2.160.989 6.558.744
Small
agglomerations 3.448.911 2.187.882 2.277.889 3.616.469 2.609.814
Nutrients
management - 52.719.582 45.873.500 18.979.050 - 1.391.488
Micro-pollutants
treatment - - - - 68.197.761
Energy and
GHG 3.472.218
Total reduction
p.e. 4.795.158 56.362.713 49.579.228 24.756.508 77.364.162
Total reduction
tons/year) 105.014 229.999 29.678
4.863.706
Reduction as a
% of maximum
feasible
27% 62% 61% 50% 63%
Table 15: Emission reduction by 2040 – preferred option
With the planed measures to reach energy neutrality, GHG emission would be reduced
by 3,472 million tons by 2040 compared to the baseline, or 33,71% of the avoidable
GHG emissions. Together with the baseline (assuming GHG emission reduction due to
the application of the EED and ESR) and compared to 1990, this would represent a
0
50
100
150
200
250
300
BOD N P E. Coli Micro pollutants
Preferred option - impacts on Emissions (million p.e.)
Baseline Preferred Option (2040) Maximum feasible
68
reduction of 62.51% of the GHG emissions - which is compatible with the EU Climate
Law and the ‘Fit for 55’ climate package.40
The annual costs and the annual monetised benefits of the measures included in preferred
options are presented in Table 3 below. Investments costs are displayed in Table 6. The
annual costs include operational and investment costs taking into account a lifetime of
the investments of 30 years to which a discount rate of 2.5% was applied (see Annex 4
for more details).41
As from 2040, the total cost would amount to € 3,793 bn per year
(less than 2,76% of the costs of the maximum feasible scenario - € 13,870 bn). Overall,
the total costs at EU level (€ 3,848 bn/year in 2040) are below the expected monetised
benefits (€ 6,643 bn per year by 2040 – of which 6.157 bn are related to improvements
to water quality and 0,486 bn to GHG emission reduction due to better N management
and energy neutrality).
Costs (€/year) Administrati
ve costs
(€/year)
Total costs
(€/year)
Monetised
benefits
(€/year)
Proportionality
(Benefits/Cost
s)
Storm water and
urban runoff
372.472.648 57.600.000 430.072.648 785.687.648 2.11
Small
agglomerations
140.406.278 472.000 140.878.278 224.242.435 1,6
Nutrients
management
2.008.825.659 0 2.008.825.659 5.285.693.790 2,63
Micro-pollutants
treatment
1.185.512.586 27.600.000 1.213.112.586 0 Reduction of
the toxic load
of 68.198 p.e.
Energy and GHG Note42
347.221.754 Energy
neutrality
Others
(AMR/Covid
surveillance, non
domestic waters)
55.700.000
Total 3.707.217.171 141.372.000 3.848.589.171 6.642.845.627 1,726
Table 16: Summary of 2040 costs and benefits of the preferred option and summary of the
investments needs between entry in force and 2040
Proportionality
The preferred option will allow emission reductions contributing to the achievement of
the main objective of this review (Objective 1 in section 4) in a cost-effective way. As
shown in Table 3, the benefits are higher than the costs for each individual measure of
the preferred option. For energy neutrality as the financial costs are expected to be more
than compensated by the financial savings (see section 6.7), only monetised benefits due
40
According to the EEA, GHG emissions from the sector amounted to 49,2 million tons of CO2eq in 1990
of which 18,6 can be considered as ‘avoidable’.
41
In the context of this IA, a net present value analysis was not applied as the investments and most of the
related benefits will occur progressively and in a linear way between the entry in force and 2040 (no major
time gaps between investment time and appearance of the benefits).
42
As detailed in section 6.7, administrative costs related to energy audits (6 million/year) and
monitoring/reporting energy and GHG emissions (98,7 million/year) as well as investments costs needed to
reach energy neutrality are expected to be compensated by the financial savings due to improved energy
efficiency and increased production of renewables.
69
to GHG emission reduction are taken into account leading to a positive benefit/cost ratio.
For micro-pollutants, in absence of monetisation of the benefits (see section 6.5), the
preferred option is the most cost effective, leading to the highest reduction of the toxic
load in particular in sensitive areas compared to the costs of the action. In summary, the
preferred option includes a proportionate package of measures representing the best
‘value for money’ of all possible options: as displayed in Table 10 and in section 6,
careful attention was given to find an optimal solution based on:
 the costs and the benefits analysis (or the cost effectiveness analysis in the case of
micro-pollutants in absence of monetised benefits): the benefits are higher than the
costs for all measures and all MS;
 administrative burden/enforceability - by targeting only a limited number of
facilities/agglomerations, significant results can be obtained on key parameters such
as pollution reduction, energy use and GHG emissions while keeping administrative
burden at a reasonable level and ensuring a high level of enforceability;
 the introduction of a risk-based approach will help ensuring that investments are
taking place where they are needed – this is the case for N/P and micro-pollutant
reduction, but also for SWOs/urban run-off.
When necessary to reach local optimal solutions, flexibility was left at national or local
levels. This is the case for instance to achieve the objective of energy neutrality or to
reduce emissions from SWOs.
If the costs are relatively well known and quantified, this is less the case for some
benefits: reliable monetised values are only available for a limited set of parameters such
as direct savings from energy use, GHG emissions, BOD, N and P emission to water but
also recent estimates of the benefits from improved management of SWO and urban run-
off (see section 6.1). Some benefits can be quantified but not monetised: this is the case
for instance for micro-pollutants and micro-plastics (no available shadow prices) but also
reduction of E.coli in waters (leading to more possibilities of bathing areas for instance).
Other significant benefits were impossible to quantify due to the lack of proper
methodologies: this is the case for access to sanitation and health related parameters
(COVID-19 and its variants and AMR surveillance) but also the benefits linked treatment
cost reduction for drinking waters producers due to improved quality of surface water.
Costs coverage
The total costs by 2040 would represent an increase of 3,85% of the current total
expenditures for water supply and sanitation (around 100 bn € - OECD (2020) – Annex
10, report 5). These additional expenses would be partly covered by the new EPR system
– € 1,213 billion/year. The remaining part – 2,64 billion/year - would be covered by a
mix of water tariffs and public budgets, depending on the financing strategies applied by
each MS. On the basis of the current financing strategies of the MS (see Figure 10), it
can be assumed that on average 30% (or € 0,791 billion/year) of the additional costs
would be covered by public budgets. 70% (or € 1,848 billion/year) would then be
covered by water tariffs. This would represent an average modest increase (2,3%)
compared to the overall water billing on the EU (80 billion for water supply and
sanitation in 2018 – source OECD, Annex 5, report 6), even if local/national difference
might be excepted. EU funds (around 2 bn/year for the water sector) would remain
70
indispensable to cover adjustment costs needed to cover the new requirements including
energy neutrality.
Impacts at MS level
The total 2040 cost and benefits for each MS is displayed in Annex 7, Table A7.8 and 9.
Figure 2 shows that – even without taking account of the non-monetised benefits from
micro-pollutants reduction - the benefits largely outweigh the costs in all MS.
Figure 16: Costs and benefits of the preferred option
As displayed in Figure 16, some MS (e.g. DK, IT, MT, CY and PT) would have to make
comparatively more efforts per inhabitant (more than 7 €/year/inhabitant by 2040). This
is due to a combination of objective factors including the lack of past investments in
more advanced water treatment for Nitrogen and Phosphorus, but also geographical
circumstances (low dilution rates across freshwater streams increasing the areas ‘at risk’).
Although the costs for these MS are expected to be slightly higher, the benefits are
nonetheless expected to remain higher than costs in all cases.
0
200
400
600
800
1000
1200
1400
AT BE BG CY CZ DE DK EE EL ES FI FR HR HU IE IT LT LU LV MT NL PL PT RO SE SI SK
Preferred Option - Costs and Benefits per MS
Total benefits (Million €/year) Total costs (Million €/year)
71
Figure 17: 2040 Annual costs and benefits per inhabitants per Member State (excluding costs
for micro-pollutant treatment to be covered by the proposed EPR scheme)
Figure 18 displays the 2040 costs of advanced treatment per MS in relation to the
reduction of the toxic load from wastewater treatment plants. Differences between MS in
terms of additional investment needed can be explained by the presence of more areas
considered ‘at risk’ for micro-pollutants (with lower dilution rates).
Figure 18: 2040 costs of advanced treatment vs toxic load reduction (micro-pollutants in waste
treatment plants)
Social impacts - Affordability
According to OECD, today the general affordability of water services is not at risk in any
country, though in some countries, such as RO and BG, the burden borne by lower
income households is slightly higher than in other MS, being above 5% of the disposable
household income – see Figure 19.
0,00
5,00
10,00
15,00
20,00
25,00
30,00
35,00
AT BE BG CY CZ DE DK EE EL ES FI FR HR HU IE IT LT LU LV MT NL PL PT RO SE SI SK
Costs and Benefits per inhabitant by 2040 (€/person/year -
without micro-pollutants)
Total cost €/year/inhab Total benefits €/year/inhab
0
10
20
30
40
50
60
70
80
0
50
100
150
200
250
300
AT BE BG CY CZ DE DK EE EL ES FI FR HR HU IE IT LT LU LV MT NL PL PT RO SE SI SK
Preferred Option - Micro-pollutants
Cost reduction toxic load (Million €/year) Reduction toxic load (%) In waste water plants
72
Figure 19: Share of water supply and sanitation expenditures in households' disposable
income (2011-2015 average) Source: OECD based on Eurostat43
Social measures to accompany lower income households are in place in several MS – but
not systematically in the whole EU. Nevertheless, particular attention should be paid to
some MS (DK, IT, MT, CY and PT) in which annual costs per inhabitants are expected
to be higher see Figure 18. Affordability is not expected to become an issue in any of
these MS: the average expected increase of water tariffs by 2040 due to the preferred
option would amount to 1,6 €/year/inhabitant (CY) to 7,26 €/year/inhabitant for DK. As
shown in Table 17 below and based on OECD data as displayed in Figure 19, compared
to the lowest 5% income in each country, this would represent a small increase of the
budget devoted to water supply and sanitation (between 0,02% for CY and 0.19% for
PT). Therefore, the share of expenditures due to water supply and sanitation for
households with poorest revenues, would remain below 5% - which is the ceiling
considered as acceptable by OECD.
Practical measures to ensure affordability is mainly a competence of the MS but the
Commission can organise further exchange of best practices notably on social measures
in the water sector in continuation of the seminars co-organised with the OECD and the
MS (see report 5 in Annex 10).
43
Note: Lack of household expenditure data for Croatia and Sweden.
73
Total
additional
cost
€/year/inhab
Water
tariff
coverage
%
To be
covered
by water
tariff
5% lowest
income
(€/year)
Tariff
increase as
% of the
5% lowest
income
Cost to
lowest 5%
income
New total
CY 7,29 21,80% 1,59 6860 0,02% 0,86% 0,88%
DK 7,36 98,60% 7,26 11998 0,06% 1,92% 1,98%
IT 6,84 82,40% 5,64 4421 0,13% 3,68% 3,81%
MT 11,34 55,60% 6,3 5461 0,12% 1,81% 1,93%
PT 7,29 75,00% 5,46 2819 0,19% 3,00% 3,20%
Table 17: analyse of affordability in MS with highest cost per inhabitant (source: OECD
reference5 in Annex 10 and Figure 25 of the REFIT Evaluation
Implementation
As it was the case with the existing Directive (refer to the REFIT Evaluation), there will
be risks of slow or bad implementation of the revised Directive in some MS. These risks
would nevertheless be mitigated with the following measures:
 Contrary to the initial Directive, enough time (2040) would be given to meet the
targets of the revised Directive. This time horizon will provide legal certainty so that
investments can take place on the basis of proper long term planning;
 Interim targets will be included in the legislative proposal for the most important
measures. These interim targets are summarised in Table 1 and will be applied for all
MS. They will help MS to plan their investments sufficiently in advance and avoid a
situation were most of the actions are taken few years before 2040; the interim target
for energy neutrality and for tertiary treatment will take into account the starting
position of each MS;
 The expected effects on public budgets and water tariffs (and therefore
affordability of the water tariffs) are modest while EU funds would remain available
(average of 2 bn/year based on past experience);
 The Commission intends to continue its mixed approach (enforcement combined
with EU funds) which has shown its effectiveness in the past;
 Several aspects of the Directive will be clarified with the revised Directive (‘sensitive
areas’, measures on SWO/urban run-off, better control of IAS) while the simplicity of
the text would be kept (clear and simple requirements with clear deadlines).
In addition, and like it was the case for MS having joined the EU after 2004, those
Member States still having difficulties to reach full compliance today will have the
opportunity to invest directly in most advanced techniques.
Coherence and added value of the initiative
Implementing the preferred option would contribute either directly or indirectly to the
attainment of the objectives of several EU strategies and legislations – see Annex 8 for
74
more details. This is the case for the Zero Pollution ambition (reduction of pollutant
releases in the waters), the 2050 EU Climate neutrality objective and the related EU
Climate law (reduction of GHG emissions due to energy neutrality), the Circular
Economy (better use of resources/sludge, better conditions for water reuse), the
Biodiversity Strategy (green infrastructures) and the Pharmaceutical and the
Chemical strategy (less releases of pharmaceuticals in the environment, financial
incentive for substitution of harmful substances). Reducing nutrient emission will
directly contribute to the preservation of the Biodiversity. In addition, direct synergies
can be excepted withy the Biodiversity strategy and the application of nature restoration
targets in urban areas (nature based solution for better water management in urban areas).
As it was already the case with the existing Directive (see the Evaluation), the revised
Directive would directly contribute to achieving the objectives of the Water Framework
Directive – namely reaching the good ecological and chemical status of water bodies by
2027. It would also contribute to the planned revision of the EQS Directive: the
additional treatment of micro-pollutants would allow the attainment of more stringent
EQS in the environment. This also the case for the ongoing review of the Bathing Water
Directive: reinforcing the standards of the UWWTD particularly for SWO and urban
runoff would contribute to the improvement of the quality of the bathing water. Better
controlling pollution at source would help to ensure a safe use of sludge in agriculture
and thus support the ongoing review of the Sewage Sludge Directive and the Soil
Strategy and the proposal for the Soil Health Law. It will also provide an incentive for
more and better re-use of treated water contributing to improve water resilience.
Synergies will be fully exploited with the ongoing review of the E-PRTR Directive
notably for what relates to reporting for the larger facilities. Coherence between the
revised IED and UWWTD will be improved to avoid non desirable industrial releases in
public networks.
The energy neutrality target would act in synergy and complement with the revised RED
and recast EED by contributing to meet the targets of each of these directives in an
optimal way for each wastewater treatment facility combining energy efficiency, use of
renewable energy and production of biogas. By encouraging the self-production of EU
based biogas, it would also contribute to reduce energy dependency, one of the objectives
of the recently adopted Communication ‘Repower EU’. Last but not least, this sectoral
target would help moving towards the EU objective of climate neutrality by 2050 and
contribute to the implementation of the ‘Fit for 55’ and the ESR (expected GHG
emission reduction of 3,472 million tons (33,71% of the avoidable GHG emissions) by
2040 compared to the baseline which assumes the application of the revised EED.
Regular monitoring of COVID-19 and its variants and other health related parameters
will help to improve the preparedness of the EU for future possible outbreaks – as
detailed in the related Communication and in the Commission recommendation on virus
surveillance in wastewaters.
75
Uncertainties
The main uncertainties are summarised in Table 18. More details on model uncertainties
are provided in Annex 4.
Uncertainty Measure taken to identify/limit
uncertainties
How it was taken into account in policy
development?
Baseline – lack of
understanding of MS
existing actions on
rain water, small
agglo., IAS
In depth consultation of the MS
on their starting positions –
Annex 5.
No major influence. Costs and benefits per MS
might be slightly different but are linked (if
costs for a MS increase or decrease, benefits will
also increase or decrease).
Baseline – lack of
information on how
MS will apply the
EED, RED and ESR
Prudent assumption taken in the
baseline based on the best
existing available information
(strict application of the energy
use reduction target from the
EED proposal for the public
sector across all MS)
Applying the proposed energy neutrality target
will generate more savings, benefits and GHG
reduction in MS not having initially the
intention to act in the wastewater sector to reach
their targets under the RED, EED and ESR. The
reverse impacts are expected in MS having
already targeted this sector. Overall at EU level
it would not change the analysis neither the
conclusions on the added value of the energy
neutrality target.
Unknown starting
positions of the MS in
terms of energy
neutrality
Very conservative assumptions
were taken on the cost and
benefits of reaching energy
neutrality
Interim targets were fixed by 2030 to allow MS
with a less favourable starting position to align
themselves with the others. MS starting with a
less favourable position are expected to gain
more benefits from the energy neutrality target.
Different starting
situations for SWO
and urban runoff.
Development of an EU scale
model calibrated on known
situations.
Flexibility left to MS and their local authorities
to design optimal solutions at local level.
Lack of reliable to
monetise micro-
pollutants benefits.
The preferred option was
identified on the basis of cost-
effectiveness.
Options were decided on the basis of lowering
the costs while maximising the toxic load
reduction.
Lack of data on the
actual toxicity of
micro-pollutants, as
well as their removal
efficiency by standard
techniques.
The best available data and
scientific knowledge was used to
make estimates – see Annex 10
reports 2, 13 and 14. More than
1.300 representative chemicals
were assessed giving a fair
representation of the toxic load
and how it can be reduced.
Advanced treatment is required to reduce
toxicity, independent of the specific chemicals.
The comparison of policy options is robust with
regard to the variation of chemical properties
driving toxicity. The introduction of a possible
EPR scheme will help to gather precise data.
The scope of the EPR scheme can be adapted to
improved knowledge on micro-pollutants.
Table 18: Main uncertainties and their potential consequences
76
The sector is relatively well known, reliable databases are in place on all treatment
facilities above 2.000 p.e. including on their level of treatment. The estimation of
conventional pollutant loads under the various scenarios, and the related costs are
relatively well established and show relatively low variability across Europe. The main
uncertainties are related to the estimation of toxic loads conveyed by wastewater and to
the sources of pollution not addressed by the current Directive. There are also
uncertainties related to the application of the ESR, the RED and the EED current and
revised legislations.
7.2 REFIT and “One in, One out”
In line with the Evaluation, several elements of the existing Directive will be clarified
and simplified in the legislative proposal on the basis of the elements discussed in this
IA. This concerns notably the requirements for SWO and urban runoff and small scale
agglomerations (clear thresholds and deadlines), the designation of ‘sensitive’ areas (list
of basins placed in the Annex of the revised Directive), clearer obligations to ensure full
compliance for IAS, and improved follow-up and transparency of operator’
performances. For the new requirements, a lot of attention has been paid to establish
simple, clear, enforceable and affordable deadlines and objectives – the Evaluation has
demonstrated the importance of clarity and enforceability of this Directive.
Apart from the expected increase in water tariffs, no additional obligations are expected
for EU citizens. This is also the case for business (water industry providing wastewater
equipment’s) which will mainly benefit from new business opportunities. The new
requirements will represent a driver for innovation and research contributing to
maintain and improve the competitive position of the EU water industry. The
Pharmaceutical and PCPs sectors would nevertheless be required to organise and finance
the new system of producer responsibility to cover the costs related to advanced
additional treatment for micro-pollutants (1,185 bn € per year) and the related
administrative costs (11,2 million per year – see section 6.5).
The revised Directive will introduce new obligations mainly for wastewater operators.
They cannot be considered as ‘business’ as all operators have strong direct links with
the public competent authorities – either they are public companies (60% of the
operators) or private/mixed companies directly acting for public entities (concessions).
Measure of the
preferred
option
Storm water
and urban
run-off
Small
agglomerations
Nutrients
management
Micro-
pollutants
treatment
Total
Total
investment up
to 2040
6.446.657.281 1.141.228.243 12.129.508.400 8.891.344.396 28.608.738.319
Table 19: Total investments costs linked with the preferred option between entry in force and
2040. To calculate annual costs, a lifetime of the investments of 30 years was applied with a
discount rate of 2.5% (see Annex 4 for more details).
Adjustment costs to cover the required investments needed to meet the new standards
and to reach energy neutrality will be progressive in time (see Table 14 and Table 16):
total investment costs are estimated at € 28,6 billion between the entry in force of the
77
revised Directive and 2040 – see Table 19. In absence of sufficient data on the baseline
situation in each MS on energy neutrality, it was not possible to provide a reliable
estimation of the investments needs for this measure.
To cover these investments, MS and local competent authorities are expected to continue
using a blend of different sources of financing:
 Public budgets, including from the EU (e.g. around 2 billion € per year of EU funds
are devoted to water infrastructures, particularly under EU regional policy);
 Loans from commercial or institutional banks (such as the European Investment
Bank) – wastewater projects are typically ‘bankable’ as they are covered by stable
revenues from water tariffs and/or energy savings;
 Private/public partnerships and/or concessions in which the private partner is
financing the infrastructures.
 The investments needed for the additional treatment for micro-pollutants (9 billion €
up to 2040 from the total 28,6 billion €) will be covered by the EPR scheme, and
more precisely by the Producer Responsibility Organisations (PROs) managing
them. As detailed in section 6.5, the PROs will have to establish a solid financing
strategy to cover such costs based on the funds gathered thanks to the fees paid by its
members.
 The recently adopted REPowerEU Plan will also boost existing funding possibilities
to cover the investments needs to reach energy neutrality. This concerns the cohesion
policy, large scale innovation calls, loans under Recovery and Resilience Facility.
MS already have and will have several possibilities to cover the investments needed
to meet energy neutrality target through these EU funds as they all aim at increasing
the independence of the EU in terms of energy supply by encouraging energy savings
and developing renewables – which is also one of the purpose of the energy neutrality
target.
8. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?
As shown in the Evaluation, proper monitoring and reporting is key to ensure the
compliance of the Directive. It is therefore crucial to maintain and improve where
possible the existing monitoring and reporting obligations so that it will be possible to
assess to what extent the general and specific objectives are achieved.
The existing Directive has established a reporting system based on a 2-year report from
the MS to the Commission via the EEA. Based on this information the Commission is
publishing implementation reports every two years (often based on more than 4 years old
data). The Commission is also using this information to launch infringement procedures.
As detailed in sections 5 and 6, this system will be modernised and simplified: national
databases to be updated at least once a year will be hosted in each MS with permanent
access for the EEA and the Commission. These databases will include actual monitoring
results for the parameters covered by EU standards not only for the quality of the treated
water but also for the new parameters to be followed such as energy use and GHG
emissions. Monitoring frequencies will also be adapted to ensure an appropriate follow-
78
up of the implementation of the Directive but also to simply align the frequencies to
current best practices.
As it is the case today, regular compliance checking will be made by the Commission on
the basis of the information reported by MS.
Different indicators to measure success can be extracted from MS reports and would be
related to:
 The existing compliance rate and distance to target per MS and per treatment level -
which provide an excellent overview on the implementation of the Directive;
 The number of facilities equipped with additional treatment for N/P and micro-
pollutants; and the related reduction of N/P releases and toxic load at MS and EU
levels;
 The energy use by MS and the related GHG emissions;
 The number of agglomerations covered by integrated management plans for
stormwater overflows and urban run-off and their compliance with the EU objective;
 The measures taken by MS to improve access to sanitation and better control
individual appropriate systems (IAS) and a summary of the main health indicators
surveyed in the MS.
Like it was the case in the context of the evaluation of the Directive, other data notably
on the water quality of the receiving waters (rivers, lakes and seas) coming from the
Water and the Marine framework Directives will be used to concretely measure the
impacts of the UWWTD.
More details on possible parameters to be reported for assessing compliance and measure
the success of the Directive are provided in Annex 10.
A first in depth evaluation of the revised Directive can be foreseen by 2030 when most
investments should have been made in larger facilities (see Table 1). This first evaluation
would allow assessing the success and remaining challenges linked with the
implementation of the revised Directive. If need be, corrective measures could be
envisaged to ensure the full implementation of the revised directive. Another evaluation
could be considered before 2040 to prepare a possible review of the directive.
79
ANNEX 1: PROCEDURAL INFORMATION
1. LEAD DG, DECIDE PLANNING/CWP REFERENCES
The preparation of this impact assessment was led by Unit C2 Clean Water Services and
Marine Environment within DG Environment (ENV) with support from DG Joint
Research D2 Water and Marine Resources. The file concerns the revision of the Urban
Wastewater Treatment Directive. This Directive was evaluated according to Better
Regulation guidelines in 2019. The Decide planning number is Plan/2020.7347 –
Revision of the Urban Wastewater Treatment Directive.
2. ORGANISATION AND TIMING
The revision of the Urban Wastewater Treatment Directive (UWWTD) is a direct
consequence from its REFIT evaluation. It was announced in a number of strategies
published under the European Green Deal, such as the Circular Economy Action Plan
(CEAP) and confirmed more recently in the Zero Pollution Action Plan. The Inception
Impact Assessment Roadmap for the revision of the UWWTD was published on 21 July
/2020 with a feedback period until 8 September 2020.
The inter-service steering group (ISSG) for the impact assessment is the same one as for
the Evaluation. It is a shared group with other water and pollution related files: the
revision of the pollutant lists under the EQSD and Groundwater Directive, the Evaluation
of the Sewage Sludge Directive and the back to back Evaluation and impact assessment
of the Bathing Water Directive. The ISSG includes members from the following DGs:
AGRI (Agriculture), CLIMA (Climate Action), ENER (Energy), FISMA (Financial
Stability, Financial Services and Capital Markets Union), GROW (Internal Market,
Industry, Entrepreneurship and SMEs), HOME (Migration and Home Affairs), JRC
(Joint Research Centre), JUST (Justice and Consumers), MARE (Maritime Affairs and
Fisheries), RTD (Research and Innovation), REGIO (Regional and Urban Policy),
SANTE (Health and Food Safety), SG (Secretariat General), SJ (Legal Service), TAXUD
(Taxation and Customs Union) as well as the EEA (European Environment Agency).
Meetings were organised between June 2020 and January 2022, the final meeting being
held on 31st
January 2022. The ISSG has been consulted on all major deliverables for this
file, including the inception impact assessment, the open public consultation
questionnaire, key deliverables for the support study prior to the its submission to the
Regulatory Scrutiny Board. The same ISSG has followed the while process having led to
the adoption of the REFIT Evaluation of the Directive.
3. CONSULTATION OF THE RSB
The Regulatory Scrutiny Board (RSB) was consulted on the Evaluation of the Directive.
On 17 July 2019 the RSB meeting on the draft SWD Evaluation was held. The RSB gave
a positive opinion on 19 July 2019 and suggested a few improvements which were taken
on board before the finalisation and publication of the evaluation.
An informal upstream meeting with the RSB took place on 23 September 2020 on the IA.
During the meeting ENV explained that the options will be built into packages that range
from less ambitious to more ambitious. The costs and benefits of each package will be
80
assessed as far as possible. They should all aim to meet all objectives of the initiative.
RSB suggestions and answers provided in this IA are summarized in Table 7.
After final discussion with the ISSG, a draft IA was submitted to the RSB on 15th
February 2022 and discussed at a meeting with the RSB on 16th
March 2022. Following
the opinion of the RSB from 18th
March 2022, a revised IA was submitted to the Board
on 2nd
of May. A second ‘positive opinion with reservations’ was issued by the RSB on
3rd
of June. Table A1.1 presents an overview of the RSB's comments and how these have
been addressed.)
RSB Comment – second Opinion How the comment has been addressed
(1) The report does not present a fully developed
and dynamic baseline scenario. It is neither
sufficiently clear how the measures expected from
the Member States to meet their national ‘Fit for
55 targets’ nor how the recent actions under the
Repower EU package have been incorporated and
which overall energy saving gap would remain in
absence of further sector specific action and
targets.
Section 5.1 has been improved to better explain that
all possible efforts have been made to build a
dynamic baseline and why the only reliable
mandatory quantitative target applicable for this
sector is the legally binding target on energy
efficiency for public entities (reduction of energy
use of 1,7% per year for the public sector). This
target was included in the calculations of the
baseline scenario as displayed in the new Table 3 of
section 5.1. It was also better explained that no
quantified precise information is available on
Member States intended efforts to reduce GHG
emissions from the wastewater sector in order to
reach the objectives of the Fit for 55 and the ESR
regulation. The potential effects of the REPowerEU
Plan (adopted after the submission of this report) are
discussed in section 5.1 on the baseline scenario and
in sections 7.1 and 7.2. The REPowerEU plan does
not include specific objectives for the wastewater
sector as such therefore only its qualitative effects
on the baseline scenario are presented in section 5.1.
Nevertheless, the preferred option will contribute to
achieve the objectives of the package by reducing
energy use and increasing the production of
renewables including biogas. This is better
explained in section 7.2.
(2) The report does not sufficiently demonstrate
the need for and value-added of new sector
specific energy neutrality targets over and above
the already envisaged obligations for Member
States.
The need and the added value of this specific target
are better explained respectively in sections 5.2.7
and 6.7 - Tables 10 and 11. The contribution of this
target to the attainment of different EU objectives is
better discussed in section 7.1 while the flexibility
on Member States choices are discussed in section
5.2.7. More details are provided on how the costs to
reach energy neutrality were estimated and why the
extrapolation made on the basis of the Danish
concrete and successful experience is reliable and
provide a robust base to justify the target in the
context of this impact assessment. It is also better
explained why the recent increase in energy prices
makes the assumptions taken in this report (expected
costs will be covered by the expected financial
savings) even more realistic and probably too
prudent. More details on stakeholder views are
provided in the same section - recent information
and contributions from industry were also included.
More explanations in section 5.2.7 and 7.1 (Table 14
and section on implementation) are provided to
81
justify how the interim target would be fixed while
the Table 18 on uncertainties was completed to
discuss the possible effects of different starting
positions of MS as regards energy neutrality.
(3) The report does not sufficiently justify the
proportionality of individual measures as well as
of the preferred option considering the estimated
investment needs.
Expected overall investment needs seem to
substantially outweigh monetised benefits. The
report should explain whether it can be reasonably
assumed that all Member States will cover these in
a timely manner (including those less reliant on
water tariffs). It should be explicit about whether
there are any risks for the implementation of the
measures and for benefits materialising.
The report should better demonstrate the
proportionality of the preferred option, preferably
on the basis of a net present value analysis. When
it comes to the proportionality assessment of the
stormwater overflow options, the report should
better justify why it did not choose, as preferred
option, the one, which provides the highest net
benefits overall, performs best in terms of
effectiveness and enforceability and has the most
favourable benefit-cost ratio.
When assessing the proportionality of imposing
energy neutrality targets, the report should better
reflect the relative small contribution to the overall
monetised benefits and the uncertainty that the
targets will be the most costefficient measure
among those available for the Member State
The report should better explain the robustness
and validity of the used evidence on the
willingness to pay. It should justify why, in order
to extrapolate to EU level, it assumes 10% of the
value determined for the case study of Berlin in
terms of public willingness to pay for ecosystem
services associated with drainage. As willingness
to pay depends on income, the report should
explain why it did not consider a comparison of
Germany’s GDP and the EU average or other
means of extrapolating.
Table 16 and section 7.1 were improved to show
that for each of the proposed individual measure in
the preferred option the annual benefits are
systematically higher than the annual costs (except
for micro-pollutants for which a cost/effectiveness
approach was used). In that sense, all individual
measures are justified in terms of proportionality. In
section 7.1 (implementation), more details are
provided on the measures taken to limit the risks of
non-timely implementation of the preferred option
by the MS. Those MS less reliant on water tariffs
are also those having more margins to increase their
water tariffs without affecting affordability.
A footnote (41) was added to explain an NPV
analysis is not relevant in this context and the
justification for the preferred option on stormwater
overflow (most cost effective) was clarified in
section 6.1.
The uncertainties related to the energy neutrality
target were better identified in Table 18, section 7.1.
More details are provided in section 6.1 on why the
10% assumption applied the willingness to pay from
the Berlin case is reasonable in the context of this
IA.
The report provides more information in an annex
regarding the proposed extended producer
responsibility scheme. It should be explicit about
whether there are any choices for policy makers in
this regard and if so, present them in the main
report.
The main choices to be done by policy makers were
explicitly summarised in section 6.5.
The report provides stakeholder views without any
numbers (either percentages or 3 absolute
numbers). This presentation may be misinterpreted
as a representative survey which is not the case.
The report should be more specific on the views of
particular categories of stakeholders and Member
States, including by explaining why certain
academics, business or Member States authorities
More efforts were achieved in the report to better
summarise and quantify where possible stakeholder
views. It was not always possible to verify during
the consultation some more precise assumptions or
issues like the calculations made on the costs and
the financial benefits of reaching energy neutrality.
There was nevertheless a broad consensus on the
need to act with a combination of measures
82
were less supportive on some issues. including better monitoring, audits, energy
efficiency with less overall support for EU based
targets.
RSB Comment – first Opinion How the comment has been addressed
(1) The report should be clearer about how the
initiative fits in the context of existing legislation
and initiatives. It should explain the coverage of
each of these and identify the remaining gaps that
the revised Directive would be expected to
address.
Sections 1 (introduction) and 7.1 (preferred options)
were improved and completed by a summary Table
in a new Annex 8 displaying the main interactions
with other legislations. In addition in each ad hoc
section the gaps of the existing legislation are
discussed as well as the potential added value of the
initiative.
(2) The report should explain clearly the evidence
base for considering sector-specific Energy
Neutrality Targets and further measures related to
Green House Gas emissions. It should be specific
on the scale of the identified Green House Gas
emission reduction and energy savings gaps under
the dynamic baseline, fully reflecting the impacts
expected from the requirements of the Effort
Sharing Regulation, the Energy Efficiency
Directive and other relevant ‘Fit for 55’ initiatives.
It should explain how the new targets and
measures are expected to interact with the ‘Fit for
55’ initiatives, how double regulation will be
avoided and flexibility for Member States on the
choice of the best measures in reaching their
overall reduction targets will be ensured. It should
better justify the 2040 time horizon used for the
baseline, given the need to ensure coherence with
the 2050 climate neutrality objectives and the
envisaged measures in the adopted ‘Fit for 55’
package.
On GHG emissions, sections 5, 6 and 7.1 have been
clarified to better explain the interactions with the
exiting initiatives (Climate Law and by the Effort
Sharing Regulation). It was clarified that the
revision of the UWWTD does not have the ambition
to set any additional legally binding target for GHG
reduction. The justification of a sector based energy
neutrality target is further detailed in the IA in
sections 1 (introduction), 2.1.2.2 (problem
definition), 5.1 (baseline), 5.2.7 (options), 7.1
(preferred option) and further detailed in a new
annex 8.
This includes an analysis of the added value of a
sectorial target compared with the baseline including
the application of the EED and ESR (additional
reduction of energy use and related reduction of
GHG emission from the sector but also development
of local optimal solutions combining energy
efficiency, renewables and bio-gas production). The
contribution of this target to the EED and ESR is
better explained as well as its added value in the
context of the recently adopted ‘Repower EU’
Communication in section 6.7. The justification for
the 2040 horizon (the main objective and main
investments of this initiative are related to water
quality improvement) is better explained in the
introduction of section 6.
(3) When it comes to micro-pollutants, the report
should further elaborate on the Extended Producer
Responsibility scheme it considers. It should set
out the main elements and present the key policy
choices to be made by policy makers (e.g. scope,
progressive expansion) and assess the costs and
benefits of available alternatives.
More detailed explanations on the envisaged EPR
system (scope, policy choices, possible alternatives,
costs and benefits) were included in sections 5.2.5
and 6.5 although more details on the functioning of
the EPR scheme were provided in a new Annex 9.
The possible impacts of an alternative based on a
‘classical’ financing system is discussed in section
6.5.
(4) The report needs to strengthen its narrative
significantly and the argumentation in support of
the proportionality of the preferred set of
measures, in particular on SWOs and urban runoff.
It should make an effort to further quantify the
expected, most significant, benefits. Where this is
not possible, the report should explain why and
provide qualitative analysis to support the
conclusion that the benefits overweigh the costs. It
should provide more convincing arguments to
show how the intervention is expected to bring
New evidence based on recently published articles
were included in section 6.1 showing (1) how costs
could be reduced with good integrated management
plans and digitalisation and (2) new estimates of the
potential benefits based on ‘willingness to pay’
beyond water quality of improved storm-water
overflows management. In addition, more flexibility
was introduced (EU objective would become
indicative leaving more flexibility at local level
while focusing actions only in areas ‘at risk’) so that
optimal solutions would be decided at local level
83
about the non-monetised benefits and the extent to
which this will happen. It should show the order of
magnitude (e.g. case studies, expert estimates,
literature) of the benefits expected to materialise.
It should present a more balanced analysis of
benefits and costs, fully reflecting the recurring
and the (quite high) one-off investment costs. For
‘one in one out’ approach, it should only include
the costs to businesses and citizens.
based on decentralised analysis of the costs and the
benefits. This has reduced the investment needs
while increasing the benefits leading to an
improvement of the proportionality of the measure.
In consequence, the proportionality of the whole
package has improved and is better demonstrated in
section 7.1 (preferred option). The benefit/cost ratio
is largely positive for all MS. Section 7.2 (One in,
One out) was adapted to only focus on costs for
citizens and businesses.
(5) The report should show more transparently
where the impact is expected to be different across
Member States. It should explain how the
financing of the investment costs will be ensured.
In this context, it should be more explicit about the
expected use of EU funding to support the
measures envisaged. It should also be more
explicit about possible affordability issues for low-
income households and whether this poses any
risk for implementation.
Additional information on the impacts on MS were
extracted from annex 7 and included in section 7.1.
More details are provided in section 7.2 on the
financing of investment costs based on OECD
analyse. Additional detailed analysis on affordability
was included in section 7.1.
(6) The analysis should report more systematically
on the different views expressed by the consulted
stakeholders.
More details on stakeholder point of views were
extracted from the consultation process and from the
Evaluation to the main text.
(7) The report should specify when the initiative
will be evaluated, and how success will be
measured.
Section 8 and Annex 10 were completed to better
explain when evaluations would be undertaken and
what success indicators will be used.
Some more technical comments have been sent
directly to the author DG.
All suggestions were taken on board.
Table A.1.1: RSB comments and how comments have been addressed
4. EVIDENCE, SOURCES AND QUALITY
Besides the stakeholder consultation, the following main sources of information were
used to build this impact assessment:
1. Models developed by the JRC: The JRC has developed for several years’ models on
water quality and quantity in the EU. These models were adapted to the policy questions
related to the impact assessment and to the review of the Directive. They were also used
in the context of the REFIT Evaluation of the Directive.
2. Consultation of ad hoc experts: under the co-lead of JRC and DG ENV, a small
consortium of experts were consulted on specific policy questions. For each issue, a
report was prepared and used directly in the IA or to improve the JRC model. All reports
are annexed to this IA (see Annex 7). In particular, the JRC cooperated with experts to
assess which micro-pollutants are the most typical to be found in wastewater and what
treatment technologies exist to deal with these micro-pollutants. In addition, individual
experts provided input through the drafting of short analytical peer-reviewed studies,
financed under an administrative agreement with the JRC on the following topics:
individual and other appropriate systems, antimicrobial resistance, combined sewer
overflows and urban runoff, nutrients, micro-plastics, and greenhouse gas emissions from
the wastewater sector.
3. Support from the Organisation for Economic Cooperation and Development
(OECD): DG ENV cooperated with the OECD to develop a benefit methodology for the
UWWTD IA. This was done, among others, to address methodological shortcomings
uncovered in the Evaluation of the UWWTD. Furthermore, the OECD re-assessed the
84
investment gap to reach full compliance with the current UWWTD. OECD also provided
analysis of the issues related to transparency and governance.
4. In depth consultation of the Member States: in order to establish a solid baseline
scenario but also to gather evidence on the best practices in place in the Member States, a
specific consultation of each Member State was organised in 2020. For each country a
fiche was pre filled with the hypothesis JRC intended to use in the context of the
modelling. Each fiche was about 50 pages long and contained tentative assumptions on
how far advance the Member State is in implementing policy measures that go beyond
the current Directive. Member States had a 4-6-week period of time to comment on the
information and the assumptions. The main assumptions taken per MS are summarised in
Annex 5.
5. To support the analysis of the different options, the European Commission awarded
two support contracts to external consultants:
 for the general Impact Assessment Support Study, a consortium of consultants
comprised: Wood E&IS GmbH (consortium lead) with Trinomics, Ricardo, IMDEA,
ELLE and Tyrsky.
 another consortium led by BioInnovation in association with RDC Environment,
AirQuality Consultants, VVA Economics & Policy and CETAQUA Water
Technology Center assessed the feasibility of an Extended Producer Responsibility
System for micro-pollutants.
Further evidence was compiled from the Evaluation report of the UWWTD (2019), the
OECD water investment needs study (2020) and a vast variety of background
information submitted by stakeholders over the course of the IA. Further information
regarding the evidence used is included in each section via footnotes as well as in Annex
10 (references). In addition, extensive consultation of stakeholders was carried out, as
detailed in Annex 2. The data used in this IA are those that were available when the
calculation model was developed (data from 2016). Data for 2018 were in the meantime
available. The difference between the 2016 and the 2018 data set is minimal (less than
0,5% of distance to target) due notably to the long time period needed for the investments
to produce their effects. These differences have no influence on the conclusions related to
the main and the preferred options detailed in this impact assessment.
85
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT)
The impact assessment accompanying the revision of the Urban Wastewater Treatment
Directive was subject to a thorough consultation process that included a variety of
different consultation activities, as set out in the Consultation Strategy. The methods
selected for consulting stakeholders consisted of semi-structured interviews (speed
dates), interactive workshops with the option to send additional feedback after workshop,
a broad online public consultation (OPC) to reach a large range of stakeholders on a
variety of topics as well as written consultation on factual information and assumptions
for modelling. A final stakeholder conference was held to have their views on the
different policy options proposed by the Commission and was divided into three main
sessions.
1. CONSULTATION STRATEGY & ACTIVITIES
The consultation strategy identified groups of stakeholders and consultation activities.
The consultation strategy was developed at the start of the study by DG Environment,
assisted by its consultants.44
The strategy identified groups of stakeholders, consultation
activities and mapped these as presented below. Table A2.1 below presents the different
groups consulted and the consultation approaches:
Stakeholder groups
Consultation activity
Open public
consultation
Member State
overviews
Interviews
Stakeholder
workshops
Final
conference
EU Member States and their
public authorities
x x x x
Industrial/economic actors,
including small and
medium sized enterprises,
represented through EU
level association.
x x x x
Non-Governmental
Organisations
x x x x
International organisations x x x
Academia, research and
innovation
x x x
Citizens x
Table A2.1 below presents the overview of the stakeholder activities:
Consultation
activity
Attending
Stakeholders
Main discussion points and results
29/01/2020-30/01/2020
Making water fit for life –
LIFE and the Urban Waste-
Water Treatment Directive
Over 100 participants:
technical experts from 53 EU
LIFE and 7 H2020 projects
representing 14 member
states.
Key discussions outcomes included: 1) Circular economy
aspects need to be included in the new UWWTD.
Harmonised EU Regulatory Framework is required to
facilitate the secondary use of raw materials. Particular focus
should be on energy and nutrient recovery. 2) Contaminants
of emerging concern are generated through pharmaceuticals
and other products, which therefore require a shared
(extended) responsibility to be applied. Raising awareness to
change attitudes and behaviour in society is key. But lack of
financial resources present barriers to develop technologies.
44 European Commission (2021) UWWTD Consultation strategy
86
3) SWOs ad CSO need more precise and more ambitious
regulation. Potential solutions included NBS and green
infrastructure, and sustainable drainage systems. 4)
Legislation/ regulation needs to drive the development of
improved technologies, especially in relation to online, real-
time monitoring.
21/07/2020-08/09/2020
Roadmap feedback
57 replies from business
associations (35%), NGOs
(14%), individual companies
(25%), public authorities
(14%), EU citizen (9%) and
research institutes (2%) from
across the EU.
General support for the revision of the Directive
Important topics to consider in the revision: micro-pollutants,
energy consumption, sludge and water reuse management,
address SWOs, climate neutrality and coherence with other
EU legislation.
14-16/10/2020
Speed dates with selected
stakeholders
10 stakeholders representing
the wastewater sector or
related sector and interests
(e.g. env. NGOs).
All stakeholders received a
background document with
draft policy ideas in advance.
Overall general agreement on the topics identified for the
revision. New topics: access to sanitation and water reuse.
Divergent views between those preferring a risk-based
approach compared to those in favour or stricter standards.
Audits for energy and climate neutrality generally supported.
22/10/2020
UWWTD Member States
expert meeting.
100 participants from all EU
MS.
A background document with
draft policy ideas was
circulated in advance.
Informal meeting to present preliminary ideas for policy
measures to the MS providing room for feedback (orally and
in written format).
Though problems with remaining pollution are
acknowledged, MS are cautious regarding the cost and
benefits of addressing them.
Support regarding better management of energy use.
26-27/11/2020
Joint DE/EC UWWTD
Revision conference on
nutrients and micro-
pollutants.
About 200 participants from
Member States and
stakeholder associations.
A background document was
circulated in advance of the
conference.
There is room for improvement regarding nutrient
management (min. targets and definition of sensitive areas)
under the UWWTD
Few MS already address micro-pollutants in wastewater,
control at source, monitoring and addressing micro-
pollutants in hotspots is needed. EPR could be a solution to
deal with additional costs.
19/02/2021
Expert workshop on a
computational scheme for
GHG from wastewater.
About 20 experts.
A draft computational scheme
was circulated in advance
among the experts.
Different methods to monitor and calculate GHG emissions
for the wastewater sector were discussed.
23-24/03/2021
Joint workshop with the EEA
on reporting. 11th
reporting
cycle, 12th
reporting cycle,
Treatment Plant under the E-
PRTR and the Industrial
Emissions Portal,
streamlining of monitoring
and reporting.
127 participants from all 27
Member States and observers
from the UWWTD Expert
Group.
A background document was
circulated in advance.
MS appreciated focus on simplification of reporting. QA/QC
is a major burden.
Art. 15: some MS already use datasets that can be filled by
operators directly.
Art. 16: general agreements that this Article is outdated and
information should be more tailored to what is location-
specifically interesting.
Art. 17: agreement that this Article needs to be simplified
with a focus on access to EU funding.
20-21/04/2021
Joint workshop on sludge and
urban wastewater in light of
climate change and the
circular economy.
Day one: 323 participants
from 15 Member States.
Day two: 290 participants
from 16 Member States.
A background document was
circulated in advance of the
workshop.
Key discussions outcomes included: 1) Participants indicated
the need for more data to be collected on WWTP processes
for better quantification of energy consumption/production.
2) Energy auditing and the tracking of energy use was
portrayed as a key area to fill data gaps. 3) Participants were
concerned about GHG emission targets since the data gap to
set a well-informed baseline was missing.
28/04/2021-21/07/2021
Online Public Consultation
(12 weeks)
A total of 285 responses and
57 position papers were
received from stakeholders in
22 Member States.
The OPC consisted of introductory questions related to
respondent profiles, followed by a questionnaire divided into
two parts: the general questionnaire and the targeted expert
survey. The OPC included questions to examine the general
public’s perception of the success and needed improvements
of the UWWTD, as well as an expert section that targeted
those with more expertise to elaborate on their views
regarding specific measures to be taken in the impact
assessment of the directive. The survey was made available
in all EU languages on the Have Your Say Portal and
uploaded to the EU Survey tool.
04/05/2021
Cost and benefits workshop.
80 participants from all
Member States and
Key discussions outcomes included: 1) to identify all
uncertainties and be transparent about these, 2) synergies and
87
stakeholder associations. trade-offs between policy measures should be considered and
3) a revised Directive will lead to additional cost while some
MS are still “catching up” with the current Directive. For
these MS it is expected that the revised Directive will lead to
efficiencies in implementation.
29/04-21/05/2021
Member State overviews and
targeted questionnaires.
25 out of 27 Member States
replied to the written
consultation.
For all Member States detailed factsheets on topics related to
urban wastewater management were prepared to reflect the
current situation in the country in particular identifying
where the current practices are going beyond the UWWTD
requirements. All factsheets included tailored assumptions
for the Member States that would be used for the modelling
of the baseline. Member States were asked to validate and
add to the information provided.
22/06/2021
Workshop in approaches for
integrated management of
collecting systems in the
revision of the UWWTD.
177 participants from 27 MS
and 6 from third countries,
stakeholder associations and
local authorities.
Key discussions outcomes included: 1) NBS and green
infrastructure need more knowledge sharing and financial
support for further implementation, 2) Targets for SWOs and
urban runoff need to be set at EU level while still allowing
MS control to account for local conditions, 3) Collection
systems need to deliver sustainable solutions to urban
environments while maintaining/achieving good/high status
of water bodies, 4) Modelling and regular water quality
monitoring systems may be costly and time intensive but
provide necessary information for developing collection
systems.
August 2021
Interviews
A few selected EU-level
stakeholder associations were
contacted for further
information on specific topics.
A series of targeted interviews was organised in the final
stage of the data collection. A list of questions was sent to
them ahead of the interviews which were then discussed.
Interviews focused on remaining gaps including costs and
benefits of the various options considered.
26/10/2021
Stakeholder conference
312 participants from 226
organisations and all 27 MS.
There were a total of 9 non-
EU participants from Iceland,
Morocco, Norway, Scotland
and Serbia.
Key discussions outcomes included: 1) Industrial pollution
needs to be addressed up-stream using the polluter pays
principle, 2) NBS and green infrastructure to be considered
in addressing SWOs and IAS, 3) UWWTD should be aligned
with existing legislation (e.g. WFD), 4) facilities must
contribute to climate-change mitigation (energy efficiency
audits were welcomed as a first approach), 5) improving
resource recovery and water reuse, 6) apply risk-based
approaches for advanced treatments, and 7) participants
recognised that interventions at different levels of
governance are necessary (proportionate and require clarity
on the roles of the stakeholders).
88
2. STAKEHOLDER GROUP
Overall, the consultation activities have been successful in reaching the identified
stakeholder groups as defined in the consultation strategy. All Member States and the
vast majority of industrial/economic actors were represented. For citizens, the OPC was
the primary approach for engagement. While citizens were the second highest group of
respondents in the OPC, the number was overall low when considering it in the context
of the entire project.
A wide range of stakeholders groups were involved throughout the activities, for example
the split of groups involved in the OPC is presented in the figures below. Figure A2.1
below shows the share of the 228 participants by stakeholder type for the OPC.
Although 285 stakeholders participated in the OPC, only 228 of those answered the
question about the stakeholder type they represented. In the OPC, stakeholders were
asked to indicate the sectors which they represented (by selecting three subjects that were
relevant to the representation of their organisation).
Figure A2.2 below illustrates the representation of different sectors in the OPC:
Stakeholders from all EU Member States and third countries were involved in the
consultation process. For example, the final conference saw participants from 226
organisations across all 27 Member States. In addition, there were a total of nine non-EU
participants representing Iceland, Morocco, Norway, Scotland and Serbia.
21%; 61
19%; 55
17%; 48
15%; 42
11%; 30
8%; 23
5%; 15
2%; 6
1%; 2
1%; 2
0%; 1
- 10 20 30 40 50 60 70
Company/business organisation
EU citizen
Public authority
Business association
Non-governmental organisation (NGO)
Other
Academic/research institution
Environmental organisation
Trade union
Non-EU citizen
Consumer organisation
23%, 143
23%, 139
12%, 75
11%, 69
6%, 34
5%, 33
3%, 18
2%, 14
3%, 16
3%, 16
2%, 15
0 50 100 150 200 250
Waste water treatment sector
Water industry and/or…
Public sector
Biodiversity and/or environment
Non-governmental organisation
Scientific research
Energy
Urban planning and development
Chemical industry
Climate Policy
Other
89
3. METHODOLOGY AND TOOLS USED TO PROCESS THE DATA
All feedback submitted through different consultation activities was collated and taken
into account in the analysis presented in the impact assessment. Questionnaire responses
from the OPC were obtained from the European Commission Survey system. For the
final OPC data download, no significant update of formatting/data structure was required.
The steps followed were: the raw data was imported and cleaned in an Excel template; no
campaigns were identified, but small series of duplicated responses were noted. There
were three sets of duplicated responses which were not removed but it has been ensured
duplicates are not double-counted the statements in the open-response analysis. It is
considered that these duplicates have no impact on the overall results.
Graphics presenting the details of the responses, distinguishing stakeholders’ categories
and Member States were created via Excel. Respondents had the option of elaborating on
their answers in open text fields or responding to stand-alone open-ended questions.
Responses in all languages were analysed after having been translated to English using
machine translation. Survey data was then analysed and coded. The aim of the coding
exercise was to identify the keywords and themes mentioned by respondents and then
attribute these as established “codes” for which a consensus can be built and counted. For
instance, if one respondent mentions a need for more transparency, “more transparency”
can be coded and then used to count further responses that communicated the same need.
Finally, any attachments, links, or other materials submitted by stakeholders were
analysed and incorporated throughout. Qualitative and quantitative data obtained from
workshops, interviews and the conference were summarised in respective reports
(available on CIRCABC) and included into the analysis of individual measures in the
impact assessment. Feedback from consultation activities has been integrated into the
assessment of policy measures per area of improvement, informing recommendations for
each area. The MS overviews have been integrated into the final report through a
horizontal analysis as well as informing detailed assessment of policy measures per area
of improvement.
Overall, the evidence collected throughout the consultation has been compared with other
evidence gathered, namely with results of individual consultations as well as the results
of the literature review, modelling and data analysis. This triangulation of several
research methods helped to identify whether there were any major divergences between
different sources of evidence.
4. OPC – GENERAL VIEW
The OPC was divided into five sections. After some initial questions regarding the
profile of respondents, sections 2-3 were addressed to all respondents and covered
respondents’ understanding of the UWWTD, their views on the problems relating to
wastewater pollution, and how to best address water pollution through wastewater
treatment processes. Section 4 was targeted at expert respondents and included more in-
depth questions on specific measures to address in the revision of the Directive. Finally,
respondents could share additional relevant materials/publications and/or information in
section 5. As most of the questions were not mandatory, the total number of responses
for each question varies throughout the report.
A high number of respondents agreed that wastewater was correctly treated before
discharge in their country of residence, particularly respondents from Germany (n=64/77,
90
83%) and Austria (n=7/8, 87%) who overall showed the most agreement. When asked
whether urban wastewater was an increasing source of pollution, stakeholders mostly
disagreed with that statement, with 59% (n=159) disagreeing (particularly respondents
from Germany, Austria, Spain, and Sweden with 75%, 100%, 79%, and 84% of
respondents disagreeing, respectively).
When asked about the risk perception of pollution from untreated wastewater, almost all
risks were rated by more than half of respondents (n=152), as a significant concern. The
topic ranked of the highest importance to be addressed in the upcoming revision was the
improved implementation of the polluter pays principle; where 68% of respondents felt
that this was a very important topic. On the importance of monitoring and removal of
contaminants, there was consensus among respondents that all contaminants listed
required stronger efforts to be addressed. Respondents also indicated that there was a
need for receiving more information (e.g. informing the public).
Open text answer analysis showed that businesses/companies and the public authorities
were mainly concerned with the details of implementing proposed measures and the
potential additional cost burdens. Lastly, the OPC showed all stakeholder groups’
support for measures related to access to sanitation, access to information and more
coherence and alignment of the UWWTD with other policies.
Two topics that stood out as particularly important to experts were the introduction of an
extended producer responsibility (EPR) scheme to further implement the polluter pays
principle and the need to better tackle pollution at-source. However, businesses were the
most critical about the feasibility of the EPR, where all votes for ‘not at all’ effective
(n=16, 7%) came from this stakeholder group.
91
5. STAKEHOLDERS’ VIEWS ON THE DIFFERENT AREAS45
5.1 Storm water overflows and urban runoff
Issues relating to the improved management of SWO and urban runoff were considered
of high importance to all stakeholders.
During the workshop, strong support from participants for the increased use of Integrated
Management Plans was identified, whilst support for target values for SWOs and urban
runoff received the lowest support from participants. Similarly, the OPC results indicated
that a strategic integrated planning approach for management and prevention was highly
supported. OPC respondents were also strongly supportive of NBS playing an increased
role in managing urban wastewater, with 71% of respondents (n=185) rating this as either
very important (5) or important (4). Expert stakeholders were asked about the
appropriateness of various measures to minimise pollution through SWOs and urban
runoff. The most positive response from all respondents was for the statement that a
combination of measures is required to achieve the needed results. Mandatory reporting
of overflows was considered the least appropriate measure, particularly by public
authorities and businesses (average scores 2.9 and 3.2, respectively).
OPC Targeted consultation: How appropriate are the following proposed measures for
minimising pollution through storm water overflows and urban run-off? Please rate on a
scale of 1 to 5 (1 = not at all; 5 = very appropriate). (n= 260).
45
For more details, please refer to Appendix F Views of the stakeholders by area of improvement from the
WOOD report – report 1 in Annex 10
Public authorities; 2,9
Public authorities; 3,2
Public authorities; 3,1
Public authorities; 3,2
Public authorities; 3,5
Public authorities; 3,8
Public authorities; 3,6
Public authorities; 4,1
NGOs; 4,0
NGOs; 4,2
NGOs; 4,2
NGOs; 4,5
NGOs; 4,4
NGOs; 4,6
NGOs; 4,7
NGOs; 5,0
Citizens; 3,8
Citizens; 3,8
Citizens; 3,8
Citizens; 4,1
Citizens; 3,9
Citizens; 4,3
Citizens; 4,2
Citizens; 4,4
Businesses; 3,2
Businesses; 3,4
Businesses; 3,4
Businesses; 3,6
Businesses; 4,0
Businesses; 4,0
Businesses; 4,3
Businesses; 4,5
Academia; 4,2
Academia; 4,3
Academia; 4,4
Academia; 4,3
Academia; 4,2
Academia; 4,3
Academia; 4,4
Academia; 4,7
All respondents; 3,4
All respondents; 3,6
All respondents; 3,6
All respondents; 3,8
All respondents; 3,9
All respondents; 4,1
All respondents; 4,2
All respondents; 4,5
Introducing mandatory reporting for frequency and volumes of
overflows
Introducing continuous monitoring to measure frequency,
volumes and pollution in the network to improve management
Establishing EU targets regarding the management of storm
water overflows and urban run-off (e.g. dilution rates, rain
water treatment capacity, rain water storage capacity and
minimum treatment for run-off)
Providing EU guidance on strategies for preventing, reducing and
managing pollution from storm water overflows and urban run-
off
Applying a risk-based approach to deal with storm water
overflows and urban run-off in line with the Water Framework
Directive (WFD) objectives
Requiring the use of nature-based solutions to reduce the
amount of clean water to be collected in public systems (e.g.
through natural water retention measures, green urbanisation)
Establishing an obligation for agglomerations to adopt a
strategic planning approach to the management and prevention
of storm water overflows and urban run-off (e.g. develop an
integrated management plan for collecting systems)
To what extent do you agee with this statement: 'To be
effective, action must combine several types of measures'
92
5.2 Smaller agglomerations
The need for several types of measures to address the issue was highlighted by
stakeholders. Results from the OPC show that introducing a risk-based approach for
urban wastewater management in agglomerations below a certain size (requiring more
treatment where their discharges can cause problems) was rated the most appropriate
individual measure across all stakeholder groups. Respondents noted that the risk-based
approach was already covered under the WFD. Redefining agglomerations scored an
appropriateness score of 3.6 (1-low and 5-high), however three respondents highlighted
that they were not able to propose a better definition. Suggestions made included
considering size and distance to sewer system. It was highlighted that there is a need to
improve the centralisation and the connection rates of smaller agglomerations to larger
treatment plants in order to reduce pollution impacts.
5.3 IAS
Overall, a flexible system, was favoured and stakeholders also indicated that guidance
was needed on IAS technologies, registration, monitoring, and inspections. From the
OPC, the option to require agglomerations to report to the EC if an IAS is used to collect
more than a set amount of the load was generally perceived as inappropriate to address
the problem. Academics were most supportive of reviewing the EU-wide standards for
IAS (4.8) and generally felt that the measures presented were appropriate. Businesses
were particularly in favour of ensuring connection to public sewer systems (4.1),
providing guidance on IAS technologies (4.0), and reviewing the definition of IAS (4.0).
Citizens were generally supportive of the measures presented but showed a lower
average response for reporting to the EC (3.4) and requiring countries to keep an IAS
registry. NGOs were particularly critical on requiring agglomerations to report to the EC
(3.0). Public authorities, on the other hand, only showed an average positive response for
ensuring connection to the public sewer system (4.0). Measures relating to a risk-based
approach, consumer awareness campaigns, keeping an IAS registry, and limiting IAS use
generally had more support from academia and citizens than from other stakeholder
groups. One NGO respondent also noted the difference that consumer awareness can
create and how education of the general public on these issues can widely encourage an
EU-wide change in behaviour over time. Overall, there was quite a varied interest and
response between stakeholder groups, but also within the different groups themselves.
Several of the position papers submitted addressed the topic of IAS. EurEau supported
the use of a database to record the use of IAS under the responsibility of the local
authority. EurEau and AquaPublica both raised the fact that some flexibility should be
kept so that the cost of connection, and the associated emissions with building networks
are considered.
5.4 Sensitive areas
Overall, stricter N/P emission requirements were supported by stakeholders. While an
obligation for additional treatment where there is a bathing site, shellfish water or a
drinking water catchment downstream (and abandoning criterion b and c in Annex II of
the Directive) was widely supported, a more general stringent standard for N/P treatment
for all large UWWTPs was less popular with OPC respondents. Moreover, with regard to
sensitive areas, the most highly rated measures was providing EU-level guidance (score
4.2/5). Measure 1 on improving the ways ‘sensitive areas’ are designated by requiring the
93
same methodology and criteria to be used and aligning them with the Nitrates Directive
and the WFD (score 4.1/5). Also the less rated one abandon the possibility for MS to
designate less ‘sensitive areas’.
5.5 Micro-pollutants
Across all stakeholders’ categories, increasing consumer awareness on releasing micro-
pollutants and on safely using and disposing products was a widely supported approach
to the issue. Stakeholders generally supported the idea that micro-pollutants are the
responsibility of manufacturers and producers and the concept of source control was
widely supported. From the OPC, on average, all contaminants were ranked with similar
importance. Respondents also commented on the need to prevent pollution at source and
the greater need for the polluter pays principle to be implemented. The results of the OPC
highlight the general desire from respondents for the UWWTD to increase monitoring
and improve the removal of contaminants in wastewater. The responses show that
predominantly respondents felt that manufacturers and producers were responsible for
addressing pollution of most contaminants.
The exception is for urban runoff, where 69% of respondents felt the responsibility lies
with the municipalities (n=71). Industrial wastewater contaminants had the highest rate
of agreement with 91% (n=97) of respondents indicating that this is the responsibility of
manufacturers and producers, which further reflects earlier results on the importance of
tracking industrial contaminants and the importance of the polluter pays principle.
To address micro-pollutants, setting an obligation for EPR to fund upgrades of UWWTPs
had by far the most positive response across all stakeholder groups (4.3) whereas the
introduction of a risk-based approach (3.7) and requiring larger UWWTPs to remove
micro-pollutants based on EU-set performance indicators (3.2) ranked lowest. While
academics, citizens, and NGOs generally felt measures were appropriate, businesses felt
particularly negative towards requiring larger UWWTPs to remove micro-pollutants
based on EU-set performance indicators. Despite there being a lower overall ranking for
the risk-based approach, a number of open responses highlighted their support for
bioassays and their suitability to identify hotspots or effluent toxicity. However, all
respondents noted that there are some challenges in the application of bioassays that need
to be taken into account when identifying the correct bioassay to use under specific
circumstances (n=4). Regarding the position papers, it was commonly mentioned that
substances of emerging concern should be better considered under the revised Directive
text (n=3) and that the list of substances covered should be revised (n=5) and,
furthermore, that this list should be an open and/or live list that can be updated when new
substances of concern emerge (n=2).
94
OPC Targeted consultation: How appropriate are the following proposed measures for
addressing micro-pollutants under the UWWTD? Please rate on a scale of 1 to 5 (n=258)
5.6 Industrial Emissions
Views from stakeholders confirmed that there is a need for action to enhance coherent
legislative requirements, as identified in the recent UWWTD evaluation. This would
include alignment of monitoring and reporting requirements under different sets of
legislation. A generalised comment across all stakeholders was the need for coherence of
the UWWTD with other Directives, especially with the IED.
From the OPC, a very positive response across all stakeholders was recorded for the
measure requiring pre-treatment at industrial installations before wastewater is
discharged into UWWTP. Regarding the type of contaminants that should be prioritised
for removal, on average all contaminants were ranked with similar importance.
Endocrine disruptors and other pollutants from industrial installations had the highest
score, closely followed by pharmaceutical residues, excess nutrients, and pesticides.
Micro-plastics as well as nutrients and pharmaceuticals had a wider spread of responses
resulting in the lowest average rate of importance. Overall, respondents felt that that
stepping up monitoring and removal of all listed contaminants was at least somewhat
important. Industrial wastewater contaminants were considered for 91% of respondents
as being the responsibility of manufacturers and producers, which further reflects the
importance of tracking industrial contaminants, and the importance of the polluter pays
principle.
Targeted interviews drew several conclusions regarding industrial discharges including:
the need for policy coordination, especially with the WFD, but also with the IED, SSD
and Nitrates Directive; mixed views on the added value of IED/BREF process for
wastewaters; a need for further reflection on industrial releases in the urban networks; a
short-list of selected indicators of groups of substances that should be monitored in
treated wastewater and trigger more targeted source control if thresholds are reached; and
Public authorities; 3,4
Public authorities; 3,4
Public authorities; 3,6
Public authorities; 4,2
Public authorities; 4,3
NGOs; 4,1
NGOs; 4,4
NGOs; 4,5
NGOs; 4,8
NGOs; 4,9
Citizens; 4,0
Citizens; 3,8
Citizens; 4,2
Citizens; 4,5
Citizens; 4,6
Businesses; 2,5
Businesses; 3,5
Businesses; 3,6
Businesses; 3,9
Businesses; 4,3
Academia; 3,8
Academia; 3,9
Academia; 4,1
Academia; 4,5
Academia; 4,8
All respondents; 3,2
All respondents; 3,7
All respondents; 3,9
All respondents; 4,3
All respondents; 4,5
Requiring large UWWTPs to remove micropollutants based on
several EU-set performance indicator substances to reduce
micropollutants by X% (X to be defined based on analysis). The
performance indicator substance indicates whether the
treatment has worked
Introducing a risk-based approach using bioassays to identify
hotspots requiring additional treatment upgrades based on
chemical substances present in the water
Adopting EU guidance on good practices focusing on, among
other things, micropollutants, antimicrobial resistance, etc.
Set an obligation for Extended Producer Responsibility Scheme to
fund the upgrades of UWWTPs to improve treatment and to
incentivise research and development into more sustainable
chemicals upstream
To what extent do you agree with this statement: ‘To be
effective, action must combine several types of measures’
95
a general principle in the Directive in relation to industrial releases could be useful
although it is acknowledged that it is difficult to enforce because of resources constraints.
5.7 Energy efficiency, generation and climate neutrality
Stakeholders indicated that more data is required on WWTP processes to enable better
quantification of energy consumption/production. Energy auditing and the tracking of
energy use were highlighted as being key activities which could be used to fill these data
gaps.
The OPC results as well as inputs received during the specific workshops showed that all
stakeholder categories broadly support the generalisation of energy audits. There was a
general recognition on the necessity to better understand and monitor energy use of the
treatment plants so that measures can be taken to reduce energy use and where possible
produce energy. Citizens, NGOs and to a lesser extent academia were supportive on
introducing energy related targets while mixed views were expressed by public
authorities and business. Some representatives from MS and business pointed out that
these targets should be introduced for large UWWTPs only, and, despite the importance
of the 2050 energy neutrality targets, these should not hamper the primary objectives of
UWWTPs; wastewater treatment. Other representative of business were in favour of both
climate and energy neutrality targets. Most advanced MS were clearly supporting an EU
wide target similar to their own target.
In the targeted consultation component of the OPC, proposed measures to address energy
use and emissions were generally not as highly rated as other measures in previous
sections. On average, the highest rated measure was related to introducing an obligatory
energy audit in larger plants (3.8), which was rated highest by academia, citizens and
NGOs. In terms of stakeholder response patterns, academics indicated the most support
for the measure relating to setting energy use reduction targets based on UWWTP sizes.
This was, on the other hand, businesses least rated option, with a generally negative
perception. Overall, none of the stakeholder groups felt particularly positive about
introducing energy efficiency targets at a national level (average 3.0) – in particular,
public authorities did not seem supportive of the measures (2.6).
Academics noted in the open text questions for suggestions that energy efficiency and
regulation of emissions must consider other additional emissions as a consequence, for
example nitrous oxide and nitrogen dioxide (n=2). Public authorities generally expressed
their support for the implementation of energy audits and improved energy management
(n=4), however they also expressed that the best possible purification of wastewater must
not be lost from sight when trying to implement rigid energy efficiency classes (n=1).
The respondents also noted that energy efficiency and management should be strictly
addressed during the design and renovation phases of plants and suggested that the
Directive’s wording should not go beyond suggesting energy efficiency be considered
during these steps (n=2).
Business respondents showed support in particular for energy audits (n=4) but expressed
concerns regarding target setting. Similar to Public authorities, Businesses expressed the
importance of efficient cleaning producers and set it as a higher priority than energy
efficiency, which thus spoke against setting firm targets (n=4).
96
During workshop on wastewater and sludge, the overall feedback of the participants was
that it should be up to MS to decide which interventions to apply to which treatment
plants to achieve the best efficiency results based on local data from operators, treatment
stages and applied technology. The challenge of setting a target across such local
variability without proper baseline remains too significant in absence of energy audits.
In relation to GHG emissions including methane, overall views from stakeholders
confirm that there is a need to better understand the baseline of GHG emissions
generated by UWWTPs in the EU. On the OPC results, stakeholders appeared to be more
interested in energy efficiency investments than in actions to reduce GHG emissions.
This could stem from the fact that many respondents had previously noted that GHG
benefits could be achieved from improvements in energy efficiency. Respondents
generally believe that benchmarking and specific targets should only be set once
sufficient data is collected from audits that would allow a well-informed baseline to be
set. Respondents preferred, if required, that any limits set should be based on plant size
and highlighted the need to go beyond the UWWTP and incorporate the sewer collection
system and other sectors too. Similar conclusions were made during the workshops.
OPC targeted consultation: Response to: How appropriate are the following proposed
measures for improving UWWTPs' energy use and emissions intensity to help achieve
energy use reduction? Please rate on a scale of 1 to 5 (n=258).
5.8 Circular economy
The concept of source control, i.e. targeting substances such as micro-plastics and micro-
pollutants at source, was widely supported by stakeholders in order to improve circularity
in the wastewater treatment sector. Others also highlighted the need for tracking and
more stringent requirements to prevent pollution at source when sludge is used in
agriculture. From the OPC, the most highly rated measure in relation to circular economy
(sludge reuse) was preventing pollution at source (Measure 4: Member States to adopt
strategies for tracking and preventing pollution at source, in particular when sludge is
reused in agro-industrial activities. Track and trace of pollution if sludge reused in
agriculture (consistent for industrial emission requirements above. (4.4/5)), with a less
preferred option setting minimum levels for recovery phosphorous and other resources
Public authorities; 2,6
Public authorities; 3,1
Public authorities; 3,4
Public authorities; 3,6
Public authorities; 3,8
NGOs; 3,2
NGOs; 3,7
NGOs; 4,0
NGOs; 4,2
NGOs; 4,5
Citizens; 3,3
Citizens; 3,5
Citizens; 4,0
Citizens; 4,0
Citizens; 4,2
Businesses; 3,0
Businesses; 2,6
Businesses; 3,1
Businesses; 3,6
Businesses; 4,0
Academia; 3,0
Academia; 4,3
Academia; 3,8
Academia; 4,2
Academia; 4,8
All respondents; 3,0
All respondents; 3,1
All respondents; 3,5
All respondents; 3,8
All respondents; 4,1
Setting energy use reduction targets at national level rather
than for individual UWWTPs
Setting energy use reduction targets based on UWWTP size to
be achieved gradually over time
Introducing target values regarding UWWTPs renewable energy
generation/self-sufficiency over time (i.e. generating energy
through biogas)
Requiring, at first, large (and subsequently, smaller) UWWTPs
and their networks to carry out energy use audits followed by
action to reduce energy use over time (unless it is shown
through standardised energy audits that due to local conditions
it is not
To what extent do you agree with this statement: ‘To be
effective, action must combine several types of measures’
97
(Measure 2: Setting minimum levels for recovering phosphorous and other materials,
such as cellulose, from wastewater and sludge. All valuables in sludge (e.g. materials and
energy) need to be recovered and recycled / Measure 1: Setting minimum levels for
recovering phosphorous and other materials, such as cellulose, from wastewater and
sludge, P recovery mandatory for large UWWTPs > 100.000 p.e. (Score: 3.6/5)).
5.9 Monitoring and reporting
The concept of providing EU-wide guidelines to operators on ‘normal operating
conditions’ in UWWTPs to support comparability of monitoring data received strong
support. Clarifying the requirements on sampling conditions and sampling frequency
were also identified on the OPC as supporting the comparability of monitoring data.
As part of the OPC, the measures proposed relating to sampling frequency and
monitoring did not receive particularly high scores, with the majority scoring below 4 on
average. Providing guidelines for normal operating conditions was generally considered
the most feasible measure (average 4.0). The least rated option was to replace COD
measurements with total organic carbon across all stakeholder groups (average 2.6). All
stakeholders rated very low the deletion of COD monitoring requirements (2.3), which
reflects their willingness to maintain the monitoring standard, rather than removing it
entirely.
Public authorities were less supportive of measures relating to additional parameters and
increasing sampling frequencies. This is likely because such measures would cause
additional burdens for the authorities. NGOs were most in favour of adding additional
parameters. Academics and NGOs generally were supportive of more options than other
stakeholder groups, rating half of the options above 4.0. NGOs noted in particular that
many of the substances that urgently require monitoring (e.g micro-pollutants) often
occur at low limits. The respondents noted that there is a need for establishing analytical
methods for low detection limits in order to monitor these pollutants. This was linked
both to the acknowledgment of the water body condition and, therefore, the coherence
with the WFD, as well as to decisions on water reuse, bathing sites and drinking water
sources. A few businesses also mentioned the need for new monitoring parameters that
should stimulate the use of innovative technology and integration with existing efforts to
improve monitoring practices such as the use of satellite data (n=3). OPC respondents
rated the use of EEA data availability as the highest option overall, indicating that the
interest in providing further information to the public is supported by all stakeholder
groups
Some respondents also noted that harmonisation of data reporting is not the only factor
making comparisons difficult but that diversity in analysis methods and the related
frequencies prevent environmental data from being effectively compared (n=3).
Respondents also noted the importance of new reporting requirements to be aligned with
other EU policies such as the E-PRTR (n=3). In this respect, respondents mentioned that
identifying chemical classes to compare across countries with existing PRTRs and
creating a global PRTR for all relevant policies should be considered. Generally, the
pursuit for simpler and more harmonised reporting was supported by respondents but
there seems concern regarding the increasing ambitions in the other sub areas and the
possible additional reporting costs that this may cause.
98
The conclusions from the workshop on reporting specifically highlight that regarding
Art. 15, some MS already use datasets that can be filled by operators directly; on Art. 16,
there are general agreements that this Article is outdated and information should be more
tailored to what is location-specifically interesting, and finally, on Art. 17, there is an
agreement that this Article needs to be simplified with a focus on access to EU funding.
5.10 Wastewater surveillance
Recent developments have indicated that wastewater surveillance can be used as an early
warning signal for the current coronavirus pandemic and further viral outbreaks that
could occur in the future. These are aspects that are not covered by the existing
legislative framework. Stakeholders preferred the provision of guidelines for
collaboration between UWWTPs and health authorities compared to other measures.
Regarding the OPC, respondents generally felt that the additional costs of wastewater
surveillance should be covered by different groups / entities, but health authorities
received the highest number of total votes (48%, n=122), followed by the general public
(37%, n=93). When asked about measures on how to incorporate wastewater surveillance
in the UWWTD, stakeholders preferred the provision of guidelines for collaboration
between UWWTPs and health authorities, as well as establishing EU-wide binding
standards on implementation. Respondents noted that the characteristics of local
conditions need to be taken into account and, therefore, national rather than EU-level
targets would be more appropriate. Nonetheless, a number of respondents mentioned that
standardization for water surveillance was important.
5.11 Information to the public
Stakeholders appeared to widely support improvements to accessing information from
UWWTPs although accessing real-time information on water quality after treatment was
of least interest.
Results from the OPC show that quality of rivers, lakes, and seas where wastewater is
discharged and the compliance of the UWWTP with the EU, national and regional laws
were the two most highly yes-voted information subjects at 77% (n= 205) and 72%
(n=192), respectively. The least interesting information appeared to be real-time
information on water quality after treatment as well as sources for funding, which had
more respondents voting no or did not know/no opinion than yes.
In the targeted part of the questionnaire, stakeholders were of the opinion that regardless
of what measures are to be taken, there is a strong need to improve the level of
communication and information provided to the public. The highest support among
stakeholders was for the use of the EEA website, providing information relevant to the
public (57% respondents marked this option as ‘appropriate’ or ‘very appropriate’).
5.12 Late implementation
Member States perceive Article 17 as burdensome and many stakeholders supported its
improvements. The OPC drew attention to several observations: over 50% of respondents
agreed with the measure to adjust planning/reporting under Art. 17 to link better with
obligations/reporting with enabling conditions to access EU funds. Respondents felt
mostly quite negative towards the idea that planning and implementation obligations
should be set for those EU countries that receive significant EU funding. Only 19%
99
agreed with the measure as an effective way to improve implementation. A high number
of respondents (at least 30%) did not know or had no opinion on the matter. This may be
because the subjects were outside their area of expertise or that the questions were too
broadly formulated for respondents to give confident answers. Respondents noted a
general lack of funding and a need for better investment planning to be adjusted for
incorporation of other obligations, such as under the WFD, which may increase the costs
of effective treatment and procedures. There were also requests on improving
transparency on investment needs in countries to anticipate future requirements. Overall,
those that provided a response felt political willpower needed to be improved across the
EU and that this could come through pressure, such as infringement and sanctions, from
the EC.
5.13 Access to sanitation
Sanitation is not yet accessible to all EU citizens to the same extent.
There was general support among stakeholders for improved access to sanitation for
vulnerable and marginalised groups.
5.14 Access to justice
Currently, the UWWTD contains no provisions concerning access to justice. Therefore,
this area of improvement and the associated measure are aimed at improving social
justice for both individuals and organisations. Consultation activities aimed to establish
stakeholder views on the issue as well as on potential measures to address the problem.
The majority of the position papers provided recommendations for the revision of the
UWWTD and touched upon the topic of ‘Transparency, governance and justice’. Very
few details were provided on ways this should be improved / strengthened.
6. POSITION PAPERS46
In addition to the response to the online public consultation, a total of 5747 position
papers were received, mostly from business associations (n=25) and companies /
business organisations (n=11). The majority of position papers submitted touched on the
following areas of revision: ‘Fit for the Future’ (n=33), ‘Remaining loads and pollution
of the environment’ (n=12), ‘New pollution’ (n=6) and ‘Transparency, governance and
justice’ (n=5). Overall, there was a particular interest in circular economy, with strong
focus on recovery and reuse of materials from sludge (n=17). There was also support for
addressing energy efficiency and standardising audits (n=12). The EPR also stood out as
an important measure (n=15), particularly as a tool to address pollution at source rather
than end-of-pipe. There was interest expressed in addressing issues from storm water
overflows (n=19) and urban run-off (n=13).
20 additional contributions were received in 2021. The position papers can be divided
into 2 main categories, either providing direct reflection on the stakeholder conference
(n=3, public authorities and one NGO) or providing general inputs and suggestions
46
The list of all the position papers received in 2021 is detailed in Appendix G Position papers from the
WOOD report
47
In total 59 position papers were submitted alongside the OPC submissions, two of which were duplicates
100
regarding the revision of the UWWTD (n=17, public authorities, business association,
NGO and a company).
101
ANNEX 3: WHO IS AFFECTED AND HOW?
5. PRACTICAL IMPLICATIONS OF THE INITIATIVE
The following table summarise the main implications for the affected stakeholders.
Category affected Possible effect
National and
regional
authorities
The EU Member States and national/regional authorities (in
Federal States) will be involved in the implementation and
enforcement of the revised directive, like it is the case for the
existing Directive. Additional investments in wastewater
infrastructure and the necessary operation and maintenance of such
equipment will be required. As shown in section 7, the additional
yearly costs required to implement the preferred option represents
on average an increase of the 3,85% of the yearly expenditures of
the sector. These costs will be covered by a combination of
additional budgets, water tariffs and the new system of producer
responsibility for micro-pollutants. On the basis of the existing
financing strategies in the water sector, additional required annual
public budgets were stimulated at € 0,791 billion/year (see section
7.1). Part of these budgets could be covered by EU funds which
will also be essential to cover adjustment costs. In that sense,
National/Regional authorities will have to make sure that EU funds
are made available and used for the water sector - when it is
necessary.
Also they should maintain/intensify accompanying social measures
in case water tariffs are increased. An appropriate control of the
new system of producer responsibility should be put in place,
representing minor additional administrative costs compared to the
expected financial contribution from the sector (€ 1,185 bn per
year).
Even if the IT tools will be provided by the EEA and the
Commission, National/regional authorities will have to adapt their
reporting system to the revised directive which will include new
requirements but also key simplifications. Overall,
National/Regional authorities will benefit from the proposed
simplification and digitisation of reporting even if part of these
benefits might be cancelled by additional reporting requirements on
access to sanitation, GHG emissions or new pollutants (see Table
11).
The application of the revised Directive will result in better
protection of the aquatic environment and maintaining these assets
is of critical importance to protecting human health and the
environment in Europe. With potential significant economic
impacts – for instance in regions/countries where tourism is a key
source of revenues.
Water/wastewater
operators
Wastewater operators are first in line for compliance with existing
national and European legislations related to water quality
standards. They are responsible for collection, treatment,
102
monitoring and proper discharge of different waste streams.
Wastewater operators are public, mixed or private companies
working for the local competent authorities (municipalities or
group of municipalities).
Changes to the UWWTD will have direct impacts on this sector.
Additional investments will be needed notably to better manage N
and P but also to treat micro-pollutants where it makes sense.
Investments will also be needed to meet energy neutrality - even if
these investments will be profitable on the long run.
Additional monitoring efforts will be required notably to better
understand GHG emission and energy use and to monitor the
achievements on the micro-pollutant reduction (see Table 11).
On top of their existing contractual obligations with their
municipalities or group of municipalities, wastewater operators will
have to establish contracts with the new organisations in charge to
implement the producer responsibility schemes for micro-pollutants
(administrative burden estimated at € 5 million/year). At the same
time, they will be funded for the additional investments required to
treat micro-pollutants (1,185 € bn in total). New efforts will be also
asked in terms of transparency but also to monitor of key
performance’s indicators (economic, social but also environmental,
energy and GHG) which in the mid-term is expected to contribute
to optimise their operations and reduce their costs.
Operators are expected also to be better involved in the permitting
process in case of industrial release in their facilities. They will also
be a key player of the future integrated management plans aiming
at reducing releases from storm water overflows and urban runoff.
Local competent
authorities
(municipalities)
The local competent authorities (mainly municipalities or group of
municipalities) will have to ensure that enough resources are given
to their wastewater operators to ensure the implementation of the
measures included in the preferred option. They will have to make
sure that national/EU budgets are reserved for their investments,
but also that water tariffs are adapted when necessary. Local
authorities will also play a key role in establishing and
implementing the integrated water management plans (see section
6.1) aiming at reducing SWO and urban runoff : their coordination
role between different services (urbanism, wastewater collection
and treatment, floods, urban greening etc) is essential to ensure the
success of such plans.
Citizens Citizens are affected in that they pay water tariffs and taxes to
support the wastewater treatment sector. Citizen on the other side
benefit from clean drinking and bathing water, improved
environmental and ecological status of the waters, preserved
biodiversity and improvement to the public health reactiveness to
possible outbreaks.
Environmental protection, clean and safe bathing waters and access
to sanitation are essential aspects of human health and wellbeing
and contribute both socially and economically to EU citizens.
The implementation of the preferred option will contribute to
103
improve the aquatic environment while reducing the risks
associated with new emerging pollutants. Citizen will also directly
benefit from health-related measures notably the surveillance of
COVID-19 and its variants in wastewaters but also the better
control of AMR.
Citizen will also benefit from a better access to sanitation but also
to key information on their operators’ performances – which is
important as they can’t choose their operators. Depending on the
financing strategies of their local and national authorities, increases
in water tariffs can be expected (estimated on average at 2,3% - see
section 7.1). In case the whole additional cost linked to the
implementation of the new producer responsibility schemes is
included in the product prices, PCPs and pharmaceutical prices
would slightly increase (0.6% on average see section 6.5).
Water Industry
sector
The water and treatment technology industry will directly benefit
from a reinforcement of the standards, but also from measures
aiming at expanding the scope of the Directive to smaller
agglomerations and optimising the operations and reducing energy
use and GHG emissions. New business opportunities to develop
new treatment techniques while reducing GHG emissions will
emerge from the preferred option. Innovation will be boosted
maintaining a comparative advantage for EU water industry. At the
time of the Evaluation, eight out of the top 15 worldwide water
businesses were based in the EU, showing clearly the global
business leadership of this sector. The total gross value added
(GVA) of the water industry (collection, treatment, supply and
sewerage) reached € 43.84 billion, or 0,35% of the total EU28
value added in 2010 (Eurostat, 2013). In the context of changes to
the UWWTD, additional jobs could be created as well as new skills
(digitalisation, advanced treatment).
Pharmaceutical
and PCP’s
industries
PCPs and the Pharmaceutical industry will have to set up new
‘Producer responsibility’ organisations and finance their
operations. As explained in section 6.5 and further detailed in
Annex 9, these industries will have the choice to either pass these
new costs in the price of their products (max increase of 0.59%) or
reduce their profit margins on these products (average maximum
impact of 0.7).
Other industrial
sectors
Inefficiencies in wastewater treatment and subsequent pollution
have direct negative impact on the EU economy and industry.
Multiple industry sectors are highly dependent on sufficient
treatment of wastewater, and clean water quality. For example,
water for the food industry or for irrigation in agriculture, provision
of drinking water, tourism and recreational industry. Improved
water quality as a result of the application of the preferred option
will positively affect these sectors.
Since micro-pollutants are not entirely biodegradable, they can
pose a risk to drinking water resources and aquatic ecosystems. The
application of the preferred option will avoid putting additional
104
burdens on drinking water providers who must rely on sufficient
clean water resources (surface and groundwater) so that they can
fulfil their task to ensure healthy and safe drinking water.
Water quality and security affects agriculture as well, which can
use up to 80% of water in Southern regions (EIB, 201648
). Given
that the dominant use of water is for agricultural irrigation (global
average is 70%49
), the economic consequences of poor water
quality and water scarcity are most pronounced in agriculture-
dependent economies.
Environment Protection of aquatic ecosystems and water resources is a key
ambition of the UWWTD and in coherence with the WFD, targets
treating water for pollution to enable favourable conditions for
aquatic life. With the preferred option, the expected reduction of
organic matter and other pollution in treated wastewater will
improve water quality throughout the European Union. Water
quality improvements lead to an increased provision of ecosystem
services such as recreational benefits of improved bathing waters
and tourism. The impacts include direct and indirect impacts on
fisheries, recreation (including human health), biodiversity and the
production of drinking water.50
According to a report published by the EEA, the effectiveness of
national water policies and many years of investment in better
wastewater treatment and sewerage systems has led to Europe’s
bathing water being much cleaner today than it was decades ago.
As shown in the Evaluation of the UWWTD, the implementation of
the Directive has almost doubled the river length with at least good
quality, from 43.5% in the pre-Directive scenario to 82,9% under
full compliance. The implementation of the UWWTD is estimated
to have increased the length of coastlines with at least good quality
from 73,5% in the pre-Directive scenario to 95,2% under full
compliance which would be a direct benefit for citizens using these
waters. These percentages are expected to further increase with the
implementation of the preferred option (% to be added).
Differences in the implementation and interpretation of the
UWWTD principles and procedures across Member States can
limit the protection of the environment, creating transboundary
issues and directly affecting the functioning and effectiveness of
the Directive in reducing pollution with subsequent impacts on EU
society. Approximately 60% of the EU's rivers run across borders
of Member States (and non-Member States). If waters are of poor
quality in an upstream Member State, this may have impacts on any
downstream Member State. Action taken by all Member States is
therefore required so that cross border environmental problems can
48
European Investment Bank, (2016), Restoring European Competitiveness, Luxemburg
49
OECD, (2020), Financing Water Supply, Sanitation and Flood Protection: Challenges in EU
Member States and Policy Options
50
Milieu and COWI, (2016), Study to assess the benefits delivered through the enforcement of
EU environmental legislation
105
be mitigated and water quality improved.
6. SUMMARY OF COSTS AND BENEFITS
The annual overall costs and benefits of the preferred option by 2040 are presented below.
I. Overview of Benefits (total for all provisions) – Preferred Option - A breakdown per MS is provided in Annex 7,
Table A7.6 (total costs and benefits).
Description Amount Comments
Direct benefits
Improvement of water
quality
€ 6.156.474.955 /year Monetised benefits due to reduced
emissions of Nitrogen, Phosphorus and
BOD in the environment and willingness to
pay for SWOs/urban run off
Reduction of the toxic load
in receiving waters
44% reduction of the toxic load rejected to
receiving waters of which 64% happening in
areas at risk (with low dilution rates)
Benefits mainly for the environment and
public health (notably bathing and drinking
water), for biodiversity (protection of
fauna)
Reduction of GHG
emissions and energy
neutrality
€ 486.370.454 /year (GHG reduction)
€ 0 (2 bn /year savings due to energy
neutrality compensated by the costs to reach
energy neutrality - see section 6.7)
Monetised benefit due to GHG emission
reduction from improved process (N2O
emissions) and energy neutrality
Direct savings due to energy neutrality
Indirect benefits
Improved bathing water
quality
Significant reduction of E. coli emissions (key
parameter for bathing water quality), impacts on
tourism, well-being in the cities
Improved raw water for
drinking water
Improved protection of the raw water used for
drinking water, reduced health risks, reduced
treatment costs for water operators
Biodiversity Cleaner water is essential to preserve
biodiversity on the rivers, lakes and coastal
areas. Actions on SWO and urban runoff will
incentivize actions to ‘green’ the cities
Public Health Monitoring COVID-19 and its variants as well
as Anti-Microbial resistance is providing
precious information for public health
EU water industry New business opportunities. Push for
innovation, modernisation and transition towards
climate neutral industry. Maintain/amplify of the
worldwide leadership of the EU water industry
Innovation Energy and Climate neutrality as well as micro-
pollutant treatment are new and will drive
innovation. Same for improved N and P
efficiency
Administrative cost savings related to the ‘one in, one out’ approach
National digitalised
database for reporting
Potential savings for operators compensated by
additional costs due to reporting more
parameters
Better coherence reporting Modest savings
106
with E-PRTR
II. Overview of costs – Preferred option - A breakdown per MS is provided in Annex 7, Table A7.6 (total costs and
benefits) and in Table A7.5 (detailed costs per MS). Costs are annual costs by 2040 including capex and opex.
Citizens/Consumers Wastewater operators/
municipalities
National/regional
administrations
One-off Recurrent
€/year in
2040
One-off Recurrent
€/year in 2040
One-off Recurrent
€/year in
2040
SWO and
urban run
-off
Direct adjustment
costs
6.446.657.281 372.472.648
Administrative
costs
57.600.000
Small
scale
agglomer
ations
Direct
adjustment costs
1.141.228.243 140.406.278
Administrative
costs
472.000
Nutrients
removal
Direct
adjustment costs 12.129.508.400
2.008.825.659
Administrative
costs
0
Micro-
pollutant
s
removal
Direct
adjustment costs 8.891.344.396
1.213.112.586
Administrative
costs
27.600.000
GHG
and
energy
neutralit
y
Direct
adjustment costs
0
(1.560.000
€/year
compensated
by direct
savings – see
section 6.7)
Administrative
costs
Audits –
(6.000.000
and
monitoring -
107
98.700.000
compensated
by direct
savings – see
section 6.7)
Other
actions
Direct
adjustment costs
Average
increase of
water tariffs
of 2,26% -
or €
1.806.000
/year
Average
increase in
public
budget of
774 million
Administrative
costs
No changes 55.700.000
million AMR
+ COVID-19
+ non
domestic
waters
Neutral
Costs related to the ‘one in, one out’ approach (PCP’s and pharmaceutical industry) 51
Total
Direct adjustment
costs
8.891.344.396 €
for PROs to cover
investments for
micro-pollutants
advanced
treatment
between entry in
force and 2040
Indirect
adjustment costs
Administrative
costs (for
offsetting)
16,2 million
€/year to be
shared between
PRO (11,2
million) and
industry (5
million)
51
As explained in section 6.11 the private and mixed private/public companies will face additional
administrative costs (€ 39,29 million per year). These additional costs will nevertheless be passed on the
competent public authorities having contracts with these operators and/or compensated by the expected
gains due to the application of the energy neutrality target.
108
109
7. RELEVANT SUSTAINABLE DEVELOPMENT GOALS
Relevant SDG Expected progress towards the Goal Comments
SDG no. 6 – ‘Ensure
availability and
sustainable management
of water and sanitation
for all’
Targets 6.2, 6.3, 6a and
6b.
Increased population connected to
sanitation systems by actions to improve
access to sanitation but also extending the
scope to smaller facilities.
The Directive directly contributes to
the implementation of the
requirements of SDG 6. The level of
treatment as well as the collection rate
of the EU is one of the most advanced
worldwide. With the revision of the
Directive, this will be intensified
(reinforcement of the standards, new
parameters to be treated, more
agglomerations covered by the
Directive). The scope of the Directive
could also be expanded to ensure
access to sanitation.
SDG no 3 – ‘Ensure
healthy lives and
promote well-being for
all at all ages’
Targets 3.3: By 2030,
end the epidemics of
AIDS, tuberculosis,
malaria and neglected
tropical diseases and
combat hepatitis, water-
borne diseases and other
communicable diseases.
and 3.9 By 2030,
substantially reduce the
number of deaths and
illnesses from hazardous
chemicals and air, water
and soil pollution and
contamination
Monitoring of health relevant parameters
in wastewater will contribute to improved
public health (Covid 19, AMR others).
Increased removal of pollutants in
wastewater released to water bodies will
contribute to reduce hazards due to water
pollution (bathing-g waters, drinking
water).
The Directive directly contributes to
the implementation of specific parts of
the targets of SDG 3, in particular
targets 3.3 and 3.9.
SDG no 14 – ‘Conserve
and sustainably use the
oceans, seas and marine
resources for sustainable
development’
Target 14.1 “By 2025,
prevent and
significantly reduce
marine pollution of all
kinds, in particular from
land-based activities,
including marine debris
and nutrient pollution”
Increased removal of pollutants including
contaminants, plastics, nutrients in
wastewater will reduce pollution going to
seas.
The Directive directly contributes to
the implementation of specific parts of
target 14.1 of SDG 14
110
ANNEX 4: ANALYTICAL METHODS
In line with previous assessments in the context of the Evaluation of the Directive52
, the
JRC has developed ad-hoc model calculations tailored for the policy questions of this
impact assessment.
1. Quantification of emissions reduction and costs for current and scenario
conditions
Addressing the questions required mainly the quantification of costs of action and
changes in water pollutant and greenhouse gas (GHG) emissions following from the
implementation of a set of measures at selected wastewater treatment plants. Pollutants
addressed include organic matter (as biochemical oxygen demand, BOD), nutrients (as
total N and total P), faecal coliforms, and micro-pollutants. GHG emissions are
represented as carbon dioxide equivalent (CO2e) emissions.
All calculations ground on the database of wastewater treatment plants (WWTPs) from
the 10th
UWWTD Implementation report. For each WWTP, we assume an emission
factor expressed as:
- mass of BOD, N or P per population equivalent (pe) per day;
- coliforms colony-forming units (CFU) per p.e. per day;
- normalized toxic units (TU) of micro-pollutants per p.e. per day;
- GHG emissions as kg CO2e per p.e. per day.
The emission factors are attributed on the basis of the level of treatment and the treated
population equivalents of the plant.
For each policy scenario, we modify one or more of the emission factors (depending on
the measures foreseen in the policy) for those WWTPs to which the policy applies. The
product of an emission factor by the treated population equivalents of the plant yields the
emissions from the plant. The sum of emissions from plants within one Member State
(MS) or the total for the EU indicate the aggregated effect of a policy scenario on
emissions. In a similar way, for each plant we calculate the cost of implementing a
measure based on appropriate assumptions, and consequently the MS and EU total costs.
Therefore, the quantification of present conditions and scenarios in this impact
assessment is based on simple Excel calculations that are all similar in structure, but
differ for the issue addressed each time in terms of emission factors and costs.
The emission factors for coliforms, BOD, N and P, based on Pistocchi et al., 201913
but
slightly adapted for N and P, are summarized in Table A4. 1.
52
https://publications.jrc.ec.europa.eu/repository/handle/JRC115607
111
Substance Emission factor
(g/p.e./day)
Removal
efficiency
of
primary
treatment
Removal
efficiency of
secondary
treatment
Removal
efficiency of
tertiary
treatment
BOD 60 50% 94% 96%
N Varies slightly by
country, average 11.18
25% 50% 75%
P Varies slightly by
country, average 1.34
(excreta) and 0.34
(detergents)
30% 55% 85%
Faecal coliforms 1.23 x 1010 (*)
40% 90% 99% (**)
Table A4. 1– Emission factors for N, P, BOD and coliforms. After treatment, the emission
factor is multiplied by (100 – removal efficiency)/100. (*) for coliforms, units of the emission
factor are CFU/PE/day ; (**) for N removal : if only P removal, efficiency is 90%.
The emission factors for micro-pollutants are estimated as the sum of concentrations of a
list of several representative micro-pollutants, each divided by an appropriate threshold
indicative of toxic risks. For the modelling of micro-pollutant removal in wastewater
treatment plants we use the SimpleTreat model53
, used for risk assessment within the
European Union System for the Evaluation of Substances (EUSES)54
. For advanced
treatment, we refer to measured removal efficiency in ozonation and adsorption on
activated carbon for a set of representative substances.
All details of the analysis, including an in-depth discussion of assumptions and
limitations, are presented in Pistocchi et al., 2022a55
containing also all the data on
micro-pollutant properties used for the estimation. Table A4. 2 summarizes the emission
factors adopted in the impact assessment. This representation of emission factors is
equivalent to assigning “weights” to the discharges of wastewater subject to different
treatments, so that the results appear as “untreated wastewater equivalent discharges”.
Level of treatment Emission factor (normalized TU)
Untreated wastewater 1.0000
Primary treatment effluents 0.6595
Secondary treatment effluents 0.3148
Tertiary treatment effluents 0.2955
53
https://www.rivm.nl/en/soil-and-water/simpletreat
54
https://echa.europa.eu/support/dossier-submission-tools/euses
55
Supporting Report 13 in Annex 10
112
Advanced treatment effluents 0.0783
Table A4. 2– Emission factors for micro-pollutants, expressed as dimension less toxic units and
normalized by assigning a unit value for untreated wastewater.
A specific model of GHG emissions has been developed for this impact assessment
(Parravicini et al., 202256
) drawing on the 2019 refinement of the IPCC Guidelines for
national GHG inventories. The emissions of a WWTP depend on various design and
operational parameters that are not known for the plants included in the database used for
the assessment. Therefore an emission factor was estimated for a set of typologies of
plant configurations. For each plant, we considered the average of emissions from the
typologies compatible with the plant’s size and level of treatment. Figure A4. 1 plots the
emission factors for the typologies considered in Parravicini et al., 202217
.
56
Supporting report 9 in Annex 10
113
Figure A4. 1– Emission factors for the typologies of plant configurations considered in the IA.
For the Evaluation of costs of conventional wastewater treatment we used the OECD-
endorsed FEASIBLE model57
to quantify the costs of upgrading a WWTP from
secondary to tertiary treatment. In particular, we refer to the expenditure functions
described in Appendix 3 of the model documentation58
, as updated more recently in a
study on the costs of compliance with the UWWTD59
.
57
https://www.oecd.org/env/outreach/methodologyandfeasiblecomputermodel.htm
58
https://www.oecd.org/env/outreach/36227787.pdf
59
https://ec.europa.eu/environment/water/water-urbanwaste/info/pdf/Cost%20of%20UWWTD-
Final%20report_2010.pdf
114
For the costs of advanced treatment for the removal of micro-pollutants, we used the
simple expenditure function proposed and discussed in Pistocchi, 2022b60
. For the costs
of treatment of small agglomerations, we used a combination of costs from the
FEASIBLE expenditure functions and the expenditure functions proposed in a study on
the Danube region (Pistocchi et al., 2020)61
.
All details on the calculation of costs of upgrade for nutrient removal, as well as micro-
pollutant removal, are presented in Pistocchi et al., 2022b62
, and in Pistocchi et al.,
2022c63
. Details on the costs of extending the scope of the UWWTD to smaller
agglomerations are provided in Pistocchi et al., 2022d64
. For the quantification of the
benefits, we have assumed a shadow price of avoided BOD emissions of 50 €/t, and a
shadow price of 1 kg of avoided N or P equal to 20 and 30 €, respectively24
. For GHG
emissions, we assume a shadow price of 100 Euro/t CO2e.
For coliforms, micro-pollutants and micro-plastics, it was not possible to identify a valid
shadow price. The benefits of removing these pollutants are therefore not quantified.
2. Modelling impacts of policy scenarios at the level of the whole stream network
While most of the policy options are evaluated on the basis of the above calculations, for
nutrients and micro-pollutants we quantified the change in the conditions of the receiving
water bodies through appropriate indicators. For nutrients, we used the GREEN model
(Grizzetti et al., 202165
) to compute the discharges of N and P to the EU regional seas
taking into account also other sources of nutrients (agriculture, atmospheric deposition
etc.). For micro-pollutants, we computed the distribution of toxicity, both at the discharge
point for individual WWTPs, and for the whole stream network taking into account the
accumulation of contaminants from upstream to downstream. These calculations are
further discussed in detail in Pistocchi et al., 2022a16
and Pistocchi et al., 2022c24
.
3. Modelling costs and impacts of policy scenarios on storm water overflows (SWO)
SWO are a potentially significant source of pollution in Europe. However, we lack data
and knowledge about their current occurrence and existing management practices. In
order to support the analysis of policy options, we have developed a dedicated
hydrological model (Quaranta et al., 2022a66
) that was reality-checked with satisfactory
results (ibid.). The model was then used to appraise the impacts and costs of various
action strategies, representative of policy scenarios. The results are discussed in detail in
Quaranta et al., 2022b67
.
4. Model uncertainties
The main uncertainties linked with the use of the models are concisely recalled here for
each area of model application. When feasible and relevant, a sensitivity analysis was
performed to better understand the limits of the model. In general terms, it should be
stressed that:
60
See Annex 10, report 14
61
https://publications.jrc.ec.europa.eu/repository/handle/JRC115606
62
Supporting report 15 in Annex 10
63
Supporting report 14 in Annex 10
64
Supporting report 10 in Annex 10
65
https://www.sciencedirect.com/science/article/pii/S0959378021000601
66
Supporting report 17 in Annex 10
67
Supporting report 18 in Annex 10
115
 Cost estimates are uncertain at least within a factor 2 in absolute terms. Costs of
all policy measures depend on local conditions warranting for a high variability
and specificity of costs.
 The quantification of impacts varies with the emission factors in a linear way, so
the uncertainties on emission factors reflect directly in uncertainties on impacts.
 The uncertainties on individual emission factors are high and (in some cases)
difficult to even quantify. However, for the impact assessment the relative change
in emission factors among scenarios is most important, and is expected to be
much less uncertain.
 In order to make sure that uncertain emission factors do not yield misleading
conclusions for policy, we have complemented the more “technical” sensitivity
analysis and discussion of uncertainty with a qualitative assessment of the
“safety” of assumptions, where we show that even stretching the assumptions to
the limits of plausibility would not significantly affect the conclusions of the
impact assessment. Further details are provided in the following sections.
5. Detailed analytical methods – micro-pollutants
Quantification of policy impacts68
The impact of implementing of advanced treated is evaluated by analysing how two
indicators of water pollution change under different policy scenarios.
The first one (L) is an indicator of aggregated toxic loads with reference to a set of m
WWTPs and l agglomerations in the EU:
𝐿 = 𝑤0 ∑ 𝑃𝑘
𝑙
𝑘=1
𝛿0,𝑘 + 𝑤𝐼 ∑ 𝑃𝑘
𝑙
𝑘=1
𝛿𝐼,𝑘 + 𝑤𝐼 ∑ 𝑃𝑗
𝑚
𝑗=1
𝛿𝐼,𝑗 + 𝑤𝐼𝐼 ∑ 𝑃𝑗
𝑚
𝑗=1
𝛿𝐼𝐼,𝑗
+ 𝑤𝐼𝐼𝐼 ∑ 𝑃𝑗
𝑚
𝑗=1
𝛿𝐼𝐼𝐼,𝑗 + 𝑤𝐼𝑉 ∑ 𝑃𝑗
𝑚
𝑗=1
𝛿𝐼𝑉,𝑗
(Eq 1)
Where:
- 𝑤0, 𝑤𝐼, 𝑤𝐼𝐼, 𝑤𝐼𝐼𝐼, 𝑤𝐼𝑉 are the emission factors (normalized toxic units) for
untreated wastewater and wastewater treated at primary, secondary, tertiary or
advanced level (),
- Pk is the wastewater load, expressed in population equivalent (pe), in the k-th
agglomeration,
- Pj the wastewater load treated by the j-th WWTP in pe,
- 𝛿0,k and 𝛿I,kthe fractions of Pk that are untreated or treated mechanically,
- 𝛿𝐼,𝑗, 𝛿𝐼𝐼,𝑗, 𝛿𝐼𝐼𝐼,𝑗 and 𝛿𝐼𝑉,𝑗 are Boolean variables equal to 1 if the j-the WWTP
provides mechanical, biological carbon removal or denitrification or advanced
treatment, respectively, and 0 otherwise.
The data on agglomerations and wastewater treatment plants are drawn from the 10th
UWWTD implementation report database. Indicator L is expressed in units of population
equivalents (p.e.).
68
All details of the modelling summarized here are presented and discussed in Pistocchi, 2022a55
116
The “population equivalents” of an emission represent the discharge of pollutants
expressed in terms of the number of persons that would generate the same discharge
(before any treatment). So for instance a WWTP treating 100 thousand p.e. with a
removal efficiency of BOD of 95% corresponds to a discharge of 100 x (1-0.95)= 5
thousand p.e. for BOD. The same plant would correspond e.g. to 20 thousand p.e. for
total N if its N removal efficiency were 80%. p.e. of discharges must be always
interpreted with reference to a specific contaminant, as highlighted by the above example
with BOD and N. Referring to p.e. instead of more physical units (e.g. tonnes per year)
enables presenting results on the same scale for all pollutants of concern (BOD, N, P,
coliforms, micro-pollutants).
Converting p.e. to tonnes/year is always possible, provided that we know the emission
per capita. This is the case for BOD (60 g/PE/day), N (roughly 11-12 g/PE/day) and P
(roughly 1.5 g/PE/day). In certain cases (e.g. micro-pollutants), we do not know the
emission per capita. In these cases, we can still compute p.e. if we know the removal
efficiency of different types of treatment. These are the reasons why the results are
presented in terms of p.e. A practical advantage is also that p.e. are relatively easy to
visualize: for instance, if we say that EU CSO convey 9 million p.e. of pollution, we can
imagine them as the total load (before any treatment) of the population of Austria.
The second one (CT) takes the form of a map accounting for the accumulation of all
toxic loads from their point of release along the stream network. At a point (x,y) in the
stream network the map is computed as:
𝐶𝑇(𝑥, 𝑦) = 𝑤0
∫ 𝑃0(𝜉,𝜁)𝑑𝜉𝑑𝜂
𝐴(𝑥,𝑦)
𝑄(𝑥,𝑦)
+𝑤𝐼
∫ 𝑃𝐼(𝜉,𝜁)𝑑𝜉𝑑𝜂
𝐴(𝑥,𝑦)
𝑄(𝑥,𝑦)
+𝑤𝐼𝐼
∫ 𝑃𝐼𝐼(𝜉,𝜁)𝑑𝜉𝑑𝜂
𝐴(𝑥,𝑦)
𝑄(𝑥,𝑦)
+𝑤𝐼𝐼𝐼
∫ 𝑃𝐼𝐼𝐼(𝜉,𝜁)𝑑𝜉𝑑𝜂
𝐴(𝑥,𝑦)
𝑄(𝑥,𝑦)
+ 𝑤𝐼𝑉
∫ 𝑃𝐼𝑉(𝜉,𝜁)𝑑𝜉𝑑𝜂
𝐴(𝑥,𝑦)
𝑄(𝑥,𝑦)
(Eq 2)
Where:
- 𝑃0(𝑥,𝑦), 𝑃𝐼(𝑥,𝑦), 𝑃𝐼𝐼(𝑥,𝑦), 𝑃𝐼𝐼𝐼(𝑥,𝑦), 𝑃𝐼𝑉(𝑥,𝑦) are the wastewater discharges at location
(x,y) (expressed in PE) subject to no treatment, mechanical, biological treatment
for carbon removal, for nitrogen removal and advanced treatment, respectively,
- 𝑄(𝑥,𝑦) is the diluting discharge at (x,y), A(x,y) is the drainage area at point (x,y).
Wastewater discharges accounted for include not only WWTPs and releases from IAS
and untreated wastewater in agglomerations, but also discharges from other European
countries not reported under the UWWTD, as well as smaller agglomerations outside the
scope of the UWWTD. The map CT(x,y) is computed at the cells (x,y) of a regular grid
of 5 km resolution over Europe in a GIS using standard map-algebraic operations with
flow accumulation operators as described in detail in Pistocchi, 201469
.
Indicator CT is expressed in the rather abstract units of p.e. m-3
s, but can be interpreted
in a more informative way if we assume a certain emission rate per p.e. For the sake of
illustration, we refer to the example of diclofenac, a drug commonly considered of
69
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117
concern for which we can assume an environmental quality standard (EQS) of 100 ng/L
(Ort et al., 2009; EC, 2012). If we assume that a p.e. corresponds to an emission of 240
ug/day of diclofenac to wastewater (ibid.), then 1,000, 10,000 and 50,000 p.e. m-3 s
correspond to a concentration of about 3 ng/L, 30 ng/L and 150 ng/L, respectively. These
concentrations are estimated assuming an annual average discharge, and may be higher
during low flow, or lower during high flow conditions.
Therefore our thresholds may be regarded as discriminating situations where
concentrations are low (<1,000 p.e. m-3
s), medium-low (1,000-10,000 p.e. m-3
s),
medium-high (usually below EQS but at risk of exceedance in case of low flows: 10,000-
50,000 p.e. m-3
s) and high (usually above EQS: > 50,000 p.e. m-3
s). This categorization
is based on diclofenac, and would be valid for any other micro-pollutant having a similar
ratio between emission rate (ER) and EQS. For micro-pollutants with higher ER/EQS, a
lower amount of p.e. could be conveyed per m3 s-1 of streamflow before exceeding the
EQS, and the other way around for micro-pollutants with lower ER/EQS.
The calculation of indicator L is performed in MS Excel, while CT is computed using
ArcGIS 10.7 (Spatial Analyst extension).
The analytical structure is simple and transparent, and calculations can be followed in
details (e.g. by inspecting Excel formulas and ArcGIS command scripts).
The indicators are used as proxy of the toxic pollution associated with wastewater under
the following key assumptions, limitations and simplifications:
1. The chemical mixture composition of wastewater is constant across the EU and in
time.
2. The assumed concentrations of individual micro-pollutants, on the basis of
available measurements, are representative.
3. Advanced treatment is assumed to consist of ozonation, activated carbon or a
combination of the two in different process configurations. The latter are assumed
to be largely equivalent to each other in terms of aggregated toxicity reduction.
4. The removal of micro-pollutants in conventional wastewater treatment is
represented by the SimpleTreat model using the partitioning and degradation
properties of the substances that can be inferred from the available data.
5. For advanced treatment, the removal efficiency is represented by measured
removal efficiencies of the known chemicals. In the case advanced treatment
removal efficiency for a substance is not known, we assume the substance is
removed as the average of the known substances. This assumption is particularly
critical as the available data on removal are limited, and in practice the majority
of chemicals is removed as the average.
6. Additionally, for indicator CT we consider only toxicity caused by wastewater
(neglecting e.g. urban runoff, agricultural pesticides, industrial chemicals and
other emissions potentially overriding the effect of wastewater. Moreover, we
consider the micro-pollutants as conservative in the stream network after
discharge.
118
The above assumptions are apparently crude approximations laden with limitations (see
Pistocchi et al., 2022a, for more details). However, their introduction leads to the
estimation of the toxicity emission factors shown in Table A4. 2, which is reasonably in
line with the expectations: the toxicity of untreated wastewater is reduced by a factor > 3
with conventional treatment, which may allow meeting environmental quality standards
in many cases, but advanced treatment is needed to reduce toxicity by one order of
magnitude or more. Measurements suggest that advanced treatment may reduce toxicity
even more, but this would only strengthen the recommendations deriving from this
modelling exercise. Therefore, it can be concluded that the representation is acceptable
insofar as not misleading. For indicator CT, neglecting other sources of contamination
may be appropriate for those chemicals (such as pharmaceuticals) for which urban
wastewater is expected to be a key driver. For other classes of pollutants, wastewater
may be a minor, or anyway a secondary source.
In addition to the impacts in terms of toxicity indicators, we have quantified the
greenhouse gas (GHG) emissions of advanced treatment, assuming an average emission
factor of 0.225 kg CO2e/m3 of wastewater treated, and a wastewater volume to treat of
200 L/PE/day21
.
The approach has been developed in collaboration with a network of leading experts in
Europe, presented at specific workshops and meetings with stakeholders and subject to
scientific peer-review in fully open access form (including supporting material with all
the data used in the calculation)16
.
Quantification of policy costs70
The cost of advanced treatment (€/PE/year including investments and operation) is
described by the following simple expenditure function:
Cadv=1000 PE-0.45
(Eq 3)
This function corresponds to the available evidence and is accurate within a factor 2
(Pistocchi et al., 2022b21
). In addition to the costs of advanced treatment, in some
scenarios certain WWTPs might be required to implement advanced treatment even if not
currently required to perform nitrogen removal (tertiary treatment). In this case, we
calculate also a cost of upgrading the plant from secondary to tertiary treatment. To this
end, we assume the costs of upgrade to correspond to the difference between costs of
new tertiary and secondary plants, plus 50% of the costs of a new secondary plant to
account for the potentially significant infrastructural overhaul. The costs of upgrade are
described with the FEASIBLE expenditure functions19, 20
. This cost is likely
overestimated and provides a “worst case” bound to the overall costs. In the calculation,
we assume a lifetime of the investment of 30 years, and a discount rate of 2.5%.
The method has been designed in order to explore the trade-offs between costs and
effectiveness of advanced wastewater treatment for micro-pollutant removal. The
calculation is quick and transparent and enables comparing several scenarios in order to
define precisely the Pareto front of trade-offs.
70
Supporting report 15 in Annex 10
119
As a starting point, we compute the indicators L and CT for the present conditions
(“baseline”) and the conditions of full compliance with the current directive, not yet
achieved although quite close in reach.
We also assume that, in the absence of a specific provision, advanced treatment will
not be implemented. This is a “pessimistic” assumption, because some initiatives are
already being undertaken notably in Germany, Sweden, Denmark and the Netherlands.
However, stakeholder consultations and Member State surveys (see Annex 5) have
highlighted how in most of the EU there is no appetite for advanced treatment, and even
within the above mentioned countries the subscription to advanced treatment is not
always enthusiastic due to the relatively high costs entailed.
We then compare the baseline and full compliance scenarios with scenarios of advanced
treatment implemented at all plants above a certain treatment capacity (expressed as PE),
and when the dilution ratio (annual average flow of the receiving water body divided by
the effluent discharge) is less than a minimum value. Pistocchi et al., 2022a16
and
Pistocchi et al., 2022b21
present a systematic exploration of all combinations of capacity
thresholds between 0 and 1 million PE, and dilution thresholds between 2 and infinity.
For each scenario, the calculated indicator L is compared with those under baseline and
full compliance scenarios. Moreover, for each scenario we can compute the costs of
advanced treatment (and the additional costs of upgrading conventional treatment from
secondary to tertiary), and the value of L plotted as a function of the corresponding costs
indicates the cost-effectiveness of the scenario. While L is a scalar number, indicator CT
is a map. In order to compare CT maps for the baseline/full compliance and the various
scenarios, we refer to the percentage of the stream network (on which CT is computed)
under conditions of “high”, “medium”, and “low” toxicity as discussed above. While the
reader is referred to the supporting reports16, 21
for the full exploration of scenarios, here
we focus on representative scenarios:
- “low ambition”: all plants with a treatment capacity of 100,000 p.e. or more,
discharging in water bodies with any dilution are required to implement advanced
treatment;
- “high ambition”: advanced treatment at all plants above 10,000 p.e. and with dilution
of 100 or less;
- ”medium option”: advanced treatment at all plants above 100,000 p.e. irrespective of
dilution, and between 10,000 and 100,000 p.e. only when justified by the
environmental risks caused by the toxicity of the effluents, which we expect to be the
case when the dilution is 10 or less. For scenario modelling purposes, we assume that
risks occur in 70% of the cases when effluents are discharged with a dilution of 10 or
less, excluding discharges to seawater.
Table A4. 3 shows a comparison of indicator L among the 4 scenarios, as well as the
current and baseline scenarios, for all Member States and the EU. Table A4.4 shows the
corresponding costs of advanced treatment.
The results of this scenario analysis suffer from the uncertainty in the calculation of the
toxicity emission factors discussed above, while costs can be considered uncertain within
a factor of 2. On the other hand, the uncertainty in the difference among scenarios is
arguably much smaller, although it is not possible to quantify it.
120
As all the WWTPs in Europe under a full compliance scenario have a biological
(secondary or tertiary) treatment process, obviously the value of indicator L normalized
by the value under full compliance is approximately proportional to the following
quantity:
L~ 1 - (1 -a)b
where a is the ratio between the emission factors of advanced treatment and of biological
(secondary or tertiary) treatment, and b the fraction of the treated load undergoing
advanced treatment.
Parameter a is assumed to be about 0.3 (see Table A4. 4) in our assessment, but could be
in principle any value between 0, meaning that advanced treatment removes toxic
emissions completely, and 1, meaning advanced treatment is not effective at all.
Measurements at European WWTPs suggest, however, that an advanced treatment may
reduce toxicity more than we assume in this analysis, meaning the ratio could be lower
than the assumed value of ca. 0.3 (see Pistocchi et al., 2022a16
, for a more detailed
discussion).
121
Current Baseline Low ambition High ambition Preferred
Option
AT 6,119,085 6,108,046 3,546,436 4,016,808 3,438,856
BE 2,742,273 2,723,002 1,969,469 1,295,348 1,738,730
BG 2,414,676 2,120,715 1,192,954 818,890 1,097,659
CY 247,404 247,404 128,582 71,756 109,705
CZ 2,606,374 2,592,882 1,890,969 1,452,995 1,782,165
DE 32,754,448 32,722,942 21,240,721 17,977,985 19,424,388
DK 3,434,246 3,427,488 2,059,544 1,160,506 1,803,292
EE 467,417 467,092 224,967 179,905 218,287
EL 3,169,802 3,169,656 1,429,615 1,036,919 1,299,737
ES 19,548,256 18,865,567 9,962,682 7,227,673 8,784,926
FI 1,558,348 1,542,112 970,737 708,047 859,729
FR 21,239,621 21,212,684 13,736,729 12,803,272 13,025,377
HR 1,259,648 831,086 655,425 501,687 583,036
HU 3,621,328 3,507,410 2,188,519 2,074,575 1,786,917
IE 1,564,034 1,528,949 807,688 656,659 780,328
IT 23,550,204 22,136,548 14,511,265 10,524,659 12,991,187
LT 835,613 835,021 451,115 346,437 415,460
LU 189,550 187,892 146,144 85,375 118,943
LV 459,302 455,703 291,351 226,829 279,275
MT 233,874 233,874 68,377 96,973 68,377
NL 5,750,272 5,745,852 3,317,420 2,071,206 2,717,265
PL 11,492,932 11,277,713 7,154,561 5,588,834 6,231,897
PT 4,117,119 3,741,518 2,151,928 1,577,466 1,993,711
RO 4,388,110 3,758,579 2,074,170 1,624,079 1,883,691
SE 3,750,202 3,730,919 2,159,454 1,798,495 1,976,559
SI 417,493 392,153 297,248 279,597 293,388
SK 1,066,615 1,050,489 749,180 640,810 712,648
EU
total
158,998,247 154,613,295 95,377,249 76,843,786 86,415,534
Table A4. 3– indicator L under the 5 representative scenarios. Values in pe.
122
Low ambition (€) High ambition (€)
Preferred option
(€)
AT 33,210,752 46,218,522 37,634,807
BE 11,707,932 41,768,823 21,949,684
BG 10,684,777 27,658,707 14,110,021
CY 2,221,470 4,047,861 2,527,273
CZ 9,510,998 29,613,650 14,178,119
DE 163,933,461 395,431,303 238,477,441
DK 25,743,637 61,573,612 33,680,164
EE 4,145,769 6,576,343 4,926,170
EL 12,527,860 27,840,446 14,622,260
ES 117,778,928 233,330,473 162,112,160
FI 8,422,797 19,358,750 13,046,187
FR 100,866,076 205,704,604 130,822,544
HR 2,593,678 11,240,852 5,292,965
HU 17,815,481 43,511,578 33,482,887
IE 7,139,764 14,036,162 8,965,060
IT 115,125,309 284,333,910 168,242,744
LT 5,321,231 9,394,797 6,565,971
LU 805,524 2,930,275 1,683,707
LV 1,633,313 4,373,038 2,510,885
MT 2,101,382 1,477,121 2,101,382
NL 42,911,706 93,937,353 64,774,361
PL 64,718,529 148,376,715 101,748,705
PT 26,269,579 49,993,994 31,301,446
RO 24,670,642 43,627,782 32,114,988
SE 21,925,166 44,336,138 29,257,162
SI 1,697,477 2,870,358 1,697,477
SK 5,869,996 12,018,361 7,686,018
EU 841,353,236 1,865,581,530 1,185,512,586
Table A4. 4– costs of advanced treatment under the 3 representative scenarios. Values in €.
Figure A4. 1 shows that, for very different values of a, L changes much less as per the
above linear relationship with b, so a large error on a would reflect in a smaller error on
L.
123
Figure A4. 2–variation of indicator L (represented here as a percentage of the value of L under
full compliance) to the % of wastewater subject to advanced treatment (b), for values of a from
0.01 to 0.7 (a value a=0.3 (continuous black line) represents the assumption made in this
analysis).
6. Detailed analytical methods - Nutrients
General description of the methods
In order to appraise the costs and benefits of nutrient removal, we calculate the discharge
of total N and total P under the various policy scenarios, as:
𝐷𝑥 = (1 − 𝜂𝐼𝑥) ∑ 𝜀𝑥,𝑗𝑃
𝑗
𝑚
𝑗=1
𝛿𝐼,𝑗 + (1 − 𝜂𝐼𝐼𝑥) ∑ 𝜀𝑥,𝑗𝑃
𝑗
𝑚
𝑗=1
𝛿𝐼𝐼,𝑗 + (1 − 𝜂𝐼𝐼𝐼𝑥) ∑ 𝜀𝑥,𝑗𝑃
𝑗
𝑚
𝑗=1
𝛿𝐼𝐼𝐼,𝑗
Where:
- x=N, P,
- 𝜀𝑥,𝑗 is the emission factor for N or P at the jth
WWTP,
- 𝜂𝐼𝑥, 𝜂𝐼𝐼𝑥, 𝜂𝐼𝐼𝐼𝑥 are the removal efficiencies for N and P at primary, secondary or tertiary
level of treatment, respectively,
- Pj the wastewater load treated by the j-th WWTP in PE
- 𝛿𝐼,𝑗, 𝛿𝐼𝐼,𝑗, 𝛿𝐼𝐼𝐼,𝑗 are Boolean variables equal to 1 if the j-the WWTP provides primary,
secondary or tertiary treatment, respectively, and 0 otherwise.
124
The WWTPs considered in the analysis are the same described under the previous
section, and were characterized on the basis of the data from the 10th
Implementation
report of the UWWTD. The removal efficiency for N and P is given in A4.1 The
emission factors for N and P are assumed to vary by country as per Table A4. 5.
Country
N
(g/year per
capita)
P in excreta
(g/year per
capita)
P in detergents
(g/year per
capita)
Austria 4443 515 95
Belgium 4033 471 82
Bulgaria 3399 430 100
Switzerland 3923 445 11
Cyprus 3695 457 100
Czechia 3581 421 100
Germany 4235 490 100
Denmark 4653 516 100
Spain 4345 496 100
Estonia 4181 474 100
Finland 4785 541 100
France 4432 521 100
Greece 4232 510 100
Croatia 3623 431 100
Hungary 3511 420 100
Ireland 4498 530 100
Italy 4161 512 60
Lithuania 5066 590 100
Luxembourg 4514 514 95
Latvia 4177 491 100
Malta 4596 541 100
Netherlands 4383 483 82.1
Poland 4189 503 100
Portugal 4596 522 100
Romania 4370 541 100
Slovakia 2803 339 100
Slovenia 3966 481 100
Sweden 4344 484 100
Table A4. 5 – Emission factors for N and P assumed in this study.
The policy options entail the upgrading of certain plants from secondary to tertiary
treatment. We assume the corresponding costs to equal the difference between costs of
new tertiary and secondary plants, plus 50% of the costs of a new secondary plant to
account for the potentially significant infrastructural overhaul. The costs of upgrade are
described with the FEASIBLE expenditure functions19,20
. This cost is likely
overestimated and provides a “worst case” bound to the overall costs. In the calculation,
we assume a lifetime of the investment of 30 years, and a discount rate of 2.5%.
Under some policy options, the removal efficiency of N and P is increased above current
standards, from 75% to 85% for N and from 85% to 90% for P. In both cases, we assume
125
the additional costs to be 10% of the annualized cost of a tertiary treatment plant (capital
repayment, operation and management), the latter evaluated using the abovementioned
FEASIBLE model expenditure functions.
The changes in GHG emissions under the various policy options have been evaluated
using the approach discussed in a dedicated section below. All calculations are
implemented in MS Excel © as discussed in detail in Pistocchi et al., 202224
.
For the quantification of the benefits, we have assumed a shadow price of GHG
emissions of 100 €/t CO2e, and a shadow price of 1 kg of N or P removed from the
effluents equal to 20 and 30 €, respectively24
.
How the method has been applied in the impact assessment?
The approach has been broadly discussed with experts involved in the development of
supporting scientific work24
, and presented and discussed at conferences and workshops
during the preparation of this IA. The approach has been designed specifically to provide
a simple and transparent quantification of the policy options.
7. Detailed analytical methods - Stormwater overflows (SWO)
For the modelling of SWO, we developed and applied an urban-scale hydrological model
simulating combined sewer flows using an input time series of precipitation at the
resolution of 3 hours. The model is described in detail in Quaranta et al., 2022a27
, and
was developed by the JRC in the form of an Excel © workbook. The model itself is
available as supplementary electronic material with the cited paper. It was developed
with the contribution of various European experts, initially convened at a technical
workshop organized by the JRC in 2019. Some of the contributing experts were also
involved in the verification and calibration of the model as well as the analysis of
scenarios as described in details in Quaranta et al., 2022b28
.
The model is applied to describe a unit-area (1 hectare) urban hydrological response unit
(HRU) of impervious ground connected to a combined sewer receiving the wastewater
generated by a population equal to the average population density of an urban area. The
lumped, conceptual hydrological model has the analytical structure of a cascade of 3
linear reservoir models with 6 parameters reflecting the rate constant of the reservoir and
the volume filling threshold triggering an overflow (see Quaranta et al., 2022a27
, for
details).
The model has been applied to 671 HRUs each with the precipitation time series and
population density of one of the 671 functional urban areas (FUA) of Europe, as detailed
in Quaranta et al., 2022a. The parameters of the model were assigned in order to reflect a
realistic “average” condition of European combined sewer networks, and were found to
yield an acceptably realistic description of the initial situation in a specific model
verification exercise (see Quaranta et al., 2022a27
, for details).
Both SWO volume, and the volume of dry-weather wastewater flow (DWF) released
with the SWO, computed for a 1 ha urban HRU for each FUA were then multiplied by
the impervious area of the FUA and summed by EU member state. The resulting sums
were multiplied, for each country, by the % of population assumed to be serviced with
combined sewers in each country, and by a correction factor representing the ratio of the
total impervious urban area in a country, divided by the total impervious area of the
FUAs in the country (see Table A4. 7).
126
The model parameters were then changed to simulate the various measures that can be in
principle taken to reduce SWO. The scenario chosen for reference, representing a
condition where SWO is managed so that they meet the proposed standards (SWO not
discharging more than 1% of the yearly dry-weather wastewater generated in the
catchment), includes:
- greening measures in line with the Biodiversity strategy, ensuring an additional surface
storage volume of 5 mm in combined-sewer urban areas, combined with
- constructed wetlands (CW) removing 50% of the pollution of SWO before discharge.
The CW are sized in order to detain SWO for 1 day (24 hours). The volume of the
required CW is calculated as the average of the 50th
and 75th
percentiles of the
cumulative SWO over 24 hours. The total volume required for CW is shown in Table A4.
8. This is calculated on the basis of the impervious urban area in the FUA within each
country, and the percentage of this area that is served by CS. In this case, we do not
correct for the ratio of the total impervious urban area in a country, divided by the total
impervious area of the FUAs in the country. This accounts for the potential of
inexpensive solutions, particularly in less densely populated zones. Inexpensive solutions
include the buffering of overflows in marginal land, effectively avoiding most of the
discharge directly to water bodies, as well as the simple disconnection of stormwater
drainage from sewers by allowing runoff dispersion directly on land.
The cost of a CW is estimated from an investment cost of 500 Euro/m3, a discount rate
of 2.5%, a lifetime of 30 years, and an operation and maintenance cost (O&M) of 1% per
year. The costs of urban greening are not included in the assessment, as they pertain to
other specific initiatives and deliver benefits much beyond SWO control.
The various policy options considered in this assessment differ for the size threshold of
agglomerations for which SWO management is required. The cost of CW, as well as the
avoided volumes of overflow and of DWF in overflow, are computed under the
assumption that SWO management applies to all agglomerations, and then multiplied by
the population in agglomerations subject to measures as a fraction of the total population.
Information on the factors used for the calculation are provided in Table A4. 8.
Particularly, the policy options shown in Table 3 in Section 6.1 of this assessment are
evaluated considering the population in agglomerations above 100,000 PE (option 1), the
population above 100,000 PE and 30% of that between 10,000 and 100,000 PE (option
2), and the sum of population above 100,000 PE and between 10,000 and 100,000 PE
(option 3).
The impacts and benefits of the policy options considered in the IA were evaluated by
multiplying the results obtained for each EU Member State, by the percentage of the
population equivalents covered with different thresholds of agglomeration size (10 and
100 thousand PE) as for the costs. Impacts are meant here as the reduction of pollutant
loads discharged through overflows.
To this end, we convert the volumes of overflow assuming that 1 PE corresponds to 73
m3/year (200 l/day) of DWF, 60 g BOD/day, 11.18 g N/day and 1.68 g P/day. Runoff in
overflows is converted to PE assuming the concentrations shown in Table A4. 6, or
equivalently considering the volumes of overflow as volumes of sewage subject to a
treatment with a given removal efficiency, as shown in the table.
127
Pollutant Concentration
mg/L
Equivalent
removal
efficiency
BOD 7.77 97%
N 2 96%
P 0.27 97%
Toxicity(*) 0.50 50%
Table A4. 6 – assumed concentrations in runoff, and corresponding removal
efficiency that would make treated sewage equivalent to runoff. (*) Toxicity
(dimensionless) of runoff is assumed to be 50% of that of untreated sewage.
For the quantification of the benefits, we have assumed a shadow price of avoided BOD
emissions of 50 €/t, and a shadow price of 1 kg of avoided N or P equal to 20 and 30 €,
respectively24
.
Additional benefits not included in the above monetization are those from the removal of
micro-pollutants and micro-plastics, as well as those related to the reduction of fish die-
offs and impairment of the water bodies as a consequence of reduced pollution episodes.
Johnson and Geisendorf, 202271
quantify the willingness to pay (WTP) for the latter in
about 100 Euro/person/year for the case of Berlin. For a given policy option, we
extrapolate this WTP by multiplying, for each country, the total number of population
equivalents in the agglomerations of the size range affected by the policy (Table A.4.8)
by the assumed % of agglomerations implementing specific measures for SWO
reduction, and the assumed % of urban areas served by combined sewer networks (Table
A.4.7) and by the WTP of 100 Euro/PE/year. This represents a likely upper limit to the
benefits expected from SWO management. In order to avoid overestimations of the
benefits, we assume for Europe a WTP equal to 10% of the one in Berlin, on average.
71
https://www.sciencedirect.com/science/article/pii/S0301479722000810?via%3Dihub#
128
EU
Member
State
Population served
by combined sewers
Correction factor (Total to
FUA impervious area)
AT 28.0% 2.00
BE 92.3% 1.99
BG 0.0% 2.12
CY 100.0% 1.77
CZ 0.0% 1.80
DE 46.1% 1.49
DK 50.0% 1.70
EE 50.0% 2.07
EL 39.0% 2.38
ES 13.0% 2.26
FI 17.5% 2.52
FR 32.0% 1.83
HR 59.0% 2.83
HU 32.5% 2.24
IE 24.0% 2.10
IT 70.0% 2.34
LT 50.0% 2.62
LU 90.0% 1.00
LV 50.0% 3.03
MT 100.0% 1.12
NL 73.0% 1.59
PL 92.0% 2.00
PT 34.0% 2.41
RO 0.0% 3.03
SE 12.0% 2.47
SI 59.0% 3.01
SK 7.5% 3.00
Table A4. 7– EU Member State factors used for the calculation of SWO
129
Overflow
volume
Mm3/y,
current
conditions
Volume
of DWF
in
overflows
Mm3/y,
current
conditions
Reduction
of DWF
in
overflows
with
measures,
Mm3/y
Reduction
of
overflow
with
measures,
Mm3/y
Volume of
CW
required
for
overflow
treatment
(m3
)
PE in
agglo 10-
100 k PE
PE in
agglo >
100 k PE
PE in
agglomerations,
total
AT 59 2 0.48 11.57 571,255 7,417,950 11,493,783 20,670,206
BE 259 27 6.57 55.78 2,717,920 3,854,900 4,287,600 9,231,350
BG 0 0 0.00 0.00 - 2,481,677 4,043,148 7,448,278
CY 27 2 0.58 6.08 597,602 381,000 400,000 849,500
CZ 0 0 0.00 0.00 - 4,152,849 3,258,497 9,348,994
DE 773 35 7.76 133.53 6,525,214 48,938,729 53,011,623 112,009,321
DK 104 11 2.63 21.85 1,055,605 4,906,031 5,452,145 11,598,945
EE 8 1 0.24 1.80 101,507 504,117 923,961 1,589,716
EL 63 4 1.26 14.88 1,446,670 19,425,222 39,135,381 65,207,923
ES 92 8 1.88 19.84 2,056,473 2,083,050 2,386,500 5,057,300
FI 27 3 0.71 6.12 309,888 26,750,168 35,178,994 72,482,923
FR 841 68 21.61 233.24 10,797,463 2,845,037 7,270,546 11,021,837
HR 86 6 1.31 15.80 1,063,079 2,532,958 1,661,154 4,999,712
HU 42 4 1.09 9.68 785,497 4,982,145 6,833,741 13,588,976
IE 34 3 0.92 8.38 297,335 1,439,948 3,146,478 5,080,615
IT 1287 90 23.66 290.12 20,141,349 30,696,516 37,108,985 77,187,042
LT 15 2 0.49 3.77 223,036 946,880 1,796,720 2,905,700
LU 42 4 0.83 7.70 373,767 259,190 231,359 637,438
LV 6 1 0.14 1.10 99,210 706,183 673,670 1,611,113
MT 12 1 0.38 4.09 310,741 52,313 736,726 789,039
NL 135 6 2.17 35.23 2,234,155 7,349,318 11,623,761 19,444,506
PL 414 43 11.03 91.69 6,314,024 13,903,757 20,035,549 38,542,418
PT 164 11 3.07 41.28 2,334,196 3,902,270 6,959,400 12,250,540
RO 0 0 0.00 0.00 - 5,105,297 8,431,853 16,169,845
SE 22 2 0.65 5.55 272,739 4,114,260 7,148,200 12,517,265
SI 57 4 0.66 8.49 611,116 502,032 436,270 1,462,223
SK 6 1 0.11 1.05 87,887 1,904,850 1,255,500 4,088,385
Table A4. 8– factors used for the calculation of SWO. DWF = dry weather flow.
8. Detailed analytical methods - Small agglomerations
Small agglomerations are not covered by the current scope of the UWWTD, and
systematic data are not available at European scale concerning agglomerations below
2000 PE. Hence, a key issue with the assessment of policy options concerning small
agglomerations is the estimation of the number of agglomerations and cumulative
population living therein. This assessment is based on a model simulation of
agglomerations smaller than 2000 PE, as presented in Pistocchi, 202272
.
72
Supporting report 10 in Annex 10
130
The simulation is based on the spatial distribution of population available for Europe
according to the Global Human Settlements Layer (GHSL)73
, and compares favourably
with information available on small agglomerations in the different MS gathered in a
study in support to the IA74
. The simulation suffers from an overestimation of population
living in small agglomerations as discussed in Pistocchi, 2022. In order to correct this
bias, we considered the average between the simulation and a previous estimate used in
the GREEN model75
.
The latter was based on the difference between the population of each member state, and
the population corresponding to the population equivalents reported for agglomerations
above 2000 p.e. under the UWWTD, and appears to be underestimating. The two
estimates differ by a factor of about 3, and their average is still compatible the
information gathered in the different MS. The loads from small agglomerations remain
affected by a significant uncertainty, close to a factor 2, as further discussed in Pistocchi,
2022. The dataset of simulated agglomerations is publicly available as supplementary
electronic material of the cited paper.
Table A4. 9 summarizes the assumed population in the various EU MS living in
agglomerations between 50 and 2000 PE. This is assumed to undergo a given level of
treatment, based on the information gathered in each MS concerning the current
practice35
.
Based on the estimated population in small agglomerations, we compute the costs and
pollution reduction due to improving the treatment level from current conditions to
policy scenario standards. The policy options considered entail enforcement of a
secondary (biological) treatment for all agglomerations above a certain population size.
When a MS has a level of treatment already equivalent to secondary or more stringent,
the policy does not cause any change. Also, agglomerations below the size assumed for
the policy scenario do not change their assumed current level of treatment. When small
agglomerations have a level of treatment less stringent than secondary, we represent the
cost of upgrade to a secondary system as (Pistocchi, 2022):
Annualized Cost = 218.36 * P-0.37
(€/PE/year)
This cost corresponds to assuming that (1) agglomerations are initially equipped with
septic tanks, (2) a sewer network does not exist in the agglomeration; and (3) the
secondary treatment plant is a constructed wetland.
The reduction of pollution achieved by expanding the scope of the UWWTD to smaller
agglomerations is evaluated as the difference between loads emitted under baseline and
under policy scenario conditions. To this end, we assume the emission factors for
conventional pollutants as shown in Table A4. 1. For the quantification of the benefits, we
have assumed a shadow price of avoided BOD emissions of 50 €/t, and a shadow price of
1 kg of avoided N or P equal to 20 and 30 €, respectively24
.
73
https://ghsl.jrc.ec.europa.eu/
74
Annex 10, report 1
75
Vigiak, O., Grizzetti, B., Zanni, M., Dorati, C., Bouraoui, F., Aloe, A., Pistocchi A., Estimation of domestic and
industrial waste emissions to European waters in the 2010s, EUR 29451 EN, Publications Office of the European
Union, Luxembourg, 2018, ISBN 978-92-79-97297-3 , doi:10.2760/08152, JRC113729.
131
Untreated Mechanical Biological More stringent Total
AT - - 1,009,259 - 1,009,259
BE - - - 924,016 924,016
BG - 1,008,806 - - 1,008,806
CY - - 247,538 - 247,538
CZ - - 2,120,496 - 2,120,496
DE - - 6,923,236 - 6,923,236
DK - - - 489,605 489,605
EE - - 99,698 - 99,698
EL - - 1,341,030 - 1,341,030
ES - 2,256,118 - - 2,256,118
FI - - - 722,561 722,561
FR - - 9,667,829 - 9,667,829
HR - 511,990 - - 511,990
HU - - 1,042,439 - 1,042,439
IE - - 575,845 - 575,845
IT - 3,468,576 - - 3,468,576
LT - 655,136 - - 655,136
LU - - 64,439 - 64,439
LV - - 460,709 - 460,709
MT - - 2,180 - 2,180
NL - - - 572,870 572,870
PL 8,419,068 - - - 8,419,068
PT - - 959,706 - 959,706
RO - 2,799,874 - - 2,799,874
SE 702,693 - - - 702,693
SI - 626,849 - - 626,849
SK - - 1,616,210 - 1,616,210
total 9,121,761 11,327,349 26,130,613 2,709,052 49,288,776
Table A4. 9– Assumed load of wastewater (PE) from agglomerations smaller than 2000 PE, at
different levels of treatment. Estimations are based on detailed results from Annex 5
132
9. Detailed analytical methods - Greenhouse gas emissions
General description of the method
Greenhouse gas (GHG) emissions are computed for each wastewater treatment plant on
the basis of its size and level of treatment, using the emission factors described in
Parravicini et al., 202276
, based on a specific improvement of the IPCC 2019 Guidelines
to account for the state of current knowledge of GHG emissions from the wastewater
sector. The emissions of all WWTPs were summed by country and at EU scale, to yield
the total emissions from the sector. Under an energy neutrality scenario, we assume
electricity to come at zero emissions. For a climate-neutral scenario we assume the
emissions corresponding to the average of two scenarios, namely:
- A scenario with systematic implementation of simultaneous aerobic stabilization
of the sludge, yielding the lowest possible N2O emissions;
- A scenario with systematic implementation of anaerobic digestion with delivery
of bio-methane to the gas grid, thus displacing fossil methane, yielding low
emissions of CH4 and credits from the displaced fossil fuel.
The model calculations are all implemented in an Excel © workbook, provided for open
access as supplementary electronic material to Parravicini et al., 202237
. The JRC
developed the model with leading European experts after thorough consultation of
additional experts from the sector (in government, academia and industry).
Although the validation of GHG emissions from the wastewater sector is problematic for
various reasons also due to the difficulty of measurements and their generalization, the
results of the calculation were found in line with the current literature, as discussed in
Parravicini et al., 202237
.
10. Micro-plastics
Under all policy options, we quantify the change in microplastics emissions with
effluents and runoff. For runoff, we assume an amount of Tire wear particles (TWP)
generated in Europe equal to 1,327,000 t/a according to Wagner et al. (2018). Of this
amount, we assume 10% (132,700 t/a) ends up in urban runoff, uniformly distributed
across the EU. With 57.7 billion m3/a of urban runoff (Pistocchi et al., 2019), this results
in an average concentration of 2.3 mg/L TWP. Plastics in WWTP effluents are assumed
to equal 560 mg/PE/a according to Simon et al. (2018), as the result of a 95% removal in
WWTPs. This is not the average removal rate of a WWTP, but a representative value for
the plants Simon et al., (2018) refer to. Hence in untreated sewage the plastics amount to
560 / (1-0.95) = 11200 mg/PE/a. The concentration in untreated sewage, assuming 200
l/PE/day of sewage, is 11200 / (365*0.2) mg/m3 = 0.157 mg/L. when comparing the
various policy options, we consider a removal efficiency of microplastics in WWTPs
equal to 70% for primary treatment, 85% for secondary, 90% for tertiary and 99% for
advanced treatment.
Additional details can be found in Obermaier and Pistocchi, 202277
.
76
Supporting report 9 in Annex 10.
77
See Annex 10, report 15
133
11. Definition of the reference maximum technical feasibility scenario
In order to appraise the impacts of the preferred policy options, we compare them with
the scenario corresponding to the “maximum technical feasibility” option for each
specific problem. This is summarized in the following table.
Specific problem Maximum technical feasibility
scenario
Reasoning
Storm water overflows (SWO) Doubling of the removal under
the preferred option
Result of combining the most extensive
preventive measure with the treatment
of overflows as in the preferred option.
Micro-pollutants All plants above 5,000 p.e.
discharging with a dilution ratio
of 100 or less are treated
An upper limit of advanced treatment
requirements.
Nutrients All plants above 2000 p.e. are
required to remove N and P
with higher efficiency than
current
The maximum removal that can be
achieved before regulating smaller
agglomerations as well.
Small agglomerations All agglomerations above 100
p.e. are required to have at least
a secondary treatment
Assumed upper limit of regulation.
12. References of supporting reports - see Annex 10 documents 8 to 18.
134
ANNEX 5: SUMMARY OF MEMBER STATE SITUATION
On top of the core consultation activities, Member States were consulted on the basis of
pre-filled overviews. MS had the opportunity to comment, provide their feedback and
validate on these pre-filled overviews. The Member State overviews were filled in,
consolidated with the inputs from the EPR Feasibility study, reviewed by the
Commission and sent to the Member States for the opportunity to complete the
information, comment on the content and any assumptions made, notably for the
modelling.
Member States have had 4-6 weeks to verify their national information presented in the
overview and to challenge the assumptions made by the project team on likely impacts of
possible change to the legislative framework for their country.
The EC has received 25 Member State responses to the overviews.
Member State overviews cover all areas of intervention considered as part of the impact
assessment. The overviews are mostly descriptive and present the current practices in
Member States, including where practices go beyond the requirements of the UWWTD.
It also included the main assumptions used in the context of the modelling.
Section Summary
Storm water
overflows and
urban runoff
 Urban runoff management differs significantly between Member
States.
 12 of 21 reporting Member States have mainly separate sewers
with the minority combined. However, there is a wide variety of
combinations among Member States and differences between
older and newer urban areas.
 Several Member States report that new additional urban areas are
serviced by separate sewers.
 2 Member States reported a reference to treatment requirements
for ‘first rain’.
 Several Member States reported treatment of overflows and
several Member States also reported explicit dilution rates.
 5 reported the use of Integrated Management Plans.
Smaller
agglomerations
 Evidence collected from 21 Member State authorities suggests
that there may be more than 85.000 agglomerations below 2.000
p.e. across these countries.
 For 15 Member States, the majority of small agglomerations are
connected to an urban wastewater treatment plant.
 In 2 Member States, individual and appropriate systems are most
commonly used to manage urban wastewater from small
agglomerations.
Individual or
other
Appropriate
Systems
 26 Member States have national legislation on IAS in place but
there are a few that do not have specific regulatory frameworks
for IAS either for smaller agglomerations or for all
agglomerations independent of size.
 17 Member States reported that the connection to the public
135
sewer system is mandatory where available (sometimes
facilitated by financial incentives).
 The predominant types of IAS installed are cesspools and septic
tanks. At least 9 Member States do not report the use of IAS in
agglomerations < 2000 p.e. (not required by the UWWTD).
 At least 14 Member States require a permit for the use of IAS.
 At least 13 Member States do not centrally record use of IAS
through a national database.
 The inspection and monitoring schemes across the Member
States vary to a great extent.
Sensitive areas
(in combination
with nutrient
removal)
 Only 9 Member States apply stricter measures than those set in
the Directive.
 10 countries apply more stringent standards for certain pollutants
or for smaller agglomerations or include new agglomerations size
range.
 The majority of Member States have a nitrification requirement.
 The majority of the Member States have designated part of their
territories as sensitive areas; only 11 Member States go beyond
UWWTD by classifying their whole territory as Sensitive Areas.
Drivers mentioned include orthophosphate/phosphorous
compound levels, vulnerability, the status of water bodies
according to WFD, eutrophication, poor status of receiving
waters.
 A specific national definition for eutrophication often does not
exist and only 3 Member States use a methodology aligned with
the Nitrates Directive.
 13 Member States do not apply a nutrient balance calculation.
 Only 9 Member States are entirely designated as Nitrate
Vulnerable Zones (NVZ).
 5 Member States identified a link when designating NVZs with
sensitive zones under the UWWTD.
Micro-
pollutants
 Each Member State has different approaches to the monitoring
and treatment of micro-pollutants, and the predicted future uptake
of 4th
stage treatment technologies varies widely between
Member States.
Industrial
discharges
 11 Member States have mandatory pollutant-specific treatment
level for UWWTPs receiving industrial discharges (from either
IED installations or SMEs).
 9 Member States have specific provisions in their legislation
regarding the specification for pre-treatment of wastewater from
industrial sites as mandatory.
 The setting of limit values for industrial wastewater discharges to
UWWTP is performed differentially based on prescriptive
provisions in regulations or permits or based on operational
agreements.
136
Energy
efficiency,
generation and
climate
neutrality
 In 10 Member States, no legislation in relation to energy
efficiency requirements is in place.
 There is legislation and/or guidance, to various extents, in place
in 8 Member States.
 There are 9 Member States with a requirement to carry out
energy audits in UWWTPs.
 In most cases, Member States have taken no action in relation to
the energy efficiency of UWWTPs (only 2 Member States have
concrete legislative measures in place).
Greenhouse gas
emissions,
including
methane
 12 Member States do not have any information available on
average emissions of greenhouse gases.
 Another 8 Member States have information available on average
emissions of greenhouse gases.
Circular
economy (sludge
reuse)
 Sewage sludge is not used in agriculture in several Member
States due to concerns related to contaminants. Alternatives such
as incineration (with or without energy recovery) are often used.
 Pre-treatment of industrial discharges is mandated in several
Member States.
 Assessment of micro-pollutants is being undertaken by several
Member States.
 Of the information that was identified, 4th
stage treatment is not
planned to be widely used in the near future by Member States.
Monitoring and
Reporting
 All Member States have adopted sampling frequencies that
comply with the requirements of the UWWTD.
 6 Member States have not set any other sampling frequencies
than those set in the Directive.
 11 Member States have set additional frequencies for sampling of
UWWTPs below 2.000 p.e.
 5 Member States have set frequencies taking into other
parameters than the size of the WWTPs (e.g., sampling per
parameters).
 The sampling process and sampling parameters vary between
Member States and are covered within Appendix B in detail.
 12 Member States have indicated that continuous monitoring is a
common practice in wastewater treatment plants (and an addition
5 Member States have continuous monitoring the largest
WWTPs) and that data from continuous monitoring is available
to water authorities.
 Member States show some diversity on the monitoring of TOC.
 All Member States (who responded to this topic) indicated that
exact measurements, including concentrations are made available
to authorities.
 In many instances, the monitoring requirements are detailed in
the permit of the UWWTPs.
Wastewater  A Europe-wide Umbrella Study was conducted to monitor the
137
surveillance presence of the SARS-CoV-2 virus (that causes COVID-19) in
the population. On 17/03/2021, the EU Commission published a
Recommendation on a common approach to establish a
systematic surveillance of SARS-CoV-2 and its variants in
wastewaters in the EU.
 The Umbrella Study involved 17 Member States.
Information to
the public
 Requirements for public consultation and participation are in
place in 5 Member States and are primarily in place in relation to
EIAs for new UWWTPs.
 Additional requirements in relation to reporting (made available
to the public) is in place in 13 Member States.
Access to
sanitation
 The specific recognition of the right to sanitation is only subject
to the national legislation of 1 Member State.
 Other countries have made attempts to different extents.
Access to justice  Of the Member States for whom information was identified, 2
Member States identified specific legal provisions for access to
justice and 2 Member States identified their transposition of the
Aarhus convention. Furthermore, several Member States
identified that no additional requirements on access to justice
beyond the UWWTD are applied.
Source: Wood report Section 3 p.21-22, see Annex 10, report 1
138
ANNEX 6: ASSESSING COMPLIANCE
To assess compliance, the following examples of organisation of the data to be gathered
can be considered:
I. Agglomerations
II. Population of each municipality/agglomeration
III. Individual and other Appropriate Systems
a. Data on exceedances
b. Type of IAS applied
c. Measures in place to ensure inspection
IV. Storm water overflows and urban runoff
a. Existence of integrated management plan
b. % of system that is combined / separate
c. Results of data monitored notably for what relates to the % of pollutants
releases compared to dry weather conditions or equivalent data
d. Information on separate sewer discharges
V. Access to sanitation
a. Identification of the vulnerable/marginalised people and measures taken to
ensure/improve access to sanitation
b. Measures taken to improve access to sanitation in the cities
VI. Treatment Plants
a. Volume of urban wastewater treated by each treatment plan and design
capacity
b. Parametric values of effluent at UWWTPs discharge point
i. Data on concentrations
ii. Data on percentage of reduction (for secondary, tertiary with stricter P
& N thresholds and fourth treatment for micro-pollutant removal)
iii. Data on toxicity (e.g. from bio-assays)78
78
As included in Commission Implementing Decision (EU) 2016/902) establishing best available
techniques (BAT) conclusions for common wastewater and waste gas treatment/ management systems in
139
iv. Other parametric values (e.g. Environmental Quality Standards
Directive parameters)
b. Energy use and reduction over time; and energy production
i. If an audit system is in place and date of last audit
ii. Baseline of last 3 years of energy use in kWh/p.e79
iii. % reduction over X years achieved.
c. Greenhouse gas emissions and reduction of emissions over time
i. Report on performance indicators (see IPCC 2006, 2019)
the chemical sector: https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32016D0902&from=EN
79
Baseline should account for the energy consumption for new treatment technologies applied to reduce
micro-pollutants in treated urban wastewater
140
ANNEX 7: ADDITIONAL DETAILED INFORMATION
Collection - Article 3 Secondary - Article 4 More stringent - Article 5
AT 0% 0% 0%
BE 0% 0% 1%
BG 5% 18% 20%
CY 15% 15% 16%
CZ 0% 0% 21%
DE 0% 0% 0%
DK 0% 0% 1%
EE 0% 0% 0%
EL 0% 4% 1%
ES 0% 9% 16%
FI 0% 1% 2%
FR 0% 6% 6%
HR 11% 67% 89%
HU 3% 12% 10%
IE 0% 50% 75%
IT 1% 12% 6%
LV 0% 0% 0%
LT 0% 0% 0%
LU 0% 0% 1%
MT 0% 98% 100%
NL 0% 0% 0%
PL 0% 1% 4%
PT 0% 6% 15%
RO 36% 66% 59%
SE 0% 1% 3%
SI 1% 26% 36%
SK 1% 1% 2%
Table A7.1: Distance to target per MS in 2018, source: Annex 10, report 7
141
BOD Nitrogen Phosphorus E. coli Micro-
pollutants
SWO 9.497.956 9.497.956 9.497.956 9.497.956 9.497.956
Urban runoff 3.021.652 4.178.561 4.655.970 11.669.055 58.345.277
Non Compliant IAS 9.761.177 8.437.746 8.437.746 10.328.361 8.860.309
Compliant IAS 653.509 4.901.318 4.356.727 1.089.182 3.428.287
Small Agglo 16.461.634 30.143.614 28.044.961 18.639.594 25.634.454
Non compliant load
from wastewater
plants
4.420.871 3.601.479 11.541.423 5.272.255 2.312.323
Remaining compliant
load treated in
wastewater plants
22.332.023 130.366.051 82.065.999 14.614.358 156.048.652
Total remaining load 66.148.823 191.126.725 148.600.784 71.110.762 264.127.257
Table A7.2: Remaining loads sent to the environment - source JRC, See annex 4
Treated load
(pe)
Treated
load (%)
Cumulati
ve load
(%)
Number
of
facilities
Number
of
facilities(
%)
Cumulati
ve
number
(%)
<1000 24.644.388 4,32% 100,00% 30.354 41,51% 100,00%
1001-2000 24.644.388 4,32% 95,68% 19.138 26,17% 58,49%
2001-10.000 56.691.407 9,94% 91,36% 16.102 22,02% 32,31%
10.001-100.000 199.793.943 35,02% 81,42% 6.610 9,04% 10,29%
100.001-1.000.000 165.897.806 29,08% 46,41% 864 1,18% 1,25%
> 1.000.000 98.865.557 17,33% 17,33% 53 0,07% 0,07%
Total 570.537.489 100% 73.121 100%
Table A7. 3: Treated load, number of treatment plants per category size (source – JRC 2021)
142
Agglomeration Treated load
(pe)
Treated
load (%)
Cumulati
ve load
(%)
Number
of
agglomera
tions
Number
of
agglomera
tions(%)
Cumulati
ve
number
tions (%)
< 1000 24.644.388 4,15% 100,00% 30.354 42,63% 100,00%
1001 - 2000 24.644.388 4,15% 95,85% 19.138 26,88% 57,37%
2001 - 10.000 63.626.959 10,72% 91,70% 13.954 19,60% 30,49%
10.001 - 100.000 202.455.997 34,10% 80,98% 6.840 9,61% 10,89%
100.001 – 1M 216.413.317 36,45% 46,88% 876 1,23% 1,28%
> 1.000.001 61.891.051 10,43% 10,43% 38 0,05% 0,05%
Total 593.676.100 100% 71.200 100%
Table A7.4: Treated load, number of agglomerations (based on MS reports for agglomerations
above 2.000 p.e. and on JRC below 2.000 – see Annex 10, report 7 and 10)
143
BOD Nitrogen Phosphorus E. Coli. Micro-
pollutants
AT 982.988 4.841.959 2.591.978 569.588 7.269.045
BE 1.335.367 3.213.281 2.219.618 1.569.320 6.932.759
BG 1.200.409 2.761.572 2.186.688 1.213.787 2.942.393
CY 132.994 378.495 286.978 165.853 699.318
CZ 645.548 3.136.876 2.199.997 533.381 3.545.495
DE 6.045.065 27.373.203 16.335.408 4.269.852 43.559.047
DK 793.354 2.876.336 1.614.096 636.738 4.920.322
EE 109.766 407.577 243.584 82.476 633.860
EL 867.769 3.293.870 4.409.166 801.879 4.897.692
ES 6.224.028 24.792.808 19.527.424 7.427.139 24.235.427
FI 370.575 1.973.909 807.885 504.821 2.289.153
FR 5.892.901 24.048.613 18.930.021 6.342.548 36.055.353
HR 2.903.371 4.912.404 4.567.034 3.674.225 5.683.355
HU 2.139.098 5.278.430 4.196.803 2.249.799 6.120.729
IE 554.087 2.611.671 2.100.435 837.615 2.402.121
IT 11.698.165 30.222.485 27.497.639 14.944.615 48.568.544
LT 556.669 1.204.833 889.115 583.722 1.626.472
LU 101.079 253.551 180.764 130.651 525.712
LV 149.437 565.518 404.267 149.434 721.932
MT 50.921 188.181 337.330 42.372 332.704
NL 1.017.682 4.350.802 2.417.517 660.753 7.470.835
PL 11.881.413 19.508.154 16.023.586 11.954.366 26.443.195
PT 1.791.299 6.381.166 5.769.058 2.638.153 7.439.871
RO 6.146.977 9.379.433 8.166.039 6.366.004 9.683.748
SE 1.300.473 3.975.096 2.060.985 1.214.548 4.870.822
SI 709.482 1.241.119 1.110.856 945.243 2.201.401
SK 547.903 1.955.381 1.526.514 601.881 2.055.954
Total 66.148.823 191.126.725 148.600.784 71.110.762 264.127.257
Table A7.5: Starting position - remaining total pollution per MS (p.e. per year)
144
BOD Nitrogen Phosphorus E. Coli Micro-pollutants
AT 982.712 4.776.459 2.587.832 546.008 7.264.004
BE 1.305.155 3.124.313 2.095.212 1.517.803 6.903.582
BG 830.195 2.718.057 2.100.757 875.145 2.787.322
CY 119.700 365.201 273.684 152.559 686.024
CZ 512.585 3.049.183 1.961.037 387.226 3.444.735
DE 6.030.528 27.313.726 15.632.341 4.246.324 43.564.031
DK 792.313 2.864.136 1.596.993 632.346 4.919.383
EE 100.572 398.545 232.128 73.444 624.827
EL 726.442 3.197.615 4.310.627 641.453 4.787.093
ES 4.463.935 23.347.879 16.544.830 5.502.645 22.850.725
FI 348.909 1.959.779 779.625 481.271 2.272.917
FR 5.860.178 23.875.125 17.034.481 6.280.093 36.042.001
HR 956.981 3.553.503 3.208.133 1.476.053 4.136.872
HU 817.798 4.190.002 3.104.480 820.218 4.966.007
IE 428.232 2.514.022 2.010.150 691.295 2.303.401
IT 9.140.615 28.943.614 24.393.328 12.102.546 47.165.347
LT 520.846 1.180.826 855.909 543.711 1.598.889
LU 98.239 242.233 166.729 124.799 523.383
LV 126.268 628.487 403.443 133.166 756.559
MT 50.921 188.181 337.330 42.372 332.704
NL 1.015.153 4.295.523 2.312.854 640.852 7.466.581
PL 11.413.974 18.760.109 13.940.937 11.403.368 26.111.479
PT 1.229.235 5.992.623 5.299.321 2.003.827 7.001.877
RO 1.911.616 4.903.262 3.275.387 1.900.529 5.625.198
SE 1.300.473 3.900.146 2.060.985 1.187.566 4.865.055
SI 584.185 1.044.244 856.609 787.973 2.090.006
SK 299.015 1.760.707 1.246.470 315.554 1.864.623
Total 51.966.775 179.087.499 128.621.614 55.510.146 252.954.625
Table A7.6: Full implementation - remaining total pollution per MS (p.e. per year)
145
PE (BOD) PE (N) PE (P) PE (coli.) PE (tox)
AT 973.984 3.224.208 1.665.054 27.261 4.528.605
BE 1.209.235 2.438.914 1.652.186 1.167.253 5.538.284
BG 661.450 1.768.241 1.184.964 382.876 1.632.070
CY 111.726 289.076 222.510 115.771 511.584
CZ 512.585 2.531.274 1.640.524 200.779 2.634.019
DE 5.928.573 19.502.774 10.887.951 1.287.057 29.611.873
DK 759.590 1.978.244 1.054.752 278.307 3.167.187
EE 97.388 266.098 150.665 22.483 364.488
EL 705.892 2.267.789 2.403.258 281.297 2.814.172
ES 4.121.344 11.910.806 5.191.524 1.070.721 12.377.161
FI 336.300 1.250.743 453.216 212.271 1.539.761
FR 5.607.007 17.070.757 11.198.073 3.528.963 26.663.693
HR 865.910 2.928.612 2.461.106 1.157.893 3.671.634
HU 800.686 2.990.945 1.959.827 369.689 3.175.191
IE 415.898 1.285.630 637.899 235.380 1.503.459
IT 8.112.554 19.592.485 14.875.127 7.663.326 35.339.851
LT 461.895 915.395 682.866 394.405 1.109.306
LU 91.646 197.602 137.537 101.350 426.589
LV 123.037 522.994 338.644 91.812 568.102
MT 48.621 106.644 150.587 10.280 156.396
NL 988.001 2.758.223 1.401.863 49.112 4.270.128
PL 9.745.509 15.090.633 11.243.121 8.786.994 19.368.415
PT 1.175.483 3.124.260 1.917.666 901.137 4.960.512
RO 1.395.384 3.591.525 2.354.828 968.387 3.345.888
SE 1.115.151 2.671.245 1.323.520 603.183 2.941.002
SI 510.509 911.032 751.431 667.741 1.856.563
SK 296.257 1.538.638 1.101.687 232.432 1.514.533
EU 27 47.171.616 122.724.787 79.042.386 30.753.638 175.590.463
Table A7.7: Preferred option - remaining total pollution per MS by 2040 (p.e. per year)
146
SWO Advanced
treatment
N removal P removal Small
agglomerations
AT 3.560.329,31 37.634.807 32.379.268 5.291.899 -
BE 16.330.626,78 21.949.684 12.952.199 2.116.851 -
BG - 14.110.021 29.355.506 6.456.473 8.219.939
CY 3.742.600,63 2.527.273 1.514.832 259.727 -
CZ - 14.178.119 11.435.666 1.869.953 -
DE 40.457.861,96 238.477.441 167.387.373 27.364.710 -
DK 6.421.552,56 33.680.164 17.792.156 2.908.121 -
EE 621.158,85 4.926.170 2.692.551 440.598 -
EL 8.850.101,31 14.622.260 20.164.361 16.206.301 -
ES 12.380.600,66 162.112.160 433.509.361 79.209.160 20.951.645
FI 1.803.587,45 13.046.187 25.749.799 1.249.958 -
FR 67.504.427,91 130.822.544 199.545.499 41.598.903 -
HR 6.074.831,94 5.292.965 27.095.418 6.384.738 3.767.257
HU 4.652.621,94 33.482.887 39.995.041 8.904.487 -
IE 1.828.429,24 8.965.060 54.094.724 11.983.135 -
IT 120.526.543,74 168.242.744 310.661.745 76.238.048 40.257.269
LT 1.434.560,68 6.565.971 4.657.565 761.559 1.615.957
LU 1.959.380,80 1.683.707 821.998 134.039 -
LV 578.808,45 2.510.885 2.216.124 362.289 -
MT 2.116.764,86 2.101.382 1.818.724 1.632.185 -
NL 14.850.045,72 64.774.361 31.792.349 5.192.741 -
PL 37.874.231,11 101.748.705 56.357.670 9.214.379 27.484.957
PT 14.097.828,85 31.301.446 124.114.881 29.627.744 -
RO - 32.114.988 20.130.685 3.291.664 31.165.876
SE 1.671.644,53 29.257.162 30.846.067 3.175.212 5.464.910
SI 2.671.321,25 1.697.477 1.868.410 322.912 1.478.466
SK 462.787,78 7.686.018 4.880.057 797.844 -
EU
27 372.472.648
1.185.512.586 1.665.830.029 342.995.630 140.406.278
Table A7.8: Detailed costs of the preferred option per Member State (€ per year by 2040)
147
Total benefits (€/year) Total costs (€/year)
AT 174.914.995 78.866.303
BE 94.494.053 53.349.360
BG 100.232.620 58.141.939
CY 10.082.786 8.044.433
CZ 56.105.349 27.483.738
DE 953.191.567 473.687.386
DK 106.556.866 60.801.994
EE 15.582.780 8.680.477
EL 260.765.336 59.843.024
ES 1.150.729.864 708.162.927
FI 166.668.941 41.849.532
FR 678.512.609 439.471.374
HR 74.757.636 48.615.210
HU 141.983.549 87.035.037
IE 137.425.378 76.871.348
IT 1.157.375.180 715.926.350
LT 31.024.455 15.035.613
LU 6.040.250 4.599.125
LV 13.156.919 5.668.106
MT 12.747.036 7.669.056
NL 197.125.498 116.609.496
PL 475.052.545 232.679.943
PT 325.829.876 199.141.900
RO 132.592.302 86.703.213
SE 129.501.116 70.414.996
SI 15.757.529 8.038.587
SK 24.638.474 13.826.707
EU 27 6.642.845.627 3.707.217.171
Table A7.9: Total costs and benefits of the preferred option per MS by 2040
148
Total cost
€/year/inhab
Total benefits
€/year/inhab
AT 5,20 19,58
BE 3,49 8,17
BG 4,16 14,49
CY 7,29 11,25
CZ 1,50 5,24
DE 3,68 11,46
DK 7,36 18,25
EE 4,50 11,72
EL 3,71 24,41
ES 5,80 24,28
FI 2,91 30,12
FR 3,56 10,06
HR 5,33 18,52
HU 4,83 14,59
IE 4,55 27,45
IT 6,84 19,53
LT 3,71 11,10
LU 5,95 9,52
LV 1,82 6,95
MT 11,34 24,70
NL 4,85 11,28
PL 4,66 12,55
PT 7,29 31,64
RO 3,47 6,91
SE 3,81 12,48
SI 2,93 7,47
SK 1,64 4,51
Table A7.10: 2040 costs and benefits of the preferred option per inhabitant
149
ANNEX 8: MAIN RELATIONS BETWEEN ONGOING INITIATIVES AND THE PRESENT INITIATIVE
Initiative Brief description of the initiative Potential interactions and added value of the preferred option
Sections in the IA were
interactions are
described
Evaluation
of the
Sewage
Sludge
Directive
This Directive regulates the use of sludge in agriculture and
includes limit values (mainly for heavy metals) when sewage
sludge is used in agriculture. The Directive is under evaluation
before deciding on its possible revision.
Measures aiming at better controlling pollution at source notably for
non-domestic pollution will contribute to improve the quality of the
sludge making it more suitable for agriculture. Actions to better capture
and treat SWOs and urban run-off are expected to allow capturing more
micro-plastics and increase their presence in sludge. Moving towards
energy neutrality will only happen if more sludge is digested (production
of biogas).
The potential
consequences on sludge
management of the
proposed measures are
identified in the IA
(sections 1, 7.1, 5.2.8
and 6.6).
Revised
Industrial
Emission
Directive
The Industrial Emission Directive (IED) regulates water and air
emissions from large industrial facilities.
Most of the large facilities are located outside the cities and are not
connected to the urban collection system. When they are connected, the
ongoing revision of the IED will contribute to better control wastewater
emissions from large industrial facilities notably for what relates to non-
domestic pollution. Reversely, actions aiming at better controlling the
incoming waters in the wastewater treatment plants will help reducing
possible emissions from IED facilities connected to the public network.
The interactions between
the IED and the
proposed revised
UWWTD are identified
in sections 1, 2.1.1.7,
5.2.6 and 7.1.
Revised
Energy
Efficiency
Directive
(EED) and
Renewable
Energy
Directive
(RED)
The proposal for a revised EED requires MS to further reduce their
energy consumption by 9% by 2030 (compared to 2020). Energy
audits are imposed for enterprises consuming large amounts of
energy. The exemplarity of the public sector is highlighted and a
specific objective is included in the EED for the public sector
(1,7% reduction per year). The proposal for a revised Renewable
Energy Directive set a binding target of 40 % for the overall share
of energy from renewable sources in the EU's gross final
consumption of energy in 2030.
Moving towards energy neutrality for the wastewater sector by 2040 will
directly contribute to reach the objectives of the RED and the EED as
combination of measures will be necessary to meet energy neutrality
(more energy efficiency, production of bio-gas and installation of
renewables). The optimal combination of measures needs to be defined
at each plant level based on in depth energy audits - which are not
required for wastewater treatment plants under the EED. Fixing a
specific energy neutrality objective for the sector will help capturing the
specific potential from this sector while promoting the development of
optimal solutions at local level.
The interactions with the
RED and EED as well as
the necessity of a
specific target of energy
neutrality for the sector
is explained in section
2.1.2.2 (problem
definition), 5.1
(baseline), 5.2.7 and 7.1
Climate
Regulation,
Effort
sharing
regulation
and 'Fit for
The Climate Regulation includes a legally binding objective of
climate neutrality for the EU by 2050. The Efforts Sharing
Regulation (ESR) request MS to reduce GHG emissions from the
sectors not covered by the EU Emission Trading Scheme -
including wastewater treatment. Binding national emission
reduction targets are included in the ESR. The 'Fit for 55'
Moving towards energy neutrality by 2040 of the wastewater sector will
directly contribute to reduce its GHG emissions (around 46,45% of the
'avoidable' emissions of the sector). It will help to achieve the objectives
of the ESR, the Climate regulation and the "Fit for 55" package (62,5%
reduction compared to 1990 levels).
The impacts of energy
neutrality on GHG
emissions are discussed
in section 5.1, 5.2.7 and
7.1
150
55' package package includes different measures ailing at reaching a reduction
of GHG emissions of 55% by 2030 (compared to the 1990 levels).
RePowerEU
The plan aims at rapidly reduce dependence on Russian fossil fuels
and fast forward the green transition
The preferred option through the energy neutrality objective will directly
contribute to the objectives of the REPowerEU plan: more biogas and
more renewables are expected to be produced while at the same time
efforts will be achieved to reduce energy use. The REPower plan will on
the other side help achieving the energy neutrality objective for the
sector notably by promoting the ‘to-go areas’ which could include
wastewater treatment plants and offering new funding opportunities for
renewables and energy savings.
The potential influence
of the REPowerEU plan
is discussed in section
5.1 (Baseline scenario))
and 7.1 (preferred
option).
Proposal for
Nature
Restoration
Regulation
(NRR)
The proposal of NRR aims at ensuring that there is an increase in
the total national area of urban green space in cities and towns and
suburbs of at least 3 % of the total area of cities and towns and
suburbs in 2021, by 2040, and at least 5 % by 2050.
The NRR will directly contribute to increase the green areas in the cities
and therefore the capacities of urban soils to absorb rain water. In case
heavy rains, less ‘clean’ rain water will be mixed to polluted waters in
the urban collecting systems and less untreated water will be sent to the
environment. The precise effects on water absorption of Nature
Restoration targets will depend on the very local circumstances, but both
legislation will act in a synergetic way. The NRR was taken into account
in the modelling (see annex 4).
The influence of the
Nature restoration
targets on the SWOs and
urban run-off
management is detailed
in sections 1, 7.1 and
6.1.
Initiative on
micro-
plastics
The Micro-plastics initiative is expected to reduce non-intentional
micro-plastics emissions from some sources such as the textile,
tyre or plastic pellets.
With the planned initiative and in the mid-term, less emissions of micro-
plastics from these sectors could expected in urban wastewaters. But
even if all possible measures are taken to reduce emissions at source,
there will always be residual emissions. Micro-plastics are well captured
in wastewater treatment plants (between 80% up to 99% when tertiary
treatment is in place). The proposed set of measures (notably measures
to better manage urban run-off and SWOs, to impose more tertiary
treatment for N/P but also to improve IAS and cover smaller
agglomerations from 1.000 p.e.) will improve the abilities of capturing
more micro-plastics in the collecting and treatment system. This will
complement the envisaged measures under the micro-plastic initiative.
The expected
interactions between the
initiative on micro-
plastics and the review
of the UWWTD are
discussed in sections 1,
2.1.1.6, and 7.1.
151
ANNEX 9: ACTORS INVOLVED IN AN EPR SCHEME AND THEIR RESPECTIVE ROLES
The roles and responsibilities of the main actors involved in the possible EPR scheme is
displayed in Figure 9.1 below and summarised in the following Table (main source:
report 2 in Annex 10).
Figure 9.1: Roles, responsibilities and relationship between the different actors
involved in the EPR scheme (source: report 2, Annex 10).
Main actors Main role and responsibilities of the actors
European Union  The EU in its Directive will define minimum objectives, the
scope and common principles for the EPR scheme to be
complied by Member States, in line with the generic
principles of an EPR defined in the Waste Framework
Directive (including modulation on fees, full cost coverage,
transparency).
Member States  Member States would be responsible mainly for overseeing
the detailed and proper implementation of EPR
(transposition compliance)
 More specifically, MS should ensure that:
 a reporting system is in place to collect data on products
placed on the market and on wastewater treatment;
 PROs have the financial and organisational means to
meet the EPR obligations (procedure to recognise the
PRO’s) and proper self-control mechanisms (regular
152
independent audits for financial management and quality
of data collected and reported);
 Fee modulation is applied by the PRO’s;
 MS will also put in place a control system to ensure that all
importers/producers are fulfilling their obligations by being
member of a PRO’s.
Producers/Importers  They will have to adhere (have a contract) with PRO’s,
declare what they are placing on the EU market and pay
fees to PRO’s depending on the quantities and toxicity of
the products they place on the market.
 They will take decisions on cost allocation (either product
cost increase or reduce profit margins) and on product
composition (less toxic if possible).
Producer
Responsibility
Organisations
(PRO’s)
 PRO’s will implement the financial responsibility for the
treatment of micro-pollutants for their members;
 PRO’s will collect statistics on products placed on the EU
market by their members, and collect their financial
contributions according to fees to be established by the
PRO’s;
 The funds collected will be used to finance additional
treatment (4th
treatment) via contracts to be established with
wastewater operators while respecting the deadlines and the
objectives fixed in the Directive.
Wastewater
operators
 They will have to progressively install additional treatment
for micro-pollutants in line with the deadlines included in
the Directive and with the financial support of the PRO’s
(contract to be established).
 They will report on the performances met to PRO’s and
competent authorities.
Auditing Companies  External control by independent auditing companies will
concern the quality of the reported statistics on products
placed on the EU market and on financial streams;
 Results of the audits should be made available to MS
competent authorities.
Table A9: Summary of the roles and responsibilities of the main actors involved in the
possible EPR scheme.
153
ANNEX 10: LITERATURE REFERENCES
Main reports used for this impact assessment:
1. WOOD (2021) Study to support the Impact Assessment of the UWWTD
2. Bio Innovation Service (2021) Feasibility of an EPR system for micro-pollutants
3. EC/Eunomia, (2018) Investigating options for reducing releases in the aquatic
environment of micro-plastics emitted by (but not Intentionally added in) products:
Final report
4. OECD (2021) Building a methodology to assess the benefits of a revision of urban
wastewater regulation in the European Union
5. OECD (2020) Financing Water Supply, Sanitation and Flood Protection: Challenges
in EU Member States and Policy Options | en | OECD
6. OECD (forthcoming 2022) Transparency and the performance of wastewater
collection and treatment services
7. European Commission (2020) 10th implementation report of the UWWTD, 10th
technical assessment on the Urban Wastewater Treatment Directive (UWWTD)
implementation 2016 European review and national situation - Publications Office of
the EU (europa.eu)
8. Obermaier, N., Pistocchi, A., (2022) Plastics in European Wastewater Treatment
Plants. Frontiers in Environmental Science, Sec. Water and Wastewater
Management, https://doi.org/10.3389/fenvs.2022.91232
9. Parravicini, V., Nielsen, P. H., Thornberg, D., Pistocchi, A., (2022) Evaluation of
greenhouse gas emissions from the European urban wastewater sector, and options
for their reduction, Science of The Total Environment, Volume 838, Part 4, 156322,
ISSN 0048-9697, https://doi.org/10.1016/j.scitotenv.2022.156322.
10. Pistocchi, A., Parravicini, V., Langergraber, G. et al. How Many Small
Agglomerations Do Exist in the European Union, and How Should We Treat Their
Wastewater?. Water Air Soil Pollution, 233, 431. https://doi.org/10.1007/s11270-
022-05880-7.
11. Manaia, C.M. (2022) Framework for establishing regulatory guidelines to control
antibiotic resistance in treated effluents, Critical Reviews in Environmental Science
and Technology, https://doi.org/10.1080/10643389.2022.2085956
12. Pistocchi, A., Cinnirella, S., Mouratidis, P., Rosenstock, N., Whalley, C., Sponar,
M., Pirrone, N. (2022) Screening of mercury pollution sources to European inland
waters using high resolution earth surface data. Frontiers of Environmental Science.
https://www.frontiersin.org/articles/10.3389/fenvs.2022.1021777/abstract
13. Pistocchi, A., Alygizakis, N. A., Brack, W., Boxall, A., Cousins, I. T., Drewes, J.
E., Finckh, S., Gallé, T., Launay, M. A., McLachlan, M.S., Petrovic, M., Schulze,
T., Slobodnik, J., Ternes, T., Van Wezel, A., Verlicchi, P., Whalley, C., European
scale assessment of the potential of ozonation and activated carbon treatment to
reduce micropollutant emissions with wastewater, Science of The Total
Environment, Volume 848, 157124, ISSN 0048-9697,
https://doi.org/10.1016/j.scitotenv.2022.157124.
14. A. Pistocchi, H.R. Andersen, G. Bertanza, A. Brander, J.M. Choubert, M.
Cimbritz, J.E. Drewes, C. Koehler, J. Krampe, M. Launay, P.H. Nielsen, N.
Obermaier, S. Stanev, D. Thornberg, Treatment of micropollutants in wastewater:
154
Balancing effectiveness, costs and implications, Science of The Total Environment,
Volume 850, 2022, 157593, ISSN 0048-9697,
https://doi.org/10.1016/j.scitotenv.2022.157593.
15. Pistocchi, A., Grizzetti, B., Nielsen, P.H., Parravicini, V., Steinmetz, H.,
Thornberg, D., , Vigiak, O., An assessment of options to improve the removal of
excess nutrients from European wastewater. Submitted, 2022
16. Psomas, A. (2021) Support studies on specific aspects of wastewater management:
Individual or other Appropriate Systems (IAS). Brilliants Solutions Engineering &
Consulting (BRiS).
17. Quaranta, E., Fuchs, S., Liefting, H.J., Schellart, A., Pistocchi, A., (2022) A
hydrological model to estimate pollution from combined sewer overflows at the
regional scale, Application to Europe, Journal of Hydrology: Regional Studies,
Volume 41, 101080, ISSN 2214-5818, https://doi.org/10.1016/j.ejrh.2022.101080.
18. Quaranta, E., Fuchs, S., Liefting, H.J., Schellart, A., Pistocchi, A., (2022) Costs
and benefits of combined sewer overflow management strategies at the European
scale, Journal of Environmental Management, Volume 318, 115629, ISSN 0301-
4797, https://doi.org/10.1016/j.jenvman.2022.115629.
19. Energy and GHG in Denmark, the Netherlands and Scotland
 DANVA (2020) Positiv aftale om en energi- klimaneutral vandsektor (danva.dk)
 The overall strategy is included in the ‘Klimahandleplanen for vandsektoren’,
which is part of the ‘Klimaplan for en gron affaldssektor og cirkulaer okonomi’
 Unie van Waterschappen (n.d.) Renewable energy | Union of Water Boards
(uvw.nl)
 Energie en Grondstoffen Fabriek (n.d.) English | Energie en Grondstoffen Fabriek
(efgf.nl)
 Scottish Waters, Net Zero Emissions Roadmap – Transformation Transformation
- Net Zero (scottishwaternetzero.co.uk)
 Scottish Waters, Net Zero Emissions Roadmap – Reducing Emissions Reducing
Emissions - Net Zero (scottishwaternetzero.co.uk)
 Veolia (2022) Transforming drinking and wastewater management in Sofia
Transforming drinking and wastewater management in Sofia | Veolia
20. Research projects having supported the impact assessment
a. Horizon 2020 – POWERSTEP POWERSTEP project to verify two of its
key technologies | Eco-innovation Action Plan (europa.eu)
b. Horizon 2020 – TRUST Transitions to the Urban Water Services of
Tomorrow | TRUST Project | Fact Sheet | FP7 | CORDIS | European
Commission (europa.eu)
c. Horizon 2020 – ENERCOM Treating sewage sludge intelligently | Horizon
2020 (europa.eu)
21. Van der Werf JA., Kapelan Z., Langeveld J. (2022) Towards the long term
implementation of real time control of combined sewer systems: a review of performance
and influencing factors, Water and Science&Technology
155
22. Johnson D., S. Geisendorf S., (2022) Valuing ecosystem services of sustainable urban
drainage: A discrete choice experiment to elicit preferences and willingness to pay ,
Journal of Environmental Management Volume 307, 1 April 2022
Aus der Beek, T. et al. (2015). Pharmaceuticals in the environment – Global occurrences and
perspectives. Critical Review in Environmental Toxicology and Chemistry.
Barco et al. (2008). First flush in a combined sewer system. Chemosphere 71, 827-823, p. 827.
Barrat, L. & People, C. (2019). Ex-Post Study on LIFE and the Urban Wastewater Treatment Directive
(91/271/EEC), p. 49.
BIO Intelligence service (2013). Study on the environmental risks of medicinal products. Final report:
Bloomer, E. and McKee, M. (2018) Policy options for reducing antibiotics and antibiotic-resistant genes
in the environment.
Bouraoui, F et al. (2014). Scenario analysis for nutrient emission reduction in the European inland waters.
Britannica (n.d.a). Biological oxygen demand.
Britannica (n.d.b). Combined sewers.
Britannica (n.d.c). Wastewater treatment.
Case C-100/13 European Commission v Germany.
Case C-236/99 Commission of the European Communities v Kingdom of Belgium.
Case C-252/05 The Queen on the application of Thames Water Utilities Ltd v South East London
Division, Bromley Magistrates' Court.
Case C-280/02 Commission of the European Communities v French Republic.
Case C-310/10 European Commission v UK
Case C-398/14 European Commission v Portuguese Republic.
Case C-427/17 European Commission v Ireland
COWI et al. (2019). Integration of environmental concerns in Cohesion Policy Funds (ERDF, ESF, CF) –
results, evolution and trends through three programming periods (2000-2006, 207-2013, 2014-2020). Final
report.
Eawag, Faure, F, & Spuhler, D. (2019). Conventional Sewers (Combined sewers). Sustainable Sanitation
and Water Management Toolbox.
ECHA (2019) Annex XV Restriction report. Proposal for a restriction.
EEA (2015), Bathing water quality.
EEA (2016). European water policies and human health. Combining reported environmental information.
Report No 32/2016.
EEA (2017). Climate change, impacts and vulnerability in Europe 2016. An indicator-based report. No.
1/2017.
EEA (2018a). Water use and environmental pressures.
EEA (2018b) European Waters – assessment of status and pressure 2018.
EEA (2018c). European Bathing Water Quality 2017. No 2/2018.
EEA (2018d). Industrial wastewater treatment –pressures on Europe’s environment. EEA Report No
23/2018.
EEA (2018e). Mercury in Europe’s Environment.
EEA (2018f). Chemicals in European water – knowledge developments. EEA report No 18/2018.
EEA (2019a). Oxygen consuming substances in European rivers. (Voluntary reporting from EEA’s 33
member countries).
EEA (2019b). Meeting note on anti-microbialresistance and urban wastewater treatment.
EEA (n.d.a) Wastewater database, based on Member State reported data of the year 2014.
EEA (n.d.b) Water and marine environment Articles.
EEA (n.d.c) Water and marine environment data and maps
EEA (n.d.d). UWWTD website.
ETC/ICM (2016) European assessment of eutrophication abatement measures across land-based sources,
inland, coastal and marine waters. Technical report 2.
ETC-ICM (2017). Emissions of pollutants to Europe’s waters – sources, pathways and trends.
Eunomia (2018). Investigating options for reducing releases in the aquatic environment of microplastics
emitted by (but not intentionally added in) products.
EurEau (2017) Water matters. p.78.
EurEau (2018). The governance of water services in Europe.
156
EurEau (2018). Water and the EU’s Circular Economy. Briefing note.
European Commission (2001). Extensive wastewater treatment processes adapted to small and medium
sized communities.
European Commission (2009). Guidance document No. 20. Common implementation Strategy for the
Water Framework Directive (2000/60/EC). Guidance document on exemptions to the environmental
objectives.
European Commission (2009). Guidance Document No. 23. Common Implementation Strategy under
WFD Guidance document on eutrophication assessment in the context of European Water Policies.
European Commission (2012a) Guidance Document No.28. Common Implementation Strategy for the
Water Framework Directive (2000/60/EC). Technical Guidance on the preparation of an Inventory of
Emissions, Discharges and Losses of Priority and Priority Hazardous Substances.
European Commission (2012b). Communication from the Commission to the European Parliament, the
Council, the European Economic and Social Committee and the Committee of the Regions. A Blueprint to
Safeguard Europe’s Water Resources. COM/2012/0673 final.
European Commission (2012c). A Water Blueprint – taking stock, moving forward.
European Commission (2015). Communication from the Commission to the European Parliament, the
Council, the European Economic and Social Committee and the Committee of the Regions. Consultative
Communication on the Sustainable Use of Phosphorus (COM/2013/0517 final).
European Commission (2016) Synthesis Report on the Quality of Drinking Water in the Union examining
Member States' reports for the 2011-2013 period, foreseen under Article 13(5) of Directive 98/83/EC.
European Commission (2016b). Sewage sludge.
European Commission (2016c). WFD Reporting Guidance.
European Commission (2017). Roadmap for Evaluation of the Urban Wastewater Treatment Directive
91/271/EEC (UWWTD).
European Commission (2017b) Fitness Check of Reporting and Monitoring of EU Environment Policy.
SWD(2017) 230
European Commission (2017c). AMR Action Plan.
European Commission (2017d) 9th
implementation report.
European Commission (2017e) Special Eurobarometer 468/2017: Attitudes of European citizens towards
the environment.
European Commission (2018a). Communication from the Commission to the European Parliament, the
Council, the European Economic and Social Committee and the Committee of the Regions. A European
Strategy for Plastics in a Circular Economy. COM/2018/028 final.
European Commission (2018b) Consultation strategy.
European Commission (2018c). Proposal for review of the drinking water Directive.
European Commission (2018d) Mercury
European Commission (2018e). Water reuse.
European Commission (2018f).Impact Assessment - accompanying document – proposal for a Regulation
of the European Parliament and of the Council on minimum requirements for water reuse.
European Commission (2018g). Urban Water Atlas.
European Commission (2019). Blue2 study: Assistance for better policy-making on freshwater and
marine environment.
European Commission (2019a). Communication from the Commission to the European Parliament, the
Council and the European Economic and Social Committee. European Union Strategic Approach to
Pharmaceuticals in the Environment.
European Commission (2019b). Report from the Commission to the European Parliament, the Council,
the European Economic and Social Committee and the Committee of the Regions on the Evaluation of the
7th Environment Action Programme (COM(2019)233 final)
European Commission (2019c). Report from the Commission to the European Parliament and the Council
on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive
(2007/60/EC). Second River Basin Management Plans and First Flood Risk Management Plans.
COM(2019)95 final.
European Commission (2019d). EU Action on Antimicrobial Resistance.
European Commission (2019d). LIFE programme Wastewater treatment.
European Commission (2019e). Proposal for a regulation on minimum requirements for water reuse.
European Commission (2019f). Priority substances under the Water Framework Directive.
European Commission (2019g). Fitness Check on the Water Framework Directive, its daughters and the
floods Directive. Open public consultation.
European Commission (2019h). Water reuse: Commission welcomes the provisional agreement on
minimum requirements for water reuse in agriculture.
European Commission (n.d.) JASPERS: Joint Assistance to Support Projects in European Regions.
157
European Commission (n.d.). Energy strategy and energy union.
European Commission (n.d.). Peer Learning for environmental authorities.
European Commission (n.d.). Structural Reform Support Service.
European Commission (n.d.). TAEIX-REGIO Peer 2 Peer.
European Court of Auditors (2015). EU-funding of urban wastewater treatment plants in the Danube
river basin: further efforts needed in helping Member States to achieve EU wastewater policy objectives.
Special report 02.
European Court of Auditors (2015). Water quality in the Danube river basin: progress in implementing
the water framework Directive but still some way to go.
European Court of Auditors (2016). Combating eutrophication in the Baltic Sea: further and more
effective action needed. Special report 03.
Fuchs, S., Scherer, U., Wander, R., Behrendt, H., Venohr, M., Opitz, D., Hillenbrand, Th.,
Marscheider-Weidemann, F., Götz, Th. (2010). Calculation of Emissions into Rivers in Germany using
the MONERIS Model. Nutrients, heavy metals and polycyclic aromatic hydrocarbons. UBATexte 46/2010,
Dessau
Ganora et al (2019). Opportunities to improve energy use in urban wastewater treatment: a European-
scale analysis. Environmental Research letters 14 044028.
Global water intel (2016). The top 50 water businesses.
Grizzetti et al. (2017). Human pressures and ecological status of European rivers. Scientific reports
Nature.
Groundwater Directive (GWD): Directive 2006/118/EC of the European Parliament and of the Council of
12 December 2006 on the protection of groundwater against pollution and deterioration, OJ L 372,
27/12/2006.
Gupta, K. & Saul, A.J. (1996). Specific relationships for the first flush load in combined sewer flows.
Water research, volume 30, Issue 5, pp. 1244-1252.
Haigh, N. (2016). EU Environmental Policy: Its Journey to Centre Stage. Earthscan, London
Hudcova, H et al (2019). Present restrictions of sewage sludge application in agriculture within the
European Union. Soil and Water Research, 14, p. 104-120.
ICF et al. (2017). Support to the Fitness Check of monitoring and reporting obligations arising from EU
environmental legislation.
IEEP, Ecologic Berlin, Central European University (2019). Development of an assessment framework
on environmental governance in the EU Member States.
Internationale Kommission zum Schutz des Rheins (2019). IKSR-Empfehlungen zur Reduktion von
Mikroverunreinigungen in Gewässern.
Johnson, A. C. et al. (2017). An alternative approach to risk rank chemicals on the threat they pose tot he
aquatic environment. Science of The Total Environment. Vol. 599-600, p.1372-1381. An alternative
approach to risk rank chemicals on the threat they pose to the aquatic environment - ScienceDirect
Kay, D. (2018). Presentation on health benefits of UWWTD. Stakeholder conference on the Evaluation of
the UWWTD. Available here: Evaluation Study 2018.
Kompetenzzentrum (n.d.) General information.
Navrud, S (2016). Possibilities and challenges in transfer and generalization of monetary estimates for
environmental and health benefits of regulating chemicals, OECD Workshop on socioeconomic impact
assessment of chemicals management, ECHA, Helsinki July 6-8
Niva (2018). Microplastics in agricultural soils: A reason to worry?
OECD (2018) Contaminants of emerging concern.
OECD (2009) Managing water for all: An OECD perspective on pricing and financing.
OECD (2019) Pharmaceutical residues in freshwater – hazards and policy responses.
Phillips et al. (2018), The value of bathing waters and the influence of bathing water quality: Final
Research Report
Ricardo, (2019a). EEA activity 1.5.2 Urban wastewater treatment – approaches, challenges and
opportunities.
Ricardo, (2019b). EEA activity 1.5.2 Urban Wastewater – non-connected dwellings.
Right to water (2019). Water and sanitation are a human right, reference to OPC WFD FC
Sawyer, C., McCarty, P., & Parkin, G. (2003). Chemistry for Environmental Engineering and Science
(5th ed.). New York: McGraw-Hill.
Schmitt H, Blaak H, Kemper M, van Passel MW, Hierink F, van Leuken J, de Roda Husman AM,
van der Grinten E, Rutgers M, Schijven J, de Man H, Hoeksma P, Zuidema T (2017). Sources of
antibiotic resistance in the environment and intervention measures.
Spit et al. (2018). The Economic Value of Water - Water as a Key Resource for Economic Growth in the
EU. Deliverable to Task A2 of the BLUE2 project “Study on EU integrated policy assessment for the
158
freshwater and marine environment, on the economic benefits of EU water policy and on the costs of its
non- implementation”.
Stauffer, B & Spuhler, D. (2019). Separate sewers. Sustainable Sanitation and Water Management
Toolbox.
Surfrider (2018). Biomedia pollution.
Sutton et al. (2011). The European Nitrogen Assessment, Chapter 22
Swedish Environmental Protection Agency (2017). Advanced wastewater treatment for separation and
removal of pharmaceutical residues and other hazardous substances -Needs, technologies and impacts.
UKWIR (2014), Chemical investigations programme: Volume 1 – Main report. Report Ref. No.
13/EQ/01/6.
UKWIR (2018a), The national chemical investigations programme 2015-2020. Volume 2 monitoring of
substances of emerging concern. Report Ref. No. 18/EQ/01/13.
UKWIR (2018b), The national chemical investigations programme 2015-2020, Volume 1 part 1 (2015-
2017) Monitoring of sewage effluents, surface waters and sewage sludge: Annex A CIP2 Sludge
Investigations. Report Ref. No. 18/EQ/01/12.
UKWIR (2018b), The national chemical investigations programme 2015-2020, Volume 1 part 1 (2015-
2017) Monitoring of sewage effluents, surface waters and sewage sludge: Annex A CIP2 Sludge
Investigations. Report Ref. No. 18/EQ/01/12.
Umweltbundesamt (2015). Organische Mikroverunreinigungen in Gewässern. Vierte Reinigungsstufe für
weniger Einträge. p.8.
Umweltbundesamt (2015). Organische Mikroverunreinigungen in Gewässern. Vierte Reinigungsstufe für
weniger Einträge. p.8.
Umweltbundesamt (2015). Organische Mikroverunreinigungen in Gewässern. Vierte Reinigungsstufe für
weniger Einträge. p.8.
Umweltbundesamt (2017). Wastewater management in the Danube region. Challenges and opportunities
of EU accession.
Umweltbundesamt et al. (2017). Support to the implementation of the UWWTD – COD substitution
scoping study.
UNESCO (2019). Emerging pollutants in water and wastewater.
United Nations (n.d.a) Sustainable Development Goals. Goal 6: Ensure access to water and sanitation for
all.
United Nations (n.d.b). Clean Water and Sanitation: Why it matters.
UWWTD-rep group, (2007). 2007 guidance document.
Vergine, P., Salerno, C., Barca, C., Berardi, G. & Pollice, A. (2017) Identification of faecal indicator
Escherichia coli in wastewater through the β-D-glucuronidase activity: comparison between two
enumeration methods, membrane filtration with TBX agar, and Colilert®
-18. Journal of Water & Health,
15(2):209-217.
Vigiak, O., Grizzetti, B., Zanni, M., Dorati, C., Bouraoui, F., Aloe, A., Pistocchi A., Estimation of
domestic and industrial waste emissions to European waters in the 2010s, EUR 29451 EN, Publications
Office of the European Union, Luxembourg, 2018, ISBN 978-92-79-97297-3 , doi:10.2760/08152,
JRC113729.
VSA-Plattform (n.d.) Verfahrenstechnik Mikroverunreinigungen
Water Framework Directive (WFD): Directive 2000/60/EC of the European Parliament and of the
Council of 23 October 2000 establishing a framework for Community action in the field of water policy
(OJ L 327, 22.12.2000, p. 1).
Water UK (2017). Wipes in Sewer Blockage Study. Final Report.
WHO (2017). Drinking Water Parameter Cooperation Project. Support to the revision of Annex I Council
Directive 98/83/EC on the Quality of Water Intended for Human Consumption (Drinking Water Directive).
Recommendations.
WHO (2018a). Guidelines on sanitation and health.
WHO (2018b). WHO water, sanitation and hygiene strategy 2018-2025, p.5.
WHO (2019). A global health guardian: climate change, air pollution, and antimicrobial resistance.
WHO (2022) Antimicrobial resistance (who.int)
Wilkinson et al. (2022) Pharmaceutical pollution of the world’s rivers. PNAS Proceedings of the National
Academy of Science of the United States of America. Vol 119, No 8. Pharmaceutical pollution of the
world’s rivers | PNAS
Wood et al., (2019). Digestate and compost as fertilisers: Risk assessment and risk management options.
Wood, IEEP, COWI, Cenia, and HR Wallingford (2019). Evaluative study on the Urban Wastewater
Treatment Directive.
Woodard & Curran (2006). Industrial Waste Treatment Handbook.
159